Sport Aviation Specialties, LLC
Lawrenceville, GA 30044
Copyright © 2005 - 2015
G. Michael Huffman
of ASTM F37 Light-Sport Aircraft Committee
of Light Aircraft
FAA regulations, orders, policies, ASTM publications, and other documents are
subject to change and interpretation. Any information on this site that pertains
to those documents is for reference only. It is the responsibility of visitors
to verify all such information with the FAA or ASTM.
optimized for 800 x 600 display
you building an Experimental Amateur-Built (E-AB) aircraft and want
to get it certificated?
you own a Special Light Sport Aircraft (S-LSA) and want to change
its certification to Experimental Light-Sport so you can make modifications
and perform your own annual condition inspections?
you building an aircraft from an SLSA manufacturer's kit and want
to get it certicated?
you an S-LSA manufacturer and need production flight-test permits
and airworthiness certification
for your production aircraft?
Are you engaged in an FAA design approval program (TC, STC, PMA,
or TSO) and need FAA conformity inspections for your prototypes
parts and assemblies?
here for an explanation of the
differences between these certificate types.)
you will likely need the services of a Designated Airworthiness
Representative (DAR). To learn more about our DAR services, click
the links below. Or, simply scroll down the page.
is a DAR?
A DAR is a private citizen who has extensive experience in aviation,
has received special training from FAA, and has been delegated the
authority to perform certain FAA functions.
Aviation Safety Inspectors (ASIs--who are FAA employees) can and
sometimes do perform the functions of a DAR. However, in practice,
due to FAA budget constraints and increasing workloads, most such
tasks are performed by DARs.
Michael Huffman, owner of Sport Aviation Specialties, is a DAR authorized
to perform the following functions:
airworthiness certificates for Experimental Amateur-Built (EAB)
airworthiness certificates for Experimental Light-Sport aircraft
airworthiness certificates and production flight-test permits
for Special Light-Sport Aircraft (SLSA). If
you have need of these services, please contact us by phone or
FAA conformity inspections for prototype parts used in FAA design
approval programs, including type certification (TC), suppllemental
type certification (STC), parts manufacturer approval (PMA), and
technical standard order (TSO). If you
have need of these services, please contact us by phone or email.
you have an aircraft to be certified, call or email us as early
as possible. We can guide you through the process. Or, if you have
other questions, we would be happy to try and answer them.
EAB & ELSA Certification Process (Back)
The certification process for experimental light-sport aircraft
and experimental amateur-built aircraft are very similar. This section
describes the process and points out differences between the two.
The basic steps for certificating an E-AB or E-LSA are very similar,
as described below. Differences are explained in the subsequent
sections. Click any of the links below for details, or simply
scroll down the page.
Your first task is to determine which certification category your
aircraft is eligible for.
be eligible for experimental amateur-built certification:
be eligible for experimental light-sport certification:
aircraft must meet the light-sport aircraft specifications regarding
weight, speed, and configuration.
aircraft must be either a fixed-wing airplane, a weight-shift
aircraft, a powered parachute, a gyroplane, a glider, or a lighter-than-air
vehicle. Helicopters are not eligible.
aircraft must fall into one of the following classifications.
"ultralight-like vehicles" Note
that the final January 31, 2010 deadline for certificating
aircraft under this classification has past--no other aircraft
will be certificated under this provision.
built from a kit produced by an S-LSA manufacturer and assembled
in accordance with the manufacturer's instructions. Note
that the 51% rule does not apply to such kits. If
your aircraft falls into this classification, please phone
or email us for instructions.
previously issued an airworthiness certificate as an S-LSA,
for which the owner desires to change the certification
to E-LSA, either to allow modifications and/or annual condition
inspections by the owner who has obtained a Light-Sport
Repairman- Inspection (LSRI) certificate or because the
SLSA manufacturer has gone out of business. If
your aircraft falls into this classification, please phone
or email us for instructions.
you start the registration process, we recommended you contact
us. We can guide you through the process, let you know where to
obtain forms, and help you avoid pitfalls and unpleasant surprises.
It is in everyone's best interest for the certification process
to go smoothly.
also highly recommend you purchase EAA's E-AB Conversion Kit.
It contains all the necessary forms, placards, dataplate, and
a 15-page E-AB Conversion Guide, which takes you through
the process step-by-step. To order the guide, visit www.sportpilot.org
E-AB conversion guide provides detailed instructions for registering
your aircraft with the FAA and obtaining an N-number. In summary:
first need to decide whether you want to choose your own N-number
or accept one automatically assigned by FAA.
If you want to have a special N-number, you will need to reserve
it, which can be done online here.
You can check with FAA Aircraft Registry to see what N-numbers
are available here.
Alternatively, you can submit a request letter to FAA Aircraft
Registration Branch, AFS-750, PO Box 25504, Oklahoma City, OK
73125, but this process takes more time. List five different
N-number choices in your letter and include a check for $10
payable to the U.S. Treasury.
receiving your special N-number reservation, or if you have
decided to accept the one assigned by FAA, the next step is
to to fill out and submit the following forms. You'll need to
include a check for $5.00 payable to FAA Aircraft Registry.
Form 8050-1, Aircraft Registration Application
Form 8050-88, Affidavit of Ownership- for E-AB
is a caution concerning filling out the registration application
The manufacturer, model, serial number, N-number, and owner's
name listed on your registration certificate are the "master"
data by which FAA knows your aircraft. All your other forms must
agree with the registration data. Unfortunately, inconsistencies
in FAA forms can result in confusion; for instance, the registration
application form refers to "aircraft manufacturer,"
while the application for airworthiness form refers to "builder's
name," both of which mean exactly the same.
an E-AB, you should generally use your own name as the manufacturer/builder.
If you built the aircraft from a kit, the model designation and
serial number can be that assigned by the kit manufacturer. If
you significantly modified the aircraft from the kit configuration,
you may want to modify the model number, i.e., "Jones RV-7A"
it short--remember, what you list here will have to appear on
all other forms and on your fireproof dataplate. There may not
be room for long names on your dataplate or forms. As an example,
where more than one person owns the aircraft, list only one as
the manufacturer or builder. The other names should be listed
as owners, but not as the manufacturer or builder.
model numbers short for the same
reason; for instance, rather than listing the model as "RANS
S-7S Courier," just list "S-7S."
FAR Part 45 has very specific requirements for N-numbers. For
instance, it says they should be painted on or "affixed by
any other means insuring a similar degree of permanence."
Vinyl tape letters available from aviation supply companies meet
this requirement if there is a reasonable expectation that removing
them would damage the paint; however, typical office supply or
hardware store letters do not.
also says N-numbers must be legible, must contrast with the background,
and must have no ornamentation. Obviously, many N-numbers seen
on aircraft in use do not meet these requirements, but you will
need to do so to get your aircraft certificated.
are specifications on the letter height, letter width, stroke
width, spacing of the letters, and the placement of the N-number
on the aircraft. All E-LSAs and any E-ABs that do not exceed 180
knots cruising speed are allowed to use 3" numbers; otherwise,
12" numbers are required. Also, 12" numbers are required
on any aircraft penetrating an Air Defense Identification Zone
(ADIZ) or Distant Early Warning Identification Zone (DEWIZ).
also that the rules are a little different for powered parachutes
and weight-shift aircraft. There, N-numbers must be 3" high
displayed horizontally on diametrically-opposed locations on each
side of the fuselage or component of the fuselage. Some PPCs and
weight-shift aircraft do not have a location large enough to accommodate
3" N-numbers; in those cases, it is allowable to mount a
plate on the structure using clamps or other means, onto which
to apply the 3" numbers. Numbers smaller than 3" or
numbers on easily removable items such as saddlebags are not allowed.
you are in doubt about N-numbers, contact us.
an "Experimental" Placard
FAR 45.23 requires a placard with the word "Experimental"
in letters at least 2" high to be applied "near each
entrance to the cabin, cockpit, or pilot station."
a Passenger Warning Placard
The operating limitations document that will be issued by the
DAR for your E-AB or E-LSA requires that you advise each passenger
of the experimental nature of the aircraft and that it does not
meet the certification requirements of a standard certificated
aircraft. This is accomplished by applying a placard in view of
passengers with the following wording.
WARNING - THIS AIRCRAFT IS AN EXPERIMENTAL LIGHT SPORT [or AMATEUR-BUILT]
AIRCRAFT AND DOES NOT COMPLY WITH FEDERAL SAFETY REGULATIONS FOR
There is no minimum set of instruments or equipment required to
certificate either an E-AB or an E-LSA. (However, you should note
that if you plan to equip the aircraft for night or IFR flight,
a specific complement of instruments and equipment is required--see
FAR 91.205 for a list) In any case, if such instruments/equipment
are installed, they must be marked. Each flight, engine, and other
instrument must have markings on its face indicating the acceptable
operating range, as defined below.
airspeed indicator must have the following markings (determined
from the kit manufacturers data where applicable).
green arc, the bottom of which is the anticipated power-off,
no-flaps stall speed and the top of which is the maximum
anticipated cruise speed
red line, which is located at the never-exceed speed of
equipped with flaps, a white arc, the bottom of which is
the power-off, full-flaps stall speed and the top of which
is the maximum flaps-extended speed
oil temperature gauge, oil pressure gauge, coolant temperature
gauge, tachometer, or other engine/propeller gauges must be
marked with green arcs indicating normal operating ranges and/or
red lines indicating maximum values as determined from the engine
is recommended that the
compass have a compass correction card, which is created by
pointing the aircraft on known headings on the ground and recording
the compass reading. This is done using a "compass rose"
painted on an airport ramp. If your airport does not have a
compass rose, you may wait until after the aircraft is certificated,
fly to an airport that does, and create the compass correction
of the new electronic flight and engine instruments have built-in
programmable alarms that will produce audible or visual annunciation
if they are exceeded. If properly programmed to the aircraft/engine/propeller
specifications, these alarms are considered adequate in place
of colored arcs or textual placards on conventional instruments.
Placards on All Controls, Switches
Each control, indicator, switch, circuit breaker, fuse, etc. is
required to be labeled to identify its function and direction
of operation (e.g., "Landing Light- On- Off"). Where
applicable, word the labels to correspond with the position of
the control to be used in an emergency (e.g., "Throttle-
Push On," "Carburetor Heat- Push Cold").
and flap controls and indicators should be marked showing the
limits of operation, the direction of operation, and the correct
position for normal takeoffs and landings.
a Fireproof Dataplate
"Fireproof" in this case means having an ability to
resist fire equivalent to steel. The EAA supplies a stainless
steel dataplate with blanks for manufacturer/builder, model, and
serial number. Note that earlier EAA dataplates that contain blanks
for other information such as year built, builder's name and address,
etc are acceptable, but the extra information is not required
45.11 requires that the dataplate information be marked by "etching,
stamping, engraving, or other approved method of fireproof marking."
It also specifies location and mounting provisions; in general,
dataplates should be permanently mounted (with screws or rivets--not,
for instance, pressure-sensitive adhesives) and located as far
aft as possible on the primary structure of the aircraft (not
on a removable access cover, fairing, etc.)
you are in doubt of how or where to mount your datatplate, contact
Unless you own a single-place aircraft, a weight shift aircraft,
or a powered parachute, you will be required to have an emergency
locator transmitter (ELT).
ELT meeting the requirements of TSO-C91a is acceptable; older
TSO-C91 ELTs are not allowed for new installations after June
21, 1995. The difference is that the newer ELTs have an external
antenna to be mounted on the outside of the aircraft and a small
remote panel to be mounted on the aircraft instrument panel; the
remote panel has an indicator light that shows when the ELT has
been activated and a switch to reset the unit.
the manufacturer's instructions in mounting the ELT. It should
be mounted as far aft as possible, in the correct direction to
allow activation in a crash. It is also important that the structure
to which the ELT is mounted be adequate to withstand the weight
and G-forces of the ELT without vibrating in flight or failing
in case of a crash.
might want to consider one of the new digital TSO-C126 406-mHz
ELT, some of which have the ability to broadcast not only the
emergency signal, but also the GPS coordinates of a crash and
contact information for the pilot. The 406-mHz units are currently
a good bit more expensive than the TSO C91a units ($900- $1500
type of ELT you choose may be influenced by what you want it to
do, i.e., to either simply satisfy FAA regulations for an ELT
or to provide the best chance of being found after a crash. As
of February 2009, the 121.5-MHz ELT signals are no longer monitored
by the Cospas-Sarsat orbiting satellites. However, they are still
routinely monitored by airliners and ground-based observers.
The location of a 406-mHz signal can be pinpointed much more accurately
than that of a 121.5-MHz signal.
Other Required Equipment
If your aircraft is based inside the 30-nautical-mile-radius Mode
C ring associated with the Class B airspace around several major
airports, you will most likely need a radar transponder and altitude
there is an exception that may apply to a few E-ABs and E-LSAs.
The way it is stated in FAR Part 91.215, if your aircraft was
"originally certificated without an engine-driven electrical
system" and has not been retrofitted with such a system,
a transponder is not required. This statement is interpreted by
the FAA to apply only to engines such as the Continental A-65/75
that were originally manufactured without generators or alternators
and for which fitting a generator or alternator would be difficult.
That means if your engine is a newer Continental or Lycoming,
a 2-stroke or 4-stroke Rotax, or any other engine that is easily
capable of having an alternator or generator,
the exception does not apply.
a Weight and Balance
Actually, the term "weight and balance" applies to fixed-wing
E-ABs and E-LSAs. A better term for weight-shift aircraft and
powered parachutes is "weight and loading," since center
of gravity calculations generally do not apply to those aircraft.
The reason is that the frame or carriage of such machines is suspended
from a pivoting "hang point," so the distribution of
weight between pilot, passenger, fuel, baggage, etc, often do
not affect the stability of the aircraft. However, the location
of the hang point relative to the center of lift of the wing or
the parachute may affect performance and stability. If you are
certificating a weight-shift aircraft or powered parachute, obtain
the allowable weight, weight distribution, and hang point data
from the manufacturer.
fixed-wing aircraft, we like for applicants to use our weight
and balance form; when you get us involved in your certification,
we will supply you a copy. A Microsoft Excel spreadsheet, it provides
step-by-step instructions for performing the weight and balance,
it provides a sheet to record the equipment installed in the aircraft
at the time, and it automatically performs weight and balance
calculations. The printed output from the form goes into the aircraft
need to perform calculations for most-forward CG, most-aft CG,
and the actual loading condition that will be used for your Phase
I flight tests. The FAA has established a very specific procedure
for the most-forward and most-aft CG calculations; the instructions
for our spreadsheet explain the procedure.
your aircraft is built from a kit, the kit manufacturer can supply
you with the weight, center of gravity limits, datum location,
and the location of the pilot, passenger, fuel, oil, coolant,
and baggage weights relative to the datum. On the other hand,
if your aircraft is an original design or has been modified, you
will need to make your own determination of those parameters.
Aircraft Maintenance Logbooks
the time you present your aircraft for certification, you will
need a maintenance logbook for at least the aircraft and preferably
another one for the engine, not associated with your pilot logbook.
Blank logbooks are easily obtainable from a local FBO or from
any of a number of aviation supply companies. The reason for having
separate logbooks is that engines often get removed from one airframe
and installed on another.
airframe logbook should identify the aircraft builder/manufacturer,
model designation, and serial number exactly as shown on the aircraft
registration certificate. It should also identify the manufacturer,
model number, and serial number of the engine and propeller installed
in the aircraft at the time of certification. If the engine or
propeller is subsequently changed, an entry should be made in
the airframe log noting the new manufacturer/model/serial number
engine logbook should identify the engine manufacturer, model
number, and serial number exactly as shown on the engine dataplate.
maintenance or inspection is done, an entry should be made in
the appropriate logbook. Each entry should be dated; the total
time on the engine or airframe and the time since overhaul of
the engine logged; a description of the maintenance or inspection
entered; and the entry signed by the person doing the maintenance
or inspection. In the case of an annual condition inspection,
the certificate type and number of the person perfoming the inspection
should also be logged.
that only items directly pertaining to the engine or its accessories
(starter, alternator, carburetor, magnetos, vacuum pump, etc)
should be logged in the engine logbook. Other items pertaining
to the engine compartment area of the aircraft, including the
propeller, fuel system, exhaust system, engine control system,
engine baffling, oil cooler, radiator, etc should be logged in
the airframe logbook.
Your Aircraft & Correct Deficiencies
Prior to making an appointment for the DAR visit, you will need
to inspect your aircraft, document the results on an inspection
checklist, correct any deficiencies found, and make an entry in
the airframe logbook to that effect.
DAR's responsibility is to make a determination whether the aircraft
"is in a condition for safe operation," in the words
used by FAA. Your responsibility is to correct any conditions
that would cause it not to be in a condition for safe operation.
may use a checklist from an FAA publication such as Advisory Circular
90-89A or one provided by the kit manufacturer. Or you may make
your own checklist. However, to make our visit go smoothly, we
like for applicants to use our own checklist, which we will provide
when you get us involved in your certification. At that time,
we will coordinate with you on specific items we will be looking
you have completed your inspection, filled out the inspection
checklist, and corrected deficiencies, you will need to make and
sign an entry in the airframe logbook documenting the inspection,
to be worded as follows.
certify that this aircraft has been inspected on [insert date]
in accordance with the scope and detail of appendix D to part
43, and was found to be in a condition for safe operation."
word about compliance with FAA Airworthiness Directives (ADs)
is in order. Confusion has existed as to whether E-ABs and E-LSAs
must comply with ADs. The question is pertinent to any aircraft
that has FAA-approved engines, propellers, seat belts, magnetos,
carburetors, instruments, etc.
the bottom line: the FAA regulations and guidance do not specifically
define whether AD compliance is required. However, the DAR's job
is to determine that the aircraft is "in a condition for
safe operation" (FAA terminology). Most DARs work under the
premise that since ADs describe known unsafe conditions, they
must be complied with in order to make that statement. If you
believe a particular AD is not applicable to your situation, talk
with your DAR about it in advance.
the Aircraft is Complete
DARs are not allowed to certificate an uncompleted aircraft. Therefore,
wait until you get everything finished before setting up the appointment
for our visit. The idea is that as soon as we hand you the airworthiness
certificate, you should be able to install the engine cowling
and access covers and go fly.
the FAA Paperwork
In addition to the paperwork you have already completed, you will
also need to complete the following:
E-AB Conversion Guide provides templates for completing these
the program letter, coordinate with the DAR regarding the size
and shape of the Phase I test area.
When the DAR arrives, the paperwork should be complete and the
aircraft ready to fly.
other advance arrangements have been made with the DAR, the aircraft
should be located indoors with good lighting and, if practical,
some means of temperature control. The engine cowling and all
access panels should be removed and the aircraft thoroughly cleaned.
It is a good idea to provide a creeper or mats for the DAR's inspection
of the underside of the aircraft and a worktable, desk, or other
surface for paperwork.
the inspection seriously. Although the DAR may be a friend, in
this setting he/she is an official representative of the FAA.
This is not the time to have your airport buddies hanging around.
Be courteous and expect the DAR to also be courteous. Answer questions
promptly and completely when asked; however, keep idle chatter
to a minimum. By all means avoid describing or bragging about
past transgressions of the FARs; such talk puts the DAR on the
spot. Remember: when the DAR ain't happy, nobody's happy!
a pad and pencil ready to note any discrepancies the DAR finds.
If the up-front coordination has been handled properly, discrepancies
will likely be minor and can be corrected after the DAR has issued
the airworthiness certificate.
little nervousness is normal. On the other hand, have fun-without
exception the inspections we have been involved with, whether
on the giving or receiving end, have been enjoyable and were frequently
occasions for additional learning.
the conclusion of the inspection, the DAR will likely issue your
brand-new airworthiness certificate and operating limitations,
explaining them in detail. At that point, after reinstalling the
engine cowling and access covers, you'll be set to go flying!
Our normal fee for issuing an original airworthiness certificate
is $400, payable at the beginning of the inspection. Complex aircraft
with pressurization systems, retractable landing gear, turbine engines,
etc, may be more. This fee applies when the aircraft is located
no more than an hour's drive each way from our home base in Lawrenceville,
locations more than an hour away, additional fees will apply to
cover travel time and expenses. Sometimes it is possible to arrange
for more than one aircraft to be certificated at the same time in
a remote location, thus spreading out the additional costs.
want your aircraft to be certificated as much as you do. So, we
coordinate closely with you to assure that all the required steps
in the process are accomplished, that the paperwork is complete,
and that the aircraft is ready and will pass the inspection. However,
in rare instances, conditions may be discovered during the inspection
visit that will not allow us to issue an airworthiness certificate.
So, we must add this disclaimer:
of the certification fee does not guarantee issuance of an airworthiness
Can I get my Experimental Amateur-Built aircraft re-certificated
as an Experimental Light-Sport Aircraft (or vice versa)?
ANSWER: No, once the aircraft is certificated as one of these types,
the certification type cannot be changed.
I get my Ercoupe 415-C, Aeronca 7AC, or other type-certificated
aircraft that meets light-sport aircraft specifications re-certificated
as an Experimental Light-Sport Aircraft? ANSWER: No, as
explained in the previous FAQ.
just bought an Experimental Amateur-Built aircraft from the original
builder. Can I take a 16-hour Light-Sport Repairman- Inspection
course and become certified to perform my own annual condition inspections?
ANSWER: Unfortunately, no. The Light-Sport Repairman- Inspection
courses only apply to Experimental Light-Sport aircraft, not Experimental