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Roger Lee

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My Sky Arrow made the journey from SLSA to ELSA last December.






No regrets.


As stated, I can now do all of my own maintenance and minor mods with no restrictions.


I also took the 16-hour course so next December I can do my own "annual".


Downsides are that the plane can no longer be used for flight instruction or hire, but I had not planned to do so anyway. The insurance company decreased the amount they would insure the hull for (from $70k to $50k), but that also resulted in a commensurate drop in premiums. The effect on actual resale value remains to be seen.


Not for everyone, but certainly worth considering - but remember - there's no going back to SLSA, EVER!

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Hi Doug, (Look I remembered :))


FD wouldn't even know unless they went out and did a major search. There are a couple of CT's that went ELSA a few years back. It's still their plane to support. Nothing has changed there. But you most likely won't be going back to SLSA since they would have to sign off on it. Like Eddie said it may not be for everyone, but depending on your circumstances it may be worth a consideration. I had thought about it right after I got my plane, but decided against it.

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One more data point...


...the company that makes the Carbon Cub will deliver the identical plane as either an S-LSA or an E-LSA, customer's choice.


I know this because a fellow over on the Cirrus Owner's site just took delivery of his as an E-LSA.


And, in the interest of "how far can we get from the original concept of LSA?" his Carbon Cub went out the door at over $190k

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  • 2 months later...

Here is what the DAR in kentucky sent me in reply to me asking him if he had found out any info on how to do this:


Does anyone know the names of the 2 people who have already done this with CT's? Maybe i could contact them personally?




The reply for the DAR:


Here is some reading for you. Were is the aircraft at now and is ready to fly




c. Kit Assembly.

(1) Eligible aircraft must be designed in accordance with the applicable consensus

standard, and assembled in accordance with the LSA kit manufacturer’s assembly instructions.

Accordingly, the detailed design data, quality systems, and procedures will not necessarily be the

same as that of the holder of a type design and PC for the production of aircraft. The

components of LSA kit aircraft are not necessarily held to the requirements of type-certificated

or supplement type-certificated aircraft, or those of parts manufacturer approval status.

(2) The LSA kit does not have to meet a major portion requirement. However, the

applicant must show evidence that the LSA is properly assembled in accordance with the

manufacturer’s assembly instructions for that aircraft.

Note: The FAA does not certify LSA manufacturer’s kits or approve the

kit manufacturers. The FAA does not perform evaluations of LSA kits or

LSA kit manufacturers, and no FAA listing of approved or evaluated LSA

kits or manufacturers will be provided.

d. Advising Applicants.

(1) The FAA inspection of an experimental LSA will be limited to a general

airworthiness inspection when the aircraft is submitted for airworthiness certification. The FAA

will not perform any progressive inspections during the construction or assembly of the aircraft.

All advice, if any, given to the LSA kit builder by the FAA should be made a matter of record for

future reference. The FAA ASI or DAR will not perform any part of the fabrication,

construction, assembly, testing, or manufacturing inspections to the aircraft.

8/31/2010 8130.2G


(2) When the prospective LSA kit builder contacts the appropriate FAA office to advise

the FAA of the project, the FAA should provide the prospective kit builder with the applicable

forms and any guidance necessary to ensure a thorough understanding of applicable regulations.

(3) When an applicant is seeking to obtain an experimental certificate for LSA and

intends to use the aircraft for flight instruction for compensation or hire, the applicant should be

advised that this provision expired January 31, 2010, in accordance with 14 CFR § 91.319. The

date January 31, 2010 coincides with the expiration date on the initial issued special

airworthiness certificate. If an experimental light-sport aircraft (ELSA) special airworthiness

certificate expires, the aircraft cannot be operated, and there is no basis for reissuance. Before

the expiration date (that is, January 31, 2010), the applicant must have applied for, and been

issued, an amended special airworthiness certificate for the purpose of operating an ELSA of

unlimited duration.

(4) An applicant seeking to obtain an experimental LSA certificate for a kit-built

aircraft should be advised that the aircraft will have to be in compliance with

14 CFR § 91.319(B). To show this compliance, the applicant must perform flight testing that

addresses the requirements, goals, and objectives of the applicable consensus standard

acceptance flight test. The flight test program will be developed in accordance with the

manufacturer’s aircraft operating instructions, maintenance and inspection procedures, and flight

training supplement using the applicable consensus standard ground and flight testing procedures

in conjunction with the operating limitations assigned. A flight test program demonstrates that

the aircraft has been adequately tested and determined to be in a condition for safe operation

within the aircraft’s flight envelope in accordance with 14 CFR § 91.319(B).

(5) The applicant seeking to obtain an experimental LSA certificate for a kit-built

aircraft should be advised the aircraft must not be modified or altered without manufacturer’s

approval before initial certification.

(6) The FAA office, when requested, should furnish an applicant for an experimental

LSA certificate with the following forms:

(a) Aeronautical Center Form 8050-1, Aircraft Registration Application;

(B) FAA Form 8130-6; and

© Aeronautical Center Form 8050-88A, Affidavit of Ownership for Experimental

or Special Light-Sport Aircraft.

(7) At the time of airworthiness certification—

(a) The aircraft should be complete in every respect, and

8/31/2010 8130.2G


(B) The applicant must submit all required documentation. Such documentation

includes appropriate completed FAA forms, the aircraft’s documentation in accordance with

14 CFR §§ 21.191 and 21.193, and, when applicable, the aircraft maintenance records in

accordance with 14 CFR part 43. If the applicant cannot or will not provide the appropriate

documentation, the applicant should be advised that the aircraft cannot be certificated as an

experimental LSA until satisfactory evidence is provided to substantiate that the aircraft’s

required documentation is complete.

e. Weight and Balance.

(1) Before certification, the applicant should accurately weigh the aircraft in accordance

with established weight and balance or weight and loading procedures to determine the aircraft’s

empty, gross, and most forward and aft CG location, when applicable, including the weight and

balance or weight and loading for the initial flight tests to help reduce stall, spin, and other

control-related accidents. If the aircraft is constructed from a kit, the predetermined

manufacturer’s data should be used. The completed weight and balance or weight and loading

report, including load limits for flightcrew (when applicable), oil, fuel, and any cargo carrying

capabilities, should be available on the aircraft along with the other applicable placards, listings,

and markings required by 14 CFR § 91.9.

(2) Before certificating the aircraft, the FAA should verify that the weight and balance

or weight and loading data is accurate for that aircraft, that the aircraft has been weighed

correctly, and that the CG and its most forward and aft CG limits are established.

f. Transfer of Airworthiness Certificates. An airworthiness certificate is transferred

with the aircraft (14 CFR § 21.179), for example, if there is a change of ownership or transfer of

registration. There is no FAA inspection required after transfer of an aircraft with its

airworthiness certificate unless it is determined that revised operating limitations are necessary.

In this case, a new FAA Form 8130-7 must be issued to reflect the new date of the revised

operating limitations. Therefore, the applicant must submit a properly completed

FAA Form 8130-6.

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All of that verbiage pertains to kit built which is really what a DAR is for. You could just talk to you local FSDO or just send in the form and see what they say. I spoke to our local FAA inspector and the form was all he needed. Said he might want copies of the old airworthiness certicifcate, but that was it. There was someone with a Sky-Arrow on the other forum who did it.

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here was his most recent reply:



I Will talk to the MIDO office tomorrow you have to remember the rules really changed after 01/31/2010. I will let you know if its as easy as you guys think.

one thing I will tell you do not remove the existing data plate and all the original consensus reports etc. must be in order and the aircraft must be in an airworthy condition as it was when org. a/w cert was executed and you must have the org. Also I will have to make a trip to Crofton to insure that the ELSA min. placards etc. have been fulfilled , and complied with. before I issue a A/W cert. you will find this Chapter 2 para 215 thru 217 Far-8130.2G

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I had my ct converted to elsa in May 2010.

Here is what I went through.


Only a few DAR's can do this conversion. You will get it done quicker with the DAR, but they will charge you.

The FSDO will do it for free, but you are on their timetable, this is not a high priority for them.

I used the FSDO, It took several weeks to get an appointment to complete this process.


Converting an S-LSA to E-LSA:

If you are the owner of an S-LSA aircraft, and wish to change it to an E-LSA (in accordance with 14 CFR 21.191(i)(3)), the following steps must be completed:


Complete a new 8130-6 (Application for Airworthiness Certificate.. Example attached)

Create a Program letter. (See FAA Order 8130-2F, page 221 for an example)


When I went to the FSDO to complete the task, they wanted me to bring.

My air airworthiness certificate for the airplane and current flight restrictions. (These will be turned in and you will get a complete new set for elsa)

My aircraft/Engine log books showing the aircraft is current. They also wanted to see in the log book where I completed the last AD.

I printed the page from Flight Design showing all the aircraft & Engine service bulletins, which ones applied to my plane and the dates of completion. (He only looked up the last one in my book).


We went through the paperwork to verify is was all correct.

He gave me my new airworthiness certificate & flight restrictions (One significant difference when you are elsa, you can no longer fly over heavily populated areas as an experimental aircraft).

Before you go to your appointment, ask what they would like you to bring just to be on the safe side.


A friend of my who went elsa ended up with a 5 hour phase I flight restriction of 100 miles.

You will need to placard your aircraft. Where to put the "Experimental" sticker, I found this in "45.23(B)"


I hope this helps


Steve Moliterno.

8T8 -post-37-079526400 1284350027_thumb.jpg San Antonio

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Hi Steve,


Nice to hear from you again, it's been a while. Great informative post.



This is just an FYI type post from me:

I just got off the phone with Edsel Ford the head at FAA for LSA. I had a couple other question for him, but I ask this one too. He said every thing in your post was very good. He did mention that your friend with the 5 hrs and 100 mile phase one could have signed it off as soon as the paperwork was done so long as the guy had over the 100 miles on the plane and he hadn't changed the configuration from the MFG original SLSA airworthy inspection before he went to ELSA. As soon as the paperwork was done and he signed it off in his logbook he could then change the configuration.




Why aren't you coming to Page, AZ?



Take Care,


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This pretty much dovetails with all I was told except for the program letter. When I look at FAA Order 8130-2F on the FAA site, it says this order has been cancelled. The FSDO examiner here in San Jose never mentioned it to me. He also said that he wouldn't require any Phase 1 since the plane already had plenty of hours on it.


The heavily populated areas restriction is an ongoing oddity as it is flagrantly ignored by the FAA. Not sure why they even have it since there are plenty of experimentals flying around the very conjested San Jose area. Awhile ago the FAA issued guidance allowing this restriction to be removed after Phase 1 in the Oplims. Again it helps to go to the source:


So many Oplims do allow experimentals to fly in congested though many do not and the FAA doesn't bother to check. So, technically, I would guess half of the homebuilts are operating illegally. So what about an SLSA -> ELSA? It doesn't have an OpLims letter since it wasn't out of a box. According to my FSDO, the Oplims for a former SLSA are those described in the AOI which does not limit the pilot to uncongested airpsace or lightly populated areas. It's worth noting that this seems to be a confusing area even to senior FAA officers. It's all very simple though; just read this 360 page FAA order:


Just skip to section 8 on pg 160 if you want to cut to the chase. The FAA does not explicitly state where to read oplims for the case of conversion to ELSA.

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