The transition period for registering and receiving an airworthiness certificate for ultralight vehicles described in the document below came to an end on January 31, 2008. Note, however, that the FAA granted an exemption which extends the transition period until January 31, 2010. This exemption applies only to those vehicles that were registered (N-numbered) on or before the January 31, 2008 deadline but did not yet receive an airworthiness certificate. The guidance information in this document is still relevant to those who need to complete the transition. In order to make use of the exemption, one must be a member of one of the three industry organizations to which the exemption was granted: EAA, USUA, and ASC. Contact your organization, or become a member of one of the organizations, and then follow their instructions. For more information about how to make use of the exemption, visit the website of one of the industry organizations. Here are the relevant links: EAA: www.sportpilot.org/learn/lsa/transitioning_ul_aircraft.html ; USUA: www.usua.org/SportPilot/ ; ASC: www.aerosports.org/extension_granted.htm.

 

Quicksilver ELSA Transition

 

This document attempts to be thorough in the presentation of the material and is therefore somewhat lengthy. You may wish to start by skimming through the write-up so the task does not appear to be more daunting than it really is.

 

The FAA created a new category for light aircraft that became law in September of 2004. The Sport Pilot rules created a new regulatory framework for one and two seat aircraft certification and registration as well as a corresponding pilot’s license, training program, and maintenance program. During the first few years of Sport Pilot, considerable infrastructure had to be developed for the ambitious program to get underway. A transition period to phase in the new regulations and phase out some of the old ones was incorporated into the rules. The regulation of interest to Quicksilver owners that is being phased out is the two seat training exemption to FAR 103 which had permitted a two seat vehicle to be registered and operated by a qualified instructor with a national organization for ultralight training. Even though “exemptions” are typically only meant to be temporary, the “training exemption” was in place for over 15 years to improve the safety of ultralight activity by providing training in similar vehicles.  Besides doing away with the two-place exempt vehicles and offering a mechanism for the vehicles to either begin to operate or continue to operate legally, the Sport Pilot rules grant an amnesty to heavy single seat aircraft that do not meet the Part 103 rules and includes these vehicles in the transition group. This means that all unregistered two place and heavy single place Quicksilvers, called the ”existing fleet” by the FAA, must become FAA registered aircraft during the transition period. The deadline for transitioning your Quicksilver as an Experimental Light Sport Aircraft (ELSA) is January 31, 2008. The transition must be completed by this date. This is the one and only time you will have to transition your plane to ELSA. If you miss this deadline, there will be no legal way to fly your plane when the Training Exemption expires on 01/31/2008. The FAA has to some degree “turned a blind eye” in the past to heavy single seat and recreationally used two-seat operations. It is likely that enforcement action will increase now that there is place for these types of aircraft to be registered and operated.  Although it is not our responsibility to persuade you to transition your Quicksilver to ELSA, we want to make sure that you know the facts so you can make an informed decision.

 

The transition to Sport Pilot will require current owners to register their aircraft with the FAA; eventually earn a Sport Pilot license; if desired, earn a Sport Pilot Repairman’s Inspection rating. All three issues play a role in aircraft ownership and operation; benefits may be realized by addressing all three before the deadline even though aircraft registration is the only one that must be completed. The task of converting a vehicle to an ELSA is not that difficult. It just takes some time for paperwork to be processed. A planned, coordinated, and well timed effort is important to making the smoothest and most economical transition possible.

 

There are several ways to go about transitioning to ELSA. We are providing just one of them here, so it is up to you to decide what is best for you. This document includes links to websites that provide additional info you may need for transitioning your Quicksilver to ELSA as well as other helpful information. Quicksilver Dealer Robert Comperini’s site is an excellent resource: www.fly-ul.com (scroll down to “Experimental Aircraft”).  Quicksilver Dealers Brian and Carol Carpenter have written a book on the subject titled “Sport Pilot Airplane” which is another excellent source of information and fully explains every step - www.rainbowaviation.com/pilot_supplies.htm. Two other sites that provide good step by step explanations are Bill Cyzan’s site at www.sptraining2.blogspot.com/ and Paul Hamilton’s site at   www.sport-pilot-training.com/n_number.htm.

 

 

Until now, any Quicksilver could be certificated in the Amateur-Built (AB) category if the major portion (51%) of it was built by the owner. If you are the builder of your plane, have your build well documented and documents like your manufacturer’s statement of origin and/or original invoices to show transfer of ownership, etc. and if the guidance material and rules for what constitutes “major portion” work do not change, you will still be able to do this in the future. The risk in waiting is that there are no guarantees that the rules and guidance material used by inspectors will remain the same after the 2008 deadline. Also, there is no guarantee that Quicksilver kits will continue to qualify as having the “major portion” built by the owner if the “major portion” built guidance material is interpreted more strictly. ►For the reasons above as well as some of the differences summarized below, we highly recommend going the ELSA route even if you are the builder of your plane. The table below compares some of the more relevant details of ELSA versus AB.

 

 

ELSA

AB

Recommend Phase 1 Flight Time (DAR/Inspector decides)

5 hours

40 hours

Phase 1 flight time when a change/modification is made that affects the flight characteristics.

5 hours

5-40 hours

(DAR/Inspector decides)

Sales/Use Tax charged by State

likely

likely

Amount of paperwork

same

same

Cost of registration/certification

same

same

Builder can apply for a Repairman’s certificate allowing him to do the Annuals on the aircraft he assembled only (since he is listed as the manufacturer). Future owners cannot get this certificate.

no

yes

Anyone can earn a Repairman (LSA) Inspection rating by attending an FAA accepted 16 hour course which allows him to perform the annual condition inspection on any Experimental-LSA airplane he owns, now or in the future, whether the builder or not.

yes

no

Anyone can earn a Repairman Maintenance Rating by attending a 120 hour course that allows him to perform the maintenance, the annual condition inspection, and the 100 hour inspections (required on aircraft used for hire) on Special Light Sport Aircraft and Experimental Light Sport Aircraft and charge for performing the work and services. 

yes

no

Aircraft can be used for Flight Training for hire until 2010 (must request at registration). Note that the aircraft airworthiness certificate expires on 01-31-2010 when this operating limit is included, so after that date a new certificate must be issued, which may require an inspection by a DAR or FAA inspector.

yes

no

Aircraft can be rented until 2010 (when Flight Instruction operating limits are requested at time of registration) Note: the owner of the aircraft can offer his plane for rent for flight instructional purposes ONLY and not just for general use.

yes

no

Existing Fleet of Quicksilvers can be certificated with the FAA after 01/31/2008

no

not guaranteed & more challenges

Manufacturer specified on registration

Kit mfg or other

builder

 

Both AB & ELSA go back into Phase 1 after any change or modification that affects the flight characteristics. The time varies for AB, but it is 5 hours for ELSA. Another significant difference is that only the builder of an AB can apply for a repairman’s certificate to do the annual inspections. When the plane is sold, the new owner will have to find an A&P to do the annuals. With ELSA, anyone can earn a Repairman Inspection rating by attending a FAA accepted 16 hour course; which allows him to perform the annual condition inspection on any Experimental-LSA airplane owned now or in the future, whether the builder or not. Between two identical aircraft being sold off, an ELSA registered one will likely have a higher resale value over an AB one for this reason.

 

►We recommend that you take a 16 hour course as soon as possible.

In addition to having the ability to sign off your own annual condition inspections, you will learn everything you need to know about transitioning your plane.

Refer to the following site: www.rainbowaviation.com/16_hr__course.htm. 

 

Several factors will affect how long the transition to ELSA takes including availability of a FAA Inspector or DAR (Designated Airworthiness Representative) to do the Inspection, amount of labor needed to prepare your Quicksilver for the Inspection,  availability of the parts needed to meet the inspection requirements, and your time.  With an estimated 4500 Quicksilvers yet to go through this process, there may be a serious “bottleneck” as the deadline draws near. Your vehicle’s engine and the sail set are the two longest lead time maintenance issues that you will want to act immediately upon if overhaul or replacement is required.

 

►We recommend that you take several steps right away so you have everything you need:

 

  1. ______Contact the person that will be doing your Inspection. Most will offer guidance and be someone to whom you can address questions.
  2. ______Taking a 16 hour Inspection Course is an excellent 1st step. Not only will you be able to “sign off” your own Annual Condition Inspection, you will learn everything there is to know about transitioning your plane to ELSA. Quicksilver Dealers, Brian and Carol Carpenter travel the country putting on theses courses. Here is a site to find out more. www.rainbowaviation.com/transition_kit.htm
  3. ______Order the ELSA Transition Kit from the same website above. It includes all the forms, placards, samples and info that you need. The cost is $6.
  4. ______You will need a way to print labels to mark your instruments and controls. Many people use something like a label maker, but they can be done by computer, by hand, or by a sign and copy shop like Kinkos.
  5. ______It is always nice to have the manuals for your plane. Here is a list of what is available:
    1.  Assembly Manual – This Manual has part numbers and assembly procedures in case you need to make repairs & order parts.
    2. Owner’s Manual – This document includes the operating limitations for your plane as well as a maintenance schedule and usually a W&B form.
    3. Engine Manual – These documents contain a Maintenance Schedule and useful service information. Rotax manuals are available online at http://www.rotax-aircraft-engines.com/ under the [documentation] tab. You will need to select the engine model and the type of manual (Installation, Operator’s, or Maintenance) and then download a PDF. Rotax service centers sell hard copies for both current and old models.
    4. Service and Maintenance Bulletins – Some changes have been made on several Quicksilver models over the years. This is a good time to make sure that you have complied with them. Quicksilver Part Number 899-01.
    5. Engine and Airframe Logbooks
  6. ______ Emergency Locator Transmitter (ELT). This is required for any two seat aircraft but is NOT required for single seat models. The ELT is NOT required for the inspection to take place, but IS required to operate. There are many sources for these. Here is one: http://aircraftspruce.com/catalog/avpages/ak450elt.php
  7. ______Radio/Transponder – Only required if you plan to fly into airspace that requires one or both items. Here are a few good sources:
    1. Airtech Inc. is a Quicksilver Dealer with great service & accessories www.air-techinc.com/catlist.asp?categoryID=icom&typ=avionics
    2. Becker Avionics – Expensive but has 2 1/4” remote heads: http://www.beckerusa.com/products/detail/index.php?search=187
    3. Micro Air – compact radio that fits in 2 ¼” instrument panel hole http://www.microair.com.au/index.aspx?page=186&productID=53
  8. ______Instruments. Airtech has a complete selection & good prices at www.air-techinc.com/classlist.asp?classID=gauges&typ=avionics. Note that these Experimental aircraft are not specifically required to have any instrumentation or gauges, but it is advisable to have at least the minimum instruments recommended by the engine manufacturer. If you are going to use your aircraft as a Sport Pilot trainer until 2010, or if you plan to do your SP check ride in it, we recommend the following instruments:
    1. Altimeter
    2. Compass
    3. Airspeed Indicator
    4. CHT or Water Temp and EGT. (Monitor both cylinders)
    5. Hourmeter
  9. Contact a DAR or FAA Inspector and tell them what you are up to. Most will fill you in on the details of what they expect and you can decide if you want to work with them or find someone else.

 

 

 The three basic steps to transitioning your vehicle to ELSA are as follows:

 

Aircraft preparation and registration can be done concurrently, or either step first, while the airworthiness inspection is always the final step.

 

NOTE: The transition of your vehicle to ELSA involves both registration AND issuance of an airworthiness certificate. You have NOT successfully completed the process before the deadline unless you have BOTH.

 

 

STEP 1:          Prepare the Aircraft

A good way to start is by going through the Maintenance Schedules in the back of the Owner’s and Engine Manuals. One of the things for which the DAR inspector will be looking is the proper use and application of AN hardware, nuts, bolts, screws and rivets. This site will give you a good idea what the Inspector expects. Scroll down to SECTION 8. EXPERIMENTAL LIGHT-SPORT AIRCRAFT AIRWORTHINESS CERTIFICATIONS at http://www.usua.org/SportPilot/Order8130-2F.pdf

 

If you have options, improvements, or repairs that you would like to do, now might be a good time. Remember that two seat aircraft must have an ELT installed while a single seat one does not require one. It is also a good time to comply with any Service Bulletins that you may have missed. A printed copy of Service and Maintenance Bulletins can be purchased from Quicksilver Mfg. by P/N 899-01 for $20.99.

 

Fill out a condition inspection checklist. Use the maintenance schedules in the Owner’s and Engine Manuals as guidance material. A condition inspection checklist compiled from FAR 43 Appendix D and modified to more accurately reflect your aircraft will be a valuable tool. Use it before and during the registration process as well as in the future for annuals, etc. Here is a good example in Excel: www.eaaul62.com/ConditionInsp.xls

If you do not already do so, keep maintenance logs for both your airframe and engine. These will be updated as needed and used during annuals, etc.

 

Once you have installed everything and are completely satisfied that your plane is ready to go, it is time to do the weight and balance (W&B). You will typically find the instructions for the W&B in your Owner’s Manual with a diagram, ranges, and limitations. You must determine the following values for your aircraft: empty weight, gross weight, most forward and most aft CG locations, and the weight and balance for the configuration of the initial test flight.

 

The last step in preparing the aircraft is to apply all the necessary markings, labels, and placards. The following is a summary with some details:

PASSENGER WARNING – THIS AIRCRAFT IS AN EXPERIMENTAL LIGHT SPORT AIRCRAFT AND DOES NOT COMPLY WITH FEDERAL SAFETY REGULATIONS FOR STANDARD AIRCRAFT

Further instructions for this are in the Rainbow Aviation Transition Kit. It gives very specific directions for how to do this step and what is needed. Here are a few links that also talk about this step:

AC45-2B Identification and Registration Marking

AC20-88A Guidelines on the Marking of Aircraft Powerplant Instruments (Displays)

 

The FAA Form 8050-3, Aircraft Registration Certificate which assigns the N-number, must be in the aircraft. This can be in a pouch riveted to the back of a seat, or as you find most practical and secure so that it can be found and will not be lost. Since you may not have registered before getting to this step, make a note to come back to it before having the airworthiness inspection.

 

It is a good idea, after doing the kind of repairs and equipment installations that may have been done, to flight test the completed aircraft again. AC90-89A Amateur-Built Aircraft and Ultralight Flight Testing Handbook will help you develop a safe flight testing plan. AC90-89A Amateur-Built Aircraft and Ultralight Flight Testing Handbook

 

 

 

STEP 2:          Register Your Aircraft (Obtain an N-number)

 

Apply for your N-number right away. The forms required are in the Rainbow ELSA Transition Kit or you can pick them up at your local Flight Standards District Office (FSDO). 

 

There are two forms you will need:

– FAA Form 8050-1, Aircraft Registration Application. This must be an original form and not a copy. When applying, leave the N-number blank unless you have reserved one.

– FAA Form 8050-88A, Affidavit of Ownership for Light Sport Aircraft. This form must be signed in front of a notary. It can be downloaded online: www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/media/8050-88a.pdf. When applying, leave the N-number blank unless you have reserved one.

– Custom N-numbers can be reserved at an extra cost. This is optional and can be done online via http://162.58.35.241/e.gov/NN/resreqform.asp or in writing (refer to http://www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/special_registration_numbers/ ).

 

Submit the forms and fees to the FAA Aircraft Registration Branch (AFS-750).

It can take up to10 weeks to get your number back (usually 3 – 4 weeks) and you will need the registration and N-number before scheduling an inspection with the FAA or a DAR. Note that as soon as you have an N-number, the vehicle cannot be flown as an ultralight; so you will want to time your airworthiness inspection to be soon after the registration comes back.

 

STEP 3:          Get an Airworthiness Inspection

 

As soon as you get your registration and N-Number back from the FAA make an appointment with the Inspector. Here is a site that includes contact info for DAR’s: www.faa.gov/other_visit/aviation_industry/designees_delegations/media/DAR-LightSport.pdf. If you haven’t done so, place your N-numbers on your plane. They must be a minimum of 3-inches in height. Details and requirements are specified in FAR part 45.29 and on page 8 at www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/0ca2845e2aafffbb86256dbf00640cb2/$FILE/AC20-27F.pdf. It can be a challenge to find a place for the N-numbers on a Quicksilver, but opposing sides of the rudder are probably the best location.

Prepare the paperwork as outlined and supplied in the Transition Kit.

·         Aircraft Registration, FAA Form 8050-3 (Postcard you receive in the mail). This must be visible in the aircraft and have a location where you can also put the Airworthiness Inspection forms when you get them.

·         Program Letter. This document is used to specify what you want: request an airworthiness certificate for your aircraft by model, serial number, and registration, as well as identify the area to be used for flight testing. A sample is included in the Transition Kit.

·         Ask for Training Privilege in Program Letter. If you want to use the aircraft for training until 2010, make sure you ask for the training privilege in the program letter, otherwise you will not get it. This is easily glossed over and you must cover this specifically with your inspector or it can easily be left out and be hard to fix. Make sure this is clearly understood and acted upon. Understand the cost versus benefit for this request. If you will not be using the aircraft for training, do not ask for this privilege because you will need 100 hour inspections performed by a sport pilot mechanic or higher and you will also have to be sure to have your registration converted to regular ELSA before the 2010 deadline or it will lapse.

·         Application for Airworthiness Certificate, FAA Form 8130-6. This document is needed for the FAA inspection. It must contain all the information you have identical to that on your fireproof data plate and registration.

·         Weight and Balance for Aircraft. This document should have been drafted during the aircraft preparation section earlier.

·         Condition Inspection Checklist. This document should have been prepared during the aircraft preparation section earlier.

·         Aircraft Rendering. This document can be a picture/snap shot, a perspective drawing, or a 3-view of the aircraft. You will find a 3-view drawing in most Owner’s Manuals and some Assembly Manuals. 

 

 

Spend time organizing and completing the paperwork you have assembled to get ready for the Inspection appointment. The FAA likes easy to read, complete, and organized paperwork. Wait for questions; do not provide more information than needed. It will not be unusual for the inspector to question you about your work. Refer to your assembly manual or other documents as needed. When the DAR or FAA inspector gives you your Airworthiness Certificate, he will also specify Operating Limitations for your aircraft. Part of these limitations will be requirements to fly a Phase One program of flight testing that is usually 5 hours long. In some cases there will be credit given for the flight time already logged. Here is a link to a sample of the operating limitations that the FAA will use for an ELSA: ELSA Operating Limitations. For more information look at FAA Order 8130.2F CHG1.

 

Submit all the documents listed above to the FAA inspector or DAR with whom you meet for your inspection. They will issue you the aircraft airworthiness certificate and operating limitations. From this point forward, those documents MUST be kept on the aircraft at all times.

 

If you have Phase One time to fly off anyways, after doing the kind of repairs and equipment installations that may have been necessary, it is a good idea to flight test the completed aircraft again. AC90-89A Amateur-Built Aircraft and Ultralight Flight Testing Handbook will help you develop a safe flight testing plan. It is here:
AC90-89A Amateur-Built Aircraft and Ultralight Flight Testing Handbook

 

 

Summary

 

The key to completing the transition to ELSA before the deadline is to get started early and allow plenty of time for work to be done and administrative processes. The time and effort you spend will be a minimum if you use this guide and the associated material available and on the web. The following summarizes the process to reflect how simple it should be: you must properly label and placard an airworthy aircraft for which you have obtained an N-number, and then present that aircraft along with the appropriate forms to an inspector for issuance of an airworthiness certificate.

 

We wish you the best and hope your transition goes smoothly.

 

We appreciate your feedback regarding your experience; your fellow pilots may benefit from it as well. So, if you run into anyone at the local flight park or club meeting that may need to transition, share your experience with them. So far, most owners that went through the process found the transition more intimidating than difficult. If you have any comments or questions, contact us at netsales@qsair.com.