On Wed, 05 Jan 2005 01:58:23 GMT, Ron Wanttaja wrote:

I hope your interpretation is right because ELSA kits were too
restricted for the life of the plane in the early discussions.

I have a sneaking suspicion my interpretation is wrong, just because it *would*
allow a lot more flexibility that I believe the FAA and EAA intended. I've been
given a good contact at the FAA, I'll try get a clarification.

I've had a good exchange with one of the inspectors in the Light Sport branch at
the FAA.

1. Owners of an Experimental Light Sport Aircraft (ELSA) must strictly conform
to the manufacturer's assembly instruction during construction.

2. Once the aircraft is completed, the owner is free to change and modify the
airplane as he desires without permission or guidance from the original kit
manufacturer. Just like Experimental Amateur-Built, though, if a major change
is made, the aircraft will have to go back to the Phase 1 testing.

3. Persons owning an aircraft with a Special Light Sport Aircraft (SLSA)
certificate (e.g., production LSAs) may receive a new airworthiness certificate
in the Experimental category upon application (e.g., no prerequisites).

4. When the new airworthiness certificate is granted, the owner must surrender
the Special LSA certificate (which I interpret as meaning there's no going
back).

5. Once the new certificate is awarded, the owner is free to change and modify
the former SLSA as desired without permission or guidance from the original
aircraft manufacturer. Major changes will require the aircraft perform Phase 1
testing.

I did not ask specifically in regard to former two-seat ultralight aircraft, but
given #2 and #5 above, I can't believe it'd be any different.

Keep in mind, though, that this is new ground for the local FSDOs. It's likely
there may need to be some policy documents generated at the national level to
ensure a consistent interpretation.

What struck me during the exchange is how similar the SLSA to ELSA transition is
to the "owner maintenance" category in Canada. The owner of a production-type
aircraft will be able to have a lot more freedom as far as changes to his bird.

Ron Wanttaja