How to N Number Your Ultralight, by by Paul Hamilton, CFI, DPE (SPE / SPIE)

Paul Hamilton standing next to his Cosmos weight-shift trike.

How to N Number Your Ultralight

by Paul Hamilton, CFI, DPE (SPE / SPIE)

Overview

If the vehicle you fly doesn't fit the Part 103 Ultralight criteria, such as a two place Ultralight (two seats), or a fat ultralight (single seat with an empty weight over 254 pounds), then you must have it registered as an "Experimental Light-Sport Aircraft (E-LSA)" before January 31, 2008. If you don't, it will be a useless and totally worthless “lawn ornament”. We refer to Ultralight trainers and fat Ultralights that need to be transitioned as "Non Qualifying Ultralights (NQU)".

If you are one of the people who plan on flying your NQU illegally after the deadline, just like driving an unregistered car with no license plates, you can be fined from $1000 to $10,000. per infraction. If you feel you have plenty of money to give to the government, that's your choice.

"Once you register your NQU as a Light-Sport Aircraft with an N number. You'll be able to fly it as a Sport Pilot, Private Pilot with sport pilot privileges (no night or over 10,000 feet MSL), or Private Pilot with private pilot privileges. You can train in it as a Sport Pilot Instructor (CFIS) or a general aviation Certified Flight Instructor (CFI) until January 31, 2010. It will also become a valuable "Aircraft" that you can sell. So do not miss out on the opportunity to transition your NQU.

Note the important January 31, 2008 deadlines:

All non qualifying ultralights need to be transitioned to Experimental light sport aircraft.
All National organizations EAA, ASC, USUA Ultralight training exemptions expire.
If you were an Ultralight pilot before Sept. 1, 2004, you may use your transition letter for endorsements and pilot time for your Sport Pilot Certified Flight Instructor (CFIS) checkride. (This "grandfather" benefit to "show your letter only" for a CFIS checkride will expire January 31, 2008 just as the similar "show your letter only" for Sport Pilot expired on January 31, 2007.)

I'll share with you my experience and what I submitted to register my own personal aircraft. Modify this plan for your own specific circumstances. The following will help you get your NQU through the process which is three basic steps:

Register your aircraft (this includes getting an N number)
Prepare your aircraft and paperwork for the airworthiness inspection
Get an Airworthiness Inspection

Timing is critical

Keep in mind, the timing of N numbering your NQU is very important. If you become a Sport Pilot first, and you remain in one of the national organizations, you can still fly your NQU under the National Organizations USUA, ASC, and EAA exemption. However, once you N number your NQU as an aircraft, you need to be a Sport Pilot signed off to solo it by a CFI or a Private Pilot with a sign off for your particular aircraft category. Once you N number your NQU, it CANNOT be flown as an Ultralight anymore.

You must get going immediately because it takes 3 - 12 weeks to register your Ultralight (Step 1 above), and you must submit your paperwork for your airworthiness inspection, at the very latest before November 30, 2007 or you will not be able to get it inspected in time to meet the January 31, 2008 deadline. Start Now!

Timing Options for Aircraft Certification
Please note that for either option listed below - After you register your aircraft and before you have the airworthiness inspection, your aircraft is grounded.

Option A (Preferred)– Get your Sport Pilot license first, before N numbering your NQU. If you are going to become a Sport Pilot Certified Flight Instructor (CFIS), get this rating before you N number it. That way you can start training in it immediately after its N numbered. You will have to arrange with your examiner to take your CFIS checkride/practical exam in another N numbered aircraft. Most examiners will have or can find an N numbered aircraft to.
Option B (Not preferred)– Get your aircraft N numbered first, and then get your checkride/practical exam in it. The limitations in the issuance of the airworthiness inspection typically state that the aircraft must be flown five hours in the configuration by a qualified pilot to meet this requirement. So typically a Sport Pilot (or higher) rated in the category/class of aircraft must test fly the aircraft for a five hour Phase 1 test flight before two people can fly in it for the checkride.
Option C – Get your solo endorsement from a qualified CFI to fly your aircraft solo. Then you can fly the Phase 1 five hour flight test yourself so you can then take a checkride in it.
Option D (A work around) – A little known regulation 61.31(k) allows a current private pilot or higher, to fly an experimental aircraft with no passanger. This means that a pilot with private single engine airplane land license, can fly any experimental weight-shift control or powered parachute solo without a catagory rating. Again, like Option C, you can fly the Phase 1 five hour flight test yourself so you can then take a checkride in it.

Filling out the forms correctly will provide a successful outcome
If you make a mistake by checking the wrong box on one of the forms, fill out one of the lines wrong, leave one of the required lines blank, send the wrong form, or forget to supply one of the forms can delay your process 3 - 10 weeks. Therefore, it is important to follow the checklist provided here and get all of the forms that I've provided examples of.

It actually took only 3 weeks to receive my aircraft registration (I was lucky), and 2 weeks for the airworthiness inspection. This is record time for both. (We'll talk about how to get through this process as fast and painless as possible). Follow this checklist to make certain you too can make it through this process in reasonable time.

Step One
Register your Aircraft with the FAA and get an N number assigned

______ Custom N number
If you want a custom N number rather than have the FAA assign one to you, go to http://www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/special_nnumbers/ to learn about the N numbers, and http://162.58.35.241/e.gov/NN/resreqform.asp to get it. You can check what N numbers are registered already at http://162.58.35.241/acdatabase/NNum_inquiry.asp. Get this first if you want it. It costs $10 and you can do it all online. Once I submitted my request I got a letter back in less than a week. It took 3 days for me to see it appear in the FAA data base.

Obtain Your Registration

Send in the two forms listed below plus a check for $5 to obtain your registration. Make sure the forms are filled out exactly as shown in the examples or they will be returned. The forms are::

______ 1) FAA form 8050-1 Aircraft Registration Application
Carbon copy original only can be used. Can not be download. You must get official 3-peice form from FAA FSDO office found at http://www.faa.gov/about/office_org/field_offices/fsdo/. It is also supplied in the kits offered by Rainbow Aviation and EAA. (See links at bottom.) Fill in the areas highlighted in yellow in the example below and send to the FAA. Make sure to name yourself as the manufacturer, if it is amateur built (you built it yourself), and print or type your name below your signature. All information must match your data plate on the aircraft.

Example or registration form 8050-1
(Click on image for larger view.)

______ 2) FAA form 8050-88A Affidavit of Ownership
Fill in areas highlighted in yellow in the example below with your particular aircraft info. This form must be notarized at bottom. A new aircraft will have a different form. You can download the form at:
http://www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/media/8050-88A.pdf. TIP: DO NOT use the "Bill of Sale" form in lieu of the Affidavit of Ownership as this will complicate the process.

Example of Affidavit of Ownership
(Click on image for larger view.)

______ Send in the forms plus $5 check made out to "FAA Aircraft Registration" to:

Aircraft Registration Branch (AFS-750)
PO Box 25504
Oklahoma City, OK 73125

Or via courier service to:
Federal Aviation Administration
Aircraft Registration Branch, AFS-750
Registry Building, Room 118
6425 S. Denning St.
Oklahoma City, OK 73169

You may contact the Registry between the hours of 7:30am – 4:00pm Central, Monday through Friday. For registration or recordation information contact (405) 954-3116 or 1-866-762-9434. (You should get your registration post card in mail about 3 to 10 weeks.)

Example of Registration form
(This is what you receive back, in the mail.)
Click on image for larger view.

Step Two
Prepare Your Aircraft for Inspection

This step can be done while you wait for your registration to be sent to you

______ Research who you want to inspect your aircraft
Ask around your local airport and find an FAA Airworthiness Inspector or Designated Airworthiness Representative (DAR) who others have used and others like to work with. I looked for someone who would want to help. Simply ask the experimental guys around your airport who at the local MIDO or FSDO wants to help, and contact them. This can make a big difference. The guys with the FAA office will do the inspections for free because it is their job. Designated Airworthiness Representative (DAR) is a civilian who can do it for you but will charge some "reasonable" fee. The important point is to find someone who will help you accomplish this and can do it in a reasonable time frame. The FAA free guys may say it could take them 6 to 9 months (if they are very busy), others can do it in two weeks. You can also haul your aircraft to a MIDO or FSDO, any where in the country if necessary.

______ Educate the inspectors
You might hear “We know nothing about doing a light-sport aircraft.” You reply “I know, and it is my job to help you get through the process. I will drop by some information you can look at and call you back in a few days.” Make a package of videos, FAA web site, and a FAR book with the new sport pilot rules tabbed and highlighted. This will help them understand the process. I think this is very important to get the ball rolling. I also obtained the FAA paperwork issued on a similar trike and provided a copy of this to the inspector also.

Where to find an Inspector:

FSDO: http://www.faa.gov/about/office_org/field_offices/fsdo/

MIDO: http://www.faa.gov/aircraft/air_cert/locate_office/mido/

Some, but not all DAR's, can be found at: http://www.sportpilot.org/resources/dar.html

If you have concerns or questions contact the FAA Light Sport Aviation Branch in Oklahoma City (405 954-6400 or e-mail afs610comments@faa.gov).

Preparing Your Aircraft

Start your aircraft preparations early. It is best to get your aircraft labeled with placards and your aircraft documents in order as soon as you can. This should be started first or at least when you first send in your registration. It takes a while and you want to be ready immediately for your inspection when you receive your registration. Details are covered in the aircraft preparation section below.

______ Label all of your instruments and systems with placards so anyone can understand the operation of each system, instrument, switch, lever, button, and/or handle because it is properly labeled. This includes operating limitations for each instrument. This includes purpose and operating limitations for each item. I was told specifically by the FAA "everything in the aircraft needs to be labeled so someone who knows nothing about this specific aircraft would know what everything is and it's operation." Different inspectors may want different things.

Examples of items to be placarded (labeled) are:

	Under the seat we see the manufacturers data plate shown right, and the electric gloves/sox heating system switches labeled on left.
	Throttle is labeled with open and closed.
	Choke is labeled with open and closed, both ignition systems are labeled with the on position. Note the ignition switches are both off.
	Electrical switches purpose is marked along with on and off.
	Top left - Airspeed indicator with operational airspeeds marked: green arc, yellow arc, and red line. (This was tape added to the outside of the gage.) Top right - RPM and hours gage with RPM ranges and "Maximum RPM" marked (hours are showing since engine is shut off). Bottom row - CHT and EGT normal operating ranges and maximum marked.
	Fuel cap with fuel grade required, oil pre-mix fuel ratio, and fuel capacity of tank. Note additional fuel fitting added below placards so I can add an auxiliary fuel tank, and open a valve on the auxiliary fuel tank so it drains into the main tank when needed for greater range. This was not possible with an Ultralight trainer.
	Coolant fill for engine. Photo courtesy of Rainbow Aviation.

______ Make sure all instruments and systems operate properly.

______ Obtain the required Placards or stickers. (See Additional Resources below)

______ N numbers These must typically be minimum 3-inches in height and mounted appropriately to some structure of the aircraft before the inspection. They must be in the specified location and have a contrasting background so they can be easily seen. Details and requirements are specified in FAR § 45.23 Display of marks, general; FAR § 45.25 location of marks on fixed-wing aircraft; FAR § 45.27 Location of marks, non-fixed-wing aircraft; FAR § 45.29 Size of marks.
______ Experimental sticker/placard They must be 2-inches in height. Figure out how to mount them so they can be easily seen by someone entering your aircraft. Specifics are in FAR § 45.23 Display of marks, general.
______ Passenger Warning sticker/placard This must say specifically "PASSENGER WARNING - This aircraft is an experimental light-sport aircraft and does not comply with federal safety regulations for standard aircraft." Figure out how to mount it so that it can be easily seen by the passenger.

	Experimental placard on passenger entrance side for weight-shift control. N number must be on both sides.
	Powered parachute N number mounting system was added since there was no structure to mount the N number on.
	Fixed-wing Quicksilver Experimental placard attached to passenger side entrance. (Photo courtesy of Rainbow Aviation)
	Fixed-wing N number attached to boom of aircraft. (Photo courtesy of Rainbow Aviation)

______ Verify or install data plate. Verify you have a fireproof data plate secured to the aircraft. This is typically installed on most Ultralights which have the vehicle model and serial number. If the vehicle or aircraft does not have a data plate, make one and install it where it would not be defaced, removed easily, lost, or destroyed in an accident or fire.

______ Emergency Locator Transmitter. Fixed-wing aircraft are required to have an Emergency Locator Transmitter (ELT). Weight-shift trikes and powered parachutes are not required to have an ELT.

______ Ballistic parachutes must be marked. The manufacturer has placards or labels for this. (If appropriate.)

	Ballistic parachute marked on right hand side or chute canister and PASSANGER WARNING sticker on left hand side of chute canister visible from cockpit.

______ Mark the gallons or liters. Might be helpful to have for inspection, and is surely a help to you later. Mark the type and minimum fuel grade on or near the fuel tank.

Have All the Aircraft Paperwork Completed and In Place

______ Aircraft maintenance records/logbooks for engine and airframe. If you are like many Ultralight pilots, you have been operating your vehicle without documenting your maintenance. This is not the best situation from an FAA inspector's point of view. So purchase engine and airframe logbooks and reconstruct (to the best of your ability) all of the maintenance you have performed on your NQU.

______ Weight and balance document for aircraft. (You may have to create one for your aircraft.)

Weight Shift Control

Example 1: Cosmos Trike
Click on image for larger view.
Click here to download example. (.pdf file)

Example 2: Air Creation
Click on image for larger view.

Fixed Wing
Needs empty weight, gross weight, most forward CG location, most aft CG location, weight and balance for initial flight test. The manufacturer should have a weight and balance sheet for the particular aircraft.

Powered Parachute

Example
Click on image for larger view.

______ Condition Inspection. (You must inspect the aircraft and supply documentation.)

Weight Shift Control - Downloadable form: WSC condition inspection.pdf

Fixed Wing - Downloadable form: FW condition inspection.pdf

Powered Parachute - Downloadable form: PPC condition inspection.pdf

______ Aircraft Registration FAA form 8050-3 (Post card you received in the mail.) This must be visible in the aircraft and be in a location where you can also store the Airworthiness Inspection forms and operating limitation document when you receive them.

______ Program Letter (Document specifying what you want and given to the FISDO, MIDO, or DAR so they know what you want.)

Example: Program letter (from EAA kit) submitted with Airworthiness request. Click on image for larger view.

______ 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 hard to fix. Make sure this is clearly understood, acted upon, and verified once you receive the limitations from the inspector.

______ Application for Airworthiness Certificate 8130-6 (Document for FAA inspection)

Example of Airworthiness Application Form. Click on image for larger view. Download FAA form http://forms.faa.gov/forms/faa8130-6d.pdf.

______ Aircraft Rendering (This can be a picture/snap shot, a perspective drawing, or 3 views of the aircraft to document what the aircraft is.)

After You Obtain Your Registration

______ Make an Inspection appointment with the FSDO, MIDO, or DAR inspector once you receive the registration with the N number.

______ Mount the required Placards or stickers. (See Additional Resources below)

______ N numbers These must typically be minimum 3-inches in height and mounted appropriately to some structure of the aircraft before the inspection. They must be in the specified location and have a contrasting background so they can be easily seen. Details and requirements are specified in FAR § 45.23 Display of marks, general; FAR § 45.25 location of marks on fixed-wing aircraft; FAR § 45.27 Location of marks, non-fixed-wing aircraft; FAR § 45.29 Size of marks.

______ Experimental sticker/placard They must be 2-inches in height. Figure out how to mount them so they can be easily seen by someone entering your aircraft. Specifics are in FAR § 45.23 Display of marks, general.

______ Passenger Warning sticker/placard This must say specifically "PASSENGER WARNING - This aircraft is an experimental light-sport aircraft and does not comply with federal safety regulations for standard aircraft." Figure out how to mount it so that it can be easily seen by the passenger.

The Airworthiness Inspection

Spend time organizing and completing the paperwork you have assembled from the above checklist. The FAA likes easy to read, complete and organized paperwork. Avoid going over small details of the aircraft. Look at the big picture of how the aircraft has been flying successfully already and how it flies. Wait for questions, do not provide more information than needed.

It will not be unusual, for the inspector to see something that is different from what he has seen before. Explain what you have and why it is airworthy. Let him know that experimental Ultralights are different from the general aviation aircraft he has seen before.

______ Inspector issues an Airworthiness Inspection certificate.

______ Inspector issues operating limitations for Phase 1 test flight, and Phase 2 flying with passengers along with operating limitations for both phases. Go over these in detail with your inspector. Make sure you have the training privilege if you want it. These are simple privileges and limitations. Click here to download a copy (.doc file) of up to date limitations that any DAR or FAA Inspector can use and modify for your specific situation. They should be easy to understand. Make sure it is what you expected. This is the time to iron out any surprises or issues that need to be resolved. Changing things after your aircraft has been issued an airworthiness certificate is a big hassle. Make sure everything is right the first time through. Read it, understand it, and fix it if needed. If the inspector needs specific direction on these limitations, he can find them in FAA Order 8130.2F Change 2, page 143, paragraph 144. It can also be found at: http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgOrders.nsf/0/18b1d64bc8f90136862571d40072d8e1/$FILE/Order%208130F%20with%20chg%202%20incorporated.pdf

______ Inspector sign, dates, and stamps aircraft/engine logbook as part of the process.

______ Install the required Airworthiness, Registration, Operating limitations, and Weight/Balance (AROW) documents in the aircraft.

On the floor of the cockpit you can see the pink airworthiness certificate and the registration certificate. Also in this picture is the operating limitations and the weight/balance documents. These are all the papers required in the aircraft. I used the sticky US postal service customs declaration enclosures. UPS and FEDEX also have sticky document enclosures that work great for this. Some of you may have to sew a document enclosure onto the seat or find another innovative way to have these documents visible. Make sure it is waterproof and cannot possibly blow away in the wind.

Another view of the ballistic parachute placard and the aircraft papers attached to the floor of the aircraft.

______ Phase 1 flight test completed and information entered into aircraft logbook as required in operating limitations issued with airworthiness inspection.

You have completed the process and your aircraft is now a valuable N numbered aircraft.

Additional Resources

The FAA does have information that tells you how to register. This additional resource may be helpful. http://www.faa.gov/aircraft/.

EAA also supplies a handy kit with the FAA required carbon copy forms, “EXPERIMENTAL” sticker, fireproof metal aircraft data plate, some stickers you can cut out to help label things, and a checklist book at: http://shop.eaa.org/html/elsa_conversion_kit.html?cart_id=.

Rainbow Aviation also supplies a custom designed kit with the FAA required carbon copy forms, “EXPERIMENTAL” sticker, fireproof metal aircraft data plate, some stickers you can cut out to help label things, and a checklist book at: http://www.rainbowaviation.com/transition_kit.htm.

Sport Flying Shop also supplies N numbers online at: http://www.sportflyingshop.com/Placards/placards.html.

Additional Pictures

The FAA inspector broke out the camera to take pictures of the EXPERIMENTAL Weight-shift control aircraft he just inspected.

FAA Inspector, Adrian signing the salmon colored Airworthiness Certificate for Light Sport Aircraft.

The FAA Inspector stamping the aircraft maintenance logbook which he also signs.

FAA Inspector, Adrian turning over the paperwork for the N numbered trike.

Burning time in the N numbered aircraft to fly off my 3 hours of Phase 1 test flight.

Stopping at the 10,000 foot ceiling of the Sport Pilot new ceiling restriction.

Instrument panel with stickers on every instrument providing limitations for the engine and airspeeds. Note the 9,984 altitude on the digital altimeter.

Clouds building during the long flight to fly off the required time for the test flight while officially testing the limitations of the aircraft to mark in the logbook.

The new N number on the aircraft with the fuel tank marked in accurate 1 gallon increments left of N number.

Big cumulus clouds building after I landed from test flying the trike.

Article by Paul Hamilton,CFI, DPE (SPE / SPIE), one of the first persons to receive Sport Pilot and Certified Flight Instructor (CFI) certificates in weight-shift control, land category, as well as, Designated Pilot Examiner (DPE) for Sport Pilots. Owner of Adventure Productions, Paul Hamilton produces entertainment, educational, and training resources for Ultralight and Sport Pilots that you can purchase at AP-Store.com.

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"How to N Number Your Ultralight", by Paul Hamilton, CFI, DPE (SPE / SPIE)