by Jon Thornburgh
June 2005

On June 3, 2005 two airplanes were the first Quicksilvers to be placed into the "Experimental Light-Sport Aircraft" category. Quicksilver is one of the largest ultralight and experimental aircraft manufacturers in the country.

FAA Aviation Safety Inspector Van Stumpner performed the experimental inspection at Page airport, Oklahoma, about 15 miles west of FAA headquarters in Oklahoma City. The two aircraft inspected were a Quicksilver Sport 2S and a Quicksilver GT-500. 

The Sport 2S is a strut-braced version of the famous MXL Sport, which is a cable-braced, side-by-side, two-seat, open-cockpit, tube and fabric ultralight trainer. The Sport "N"-number is N103Q.

The GT-500 (N107Q) is a larger, two-seat tandem airplane. Ten years ago Quicksilver received a type certificate for the GT-500 in the "Primary Category," which is an FAA-approved aircraft manufactured under Federal Air Regulations part 21. However, this was the first GT-500 to receive an "Experimental" certification under the new FAA Sport Pilot regulations.

Both aircraft were previously registered and flown as ultralight trainers and demonstration planes at the April Sun 'n Fun airshow in Lakeland, Florida.  The GT-500 was featured on the cover of the June issue of UltraFlight. 

After the airshow the airplanes were trucked back to the factory in Temecula, California, and refurbished in preparation for the experimental certification. Paperwork was submitted to the FAA, and the required notices and placards were applied to the airplanes.  The eight-gallon fuel tank in the GT-500 was replaced by two tanks totaling sixteen-gallons.

An invaluable aid to preparing the Quicksilvers was a "Forms Packet" available from the EAA especially for ultralight vehicles that are transitioning to Experimental Light-Sport aircraft. The "E-LSA Conversion Kit" is available from the EAA at  http://www.sportpilot.org/lsa/transitioning_ul_aircraft.html, or by calling 877-379-1232. The cost is $13 (plus shipping) for EAA members or $20 for non-members.

For those readers who not familiar with experimental aircraft a quick review may be in order. Until last year there were eight categories of "Experimental."  "Amateur-built" is the most familiar. The other seven, lesser-known categories are "Exhibition," "Compliance with Regulations," "Crew Training," "Air Racing," "Market Survey," "Research and Development," and "Operating Primary Kit-Built Aircraft."  These categories are listed in FAR part 21.191 and may be seen on the "Regulations" link on the FAA web site at http://faa.gov/regulations_policies/faa_regulations.

On September 1, 2004 the new "Sport Pilot" initiative became effective. In addition to creating a new "Sport" pilot certificate, the rule established a new category of Experimental known as "Experimental Light-Sport Aircraft," abbreviated "E-LSA."  The regulation which establishes E-LSA is FAR part 21.191(i), which creates the ninth Experimental category.

Part 21.191(i) is further divided into three sub-categories, sometimes referred to as "Dash One," "Dash Two," and "Dash Three," for part 21.191(i)(1), 21.101(i)(2), and 21.191(i)(3).

"Dash One" refers to E-LSA which are "former ultralights."  Under the Sport Pilot rule, all two-seat ultralight trainers and all single-seat ultralights which do not comply with FAR part 103 (ultralight regulations) must be inspected by an FAA representative and transformed into E-LSA by January 31, 2008. After 2008 these type of "fat ultralights" will no longer be allowed to fly unless they are Experimental light-sport aircraft.

The Quicksilver airplanes discussed in this article are "Dash One" E-LSA, sometimes referred to as "former ultralight" E-LSA.

The "Dash Two" E-LSA are Experimental aircraft that are built from a kit, and the kit is based on a "Special" light-sport aircraft template.

The "Dash Three" E-LSA are aircraft which are "downgraded" to Experimental after having originally been constructed and certified as "Special light-sport aircraft."

Special light-sport aircraft (S-LSA) are factory built, ready-to-fly aircraft constructed in accordance with new "ASTM" standards created by the Sport Pilot rule. At present only a handful of S-LSA are in existence, and there are no "Dash Two" or "Dash Three" E-LSA in existence.

"Dash One" E-LSA, like the Quicksilvers in this article, are not required to meet S-LSA ASTM standards of construction or instrumentation. The inspector who examines Dash One E-LSA must simply determine that the airplane has the proper markings, the necessary paperwork (registration, weight-and-balance, etc.) and is in a "condition for safe operation." 

The only instruments required are an altimeter and airspeed indicator if the airplane is to be used for pilot training. Dash One E-LSA may be used for pilot training until January 31, 2010.  After 2010 they may only be flown for personal use. Although not required, Quicksilvers N103Q and N107Q were fully equipped with RPM indicators, temperature gauges, warning lights and flight instruments.


At the end of May 2005 the airplanes were trucked from Temecula to Page airport in Oklahoma. For the rest of this year they will be used by the FAA for their Sport Pilot Examiner seminars. The FAA is also using an experimental Pegasus weight-shift trike and an Infinity powered parachute.

All experimental airworthiness certificates are accompanied by a set of "Operating Limitations."  The Ops Limits for the Quicksilvers required a "Phase I" test flight period, which was accomplished in the vicinity of Page airport.  Todd Ellefson, Quicksilver Director of Marketing, test flew the Sport 2S and Quicksilver flight instructor Jon Thornburgh test flew the GT-500.

Most of the provisions of the Quicksilver Operating Limitations are similar to Experimental Amateur-Built aircraft limitations, but there are several notable differences. Most significant is that these Quicksilvers may be used for commercial Sport Pilot flight training until January 31, 2010, whereas Amateur-Built aircraft cannot be used commercially. Another provision is that N103Q and N107Q cannot be flown over "densely populated" areas, whereas most Amateur-Built aircraft do not have such a restriction.

One of the major differences between Experimental Amateur-Built aircraft and Experimental LSA is that the "majority" of the construction of Amateur-Built aircraft must be done by the buyer of the airplane kit. This is commonly known as the "51% rule."  The 51% rule dictates that the factory cannot deliver an airplane that is more than 49% complete.

Under the Experimental LSA rule, the buyer does not have to build a majority of the aircraft. In fact, the airplane could actually be manufactured at the factory and delivered 100% complete. The two Quicksilvers which are the subject of this article were constructed at the factory by A&P mechanic Terry Johnston. The registered owner of the aircraft is Quicksilver Manufacturing Company, not an individual owner/builder.  

The builder of an Amateur-Built airplane is entitled to a "Repairman Certificate" if he requests one. This certificate allows the holder to perform the annual "Conditional Inspection" required by the FAA.  However, since no single person is required to build the majority of an E-LSA the Amateur-Built Repairman Certificate is not available to E-LSA owners.

If the owner of an E-LSA wants to perform the Conditional Inspections he must attend an FAA sanctioned 16-hour maintenance course and obtain a "Repairman-Inspection" certificate. If he doesn't attend the course the Conditional Inspection must be done by an A&P mechanic.

Paragraph 27 of the Operating Limitations for N103Q and N107Q reflects this particular prevision regarding maintenance. It says, "An Experimental LSA owner/operator as a repairman for this aircraft under 65.107 or an appropriately rated FAA-certified mechanic may perform the conditional inspection required by these operating limitations."

If an E-LSA is used commercially for training, which is allowed under the Operating Limitations until January 2010, the aircraft must have a "100-hour" Inspection, in addition to the annual Conditional Inspection.  As noted above, the Conditional Inspection may be done by a person who attends a 16-hour maintenance school.  However, a person who attends the 16-hour school is not entitled to perform the 100-hour Inspection.

The 100-hour Inspection on light-sport aircraft must be done by a repair station, an A&P mechanic, or a person who attends a 120-hour maintenance school and obtains a "Repair-Maintenance" certificate.  Unlike general aviation aircraft that are used commercially, the annual Conditional Inspection cannot be substituted for the 100-hour Inspection. Unfortunately, at the present time there are no FAA-approved 120-hour maintenance courses, so the 100-hour Inspections on the Quicksilvers will have to be done by an A&P mechanic.

For more information on the Repairman certificates see FAR 65.107.

Quicksilver would like to give special thanks to Inspector Van Stumpner for his extensive assistance helping Quicksilver prepare for the Experimental inspection. Van worked overtime to see that the aircraft were ready for inspection in time to be used for the FAA Sport Pilot Examiner seminar that began on June 7th, only four days after the Quicksilvers received their Airworthiness Certificates.