Can a CFI Use an Airplane Experimental Light-Sport Aircraft (E-LSA) For Flight Training and Rental?

Or in other words, can I use an airplane experimental light-sport aircraft (E-LSA) for flight training and aircraft rental?

FAA Rule 91.319 spells it out for you. We’ll take a look at pilot training and the Operating Limitations for Special-Light Sport Aircraft (S-LSA) vs. Experimental – Light Sport Aircraft (E-LSA) vs. Classic Standard Category Aircraft.

For the differences in Operation and Maintenance see: Operation and Maintenance.

Flight Training in Special Light Sport Aircraft (S-LSA) and Standard Category (Classic) LSA

S-LSA and Standard category LSA

Flight training is typically done in a S-LSA or a Standard Category LSA. These can be rented out to the applicant/student during the flight training and to the applicant/student during Solo.

Additionally, they can be rented out to qualified pilots and those who have already received their pilot certificate (sport or private). This is what you typically see at flight schools and used by CFI’s for flight training.

Experimental Aircraft E-LSA (or any Experimental Aircraft)

A common question is: Can an E-LSA be used for flight training?

The answer is, Yes

And, you can charge for the flight training. But, you CANNOT charge for the airplane rental/use. Let’s look at this in more detail since there’s typically a big misunderstanding about this.

Here is the FAA rule:

91.319 Aircraft having experimental certificates: Operating limitations

(a) No person may operate an aircraft that has an experimental certificate (2) Carrying persons or property for compensation or hire.

First it needs to be understood that based on the FAA, “Flight Training” is NOT Carrying persons or property for compensation or hire. Flight training is flight training.

However, renting out an aircraft is “for compensation or hire” of the aircraft.

Therefore: Flight training is allowed (not disallowed) in an Experimental aircraft if the owner owns the aircraft since it is not being rented out. Renting an aircraft is “commercial operation”. The CFI can charge for his flight instruction time. This is for any experimental aircraft owned by anybody including the owner OR a CFI who owns the aircraft.

If you’re looking for an FAA Rule that spells out what you CAN DO…you’re not going to find it. FAA Rules, like 91.319 typically spell out the limitations and what you CANNOT do.

Now, some common sense should prevail here, the CFI needs to charge a reasonable rate, similar to others in the region, so as not to hide the aircraft rental cost into the flight instruction rate.


If anyone wants to confirm this with FAA paperwork, see:

Flight Standards Information Management System -specifically Volumn 3 Chapter 11 Use of Airplanes Issued Experimental/Exhibition Airworthiness Certificates in Flight Instruction for Compensation or Hire.

This also discusses how to get a LODA to be able to charge aircraft rental for an E-LSA or any other experimental aircraft.