Modernizing the Ultralight definition

I have had pretty much the same thoughts on the weight limit.  It would be nice to have an inexpensive and safe singleplace airplane to practice in and enjoy between flying lessons.  When I start taking lessons again, I don't anticipate being able to afford to fly often.  I am planning to set up a flight simulation program to give me a way to go through the motions.  The "ultralights"  that most appeal to me would be a real stretch when it comes to the weight limit. I would like to stress the wing spars the equilivant of utility class and add enough power for resonable climb performance well margined above stall angles of attack.  This puts us back to eyeballing "fat ultralights", which if they are still flying, should be certificated now as Light Sport Aircraft.  They are so light that they shouldn't really be catagorized there, but there is no "Too Light Sport" category.

I think it would be difficult to build a safe ultralight that actually fits the specs and it has to to qualify to fly un-certificated.  As for cross country, I don't think Part 103 was ever intended for that.  Regardless of the tank size, my interest is in staying around the patch.

As much as I would have liked to increase the capabilities of Ultralights, with the advent of the Light Sport Aricraft regs, "it ain't gonna happen".  The fat ultralights had to become Light Sport Airplanes and the chances of the FAA redefining Ultralights to be like Light Sport Airplanes won't happen in my lifetime.  If you want to fly a more capable Ultralight you need to think Light Sport.  And if you want to fly the cheapest more capable ultralight, you need to think ELSA and build it yourself.  In this day and age, Ultralights will have to conform to Part 103 or they won't be legal.

Light Sport Aircraft is one set of FARs, Ultralights is another.  Any FAR can change.  I look at LSA as mainly two place airplanes, Ultralight as single place.  Most "fat" Ultralight were two place trainers.  Now that we have the LSA category, I think it is time to review the ultralight category with an eye toward safety and practicality.  As for X-country utility, I think every airplane should be able to do at least a 100 mile X-country safely, otherwise you are never going to be able to take your project to most fly-ins.

Dean, I realize that LSA and ultralight are covered by different protions of the FARs and that FARs can be changed.  What I am saying is that FARs are written or changed by the FAA, and the FAA just ain't gonna change Part 103 any time soon.  They feel that they have covered the subject by implementing the LSA regs.  (Not all SLAs are two place) The United States Ultralight Association (USUA) has tried to get the weight limitation for Ultralights changed to permit the installation safety enhancing devices, such as brakes, to be added to current ultralight designs.  The FAA wouldn't hear of it, so I have some very serious doubts that they will even consider increasing the fuel capacity limitation so we can fly to the next fly in.

But, I'm not trying to be a wet blanket - if you want to try to get the definition of ultralights changed to permit a more useful machine, the best place to start is with a letter to the FAA requesting the changes we'd like to see.   I'd be willing to co-sign such a letter, but you need to make a very strong case, and improved safety is more likely to get a positive reception from the FAA.

You might be interested to see the recent UK de-regulated category. It's designed to remove regulation of planes that have a low kinetic energy, and hence can do little damage. Single-seat only; 115Kg (253 lbs) weight empty; maximum wing loading 10Kg/m2 (2 lb/ft2); max stall speed 35 kts.

Most of the designs that meet this reg. are the usual 50-60 kt machines. But we've stretched it a bit further... to about 125kts. (see more at www.e-Go.me)

It's great to have such freedom - although frustrating that we can't fly it as an ultralight in the US.

Tony Bishop

Cambridge UK

 I couldn't agree more, as a former manufacturer of an Ultralight design (Wren) it is my opinion that US manufacturers are at a distinct disadvantage. Its impossible to compete with a Canadian manufacturer, when they can fly their "Ultralight" with a "C" number at air shows competing against a part 103 legal Ultralight. In addition, my Ultralight was designed with a Integral roll cage structure and an all composite "Crash Tub" designed for energy absorption in the FWD crash case. Yes, this structure doubled as primary load path, but it was stronger that that needed to carry normal flight loads. Why can't that weight be deducted from the empty weight? its there purely for safety?

Its pretty apparent to me that Part 103 is designed for the safety of the people on the ground, probably a result of the publics "Chicken Little Syndrome" They want to limit the impact crater and the fireball!!   But if you want to talk safety and include the pilot, what's wrong with adding more weight so a more reliable (4 stroke) engine can be used and a higher margin of safety can be built into the structure. This is the only category I have seen where efficiency is penalized. Design a clean airplane and you can only have 18 hp , try climbing on  hot day at altitude with a 250 lb pilot with that engine.

Yes I would like to see 103 change, not only for the reasons listed, but so we can get back to the business of building Ultralight again in the US.

Good discussion.  Don't forget that we can build and fly pretty much whatever airplane we want in the USA.    This debate is really about what kind of airplane we're allowed to fly with zero training and almost zero government regulation of any kind.  Personally I think that having part 103the way we do is something of a miracle, and I'm very thankful for it.  It's nice to dream of even more freedom, but particularly with the LSA regs in place, I agree with Gerald that "it aint gonna happen". 

We are certainly better than most countries, Canada and Austraulia being the exceptions. I have a good friend in Japan (Hello Yuki!!) who just went through 3 years of jumping through government hoops so he could TEST HOP his fisher FP 303. Yuki is a retired Maintence engineer for ANA airlines, and even he had trouble complying with the Japanese regulations. the more onerous the regulations, the less and less the innovation. A hell of  lot of good ideas trickle up from low end aircraft. Unreasonable and restrictive regulations limit the creativity of the designers. I am an experienced aircraft engineer (30 plus years) I have always loved designing Ultralights however. This has served me very well in my "Day Job" because I understand that saving weight starts with the first ounce.  But the problem is our  rules really do penalize efficency.

In Australia our lighter <150kg class is now just as regulated as the heavier classes. back when i first started we had no rego or licence just limited to 400lbs all up and restricted in height. some time back we had both the empty weight and height distance restritions lifted and now have to carry rego numbers and get a certificate and suffer mandatory membership with the RAAus, costs me couple of hundred bucks each year. and i still basically do the same type of flying as back then.

If you up your weight bet it will come with a whole heap of unwanted options. be carefull!

steve

Messages number 9 and 11 make some very good points:

1.  We currently enjoy a great deal of flying freedom and limited regulation

2.  Be careful what you ask for - you may get it.

3.  The law of unintended consequences is still operational.

Fly safe....

My view – and correct me when I am in error – it that part 103 was created to deal with the getting out of control  world of powered hang gliders in the 70s.  They were getting more sophisticated and able to fly higher, faster and carry more than seemed prudent. There is no doubt the regs are there to protect the terrestrial public.  Now part 103 –lots of accidents during early flights -  didn’t allow for training aircraft and the 2 seat exemption was allowed specific to training.  Fast forward – 2 seat aircraft being sold to and operated by anyone. 

Since no one was checking , the engine sizes moved up too -  277 became a 377 became a 477 became a 503 became a 582, became a 4 cylinder VW.  We are a creative lot and the quest for more power is practically in our DNA.  (what gave us 103) So both weight and max cruise were busted.

And to service that larger engine – bigger fuel tanks……. Another bust.   

So now we have a large percentage of UL aircraft operating outside the UL limits.  Can you say 90% of fixed wings?

So instead of the FAA doing ramp checks and grounding most ULs, the hard work of a lot of people gave us a pathway – ELSA for the chubbies and 2 seaters and LSA/SP to fill in the gap between the UL and traditional GA world.  Legitimizing the whole community of UL –like aircraft amd their pilots  Closing the gap between toys and real airplanes in many people’s eyes.  AND they kept the part 103 regs intact.  It could have easily gone away when LS was created.   We thank EAA, AOPA, and hundreds of others who advocated for this. 

So designers, you now have a plethora of aerospace materials to develop real aircraft that can fly in the 103 category.  Yes, they will be more expensive but look at the price of aluminum over the last 5 years.  Support the lighter engine manufacturers by buying them.  More sales = more money and more R&D to bring up the reliability and down the price.  There are at least 2 engine manufactures that have shaved 30# off of a Rotax.   Rotax has moved to the 900 series engines leaving the smaller engines to fend for themselves.  Opportunity for others to fill the gap.  But there has to be a gap to fill.

Thinkers like James Wiebe and others http://www.beliteaircraft.com/     are starting to take up the gauntlet to resurrect part 103 aircraft design.    Now designers really have to pay attention to the regs – unlike before where they quoted compliance knowing all too well it was not true. 

I view LSA as a challenge to re-invent the 103 aircraft world.   And thank those who didn’t let it go away.

I don't remember any discussion of FAR 103 going away during the LSA discussions.  It seems to me that LSA was a natural hardware outgrowth of the Sport Pilot rule that made it less costly and faster to learn to fly, with some added restrictions.  LSA was supposed to bring us lower cost aircraft for these sport pilots, although I don't see that happening.  I am not aware of any new LSA, whether e or S, that are cheaper than used two place airplanes, some of which can be re-registered in the LSA category.

Ultralights are clearly just a single place category, as they should be.  LSA has removed the two place "ultralight" shenanigans that used to go on.  But now I believe that ultralight aircraft are an endangered species.  The Belite is a case in point.  In order to cover the entire aircraft an expensive compromise had to be made, a carbon wing and a small 2 cycle engine to stay in the 254 lb. weight limit.  I don't think a $30,000+ ultralight is going to be an economic success, but then again I don't think $130,000 LSA aircraft are going to be an economic success either.  I have talked to several dealers in the LSA business and they have told me that many LSA manufacturers have sold less than 10 aircraft and most of those were to dealers who are now stuck with them.

A walk around the ultralight area at AirVenture 09 was insightful.  Half of the commercial booths were empty and the rumor was rampant that if the ultralight area didn't see more activity and traffic at the grass strip, it would be shut down and the space turned over to some other EAA activity.

I believe that a robust future for ultralight aircraft will come about when a useful, structurally uncompromised aircraft can be built for a reasonable cost, even by a commercial venture.  I don't see $30,000+ ultralight aircraft growing the ultralight movement.

the rumor was rampant that if the ultralight area didn't see more activity and traffic at the grass strip, it would be shut down and the space turned over to some other EAA activity.

I can say there has definitely been no conversation at a staff level about shutting down the ultralight area.

  I am not aware of any new LSA, whether e or S, that are cheaper than used two place airplanes, some of which can be re-registered in the LSA category.

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Just to correct yet another rumor before it becomes "common knowledge".  A certicated aircraft can not be 're-registered in the LSA category'.   Once a certificated aircraft, always a cretificated aircraft.  Some light certificated aircraft can be flown with a light Sport Pilot ticket if they meet the LSA criteria, but they remain a certificated aircraft required to meet all the normal regulations regarding air worthiness and maintenance.

I stand corrected on the TC category for LSA aircraft.  The premise remains that there are many old two place TC'd aircraft that can be operated as if they were LSA aircraft for much less cost than new LSA aircraft on the market today.  The irony is that American Champion has brought the 7AC champ out of mothballs and is selling it as if it were an LSA, although it is produced under its original TC.  No wonder I am so confused.  :-)

As for rumors of the demise of the ultralight area, rumors are just that, rumors.  Even though an EAA spokesperson says that there is no truth to the rumor, there was still discussion of the future of the ultralight strip considering the obvious decline in activity and the fact that commercial display area was half empty, as it was last year, which does not bode well for the future of ultralights.  It appears that powered parachutes and helicopters are healthy, as most of the commercial displays were for powered parachute vendors or engines and there is definitely an uptick in helicopter activity on the  flightline.  My premise is that the decline in ultralight aircraft activity is very noticeable at AirVenture.  I would like to see that change.  I don't think $30,000+ ultralights will foster that change.  I think a revision of FAR 103 would, so that useful, economical, safe ultralight airplanes could be produced.

RE the UL area at AV09:   I had heard that manufactures had not chosen to exhibit at the UL area as they had in the past.    Case in point:  Fisher with nearly half their line as UL,  Belite-specifically going for the UL market also not there.   My question is why have some of the manfs moved to the homebuilt section ?   Do they view themselves as more homebuilts than ULs?   Does AV need to rethink the layout a bit to accommodate the changing stratification that LSA has initiated  ?   Now that LSA has created a “mainstream” acceptance are the UL manufactures having an identity issue?   The emptiness of the UL area speaks of major changes.     Wasn’t the UL area created to accommodate the huge volume of aircraft coming to AV and not able to fit in with the other arrivals? 

RE: 103.  Aren’t we glad that the FAA worked with the industry and not said – either or.  Pick one.  And gone the Canadian direction.

Thanks Jim. I'm coming to this discussion a little late. I agree it would be nice to have more robust and capable ultralights but it ain't going to happen without increased requirements for inspection and training.  Do you all want that?

On the price of equipment I would point out that even the simple trikes and PPC's cost $15K and up when built according to FAR103.   One would naturally expect fixed wings to cost even more (except in the case of homebuilts like the Legal Eagle).   Even if it could be done, raising the weight and speed limits will have the effect of causing ultralights  to become as expensive as the 2-seat trainers that have transitioned to ELSA.  It won't make them cheaper.

New technology and invention will improve the capabilities of ultralights.  Already, the legal ultralights of today easily  exceed the performance and dependability of their forebearers.

I'm sorry it will never be promised that all 103UL's can fly 100 mile XC.  My experience with a legal fixed wing indicates about 70 miles was a practical limit.  Preferably 103 ultralights should be built so they can be transported easily by trailer.

When you consider the mind set of government officials, it is quite amazing that we even have FAR103. 

I have to take issue with those saying an ultralight can't be built strong enough under the current regs.  It takes some careful work and planning, but they have been built for years.  The Skypup design is over 25 years old and it is stressed to +6Gs, Challengers have been around for years and seem to be doing ok, I haven't heard of any Kolbs breaking up in mid air, and he Banty seems to be doing just fine.  The plans and the completed planes are out there, and we have the option to design and build our own with no ifs, ands, or buts from the FAA.

I suspect the weight, fuel and speed limits are concerned with protecting people on the ground.  If you do fall out of the sky, a 254 lb airplane with 5 gallons of fuel isn't likely to do much damage.  And it is fairly easy to design an airplane that will not lose it's wings as speeds up to 63 mph.

When you look at how badly FAR103 was abused by all those with fat ULs, I am very pleased and surprised that the FAA didn't kill ultralights long ago.  They cut us way more slack than anyone had reason to expect.  If 103 is too restrictive, light sport is there and waiting.  Production light sports don't come cheap, but there is the option to build one, the "E" does stand for experimental after all.  And the cost savings continue because you can do your own work on the plane.

I think the thing that really needs to be addressed about Ultralights today, is the lack of airplanes to get training in.  the FAA really killed ultralight flight schools, and it seems to me they are now doing too little, too late to make up for it.  Granted, people were abusing the ultralight trainer exemption, but it seems to me that enforcement would have been a better option that eliminating the option for training in type.  Now that they are finally backtracking to some extent, most of the outfits that were providing training are in the process of phasing it out.  Ity also sounds like it would be very difficult for someone to get legal airplanes for training under the proposal that is kicking around now, if it happens.  I don't know, I may not understand the proposal *** well as I should though.  If anyone has insight on this, please chime in.

anyway, just my two cents worth.