Yes I do, Permanently Mounted being the key phrase. Its gonna change next year.If would certainly make electric UL's more feasible. Do you have any reason to believe the FAA will reverse it's current position that batteries are part of the empty airframe weight of a UL?
My guess is that the FAA might follow the same rationale that goes with electric bicycles which had batteries that are secured and can be easily removed without tools to be charged at home. Most Part 103 aircrafts are not stored in airports but in hangars without electricity.How is the FAA going to distinguish between Permanently Mounted and 'securely affixed'?
Possibly. It is only a legal interpretation and not a regulation. The proper course of action if you disagree with it is to fly a UL that is in violation and ensure that the FAA gives you a citation. Then you will have the standing to take them to court and prove that it is "nonsense". Short of that you can just ignore the letter, fly like we have always done, and assume that the FAA will continue to show benign neglect toward fat ultralights.
Makes perfect sense to me. It was written by an attorney that probably doesn't fly, other than commercial, in response to a request that was outside the intent of the part 103 regulation. IMHO Mr. Greer came to the correct conclusion based on the request. If the request had been more reasonable*, such as asking that we be allowed a 30 pound add to the 254 to match the MTOW of a liquid fueled part 103 then the ruling might have been in our favor.