wanttobuild
Well-Known Member
If the FAA concludes that battery weight will not be counted or considered as fuel how many will go electric?
Ben
Ben
Battery powered 103
- Thread starter wanttobuild
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jedi
Well-Known Member
Lots! It would be a game changer.
pictsidhe
Well-Known Member
The FAA has already decided that batteries aren't fuel. They must be included in the 254lb. Costs of big battery packs are offputting...
wanttobuild
Well-Known Member
where is that in the regs
Are you referring to batteries that are permanently mounted?
wanttobuild
Well-Known Member
Yes I do, Permanently Mounted being the key phrase. Its gonna change next year.
do you have a link to that
wanttobuild
Well-Known Member
It hasn't happened yet, but its gonna.
How is the FAA going to distinguish between Permanently Mounted and 'securely affixed'?
I sure don't want to be flying around with 50 or so pounds of battery that is just setting on a shelf, or even strapped down with Velcro. IMHO if it takes a tool other than human hands to remove, it's Permanently Mounted. I suspect the FAA will see it that way too.
I'd be satisfied if the FAA just let us count 1/2 of the 5 gal fuel weight against the batteries. That amount can be argued as being within the spirit of the original weight range. That is the average of a liquid fueled 103 crashing with a full, or an empty tank.
I sure don't want to be flying around with 50 or so pounds of battery that is just setting on a shelf, or even strapped down with Velcro. IMHO if it takes a tool other than human hands to remove, it's Permanently Mounted. I suspect the FAA will see it that way too.
I'd be satisfied if the FAA just let us count 1/2 of the 5 gal fuel weight against the batteries. That amount can be argued as being within the spirit of the original weight range. That is the average of a liquid fueled 103 crashing with a full, or an empty tank.
oriol
Well-Known Member
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.
I guess the original spirit of Part 103 would remain unchanged with that modification.
Oriol
TFF
Well-Known Member
Removable to charge is not the FAAs point. The tank is the tank. That the fuel is stuck in the tank is tough Nuggies. And actually it's not. Discharged it is empty and you have to add to charge. The question comes does the FAA go against the FAI where the world records are counted. FAI has batteries part of airframe. Not that everything is to FAI, but easy way out for FAA to call it.
Can anyone point to any indication that the FAA is considering this issue?
BJC
BJC
radfordc
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Here is a link to the FAA letter:
https://rainbowaviation.company/wp-content/uploads/2017/08/elect-103-battry-def.pdf
https://rainbowaviation.company/wp-content/uploads/2017/08/elect-103-battry-def.pdf
cptcliffhanger
Well-Known Member
that letter is complete nonsense.
radfordc
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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.
*We don't know the exact wording of the request because it is not included but from the response it is reasonable to conclude that they were asking that any amount of battery weight be excluded from the empty weight. "Permitting no restriction on the amount of batteries that may be carried aboard the aircraft as part of the vehicle's useful load would clearly contradict the original intent of the regulation."
They have a defensible position that the battery is the fuel tank, and the electrons or electronic "charge" is the fuel. Because an empty fuel tank is considered part of the airframe, they can make a clear case that an empty (uncharged) battery should be part of the airframe just like an empty fuel tank.
The fact that an electrical "charge" fuel doesn't weigh the same as gasolline is not their concern.
Don't get me wrong, I would really like to see a battery powered ultralight become an easily attainable thing, but the argument is not whether the battery should be weighed, the argument is whether 254 pounds is a legitimate and realistic weight for a small entry level air vehicle.
A 254 pound empty weight Colomban Cri-Cri crashing at 120 MPH will make a much bigger hole in the ground, or crash through somebody's car more easily, than a 500 pound empty weight Quicksilver crashing at 50 MPH. So if public safety is the overarching goal, then the FAA should be better off talking about wing loadings, crash speeds, total amount of foot-pounds of energy, and drag-limited velocities for defining unlicensed ultralights.
We do have to remember that Part 103 is quite a gift to the flying public. Any idiot can go out and do whatever they want, with absolutely no licensure or design review, no operational regulations, etc. as long as they simply stay away from the rest of everybody else in the air and on the ground. That should not be taken lightly IMHO. Yes it is probably safe to raise the weight limit a little bit to allow "fat" ultralights to operate. But the category of aircraft that can operate this way (light, slow, simple air vehicles tthat cannot do a whiole lot of damage) needs to stay as it is.
The fact that an electrical "charge" fuel doesn't weigh the same as gasolline is not their concern.
Don't get me wrong, I would really like to see a battery powered ultralight become an easily attainable thing, but the argument is not whether the battery should be weighed, the argument is whether 254 pounds is a legitimate and realistic weight for a small entry level air vehicle.
A 254 pound empty weight Colomban Cri-Cri crashing at 120 MPH will make a much bigger hole in the ground, or crash through somebody's car more easily, than a 500 pound empty weight Quicksilver crashing at 50 MPH. So if public safety is the overarching goal, then the FAA should be better off talking about wing loadings, crash speeds, total amount of foot-pounds of energy, and drag-limited velocities for defining unlicensed ultralights.
We do have to remember that Part 103 is quite a gift to the flying public. Any idiot can go out and do whatever they want, with absolutely no licensure or design review, no operational regulations, etc. as long as they simply stay away from the rest of everybody else in the air and on the ground. That should not be taken lightly IMHO. Yes it is probably safe to raise the weight limit a little bit to allow "fat" ultralights to operate. But the category of aircraft that can operate this way (light, slow, simple air vehicles tthat cannot do a whiole lot of damage) needs to stay as it is.
I think if people can use 90 lb engines in their ultralights, and still make the limit (?), then some kind of electric ought to be quite feasible. The electric motor is probably going to weigh 5 or 10 lbs. If you add another 10 for wiring and battery management, that leaves 70 lbs for batteries. Joby had a 20 hp (at 2,500 rpm!) motor that weighed a bit over 7 lbs, and that was several years ago. Still, the FAA ruling is absurd. Particularly since I'm fairly certain the fire risk from a battery powered plane is probably less. No gasoline to splatter and flow all over the place. OTOH, I suppose if they counted batteries as fuel, they might be restricted to 30 lbs!
