Battery powered 103

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pictsidhe

Well-Known Member
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.
Good luck in court, if you even have that option. Losing will mean that you pick up the tab from the FAAs expensive lawyers and likely a stiffer penalty.

As I see it, the letter is a correct interpretation of the current law. What we need is a concession somewhat like the float allowance. That won't happen by being combative. The FAA has no obligation to even provide 103, it's a low hassle compromise. Make it hassle and they may cease to see it as a good idea.
The best we can do is politely request extra weight for pure electric planes and hope that they throw us a 30lb bone.

wanttobuild

Well-Known Member
You gotta aim high. I would like to see the regs change. It starts with a letter to your political reps.
That is the first step. Please hand write a letter to your rep. if you would like to see the regs change.
You must go over the FAA, or there ain't nothing gonna change.
Ben

wanttobuild

Well-Known Member
Might I suggest a common message conveyed to your political reps.
We must speak clearly.
Part 103 weight increase to allow electric flight.
When directed to do so, the FAA will change the regulation.

proppastie

Well-Known Member
Log Member
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.
so what's your problem....sounds like you have a great possible design....check out the "Electric Belite". After you prove it as a UL add more batteries and a N number and make it a light sport. Are you just going to type on the computer or are you going to build something.

pictsidhe

Well-Known Member
Politicians care about votes. How many votes will a change to 103, which Joe Public likely thinks is an awful idea, win them?

Armilite

Well-Known Member
If the FAA concludes that battery weight will not be counted or considered as fuel how many will go electric?
Ben
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I doubt it will make any difference. First, People aren't Buying $15,000 to$20,000 Gas Engine Part 103's. so they aren't going to Buy $30,000+ Electric Part 103's in any great numbers. Part 103 will still have the 254lbs Dry Weight and each Type of Airframe will have it's own Useful Load. Let's take the Pheinox 103 as a good example. It has the Highest Useful Load of 396lbs for Part 103, and uses a Hirth F-23 50hp and is 78lbs. So if Batteries count towards total 254lb weight, you only have 78lbs for the Electric Motor, Controller, and Battery Packs. The Avg True Part 103 Ultralights in the past used 26hp-35hp if using a Rotax. A Rotax 377UL(35hp). Dry weight: 38.4 kg (84.6 lb) (complete including Gear Reduction drive and exhaust system). To make that 78lbs they needed a lighter Belt Drive. The Rotax 277UL(26hp) Dry weight: 29.5 kg (65 lb) (complete including reduction drive and exhaust system). The Kawasaki 340 and 440 were used also. The Kawasaki 440(40hp) Engine with a Muffler. Dry weight: 49 lb (22 kg). You need to Add for Exhaust, Redrive. but I'm sure it will come in under 78lbs. So Electric Motor HP used would probably need to fall in the same 25hp to 40hp range. The More HP used the more Batteries/Weight needed for decent Flight Time. Flight Time wanted, I personally wouldn't want less than 1:15 with a 15min Reserve and will dictate Batteries needed for HP used. 78lbs minus Motor & Controller doesn't leave much for Battery Pack. If Battery Pack not Included in total weight, you are then taking away from useful Load. 396lbs - 235lbs (Pilot & Bags) = 161lbs for Battery Packs. You would have tp figure for each HP Engine. Yes, a lighter Person could carry more Batteries, but Manufacture have to cover a Weight Range to Maximise Sales. 1hr 15min = Weight? 1hr 30min = Weight? 1hr 45min = Weight? 2hr = Weight? You have to also remember your Flying Time just got Shorter with Electric and more Expensive. You have to also Replace them Expensive Batteries in about 7 years. Try to Sell an Electric Airplane needing New Batteries! wanttobuild Well-Known Member Politicians care about votes. How many votes will a change to 103, which Joe Public likely thinks is an awful idea, win them? So the regulation remains the same, LOL Everyone wants change but not willing to do anything about it. That is a flawed thought process. Ben jedi Well-Known Member So the regulation remains the same, LOL Everyone wants change but not willing to do anything about it. That is a flawed thought process. Ben So lets see if we can get some action here. We have an electric Belight flying with 254# empty weight if I read the posts correctly. I propose we start a fund to purchase more batteries and petition the FAA for a exemption for the additional batteries to provide an additional fuel reserve for safety purposes. I'lll wager$5 that we can get a 15 pound increase. Who will up the bid to 20.

If enough individuals apply for the exemption, the FAA will revise 103-7 or issue a new AC to cover electric flight. We (the users) need to supply the example and the need. The FAA isn't going to give it for no reason. There is a big difference between want and need. We all want it. How many need it bad enough to demonstrate a need. That is how we got 103. There were thousands of needs out there flying that the FAA had ignored for many years. And, there was more than one petition that had been turned away.

BJC

Well-Known Member
HBA Supporter
So the regulation remains the same, LOL
Everyone wants change but not willing to do anything about it.
That is a flawed thought process.
Ben
Another approach that might get favorable attention from the FAA is to build an airplane that, including a removable battery pack, weighs no more than a fully fueled Part 103 compliant ultralight and complies with all performance criteria. Register it as an E-AB. Demonstrate it at Sun n Fun and AirVenture. Get the EAA on board with a petition to the FAA.

The FAA really doesn’t like to be told how to do their jobs by a bunch of politicians. When presented with a reasonable, legally demonstrated, interpretation of their regulations, they are more likely to be receptive.

BJC

cptcliffhanger

Well-Known Member
Please explain.

BJC
first off, it's nonsense because it doesn't suit my needs.. that's reason enough as far as I can tell.

furthermore, I dont believe it in any way honors the intent of part 103. Obviously the wording in part 103 did not take electric power into consideration at all. it wasnt even considered a possibility. but certainly the most reasonable interpretation that honors the intent of part 103 would be that the empty weight would not include the batteries and that "5 gallons" of batteries would be allowed.. taking into consideration the intent of the 5 gallon limit was to prevent non trained pilots from getting too far from home or lost for 100's of miles. there is no chance in the foreseeable future that 5 gallons of batteries will get you farther than 5 gallons of petrol.

the letter implies that batteries are both fuel and not fuel at the same time.. it should be titled "schrodinger's fuel". if the battery IS "fuel" than it is not part of the empty weight. if the battery is not "fuel" than it wouldn't violate part 103 law to add additional "removavlabe" range extender battery "tanks". since part 103 explicitly prohibits adding additional tanks beyond the allowed "fuel" you wouldn't be allowed to carry additional batteries if batteries were defined as "fuel". but if it's fuel, its not part of the empty weight. so is a battery fuel or not?

the letter is nonsense..

the question that needs to be asked of the FAA for clarification is "is a battery a subset of "fuel" or is it not."

Hot Wings

Grumpy Cynic
HBA Supporter
Log Member
I dont believe it in any way honors the intent of part 103.
Go read the part 103 NPRM/history. The intent was for the FAA to wash it's hands of the whole ultralight movement and still comply with it's mandate to protect the public.

The FAA didn't, and doesn't, care what kind of power plant, or fuel, was/is used. It is true that they did limit the range by limiting the quantity of liquid fuel. Had electric been a viable option back then the FAA probably would have limited the KWh of the battery pack for the same reason. If we want to use a nuclear battery to power our part 103 the FAA wouldn't care one bit*, just as long as the empty weight of the vehicle including the shielding and it's Pu-238 is less than 245 pounds. The weight restriction was arguably arbitrarily chosen but the kinetic energy rationalization via weight and speed, has been a foundation of part 103 from the time of the NPRM.

It is what it is. If someone succeeds in getting the weight limit raised, and still keep all of the other part 103 good stuff, someone some where will put a statue of them in some aviation museum. :gig:
They mess it up in the process and the pitch forks and torches will be brought out. :speechles

*Other government alphabet agencies might come knocking.

cptcliffhanger

Well-Known Member
I've read it all.. I think youre missing my point. I'm not asking for a weight increase. just a decision on the definition of batteries that is analogous to what fuel is. usable fuel is not part of the empty weight of a part 103 legal aircraft. how they determined that batteries should be part of the empty weight IMO is nonsense and violates the intent of part 103. thats all..

wanttobuild

Well-Known Member
If I may ask a question

Who directs the FAA's activities?

wanttobuild

Well-Known Member
Answer
Elaine Chow, the turtles wife.
Write her a letter

BJC

Well-Known Member
HBA Supporter
first off, it's nonsense because it doesn't suit my needs.. that's reason enough as far as I can tell.
Your saying that it doesn’t make sense because it doesn’t suit your needs doesn’t help me understand your post.

furthermore, I dont believe it in any way honors the intent of part 103. Obviously the wording in part 103 did not take electric power into consideration at all. it wasnt even considered a possibility. but certainly the most reasonable interpretation that honors the intent of part 103 would be that the empty weight would not include the batteries and that "5 gallons" of batteries would be allowed.. taking into consideration the intent of the 5 gallon limit was to prevent non trained pilots from getting too far from home or lost for 100's of miles. there is no chance in the foreseeable future that 5 gallons of batteries will get you farther than 5 gallons of petrol.
The FAA’s stated purpose of Part 103:
[From the preamble to Part 103] These rules for ultralight vehicles are needed to achieve an acceptable level of air safety by reducing potential conflict with other airspace users and to provide protection to persons and property on the ground.
We agree that they did not anticipate electric powered ultralights. They wanted to be rid of a potential regulatory problem. They accomplished that by, in essence, saying “If you operate within the confines of Part 103, we will not subject you to aircraft regulations, and we will be rid of a potential PITA regulatory problem.” I think that that action was a reasonable and generous action. As I have posted, I think that there is a pathway to get a reasonable interpertation of a battery allowance within Part 103. The letter is a straight-forward legal interpretation of an existing regulation.

the letter implies that batteries are both fuel and not fuel at the same time.. it should be titled "schrodinger's fuel". if the battery IS "fuel" than it is not part of the empty weight. if the battery is not "fuel" than it wouldn't violate part 103 law to add additional "removavlabe" range extender battery "tanks". since part 103 explicitly prohibits adding additional tanks beyond the allowed "fuel" you wouldn't be allowed to carry additional batteries if batteries were defined as "fuel". but if it's fuel, its not part of the empty weight. so is a battery fuel or not?
A battery is not fuel.

the letter is nonsense..
Whether or not one likes an answer to a specific question doesn’t mean that the answer doesn’t make sense.

the question that needs to be asked of the FAA for clarification is "is a battery a subset of "fuel" or is it not."
Please submit your question to the FAA, and post their reply here.

BJC

pictsidhe

Well-Known Member
I think it would be reasonable to petition the FAA for an extra 30lb allowance for battery powered 103s. I'd put my name on that. I don't feel entitled to anything, though.
I wouldn't write to a politician, as I doubt many of them would look at 103 favourably once made aware of it, let alone be willing to widen its scope.

I think that anyone getting antsy with the FAA and their 103 gift is at serious risk from pitchforks once the FAA have finished with him...

The way I've read the Belite thread, it exceeds 254lb with batteries. I think that the EMG-6 does comply.

cptcliffhanger

Well-Known Member
A battery is not fuel.

BJC
Perfect. then I'm not limited to 5 gallons then! I can carry as much as I want

Hot Wings

Grumpy Cynic
HBA Supporter
Log Member
Perfect. then I'm not limited to 5 gallons then! I can carry as much as I want
Yes, you can carry as much as you can/want. That is called cargo and there is no limit to the MTOW of a part 103 other than that enforced by Mother Nature. But if it's required for flight, or bolted down, then it becomes part of the vehicle.

Have to find a productive HBA thread to read..................

pictsidhe

Well-Known Member
It seems you could carry batteries as cargo, but if you use them or connect them in flight, they would not be cargo. So looks like you could swap out on the ground before flying a return leg home. That trick doesn't legally work for extra gas where all fuel, usable or not, must be under 5 gallons. Even empty cans are verboten. I am puzzling over how to make my wing tanks double as removeable gas cans thanks to that. There is no volume or weight limit to batteries. But currently, their weight must be included in the 254lbs. Build a 54lb ultralight, you can have 200lb and 10 gallons of batteries.

I saw one ultralight where the starter was a cordless drill. Snapped into a tool clip for storage. Unusable in the air. FAA compliant.

Working within 103 can require a bit of thought to be legal and get the performance you'd like. Most recent ultralights are more powerful and draggier than early ones as that really helps climb. Draggy is obviously a poor idea for electric with it's very real energy limitations. I'd be looking at something like the Carbon Dragon to convert, rather than a Belite. The EMG-6 is a ready made solution.

spaschke

Well-Known Member
Perfect. then I'm not limited to 5 gallons then! I can carry as much as I want
right. It's called a second battery pack in your backpack. You have a small main battery pack in the plane, removable or not, that can demonstrate the plane. Carry on a backpack full of batteries, secure it and plug it in to the plane for decent range.