# Chip is making progress with the Merlin Lite

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#### jazzenjohn

##### Member
An ultralight that weighs 253.99999999 pounds is absolutely less than 254 pounds and so complies with the reg. In the real world the bigger issue is whether you will run afoul of the FAA. All the people in the FAA are pilots and they are focused on what is best for aviation in general. If someone is buzzing houses and flying over stadiums and crowds of people and making a nuisance of themselves and generating many complaining phone calls, They are concerned and something will happen especially if there is an accident. If you're the one doing it, whether you are over or under the weight limit you will likely be in trouble because your actions are ruining aviation for all other pilots. If you are a conscientious pilot that isn't flaunting the rules and isn't generating a bunch of angry phone calls then you aren't likely to ever have much contact with an FAA official. They are good people in my experience, and if treated with respect will return the favor. If you have modded your engine to have obscenely loud straight pipes and insist it is your right to fly a bunch of patterns really low over nearby neighborhoods, they are less likely to fight for your right to do that then they are to convince you that your actions are endangering the existence of the airport itself. If you don't modify your actions, they will not be your friend.

#### BTCrenshaw

##### Well-Known Member
HBA Supporter
What may not be clear to everyone is the fine wording of the regulation that is often overlooked.
"Up to 30 pounds per float may be excluded by the FAA without requiring substantiation of the float's actual weight. " See the "REQUIRING SUBSTANTIATION" verbiage ? to explain. If you have a claimed ultralight plane with two floats attached and that plane weighs 454 pounds the plane COULD be legal as far as weight goes as the attached safety devices being the floats do not have a maximum weight as long at the plane itself without floats is legal.. In theory, you have to remove the floats and weigh the plane which weighs 254 pounds or less and the floats just happen to weigh 100 pounds each - because they do not have a separate weight limit. ( other than as they might affect flying qualities/speeds )
The thirty pound allowance for each of two floats comes in when you do not desire to "require substantiation" of the weight of the individual floats and the plane separately so you can weigh the whole assembled aircraft which then must not exceed 254+30+30. A Hull based Seaplane UL does not have the same flexibility as there is no way to remove the hull and weigh separately. An assembled hull based seaplane UL must weigh 254+30+10+10 or less to be legal. (ignoring parachute allowances) One other thing. As far as I know, the max speed and stall speed of ULs were never tested or required to be demonstrated by the FAA. The FAA created a formula which incorporated many variables which would determine the anticipated stall and max speeds. This formula included such things as span, wing area, single or double sided wings, strut-wire or cantilever wings, horsepower, windshield shape etc. The Kolb Firefly was famous for exploiting weaknesses in this formula such that it could exceed the max speed in reality but according to the formula it was legal. To my knowledge this formula was never adjusted to accomodate the extra weight of floats or hull ( or parachute ) so in theory the seaplane ULs could still be legal even if they could not demonstrate the minimum stall speed.
Jedi and you have made this much more understandable. Thank you both.

Todd

#### BTCrenshaw

##### Well-Known Member
HBA Supporter
e. Powered Vehicles. A powered ultralight cannot be operated under Part 103 when it has an empty weight of 254 pounds or more; has a fuel capacity exceeding 5 U.S. gallons; is capable of more than 55 knots airspeed at full power in level flight; and has a power-off stall speed wlich exceeds 24 knots.
Not to be anal about this but a LOT have the notion that 254 or less is legal, As stated in the regs 254# is NOT a legal 103 item. LESS than 254 is JB
I read it this way too, under 254 but have seen many reference as 254. I suppose in reality it may be how anal the FAA inspector is on the ramp. On the other hand I've also seen many posts and even statements in books and articles that say the chance of an ultralight having a ramp check is absolutely minimal unless there's strong evidence the plane is not legal or the pilot is an idiot. As we all know, it's a rare thing to win a disagreement with any government official. Not harping on the FAA inspector, but I get a lot more leeway on possible infractions when I'm nice and understanding than when I was young and a self appointed loud mouth know it all!

#### BTCrenshaw

##### Well-Known Member
HBA Supporter
BTW: I think the Merlin Lite is a really neat looking airplane. Its downsides are its upsides; it is clearly an airplane. That comes with both advantages and disadvantages. But if you want an airplane and want to avoid the registration and pilot certifications, the Merlin Lite is a very cool looking option. When it gets the cowl installed, I think it will look a bit like a miniature Helio-Stallion (please try to give it a cowl that looks turbine).

The Merlin has a very nice clean airframe that I think would make an excellent candidate for an electric ultralight. Electric motors are power dense, so it will likely be able to come in below 254 pounds without the BRS using electric propulsion. Add 5 gallons of new Tesla batteries and have fun!

Thanks Jedi,

Todd

#### BTCrenshaw

##### Well-Known Member
HBA Supporter
The first few times, the Cirrus activations were impressive, but the last couple I read about seemed like the pilot was looking for an excuse to deploy the chute and the problem would have been uneventful for a reasonably proficient pilot without a chute. I am concerned if someone were to become too dependent on a chute as an answer to any inflight problem. As I see it, on an ultralight gyro, a chute is a reasonable option when the alternative is certain death. I just looked at the title of this thread and it has drifted far from where it started. Maybe further discussion should be somewhere else?
Totally agree - the chute is "I have no other option, none, zero, zilch". Also agree on the thread, it kind of strayed off subject of Chip getting the Merlin Lite closer to in ultralight pilots hands. It has been a worthy subject and discussion though.

Todd

#### Aesquire

##### Well-Known Member
To recap earlier wisdom from others in answer to earlier question... Yes, it's better to be lighter than the arbitrary 254 pound limit. It's just hard to do and have extras like an enclosed cockpit. It's not easy to just have a seat.

The parachute allowance is A Patch on a regulation written before parachutes were available for "whole craft" saves. Ultralights (U.S. pt 103 to be precise ) were, in the beginning, powered hang gliders, literally. Then the "goody! Small airplanes!" part took over.

And although even in the 1980s hang gliders were occasionally up in the "you need oxygen" skies, normally you didn't have the altitude to dismount/unhook/escape from, a broken glider, get away from the spinning tangle of high strength steel cable, aluminum tubing, & dacron, fall... Then open a normal reserve parachute.

So, yeah, it's a loophole. But it's useful one, and a lot of people have used it. And it's optional if you can keep the weight down by eliminating unnecessary options like seats, windscreens, and extra instruments.

#### BJC

##### Well-Known Member
HBA Supporter
As I see it, on an ultralight gyro, a chute is a reasonable option when the alternative is certain death.
If I needed a parachute while flying a gyrocopter, I would want it strapped to my a.

BJC

#### TWilkie

##### New Member
Hello,

I've been reading AC 103-7; very informative thank you. One question though, does 55 knots maximum speed "at full power" mean wide open throttle (max RPM for short duration, sometimes as little as a minute) or maximum continuous RPM (fly all day without melting the engine)? Seems like there should be an allowance for climb performance without counting against max speed. Ever plane I've ever flown, you pull the throttle back when you level out from a full power climb. Are ultralights allowed the same? If not, then the cruise speed of the Merlin Lite would end up being pretty slow.

Thanks, Todd (different Todd)

#### BBerson

##### Light Plane Philosopher
HBA Supporter
The AC says a series of full power 1000 feet runs in item 20. And other alternate options.
55 knots is 63 miles per hour or 92 feet per second. So 1000 feet is 11 seconds.

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