# e-Lazair Info!

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#### Armilite

##### Well-Known Member
Electric Ultralight Weight Issue
I have come up with the below analysis of the weight issues regarding electric ultralights. I believe that anyone considering a project like mine should use this approach in determining their allowable component weights as no one has yet found a flaw in the analysis and its implications will allow electric ultralights to be developed with reasonable endurance using today's technology.

Here is my analysis:
I have read Part 103 and its advisory circular thoroughly and I believe that the electric Lazair, as I have constructed it, meets the definition and its interpretation as described in both documents.

The 254-pound weight limit is defined as empty weight without fuel and then, fuel is limited to 5 U.S. gallons.

A U.S. gallon is a measurement of volume, not weight. 5 gallons of diesel, Avgas, and Jet A all have different weights and, without question, all three would be acceptable fuels for a Part 103 ultralight.

There is no mention or limitation as to the type of fuel that can be used. Lacking an FAA definition of fuel, I see that the Wikipedia definition of fuel is any material that can release energy and electric Lipo cells certainly do that.

My fuel is the 384 Lipo cells, each with a volume of 2.9 cubic inches. My total fuel volume is 1114 in^3. 5 U.S. gallons is 1155 in^3.

My fuel volume is, therefore, less than 5 U.S. gallons and the regulation is met. In effect, the rule allows us to carry 1155 in^3 (5 U.S. gallons) of fuel regardless of its density.

As a practical matter, I submit that since it is difficult to physically remove only the fuel (384 Lipo cells) from my aircraft, my aircraft should be weighed with fuel (Lipo cells) and then the Lipo fuel weight should be subtracted to obtain its empty weight.

The 384 Lipo cells weigh 90 lbs.

Since my electric Lazair currently weighs 282 lbs with fuel, I believe that the empty weight without fuel is 282 - 90 lbs OR 192 lbs which is significantly below the Part 103 maximum empty weight of 254 lbs.

I would also like to point out that, under the 2011 NASA Green Challenge rules, these 384 Lipo cells only carry an energy equivalent of less than 1/4 of a gallon of auto fuel.

Dale Kramer

#### Dana

##### Super Moderator
Staff member
Nice argument, but the FAA has said that batteries are considered part of the aircraft's empty weight, so 254# max including batteries.

#### pwood66889

##### Well-Known Member
" FAA has said that batteries are considered part of the aircraft's empty weight, so 254# max including batteries. "
Question arises: Starting or Running batteries? I say modify your Lazer and fly it. The number of FAA inspectors per square mile in Iowa is low.

#### BJC

##### Well-Known Member
HBA Supporter
Electric Ultralight Weight Issue
I have come up with the below analysis of the weight issues regarding electric ultralights. I believe that anyone considering a project like mine should use this approach in determining their allowable component weights as no one has yet found a flaw in the analysis and its implications will allow electric ultralights to be developed with reasonable endurance using today's technology.

Here is my analysis:
I have read Part 103 and its advisory circular thoroughly and I believe that the electric Lazair, as I have constructed it, meets the definition and its interpretation as described in both documents.

The 254-pound weight limit is defined as empty weight without fuel and then, fuel is limited to 5 U.S. gallons.

A U.S. gallon is a measurement of volume, not weight. 5 gallons of diesel, Avgas, and Jet A all have different weights and, without question, all three would be acceptable fuels for a Part 103 ultralight.

There is no mention or limitation as to the type of fuel that can be used. Lacking an FAA definition of fuel, I see that the Wikipedia definition of fuel is any material that can release energy and electric Lipo cells certainly do that.
The FAA does not need to define words that have been in common usage for centuries. https://www.merriam-webster.com/dictionary/fuel

My fuel is the 384 Lipo cells, each with a volume of 2.9 cubic inches.
My meteorite is an airplane, too.

Since my electric Lazair currently weighs 282 lbs with fuel, I believe that the empty weight without fuel is 282 - 90 lbs OR 192 lbs which is significantly below the Part 103 maximum empty weight of 254 lbs.
As Orion often wrote, what you believe is irrelevant.

BJC

##### Well-Known Member
Here is the letter in which the FAA made it's determination that batteries must be included in the empty weight of a Part 103 vehicle. https://rainbowaviation.com/wp-content/uploads/2017/08/elect-103-battry-def.pdf

Despite the legality of the situation I would still continue to fly whatever you like and call it an "ultralight" until anyone in authority questions you. Most likely the questions will never come. If you are busted you most likely get a slap on the wrist and told don't do it again.

#### plncraze

##### Well-Known Member
HBA Supporter
Especially if you are flying over your own acreage or farm.

#### Jerry Lytle

##### Well-Known Member
Forgiveness is likely easier to grant than permission rather asking for permission, a lot less paper work.

##### Active Member
Hi Armilite,

Let's remember that ENERGY makes our engines/motors operate. Electricity is ENERGY, not fuel. Now, not always but often, "fuel" is burned to release ENERGY. But Atomic ENERGY is NOT emitted by burning Radiation Filled Rods. Yet, a Radiation Filled Rod inside a nuclear reactor is called fuel by the U.S. Government; (and said reactor is the source of power that turns a submarine propeller in many examples). Likewise, Electrical ENERGY is NOT emitted by burning batteries. I'm sad to say though, that it appears at this time, that the "The Government" says, that batteries are the container, that the "go-juice" (electricity) is stored in, just as with the system that gasoline,"fuel", is contained in the 5 gallon tank, on the Part 103 ultralights. I feel this is in conflict with the atomic energy particulars, but my feelings/opinions don't matter. In post number one you referred to how website WIKIPEDIA defined "fuel". I caution all people, that no matter what the topic, that postings on that website must be corroborated BEFORE being used for decision making. If, you'd sought your definition of "fuel" from www.merriam-webster.com/dictionary/fuel you'd see the attachment below. Whatever M-W says though, matters not, compared to what "The Government" (federal, state, municipal, village, town, etc.) says the definition of a word is. (Government has been establishing definitions of words for scores of years. One example follows. Part of the federal government's definition of MOTORCYCLE includes the mandate that such a vehicle is not permitted to operate with more that three wheels in contact with the ground. So, (see picture below) these giant Honda Gold Wing vehicles that get altered to have a pair of front wheels AND A PAIR OF REAR WHEELS, no longer meet the federal definition of "motorcycle".)

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#### BBerson

##### Light Plane Philosopher
HBA Supporter
That Carpenter letter was one broad request to the FAA that was denied. It is not law. Another more reasonable request could be approved.

##### Active Member
But BB, I am sure that you are not stating that someone is guaranteed to be free from government punishment, if that person acted contrary to what the letter stated.

#### BBerson

##### Light Plane Philosopher
HBA Supporter
But BB, I am sure that you are not stating that someone is guaranteed to be free from government punishment, if that person acted contrary to what the letter stated.
Of course.
I am saying the Carpenter letter doesn't apply to anyone except Carpenter. Or, it isn't the final say, in my opinion. Some other FAA official could have a different interpretation, if asked in a more reasonable request that could be approved.
Carpenter asked for unlimited battery weight. He could have asked for a limited amount, such as about the same weight as 5 gallons of "fuel".
But the FAA told him to stop asking.....
Other electric ultralight experimenters have told me the FAA is under pressure to allow electric development as much as possible.

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##### Active Member
Originally by BB:

"Of course.
I am saying the Carpenter letter doesn't apply to anyone except Carpenter. Or, it isn't the final say, in my opinion. Some other FAA official could have a different interpretation, if asked in a more reasonable request that could be approved.
Carpenter asked for unlimited battery weight. He could have asked for a limited amount, such as about the same weight as 5 gallons of "fuel".
But the FAA told him to stop asking.....
Other electric ultralight experimenters have told me the FAA is under pressure to allow electric development as much as possible."

I'm confident that EAA, USUA and others are on the case, as well as others, as you said in your closing sentence.
We ought to present a reasonable request that's specific, as you said, maybe something like 100 pounds max weight of batteries, and said batteries must fit within one cubic foot. * 7.48 Gallons fit in one cubic foot! https://sciencing.com/calculate-gallons-per-cubic-foot-5985285.html *As a side reference, gas weighs 6.3 pounds per gallon, and I'm hearing Thundergull Guy Mark B. talking about 90 pounds of batteries in his product E-GULL at about the 4:07 mark below, a Dec. 8, 2014 video.

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#### Armilite

##### Well-Known Member
Nice argument, but the FAA has said that batteries are considered part of the aircraft's empty weight, so 254# max including batteries.
================================

I personally haven't seen anything definite come out in Writing by the FAA on Electric Powered Ultralight Aircraft. Your comparing 5 Gallons of Liquid to a Solid. The Part 103 Rules state 254lbs Empty, a 24 knot Stall Speed, and carry Max 5 Gallons of Gas. Gas is a Liquid not a Solid. The Planes Design sets the Total Max Weight it can Fly with, which the Total Gross Weigh with Batteries is also set.

Now I don't know the FWF Weight of the (2) Rotax 185UL's to subtract off to get the Airframe only Weight. But the Hirth F-36 a Solo 210 (Weight: 28lbs, including Reduction Unit, Exhaust, and Recoil Start) is close to the same Size as Rotax 185UL, so let's use 28lbs x 2 = 56lbs. Original Weight with Rotax Engines 210lbs - 56lbs = 154lbs for a Lazair Airframe. Part 103 254's - 154lbs = 100lbs for Batteries split for both Engines. Now the Plane really only needs 9.5hp for each motor. So then the Big Question is, How much Flight Time does 50lbs of Batteries give you at 9.5hp if Batteries have to be included? A Single 18650 Lithium Cell is 42 grams. 50lbs = 22679.62 grams/42grams = 540 Cells, But you have to figure in the Controller, plus 2 (10hp) Electric Motor Weights, Battery Pack Connectors, etc. You can get rid of Fuel Tank, Fuel Line, Connectors, Fuel Pump, etc. Maybe, with some New Carbon Fiber Parts, you can maybe lighten it a little more.

Bottom line, if Batteries are to be Included in Total Weight, you probably can't Fly more than an Hour. If Batteries are not Included, the more you carry the less Useful Load will get.

Gas Powered: 2hrs Flight Time.
Max. takeoff weight:
450 lb (204 kg)
Empty Weight: 210 lb (95 kg)
Useful Load: 240 lb (109 kg)
Powerplant:
2 × Rotax 185, 9.5 hp (7.1 kW) each

2019 Pheinox 103 $15,500 with a 50hp Hirth. 2019 Aerolite 103$15,500 with a 28hp Hirth.

I think the E-Spider, Fight Star was $40,000. With Electric: Maybe 1 hr Flight Time. Max. takeoff weight: 450 lb (204 kg) Empty Weight: 254 lb (115 kg) Useful Load: 196 lb (89 kg) Powerplant: 2 × Electric, 10 hp (7.5 kW) each$25,000+

I'm still Reading Dales Electric Thread, I'm at Post #175, but Dale said up to where I'm at, he had $8000 in just Parts, add on Labor and a Profit Margin into it, probably going to be$15,000+ plus Airframe, and He's still in the R&D Stage.

A Hirth F-36
15hp with Electric start & Re-Drive $2964.00 x 2 =$5,928.

A Honda/Clone 15hp with Upgrades with Electric Start & Redrive probably $1,200 x 2 =$2,400.

With a BRS you get so much Weight ??? lb Exemption, same for Floats ??? lb?

Personally, I think there should be a separate Weight Exemption made for Batteries since their able to be taken off the Plane to Recharge, just as Gas is not Included in the Empty Weight the Batteries shouldn't be either. Gas is 6 lbs per Gallon, so 5 Gal = 30 lbs, 30 lbs of Batteries aren't going to get you very far.

I wish these People would get Input from many different Sources, talk to the EAA, talk to an Aviation Lawyer before they plead their case to the FAA. It should be all about SAFETY, and Flight Time. If 2hrs with 5 Gallons of Gas, they should be able to carry enough Batteries for 2hrs also.

The Lazair Airframe needs a few Upgrades for a Higher Max Takeoff Weight, 600-650lbs.

#### Armilite

##### Well-Known Member
" FAA has said that batteries are considered part of the aircraft's empty weight, so 254# max including batteries. "
Question arises: Starting or Running batteries? I say modify your Lazer and fly it. The number of FAA inspectors per square mile in Iowa is low.
=========================================================

I don't have a Lazair, Dale is the Designer of the Lazair Airframe and who was attempting to Upgrade it to Electric. Has the FAA put that in Writing, or did you just talk to an FAA guy who stated that? You don't have to Warm Up an Electric Motor, just pull it out, do walk around Flight Check, Jump in and Takeoff. For the most part, most USA Part 103 Airframes you really only need Max 26hp, the Lazair is more of a Motor Glider Ultralight so only needs minimum 11hp total. First Engines used was (2) 5.5hp Chainsaw Engines, but soon Upgraded to Rotax 185UL's at 9.4hp@5000rpm each, equals to 18.8hp. So even an Upgrade to 12-15hp each Engines is nice. But as HP goes up, so does GPH, so Flight Time goes down when limited to 5 Gallons.

#### Armilite

##### Well-Known Member
The FAA does not need to define words that have been in common usage for centuries. https://www.merriam-webster.com/dictionary/fuel

My meteorite is an airplane, too.
As Orion often wrote, what you believe is irrelevant.
BJC
==============================================

Yes, the FAA has to define WORDS, they are the US Government Agency who makes up these Flight Rules. An Ultralight (Part 103) is not considered an Airplane by the FAA, hence NO License, No N Number, is Required to Fly them!

GAS is a Liquid, and a Lithium Battery is a Solid. When these Part 103 Rules were written about 40 Years ago, and have never been Updated, they made No Provisions in the Rules for Electric Motors and Batteries or any other New Technology. Since most People even on here, and even these New Manufactures wanting to use this New Technology, like Dale, don't even fully understand yet what's all involved in doing this Conversion, I seriously doubt, any People in the FAA does either. So they, and most of us need to be Educated on what's all involved. As a Manufacture, they have to follow the FAA Rules & Regulations. As an Individual, you can do about what you want, the FAA doesn't really care about Part 103 and has never really enforced the Rules. Your Insurance Company may have something to say. Don't act Stupid and Fly normally, and you probably won't be bothered.

IF, the FAA has Ruled the Batteries are to be included in the Dry Weight, they have probably Killed off any USA Part 103's using it, unless Newer High Tech Batteries and Motors come out. I won't give up Flight Time to use Electric. If the Lazair can fly 2hrs on 5 Gallons of Gas, I could accept 1:30min, but nothing less.

Hvvea Amperex 18650 Cell production line.

Go on Youtube and there is many Video's of the Lazair, some with the Electric Motors. This Electric Motor conversion thread of Dales started back in 2010, and I'm not done Reading it all yet, or know where Dale is at on the project in 2019.

#### Armilite

##### Well-Known Member
Here is the letter in which the FAA made it's determination that batteries must be included in the empty weight of a Part 103 vehicle. https://rainbowaviation.com/wp-content/uploads/2017/08/elect-103-battry-def.pdf

Despite the legality of the situation I would still continue to fly whatever you like and call it an "ultralight" until anyone in authority questions you. Most likely the questions will never come. If you are busted you most likely get a slap on the wrist and told don't do it again.
==========================================
Thanks for Posting. In regards to this letter.

1. Notice, Brian, didn't bring up any of these Old Part 103 Ultralight's Data made in the last 40 Years, Flight Times with 5 Gallons, or Max Load vs Useful Loads, with the 254lb Weight Limit, or the Average Weight of an American Male today, or even his Planes Spec's! These Part 103 Rules Discriminates against Heavier People and also against People with disabilities.

2. These Battery Packs are not Permanently Attached to the Airframe, they're usually taken out to be Recharged! Just as that Gas Engine won't run without Gas, neither will an Electic Motor.

3. Gas is a Liquid in the Rules, Batteries are a Solid and removed for Re-Charging! A Planes Max Load, Limits How many Batteries can be carried, that should have been Pointed Out! No Battery Weight vs Flight Time Data was given to them. They have No Clue. The Part 103 Rules has a Full Power Max Speed which sets Max HP used and a Minimum Stall Speed which also Limits HP used. For the majority of Part 103's ever made that's minimum 18hp to 35hp.

4. They say: Including the weight of batteries that power an electric motor in an ultralight vehicle would permit an ultralight vehicle to carry an unlimited amount of batteries as a power source. Which is FALSE. They have NO CLUE!

5. They say: Although the FAA agrees that adequate fuel reserves must be available for safe flight, the FAA, in the Notice of Proposed Rulemaking in which the rules for the operation of ultralight vehicles were proposed, specifically expressed its concern about ensuring that a reasonable fuel limitation for ultralight vehicles be included in the rules. Brian should have given as much Part 103 Data as he could, Aerolite 103, Pheinox 103, Lazair, etc. Kitplanes has Data on almost every Plane made.

6. They say: The FAA is concerned that current or future developments could create a hazardous situation if a reasonable fuel capacity limitation is not specified ... That maximum capacity would have the practical effect of limiting both the range the vehicle can operate under power and the hazard of fire posed by the ultralight vehicle. This was written 40 Years ago! He should have brought that these Rules were written 40 years ago and have never been Updated. Some Examples, like a kid today can drive a High Speed Boat (Mine 310hp with 60 Gallons), Snowmobile (115hp with 9 Gallons), ATV (??hp with ??Gallons), Jet Ski (115hp eith 9 Gallons), all with No License. They really don't have a clue how far a Part 103 Ultralight can Fly on 5 Gallons of Gas also. You have 40 Years of Ultralight Data with GAS to give them today.

7. They say:
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. Do you see where Brian gave them No Data to Examine to compare against other Part 103 Ultralights, and they have No Idea, so they just used a Canned Answer!

8. They say:
This interpretation was prepared by Paul Greer, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the General Aviation and Commercial Division (AFS-800) of the Flight Standards Service and the Production and Airworthiness Division (AIR-200) of the Aircraft Certification Service. These Part 103 Rules were made 40+ Years ago when People first hung a Weed Wacker 2 Stroke Engine on a Hang Glider. I would bet 98% of the People working in the FAA today, have never Built, or Flown, a Part 103 Ultralight or Kitplane, or even Certified Airplane. They Work for us, so we have to educate them, give them DATA to compare.

9. Any Letter to the FAA/Congressman ought to always stress SAFETY, like my Lazair Ultralight I produce, with 5 Gallons and 18.8hp can Fly Safely for 2hrs at 40mph with a Small 10min Reserve. I would like to make it even Safer and Quieter with (2) 12hp Electric Motors that still keeps me under the Max Full Power Speed of 55 knots/62.3 mph which for the same 2hrs of Flight it needs (6) Removable Battery Packs for Recharging that Weighs XYZ lbs. I would like to see an Exemption for these Removable Battery Packs since under the Rules their not a Liquid. Under the Planes Max Load Design, 2hrs is the Max we can Fly it. Here is the Battery Pack Specs and the 12hp Electric Motor Specs on page 2. Since these Rules were made 40+ Years ago and today 2019 People are Heavier, it would be much more Safer today if you guys could Up the Empty Weight to say 300lbs so all of these Airframes today could be made Safer. It would also help all of these Manufactures to create more Jobs if we can Make and Sell more Ultralights. Here is a list of some Part 103 made with the Data to look at. Please write/email or call me if you have any Questions, or feel free to stop at our Company and I would be glad to show you what we are doing.

Thanks
XYZ Manufacturing
================================

Dear Mr. and Ms. Carpenter:

#### Armilite

##### Well-Known Member
That Carpenter letter was one broad request to the FAA that was denied. It is not law. Another more reasonable request could be approved.
=====================================

I agree. These People in the FAA today need to be Educated on these Ultralight Planes and this Electic Motor Stuff. The EAA doesn't really care about Part 103, and we have lost many Part 103 Manufacturers that might Support this stuff. Facts and Data needs to be collected.

#### Armilite

##### Well-Known Member
Originally by BB:

"Of course.
I am saying the Carpenter letter doesn't apply to anyone except Carpenter. Or, it isn't the final say, in my opinion. Some other FAA official could have a different interpretation, if asked in a more reasonable request that could be approved.
Carpenter asked for unlimited battery weight. He could have asked for a limited amount, such as about the same weight as 5 gallons of "fuel".
But the FAA told him to stop asking.....
Other electric ultralight experimenters have told me the FAA is under pressure to allow electric development as much as possible."

I'm confident that EAA, USUA and others are on the case, as well as others, as you said in your closing sentence.
We ought to present a reasonable request that's specific, as you said, maybe something like 100 pounds max weight of batteries, and said batteries must fit within one cubic foot. * 7.48 Gallons fit in one cubic foot! https://sciencing.com/calculate-gallons-per-cubic-foot-5985285.html *As a side reference, gas weighs 6.3 pounds per gallon, and I'm hearing Thundergull Guy Mark B. talking about 90 pounds of batteries in his product E-GULL at about the 4:07 mark below, a Dec. 8, 2014 video.
===============================

Part 103 is about Speed, Full Power Max 55 knots, with a 24 knot Stall Speed, and Limiting Distance using 5 Gallons! It's not about Gas Weight. At the Inception of these Part 103 Rules they didn't have much Data to go on, many Ultralights were nothing more than a Hang Glider with a Weed Wacker Engine. The Group of People back then that came up with the 254lbs which at the Time also started the Kitplane Market which is the Experimental Class where you need a Private pilot license. But as Time went on, People wanted Faster and more Durable Airframes, a Second Seat for Trainers that was abused by many, so many Ultralights eventually fell into the Experimental field needing a Private 40hr Pilot License, but the FAA turned a Blind eye for almost 30 Years, then we had the new Light Sport 20hr License and Rules formed and they all had to get N Numbers.

The only thing that will Change Part 103 is if the Manufactures and People get Involved, provide DATA that they can see, read, etc.

I don't see what HP, Flight Time, posted ona Website for this e-Plane you mention. Got a link showing it's Spec's? The Video said 40hp and 40min Flight Time with 90lbs for Batteries. He did say Removeable and qualified for Part 103, but seemed a little hesitant when he answered.

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#### BJC

##### Well-Known Member
HBA Supporter
==========================================
Thanks for Posting. In regards to this letter.

1. Notice, Brian, didn't ...
Brian acted. You think that he did it wrong, and state what he should have done.

Please share with us your letter to the FAA on this subject.

Thank you.

BJC

#### proppastie

##### Well-Known Member
Log Member
"Presumption of Validity" .....means the approving government agency has the presumption of validity when acting,.....yes they can be wrong, (in your opinion) but for the most part their actions are presumed valid. It is "you can not fight city hall" and yes it is a valid legal concept....the first one (presumption of validity). Organizations like AOPA and EAA can lobby the FAA and Congress to change the interpretation, it has been done before...."Through the Fence Operations",..."Basic Medical", "Homebuilding of aircraft in hangers".....So wright a letter or many letters, post on aviation sites and exercise your "right to petition" Good Luck.