10 | December 2016-January 2017 | Powered Sport Flying Ultralight & Light Sport Advocacy Volume and Power Comparisons for Electric Ultralights Introduction This white paper discusses the potential benefits of electric ultralights and a viable way for the Federal Aviation Administration to update policy regarding electric ultralights without going through a rulemaking process. The Light Aircraft Manufactures Association (lama) and the United States Ultralight Association (usua) both recognize that rulemaking is costly and resource intensive. Moreover, the ultralight community does not desire a change to the ultralight regulations. CFR Part 103 has been an incredibly successful regulation. It has allowed the owners of hang gliders, paragliders, powered airplanes, hot air balloons, powered parachutes, powered weight shift control trikes, gyroplanes, seaplanes, amphibians, and even helicopters to take to the skies as long as the vehicles meet the basic definition and operating rules of the regulation. And in the nearly 34-year history of the regulation, no one (outside an actual ultralight operator) has been seriously injured or killed by a flight operation of a legal ultralight. Innovations in battery technology have created opportunities for electric aircraft, but cfr Part 103 and a letter from the faa’s Office of Chief Counsel have actually penalized electric powered ultralights. That is the issue we shall address. Background The faa issued Advisory Circular No. 60-10, entitled “Recommended Safety Parameters for Operation of Hang Gliders” on May 16, 1974. With the growth of ultralight-type aircraft after that circular was published, and importantly, with the introduction of gasoline powerplants to the very light aircraft, “Part 103 -Ultralight Vehicles” was drafted and became effective October 4, 1982. The ultralight regulation proved to be very successful and led to advances in technology, which ultimately led to the Sport Pilot Rules which were published in 2004. Electric powered ultralights were not envisioned when cfr Part 103 was drafted. Even when the Sport Pilot and Light Sport Aircraft rules were published, electric aircraft weren’t important enough to address in the definition of a light sport aircraft. Instead, the faa had the goal to write a definition for light sport aircraft that prevented the use of multi-engine, turbine engine, and rocket propulsion. Both the rule and the preamble to the rule are silent on electric power; however the very definition of an lsa is for a single-reciprocating engine. Those understandable regulatory oversights have created a situation that is making it burdensome to introduce ultralight electric aircraft, and electric-powered light sport This is one of three presentations made by USUA and LAMA to executives at FAA Headquarters in Washington DC in November of 2016 A White Paper by & aircraft are prohibited by regulation. Meanwhile, electric propulsion is gaining popularity in ground transportation, particularly automobiles and motorcycles. Battery technology is continuing to improve, if not as quickly as many would hope. Industry leaders believe that electric ultralights could provide a real public benefit by interesting more people in aviation, much like electric aircraft have revolutionized aero modeling and have virtually created the uas industry. Benefits of Electric Ultralights The promise of electric ultralights is very bright and offers many features that appeal to existing pilots, Millennials, and aircraft makers. Quiet. Electric motors make an open-cockpit experience that much better for the pilot and makes for happier airport neighbors. Low Maintenance. Reciprocating engines, particularly two-stroke engines, require constant maintenance. Many young people, women, and professionals are put off by the idea of having to work on engines when that hasn’t been part of their life experience. Fuel Handling. Most ultralight aircraft burn autofuel which normally is purchased and carried to the airport. It is smelly, heavy, and potentially dangerous when spilled. The Environment. There are real and perceived benefits to the environment with electric aircraft. Both make flying more appealing to the non-flying and flying public alike. Problem There are actually a couple of closely related problems. Neither has to do with Part 103 itself. Even though the regulation is old, it is sound and has stood the test of time. Both lama and usua acknowledge that many people would like to see the regulation updated to increase empty weights, but we don’t believe that it is necessary or wise. The issue can be viewed as defining what ‘fuel’ is for an ultralight. cfr §103.1 defines an ultralight as an aircraft having “a fuel capacity not exceeding 5 U.S. gallons.” However,
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