The rest of the story about 330 pounds
- This is about the increase to 330 pounds.
It's long so delete it now if you are not interested.
The Flying Moose wrote:
1. The weight. 360lbs to me would have been the sweet
spot to exempt so that many of what we consider as
single seat UL's get in. The 330, or 320 will still
be very limiting.
2. The fact that it seems there was very little input
from others and became an individual effort. All of
a sudden, here it is, It is definitely NOT what
we'd ALL like it to be. But the effort was made, and
fer gaads sake Joe, the FAA is buying in on it.
3. The increase in weight should be accompanied by
slight increases in stall speed for exempted
4. S'more fuel'dve been nice.
I am in complete support of it.
Good points Moose but maybe this will change your mind.
This thing has been kept real quiet a long time and it's
starting to smell funny. I went back and tried to find
info that has been posted on it. I put it in order below
so you can see for yourself.
Anyone can submit a proposal to the FAA on their own.
Thats what happened here. Normally a group gets
togeather so that more input and ideas are available.
This was posted by Bill Czygan after several people
requested it on 3 or 4 lists. The signers did not
respond to those requests and as far as I can determine
Bill was the first to post it. Note the date on it.
Bill Czygan wrote:
Federal Aviation Administration
800 Independence Blvd.
Washington, DC 20251
Re: Proposed changes to AC103-7
This request addresses proposed changes to the Aviation
Circular AC103-7. Richard Carrier and Aero Sports
Connection are submitting this letter jointly, on
behalf of the entire ultralight community.
While it is recognized that this request must be
subservient to the more immediate issues of Sport
Pilot and the broad changes it implies, this request
is being submitted to support and enhance Sport Pilot
by clarifying the distinction between true ultralights
and the lightest of the Light Sport Aircraft.
When FAR Part 103 was adapted in 1982, the typical U/L
aircraft was a basic airframe and engine with out brakes,
self-starter, instruments, radio, or electrical system.
It had plastic wheels with no suspension system and a
canvas sling seat. Having grown out of the hang glider
movement, the craft were all extremely weight efficient
and all non- essential considerations of safety were
secondary to the prime consideration of reducing weight
to make flight possible.
As the ultralight community matured and developed the
basic designs and methods to achieve safe flight and
have additional margin for flight and safety, additional
weight items have become standard.
A classic example is the addition of electric start and
pre-rotators in the gyro community. Hand pre-rotating
and engine starting has resulted in several hand and
arm injuries, just as hand propping has resulted in
injuries in fixed wing operations. Similarly, the lack
of brakes on ultralight vehicles has resulted in several
incidents in which a taxiing ultralight on hard surface
has been forced to run off the runway or injure a leg
trying to stop before colliding with other taxing
aircraft. The need for such items as flight instruments
and engine monitoring instruments has added to overall
weight of an ultralight a safe and responsible pilot
would want to fly. At the same time, these changes do
not enhance actual flight performance. Brakes, electric
start, pre-rotators, flight instruments, engine
instruments, metal seats and upholstery, 5 point
harnesses, metal wheels, and improved landing gear will
all add to the overall safety of ultralight vehicles
without enhancing performance or violating the original
intent of FAR Part 103 to protect the non-flying
In the interest of safety, various improvements have
evolved from 1982 to the present, these include the
addition of brakes, self-starter systems, gyro
pre-rotators, gyro horizontal stabilizers, metal seats,
instrumentation, warning lights, 5-point safety
harnesses and improved metal wheels and landing gear.
We are requesting changes to the AC103-7 as it refers
to the weight restriction of FAR Part 103, paragraph
103.1, for the following safety items: brake assemblies,
self-starting devices (manual and electric), gyro
pre-rotators, gyro horizontal stabilizers, metal seats
with upholstery, flight instrument assemblies, visual
warning devices (strobe lights), 4 or 5 point safety
harnesses, metal wheels, and landing gear suspension
system improvements. It is our recommendation that an
overall field operative allowance of 66 lb. be allotted
for the above identified items (not including the
existing allotment for ballistic parachute recovery
systems) and that an additional 30 lbs be allotted for
gyro pre-rotators and 20 lbs for gyro horizontal
stabilizers, separately. Thereby, allowing an operator
of an ultralight vehicle to show compliance without
removing these safety devises to weigh the ultralight
separately. In the publics interest These above
mentioned items contribute to the safety of the pilot
and other people and property on the ground. Yet, they
do not extend either performance or range. A 103
compliant aircraft would remain otherwise compliant with
these safety related items. History has shown that many
accidents have been the result of failed plastic wheel
landing gear, injury due to attempting to hand start a
propeller, pilot injury due to penetration of the seat
area by metal components or ground debris in landing
incidents. Injuries and property damage have resulted
from attempting ground handling without brakes. The
resulting safety benefits of these changes are
reductions in personal injury and property damage and
resulting costs, at a minimal expense of revising
AC103-7 field guidance.
Richard Carrier and ASC are requesting the revision of
AC103-7 to include an allowable weight increases for
safety equipment which does not enhance performance but
does contribute to overall safety. We further request
that consideration be given to non-publication of the
summary of this petition based on FAR 11.27(j)(3)(1)
which recognizes the time critical nature of this
request and the similar change made for parachutes to be
used in the case of catastrophic emergences.
They forgot much stronger frames, improved control
systems, heavier more reliable engines, dual ignition
systems and probably a few more items.
They asked for 66 pounds and that isn't enough to
cover the differences between UL 20 years ago and UL
now. 66 pounds added to the current 254 pounds would
only be 320 pounds. This is much lower than all
previous requests and much lower than numerous
discussions on these lists.
More disturbing is the suggestion of a further 50 pound
increase for gyros but not for other UL. This would put
gyros at 370 pounds and all other UL types at 320 pounds.
Do they need it more? If thats the case, we could wind
up with different weights for each type aircraft. For
instance fixed wing craft require a tail and control
surfaces so they should have more weight than trikes.
A powered parachute "wing" is much lighter than the
wing on a fixed wing craft so powered parachutes should
have less weight. This is a road we don't want to walk
Is it for pilot safety? Prerotators shorten their
takeoff run but without the prerotator they don't take
anymore space than other fat UL. Horizonal stablizers
increase gyro stability but fixed wing craft also have
horizonal stablizers. Should fixed wing craft also get
additional weight for horizonal stablizers?
Is it for public safety? The lighter UL types would
have less energy involved in a crash so it definately
is not for public safety.
The FAA can accept a proposal and turn it over to the
ARAC committee for a recomendation. Apparently this
proposal was rejected instead.
In archive message # 501 from firstname.lastname@example.org
Jim Stephenson wrote:
Early discussions were focused on changing AC103-7 but
that would not work. The change moved to making an
exemption for the express purposes to research the
benefit of a weight increase.
As an exemption there are added costs and difficulties.
For the difficulty part, a draft has been created to
manage members of technical committees. These members
would be required to weigh and review the aircraft and
determine there applicability to the exemption. Three
volunteers would have to sit on a committee and actually
weigh and measure and fill a single place to evaluate it.
They could then document that it meets FAR 103 and its
Because the original FAR 103 has always envisioned that
pilots would be 1) trained privately, 2) register their
vehicles, and 3) be members of a national organization,
these would be requirements.
Because there are additional costs of maintaining such an
exemption, there would be a cost to hold the exemption
for two years.
a) The exemption holder would have to maintain an
accessible database of exemption qualified participants.
b) The exemption holder would have to require reporting
every 6 months, and suspend the exemption for anyone who
did not report. Cost over two years an average of 10
letters, letters returned to be opened, database
recording, and renewal processing, estimated cost per of
(b) Technical Committee management and support. The
Technical Committee members must be contacted and submit
applications. Communication and letters amortized over
all participants estimated at $10.
c) Technical committee peer review and correction work
for committee errors. Risk is high here. There is no
way to handle the liability risk of someone getting
suspended because of a bad committee decision.
Liability is very big unknown, But looking at practical
matters of sending letters and reading letters and
calling to review data and resumes. Then amortizing
these costs across an expected use. Say we managed 99
committee members and that made 33 working Technical
Committees Communication and printing the guides and
setting up the equipment estimate at
1) letters and forms out, magazine ads $1000
2) Responses, reviews reading and approving members
99 x $10 $990
3) Equipment on the cheap. One bathroom scales
calibrated with a water technique plus three
boards $20 x 33 = $660
4) A tape measure = 0 (borrowed)
5) A gas can donated and calibrated with measuring
cup (large)= 0
6) Guidance paperwork for each team including master
forms and checklists $25 x 33 = $825
7) Peer review activity per team estimate one in
three teams need review at $500, or $500/3 x 33 =
8) Liability for suspending after a team is found to
be incompetent = ????
9) Coordination of Committee meetings and locations =
Say that 1,000 people take advantage of these offers to
fly under the exemption:
>From above in order:Liability? + $25 + $10 + (1,000 + 990 +660 + 0 +0 +825 +
5,000 + 1,000)/1000
$25 + $10 +$9.45 = $44.95 plus liability
None of that pays for volunteers or contingencies and
Liability is a BIG unknown. What fool would do it? And
doing it for less than $50 per would be loading the real
costs up on the membership which would be inappropriate.
So costs to the exemption participant: $25 Veh Reg , $25
Pilot Reg, $40 a year membership, $50 two years to hold
exemption = Total over two years $190.
Is that doable? Will Technical Committee members
volunteer? Will liability be survivable?
This whole discussion is hypothetical as I do not admit
to any specific knowledge or practice etc. yada yada
yada.. (disclaimer) :^)
I have a couple of problems with this post. The reason
for changing to an exemption is stated above as "to
research the benefit of a weight increase". Every
previous proposal asking for part 103 increases has been
rejected except the one which was turned into sport
pilot. If this proposal had been accepted it would have
been given to the ARAC committee and it was not. I am
convinced the proposal was rejected which prompted this
attempt to get an exemption.
Why "research the benefit of a weight increase"? The
SP NPRM (on page 5374) states "The FAA analized the
existing accident data of ultralights that do not meet
part 103 to determine deficiencies in safety. Accident
data from the NTSB and part 103 exemption holders show
that 36 accidents occurred between 1995-2001 involving
aircraft that would meet the proposed definition of
light-sport aircraft. These accidents resulted in 51
fatalities." They quote slightly lower figures on pages
5396 and 5397. There are no figures available for true
UL since no one keeps records of them.
Legitimate research would compare accident rates of true
UL with accident rates of fat UL and this so called
research makes no attempt at that.
JS also claims that part 103 "envisioned" that we would
register our vehicles and belong to a national
organization so "these would be requirements". The
closest that I can find is this quote from AC103-7...
"The ultralight community is encouraged to adopt good
operating practices and programs in orfer to avoid more
extensive regulation by the Federal Aviation Authority."
>From Bill CzyganGuys,
This is the basic proposal as it concerns UL's:
A proposal has been submitted by ASC, and needs our
support, that will establish an exemption for 2 years,
allowing us up to 330# weight if our single seat planes
are equipped with 3 safety items. These are brakes,
starter (electric OR hand pull) and "improved" landing
gear. The exemption will be for the purpose of
conducting a safety study of these planes for a two year
period. At the end of that period the FAA would make
these weight allowances permanent for all planes. This
is a chance for a number of UL's, who would otherwise be
forced into the Sport Plane category, to remain Part 103.
The FAA wants all the Orgs. to ask for this to be
approved even if they don't set up the infrastructure
for the safety study themselves. The form it is in as
asked for by the ASC is the form the FAA would approve.
Additions or add ons or changes would ruin it's chances.
It is voluntary. If you don't like it, don't participate.
Time is of the essence.
Now details start coming out. This is a temporary thing
that will last 2 years. Now isn't it strange...sport
pilot will be out soon. There is a two year grace period
after that to grandfather your fat UL into SP. What
happens when you register your fat UL, have 3 guys sign
an inspection report on it that says it's a fat UL, get
a written waiver that says you have a fat UL, report
every 6 months that you have a fat UL and then the waiver
expires right about the time the SP grandfather period
All the exemption covers is brakes, starter and improved
landing gear. Not much "research the benefit of a weight
increase" if those items are all that's involved.
Bill states that after the 2 years "the FAA will make
these weight allowances permanent". You said it was a
"safety study" so I thought the idea was to see if the
330 pounds improved safety before they decide what to
If the FAA is offering this so freely, why do all the
orgs have to ask for it? Why doesn't the FAA just give
an exemption to ASC? The answer is that the FAA can not
legally show favoritism so if they give it to one, they
must give it to all three. Why all the concern about
EAA and USUA wanting changes to what ASC wants? Because
all three orgs must agree on the request. It's called
"concensus" and is required by law. It helps keep things
fair because it prevents any one man or org from going
off half cocked or cooking up back room deals. Just like
the ARAC committee could not issue their final report
until all committee members agreed that they had no
offical objection to that final report. It only took
them about 12 years if I remember correctly. Why the
big rush? Because it somehow affects sports pilot and
the same 2 guys that started this have been pushing real
hard for sp for a long time. Item 4 in the next post
gives a clue.
Archive # 554 In email@example.com
Jim Stephenson wrote:
I am just using this post to address a couple of
If you (we) don't want an exemption to get more weight
and that is the only way to get there, do you want to
proceed? If not, it can be stopped very easily.
2) If you want to proceed, the issues of what to compare
to are important.
We will have to deal with that, someday.
4) Remember, this idea only gains strength in that it
supports the higher priority SP proposal. It cannot get
in the way of SP. Sue does not have time to work both
issues. If this is to happen, then it has to support:
a) It shows FAA is not trying to kill FAR Part 103
b) It gives people who do not really like getting
as close to FAA as SP, a good plane to fly
outside of SP
c) It can be entirely managed by industry at
minimum FAA costs (a major issue today)
d) (What else can I say here?)
What I am trying to do is show how this helps the FAA.
When does a bureaucrat do something? When it make their
life easier while doing their job better.
Archive # 577 In firstname.lastname@example.org
Jim Stephenson wrote:
(about a particular plane that is barely under 330)
Caution... caution... caution... We have no assurance
this can happen... It will not if it detracts from SP.
DO NOT BUILD IN THE HOPES IT WILL HAPPEN.
No fuel or stall speed increase is anticipated or
Thats as shame. You see most planes can't meet the 24
knot stall speed requirement of part 103 if they weigh
330 pounds. Dave A was kind enough to post this link
the other day.
Use the info and chart to check your plane. The single
seat CGS Hawk barely (and I mean BARELY) will do it with
the FAA standard 170 pound pilot.
Apparently this is not a "one weight covers all" deal.
harveyking2002 is one of the signers on the orginial
proposal. He posted just a few minutes ago on the
part_103 group that we get 10 pounds for brakes, 36
pounds for starter, and 30 pounds for improved landing
gear. The starter can be a pull rope or electric but it
must be engaged from the seat. I guess the brake
definition is obvious but I haven't seen a defination
of "improved landing gear" yet. I just noticed that his
figures add up to 76 pounds instead of 66 pounds. Wonder
which is correct.
Best laugh today was his explanation of why the gyros
got more weight. Part 103 already gives up to 24 pounds
exemption for a BRS so a UL with a BRS could weigh up to
354 pounds if this thing happens. A gyro doesn't
normally use a BRS so it can weigh 380 pounds. Public
safety question....which do you think is safer in case of
a structrual failure?
I still wonder where the other 26 pounds went. He seems
to think it makes sense:) I'm not even gonna go into his
explanation on floats:)
I wonder what other suprises are still not public about