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The rest of the story about 330 pounds

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  • Robert Metzler
    This is about the increase to 330 pounds. It s long so delete it now if you are not interested. The Flying Moose wrote: snip 1. The weight. 360lbs to me would
    Message 1 of 1 , Mar 1, 2003
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      This is about the increase to 330 pounds.
      It's long so delete it now if you are not interested.


      The Flying Moose wrote:

      snip

      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
      machines.

      4. S'more fuel'dve been nice.

      BUT!

      I am in complete support of it.

      snip




      Metzler writes:

      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:

      11/09/02

      Federal Aviation Administration
      800 Independence Blvd.
      Washington, DC 20251

      Re: Proposed changes to AC103-7

      Dear Sirs:

      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.

      Background

      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
      populace.

      Requested change

      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.

      Summary

      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.

      Sincerely,
      Richard Carrier
      James Stephenson




      Metzler writes:

      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
      down.

      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 part103@yahoogroups.com
      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
      exemption.

      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.
      Cost?

      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
      $25.

      (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 =
      $5,000.
      8) Liability for suspending after a team is found to
      be incompetent = ????
      9) Coordination of Committee meetings and locations =
      $1,000.

      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) :^)

      Jim Stephenson



      Metzler Writes:

      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 Czygan

      Guys,
      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.

      snip

      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.




      Metzler writes:

      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
      ends? Hummmm.....

      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
      do Bill.

      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 part103@yahoogroups.com
      Jim Stephenson wrote:

      I am just using this post to address a couple of
      things:

      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.

      snip

      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.
      Jim Stephenson



      Archive # 577 In part103@yahoogroups.com
      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
      possible.

      Jim S



      Metzler writes:

      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.

      http://av-info.faa.gov/dst/amateur/ac103-7.pdf

      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
      this thing:)
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