14 CFR 103 compliant powered aircraft should be less than 254 pounds (excluding fuel). Do the batteries account for fuel in case of electric engine?
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1$\begingroup$ IMO batteries cannot be counted as 'fuel' as 'fuel' is consumed as .the flight progress. Battery does not :) $\endgroup$– vasin1987Jun 12, 2014 at 21:56
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3 Answers
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The jury (i.e. FAA) is still out on this question as of early June 2014. FAA has indicated it will not give a gasoline "fuel allowance" to be credited against weight for batteries. Given that fuel weighs 6 lbs. per gallon, or 30 lbs. for the maximum legal gas an ultralight can carry, it would be a somewhat negligible, but certainly welcome, allowance for would-be electric manufacturers.
One company, Chip Erwin of AeroMarine, has imported a barebones ultralight motorglider based on the Goat towed ultralight glider. It's called the Zigolo, and carries batteries enough for 30-40 mins. of flight, without exceeding the 254-lb. weight limit of the part 103 category.
In time the FAA may well decide to grant the allowance. It's still not going to amount to much more time, maybe 10 minutes given current battery energy density, which is a fraction of the energy density of gasoline, but research into electric storage is at a feverish pace worldwide.
Look for sport, then commercial electric aircraft, within the next 5 to 10 years. Several electric single and two-seat electrics are already flying. The Airbus ducted fan, recently ballyhooed as the first electric aircraft, which it certainly isn't, is a promising look at one way commercial electric applications might come to market.
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3$\begingroup$ Consider making a permanent account, without knowing the specifics you definitly SOUND like you can speak somewhat authoritatively on part 103... :) $\endgroup$ Jun 4, 2014 at 16:17
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No. The FAA was approached about this in 2012 and responded that there was no allowance for battery weight. All batteries must be included in the 254lb airframe weight.
Although batteries may indeed be used to provide power to an electric motor, the FAA does not agree that those batteries should be equated to usable fuel and excluded from an ultralight vehicle's empty weight.
https://rainbowaviation.company/wp-content/uploads/2017/08/elect-103-battry-def.pdf September 4, 2012
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$\begingroup$ The FAA response seems lackluster since they seem to feel that any allowance of batteries equates to an unlimited allowance. That's disappointingly lacking in imagination. As such, I wonder if there is some wiggle room. Clearly, the intention is that a ULM can have as much as 7kg more than its empty mass, since it can carry fuel in addition to empty weight. There are EU self-launching gliders such as the Atos Wing and the Birdy which are 120kg, putting them just heavier than the max Part 103 empty limit, but under the 254lbs + 2.5gal of fuel and with only several minutes of endurance. $\endgroup$ Nov 16, 2020 at 18:12
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There seems to be consensus that built-in batteries count against the weight, but removable batteries might raise questions that are unanswered to date. If it's not integral to the plane, it might be argued to fit the spirit of the rule.
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$\begingroup$ This answer could be improved by adding some sources to back it up. Welcome to Aviation.SE! $\endgroup$– dalearnMar 28, 2020 at 18:52