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I sometimes hear it stated that in the United States, ultralight vehicles are not legally considered to be aircraft. For example, Wikipedia used to state:

In the United States ultralights are classified as vehicles and not aircraft, and are thus not required to be registered, nor is the pilot required to have a pilot certificate.

Under FAA regulations and US law, are ultralights considered to be aircraft?

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Yes, under FAA regulations, ultralight vehicles are considered to be aircraft.

14 CFR 1.1 states:

Aircraft means a device that is used or intended to be used for flight in the air.

Ultralights are used or intended to be used for flight in the air, so they are aircraft.

14 CFR Part 103 defines the term "ultralight vehicle" and describes the rules for operating an ultralight vehicle. Although Part 103 avoids using the word "aircraft" to describe ultralight vehicles, nothing in Part 103 (or anywhere else) states that they are not aircraft.

It is true that ultralight vehicles are exempt from nearly all regulations governing aircraft. However, this isn't because ultralights aren't legally considered aircraft; it's because there are regulations which specifically make ultralights exempt from those regulations. For example:

  • Part 103, Section 7, states that
    • ultralight vehicles are not required to meet airworthiness standards,
    • pilots of ultralight vehicles are not required to have any kind of certificate, and
    • ultralight vehicles are not required to be registered.
  • Part 61, Section 51(j), states that pilots are only permitted to officially log flight time in aircraft that are registered (as well as military and public aircraft). Ultralights cannot be registered.
  • Part 91, Section 1(e), states that ultralight vehicles are exempt from Part 91 in its entirety. (If ultralight vehicles were not legally considered aircraft, then this paragraph would not need to exist!)

(Of course, a pilot may make logs of flights performed in ultralights, but the FAA does not recognize this time as "flight time".)

So, the FAA does consider ultralight vehicles to be aircraft. However, they are exempt from most—but not all—regulations which govern aircraft.

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    $\begingroup$ This is good information, but it's a bit absurd to assert that ultralight pilots may not log their time flying those types of aircraft. Sure, the FAA may not recognize such logged time, but flight logs are an important aspect of ultralight pilot skill proficiency programs and ratings. Also as a practical matter, one might have to produce logs when flying sites abroad (as I recently did in Germany.) $\endgroup$
    – Mike Strother
    Oct 22, 2018 at 19:52
  • $\begingroup$ @MikeStrother Good point, I've edited the answer to try to clarify that. $\endgroup$
    – Tanner Swett
    Oct 22, 2018 at 20:07
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    $\begingroup$ I'm nitpicking the regulation, not your answer. :) $\endgroup$
    – Mike Strother
    Oct 22, 2018 at 20:44
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    $\begingroup$ Got it, I'll edit the regulation to clarify that. :) $\endgroup$
    – Tanner Swett
    Oct 22, 2018 at 20:54

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