# Petition	for	Rulemaking

Petitioner
Prof. Grant W. Petty Atmospheric and Oceanic Sciences University of Wisconsin

- Madison 1225 W. Dayton St Madison, WI 53706



# Requested	change

§103.1 (b) prescribes that an ultralight vehicle is a vehicle that “ i s used or intended to be used for recreation or sport purposes only .” We seek an expansion of the above definition to include “noncommercial scientific research in the public interest .”



# Proposed	language
We propose that §103.1 be amended to read as follows (changes in bold) : §103.1 T his part prescribes rules governing the operation of ultralight vehicles in the United States. For the purposes of this part, an ultra light vehicle is a vehicle that: (a) (unchanged) (b) Is used or intended to be used only f or recreation, sport, or for noncommercial scientific research in the public interest ; (c)

– (e) (unchanged)



# Public	benefit s A number of universities, government labo ratories, and other noncommercial entities conduct scientific research with support from the National Science Foundation (NSF), the National Aeronautics and Space Administration ( NASA ) , the Department of Energy, and oth er state and federal agencies. Relevant

e xamp les include 1) studies of atmospheric processes that could lead to improved weather forecasts or to improved understanding of interactions between the land or ocea n biosphere and the atmosphere, 2) wildlife and habitat surveys, and 3 ) studies of aircraft or airborne instrument design and performance.
By definition, this research is selected for support by the aforementioned funding agencies because of its potential benefit to the public. U nder current rules, ultralight vehicles cannot be used to conduct scientific research without a case

- by

- case exemption. Yet some kinds of scient ific research would benefit enormously from a long

- term, flexible program of low

- altitude, low

- speed measurements or observations that only an ultralight vehicle can make possible

. Specifically, it is difficult and dangerous to operate larger, faster

, certificated aircraf t at extremely low altitudes (below 100 feet) , especially over irregu lar terrain and/or within confined operating areas. Indeed, there are classes of measurements and observations that simply cannot be made effectively at all from conventional cert ificated aircraft.
Finally, b eing able to conduct airborne science investigations un der Part 103 would also greatly reduce the research expenses born by the taxpayer by allowing the use of ultralights with their sharply reduced fuel, maintenance, hangaring, and inspection costs

.

# Safety	c onsiderations
All operating rules affecting safety would remain intact with the requested change to §103.1 (b) . O nly the option to engage in noncommercial scientific research would be added. Professional scientific operators of ultralight vehicles would l ikely be at least as attentive to safety issues as the casual recreational and sport users of ultralights already permitted under §103.1 (b)

. Indeed, u niversities and government labs conducting research using ultralight vehicles would likely impos e stricter internal requirements on operator qualifications, flight operations, and vehicle maintenance than are currently required of recreational and sport users. Furthermore, th se e highly specialized research activities , most likel y conducted only by a very small number of institutions nationally, would not noticeably increase the overall volume of ultralight traffic. Most such operations would occur below 1000 feet altitude, as it is below this altitude that the principle scientif ic benefits of ultralights are realized.



# Summary
Permitting noncommercial scientific operation of ultralights would not measurably decrease public safety but would open important new avenues of scientific research benefiting the public that cannot be safely or inexpensively conducted using conventional certificated aircraft.