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 “is 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 This part prescribes rules governing the operation of ultralight vehicles in the 

United States. For the purposes of this part, an ultralight vehicle is a vehicle that:

(a) (unchanged)

(b) Is used or intended to be used only for recreation, sport, or for noncommercial 

scientific research in the public interest;

(c)–(e) (unchanged)

Public	benefits

A number of universities, government laboratories, 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 other state and federal agencies. Relevant 

examples include 1) studies of atmospheric processes that could lead to improved weather forecasts or to 

improved understanding of interactions between the land or ocean 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. Under current rules, ultralight vehicles cannot be used to conduct scientific 

research without a case-by-case exemption. Yet some kinds of scientific 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 aircraft at extremely low 

altitudes (below 100 feet), especially over irregular 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 certificated aircraft.

Finally, being able to conduct airborne science investigations under 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	considerations

All operating rules affecting safety would remain intact with the requested change to §103.1(b). Only the 

option to engage in noncommercial scientific research would be added. Professional scientific operators of 

ultralight vehicles would likely be at least as attentive to safety issues as the casual recreational and sport 

users of ultralights already permitted under §103.1(b). Indeed, universities and government labs 

conducting research using ultralight vehicles would likely impose stricter internal requirements on operator 

qualifications, flight operations, and vehicle maintenance than are currently required of recreational and 

sport users. Furthermore, thsee highly specialized research activities, most likely 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 scientific 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.