Wednesday, July 29, 2009

far 103 regulations - my comments

Hey, I'm still up so it's time for a second post.

One thing that I've noticed as we've talked to many people here is confusion as to what FAA part 103 (or FAR part 103) is.

We've had some people tell us that it specifically disallows engines with greater than 28HP on wings that have double covering. That's simply not so!

I've also had people tell me that FAA part 103 doesn't allow me to put "Belite Aircraft" on my wing, because that represents 'advertising'. I've carefully read part 103, and I respectfully disagree. There are parts that say an Ultralight can't be used for advertising. A careful reading suggests you can't take money to use the aircraft for advertising someone else's product, and I agree with that interpretation. Backing up that interpretation is another part of part 103, which the naysayers ignore.

Quoting part AC 103-7, specifically 103.14.d(4):

Receiving Discount on Purchase of an Ultralight.

There is no prohibition which would prevent you from taking
advantage of any discount on the price of an ultralight a company
might offer where its logo or name appears on a portion of the
vehicle. You cannot, however, enter into any agreement which
might specify the location; number, or patterns of flights contingent
on receipt of that discount.


Any operation under such an agreement could not be
conducted under Part 103.


This seems pretty straightforward. I, as the manufacturer, can put my logos on my aircraft anywhere I please, including the wings. You, as the customer, can receive a discount if you agree to accept an eggregiously large number of logos in many locations. Heck, let's put them on the tail, the belly, the cowling, the door, the upper wing, the lower wing, the landing gear, the left tire, and just for grins, on the windshield. However, I can not enter into an agreement with you where you agree to fly your plane for my benefit, for a specificed number of flights, or over a specified location.

That's a good thing, because I'd want you to fly over a congested location. ;-)

Fly Safe,

James

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