Bits and Pieces
Canadian Ultralight Aeroplanes vs. U.S. Ultralight Vehicles
By Kathy Lubitz, EAA 640605, for Bits and Pieces
There’s a lot of confusion in Canada about our ultralight regulations mainly because a lot of what we read about ultralights originates in the United States where the rules are significantly different. Rules vary in Europe and other countries around the world as well, but we’ll stick to the United States for this comparison.
The biggest difference between ultralights in Canada and the United States is that in Canada our ultralights are aeroplanes, and they require registration and pilot licensing to be legally flown. In the United States, as long as the ultralight meets U.S. Federal Aviation Regulation 103, it’s a vehicle, not an aircraft, and it doesn’t require FAA registration or an FAA pilot certificate to be legally flown.
According to the Canadian Aviation Regulations, an aeroplane is “a power-driven heavier-than-air aircraft that derives its lift in flight from aerodynamic reactions on surfaces that remain fixed during flight”.
Close reading of the definition means that gliders can’t be Canadian ultralight aeroplanes because they aren’t power driven. Helicopters and autogyros can’t be Canadian ultralight aeroplanes because they aren’t aeroplanes; they’re aircraft whose surfaces don’t remain fixed during flight—they rotate.
There are three configurations of Canadian ultralights: two- or three-axis fixed wing planes;weight-shift trikes; and for licensing and registration purposes, powered parachutes and foot-launched powered paragliders.
In the United States, ultralight vehicles aren’t required to have their lifting surfaces remain fixed during flight which means that autogyos and helicopters can be U.S. ultralight vehicles as long as they meet FAR 103. Since there’s no requirement to be power driven, gliders
and hang gliders also can be U.S. ultralights.
U.S. Federal Aviation Regulation (FAR) 103
According to FAR 103, an unpowered U.S. ultralight vehicle must weigh less than 155 pounds. A powered U.S. ultralight vehicle must:
- weigh less than 254 pounds empty, excluding floats and safety devices which are intended for deployment in a potentially catastrophic situation
- have a fuel capacity not exceeding 5 U.S. gallons
- must not be capable of more than 55 knots calibrated airspeed at full power in
- have a power-off stall speed not exceeding 24 knots calibrated airspeed.
Canadian Aviation Regulation (CAR) 101.01
Part 1 of the CARs is where you’ll find the definitions for Canadian ultralight aeroplanes. Ultralights are defined as either “an advanced ultra-light aeroplane” or a “basic ultra-light aeroplane”.
The definition of a Canadian basic ultralight is “an aeroplane having no more than two seats, designed and manufactured to have:
a) a maximum takeoff weight not exceeding 544 kilograms (1200 pounds)
b) a stall speed in the landing configuration of 39 knots or 45 mph indicated airspeed,
or less, at the maximum take-off weight.”
The Canadian basic ultralight aeroplane has no fuel quantity or top speed restrictions, only a max stall speed and a max takeoff weight. Just as the FAR 103 ultralight vehicle has no requirement for “airworthiness,” there are no regulatory “airworthiness” requirements for basic ultralight aeroplanes. There are no inspections required before a Canadian basic ultralight is first flown or for maintenance after it is flying.
However, common sense requires that the owner maintain a basic ultralight in safe flying condition. Non-regulatory considerations, including self-preservation, economic vested interest, and liability, are more significant issues than regulatory requirements.
Unlike the U.S. ultralight vehicle which is limited to a single seat, a Canadian ultralight can have two seats. However, because there are no regulatory requirements for the airworthiness of basic ultralights, passengers can’t be carried in two-place basicultralights. It doesn’t matter what license the pilot holds; he can’t carry a passenger in a basic ultralight aeroplane. (A passenger is considered to be someone who is from the “general public” with no aviation background to judge the risk of getting into an aeroplane with no regulatory design, construction, or maintenance standards.)
The second seat of a two-place basic ultralight can be only occupied if the second person is also a pilot (he isn’t considered to be a passenger because he can judge the risk), or if the second person is a student receiving flight training from a qualified flight instructor.
The definition of an advanced ultralight in the regulations is “an aeroplane that has a type design that is in compliance with the standards specified in the manual entitled Design Standards for Advanced Ultra-light Aeroplanes”.For an aeroplane to be registered as an advanced ultralight aeroplane, it must first be onTransport Canada’s Listing of Models Eligible to Be Registered as Advanced Ultra-Light Aeroplanes.
The list can be found at this location on Transport Canada’s website.
Before a plane can be added to the list, first the manufacturer must prepare paperwork for Transport Canada including a Document of Conformity assuring Transport Canada that the plane meets the design standards cited in the regulations.
Currently the design standards include:
- a max takeoff weight of 1,232 pounds; no extra weight allowance for floats or emergency equipment such as an emergency parachute
- a max stall speed in the landing configuration of 39 knots or 45 mph or less
- a minimum useful load which is calculated based on engine horsepower.
The manufacturer of an advanced ultralight aeroplane must also:
- Issue a Statement of Conformity before an individual plane is first registered and flown. (He may elect to inspect the finished plane before he issues the statement.)
- Provide a maintenance schedule for the aeroplane.
- Notify owners when there is a problem or a service difficulty.
- Make sure owners’ modifications to the aeroplane do not affect the type design.
There’s also a Fit for Flight Form that is signed by the owner each time the advancedultralight aeroplane is sold. Because there is assurance from the manufacturer before the plane is first flown that it meets the design standards and from each owner that it continues to meet the design standards, Transport Canada allows passengers to be carried in advanced ultralights, but only if the pilot has a license or permit that allows him to carry a passenger.
Advanced ultralight aeroplanes can be built from kit or completely factory built. Any advanced ultralight can be used for flight training (just as any basic ultralight can be used for flight training). Because of the way the design standards are written, only three-axis fixed-wing aircraft can qualify as advanced ultralight aeroplanes. There are no weight-shift trikes or powered parachute advanced ultralights in Canada.
Light Sport Aircraft vs. Advanced Ultralight Aeroplanes
Have you noticed that our Canadian ultralight aeroplanes are significantly heavier than U.S. ultralight vehicles? In fact, the weight allowances for Canadian basic and advanced ultralights resemble the weight limits of the U.S. light-sport aircraft (LSA). Let’s look at LSA.
There are two types of U.S. LSA:
1) special light-sport aircraft (S-LSA) which are completely finished and test-flown by the manufacturer.
2) experimental light-sport aircraft (E-LSA) which can either be built from an approved kit or assembled completely by the manufacturer.
I’ve included a table comparing the U.S. ultralight vehicle and light-sport aircraft to our Canadian basic and advanced ultralight aeroplanes. There are many similarities and there are also significant differences. Here is a useful chart that summarizes the differences.
A Little History
The U.S. FAR 103 rules and the Canadian ultralight rules both went into effect in the early 1980s. At first, ultralights were single seat. Then two-seat ultralights were developed which allowed for training on these lightweight, little planes. In the mid-1980s, the United States allowed an exemption to FAR 103 to allow two-place ultralight trainers. Transport Canada added two-place trainers to its definition.
In 1991, Transport Canada published the Design Standards for Advanced Ultra-light Aeroplanes which were developed by the Canadian manufacturers. This created the advanced ultralight aeroplane and distinguished from what we now call the basicultralight aeroplane. In 2003, the basic ultralight was changed to a gross weight and stall speed definition; there was also a weight increase.
The United States developed the LSA rules in 2004. The requirements for LSA are so similar to our Canadian advanced ultralight rules because the ASTM International standards started with the Canadian Design Standards for Advanced Ultra-light Aeroplanes. Many manufacturers of current U.S. LSA had their planes flying in Canada as advanced ultralight aeroplanes long before there was a U.S. LSA category.
The gross weight of the advanced ultralight aeroplane was increased in 2003 to 1,232 pounds to match the proposed gross weight for the LSA. When the LSA was finally introduced in 2004, it was at the higher 1,320-pound weight. There has been no increase in the weight limits of the design standards, and none is anticipated at this time. Maintenance requirements didn’t change.
In the United States, the LSA has replaced the two-place ultralight training vehicle. The only legal ultralights in the United States right now are single-seat ultralight vehicles that meet FAR 103.
There are both positives and negatives in the rules of both countries. The freedom of FAR
103 in the United States is enviable. On the other hand, the rules for the heavier LSA in the United States involve a lot more - some would say too much more - government oversight.
In Canada, federal registration and pilot licensing give our basic and advanced ultralights some official status and a degree of credibility within the aviation community and with the general public. The relatively minimal rules we enjoy here in Canada have been working well for our ultralight community. Let’s keep it that way.