Part 103 Ultralights

Aircraft Type: Gas Cluster Balloon
Aircraft N number: N897LT
Aircraft Owner: Trent Tresch
Overview: The proposed aircraft for airworthiness certification is unknown to have a type certificate.
The only known cluster balloon registered belongs to Jon Trappe of Raleigh North Carolina: N878UP.
N897LT consists of single use balloons, latex or chloroplorene filled with hydrogen gas. These balloons
and gasses are replaced for each flight. There are then tethers that connect the balloons to the pilot’s
harness. The pilot harness contains a main and reserve parachute. Ballast in the form of dried sand or
water/antifreeze mix.
Increasing or decreasing the number of balloons will determine the aircrafts maximum altitude. Below
you can find example balloon configuration diagrams and photos of operations in 2019 and 2020.

Introduction

The purpose of this paper is to demonstrate undeniable evidence that the cluster balloon plans submitted to the FAA’s Seattle FSDO qualify as an ultralight. Documents needed for this evaluation are AC 103-7 as found on the FAA website here: https://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/22640 all other sources are outlined in the paper respectively.

I have also attached an example drawn copy of the ballooning system sent to Mr. Miller with the outline that the pilot will carry: two reserve parachute systems, appropriate oxygen equipment and/or pressure system, ICOM aviation band transceiver IC-A3, transponder with mode C and 4096 codes or mode S, GPS Spot tracker, Automatic Packet Reporting System (APRS tracker), ground team communications.

Abstract

It is well recorded that people have flown ultralight cluster balloons in the USA since 1937 to the 2010’s. These aircraft are recognized by the FAI as class AA balloons.

The proposed aircraft to the FAA on May 1^st 2020 was for a tiered ultralight manned free balloon. The system fully complies with FAR 103.1 subsection 12 (a), (b), (c) and (d) beyond reasonable doubt. The proposed craft even maintains “Satisfactory Evidence” in support of ultralight class as outlined by the FAA in 103.1 section 24(b)(1) and (2).

Aircraft nearly identical to this proposal have been flown by John Ninomiya over 80 times throughout the USA under FAR 103 as an ultralight. Kent Couch of Couch Balloons has flown multiple cluster balloons, nearly identical to this design, as ultralights in Bend OR from 2006 to 2008. Kent and others do not hold any airman certificates as per the FAA airman registry and their systems are flown under FAR 103. Even though there has been over 80 cluster balloon flights, there are no recorded incidences of these ultralight balloon systems in the National Transportation Safety Board Aviation Accident Database.¹

Given the overwhelming evidence, it is undoubtably clear that the proposed balloon cluster is an ultralight and can be flown safely as so.

Photo: Kevin Walsh cluster balloon, 1984

Satisfactory Evidence

Compliance with FAR 103

Section 103 .1 defines the scope of part 103, stating that the part “prescribes rules governing the operation of ultralight vehicles in the United States.” The same section continues, in relevant part, by defining ultralight vehicles as any “vehicle that: (a) is used or intended to be used for manned operation in the air by a single occupant; (b) is used or intended to be used for recreation or sport purposes only; ( c) does not have any U.S. or foreign airworthiness certificate; and (d) if unpowered, weighs less than 155 pounds …. “. This is validated through the FAA’s legal interpretations division² as well as FAA advisory Circular 103-7. ³

AC 103-7 section 1

Our answers to the following standards.

Subsection 12 (a): You are Limited to Single-Occupant Operations.

Answer: Our proposed system has only a single occupant as given to the FAA’s ARTCC Kevin J. Miller on May 1^st 2020.

Subsection 12 (b): You are Limited to Recreation and Sport Purposes.

Answer: We have confirmed over the phone with Portland FSDO’s Marty G. Conroy that our flights are recreational. There is no “task” to complete except to fly.

Subsection 12 (c): No airworthiness certificate.

Answer: The proposed aircraft has never had an airworthiness certificate.

Subsection 12 (b): Unpowered Vehicles. An unpowered ultralight cannot be operated under

Part 103 if it weighs 155 pounds or more. Balloons and gliders are unpowered

vehicles.

Answer: The calculated weight of the free balloon system is below 155lbs. Please see section verification of flight system weight, can be found in table of contents.

AC 103-7 section 24 subsection B. (page 13)

These standards outline the satisfactory evidence we aim to obtain in support of our ultralight.

Subsection B (1): Determination of the maximum level flight speed by use of appendix 1 and 2.

Answer: We do not have a level flight speed as we are an unpowered aircraft. Thus cannot exceed the maximum limitation.

Subsection B (2): FAA certified mechanic can weigh the ultralight to determine it meets the standard.

Answer: We have calculated the weight on paper (see section on verification of flight system weight) and have built the system. We can have a certified mechanic provide official documentation.

Verification of flight system weight

It is stated in AC 103 subsection 16 (a) Unpowered Ultralight Vehicles Eligible for Operation Under Part 103. that, all forms-of gliders and free balloons weighing less than 155 pounds and all other requirements of 103.1 are eligible for operation under Part 103.

We have proven to you that the system meets all aspects of 103.1. However, I would like to elaborate on the system weight determination and verification.

AC 103 subsection 16 (2) determines what is calculated for weight on free balloons. “The envelope, lines, harnesses, gondola, burner, and fuel tank are included in this determination. Parachutes and all personal operating equipment and harnesses associated with their use are not included. The weight of the fuel, in the case of a hot-air balloon, or any logical amount of removable ballast, when intended for control of the buoyancy of a gas balloon, is not included in the weight specified in § 103.1(d).

The following section states, “(d). Free Balloons are Considered “Unpowered.” A balloon, for Part 103 eligibility, is considered an unpowered ultralight, regardless of whether it drops ballast to ascend or uses heated air. The burner on a hot-air balloon is – used to raise the temperature of the air in the envelope allowing the balloon to rise. This can be compared to the glider’s use of lifting air as a means of ascending. In both cases, no method of horizontal propulsion is employed and a loss of the lifting force will cause the vehicle to descend to the surface.”

This clearly outlines the standards for our proposed system. Below is an on paper break down which can be verified by an official weighing by an FAA certified aircraft mechanic.

Item’s included in weight	Approximate Weight
550 paracord, 200 feet	1.25 lbs
5mm perlon cord, 100 feet	.5 lbs
Latex rubber balloons, 20	30 lbs
Connection rings, 20	3 lbs
Vinyl hose, 100 feet	24 lbs
Metal ball valves, 6	12 lbs
Total:	70.75 lbs

As outlined above we are not required to include parachutes, parachute harness, personal operating equipment or ballast. However, we have done the additional calculations below as a reference.

Item’s not included	Approximate weight
Parachute harness	10 lbs
Parachutes, 2	20 lbs
Water ballast	20 lbs
Other Misc./operating equipment	10 lbs
Total:	60 lbs

Taking both the included and unincluded weights we would be at: 130.75 pounds which is almost 20 pounds below the acceptable weight to operate under FAR 103.

History of Cluster Ballooning

This history section is provided to show the track record of cluster ballooning from the 1930’s to modern day. It is also to show examples of modern pilots who have flown these systems as ultralights.

Jean Piccard first conceived of the notion of using clusters of gas balloons to fly, and in 1937 tested his concept in a flight to 10,000 feet using 98 latex weather balloons attached to a conventional balloon basket. ⁴ ⁵

Gary Cashman made several flights in 1954 around the Albany, New York area using hydrogen-filled weather balloons attached to a seat on which he rode.

Don Piccard, son of Jean and a major figure in the development of the modern sport of hot-air ballooning, made flights using clusters of plastic balloons in 1957 and 1962, including a flight to 17,747 feet that still stands as a world altitude record for category AA-2 balloons. AA class balloons are recognized through the FAI.⁶

Larry Walters, without any prior experience with ballooning or aviation, attached 40 helium balloons to a lawn chair, flying to 16,000 feet over Long Beach, California on July 2, 1982. ⁷ ⁸

Kevin Walsh made a flight to 9,000 feet with 57 helium balloons and descended by parachute on New Year’s Day, 1984, in Stow, Massachusetts.⁹ ¹⁰

Mike Howard, attempted to fly to 18,000 feet for the Guiness Book of World Records TV show on FOX in 1998. Unfortunately, his lift calculations were apparently wrong, and he ended up unable to get above 3,000 feet. In 2001, he tried again, this time with partner Steve Davis and succeeded in reaching 18,235 feet. This was also asserted to be a record of some sort, although Howard’s balloons (up to five feet) were arguably too large for the “party balloon” record, and his altitude was several thousand feet short of the 21,400 foot mark set by John Ninomiya in 1998.

John Ninomiya went for his first cluster balloon flight in 1997, and obtained a record altitude of 21,4000 feet in 1998. It is recorded that John has flown these systems 82 times throughout the USA under FAR 103.¹¹ John N. has done a flight in Winthrop WA on 3/6/2010.

Jonathan Trappe is legal to fly a bunch of gas balloons through the sky. The lawn chair has been replaced by a carbon fiber cradle. The balloons are the same as those used for advertising. The vehicle, for want of a better term, has an official N number and an airworthiness certificate titled “Experimental Exhibition Manned Free Balloon N878UP.” It’s not the chair, but the balloons, that are certified. It is the only cluster balloon with an airworthiness certificate in the United States.¹²

Kent Couch of Couch Balloons has flown multiple cluster balloons as ultralights in Bend OR from 2006 to 2008.¹³ Kent does not hold any airman certificates as per the FAA airman registry. ¹⁴

John Freis’, October 10th, 2009 flew his first cluster balloon flight out of Borrego Springs, California.¹⁵

Other general references:

https://www.ntsb.gov/_layouts/ntsb.aviation/index.aspx

2 https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2015/Palmaz-US%20Hang%20Gliding%20&%20Paragliding%20Assoc%20-%20(2015)%20Legal%20Interpretation.pdf

3 https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_103-7.pdf

4 http://www.clusterballoon.org/history.htm

5 https://stratocat.com.ar/stratopedia/171.htm

6 https://www.fai.org/sites/default/files/documents/sc1_2013_v2.pdf

7 https://www.aopa.org/news-and-media/all-news/2010/july/pilot/pilot-briefing-(6)

8 https://www.upi.com/Archives/1983/04/06/FAA-drops-one-charge-against-lawn-chair-pilot/1353418453200/

9 https://www.57balloons.com/

10 http://www.aprealis.com/