The International Cessna^® 170 Association

gahorn wrote:Yeah, I've been there with them, John. The problem arises when the ELT is located in a compartment aft of the baggage bulkhead requiring removal of that bulkhead (like most permanent installations), and also of the need to disassemble some models of ELT's to gain access to the battery compartment.

Well, yeah, but you made kind of a blanket statement that pilots can't change ELT batteries. I've got three airplanes with ELTs in the baggage compartments that can be removed and reinstalled without using tools. I'll bet this is true more often than not in older aircraft like ours, where the ELT is a retrofit. In this situation the AC would seem to say very directly that the pilot can replace the batteries. Just saying....

gahorn wrote:Re: AC 91.44A section 8(a) does NOT APPLY to Part 91 operators: This specifies that a FAR 135 operator may train his pilots to replace ELT batteries. Quote:"The replacement can be done by the pilot if the preventive maintenance limitations of Part 43.3(h) of the FAR, are complied with." (FAR 43.3(h) pertains only to FAR 135 (air taxi/commercial) operators.)

The way I read that, if I'm operating under part 91, then I don't worry about 43.3(h), because that paragraph simply expands the rules for part 135 operators. (g) still governs non-135 operations.

jrenwick wrote: Sorry, Bruce, you're stretching the meaning too far here. From AC 43-12a, final paragraph (emphasis is mine):

Items 6 and 23 (Part 43, Appendix A, paragraph (c)). These items permit the draining and reservicing of oil, and the removal, cleaning and reinstallation of oil screens, filters, and strainers in an aircraft oil system to be done as preventive maintenance, and are subject to the provisions of Sections 43.13(a) and (b).

OK I retract my past post. I knew I should have dragged out the FAR and read the whole thing. This makes it pretty cut and dry.

jrenwick wrote:...The way I read that, if I'm operating under part 91, then I don't worry about 43.3(h), because that paragraph simply expands the rules for part 135 operators. (g) still governs non-135 operations.

It doesn't work that way, John. Just because one reg requires another reg to accomplish a task, does not mean that neither reg applies to you because it's inconvenient. One cannot impart convenient meaning to an inconvenient regulation.
The Advisory Circular you quoted SPECIFIES that only under FAR 43.3 (h) may a pilot change the ELT battery. FAR 43.3 (h) ONLY APPLIES to a Part 135 operator...with a training program...with a pilot who has undergone that training,...that also happens to find himself out on the road somewhere WITH NO MECHANIC otherwise available to change that battery!

Unless you are a pilot for a 135 operator who has undergone that training, and find yourself out on a trip somewhere with an expired ELT battery and no other qualified person to accomplish the task may you change that battery. Even if you happen to own the identical airplane personally, and it sits in the adjacent tie down spot with an equally expired battery...you may be qualified to change the battery in your employer's airplane...but NOT YOUR OWN!

Sorry.

gahorn wrote:...The Advisory Circular you quoted SPECIFIES that only under FAR 43.3 (h) may a pilot change the ELT battery....
Sorry.

Here's the text:

The replacement can be done by the pilot if the preventive maintenance limitations of Part 43.3(h) of the FAR, are complied with.

(If there's another reference to Part 135 in this AC, I missed it.)

Part 43.3(h) would limit what I could do if I were a Part 135 pilot, but I'm not. As a Part 91 operator, I'm governed by 43.3(g). I'm in compliance with the limitations of (h), because there aren't any there for me. I think to say that because it mentions (h) it's limited to Part 135 operations is reading something into it that isn't there.

Best Regards,

John

George,

You said, a while back:

gahorn wrote:Re: the Bracket filters again,...one reason some folks feel the Brackett filter excessively reduces MP is failure to follow installation instructions which require the installer to "squeeze excess wettant" from the filter before installation. A simple way to do this is wrap it in a paper towel and squeeze the heck out of it, removing all excess wettant. That's the way it was intended to be installed...without all that extra goop it was packaged with.

I can't find any instruction like this in the documentation I have with the Brackett filter on my 170. Are you sure you're remembering this right? Or could it be from the procedures from some other brand of filter, or that Brackett used to say this, but doesn't any more?

Best Regards,

John

George, we can probably both agree that Part 43 and related ACs aren't examples of the FAA's best writing. To be honest, it's probably only vanity that compels me to write things in the airframe or engine log and sign my name and pilot license number to them. It's probably best if I just stop doing that.

jrenwick wrote: I can't find any instruction like this in the documentation I have with the Brackett filter on my 170. Are you sure you're remembering this right? Or could it be from the procedures from some other brand of filter, or that Brackett used to say this, but doesn't any more.

If I recall correctly it is printed on the package.

Removing the aft bulkhead section of the baggage compartment, a non-structural component held in place by automotive style snap fasteners, in order to gain access to the ELT, to me doesn't meet the complex disassembly requirements of FAR Part 43. While Part 43 doesn't address this issue exactly, neither does it address items like adding air to the tires to spec, which could be debated to be a maintenance function as well. Russ Farris

jrenwick wrote:

gahorn wrote:...The Advisory Circular you quoted SPECIFIES that only under FAR 43.3 (h) may a pilot change the ELT battery....
Sorry.

Here's the text:

The replacement can be done by the pilot if the preventive maintenance limitations of Part 43.3(h) of the FAR, are complied with.

(If there's another reference to Part 135 in this AC, I missed it.)

Part 43.3(h) would limit what I could do if I were a Part 135 pilot, but I'm not. As a Part 91 operator, I'm governed by 43.3(g). I'm in compliance with the limitations of (h), because there aren't any there for me. I think to say that because it mentions (h) it's limited to Part 135 operations is reading something into it that isn't there.

Best Regards,

John

John, the entire verbage of 43.3 (g) and (h) is:
"(g) Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category.

(h) Notwithstanding the provisions of paragraph (g) of this section, the Administrator may approve a certificate holder under Part 135 of this chapter, operating rotorcraft in a remote area, to allow a pilot to perform specific preventive maintenance items provided—

(1) The items of preventive maintenance are a result of a known or suspected mechanical difficulty or malfunction that occurred en route to or in a remote area;

(2) The pilot has satisfactorily completed an approved training program and is authorized in writing by the certificate holder for each item of preventive maintenance that the pilot is authorized to perform;

(3) There is no certificated mechanic available to perform preventive maintenance;(4) The certificate holder has procedures to evaluate the accomplishment of a preventive maintenance item that requires a decision concerning the airworthiness of the rotorcraft; and

(5) The items of preventive maintenance authorized by this section are those listed in paragraph (c) of appendix A of this part."

So, an ordinary Part 61 owner/pilot may perform Preventive Maintenance, and a Part 135 operator can train and allow his pilots to perform Preventive Maintenance on the operator's aircraft even tho' they are not owned by the pilot (and as long as a mechanic is not available, etc etc.)

But the problem still is: Air Filters are not preventive maintenance. They are not listed in para. (c) of Appdx A.
Sorry guys. Changing the air filter is not preventive maintenance. Owner/pilots cannot do it legally.

jrenwick wrote:George, we can probably both agree that Part 43 and related ACs aren't examples of the FAA's best writing. To be honest, it's probably only vanity that compels me to write things in the airframe or engine log and sign my name and pilot license number to them. It's probably best if I just stop doing that.

In the eyes of the authorities, the only thing worse than an unauthorized person performing maintenance is... not recording maintenance performed. The latter offense is considered fraudulently criminal.

But we were talking about changing ELT batteries, in this instance. It still seems to me that's allowed by AC 91-44A if you can just reach in there and remove the ELT without tools.

Sorry, I didn't mean to suggest doing maintenance without logging it. I'll forego my vanity and ask my A&P to log it for me.

The topc title is K & N Air Filters.

ELT batteries are also not on the list of prentive maintenance items. (The battery listed is the main aircraft battery.)

I'm sure I'm not the only one who has forgotten to log mx performed until the IA's presence happens to remind me.