The International Cessna^® 170 Association

N9149A wrote:

iowa wrote:did i start all this?
iowa

It would appear from George's last response he is only talking about ELTs with Durocells when we is calling for battery replacement yearly. Somewhere in the thread that was lost.

Well Bruce, that's what happens when you install Durocells. If you bought Duracells you might be able to last longer.

BTW, nice watch you got there... what is that, a Romex?

Doug I did that intentionally to see who was sleeping.

The original question was whether an owner/pilot could change ELT batteries. I quoted AC 91-44A, which seems to say quite clearly that in some circumstances, he or she can: "The replacement can be done by the pilot...."

George joined the discussion to say that FSDOs disagree with something either Bruce or I said (he wasn't specific), but it quickly became a discussion of whether Duracell batteries could be used until their printed expiration date or not. Reading back over all this, it isn't clear if George is saying the FSDOs also disagree with the statement in 91-44A, that in simple installations, the pilot can change the battery.

I understand that there are ELT checks that must be performed annually, and those can't be done by the owner/pilot. But, George, what about the original question: are the FSDOs actually contradicting the AC about battery replacement by the owner/pilot?

Best Regards,

John

N9149A wrote:... In the case of Durocells (sic) according to George...

Actually, ... not according to me,.... according to some FSDO Inspectors. I'm just the messenger you guys are lining up to be shot.

N9149A wrote:... Depending on what FSDO you live in you a pilot can to perform this task but everywhere an A&P can change the batteries and perform the test.

John, I did address this question.... According to the Advisory Circular 91-44A previously referenced,... if the ELT is located in an area not accessable without a screwdriver... then it's a "complex" operation and may not be considered preventive maintenance.
Specifically the AC states: "Fixed type ELT installations are often permanently mounted in a remote area of the aircraft near flight control cables, vital aircraft components and critical attachments to the aircraft structure. Installations of this nature require an external antenna and often a remote on/off transmitter control switch that is usually located near the pilot's flight position. This type installation is complex and battery replacement should be accomplished by a certificated mechanic or certificated repair station." (Bold added by me to assist anyone wishing a more explicit description of an installation that will not allow the pilot to service/replace the ELT batteries.)

That's just silly! I can change my tires (something that seems pretty simple unless you screw it up!) but I can't unscrew an access cover to reach in to change my elt battery?

Sorry, I just wanted to stir the pot a little!

As I said in an earlier post I e-mailed the Houston FSDO from their website asking about this and haven't heard from them. Real nice system they have!
David

gahorn wrote:John, I did address this question.... According to the Advisory Circular 91-44A previously referenced,... if the ELT is located in an area not accessable without a screwdriver... then it's a "complex" operation and may not be considered preventive maintenance....)

Thanks, George. I was aware of the AC -- in fact, I quoted the same section you did, and I thought maybe that's what you were responding to in your original post. "Without a scewdriver" sounds like an interpretation of the AC. Yours? Or the FSDO's? What I was really wondering about is whether the FSDOs are saying a pilot cannot change a battery, or the details of how they interpret the AC on this specific point.

Thanks,

John

jrenwick wrote:

gahorn wrote:John, I did address this question.... According to the Advisory Circular 91-44A previously referenced,... if the ELT is located in an area not accessable without a screwdriver... then it's a "complex" operation and may not be considered preventive maintenance....)

Thanks, George. I was aware of the AC -- in fact, I quoted the same section you did, and I thought maybe that's what you were responding to in your original post. "Without a scewdriver" sounds like an interpretation of the AC. Yours? Or the FSDO's? What I was really wondering about is whether the FSDOs are saying a pilot cannot change a battery, or the details of how they interpret the AC on this specific point.

Thanks,

John

The "without a screwdriver" comment is my own cavalier description of what they consider a "complex" operation.... which in their written opinion is anything requiring access to an area of the aircraft requireing tools and/or is mounted to airframe structure in the vicinity of control cables etc. and having a seperately mounted antenna (i.e. anything other than a cockpit mounted, removeable, self-contained antenna type of ELT.)

I have to admit that I am as amazed at their definition of preventive maintenance as Dave (dacker) is.... Another example is the fact that anyone wishing to change their tires will have to remove/reinstall the brake calipers and friction-pads/plates from the aircraft in order to remove the wheel/tire.... yet replacing the brake pads is NOT allowed under preventive mx. (Hey, they didn't consult with me before writing the rules...)

Like it or not, the written rule is: The Rule.

gahorn wrote:.... According to the Advisory Circular 91-44A previously referenced,... if the ELT is located in an area not accessable without a screwdriver... then it's a "complex" operation and may not be considered preventive maintenance.

Whew, that was a close one! Since my rear seat back is hinged with clevises and quick release pins, I can still access the area behind the baggage compartment without a screwdriver, so I can still change my own ELT batteries. Ah, the sweet taste of freedom!

Miles

cessna170bdriver wrote:

gahorn wrote:.... According to the Advisory Circular 91-44A previously referenced,... if the ELT is located in an area not accessable without a screwdriver... then it's a "complex" operation and may not be considered preventive maintenance.

Whew, that was a close one! Since my rear seat back is hinged with clevises and quick release pins, I can still access the area behind the baggage compartment without a screwdriver, so I can still change my own ELT batteries. Ah, the sweet taste of freedom!

Miles

Hey, Miles, would you send me a copy of the 337 for the clevis's and quick release pins? I'd like to do that mod also! Oh. Wait. My ELT is located on it's own shelf behind the bagg compartment bulkhead, and it's antenna is seperately mounted on the rear fuselage. DANG!

My baggage bulkhead is a piece of canvas that snaps into place but the ELT is on its own shelf with a remote antenna. Can I change my battery?

Oh yea I’m an A&P so I guess I can.

Bill Hart wrote:My baggage bulkhead is a piece of canvas that snaps into place but the ELT is on its own shelf with a remote antenna. Can I change my battery?

Oh yea I’m an A&P so I guess I can.

Yes, but you'll have to charge an hour for it.

I knew there was a catch!

Bill Hart wrote:I knew there was a catch!

Bill, in your case there is a snap not a catch, also weather needed or not you will have to have access to a screw driver.

Well I got a reply from the Houston FSDO...I think. It was short, terse, and had been passed down from two other people for action. It said
"Read 91.207 (C) and 91.207(D).
AC 91.44 Para 8 page 6 refers to portable ELTs.
14CFR Part 43 Appendix A (C) Item 24 Refers to Aircraft Batteries not ELT Batteries.
If any questions call...".
I read this response and AC 91.44 as I CAN reach behind my seat, lift out the ELT and change my EBC-102 ELT battery (150 mile portable ELT).
I do not question whether I can inspect the ELT or not.
David

gahorn wrote:

Bill Hart wrote:My baggage bulkhead is a piece of canvas that snaps into place but the ELT is on its own shelf with a remote antenna. Can I change my battery?

Oh yea I’m an A&P so I guess I can.

Yes, but you'll have to charge an hour for it.

WOW!
I knew I was doing something wrong! I only charge 15 min.
brad