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View Full Version : SSA CRC Mandatory ELT Position Paper Posted - SRA Site


Ken Kochanski (KK)
January 17th 05, 09:02 PM
ELT FAQ - SSA Contest Rules Committee Mandatory ELT Position Paper -
Frequently Asked Questions.

http://sailplane-racing.org/
Go to rules section ...

Ken Kochanski
SRA Secretary

Eric Greenwell
January 17th 05, 10:19 PM
Ken Kochanski (KK) wrote:

> ELT FAQ - SSA Contest Rules Committee Mandatory ELT Position Paper -
> Frequently Asked Questions.
>
> http://sailplane-racing.org/
> Go to rules section ...
>
> Ken Kochanski
> SRA Secretary

Looks good, except for this:

"Today, C91 units are no longer allowed in new installations."

My reading of the rules is this applies only to airplanes, not gliders
(91.207 (a) (1). I'm guessing that since they don't require ELTs in
gliders, they don't care what model you use (probably just glad you put
something in). In any case, the c91 units remain legal to use, even in
an airplane, and I hope the RC will not prohibit their use in contests.


--
Change "netto" to "net" to email me directly

Eric Greenwell
Washington State
USA

January 17th 05, 10:48 PM
Eric Greenwell wrote:
> Ken Kochanski (KK) wrote:
>
> > ELT FAQ - SSA Contest Rules Committee Mandatory ELT Position Paper
-
> > Frequently Asked Questions.
> >
> > http://sailplane-racing.org/
> > Go to rules section ...
> >
> > Ken Kochanski
> > SRA Secretary
>
> Looks good, except for this:
>
> "Today, C91 units are no longer allowed in new installations."
>
> My reading of the rules is this applies only to airplanes, not
gliders
> (91.207 (a) (1). I'm guessing that since they don't require ELTs in
> gliders, they don't care what model you use (probably just glad you
put
> something in). In any case, the c91 units remain legal to use, even
in
> an airplane, and I hope the RC will not prohibit their use in
contests.
>
>
> --
> Change "netto" to "net" to email me directly
>
> Eric Greenwell
> Washington State
> USA


Reply:
RC is changing the text of the rule to include both TSO 91 and 91a.
There was no intention to exclude and this change will correct this
point.
Thanks to Eric for bringing it to our attention.
Given that production has been to 91a since about 1985, it is pretty
likely that new insatllations will be 91a units. The economical units
fall into that catagory.
H Nixon UH
SSA Contest Rules Committee Chair

Kevin Christner
January 17th 05, 11:10 PM
Why does the unit have to be a TSO'd type? For an experimental glider
the Filser ELT would work fine. Why not just have the rule say a
"legal ELT installation"???

Marc Ramsey
January 17th 05, 11:25 PM
Ken Kochanski (KK) wrote:
> ELT FAQ - SSA Contest Rules Committee Mandatory ELT Position Paper -
> Frequently Asked Questions.
>
> http://sailplane-racing.org/
> Go to rules section ...

The FAQ doesn't cover some obvious questions like:

1) Can the owner (assuming that he/she is not an A&P) legally
install a TSO C-91(a) ELT in an experimental glider?

2) Can the owner legally install a TSO C-91a ELT in a
certified glider?

Marc

January 17th 05, 11:34 PM
Eric,

interesting reading. Parachutes are not required in sailplanes, but if
you wear one, it's supposed to be current. Does the same apply? (I'm
not looking for a discussion, just an interpretation. I had a friend
once claim his parachute was a seat cushion, and thus exempt from FAA
rulemaking. It was his business whether he jumped out of his glider
wearing only a seat cushion. ;-)

As for the rule, compliance is relatively cheap, and in the best
tradition of freedom of choice, we can measure value as we please. How
does it go? "A ten dollar helmet for a $10 head?"

Any sailors out there? Do you typically go for the cheapest available
EPIRBs? My only experience is with avalanche beacons. I chose the best
for two reasons. To increase my chances of being found, and to be able
to more effectively locate others. Since it's my friends who'll be
looking for me, or I for them, it seemed an argument of quality over
cost.

Jim Phoenix
January 18th 05, 02:47 AM
No,

Installing a fixed ELT in a certified glider is a minor alteration and
requires an A&P. In some places, the local Feds might decide it's a major
alteration, but that's unlikely.

In any case, the actions described in Part 43, Appendix A as Preventive
Maintenance (may be accomplished by Private Pilot) does not include any
minor alteration - specifically it does not include installing an ELT.

For experimental aircraft - check your Operating Limitations, there are
differences regarding what documentation or approval is required for an
alteration - and mine says no major alterations unless documented per Part
43, so it requires a 337. For a minor alteration on my experimental glider,
as an A&P, I sign it off in the logbook - same as my standard airworthiness
certificated glider. For a major alteration, I use my IA certificate on my
standard glider - and my A&P on my experimental glider and file the 337's
the same way.

Jim


"Marc Ramsey" > wrote in message
m...
> Ken Kochanski (KK) wrote:
>> ELT FAQ - SSA Contest Rules Committee Mandatory ELT Position Paper -
>> Frequently Asked Questions.
>>
>> http://sailplane-racing.org/
>> Go to rules section ...
>
> The FAQ doesn't cover some obvious questions like:
>
> 1) Can the owner (assuming that he/she is not an A&P) legally
> install a TSO C-91(a) ELT in an experimental glider?
>
> 2) Can the owner legally install a TSO C-91a ELT in a
> certified glider?
>
> Marc

BTIZ
January 18th 05, 02:59 AM
> not looking for a discussion, just an interpretation. I had a friend
> once claim his parachute was a seat cushion, and thus exempt from FAA
> rulemaking. It was his business whether he jumped out of his glider
> wearing only a seat cushion. ;-)

A parachute style seat cushion.. interesting concept.. but I don't think the
FAA would be laughing..

BT

Eric Greenwell
January 18th 05, 03:46 AM
wrote:

> As for the rule, compliance is relatively cheap, and in the best
> tradition of freedom of choice, we can measure value as we please. How
> does it go? "A ten dollar helmet for a $10 head?"

I'm interested in the situation because I had a c91 unit installed
several years ago. I don't expect most pilots to opt for one because
they are much more expensive that some of the c91a units, but I got one
because it was much smaller and easier to mount, in part because of the
self-contained antenna.

I don't know how much less "quality" it has (it is lower power), but for
one contest a year, I'd like to stick with it until the 406 mhz units
are a lot cheaper. Also, my transponder may actually give a better
location than the ELT, assuming the searchers can get the radar trail
from ATC - don't know how easy that is to do.

--
Change "netto" to "net" to email me directly

Eric Greenwell
Washington State
USA

Marc Ramsey
January 18th 05, 03:52 AM
Jim Phoenix wrote:
> No,
>
> Installing a fixed ELT in a certified glider is a minor alteration and
> requires an A&P. In some places, the local Feds might decide it's a major
> alteration, but that's unlikely.

Hmm, for those of us who have to *pay* our A&Ps to do things, the $300
ELT appears to be a mythical creature.

> In any case, the actions described in Part 43, Appendix A as Preventive
> Maintenance (may be accomplished by Private Pilot) does not include any
> minor alteration - specifically it does not include installing an ELT.
>
> For experimental aircraft - check your Operating Limitations, there are
> differences regarding what documentation or approval is required for an
> alteration - and mine says no major alterations unless documented per Part
> 43, so it requires a 337. For a minor alteration on my experimental glider,
> as an A&P, I sign it off in the logbook - same as my standard airworthiness
> certificated glider. For a major alteration, I use my IA certificate on my
> standard glider - and my A&P on my experimental glider and file the 337's
> the same way.

For my experimental glider, the relevant limitation reads:

Aircraft instruments and equipment installed and used under 14
CFR part 91.205 must be inspected and maintained in accordance
with the requirements for those instruments found in 14 CFR
parts 43 and 91.

This puts an ELT in a gray area, as I'm not required to install one
under 91.205, but ELTs are one of instruments listed in 91.205. I
suspect the proper interpretation is that I can't simply install one
and sign the logbook (as a non-A&P), as I could with other minor
alterations.

Given current shop rates out here, the need to pull wires for the remote
control panel, and the issue of where to mount an antenna in a carbon
fiber fuselage, I'll be quite lucky if my $300 ELT costs me less than
$600. And, if someone on the RC decides that a C-91A ELT isn't good
enough a few years down the line, I get to throw it away and install a
C-126 ELT. Maybe I should take up knitting...

Thanks,
Marc

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