ELT Location - Part II

N941WR · #1 03-28-2006, 10:29 AM

In the past I have posted about the great location I selected for the placement of my ELT. I was so proud of the door I cut in the baggage compartment floor to hide the ELT.

This morning one of our EAA chapter tech inspectors paid me a visit and told me I will have to move the ELT to on top of the baggage compartment floor as any other location would be in violation of the FAR's. Apparently the ELT has to be accessible and putting it behind a door, even one with thumb screws isn?t considered accessible.

I guess I can always turn that door into a compartment to hold a quart of oil like Dan did.

Just wanted to let everyone know that what I thought was a good idea, isn't such a good idea.

BTW, I also asked him about all the RV?s with their ELT's located behind the baggage compartment bulkhead. He replied that is not a good position either and any ELT back there should be moved.

Rick6a · #2 03-28-2006, 11:20 AM

Quote:

Originally Posted by N941WR

....... also asked him about all the RV?s with their ELT's located behind the baggage compartment bulkhead. He replied that is not a good position either and any ELT back there should be moved.

Bill,

I do know of a local RV-7 that got gigged by an FAA inspector from the local FSDO because the ELT was mounted forward of the main spar.

In the case of your ELT location, I'd say....not necessarily. Like so many areas of aviation, interpretation can be an arbitrary and highly personal thing. A technical counselor may certainly have opinions but in the end has no real authority and can only advise. Unless that tech counselor also happens to be the DAR who is going to eventually issue you the airworthiness certificate, I'd forgo any immediate modification just to satisfy his personal bias. My ELT is mounted in virtually the same place as yours and with screws...not thumbscrews...and the DAR (who DOES have the weight of the FAA behind him and subsequently issued my airworthiness certificate) thought its placement was clever. He is fully aware that its location would not be allowed in a certificated airplane, but then he knows full well we are building experimental airplanes.

Rick Galati RV-6A "Darla"

13brv3 · #3 03-28-2006, 11:21 AM

Hi Bill,

Did he point you to any particular FAR that you would be violating? I've never heard that the ELT has to be accessible, though it may have to have a remote display if it's not. I had every intention of putting mine under the baggage cover on the RV-8, but maybe I'll hold off to hear what others have to say about this.

Either way, thanks for the heads up.

Rusty

kevinh · #4 03-28-2006, 11:24 AM

Quote:

Originally Posted by Rick6a

In your case, I'd say....not necessarily. Like so many areas of aviation, interpretation can be an arbitrary and highly personal thing. A technical counselor may certainly have opinions but in the end has no real authority and can only advise. Unless that tech counselor is also the DAR who is going to eventually issue you the airworthiness certificate, I'd forgo any immediate modification just to satisfy his personal bias. My ELT is mounted in virtually the same place as yours and with screws...not thumbscrews...and the DAR (who DOES have the weight of the FAA behind him and subsequently issued my airworthiness certificate) thought its placement was clever. He is fully aware that its location would not be allowed in a certificated airplane, but then he knows full well we are building experimental airplanes.

In fact - I think that such a location is allowed on at least some certified airplanes. I used to fly a (certified) Grob that was behind a screwed down panel and not accessible in flight (or even on the ground without breaking out the screwdriver). I presume that having the accessible remote activation panel is sufficient.

N395V · #5 03-28-2006, 11:42 AM

Mine is behind the rear baggage compartment under a screwed down sheet metal cover. I have seen nothing that would suggest this is illegal.

The success record of ELTs actually performing their function in a crash is dismal so easy access is not a real concern.

aadamson · #6 03-28-2006, 01:11 PM

Ok, here's the layout in my *certified*, *new*, cessna 182T!

The ELT is in the TAIL! yep, behind the baggage bulkhead, behind the rear radio compartment (this is a G1000 182 and the radios are also in the tail). It's mounted on the side of the fuselage about 8' forward of the horz stab. Only access is thru a panel on the outside of the other side of the fuse and it has 12 phillips head screws holding it on. It's about right in the middle of the N number.

I would consider a call to the FSDO and ask, but if the cert guys can do, I see no reason that you can't.

RV6_flyer · #7 03-28-2006, 01:25 PM

Ask the Tech Counselor what FAR you are in violation of. Check FAR 91.207. I do not see a location requirement. 91.207 (b) covers attachement. 91.207 (d) (1) covers installation. It just says proper installation.
http://www.risingup.com/fars/info/part91-207-FAR.shtml

Please let me know what you find.

If the DAR says something wrong (incorrect), contact his managing office and speak with his Principle Inspector or the office manager. Same goes with any FAA Inspector. (Speak to his supervisor or manager.)

I do not think you are in violation if the arrow on the ELT is pointed in the proper direction, the ELT is TSO 91(a), the battery date is good, and there is a log entry saying it was inspected in accordance with 91.207 (d).

BTW. My ELT is BEHIND the bagage compart closeout. You must take screws out to get to it. There is a remote indicator / reset panel up front where the pilot can reach it.

Gary A. Sobek
EAA TC
FAA DAR
RV-6, N157GS, 1,840+ flying hours
http://www.AB-DAR.com

Quote:

Originally Posted by N941WR

In the past I have posted about the great location I selected for the placement of my ELT. I was so proud of the door I cut in the baggage compartment floor to hide the ELT.

This morning one of our EAA chapter tech inspectors paid me a visit and told me I will have to move the ELT to on top of the baggage compartment floor as any other location would be in violation of the FAR's. Apparently the ELT has to be accessible and putting it behind a door, even one with thumb screws isn?t considered accessible.

I guess I can always turn that door into a compartment to hold a quart of oil like Dan did.

Just wanted to let everyone know that what I thought was a good idea, isn't such a good idea.

BTW, I also asked him about all the RV?s with their ELT's located behind the baggage compartment bulkhead. He replied that is not a good position either and any ELT back there should be moved.

tin man · #8 03-28-2006, 01:54 PM

Before calling his superiors why don't you contact him and tell him your interpetation, back it with facts. Perhaps he is unaware and only trying to help.
Tom
Northern California

gmcjetpilot · #9 03-29-2006, 08:06 AM

Quote:

Originally Posted by N941WR

In the past I have posted about the great location I selected for the placement of my ELT. I was so proud of the door I cut in the baggage compartment floor to hide the ELT.

I am 99% sure you where fine. Accessible does not mean visible. Also most installation instructions that come with ELT's say do not put in a baggage compartment where it can be hit or damaged. A big label in red ELT HERE would do it. Since it is required and a TSO item it must be installed by the manufactures instruction. Clearly there is some interpretation but you "recessed compartment with a door" is fine. My instructions say easily retrieved for maintenance. Your set up looks like it fills the bill.

The only controversy is the typical instruction: "...as far aft as PRACTICAL." Well if you say it is not practical to mount aft of the baggage bulkhead, than it is not practical; your location is fine and as far aft as practical.

I think he is just jealous because it is so slick.

My instruction says do not mount it IN a baggage space if subject to possible damage. Mounting it unprotected in the baggage compartment would not fly according to my Artex ELT instructions. Your recessed location is well protected.

The bigger issue is how people mount their ELT antenna, but that is a topic for another time. For the record it says: exterior, vertical, on top of the fuselage. Not much interpretation when mounting it hidden horizontal under the tail intersection fairing.

Bill it is a great idea and this guy is wrong.

G

N941WR · #10 03-29-2006, 10:20 AM

I really don't want to move the ELT. He did say that he would mark it down as a safety concern if I didn't move it. Is that like putting something on my "permanent record"?

I did buy the ELT sticker similar to the one Rick used. It arrived a few hours after the Tech Inspector left, figures. Maybe that will get me through.

I'll have to check the manual regarding placing my ELT in the baggage compartment and see if I can't use that little bit of info with the guy.

In case anyone was wondering, I mounted the ELT tray to the rib and not the floor of the aircraft. This is a better picture.

The strobe power head is tucked under the left side of the baggage compartment floor.

All this was done to keep the weight out of the tail and towards the center of the plane.