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ELT / PLB (merged)

We had the FAA 'men' take a random visit to our airfield a few months ago and they inspected the N reg's, and ours was amongst others that was required to upgrade to 121 + 406 Mhz frequency. We thought we could around the issue by having a hand help PLB on the new frequency, but that wasnt acceptable, at least not on the N reg.

I don't understand that, while recognizing that my understanding could be incomplete. On N-register you've needed a 121.5 MHz ELT for many years, unless the aircraft is single seat, operated for local training, or unless the ELT has been temporarily (less than 90 days) removed for service. However, I am not aware that upgrading any aircraft to 406 Mhz is mandatory for Part 91 operations unless the ELT is replaced for other reasons.

By my observation, on N-register only people who really see the necessity based on their operations are switching to 406 MHz. I just completed the annual inspection on mine with the same old 121.5 MHz ELT, new D-cells installed last year.

We had a permament 121.5 one on board, and the battery was serviced and changed when it reached 50% of it's usefeul life (as per the FAA requirements). I wasnt directly involved in the discussion with the FAA, but communication in our group stated that our Certificate to Fly (I'm quoting someone else on that term) would be rescinded if we didnt upgrade the old permanent installation to a 406 Mhz. We were given 90 days to comply.

So our experience is that it is mandatory. We're just utilsing a N reg PA28 here in the UK for non-public use.

The aircraft is a C172, registered in Holland ,and as far as I can determine there is no ELT available for this model where an STC exists. I am really hoping someone can tell me I am wrong and point me in the right direction (as I am sure you will understand) to the make and model required that has an existing approval

UK, United Kingdom

@FenlandFlyer

Not sure if you are based at Fenland UK, but if you are, we dealt with a guy called Garry at IAE, which is based at Cranfield. They fitted out now ELT on the PA28-181. Sorry I cant give any advice on something registered in Holland though.

The aircraft is a C172, registered in Holland ,and as far as I can determine there is no ELT available for this model where an STC exists. >

US C172s of all vintages have ELTs - many will have the latest ones.

Maoraigh
EGPE, United Kingdom

as far as I can determine there is no ELT available for this model where an STC exists

You don't need an STC, though most European avionics shops will tell you that you need one.

An STC is merely a "high grade" form of Approved Data, to support a Major Alteration i.e. a Form 337. An STC (which if used in this way has to apply to your specific aircraft type, airframe serial number range, etc) means that the 337 is mailed straight to the FAA in Oklahoma for filing. The FAA doesn't have to approve the work. You just need an A&P/IA, or an FAA Part 145 Repair Station, to certify that the work conforms to the STC.

You can do a Major Alteration without an STC. It then becomes a Field Approval. There are two ways of getting that done. One is to apply to a US FSDO - example with a 337 and supporting data. The other is to get an FAA DER to generate a "design package" with a Form 8110 (which is what certain UK installers do, not least because it's an easy option, but it can cost a lot of money).

However there must be a huge number of ELT installs being done in the USA. If you can find a plane just like yours, given its tail number and for something like $20 the FAA will send you a copy of all 337s filed for that plane. You can then use these to support your 337. See here for an example of the process - where unfortunately I failed to locate such a plane because Socata USA are banned by Socata France from supporting non-US owners, and since I got banned from their owners' group in 2008 for being too outspoken I wasn't able to openly ask there, and if I got anybody to ask on my behalf he/she would have got rumbled pretty fast

In any case contacting the major ELT makers is the first thing because they will have supporting documentation.

Another option is if the aircraft type was ever in production and delivered with an ELT from the factory (I don't mean fitted with an ELT by the dealer). That ELT can then be installed with just a logbook entry, because it is covered by the Type Certificate. The gotcha is that unless the aircraft type is current, or ceased production very recently, the ELT installed won't be a 406MHz one. BUT if you take e.g. my ELT project you can see that mine was practically identical to the original non-406 one which was on the Type Certificate (size, weight, antenna size and mounting, wiring, instrument panel switch) so that one went in as a Minor Alteration which is just a logbook entry.

An STC is relevant only to Major Alterations. If you can find a Minor route then it doesn't matter.

I hope XC-Yankee might drop in here; he's an expert on this stuff.

Administrator
Shoreham EGKA, United Kingdom

With reference to N-register and the potential for mandatory 406 MHz ELT installation:

http://www.aopa.org/whatsnew/regulatory/elt.html

Perhaps there could be some local wrinkle with continuing with 121.5 MHz in overseas operations? Dunno.

Regardless of that, I'm not sure whether pre-existing 406 MHz ELT installations in N-register aircraft would be of use to everybody on other registers. On N-register, the approved data for installation is Chapter 2 of FAA Advisory Circular 43-13, as mentioned by Peter. No specific field approval or STC is necessary.

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC%2043.13-2B.pdf

Side note: an existing 337 is not automatically FAA approved data for a new installation unless it is very, very old (like 50 or more years old). It may be considered approved data on an individual basis, and in particular will be so if backed up by a DER engineering package (which I think is automatically approved data, but not 100% sure)

The only thing is that aopa article is coming up for 4 years old. I dont know if their position has changed though. I wish I knew more about 'the men' that visited us. AFAIK, it was a un-scheduled inspection, and I presume they were a delegation from FAA Gatwick. Might we worth trying to find something on the FAA site, or emailing one of the FDO's to see where and what 406 Mhz ELT's apply to. Sorry I dont have any sources to hand as I didnt deal with it myself.

Here's something 4 days old. The second to last sentence is relevant.

http://www.avweb.com/avwebflash/news/FAAActsOnELTStraps_207853-1.html

I did a bit of searching on the FAA current regulations site and found this link which suggests (and I wouldnt put it any stronger than that myself without getting my own quote direct from the FAA about my own plane) that 121.5 is no longer allowed. The direct quote is:

"87.195 Prohibition of 121.5 MHz ELTs. The manufacture, importation, sale or use of 121.5 MHz ELTs is prohibited"

http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=14249b2e3770594cbe14825f49a8e4cc&ty=HTML&h=L&r=SUBJGRP&n=47y5.0.1.1.2.6.96

However, that might not be in context (I just did a basic search), or maybe if your not in the UK it doesnt apply, maybe we were given the wrong information by the FAA, maybe the guy in my group has misunderstood something (its all possible I guess). Or maybe it is right. I would seek direct advice myself. We've already paid something like £1200 for the new ELT and fitting so it's too late for us, if we really didnt need it.

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