New (different) battery: elementary work?

[photofly]

STANDARD 625 Appendix A lists as elementary work (among other things):

(19) removal and replacement of aircraft batteries;

Does anyone want to venture an opinion whether that covers replacing a dud battery with a different model from a different manufacturer (that's approved under an FAA STC)?

If so, what logbook entry should I make, and should I include a copy of the STC?

[robertw]

That is a good question!

This is what CAR's says about a maintenance relaese and elementary maintenance:

(3) No maintenance release is required in respect of any task designated as elementary work in the Aircraft Equipment and Maintenance Standards that is performed by

(a) in the case of a glider, a balloon or an unpressurized small aircraft that is powered by a piston engine and not operated pursuant to Part IV or VII, the pilot of the aircraft;

I'm assuming that you are the pilot (that's right, only the pilot is allowed to do elementary maintenance in this case) and you are not a part 4 or 7 operator.

It seems that this allows you to install a battery under this provision and not sign a maintnenace release, but enter the particulars into the log book. However, since you are deviating fromt he type design of the aircraft, you are completing a major modification and as such you need to accomplish it in accordance with "approved" or "specified" data. Your STC constitutes approved data.

Enter the particulars of what you did (p/n, s/n, etc...) in accordance with the STC number. Write in any additional requirements that the STC states, like required maintenance for the battery. Sign the journey log and put your pilot's license #. Dont' forget to submit a "Major Modification or Repair" form to your local TC office.

[photofly]

Thanks for the reply!

CAR 101.01 says that a major modification "means an alteration to the type design of an aeronautical product in respect of which a type certificate has been issued that has other than a negligible effect on the weight and centre-of-gravity limits, structural strength, performance, power plant operation, flight characteristics or other qualities affecting its airworthiness or environmental characteristics; (modification majeure)"

Replacing the battery seems to fall outside those criteria, so am I right in thinking it doesn't constitute a major modification?

[robertw]

Another great comment!

There are a number of questions one has to answer in the determination of whether or not what you want to install or modify on your aircraft will be a major modification or repair. CAR std. 571 Appendix A gives you all those questions.

Follow this link: http://www.tc.gc.ca/eng/civilaviation/r ... a-1893.htm

After looking at the list again, it does look like your different battery may not qualify as a major, however this will be for you to determine as I don't know the specifics of this STC'd battery. There are a few of those questions that you will need to look at very closely:

(a) Operating Limitations

Does the modification or repair involve a revision in the operating limitations specified in the approved type design?

Does the modification or repair alter:

(4) the mass distribution in a structural element?

(7) an electrical generation device, or the electrical distribution system between the generating source and either its primary distribution bus, or any other bus designated as an essential bus?

(8) reduce the storage capacity of the primary battery?

Read the list very closely and make your determination. If you're still in doubt, check with your local TC M&M inspector.

[Cyclenut]

Removal and replacement of aircraft batteries IS elementary work providing you are replacing it with the same part number battery or any other battery that is in the IPC (or PMA'd /TSO'd part). No maintenance release is required, but a Log Book entry is still required.

Since your example states an STC, you can't just install the Battery called out in the STC and think you are good to go. You must 'embody' the STC, that is purchase the 'STC' paperwork to give you the right to install it. The act of 'embodying' the STC is NOT Elementary Work, and that's no different for either Private or Commercial. You as a Pilot or Owner are not eligible to do. It MUST be an appropriately rated AME. If you are in the Owner Maintenance or Amateur Built Categories, then as the Owner you can embody the STC and release it, without having to have an AME release it. Merely 'stealing' the STC data and writing thast in the Log Book won't cut it.

The requirement for a Major Mod or Repair report to be filed still needs to be evaluated as stated previously.

[robertw]

Removal and replacement of aircraft batteries IS elementary work providing you are replacing it with the same part number battery or any other battery that is in the IPC (or PMA'd /TSO'd part). No maintenance release is required, but a Log Book entry is still required.

Since your example states an STC, you can't just install the Battery called out in the STC and think you are good to go. You must 'embody' the STC, that is purchase the 'STC' paperwork to give you the right to install it. The act of 'embodying' the STC is NOT Elementary Work, and that's no different for either Private or Commercial. You as a Pilot or Owner are not eligible to do. It MUST be an appropriately rated AME. If you are in the Owner Maintenance or Amateur Built Categories, then as the Owner you can embody the STC and release it, without having to have an AME release it. Merely 'stealing' the STC data and writing thast in the Log Book won't cut it.

The requirement for a Major Mod or Repair report to be filed still needs to be evaluated as stated previously.

Cyclenut,

Where does CAR's state that "Removal and replacement of aircraft batteries IS elementary work providing you are replacing it with the same part number battery or any other battery that is in the IPC (or PMA'd /TSO'd part)."? Elementary work is a listing of tasks, not detailing types of fabric and, part numbers etc...

A maintenance release is required per CAR's as follows:

605.85 (1) Subject to subsections (2) and (3), no person shall conduct a take-off in an aircraft, or permit a take-off to be conducted in an aircraft that is in the legal custody and control of the person, where that aircraft has undergone maintenance, unless the maintenance has been certified by the signing of a maintenance release pursuant to section 571.10.

And:

(4) No maintenance release is required in respect of tasks identified as elementary work in the Aircraft Equipment and Maintenance Standards.

"Embodying" this STC is no more than installing the new battery (which is elementary work), filing the paperwork with the aircraft technical record and making your log entries (assuming that this is not a major mod). Since the battery replacement is deemed elementary work which requires no maintenance release, and writing a log entry and filing paperwork does not constitute maintenance, where is the need for a maintenance release?

Also, in my experience, many of these types of small part STC's are given out if you purchase the STC'd part. It would not be good business to make someone buy your great idea and them make them pay again for the approval. You wouldn't sell very much.

I would really suggest getting TC's decision on this as they will be the ones giving you the grief if I am wrong. Ask a couple different inspectors. You'll probably get a few different answers!

[Cyclenut]

We agree that 625 Appendix A is an exhaustive list of eligibale tasks. If it isn't in the list, it's not Elementary Work. Embodying an STC on an aircraft is NOT in the list, therefore it is not an eligible task. Doesn't matter if it's simply a paperwork STC or an STC requiring Major Modification.

If the Part Number of the battery you want to install isn't in the IPC (or it's equivalent by way of PMA or TSO part) then you can't legally install it. You need a mechanism for installing a part that ISN'T in the IPC. The only way to do so is by way of an STC or some other remedy (DAR, Serialized STC, whatever)

If the purchase of your New Battery INCLUDES the right to install the STC (i.e. all the paperwork, etc) then I agree, you are good to have it installed BY AN APPROPRIATELY RATED AME because it will require a maintenance release. Some of these STC do require that you purchase the 'paperwork only' to be legal. (An example of this is an RGB (Recumbent Gas Battery) battery in a King Air. The STC itself is another $160.00 over and above the RGB battery cost) Another example are the MOGAS STC's to allow you to use MOGAS. (which most people just use without the proper STC) You are just buying a piece of paper, but it's that paper that keeps you legal.

The definition of 'Maintenance' doesn't just mean something you do that get's your hands dirty.
It's:
"maintenance" - means the overhaul, repair, required inspection or modification of an aeronautical product, or the removal of a component from or its installation on an aeronautical product, but does not include
(amended 2003/06/01; previous version)

(a) elementary work,

(b) servicing; or

(c) any work performed on an aircraft by the manufacturer prior to the issuance of whichever of the following documents is issued first
(amended 2007/12/01; previous version)

(i) a certificate of airworthiness,
(amended 2007/12/01; previous version)

(ii) a special certificate of airworthiness, or
(amended 2007/12/01; previous version)

(iii) an export airworthiness certificate; (maintenance)
(amended 2007/12/01; previous version)

In this example, you are modifying an aeronautical product from it's original Type Design, albeit not necessarily a Major Mod (but possibly could be, depending). You can't get hung up on the fact that the 'modication' doesn't involve any wrench turning or sheet metal bashing, it is a 'modification' nonetheless. A paperwork one.

[SeptRepair]

Well said Cyclenut. You have summed it up nicely.

[robertw]

We agree that 625 Appendix A is an exhaustive list of eligibale tasks. If it isn't in the list, it's not Elementary Work. Embodying an STC on an aircraft is NOT in the list, therefore it is not an eligible task. Doesn't matter if it's simply a paperwork STC or an STC requiring Major Modification.

Really? So under this reasoning, plugging in your headset requires a maintenance release? It's not on the list... That head set wasn't part of the type design, so by pluging it in and interfacing with the aircraft communications system you are modifying the aircraft? I don't think so.

Have you ever seen an AD signed off in a log book by a pilot / owner with no maintenance release? I have and it's legal as there was nothing other than an inspection of aircraft records required. Some AD's even state that a pilot or owner of an aircraft may sign off the AD.

The STC gives the individual the authority to install a battery not specified in the type design of the aircraft. That involves a maintenance task that just happens to be elementary maintenance which does not require a maintenance release.

The definition of 'Maintenance' doesn't just mean something you do that get's your hands dirty.
It's:
"maintenance" - means the overhaul, repair, required inspection or modification of an aeronautical product, or the removal of a component from or its installation on an aeronautical product, but does not include
(amended 2003/06/01; previous version)

(a) elementary work,

(b) servicing; or

(c) any work performed on an aircraft by the manufacturer prior to the issuance of whichever of the following documents is issued first
(amended 2007/12/01; previous version)

(i) a certificate of airworthiness,
(amended 2007/12/01; previous version)

(ii) a special certificate of airworthiness, or
(amended 2007/12/01; previous version)

(iii) an export airworthiness certificate; (maintenance)
(amended 2007/12/01; previous version) .

Which one of these items implies that adding paperwork to the technical record constitutes maintenance? This list specifies things that are actually done to the aeronautical product, not it's log books. The mainenance task in this case falls under elementary work. I stand by my original position. This does not require a maintenance release.

[photofly]

The new battery weighs 2.5lbs more than the old; so I'll need a new W&B report. Is it mandated that that has to be prepared by an AME? Or can issue it myself?

Edit: I guess that means that item (4) is triggered: "(4) the mass distribution in a structural element" - so it does count as a major modification. And a new W&B requires a maintenance release. Rats, rats, rats.

[Cyclenut]

Really? So under this reasoning, plugging in your headset requires a maintenance release? It's not on the list... That head set wasn't part of the type design, so by pluging it in and interfacing with the aircraft communications system you are modifying the aircraft? I don't think so.

Agreed. Plugging in a head set (my, aren't WE being silly now!) is not an Elementary Task because it's not on the exhaustive list of 625 Appendix A. But it ALSO doesn't meet the definition of Maintenance. No release required.

Have you ever seen an AD signed off in a log book by a pilot / owner with no maintenance release? I have and it's legal as there was nothing other than an inspection of aircraft records required. Some AD's even state that a pilot or owner of an aircraft may sign off the AD.

Yes, and agreed. Often in those cases where the Pilot signs off on the AD, an AME MUST then comply with the AD at the next inspection and make a release. (eg. Jump seats on the Otter)

The STC gives the individual the authority to install a battery not specified in the type design of the aircraft. That involves a maintenance task that just happens to be elementary maintenance which does not require a maintenance release.

You're missing the point. It's not the act of installing the battery that requires the Release. It's the act of embodying the STC on the Aircraft that requires the release. That is a maintenance task, a release should be made.

Look, you can embody STC's on your aircraft however you like. So we will disagree. My position is from discussions with an MD-M about how they (he) likes to see STC's. I agree with him and think TC would too. You obviously don't and I'm fine with that. I think it's up to photofly to proceed as he sees fit. Mine is just a different interpretation.

Have a nice day.

[robertw]

Look, you can embody STC's on your aircraft however you like. So we will disagree. My position is from discussions with an MD-M about how they (he) likes to see STC's. I agree with him and think TC would too. You obviously don't and I'm fine with that. I think it's up to photofly to proceed as he sees fit. Mine is just a different interpretation.

Have a nice day.

Agreed. Isn't it great that we as professionals are allowed to have two different opinions? Thanks for the lively discussion!

[Cyclenut]

The new battery weighs 2.5lbs more than the old; so I'll need a new W&B report. Is it mandated that that has to be prepared by an AME? Or can issue it myself?

Edit: I guess that means that item (4) is triggered: "(4) the mass distribution in a structural element" - so it does count as a major modification. And a new W&B requires a maintenance release. Rats, rats, rats.

None of these are 'biggies'. If you properly embody the STC, it will come with Installation Instructions, Weight and Balance Amendment Info, and any Instructions for Continuing Airworthiness. Simple.

As for the Major Mod thingy, in this case it's merely a 'form' that gets sent in. The STC itself is the "approved Data", and all you (usually) need in the description of work is the Name and # of the STC.

http://www.tc.gc.ca/eng/civilaviation/r ... l-1902.htm

Not complicated, just a little more friggin' paperwork.

[photofly]

Not complicated, just a little more friggin' paperwork.

No indeed.

I was originally hoping that it was something I could do myself unaided; however the new battery requires a modification to the battery box lid, which will have to be done by an AME anyway. Once I have an AME involved, the extra paperwork isn't too arduous, as you point out.

Thanks to everyone for their help.