Ameri-King ELT

H. Paul Shuch is a Light Sport Repairman with Maintenance ratings for airplanes, gliders, weight shift control, and powered parachutes, as well as an independent Rotax Maintenance Technician at the Heavy Maintenance level. He holds a PhD in Air Transportation Engineering from the University of California, and serves as Director of Maintenance for AvSport of Lock Haven.

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3Dreaming
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Ameri-King ELT

Postby 3Dreaming » Mon Oct 28, 2019 12:36 pm

If you have an Ameri-King ELT installed in your aircraft make sure whoever is doing your condition inpsections is complying the the Airworthiness Directive. I was just reviewing the records of a Sport Cruiser for a student who is getting ready for a checkride. All of the log entries looked very professional the ELT inspection per 91.207 was included, but the AD for the ELT was not signed off as being complied with.

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Re: Ameri-King ELT

Postby drseti » Mon Oct 28, 2019 1:09 pm

(Tom, I know you know this, but for everybody else's edification):

Since the SportCruiser is either an SLSA or an ELSA, the AmeriKing AD does not apply, per se. Instead, the aircraft manufacturer (either Czech Aircraft Works or Czech Sport Aircraft) will have to have issued a Safety Alert (sometimes called an Alert Service Bulletin), which has the same force of FARs as an AD. And you're right, Safety Alerts must be signed off as complied with, and verified at every Condition Inspection.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

3Dreaming
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Re: Ameri-King ELT

Postby 3Dreaming » Mon Oct 28, 2019 3:02 pm

Paul, I am going to adamantly disagree with you on this, and the FAA is on my side as well.

https://www.faa.gov/aircraft/gen_av/lig ... ly2013.pdf

This comes from the document,
Do I have to comply with an FAA Airworthiness Directive (AD) on SLSA?
While the FAA does not preclude the possibility of issuing an AD specifically for SLSA, an AD
may be issued on a TC product (e.g. engines and propellers) incorporated into an SLSA and if
necessary on products having other forms of FAA approval. 14 CFR § 91.327(b)(3) requires
compliance with all applicable ADs.
• You may want to consider the components

If it was only a Service Bulletin I would agree that a Safety Directive would be required.

By the way, since an Airworthiness Directive is issued under part 39 of the regulations it also carries the same weight as all other FAA regulations.

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Re: Ameri-King ELT

Postby drseti » Mon Oct 28, 2019 5:24 pm

3Dreaming wrote:14 CFR § 91.327(b)(3) requires
compliance with all applicable ADs.


Yes, and the confusion comes from their use of the word applicable. I was mistakenly led to believe that ADs weren't applicable unless a related Safety Directive had been issued. Apparently others were similarly confused, as evidenced by the FAA considering it necessary to issue that document you so kindly posted.

I wasn't previously aware of that document. And since it's not in the FAR/AIM, I would wager that others aren't either.

So, since that document has a title but no FAA reference number, what exactly is it? An excerpt from an FAA Order? A Letter of Interpretation from FAA legal? Something else? I don't doubt that your interpretation is correct, I just wonder what its regulatory basis is.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

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Re: Ameri-King ELT

Postby ShawnM » Mon Oct 28, 2019 6:38 pm

AD's absolutely do apply to LSA. That is the old version of the document that Tom posted, the latest version is dated 3-20-2019 and can be found here:

https://www.faa.gov/aircraft/gen_av/light_sport/media/LSA_Buyers_Guide_2019.pdf

It's been titled "Light Sport Aircraft Buyer's Guide"

I have a SportCruiser and complied with this AD for my ELT. Problem is that Czech Sport Aircraft has never issued a SD/SA or even a SB to notify its customers of the AD from Ameriking. They simply and quietly changed ELT's about a year before the AD but still never notified the legacy owners of the AD once it was issued so many dont know about it unless you are a forum member. This lack of support for owners is sadly just par for the course for Czech Sport Aircraft. The main reason I went E-LSA. :mrgreen:

For the record there is also another AD for the ACS ignition switch that is 11 years old and CSA just issued a SB notifying customers this week. Yes, 11 years after the fact. Problem is SB's aren't mandatory but the AD is. Go figure. They should have issued a SD/SA for owners to comply. Again, par for the course with CSA.

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Re: Ameri-King ELT

Postby 3Dreaming » Mon Oct 28, 2019 7:20 pm

Paul, applicable refers to the applicability section of the Airworthiness Directive. Any aircraft or equipment that is governed by the FAA can have an Airworthiness Directive issued for it. In this case the Ameri-King AK-450 is listed in the applicability section of the AD, so for any aircraft with one installed the AD is applicable. CFR 91.327 (b), (3) just further enforces that this applies to SLSA.

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Re: Ameri-King ELT

Postby drseti » Mon Oct 28, 2019 7:38 pm

Thanks for the clarification, Tom and Shawn. Just goes to show that studying the FARs isn't enough (unless you're an attorney)!
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

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Re: Ameri-King ELT

Postby ShawnM » Mon Oct 28, 2019 10:12 pm

Just so everyone is aware the AD effects the 450 AND the 451 ELT. There are 14,500 ELT’s out there that are effected. If it still works you are ok, if it fails any test listed in the maintenance manual then it must be replaced.

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Re: Ameri-King ELT

Postby 3Dreaming » Tue Oct 29, 2019 8:40 am

ShawnM wrote:Just so everyone is aware the AD effects the 450 AND the 451 ELT. There are 14,500 ELT’s out there that are effected. If it still works you are ok, if it fails any test listed in the maintenance manual then it must be replaced.


The 450 ELT can be repaired. http://merlinc.net/ Not saying this is the best option, but it might buy some time and save a little money.

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Re: Ameri-King ELT

Postby 3Dreaming » Tue Oct 29, 2019 8:52 am

drseti wrote:(Tom, I know you know this, but for everybody else's edification):

Since the SportCruiser is either an SLSA or an ELSA, the AmeriKing AD does not apply, per se. Instead, the aircraft manufacturer (either Czech Aircraft Works or Czech Sport Aircraft) will have to have issued a Safety Alert (sometimes called an Alert Service Bulletin), which has the same force of FARs as an AD. And you're right, Safety Alerts must be signed off as complied with, and verified at every Condition Inspection.


Just another thought.
I agree that Safety Directives carry the weight of the regulations because of CFR 91.327. I don't agree that the manufacture has the final say on all things related to the aircraft. The FAA has been pretty clear in legal rulings that the manufacture can not override the regulations. For example the manufacture can't write in their manual that it takes a mechanic to change the tire, when the privilege is clearly given to the pilot in the regulations. They can't require factory training when the FAA has other approved training requirements in place. In the case of an AD, it is regulation. The manufacture has no say in whether it requires compliance or not, it is governed by the FAA.

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Re: Ameri-King ELT

Postby drseti » Tue Oct 29, 2019 11:02 am

3Dreaming wrote: I don't agree that the manufacture has the final say on all things related to the aircraft. The FAA has been pretty clear in legal rulings that the manufacture can not override the regulations.


I agree with you there in principle, Tom. Unfortunately, the FAA has issued contradictory legal interpretations on the subject. One lawyer has written (in a query regarding the 5 year Rotax rubber replacement requirement) a letter of interpretation saying that the manufacturer can indeed make the maintenance rules. Another, in a different case, has written that they can't. Mike Busch has been hounding the FAA for a couple of years now, trying to get some clarification and consistency. So far, the feds have opted to keep things ambiguous.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
fly@AvSport.org
AvSport.org
facebook.com/SportFlying
SportPilotExaminer.US

3Dreaming
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Joined: Sun Jan 10, 2010 6:13 pm
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Re: Ameri-King ELT

Postby 3Dreaming » Tue Oct 29, 2019 1:10 pm

drseti wrote:
3Dreaming wrote: I don't agree that the manufacture has the final say on all things related to the aircraft. The FAA has been pretty clear in legal rulings that the manufacture can not override the regulations.


I agree with you there in principle, Tom. Unfortunately, the FAA has issued contradictory legal interpretations on the subject. One lawyer has written (in a query regarding the 5 year Rotax rubber replacement requirement) a letter of interpretation saying that the manufacturer can indeed make the maintenance rules. Another, in a different case, has written that they can't. Mike Busch has been hounding the FAA for a couple of years now, trying to get some clarification and consistency. So far, the feds have opted to keep things ambiguous.


I am aware of the contradictory legal interpretations, but they don't really apply in this case. Neither of those interpretations say the manufacture can go against what is spelled out in the regulations. In fact while contradictory they both use the regulations to back the interpretation. The issue is that they go against what has become standard practice within the aviation community.

The one legal interpretation that would be applicable here is the one that said that Rotax can not require factory training to work on their engines. The FAA said that a mechanic must meet the training requirements spelled out in the regulations, not those imposed by Rotax. This shows that the regulations take precedence over the manufacture.


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