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New Partnership w/EarthX batteries

N1049j said:
I was reading the whole thing on STC and 337 and listening the other night to Mike Bush who seems to know what he is talking about and from what he explains it is not a major alteration! The design is still a 12 volt DC system and you do not need to alter the charging design so it does not require a STC or a 337. Now he also speaks that does not stop an AP for saying you do but according to the FAR regulations I don't see you need anything. It like deciding to use synthetic oil versus non synthetic oil.
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Still reading through this entire thread, so it's possible that this is addressed later... I understand the logic here that replacing one 12V DC battery with another seems minor, but AFS-300 rev 6.0 item F.1 specifically calls out that "ny alteration that installs a new lithium battery or changes an installed battery from non-lithium battery to a lithium battery" specifically requires an STC, no DER ENG approval shortcuts allowed. Has this document been superceded / is there another reason it wouldn't apply?
 
Can you elaborate on the AFS-300 rev 6.0 you refer to? What document is this?
 
addaon said:
Still reading through this entire thread, so it's possible that this is addressed later... I understand the logic here that replacing one 12V DC battery with another seems minor, but AFS-300 rev 6.0 item F.1 specifically calls out that "ny alteration that installs a new lithium battery or changes an installed battery from non-lithium battery to a lithium battery" specifically requires an STC, no DER ENG approval shortcuts allowed. Has this document been superceded / is there another reason it wouldn't apply?
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Great point! I read AFS-300 rev 6.0, and it does seem to point out a problem for those of us flying the earlier Commanders. For those of us flying with the EarthX, item F2 would be the problem. Neither the Concorde, or the Gill are approved by STC, so I can't use either of them. F2, of course, also presents a problem for anyone wanting to switch from the Gill to the Concorde, or the Concorde to the Gill. Actually, by AFS-300 rev 6.0 standards there is no available battery for the earlier Commanders. So should they all be grounded?! I don't think so. The original battery manufacturer went out of business in the early 80's and all the early Commanders have been flying without them since - 40+ years. I think AC No: 23-27, date: 5/18/09, standard part section c & d is more applicable for our aircraft - particularly section d, because it applies to the 3 different batteries that are in common use in our aircraft. The Concorde, Gill, and EarthX are all TSO'd products - the EarthX being the most recent to receive TSO approval is the one that has been the most stringently tested.

The EarthX, the Gill, and the Concorde are either ALL illegal, or ALL legal - you choose, but you can't pick just one or two - they're all approved by the same standard.

:):):)
 
The Gills (and OEM batteries) were/are lead acid, not lithium, I thought?
 
addaon said:
The Gills (and OEM batteries) were/are lead acid, not lithium, I thought?
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Makes no difference. There's no type certificated original, and no type certificated replacement. We're talking about TSO'd replacement parts only.

Funny to be having this conversation.:) In 10 years we'll look back and laugh. "Lead" "Acid" in an airplane?! Grandpa did you reeeaaally fly around with a 30lb battery in your plane?
 
Let me try to be clear that (a) I really want a lighter, LiFePO4 based battery; (b) I'm a fan of lithium batteries in aircraft, and have spent the last three years working to certify an aircraft with hundreds and hundreds of pounds of lithium batteries; and (c) although I've worked on certified software for (future-)TC'd aircraft (including battery management software) I'm not a DER, and absolutely recognize that I know very little about this stuff -- all I can do is read what FAA guidance I can find.

My reading is that the aircraft TC includes a TSO'd lead acid battery. In general, TSO'd parts can be replaced with other parts meeting the same TSO -- that's the whole point of the standardization in the standard order -- but there's always caveats. Because lithium batteries represent a more significant fire risk than lead acid batteries, the FAA has published at least one piece of guidance suggesting that replacing a lead acid battery with a lithium battery requires an STC.

Because (a) this is obviously the right direction for future aircraft; (b) LiFePO4 as opposed to other lithium batteries is at worst a moderate fire risk; and (c) there are safety as well as operational advantages to an aircraft that can carry another 20 minutes of fuel at the same takeoff weight, this seems like a path worth pursuing, and as I said, I'd really like to explore it. I guess I just tend to lean towards understanding how horrible the process would be to get an STC as opposed to finding an ASI/DAR who hasn't run across this particular guidance and getting just a 337.
 
Isn’t it also clear that they give the ability to make substitution of parts for vintage aircraft that exact parts are not available. And there should be no distinction on type of battery use if it does not alter the requirements of the aircraft.
 
Yeah, that's the question. And certainly dropping in a TSO'd or PMA'd lead acid battery, even a sealed battery, is trivially acceptable. But this is a case where they've drawn attention to additional risks because it /can/ change the requirements of the aircraft. For example normally Halon and Halotron fire extinguishers are both considered suitable for aircraft, but while tests have shown that Halon can handle lithium-ion fires, I haven't seen similar testing for Halotron. (And of course LiFePO4 fires, though harder to get started, are not necessarily extinguishable identically to Li-Ion, which is where most of the testing has been.) You can say that this doesn't apply to us / matter to us -- but that's kinda what the STC process is, the process by which you show that these differences aren't a concern.
 
H Adam,

First of all I'd like to thank you for this discussion. This web board is a great place to air out ideas and share knowledge.Your contribution is very much appreciated.

I think where we're missing each other is in the foundation of our justification for going from a Gill, or Concorde battery to an EarthX battery. You're looking at the idea of going from a lead acid battery to a lithium battery, and I'm looking at going from one un-type-certificated battery to another un-type-certificated battery. I do see and understand your concerns.

From my experience, going through the STC process several times, the FAA follows a course that to, the best of their ability, allows them to prove "this" against "that". Any time you throw something at them that doesn't have a "this" it's very difficult to get them to approve "that". The lack of a "this" is probably the biggest reason why neither Gill, nor Concorde have STC's for our airplanes.

The original battery that came in our aircraft was the same battery that was used in the Shelby Cobras - the company went out of business before Al Gore invented the internet, so there's no good source of information about what the "this" was. We can obviously assume it was a lead acid battery, but it wasn't an aircraft approved, TSO'd battery. It was just a part that was used in our certified airplanes. For vintage aircraft the FAA simply suggests that we use replacement parts that are certified for aircraft use, like the Gill, Concorde, or EarthX.
 
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I think also the point should be understood what criteria the FAA is examining on approving or not approving or just not getting into it. I coming from the pharmaceutical side of government safety testing feel that the FAA is judging things that affect the flying functionality portion of the discussion not the safety of lead acid or LiFePO4 safety that should be examined by safety protocols as Carl indicated they are approved in aircraft. As in the pharmaceutical side of things we don’t have to prove safety of formulation chemicals that are already proven safe. We just have to show they don’t interfere with the efficacy of the drug.

We can discuss this point forever and both points of view are correct it’s just what side you want to be on. Another huge point is that these batteries are in everything and if you get technical your not even supposed to bring more than I think 2 Lithium batteries on commercial flights. Now how ridiculous is that!
 
And we haven't even talked about tires yet.......
 
Hello Carl, I would like to order a new battery from you (and probably the new battery box as well).

Wondering (1) if you have any available, and (2) if I made the trip over to GGG do you have a mechanic that can install the new battery box and battery.

Thanks in advance.
 
Update: new Earth X battery is in and working great. Plus I got a nice gain in useful load of 24 lbs.

Thanks Carl.

Now, about those 3-blade MT props….
 
j.shane.kelley said:
Update: new Earth X battery is in and working great. Plus I got a nice gain in useful load of 24 lbs.

Thanks Carl.

Now, about those 3-blade MT props….
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Cool! Did you take it to Dallas Execitive?

24lbs in the back, 28lbs in the front. 50+ more useful:-)

Call me when you get a chance.
 
carllee said:
Cool! Did you take it to Dallas Execitive?

24lbs in the back, 28lbs in the front. 50+ more useful:-)

Call me when you get a chance.
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yes, I took it to the place you recommended. They did a great job. I’m going to have them install the main landing gear lights I got from you that I still haven’t gotten around to.
 
Here's a copy of the EarthX battery STC and AML. Commanders are not listed, of course, but it does show that the batteries are an STC'd product. Because of the limited number of Commander's flying it's unlikely they'll ever be added to the list, but keep in mind, that's also true of both Gill and Concorde. There Is No STC'd battery for our airplanes! If you're considering upgrading to a Lithium battery, and want to increase your useful load by 25+ pounds, you can show this to your AP/IA to show them that this is an approved product for similar aircraft. I also have a copy of a 337 used for installation on a Commander.

https://rcmnormalizing.com/batteries

View attachment STC-SA1005DE-Re-Issued.pdf
View attachment FAA-Approved_-AML-Rev-G-for-SA01005DE-aaa-signed.pdf
 
Carl, did they forget to the 112?
 
112, 112A, 112B are all on the same ACDS. They just call out the latest model, but they're all approved. You can make reference to the ACDS in your log book entry, if it makes you feel more comfortable.
 
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