I have searched and haven't found any recommendations to replace the 3G TL Starter without removing the battery tray.
I was able to replace the Starter with the Tray still in place. This may have been discussed before but it was nothing I could find.
pics:


This is the new Starter. Access to Starter is easy with tray in place.

Tray still in place

Sliding in between hoses

Comes out at this angle and begin re-install in the way.

Inspect gasket before reinstalling

Cleaned around area for dirt and rust.

Nestled back in and ready to bolt up