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Lighting reqirements for E/A-B

fabricflyer

Well Known Member
This thread started out on the Landing Light thread in the RV-14 Forum. I stated:
"I see everyone using different makes and types of nav and landing lights for our RVs, but according to 91.205 to be legal for night or IFR flights don't we have to use TSO'd lights?"
BobTurner came back with:
The FAR actually says "approved" lights. Most interpret that to mean a light that meets the FAA's specifications (brightness, angular coverage, color, etc) but not necessarily TSO'd. It is clear that Christmas tree bulbs are not "approved"!
This is for nav and anti-collision lighting. There is no requirement for landing lights, at all. You do not even need to have them, if you so choose.
I had just read Mel Asberry's article (Ask the DAR) in Kitplanes (August 2017) in which his quote was:
Your operating limitations state that to be approved for night and/or IFR flight, the aircraft must meet the requirements of 91.205. Since 91.205 is written primarily for standard certified aircraft, there is no mention of "lesser" requirements for Experimental aircraft. Therefore, to meet the requirements for 91.205, the aircraft must meet the same requirements as if it were a standard certified aircraft.
It didn't say "specifications" as Bob had mentioned, it mentioned "requirements".

Landing lights aside, I just wanting to see what most of Vansairforce had to say about this.

Allen
RV-7A slow build
 
My opinion is that The reason type certificated aircraft need many TSO?d parts is not due to part 91- it?s buried in the type certification process. The original 172 that earned the TC had TSO?d brand X nav lights. Every 172 since then has had brand X nav lights, or nav lights installed under an STC. In the past the FAA was reluctant to issue STCs for non-TSO?d products, although that seems to be changing (e.g., Dynon EFIS). Since EAB aircraft don?t have type certificates, none of this applies. The FARs applicable to EAB say ?approved lights?, which per the FARs mean approved by the administrator. The recent FAA interpretations of this seem to be ?meets the performance specifications? of the applicable TSO or other FAA publications. So any nav light that meets the color, brightness, and coverage specifications is okay for EAB.
 
My opinion is that The reason type certificated aircraft need many TSO?d parts is not due to part 91- it?s buried in the type certification process. The original 172 that earned the TC had TSO?d brand X nav lights. Every 172 since then has had brand X nav lights, or nav lights installed under an STC. In the past the FAA was reluctant to issue STCs for non-TSO?d products, although that seems to be changing (e.g., Dynon EFIS). Since EAB aircraft don?t have type certificates, none of this applies. The FARs applicable to EAB say ?approved lights?, which per the FARs mean approved by the administrator. The recent FAA interpretations of this seem to be ?meets the performance specifications? of the applicable TSO or other FAA publications. So any nav light that meets the color, brightness, and coverage specifications is okay for EAB.

I'm at this stage - deciding on which LED nav/strobe lights. And I'm finding a gray zone that is up to the DARs interpretation, which of course is frustrating because for EAB its clearly just a money issue (ie TSO vs non-TSO performance meeting).

Has there been any more clarification in this area to help the DARs accept non-TSO performance meeting LEDs for Night&IFR approval.....?
 
Owner/operator responsibility

Just as with transponder certification, pitot-static tests, etc, DAR's do not have the equipment to verify compliance. It is up to the operator to insure that the aircraft meets the requirements for the particular flight. When I inspect an airplane if it has lights, I do make sure they are working and installed properly, such as the red nav light on the left wing (yes, I actually found one that had the green one on the left wing!). If they happen to be home-grown lights, I will make the comment that there are regulation requirements to be aware of, but that's as far as I go.
Phase I is all DAY/VFR anyway. The person may never even fly it at night, and justs likes the extra "visibility" of having position lights.

The bottom line is that the "guidance" you sek is in the FAR's already.

Vic
 
Just as with transponder certification, pitot-static tests, etc, DAR's do not have the equipment to verify compliance. It is up to the operator to insure that the aircraft meets the requirements for the particular flight. When I inspect an airplane if it has lights, I do make sure they are working and installed properly, such as the red nav light on the left wing (yes, I actually found one that had the green one on the left wing!). If they happen to be home-grown lights, I will make the comment that there are regulation requirements to be aware of, but that's as far as I go.
Phase I is all DAY/VFR anyway. The person may never even fly it at night, and justs likes the extra "visibility" of having position lights.

The bottom line is that the "guidance" you sek is in the FAR's already.

Vic

Vic yeah I get that the guidance on lights is in the regs. I know it well already. And I know Phase I is day VFR.

Maybe I'm wrong on this, but my understanding is that operational limitations for the life of the plane are set by the DAR at the airworthiness inspection and cant be changed. If I'm wrong, please guide me as I'm in learning mode.

If I can change the opslims myself later, then I get it, this is moot. Just dont know this part.

Thanks
 
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Vic yeah I get that the guidance on lights is in the regs. I know it well already. And I know Phase I is day VFR.

Maybe I'm wrong on this, but my understanding is that operational limitations for the life of the plane are set by the DAR at the airworthiness inspection and cant be changed. If I'm wrong, please guide me as I'm in learning mode.

If I can change the opslims myself later, then I get it, this is moot. Just dont know this part.

Thanks

Mani, this is like the IFR "certification" for the plane. You can build and fly the plane now, Day VFR, and add the lights later and self certify that they meet the requirements, if you plan on flying at night.

Most builders add the lights when they build simply because they are easier to install during construction.
 
Maybe I'm wrong on this, but my understanding is that operational limitations for the life of the plane are set by the DAR at the airworthiness inspection and cant be changed. If I'm wrong, please guide me as I'm in learning mode.
If I can change the opslims myself later, then I get it, this is moot. Just dont know this part.
Thanks

The DAR does not "set" this requirement. The requirement is a part of the Operating Limitations stipulated in FAA Order 8130.2j. The DAR may add additional requirements if it is determined to be a safety issue, but may NOT change or remove any requirements from the original document.
The requirement clearly states that meeting the requirement is up to the owner/operator.
 
The DAR does not "set" this requirement. The requirement is a part of the Operating Limitations stipulated in FAA Order 8130.2j. The DAR may add additional requirements if it is determined to be a safety issue, but may NOT change or remove any requirements from the original document.
The requirement clearly states that meeting the requirement is up to the owner/operator.

Mel, the word requirement is used so many times, I'm not sure what youre talking about. But ok, lets forget that for now.

Youre quoted in the OPs post on lights, so I'd like to better understand how you go about this at the airworthiness inspection.

For post Phase I, what do you need to see wrt lights and documentation to NOT post a day-only limitation?

Vic, if I get what youre saying, if the builder has lights installed, you just mention theres a requirement to be met for night, but dont go out of your way to post a day-only limitation....(?)

Or do I still not understand enough of the process to be asking the right question.....?
 
Mel, the word requirement is used so many times, I'm not sure what youre talking about. But ok, lets forget that for now.
Youre quoted in the OPs post on lights, so I'd like to better understand how you go about this at the airworthiness inspection.
For post Phase I, what do you need to see wrt lights and documentation to NOT post a day-only limitation?
Vic, if I get what youre saying, if the builder has lights installed, you just mention theres a requirement to be met for night, but dont go out of your way to post a day-only limitation....(?)
Or do I still not understand enough of the process to be asking the right question.....?

The following is what is listed in you operation limitations:

22. Night flight operations are authorized if the instruments specified in § 91.205(c) are installed, operational, and maintained per the applicable requirements of part 91. (48)

Therefore is your lights don't meet 91.205, you are restricted to daytime operations.
 
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The following is what is listed in you operation limitations:

22. Night flight operations are authorized if the instruments specified in ? 91.205(c) are installed, operational, and maintained per the applicable requirements of part 91. (48)

Therefore is your lights don't meet 91.205, you are restricted to daytime operations.

.....and here we are full circle...

"(2) Approved position lights. "

.....which is up to me to ensure (via mfg assurances/documentation), but not for the DAR to make a call on. Ok got it.

Thanks, thats what I needed to know.

Cheers
 
Good info on this thread...

I'm still a bit confused how to proceed.

If I built an RV, and I want to fly legally at night, but I don't have the equipment or facilities to measure brightness, angular coverage etc. How do I go about selecting the lighting for my plane? What would be the lowest cost option?
 
Good info on this thread...

I'm still a bit confused how to proceed.

If I built an RV, and I want to fly legally at night, but I don't have the equipment or facilities to measure brightness, angular coverage etc. How do I go about selecting the lighting for my plane? What would be the lowest cost option?
Get the AreoLED nav/strobes that Van?s sells as well as the standard Van?s landing light kit.

Build on.
Carl
 
Good info on this thread...

I'm still a bit confused how to proceed.

If I built an RV, and I want to fly legally at night, but I don't have the equipment or facilities to measure brightness, angular coverage etc. How do I go about selecting the lighting for my plane? What would be the lowest cost option?

The easiest way IMO is to go with one of the lighting manufacturers who have done the tests and sell products that meet the required specs. Not the cheapest option for sure, but the easiest plug and play choice vs rolling your own system.

Edit: I have AeroLeds like Carl recommended.
 
Yeah, thanks. Just wondering if there was any way to fly legally at night without spending $1,500 for lights
 
My take

I have no connection to these guys but I am planning to use Fly LEDs, and advertiser here. I think I will be able to meet the cost target.
 
Yeah, thanks. Just wondering if there was any way to fly legally at night without spending $1,500 for lights
Hi Jake
A few years ago I was tasked with making LED strobe and position lights for the RV10 I was helping to build. I came across this analysis of some Whelen LED strobes, as seen fitted to a Cessna Citation. This became my (minimum) benchmark, and has since been duplicated more than a few hundred times in the Flyleds kits I sell.

The comments I get back usually contains the phrase "...Holy (...) those lights sure are bright!"

 
My opinion is that The reason type certificated aircraft need many TSO?d parts is not due to part 91- it?s buried in the type certification process.

Well, Part 21, but yes. Part 21 Subpart A covers all that. And as you note, things don't technically have to have a TSO or PMA to go on a certified aircraft, but they do have to be approved somehow, via TC or STC.

It's interesting when you get to ADS-B, because the prevailing opinion was that those units had to be TSO'ed. The FAA eventually clarified that the regs say "meets the performance requirements of" the TSO, but don't require the actual TSO itself. However, approval to install the equipment was another matter. The FAA eventually issued guidance that, for certain aircraft (typically unpressurized ones), you could install ADS-B with just a 337 and no STC or 8130 provided that the equipment had been approved on a TC or STC somewhere previously (on any aircraft) and it was TSO'ed. And that pretty much closed up the market, because installing a non-TSO'ed unit would require a specific STC.
 
Just use some common sense. Everyone here know that there are 1,000,000 different options. Some are more important than others.

Obviously there is a perceived gray area. Just make sure you put equiptment that is good and reliable.

Do you want to land at night with a candle as your illumination?

Do you really want to fly at night with a nav light that is dimmer than your cell phone?

Strobe/position lights...lots of options here... pick out ones that work well.

In my 15,000 hours of flight time, I’ve never seen a fed pull an airplane over in the sky and ask if his green light met FAR.bumpita bumpita.

The technology is moving fast right now. Buy something that is safe, works well, and does what it is supposed to do. Make sure you’ll be happy with it, and the better it fits your budget, the happier you’ll be.

I have lights on my airplane that make a 737 look dim. Nothing is certifiable. They work **** good, and many many feds have ramp checked my plane.
 
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