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  #1  
Old 01-01-2018, 09:56 PM
fabricflyer fabricflyer is offline
 
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Location: Tylertown, MS
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Default Lighting reqirements for E/A-B

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:
Quote:
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:
Quote:
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
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  #2  
Old 01-01-2018, 11:06 PM
BobTurner BobTurner is offline
 
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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.
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  #3  
Old 06-04-2018, 05:54 AM
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maniago maniago is offline
 
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Quote:
Originally Posted by BobTurner View Post
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.....?
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MustangII (FoldingWing) "FirewallFwd&sundries": IO360B1E,RSA,C2YR-BF/F7666-2,Superior sump,James; 2xHXr,MiniX,EIS,480,327,240,SL30,Navworx; SteamAlt,AS,VSI
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  #4  
Old 06-04-2018, 06:27 AM
vic syracuse vic syracuse is offline
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Default 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
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  #5  
Old 06-04-2018, 06:32 AM
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maniago maniago is offline
 
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Quote:
Originally Posted by vic syracuse View Post
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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MustangII (FoldingWing) "FirewallFwd&sundries": IO360B1E,RSA,C2YR-BF/F7666-2,Superior sump,James; 2xHXr,MiniX,EIS,480,327,240,SL30,Navworx; SteamAlt,AS,VSI
Don't be a hater; I'm a cousin with thin wings!
N251Y (res)
Dec2017

Last edited by maniago : 06-04-2018 at 06:35 AM.
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  #6  
Old 06-04-2018, 06:52 AM
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N941WR N941WR is offline
 
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Quote:
Originally Posted by maniago View Post
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.
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  #7  
Old 06-04-2018, 07:01 AM
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Mel Mel is offline
 
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Quote:
Originally Posted by maniago View Post
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.
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  #8  
Old 06-04-2018, 09:37 AM
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maniago maniago is offline
 
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Quote:
Originally Posted by Mel View Post
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.....?
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Mani
MustangII (FoldingWing) "FirewallFwd&sundries": IO360B1E,RSA,C2YR-BF/F7666-2,Superior sump,James; 2xHXr,MiniX,EIS,480,327,240,SL30,Navworx; SteamAlt,AS,VSI
Don't be a hater; I'm a cousin with thin wings!
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Dec2017
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  #9  
Old 06-04-2018, 09:50 AM
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Mel Mel is offline
 
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Quote:
Originally Posted by maniago View Post
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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Mel Asberry..DAR since last century
A&P/EAA Tech Counselor/Flight Advisor/Nat'l Test Pilot School
Specializing in Amateur-Built and Light-Sport Aircraft
<rvmel(at)icloud.com>
North Texas (8TA5)
RV-6 Flying since 1993, 172hp O-320, 3-Blade Catto (since 2003)
Legend Cub purchased 12/2017
FRIEND of the RV-1
Eagle's Nest Mentor
Recipient of Wright Brothers "Master Pilot" Award

Last edited by Mel : 06-04-2018 at 09:52 AM.
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  #10  
Old 06-04-2018, 10:37 AM
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maniago maniago is offline
 
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Quote:
Originally Posted by Mel View Post
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
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Mani
MustangII (FoldingWing) "FirewallFwd&sundries": IO360B1E,RSA,C2YR-BF/F7666-2,Superior sump,James; 2xHXr,MiniX,EIS,480,327,240,SL30,Navworx; SteamAlt,AS,VSI
Don't be a hater; I'm a cousin with thin wings!
N251Y (res)
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