Nav/Strobe Lights

[Sonerai13]

Clearly I would need a TSO set to put on a certified airplane. Do you think I would have any issues with the non-TSO set if I wanted my A/W cert to reflect day/night VFR? A big difference from the Aveo is that AeroLED does offer TSO lights.

The operating limitations issued to an experimental aircraft should contain the allowance to operate at night (or under IFR) "if equipped in accordance with 14 CFR 91.207". It is up to the person operating the aircraft under those conditions to be able to prove that the equipment installed meets the requirements. In the case of AeroLED, they should be able to provide documentation that their lights meet the brightness and color requirements called out by the FAA. So long as you have documentation from the light manufacturer or vendor stating that the appropriate requirements have been met, you're good to go. (There are also angle of visibility requirement to be met, but that is the responsibility of the installer rather than the light manufacturer.)

Note that this is an operational requirement, not a certification requirement. The operating limitations should contain the allowance to operate at night or under IFR whether the aircraft is currently equipped to do so or not. This allows the equipment to be upgraded at a later date to allow such operations without having to have the operating limitations revised or reissued. If your inspector doesn't issue said limitations, he or she is not doing the job correctly.

[MichaelFarley56]

Ken,

A homebuilt must be allowed to fly at night in the Operating Limitations issued to that airplane. Then, assuming the equipment meets the FAA requirements for light placement, brightness, etc. then it's up to the pilot to follow FAR 91.205 per night operations.

[Sonex1243]

Thanks for the clarification Mike;
I'll have to dig out the specs I received from AeroLED and bump it with the requirements. Pretty sure I will be ok. I think I'll start hitting up the FSDO next time one of the inspectors is in town doing a FAA wings presentation. Never to early to get them "primed".

[mike.smith]

Thanks for the clarification Mike;
I'll have to dig out the specs I received from AeroLED and bump it with the requirements. Pretty sure I will be ok. I think I'll start hitting up the FSDO next time one of the inspectors is in town doing a FAA wings presentation. Never to early to get them "primed".

The experimental lighting manufacturers often make two versions of their position/strobe lights: TSO'd and non-TSO'd. For experimentals, position/strobe lights are one of the few areas in the FAR's that are required to be TSO'd if used at night (daytime you can do whatever you want). I'm not making that one up; it's in the regs if you actually read the wording. The non-TSO'd may be essentially the same at the TSO'd, but technically they have not been tested that way and do not have the paperwork to support compliance. The non-TSO'd units are usually quite a bit cheaper than the TSO'd versions.

Read the manufacturer's disclaimer in the left column:
http://aveosw.com/3-in-1-nav-position-s ... ed-lights/

[Direct C51]

The experimental lighting manufacturers often make two versions of their position/strobe lights: TSO'd and non-TSO'd. For experimentals, position/strobe lights are one of the few areas in the FAR's that are required to be TSO'd if used at night (daytime you can do whatever you want). I'm not making that one up; it's in the regs if you actually read the wording.

Hmmm, Mike I sure would like to know what FARs require experimental aircraft to have TSO lights to fly at night. FAR 91.205, FAR Part 23, and the following legal interpretation does not say that.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2014/Josephson%20-%20(2014)%20Legal%20Interpretation.pdf

Nate

[mike.smith]

The experimental lighting manufacturers often make two versions of their position/strobe lights: TSO'd and non-TSO'd. For experimentals, position/strobe lights are one of the few areas in the FAR's that are required to be TSO'd if used at night (daytime you can do whatever you want). I'm not making that one up; it's in the regs if you actually read the wording.

Hmmm, Mike I sure would like to know what FARs require experimental aircraft to have TSO lights to fly at night. FAR 91.205, FAR Part 23, and the following legal interpretation does not say that.

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2014/Josephson%20-%20(2014)%20Legal%20Interpretation.pdf

Nate

I'll find it for you tonight. I was a naysayer for a long time, but it was finally pointed out to me by both Aveo (lighting manufacturer) and by an FAA inspector.

[mike.smith]

I found the post I made some time ago, after posing this question to Mel, the "Ask the DAR" guy in Kitplanes.

============

Michael,

Thanks for your question. It is a common one.

First off, let's get clear the distinction between "Standard", and "Experimental Amateur-Built" certificated aircraft. When it comes to lighting during daytime VFR, there are no standards for EAB aircraft. You may use anything you want or nothing! That's because as
many are quick to point out, 91.205 does not apply to experimental aircraft.

Now when it comes to Night and/or IFR operations, things change a bit. By way of our operating limitations, 91.205 does indeed apply during night and/or IFR operations. This is where the confusion begins. People want to "interpret" 91.205 as it applies to experimental aircraft. Actually there is nothing to interpret. Since 91.205 does not normally apply to experimental aircraft, there is nothing in it about these aircraft.

When 91.205 is applied to experimental aircraft by way of our operating limitations, it applies in it's entirety. Our operating imitations do not say "For night and/or IFR operations, 91.205 applies except that the lights need not meet TSOs." There are absolutely no provisions to distinguish between "Standard" and "Experimental" aircraft within 91.205.

In other words when operating within 91.205 our systems must meet the same requirements and a "Standard Certificated Aircraft".

As far as the inspector "approving" your lighting installation, that is not his/her job. He/She does NOT certify the aircraft lighting systems. The issued operating limitations for your aircraft simply state that if you fly at night and/or IFR, you must comply with 91.205. It is the responsibility of the owner/operator of the aircraft during these operations to see that this regulation is complied with.

I hope this helps,

Mel

[Sonerai13]

Mike, the FAA inspector is wrong. (That's not all that unusual.) There is NO requirement that the lights (or any other equipment) used on an experimental aircraft be built under a TSO authorization. The regulation (91.205) says the lights must be "approved". A TSO authorization is one way, but not the only way, to prove compliance with FAA requirements. I worked this issue directly with the FAA Small Airplane Directorate and FAA HQ in Washington DC, and the word I got from them was that a TSO, while it is one easy way to prove compliance, is not required. All that is needed is documentation to prove that the lights meet the brightness and color requirements called out in the FAA guidance. The installation must also meet the visibility requirements called out, but that is shown by physical inspection of the aircraft.

Of course, having lights built under a TSO authorization ends the argument, so it's not a bad idea. But in these days where there are many new products coming out and many of these vendors don't want to go through the hassle of TSO authorization, we need to look at other ways to document compliance.

There are two FAA advisory circulars that spell out what is needed. They are AC 20-30B and AC 20-74. You can find these on the FAA website. So long as your light installation meets all the requirements called out in these two ACs, your lights are considered "approved". Again, while a TSO is an easy way to show approval, it is not required by regulation as there are other ways to show approval.

[Fastcapy]

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[Fastcapy]

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