Navstrobe lights

[philiplane]

I guess I am not following you guys ....  It my understanding that Nav Strobe bulb and lens replacement and not a  entire replacement for the Navigation light  assembly. Granted there isn't much to Nav light assembly.  So if  1512 /1513 bulb  replacement bulb  is  suitable bulb replacement and  meets original bub specification. I forget AC (advisory circular  ) number that allows replacement parts like switches and  electronic  parts/components  with off the shelf parts being that meets or exceeds the part being replaced.

I think  found the AC  (20-60E part 5 f. )  that I was think of ...

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0CCQQFjAA&url=http%3A%2F%2Fwww.faa.gov%2FdocumentLibrary%2Fmedia%2FAdvisory_Circular%2FAC%252020-62E.pdf&ei=LivjUvn8HMPeoAT0qYGIAQ&usg=AFQjCNHWbXScVmDnsfHCS4Up1KJ9h7OKfA&bvm=bv.59930103,d.cGU&cad=rja

Let me simplify. The lamp holder does not emit light, so there is virtually no concern about it in the lighting TSO. Anything you put into the lamp holder must maintain the original TSO. That means lamps and lenses must comply.

 

The lamp itself is the subject, and anything that replaces the original lamp MUST be built, tested, and accepted by the FAA under a TSO. AND, the manufacturer MUST apply for and receive a PMA from the FAA that approves the manufacturer's Quality Control System. If the manufacturer does not maintain the conditions of the PMA, it is revoked.

 

NavStrobe has no PMA and therefore no Authority to manufacture parts for Type Certificated Aircraft. They also cannot make any claims to "meet a TSO", since they have not applied for one, don't possess one, and by the way, there is no TSO that covers a combination lamp such as this.

 

It's still an innovative product, but we can't install it on anything but Experimentals so far. The fastest route at this point is to obtain a Field Approval but I haven't been able to put together an acceptable data package yet.

[rdav]

This may be going too far into the details, but the company can also apply for a PMA letter if the FAA approves an STC for installation of the product. It is beneficial, but not necessary to have TSO for a product to install it on an aircraft. If you don't have a TSO though, it is harder to show that the product is suitable for installation in an aircraft.

I work for a company that manufactures audio equipment and servers for aircraft use. Most of our products are TSO'd, but the servers have no TSO. Our PMA letter comes from the fact that an STC has been approved.

[jetdriven]

Let me simplify. The lamp holder does not emit light, so there is virtually no concern about it in the lighting TSO. Anything you put into the lamp holder must maintain the original TSO. That means lamps and lenses must comply.

The lamp itself is the subject, and anything that replaces the original lamp MUST be built, tested, and accepted by the FAA under a TSO. AND, the manufacturer MUST apply for and receive a PMA from the FAA that approves the manufacturer's Quality Control System. If the manufacturer does not maintain the conditions of the PMA, it is revoked.

NavStrobe has no PMA and therefore no Authority to manufacture parts for Type Certificated Aircraft. They also cannot make any claims to "meet a TSO", since they have not applied for one, don't possess one, and by the way, there is no TSO that covers a combination lamp such as this.

It's still an innovative product, but we can't install it on anything but Experimentals so far. The fastest route at this point is to obtain a Field Approval but I haven't been able to put together an acceptable data package yet.

I'm not following you. The manufacturer of the position light assembly proves the assembly meets the TSO and FAA minimum specifications for navigation lamps as installed. Now part of that is th bulb specified. If its a GE311 bulb, then that meets the definition of as a "standard part", much like a belt, resistor, sheet of plexiglass, hardware, or a washer. None of those have TSO but they can still meet th definition of airworthy when installed on certificated aircraft. All the owner/A&P has to do is either install another GE 311 bulb or its equivalent. The problem I have is the complete lack of data showing that the LED lamps meet or exceed the data if the lamp in he parts catalog.

[philiplane]

I'm not following you. The manufacturer of the position light assembly proves the assembly meets the TSO and FAA minimum specifications for navigation lamps as installed. Now part of that is th bulb specified. If its a GE311 bulb, then that meets the definition of as a "standard part", much like a belt, resistor, sheet of plexiglass, hardware, or a washer. None of those have TSO but they can still meet th definition of airworthy when installed on certificated aircraft. All the owner/A&P has to do is either install another GE 311 bulb or its equivalent. The problem I have is the complete lack of data showing that the LED lamps meet or exceed the data if the lamp in he parts catalog.

The FAA doesn't care so much about the nav lamp assembly as a structure, they really care about the light it emits. They are primarily focused on the lamp, not the holder.

There are several varieties of standard parts, some are accepted as relics from the pre-FAA and pre CAA days (before 1938). Others meet TSO's developed since then.

 

You are correct that the 311 does not have a TSO, because it does not perform a function that requires one. But GE and others have PMA for aircraft lamps, some TSO'd some not. All are subject to FAA audit of the QC system. 

 

However, we are talking about external nav lamps, which must meet brightness, color, and beam spread incorporated into a TSO that is referenced by the CFR that governs navigation position lights. Those particular lamps must be manufactured IAW the TSO by a PMA holder. You absolutely cannot substitute any lamp into a nav lamp holder that does not conform to the TSO C30c. You talked about installing an equivalent, which you can do, provided the equivalent meets the same TSO and is an approved part. These LED's are not equivalents because they have not been tested & accepted by the FAA, nor has the maker applied for PMA approval or STC. Fit Form and Function rules governing standard parts do not apply when the subject part is required by regulation, and the regulation specifies a standard to be met. 

 

Strobe, beacon, and nav lamps must conform to a TSO, because they are required equipment for certain Kinds Of Operation, and there are defined standards for them. The FAA doesn't care if you can see your charts or engine instruments in the dark, but they do want to be certain that you can see other planes and they can see you. Thus the external lighting standards.

 

The hazard with LED's is the very narrow beam of each LED. You'll notice that any certified LED nav lamp has multiple LED's arranged in several directions. They may also incorporate mirrors to aid in spreading the light around. Traditional incandescent lamps do not suffer from narrow beams and use a reflector to help intensify the light, and an external lens to increase the spread even more. The faster an object moves, the wider the spread required for it to become visible and remain visible as it passes an observer. Here in busy South Florida, you really want to be able to pick out and maintain contact with the many other planes you come across at night. 

 

The FAA is way behind the developments in lighting, but that's how they function. Someone has to spend a  lot of time and money to get new technology to the market. Let's hope the Part 23 rewrite actually helps.

 

I was an early adopter of HID lighting and installed many XeVision lights through the Field Approval process for myself and customers. I did the 337's that got HID's on Cessna Citations in 2005. Those have morphed into a full product line for an aftermarket supplier. It wasn't easy working with the FSDO at first, but they finally saw the light...

[bumper]

Besides light output, there's also a radio frequency interference (RFI) concern. This is not from the LED itself, but rather from the LED driver circuitry. LED's require current limiting and on small lower power LED lights this is typically accomplished with a resister. The downside is that resisters waste power and for higher power LEDs become somewhat impractical, so a LED driver circuit is employed.

 

The LED driver typically consists of a DC to DC switching circuit and regulator (a "buck" circuit to both regulate voltage and limit current output, or a "buck boost" circuit which can also compensate for low voltage input). It's the DC to DC switching circuit that can generate RFI, so filters and proper grounding may be employed to prevent interference with avionics.

 

bumper

[cliffy]

 

Standard parts MUST conform to an industry or US design standard (AN bolts for instance). LEDS (unless approved) do not conform to an industry design standard- they are unique in their design even though they do the same function. 

Below is a cut from AC 21-29C on how to determine unauthorized or bogus parts. 

The full AC link is shown at the bottom.

 

(8) Produced as standard parts that conform to established industry or U.S. specifications 

(refer to definition in subparagraph 3l, Standard Part). 

NOTE: Standard parts are not required to be produced under FAA 

approval; therefore, it is incumbent upon the installer (and the producer) to 

determine that the part conforms. The part must be identified as part of the 

approved type design or found to be acceptable for installation under 

part 43. Refer to the AC 20-62 for additional guidance on this matter.

 

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC%2021-29C%20CHG%202.pdf

[CDF219]

Watch "N5986Q nav strobe lighting at night" on YouTube

"N5986Q new navigation strobe lighting" on YouTube

It was a 15 min install and a 337 from my A&P. Worth the money on our older birds. I got a compliment from the control tower when I landed about how bright the plane is. Wheelen landing light and beacon and now Navstrobe position and tail.

let me know what you think.

installed mine and I love them.

[fantom]

let me know what you think.

 

 

Very nice....thanks, BUT....

 

Go directly to Jail; do not collect $200

[Steve65E-NC]

Aircraft Spruce sent out an e mail featuring this product. The ad claimed they were pilot plug-in compatible. It would be nice if Aircraft Spruce took the time to establish the facts and communicate them clearly. Perhaps the manufacturer has legally extablished that these meet angle and brightness requirements. Based on conversation here I have my doubts. Right now, if I had these installed, I would hate to be on the receiving end of a court case where nav lights were and issue.

[jetdriven]

Or an enforcement case. Those clear lenses give it away. I don't understand the strobe function either. You can't use that feature at night, and daytime usage doesn't appear very effective either.

[philiplane]

Watch "N5986Q nav strobe lighting at night" on YouTube

"N5986Q new navigation strobe lighting" on YouTube

It was a 15 min install and a 337 from my A&P. Worth the money on our older birds. I got a compliment from the control tower when I landed about how bright the plane is. Wheelen landing light and beacon and now Navstrobe position and tail.

let me know what you think.

installed mine and I love them.

Please post the 337 so others can have a basis for a follow on Field Approval.

 

Thanks

[AmigOne]

x

[cliffy]

I would still like to see the 337 and the FAA response when 1 copy is sent in. Standard parts do not need a 337 to install.

I have tried to find any contact information for Navstrobes. No address, no phone number, no nothing can I find. Can anyone provide such contact information? I will contact the company and get their side of the story and then I will contact the FAA to get their side of the story. No more guessing and conjecture

From what I see, it is only 1 person in the company and selling these lights by what is said on the website.

Lets get to the bottom of this. Someone find me a contact and I'll do the calling and report back.

[fantom]

www.navstrobelighting.com

 

Any pireps from early adopters?

 

Interesting reads, but to me, seems like the light spread (arc), at least on Mooney's with wing tip lenses is already restricted.

 

To 'see and avoid' wouldn't blinking LED navstrobe lights be a plus. If you relying on spotting conventional wingtip nav lights to avid a collision....it's too late!

 

Given all the other semi-legal stuff the rest of you guys have done to your planes aren't we making a mountain of of a molehill?

[fantom]

 Head on, the only space you'll see my nav lights is from 12 to 3 o'clock on the right side. From above and below it will be more. Interesting.

 

Gary

[cliffy]

Here's the rub- If you, as an owner, replace the bulbs YOU are required to sign off the work in the a/c log book. If an A&P does the work HE is required to be certain that the part he is installing is LEGAL to be installed and then sign off the log book.

The link to the company has NO contact information available. No address, no phone number, no nothing!

The only thing I have found is that the company "says" it complies and can be installed. NOT good enough for me.

Now, as to- "Given all the other semi-legal stuff the rest of you guys have done" PLEASE don't even go there. If the Feds ever have an occasion to look at you, you don't want to be semi-legal.

[mike_elliott]

Here's the rub- If you, as an owner, replace the bulbs YOU are required to sign off the work in the a/c log book. If an A&P does the work HE is required to be certain that the part he is installing is LEGAL to be installed and then sign off the log book.

The link to the company has NO contact information available. No address, no phone number, no nothing!

The only thing I have found is that the company "says" it complies and can be installed. NOT good enough for me.

Now, as to- "Given all the other semi-legal stuff the rest of you guys have done" PLEASE don't even go there. If the Feds ever have an occasion to look at you, you don't want to be semi-legal.

 

Chris WInter

NavStrobe Lighting, LTD

navstrobe@gmail.com

613-285-0911

 

I have found Chris to be very responsive to emails. Nav Strobe has donated a set of Sextant 30W Nav Strobe lights to the Mooney Summit as a door prize, and I have had more than one IA say that this is a minor alteration, no change in W&B, no 337 necessary. I really like mine, much brighter than the old grimes, much less current draw.

[cliffy]

Frankly I like them too, but, they can't be "Standard Parts" by definition without supporting documentation. I have tried to contact Chris and have not received any call back from my message yet. I will keep trying.

I have contacted 2 FAA FSDOs and both have said that they feel they are not legal to use on certified aircraft. Even night, VFR on home-builts is suspect with them at this time. They feel without any supporting evidence that the lights comply, they are not legal yet. The claim that they do is not enough.

They have contacted the FAAs Resource man in this field for his take as they say there might be some obscure or arcane letter to support the standard part claim that they do not know about.

If any of you who have installed them have any paper work from the company other than the claim that they meet the criteria, would you be kind enough to post it or email to me so I can continue the search.

Was there any markings on the parts themselves that say FAA_TSO or any other markings? Does the paper work that comes with the kit have anything?

[cliffy]

Letter sent to Chris also asking for clarification

[AmigOne]

I have another email for Chris Winter from an email exchange with a friend of mine

On May 3, 2013, at 3:22, Chris Winter <ctwinter@gmail.com> wrote:

Not a problem. Just send me an additional $8.00 to my PayPal account for the tailfin strobelight at ctwinter@gmail.com and I will make the adjustments.

Regards, Chris Winter

NavStrobe Lighting

[cliffy]

amigone? Not quite sure what you are getting at with your post Clarify please

[AmigOne]

Though that Chris winter did not reply to em sent to the navstrobe@gmail so I was providing this alternate address ctwinter@gmail Just copied and pasted my friend's email which contained the address which apparently created confusion. Sorry.

[philiplane]

Chris WInter

NavStrobe Lighting, LTD

navstrobe@gmail.com

613-285-0911

 

I have found Chris to be very responsive to emails. Nav Strobe has donated a set of Sextant 30W Nav Strobe lights to the Mooney Summit as a door prize, and I have had more than one IA say that this is a minor alteration, no change in W&B, no 337 necessary. I really like mine, much brighter than the old grimes, much less current draw.

Let me clarify.

 

First of all, changing one lamp to another is not even a minor alteration. It is maintenance. That is where the IA first went wrong. Second, anything on a Type Certificated aircraft has to have both a certification basis, and an installation approval through one of several channels.

 

If your IA thinks these LED's are legal, he is wrong. No shade of gray here. There is no room for opinion on the subject, only facts.

 

Fact #1, NavStrobe does not possess a PMA for the manufacture of aircraft parts. Stop here, do not pass GO, do not collect $200.

 

Fact #2, TSO'd parts are REQUIRED by regulation to be clearly marked with the applicable TSO and or PMA number, or STC information. NavStrobe lights have none of these markings.

 

Fact #3, nav lights are REQUIRED by regulation, and the nav lights required by reg have a certification basis. Nav lights HAVE to to conform to a TSO. The parts that comprise a nav light assembly are TSO'd. Remove the existing TSO'd 7512-12 lamp, install a NavStrobe lamp, and now you have an Unapproved Part performing a required function. Simple as simple can be.

 

Fact #4, these lights combine two normally separate functions. The controls for the functions have to be clearly marked, so the switch needs appropriate placarding to describe the functions and how to select each mode. That alone rules out your standard parts argument, since the lamp functions differently depending on its' mode of activation. 

 

I think these lights could be a winner, but absent any approvals, they cannot be installed legally on a Type Certificated Aircraft. The approval can be as simple as a Field Approval. Or as complex as a TSO'd part produced under an FAA PMA. Or equally complex as an STC'd part. 

 

People are confusing this as a standard parts issue and it is not. The bulb is not the same as the lamp it replaces so it cannot hope to meet the definition of a standard part. There are NO standards for LED replacement lamps, therefore there are NO standard LED lamps. All LED approvals so far have been as entirely new assemblies, such as Whelen and Aveo are producing. Those assembles use multiple LED's carefully arranged SPECIFiCALLY to meet the field of view requirements that an LED replacement lamp could not. 

[cliffy]

philplane

Your last paragraph is exactly as my discussion went with the Feds today.

Regardless of what the claims are, they are not "Standard Parts" unless documentation can be provided to the contrary.

The lights might meet the requirements of the AC in light performance but they are not exact DUPLICATES of a national standard for construction so that anyone competent could reproduce them (as required by the AC). As you state, there are no national standards for LED light bulbs there for they are not standard parts by definition. The AC goes on to further state that if a product complies by "performance" alone THEN FAA approval must be sought.

I am still waiting for Chris to explain how they comply as a standard part. I really do hope he can.

[philiplane]

Here's the killer. These lamps are supposed to replace NAV lamps, but, and I quote from the manufacturer:

 

"When these lights are in strobe mode, do the red & green nav lights still illuminate between strobe flashes?

Per the supplier: No. There is no light output between light bursts.

 

Do these satisfy the anti-collision beacon requirement for night VFR?

Per the supplier: My strobe lights do not meet the requirements for anti-collision lights. They are only a replacement for the standard navigation or position lights, with the additional strobe feature for safety."   **********************

 

So you no longer have nav lights when the strobes are on. That's a deal breaker, since nav lights are required for night flight, and they do NOT meet the requirements for strobe lights. So you've now lost your nav light function (intentionally to boot), which is a Part 91.205c, violation in addition to the Unapproved Parts that made your airplane Unairworthy the moment you installed them.

 

Although you might install them on a homebuilt without approvals, you can't use the strobe function at night since it kills the position lights, which are required.