Navstrobe lights

[philiplane]

Although the CAR 3 rules applied during manufacturing, unfortunately you can't OPERATE it under those rules today. Or maintain it. Unless you have a time machine...

 

So this is where the linkage to the current 14CFR Part 21, 43, and 91 comes in. If you are operating a plane today, it is in accordance with Part 91, which links to lighting regulations, which in turn links to maintenance rules, in turn to certification standards for parts. All of those are currently enforced by our Friendly Aviation Advisors, not the CAA of yesteryear.

 

I've already run this LED scenario past FAA personnel and one of the country's top enforcement defense attorneys. Installing non-approved parts is one violation by the installer, accepting them at annual is another violation by the IA, and flying the plane is a violation, times the number of flights that it was unairworthy. There is no good outcome here.

 

Suspect Unapproved Parts have been a priority of the FAA since 2006, mostly to prevent bogus turbine engine parts from getting into jet engines, but the SUP process is very well defined within the # 8300 guidelines in the Inspector's Handbook.

 

These discussions came about as part of the STC process for HID landing lights. I am a pioneer in the process, and the Cessna Citation HID lights offered by Lopresti was one of my recent projects. I know lighting, regulations, and the approval process better than your average owner's group website contributor. 

 

I also have run a Part 145 Repair Station, served as a Part 135 Director of Maintenance, been a Part 135 pilot, and have taught classes in regulatory compliance.

 

If you really want LED nav lights, you just pony up for the Whelen Orion nav & strobe assemblies. They are amazing.

[DonMuncy]

It's hell when someone with both knowledge and credentials pops up and ruins our dreams.

[Hank]

  On 7/16/2015 at 11:04 PM, philiplane said:

 

If you really want LED nav lights, you just pony up for the Whelen Orion nav & strobe assemblies.

Starting at just $450 per wingtip . . . I'm still waiting. That's double what I paid for my Whelen Parmetheus LED landing light.

[jetdriven]

  On 7/16/2015 at 11:04 PM, philiplane said:

Although the CAR 3 rules applied during manufacturing, unfortunately you can't OPERATE it under those rules today. Or maintain it. Unless you have a time machine...

 

So is my CAR 3, 1977 airplane un-airworthy because I dont have 23G seats?

Or 50 FPS gust loading at the top of the green arc? 

It didnt come equipped with shoulder harnesses, must I have those too? 

What about an airspeed indicator marked in knots?  Do I need one of those?

How about parts subsitiution, IE a Dayco green stripe alternator belt in lieu of the 67$ Lycoming version. 

I must buy parts from the same source as the manufacturer, and only PMA parts are allowed? No subsitutions?

Is a Mandatory service bulletin from Mooney or Lycoming (not an AD) required to be performed by me?  

Is a component replacement time, listed in the "airworthiness limitations" section of the AMM required for airworthiness?  (lets asume its published after 1977)

 

What about a 1947 Aeronca Champ? 

 

I guess the point is, I fail to see how FAR 23 affects the maintenance and certification of my CAR3 airplane. There is newer and far better stuff out there, but I am required to maintain my airplane to the FAR part 43 standards in effect as of April 1977 unless dictated by AD?

 

So this is where the linkage to the current 14CFR Part 21, 43, and 91 comes in. If you are operating a plane today, it is in accordance with Part 91, which links to lighting regulations, which in turn links to maintenance rules, in turn to certification standards for parts. All of those are currently enforced by our Friendly Aviation Advisors, not the CAA of yesteryear.

 

And is my aircraft bound by the FAR 23 standard or the CAR 3 standard as of April 1977?

 

 

 

I've already run this LED scenario past FAA personnel and one of the country's top enforcement defense attorneys. Installing non-approved parts is one violation by the installer, accepting them at annual is another violation by the IA, and flying the plane is a violation, times the number of flights that it was unairworthy. There is no good outcome here.

 

Id like to see the PMA or certification standards on a GE 4522 landing light bulb and fiurther, since its not required to operate a Part 91 airplane not for hire, how it is inferior to an incandescent bulb.   heres some more reading.   http://www.avweb.com/blogs/insider/AVWebInsider_FAACounterSafety_203196-1.html

 

Suspect Unapproved Parts have been a priority of the FAA since 2006, mostly to prevent bogus turbine engine parts from getting into jet engines, but the SUP process is very well defined within the # 8300 guidelines in the Inspector's Handbook.

 

These discussions came about as part of the STC process for HID landing lights. I am a pioneer in the process, and the Cessna Citation HID lights offered by Lopresti was one of my recent projects. I know lighting, regulations, and the approval process better than your average owner's group website contributor. 

 

My airplane has a 50W Xevision HID landing light installed as a minor alteration before the FAA published the "EFIS in small airplanes" AC back in October 2010.  Its is by definition a minor alteration, its several times brighter than the GE 4522 bulb that came originally.  Speaking of which, I cannot find any TSO on landing light bulbs nor the PMA on the GE 4522. Can you help me find it?

 

I also have run a Part 145 Repair Station, served as a Part 135 Director of Maintenance, been a Part 135 pilot, and have taught classes in regulatory compliance.

 

If you really want LED nav lights, you just pony up for the Whelen Orion nav & strobe assemblies. They are amazing.

 

I agree totally.  I think the certified options offered by Aveo are a better value but the clear resin they are made of yellows in sunlight over time.

 

not tryig to be a prick, but it seems that FAR 23 airplanes are held to a higher standard than CAR 3 planes, and we are able to substitute parts and make minor alterations by definition easier than the FAR 23 airplanes.   Ive read that the Garmin G700 autopilot servos must be removed every year (or two?) to have the clutch torque measured and adjusted and since its in the airworthiness limitations section of the AMM, its mandatory. Along with the parachute. 

[philiplane]

So is my CAR 3, 1977 airplane un-airworthy because I dont have 23G seats?  No, you aren't changing seats so you don't have to comply with any new regs. 

Or 50 FPS gust loading at the top of the green arc?  No, you aren't changing certification basis, so new loading does not apply.

It didnt come equipped with shoulder harnesses, must I have those too?  No, you are not required to install them since you are not required to have them for Part 91operations of CAR3 aircraft, unless the plane originally had them and they are listed in the Type Certificate notes as required equipment.

What about an airspeed indicator marked in knots?  Do I need one of those? No, your airspeed indicator must match the markings in your TC and flight manual which are MPH. 

How about parts subsitiution, IE a Dayco green stripe alternator belt in lieu of the 67$ Lycoming version. Yes, the original parts manual referenced the Gates part number, you may use it.

I must buy parts from the same source as the manufacturer, and only PMA parts are allowed? No subsitutions? That is correct. Unless you can affirm Fit Form and Function are equivalent.

Is a Mandatory service bulletin from Mooney or Lycoming (not an AD) required to be performed by me? No Service Bulletin is mandatory unless referenced in an AD.   

Is a component replacement time, listed in the "airworthiness limitations" section of the AMM required for airworthiness?  (lets asume its published after 1977) Any time limit listed in a Chapter 4 Airworthiness Limitations section is Mandatory. No exceptions.

 

What about a 1947 Aeronca Champ?  What about it? Be specific.

 

I guess the point is, I fail to see how FAR 23 affects the maintenance and certification of my CAR3 airplane. There is newer and far better stuff out there, but I am required to maintain my airplane to the FAR part 43 standards in effect as of April 1977 unless dictated by AD? Ah, here is the sticky part. You are required to maintain your airplane to the current standards, and those were the standards current at the date of manufacture, PROVIDED you have the maintenance and parts manuals of that period. If you do not, you must maintain it in accordance with the reference material you do have. Remember, you are not complying with Part 23, you are complying with Part 91 operations rules, which may reference newer standards than CAR3. That is what binds you to newer standards, not the fact that Part 23 exists.

 

So this is where the linkage to the current 14CFR Part 21, 43, and 91 comes in. If you are operating a plane today, it is in accordance with Part 91, which links to lighting regulations, which in turn links to maintenance rules, in turn to certification standards for parts. All of those are currently enforced by our Friendly Aviation Advisors, not the CAA of yesteryear.

 

And is my aircraft bound by the FAR 23 standard or the CAR 3 standard as of April 1977?  It depends. If you change parts to newer parts, the parts must comply with the regs at the date of the parts manufacture, since they are required to be eligible for installation via an 8130 Form, a 337 Form, an STC, a PMA, or as an exact replacement that maintains Fit Form and Function, or is produced by you as an Owner Produced Part, with reference to the standards used to create the original part you are replacing.The aircraft as a whole is not boundary newer standards. Only the replacement parts are, because someone has to verify that they are eligible for installation on Type Certificated aircraft. 

 

 

 

I've already run this LED scenario past FAA personnel and one of the country's top enforcement defense attorneys. Installing non-approved parts is one violation by the installer, accepting them at annual is another violation by the IA, and flying the plane is a violation, times the number of flights that it was unairworthy. There is no good outcome here.

 

Id like to see the PMA or certification standards on a GE 4522 landing light bulb and fiurther, since its not required to operate a Part 91 airplane not for hire, how it is inferior to an incandescent bulb.   heres some more reading.   http://www.avweb.com...y_203196-1.html   Certification standards on landing lights govern brightness, depth of field, and width of field. They are spelled out in several documents such as the AC23-17 which also concern halation, radio interference, and other details. AvWeb is typically a poor source for regulatory information.

 

Suspect Unapproved Parts have been a priority of the FAA since 2006, mostly to prevent bogus turbine engine parts from getting into jet engines, but the SUP process is very well defined within the # 8300 guidelines in the Inspector's Handbook.

 

These discussions came about as part of the STC process for HID landing lights. I am a pioneer in the process, and the Cessna Citation HID lights offered by Lopresti was one of my recent projects. I know lighting, regulations, and the approval process better than your average owner's group website contributor. 

 

My airplane has a 50W Xevision HID landing light installed as a minor alteration before the FAA published the "EFIS in small airplanes" AC back in October 2010.  Its is by definition a minor alteration, its several times brighter than the GE 4522 bulb that came originally.  Speaking of which, I cannot find any TSO on landing light bulbs nor the PMA on the GE 4522. Can you help me find it? You cannot install a XeVision HID as a minor alteration, because the light does not have any installation eligibility. A Field Approval is needed. I have done dozens of them.Minor alterations can only be done using Approved Parts of the same Fit Form and Function. HID does not qualify because Form and Function are significantly different, They also have to be tested to the DO-160 standards governing RFI interference with radios and navigation equipment. Incandescent lamps do not produce RFI. HID's do, sometimes too much to be installed in some locations.

 

I also have run a Part 145 Repair Station, served as a Part 135 Director of Maintenance, been a Part 135 pilot, and have taught classes in regulatory compliance.

 

If you really want LED nav lights, you just pony up for the Whelen Orion nav & strobe assemblies. They are amazing.

 

I agree totally.  I think the certified options offered by Aveo are a better value but the clear resin they are made of yellows in sunlight over time.

[C-FRJI]

  On 1/25/2015 at 10:22 PM, cliffy said:

C-FRJI

Can you use non-approved parts in Canada on certified airplanes? We can't down here in the lower 48. They even say on their literature that the kit is not FAA approved.

Just curious, did your Aircraft Technician put them on and sign off on the log books?

Expand  

There are two kits from Aircraft Spruce. Use the approved one. The bulbs are different. Changing light bulbs is as legal as changing tires and oil. Make the log entry yourself.

[cliffy]

Can you pass along the  name or model number you used that is approved? 

I can't find an approved replacement LED nav light bulb anywhere on Spruce;'s website. I'd like to use them if I can find them.