Nav light replacement bulb

[0TreeLemur]

On 9/17/2019 at 2:20 PM, Huitt3106 said:

I'm digging up an old thread here.  To do the drop in replacement LED bulbs, you would have to replace the current green/ red lenses with a clear lens correct?  Where do you get the clear lens?  The part number according to this parts list (https://www.aircraftspruce.com/catalog/elpages/whelenstrobeparts1.php?gclid=Cj0KCQjwiILsBRCGARIsAHKQWLN0ZWpVVYriZGowTk6SFCZoPVHtVAI3IL9Df1tbNHMTiexXo3N_wSQaAlk7EALw_wcB) is w1284.  The whelen brand clear lens I found is like $217 on SkyGeek.  Am I missing an easier (cheaper) way to accomplish this?  

There are much cheaper solutions for sale on eBay.  Use picclick.com to search for "Grimes model E"  and "position lights"

[EricJ]

17 hours ago, Bob E said:

So, may I simply replace my old incandescent position light bulbs with LED bulbs?  Yes.  Unlike anti-collision lights, position lights are not TSO'd.  Certainly no 337 needed.  My LED position lights are Aero-Lites. The wingtip lights are aviation green and red; the colors are pure and brilliant when the bulbs are under the original colored lenses.

TSO-C30c applies to position lights, so there is a TSO.   I believe it is cited in my Mooney IPC or S&M.    Some of the LED plug-in replacements claim compliance to TSO-C30c, including the ones I put in.   So if you want to cover yourself that way, too, it is possible.

I think if you have a decently bright green, red, and white light plugged into the proper socket on the airplane, you're unlikely to get much grief.   The main opinion that matters is your IA's.

[Bob E]

As far as I can tell, TSO-C30c is for position lights -- a position light is an assembly including socket, wiring, housing, bulb and lens -- not for the light bulbs in them.  But like you mentioned, I'll go with my IA's opinion (as well as that new AOPA Pilot article). 

At this point going around and round on the legality, while really interesting and actually educational too, is kinda like debating angels on the head of a pin. Those old odd-shaped bulbs were expensive, ran hot, and burned out fairly often -- in the middle of night flight. The new LED bulbs are bright, the color is pure and intense, they use almost no electricity, and are safer because they won't burn out just when you need them.  (Same thing for my LED landing light -- about twice as bright as the old one, won't blow out when I'm on final, and the radios and lights don't dim when I switch it on.  I can keep it on all the time.)

[jaylw314]

36 minutes ago, Bob E said:

As far as I can tell, TSO-C30c is for position lights -- a position light is an assembly including socket, wiring, housing, bulb and lens -- not for the light bulbs in them.  But like you mentioned, I'll go with my IA's opinion (as well as that new AOPA Pilot article). 

At this point going around and round on the legality, while really interesting and actually educational too, is kinda like debating angels on the head of a pin. Those old odd-shaped bulbs were expensive, ran hot, and burned out fairly often -- in the middle of night flight. The new LED bulbs are bright, the color is pure and intense, they use almost no electricity, and are safer because they won't burn out just when you need them.  (Same thing for my LED landing light -- about twice as bright as the old one, won't blow out when I'm on final, and the radios and lights don't dim when I switch it on.  I can keep it on all the time.)

Agreed, I think the presence or lack of a TSO says less about whether it's reasonable, and more about how nervous you would be if the FAA ever decided to ramp check you.   If I get around to replacing mine, I know I'll keep the original bulbs in the hangar just in case  

[EricJ]

8 hours ago, Bob E said:

As far as I can tell, TSO-C30c is for position lights -- a position light is an assembly including socket, wiring, housing, bulb and lens -- not for the light bulbs in them.  But like you mentioned, I'll go with my IA's opinion (as well as that new AOPA Pilot article). 

I can't find it right now, but I think it specifies brightness, color, radiation angles, etc.   It's not complicated but just has to do with the functionality.   A bulb can be compliant, which is why many bulbs or bulb replacements cite that spec.

 

[0TreeLemur]

Putting a colored LED behind a colored lens will make it difficult to verify required brightness.   Colored lenses attenuate colors off the desired color by almost 100%.   They also attenuate the desired color.  With a colored LED there is no reason for a colored lens.  In fact the colored lens might cut the brightness enough to make it not meet brightness requirements.  I bought clear polycarbonate lenses for the Grimes position lights for about $25 ea.  These made a huge difference with the red/green LED bulbs that were installed.  They cast large red and green lobes of light on the ground below the wing-tips that were not there with the colored lenses.

[bob865]

Maybe I'm just cynical. All this conversation about if a bulb is or is not approved by the FAA is crazy.  I feel like we like to obsess about the minutia of the regulations on stuff where it’s basically irrelevant.  Let me walk down this path a little and go with me for a bit.  Then you can hang me.

A light bulb type specifies the base, wattage(in the case of incandescent bulbs this is how bright it is), size, and shape.  For the sake of this discussion let’s call it a #123 bulb.  If I buy a brand A #123 bulb or brand B #123 bulb they are both going to have the same base, wattage(light output), size and shape.  If I buy a LED “bulb” compatible with #123, it will have the same base, pull the same or less wattage (but produce the comparable amount of light as it’s incandescent bulb), and fit within the same size and shape requirements. Why should I look at an LED bulb any different than I would an incandescent?  Let’s take a second to consider safety.  An incandescent bulb works by creating heat.  An LED doesn’t.  Point to LED.  An LED pulls less power than a comparable incandescent bulb.  Another point to an LED.

I cannot believe a world exists where an FAA inspector would ramp check a light bulb when there is hardly a Mooney in existence with the same panel it originally had.  If the inspector walks up for a ramp check and asks about my light bulb choice and not about the paperwork on my G5, Radios, or Skybeacon then aviation is doomed.  I think a log entry saying I did it is a fair and reasonable solution.  It wouldn’t say anything other than R&R right wingtip light bulb with compatible LED bulb.

Just my opinion.  Flame away.

[0TreeLemur]

I agree with you @bob865  The problem as I see it is lack of clear guidance and fear of the gov'ment.  There are different decisions/interpretations of the FARs written by different FSDOs at different times that folks can choose from to support their personal opinion.   Sadly there is no ultimate decider.   If the FAA wants to get you, they will almost always find a way.   I replaced the energy wasting/heat generating rice grain bulbs in my  post lights with LEDs.  Getting rid of any source of ignition in the cabin seemed like a great idea, as did going with bulbs that are not vibration sensitive. 

The 'owner approved maintenance list' was just reinterpreted by the FAA to allow us to do more stuff than what is black-n-white in the FARs.   Common sense works until it doesn't.   Interpretation of the regulations is an inexact art.  The stock answer in certified aircraft is to pass the buck up to the appropriate level and get it in writing to reduce finger pointing ambiguity when something goes wrong.   Sad but true it seems.

[bob865]

22 minutes ago, 0TreeLemur said:

If the FAA wants to get you, they will almost always find a way.

That's kinda my point.  Prime example is when I installed the skybeacon.  I missed the required placard at first.  Just a small oversight that made my install illegal(that has since been corrected).  That would have been an easy find an inspector that wouldn't require taking the plane apart and looking for model numbers on light bulbs or digging through log books for correct entries.  I also remember the conversation on here a few months/years back about IFR legal GPS installs.  From that thread I gathered that many GPS installs that are used for IFR actually aren't even legal for IFR.  Not becuase of the capability of the GPS, but becuase the install are't per the rules.  Easy to catch if you know what you're looking at and you don't even have to tear into the log books or look at a bulb and crossreference for an STC.  I guess to sum up, if I was an inspector, I'd have to be kinda sadistic to go after small owner operators over a LED light bulb.

Just my $.02 as a non-faa inspector plane owner.

[jaylw314]

39 minutes ago, bob865 said:

That's kinda my point.  Prime example is when I installed the skybeacon.  I missed the required placard at first.  Just a small oversight that made my install illegal(that has since been corrected).  That would have been an easy find an inspector that wouldn't require taking the plane apart and looking for model numbers on light bulbs or digging through log books for correct entries.  I also remember the conversation on here a few months/years back about IFR legal GPS installs.  From that thread I gathered that many GPS installs that are used for IFR actually aren't even legal for IFR.  Not becuase of the capability of the GPS, but becuase the install are't per the rules.  Easy to catch if you know what you're looking at and you don't even have to tear into the log books or look at a bulb and crossreference for an STC.  I guess to sum up, if I was an inspector, I'd have to be kinda sadistic to go after small owner operators over a LED light bulb.

Just my $.02 as a non-faa inspector plane owner.

A cynic might suggest installing the LED position lights just to give an ramp check inspector a rules violation that is easy to find and easy to fix.  That might satisfy him and keep him from looking for a bigger more expensive problem  

[jetdriven]

A real problem with LED bulbs is that they require an array to meet aspherical illumination requirements. LED emitters have a very narrow beam, and if you just stick one in the wingtip it’ll be bright  in some areas and not as bright in others. Incandescent bulb radiates light in 360° of sphere  from the elements, and LED like I said must have an array and it must be shaped properly. There’s a lot of LED bulbs out there that are not very bright at all

Edited September 19, 2019 by jetdriven

[EricJ]

20 minutes ago, jetdriven said:

 There’s a lot of LED bulbs out there that are not very bright at all

I wasted money on some that were just duds since they were very dim.   The ones I wound up with are TSO-C30c compliant (according to the mfg) and are plenty bright, even though they look nearly identical to the duds that were too dim.

 

[philiplane]

Unless the manufacturer has been issued an FAA PMA for replacement parts, their statement of 
meets TSO..." is worthless. The only way they can claim it meets the TSO C3b for lights, is to submit them to the FAA for approval, then receive a PMA, which will be the certification basis. Then you need an installation approval, if the PMA is not worded as "direct replacement for 7512-12 lamp", or similar.

To make it simple, the ONLY current FAA approved drop-in LED navigation lamps are the Whelen Chroma series. 

[kortopates]

28 minutes ago, EricJ said:

I wasted money on some that were just duds since they were very dim.   The ones I wound up with are TSO-C30c compliant (according to the mfg) and are plenty bright, even though they look nearly identical to the duds that were too dim.

 

I think I used the same bulbs from Spruce for a few years, I thought they were plenty bright. But as Philip states, "compliant" technically means nothing to the FAA. They're definitely not approved but since they sure seemed adequate, I installed them with the clear lenses as a minor mod - a modification though is not something an owner can sign off on under preventative maintenance. But later when the Whelen Orions came out I upgraded all 3 of my lights to the Orions. But I didn't lose any sleep when I had them installed.

[EricJ]

2 minutes ago, kortopates said:

I think I used the same bulbs from Spruce for a few years, I thought they were plenty bright. But as Philip states, "compliant" technically means nothing to the FAA. They're definitely not approved but since they sure seemed adequate, I installed them with the clear lenses as a minor mod - a modification though is not something an owner can sign off on under preventative maintenance. But later when the Whelen Orions came out I upgraded all 3 of my lights to the Orions. But I didn't lose any sleep when I had them installed.

In the above case I was just citing the TSO compliance as an indication that they'll likely be bright enough to be useful, since some of them out there clearly are not, and at least meet the brightness and color requirements specific for the task of position light.

The rest of it is all the subject of the usual discussions, and given the recent citing of the FAA's legal opinion on Preventive Maintenance not being restricted to the Part 43 App A(c) list, probably gonna continue to be open to a lot of interpretation and opinion.

 

[Steve W]

The problem is, given 3 different FAA employees you'll get at least 4 different opinions. 

It would be nice if they'd just come out and say(consistently, maybe an AC) "Fine, use 'consumer grade' LEDs, make sure they meet these brightness/color requirements and do an interference check" or "PMA only, no LED for you, pay $1000"

 

[jetdriven]

Question is how do you measure or verify 100cd  of brightness from zero degrees forward to 110 degrees aft, and from 90 degrees up through down. Those are the requirements and like i mentioned earlier, LEDs tend to have dark spots in random areas. 

Edited September 20, 2019 by jetdriven

[Hank]

2 hours ago, philiplane said:

Unless the manufacturer has been issued an FAA PMA for replacement parts, their statement of 
meets TSO..." is worthless. The only way they can claim it meets the TSO C3b for lights, is to submit them to the FAA for approval, then receive a PMA, which will be the certification basis. Then you need an installation approval, if the PMA is not worded as "direct replacement for 7512-12 lamp", or similar.

To make it simple, the ONLY current FAA approved drop-in LED navigation lamps are the Whelen Chroma series. 

There's no such statement, PMA or TsO certificate for my current incandescent bulb. Why do I need these things for one new bulb but not for another new bulb? And how do I as a mere owner know which new bulb needs all of this and which new bulb doesn't???

[EricJ]

40 minutes ago, jetdriven said:

Question is how do you measure or verify 100cd  of brightness from zero degrees forward to 110 degrees aft, and from 90 degrees up through down. Those are the requirements and like i mentioned earlier, LEDs tend to have dark spots in random areas. 

I don't think it would be difficult to make a test fixture to measure that.   Measuring brightness wrt the device position isn't conceptually difficult, and the spec should define the test criteria.   It turns out that TSO-C30c is based on an SAE spec, AS 8037, which lives behind a paywall.   Otherwise we could look it up, but I don't think determining brightness and color at various positions and distances (assuming that's how it's spec'ed) wouldn't be egregiously difficult.   Clearly it's been done a number of times judging by the number of LED suppliers in the list for TSO-C30c devices.    If the measurements are made at a reasonable distance, the "dark spots" might not matter.  If the device meets it, and the assembly that holds the bulb doesn't defeat it (e.g., block any of the required radiation angles), then the system should be functionally compliant.

[cliffy]

This is a long standing issue here on MS

Light bulbs are considered "standard parts" There is a complete description of what qualifies as a standard part from the FAA-

https://www.faa.gov/aircraft/safety/programs/sups/standard_parts/media/standard_parts.pdf

Just because the "new" bulb fits the socket and kind of does the same thing as the specified bulb doesn't allow it to be considered as a standard part replacement. 

Nav light bulbs are made to an industry standard of design and performance (glass bulb, filament, wattage, COLOR TEMPERATURE, etc, published by SAE  or other independent industry design group. 

Standard parts are not required to meet any FAA/PMA requirements either-read the above reference. 

If the bulb is designed to be a replacement but it does not match the exact design of the SAE published design it doesn't meet standard part qualification. in the above cited FAA paper that requires a specific finding by the FAA for use. 

Whelen's own website on their "drop in" LED bulbs says "FAA APPROVALS PENDING" so even they are no truly legal on certified airplanes. (page 3 of the Whelen catalog-look at the other offerings where they show approvals)

https://www.whelen.com/pb/Aviation/Catalog Price Lists and Manuals/General_Aviation_Catalog.pdf

The bulb specified by Mooney is the industry standard bulb. Its a "standard part" as it conforms exactly to an industry standard design, Any bulb you put in that does not match that design exactly is an alteration to the Type Design of the airplane by definition. 

Now what you do on your own is up to you I'm just explaining the legal definition and if you want to run the risk of questions by the Feds Go for it. Its your airplane and your license, 

If you install it and sign it off and in the slight chance that the FAA questions it, you have to answer the questions. If you put it in and don't sign it off and it is questioned- you still have to answer why your airplane is not legal in its log book requirements as YOU the owner are responsible for the maintenance on your airplane NOT your mechanic. 

It all comes down to you. Is it legal or is it not- it's a simple question to answer. 

[Andy95W]

3 hours ago, cliffy said:

This is a long standing issue here on MS

Light bulbs are considered "standard parts" There is a complete description of what qualifies as a standard part from the FAA-

Exactly.

It's just like AN bolts.  If your A&P said that he replaced your engine mounts, and used bolts that were not standard aviation parts but "met the standards" of AN bolts, how would you feel about it?

I personally don't care what an owner does or does not install on his own airplane, but I know where I draw the line on mine.

[Wayne Cease]

C’mon guys let’s consider the totality of the circumstances here. The Whelen LED nav or landing light bulbs are drop-in replacements. They clearly use less energy. They will almost last the lifetime of the aircraft. There is no way the FAA would dare fight this one. 

There are some people in the FAA working to fix this mess so you do exactly that. But it's a slow turning supertanker.



Wayne

[philiplane]

12 hours ago, Hank said:

There's no such statement, PMA or TsO certificate for my current incandescent bulb. Why do I need these things for one new bulb but not for another new bulb? And how do I as a mere owner know which new bulb needs all of this and which new bulb doesn't???

There is. The original lamp assembly, consisting of the housing, lens, and lamp, is a TSO article. Any replacement parts must maintain the TSO of the assembly. It's that simple.

The lamp in a wingtip navigation light assembly is NOT a "standard part". It is part of the design of the assembly, and an alteration to the lamp would require new testing to verify compliance with the applicable TSO. 

14CFR Part 21 governs aircraft replacement parts. Absent an FAA approval in the form of an STC, PMA, a part required under regulation (red/green position lights for example) must conform to the applicable standard, which in this case is TSO-C3b. If it doesn't, it's an Unapproved Part and renders the aircraft Unairworthy. 

The original reflector lamp for the wingtip lights can be replaced by an equivalent lamp, meaning one of the same Fit Form and Function. LED's fail that first and second test, and ones that add a strobe feature fail the Function portion. And equivalent doesn't mean that a manufacturer can simply make a claim, testing is done and certification is granted by the FAA for a replacement part. Many LED lamps will fail the field of view test, due to their design. LED's produce very bright pin points of light but leave large blind spots, especially when used without a reflector. 

Edited September 20, 2019 by philiplane

[EricJ]

10 minutes ago, philiplane said:

There is. The original lamp assembly, consisting of the housing, lens, and lamp, is a TSO article. Any replacement parts must maintain the TSO of the assembly. It's that simple.

The lamp in a wingtip navigation light assembly is NOT a "standard part". It is part of the design of the assembly, and an alteration to the lamp would require new testing to verify compliance with the applicable TSO. 

In the IPC for my airplane, a J, the bulb does not appear in the exploded drawing for the assembly.   It only appears, as a separate item, separate from the assembly, in a different drawing in a different section.

 

[JimB]

9 minutes ago, philiplane said:

There is. The original lamp assembly, consisting of the housing, lens, and lamp, is a TSO article. Any replacement parts must maintain the TSO of the assembly. It's that simple.

The lamp in a wingtip navigation light assembly is NOT a "standard part". It is part of the design of the assembly, and an alteration to the lamp would require new testing to verify compliance with the applicable TSO. 

14CFR Part 21 governs aircraft replacement parts. Absent an FAA approval in the form of an STC, PMA, a part required under regulation (red/green position lights for example) must conform to the applicable standard, which in this case is TSO-C3b. If it doesn't, it's an Unapproved Part and renders the aircraft Unairworthy. 

The original reflector lamp for the wingtip lights can be replaced by an equivalent lamp, meaning one of the same Fit Form and Function. LED's fail that first and second test, and ones that add a strobe feature fail the Function portion. And equivalent doesn't mean that a manufacturer can simply make a claim, testing is done and certification is granted by the FAA for a replacement part. Many LED lamps will fail the field of view test, due to their design. LED's produce very bright pin points of light but leave large blind spots, especially when used without a reflector. 

Just to clarify, the current TSO for position lights is TSO-C30c. The TSO for these lights would be TSO-C30b dated 1957

 http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/cfa519bb271ee2df86256e93005f4e30/$FILE/TSO-C30b.pdf