Adding a landing/pulsating light to the J and K wingtip

[Steve Dawson]

As anyone that has a J or K knows the landing and taxi lights are lacking a bit in being barely utilitarian. I have a design to install a bright LED landing light that is capable to also pulsate in conjunction with installation of  a Whelen LED strobe/position light however the light is classed as experimental. It's much brighter than their new recognition lights,  Is there a way to install this and still have it legal? 

[Will.iam]

Field approval?

[kortopates]

Precise makes an approved flasher to do what you want. probably others as well. Lots an approved LED and HID lights.
I have a HID lights and a flasher on my WAT Recognition lights.
Aircraft position lights are not allowed to flash.


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[PT20J]

I put a Seaton Maxpulse on my LED recognition lights. https://seatoneng.com/our-products/ It has more flashing modes than anyone would need, but the ability to stop the flashing easily has come in handy when trying to find a turn onto an unlighted taxiway. The WAT Prometheus 2 landing and taxi lights are plenty bright.

 

[Steve Dawson]

Thanks all, I wanted landing lights and not position lights because of the design of Mooney's only having the lone landing/taxi lights position in the cowl. The lights I was looking at from Whelen have the capacity to pulse when connected and powered together and don't need a separate controller. These lights are also much more bright than the Whelen Mooney position lights but they're also classified under experimental so I'm unsure of which approval or which law needs to be checked.

If it's just a matter of getting a field approval does anyone know of a way to check that out before I start?  

[PeteMc]

Reach out to @OSUAV8TER.

I have the original Whelen wingtip recognition lights and upgraded to the LED bulb through Gallagher Aviation.  He should be able to tell you want the lates wingtip options are.  And if you don't have a LED landing light, you might want to consider that too.  I have the option to switch my pulsing lights to solid on if I need more light.  But never have since I put in the LED landing light. 

Here's his contact info if he doesn't chime in:
https://www.gallagheraviationllc.com
gallagheraviationllc@gmail.com 
1-833-425-5288 <-- Call/Text, please leave a voicemail if I do not answer
513-401-6495 <-- Call/Text/MMS, please leave a voicemail if I do not answer

[PeteMc]

22 hours ago, Steve Dawson said:

Whelen Mooney position lights but they're also classified under experimental

Are you sure the wingtip lights are considered experimental?  Usually things that are approved in the US, especially from a company like Whelen, are also approved in Cda. 

[Steve Dawson]

6 hours ago, PeteMc said:

Are you sure the wingtip lights are considered experimental?  Usually things that are approved in the US, especially from a company like Whelen, are also approved in Cda. 

I'd be adding a "meant for an experimental aircraft" light in the wingtip that hadn't had a landing light in before. 

[kortopates]

I'd be adding a "meant for an experimental aircraft" light in the wingtip that hadn't had a landing light in before. 

Maybe if you shared the product you want to install we may have a better idea.
“Position” lights have to meet a TSO standard, “recognition” lights do not.
A Field Approval is a 337 submitted by a mechanic to the local FSDO for sign off by the FAA. My local FSDO is so understaffed about the only way to get a field approval is to present one signed off for the same mod you want by another FSDO already. Any field approval must essentially have approval from the FSDO before starting.

FSDO’s vary on their opinion of unapproved lighting. Best to be asking your IA that does your annuals. He/she could say he could do it as a minor mod, check into getting a field approval for you or say no way will it get approved. The specifics matter.


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[kortopates]

I'd be adding a "meant for an experimental aircraft" light in the wingtip that hadn't had a landing light in before. 

Maybe if you shared the product you want to install we may have a better idea.
“Position” lights have to meet a TSO standard, “recognition” lights do not.
A Field Approval is a 337 submitted by a mechanic to the local FSDO for sign off by the FAA. My local FSDO is so understaffed about the only way to get a field approval is to present one signed off for the same mod you want by another FSDO already. Any field approval must essentially have approval from the FSDO before starting.

FSDO’s vary on their opinion of unapproved lighting. Best to be asking your IA that does your annuals. He/she could say he could do it as a minor mod, check into getting a field approval for you or say no way will it get approved. The specifics matter.


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[Aaviationist]

To go on a certified aircraft it’s needs a TSO and PMA. 
 

You cannot put “experimental “ parts on a certified aircraft. 
 

you can’t install the experimental version of a Garmin 650 and you can’t install an experimental version of lighting. 

[EricJ]

1 hour ago, Aaviationist said:

To go on a certified aircraft it’s needs a TSO and PMA. 

You cannot put “experimental “ parts on a certified aircraft.

Both of those statements are incorrect.   A simple counterexample from a safety system is a sonalert, which exists in many, many certificated aircraft.   They are neither TSO nor PMA.   Further examples are numerous.   There are FAA ACs and legal opinion letters that help clarify guidance in this area, especially for older aircraft with restricted availability to replacement parts.  The FAA VARMA program exists essentially to help document the installation of otherwise potentially non-approved parts on certificated aircraft.   Owner Produced Parts are also legal if done properly.

[Aaviationist]

7 hours ago, EricJ said:

Both of those statements are incorrect.   A simple counterexample from a safety system is a sonalert, which exists in many, many certificated aircraft.   They are neither TSO nor PMA.   Further examples are numerous.   There are FAA ACs and legal opinion letters that help clarify guidance in this area, especially for older aircraft with restricted availability to replacement parts.  The FAA VARMA program exists essentially to help document the installation of otherwise potentially non-approved parts on certificated aircraft.   Owner Produced Parts are also legal if done properly.

can you provide something specific that shows this guidance?

 

It’s my understanding the Sonalert for example is installed under Norsee. 
 

for older or restricted available parts, that’s what the owner produced part allowances are for. 
 

When it comes to lighting where MANY certified option with PMA / TSO options are available, not aware of any legal path of installing any non certified alternative. Just like any other non certified radio or avionics. 
 

Edited August 11, 2025 by Aaviationist

[EricJ]

4 hours ago, Aaviationist said:

can you provide something specific that shows this guidance?

First, it's much more straightfoward to ask for a specific regulation or regulations requiring all parts to be PMA or TSO.  See if you can find that.

Otherwise, just to name a few, AC 23-27 for part subsitution for vintage aircraft, AC 20-62 for replacement parts, OPP, AC 43-18.   There are numerous FAA opinion letters covering things like standard parts (none of which are TSO or PMA, the easiest example being electronic parts, even connectors, wiring, etc.)(Kaplan), including the Byrne letter on Owner Produced Parts, the Coleal letter on what is Preventive Maintenance (since the installer determines whether a part is appropriate or not).

4 hours ago, Aaviationist said:

It’s my understanding the Sonalert for example is installed under Norsee. 

NORSEE didn't exist until 2016.   My airplane has two sonalerts and was built in 1977.

4 hours ago, Aaviationist said:

When it comes to lighting where MANY certified option with PMA / TSO options are available, not aware of any legal path of installing any non certified alternative. Just like any other non certified radio or avionics. 
 

Again, find something that indicates these must be PMA or TSO, especially for lighting, especially for something like a landing light.   The requirements for landing lights are that they "provide illumination and are safe for operation".   Seriously, that's it.   Also see the interpretations for standard parts for things like bulbs, nuts and bolts, connectors, etc.

There are many parts where a TSO or PMA are appropriate, but there are many, many parts outside of those requirements.   According to the FAA presenters at our local IA seminar you can buy parts at your local auto parts dealer, as long as it is the same part that is on the aircraft (and automotive suppliers are where a lot of airplane parts come from).  

[Pinecone]

On 8/9/2025 at 10:59 AM, kortopates said:

Precise makes an approved flasher to do what you want. probably others as well. Lots an approved LED and HID lights.
I have a HID lights and a flasher on my WAT Recognition lights.

WAT has a flasher that is about 1/2 the price of the Precise one.  They don't advertise it much.  But James Gallagher is familiar with them and stocks or can get them.

It can flash 4 circuits, with 1 and 2 together opposite 3 and 4.   Each one can also have a switch to turn the light on steady.

So, in my 252 I flash the taxi light opposite the recognition lights.  But if I turn the Taxi light switch On, the light stays on steady.

[Aaviationist]

54 minutes ago, EricJ said:

First, it's much more straightfoward to ask for a specific regulation or regulations requiring all parts to be PMA or TSO.  See if you can find that.

Otherwise, just to name a few, AC 23-27 for part subsitution for vintage aircraft, AC 20-62 for replacement parts, OPP, AC 43-18.   There are numerous FAA opinion letters covering things like standard parts (none of which are TSO or PMA, the easiest example being electronic parts, even connectors, wiring, etc.)(Kaplan), including the Byrne letter on Owner Produced Parts, the Coleal letter on what is Preventive Maintenance (since the installer determines whether a part is appropriate or not).

NORSEE didn't exist until 2016.   My airplane has two sonalerts and was built in 1977.

Again, find something that indicates these must be PMA or TSO, especially for lighting, especially for something like a landing light.   The requirements for landing lights are that they "provide illumination and are safe for operation".   Seriously, that's it.   Also see the interpretations for standard parts for things like bulbs, nuts and bolts, connectors, etc.

There are many parts where a TSO or PMA are appropriate, but there are many, many parts outside of those requirements.   According to the FAA presenters at our local IA seminar you can buy parts at your local auto parts dealer, as long as it is the same part that is on the aircraft (and automotive suppliers are where a lot of airplane parts come from).  

In a world where there are dozens of TSO/PMA lighting options, where exactly does 23-27 fit into this?  (23-27 is meant for and specifically says it’s for vintage aircraft whose parts are no longer available or difficult to find. It must meet or exceed the original specification, which, in a world with a large list of TSO/PMA options, an experimental version would not cover). It doesn’t.
 

So let’s move to the next one. 

 

20-62e standard parts - (nuts bolts, etc) (lighting assemblies and LED assemblies are not considered “standard parts”  there is guidance on this in the document  

owner produced parts - nope

parts which inspections have been accomplished by appropriate certificates persons (DAR) to conform to FAA approved design - by definition, an experimental light assembly would not 

 

parts fabricated by a rated certificate holder with a quality system …..  - nope

 

Again, show me specifically what allows you to use a non standard electronic device and assembly without a PMA or TSO in a certified aircraft?  None of what you referenced previously shows that. In fact, it states the opposite. 
 

you state I’m incorrect, but then you reference advisory circulars that defend what I’ve said and directly contradict the idea that “I’m incorrect”

Edited August 11, 2025 by Aaviationist

[IvanP]

5 hours ago, Aaviationist said:

When it comes to lighting where MANY certified option with PMA / TSO options are available, not aware of any legal path of installing any non certified alternative. Just like any other non certified radio or avionics. 
 

Just because YOU are not aware of something, it does not necessarily mean that it does not exist  . It may be prudent to do some fact checking before making broad, and inaccurate, statements of "facts".

[Aaviationist]

8 minutes ago, IvanP said:

Just because YOU are not aware of something, it does not necessarily mean that it does not exist  . It may be prudent to do some fact checking before making broad, and inaccurate, statements of "facts".

Having been doing this a number of years, I like to think I’m up on my regs. I have not seen a reg that allows a non TSO/PMA lighting assembly in a type certificated aircraft. 
 

if you know of something, send it my way. But so far nobody has been able to point to anything that actually says that. 
 

at then end of the day, it’s not be getting ramp checked or selling the aircraft with illegal parts, so you do what you want. 
 

if you have something seemingly nobody else has, feel free to post it so it’s accuracy and legitimacy can be discussed. But saying I’m wrong and then referencing owner produced parts isn’t really a good argument. 
 

Edited August 11, 2025 by Aaviationist

[EricJ]

4 minutes ago, Aaviationist said:

Having been doing this a number of years, I like to think I’m up on my regs. I have not seen a reg that allows a non TSO/PMA lighting assembly in a type certificated aircraft. 

Again, find something that says it is always required.  It isn't, or all of our airplanes would be permanently grounded.

4 minutes ago, Aaviationist said:

if you know of something, send it my way. But so far nobody has been able to point to anything that actually says that. \

You need to actually read the ACs I listed, not just a cursory glance.

4 minutes ago, Aaviationist said:

at then end of the day, it’s not be getting ramp checked or selling the aircraft with illegal parts, so you do what you want. 

Does your airplane have a sonalert?   A canon plug somewhere?   Electrical wiring?  Standard nuts and bolts?  Interior trim?  None of those things typically have TSOs or PMAs.  

4 minutes ago, Aaviationist said:

if you have something seemingly nobody else has, feel free to post it so it’s accuracy and legitimacy can be discussed. 

Pilots can attend IA seminars, often with Wings credit, and those usually include a lot of presentations from FAA representatives as well as manufacturer's representatives.   Often there are sessions covering part stubstitutions, etc., etc.

Also, look into the VARMA program.   Some of the FAA presentations for that include examples using parts from auto parts stores or other non-TSO and non-PMA sources.   The purpose of the VARMA program is to provide the owner with documentation that the parts are approved so that a misguided IA or A&P doesn't try to make them remove them later.

[Aaviationist]

4 minutes ago, EricJ said:

Again, find something that says it is always required.  It isn't, or all of our airplanes would be permanently grounded.

You need to actually read the ACs I listed, not just a cursory glance.

Does your airplane have a sonalert?   A canon plug somewhere?   Electrical wiring?  Standard nuts and bolts?  Interior trim?  None of those things typically have TSOs or PMAs.  

Pilots can attend IA seminars, often with Wings credit, and those usually include a lot of presentations from FAA representatives as well as manufacturer's representatives.   Often there are sessions covering part stubstitutions, etc., etc.

Also, look into the VARMA program.   Some of the FAA presentations for that include examples using parts from auto parts stores or other non-TSO and non-PMA sources.   The purpose of the VARMA program is to provide the owner with documentation that the parts are approved so that a misguided IA or A&P doesn't try to make them remove them later.

I did read it and have read it many times. It appears you didn’t read my response. 
 

cannon plugs, nuts, bolts are standard parts. 
 

pulsating experimental lighting, is not. Nor are they OPP. 

[EricJ]

16 minutes ago, Aaviationist said:

I did read it and have read it many times. It appears you didn’t read my response. 

I did read your response, but perhaps you missed in those documents where parts other than TSO and PMA can be used.

16 minutes ago, Aaviationist said:

cannon plugs, nuts, bolts are standard parts. 

Yes, and neither TSO nor PMA.

16 minutes ago, Aaviationist said:

pulsating experimental lighting, is not. Nor are they OPP. 

Not sure what you're talking about here.   I was only addressing your blanket statement that "To go on a certified aircraft it’s needs a TSO and PMA.  You cannot put “experimental “ parts on a certified aircraft. "

[PeteMc]

12 hours ago, EricJ said:

here are FAA ACs and legal opinion letters that help clarify guidance in this area, especially for older aircraft with restricted availability to replacement parts.  The FAA VARMA program exists essentially to help document the installation of otherwise potentially non-approved parts on certificated aircraft.

One minor point...  Note that the Steve shows he's based at CYKF.  So our FAA rules do not apply.

 

[Aaviationist]

17 minutes ago, EricJ said:

I did read your response, but perhaps you missed in those documents where parts other than TSO and PMA can be used.

Yes, and neither TSO nor PMA.

Not sure what you're talking about here.   I was only addressing your blanket statement that "To go on a certified aircraft it’s needs a TSO and PMA.  You cannot put “experimental “ parts on a certified aircraft. "

I can’t tell if you’re just being obtuse because you can’t find anything to base your claim that it’s ok to install this light, or if you really expected me to post every single thing that was an exception to needing a TSO. 
 

It seems your responses now are just being childish. 
 

yes, nuts and bolts are considered standard parts and don’t need a TSO or PMA. 
 

That is not relevant to my initial comment of - 

To go on a certified aircraft it’s needs a TSO and PMA. 
 

You cannot put “experimental “ parts on a certified aircraft. 

 

which was in reference to the subject of this thread and not “a blanket statement.” 
 

when it comes to Canada, I believe their regulations are more strict than in the US. 

Edited August 11, 2025 by Aaviationist

[Steve Dawson]

43 minutes ago, PeteMc said:

One minor point...  Note that the Steve shows he's based at CYKF.  So our FAA rules do not apply.

 

I have a N registered aircraft so it will fall under the FAA regulations. Secondly I believe that under Canadian rules something approved under FAA regulations it will be approved in Canada. 

[Steve Dawson]

15 hours ago, kortopates said:

Maybe if you shared the product you want to install we may have a better idea.
“Position” lights have to meet a TSO standard, “recognition” lights do not.
A Field Approval is a 337 submitted by a mechanic to the local FSDO for sign off by the FAA. My local FSDO is so understaffed about the only way to get a field approval is to present one signed off for the same mod you want by another FSDO already. Any field approval must essentially have approval from the FSDO before starting.

FSDO’s vary on their opinion of unapproved lighting. Best to be asking your IA that does your annuals. He/she could say he could do it as a minor mod, check into getting a field approval for you or say no way will it get approved. The specifics matter.


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Two examples are: The Whelen Microsun LED taxi/recognition light or their SunRay Evo III landing recognition light. Both have internal pulsating options