Replies to This Discussion

Permalink Reply by David J. Beaulieu on September 16, 2021 at 2:45pm

Bradford, I know that there is a candela and azimuth requirement for the lights.  Those requirements have changed over time, which requirement applies depends on when the aircraft is completed and certified. I looked into this after my build was complete (2017) and was disappointed to find that the AeroLed kits I purchased with my 750 kit do not meet the newer requirements in place at that time.  If I would have done my research prior I simply would have upgraded the light to a different model that met current requirements.  I wish I had the references but a search on the internet should provide those relatively easy.  Here is a link to previous thread

http://www.zenith.aero/forum/topics/legal-night-flight-lighting

Good luck!

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Permalink Reply by Bradford Drown on September 16, 2021 at 7:34pm

Thanks David,

Reading thru § 23.1387 through 23.1397.

Last revision I see is 1993.

Need to take a course in this stuff to understand it.  

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Permalink Reply by Jim and Amelia Isaacs on September 18, 2021 at 2:18am

For position lights:

https://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/d27...$FILE/C30c.pdf

For anticollision lights (there’s also a newer version C96b but lighting meeting either one works):

https://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/548...$FILE/C96a.pdf

So look at lighting where the manufacturer states it meets these TSOs

Me I don’t fly at night anymore, night air has no lift.  I don’t know how I ever did it in the past. Must have been voodoo magic.

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Permalink Reply by Bradford Drown on September 18, 2021 at 7:49pm

Thanks for the links.

I am not going to be flying at night with the 601, but I was wondering about resale in the future. 

 

And should I spend hundreds for nav, strobe, and landing/taxi lights when I could just buy at Wal Mart, Amazon, or Marine lights?

Best I can find so far is Whelen MicroBurst Plus II @ $349, not night legal, but look real :-)

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Permalink Reply by Bob Johnson on September 20, 2021 at 1:02am

My understanding is that the "legal" light kits are those that have applied for and received the FAA-blessed TSO that confirms they meet the requirements of 91.205(c), which basically references 23.1385 through 23.1401 where the specs are actually listed. They cost (much) more in order to compensate the manufacturer for the expense the manufacturer incurred getting that blessed FAA paperwork. These days the "non-legal" LED kits are typically just as bright and perform just as well (ie basically identical to the TSO version) they just don't come with the blessed paperwork attached. Your operating limitations will simply state that your plane must meet 91.205(c) to fly legally at night, and 91.205(c) states that the lights must meet the specifications in Part 23 et al. There is no absolute requirement in the regs for TSO lights, simply that they meet the specs. For certified this means TSO, for E-AB it just means they must meet the same specs. Except in rare instances Part 23 and TSO do not apply to E-AB.

However, I've heard that some DARs frown on non-TSO nav/strobe lights believing only TSO lights will meet the specs, and other DARs are perfectly happy with whatever reasonable lights you have. I've also heard rumors that some builders don't have the nav/strobe lights installed during the inspection so no such issues arise, and the builder (re-)installs his preferred choice after the inspector signs the plane off. Just about any LED light set bought these days will meet the specs and is plenty bright enough to do the job compared to, say, the TSO lights on the Cessna parked on the adjacent tie-down with its 50-year-old hazed lens covers. "Legal" and "safe" aren't mutually inclusive.

Also note that the Part 23 requirements include not just the candela rating of the lights, but also the required 'field of coverage' of each light. On certified airplanes the nav/strobe/pos lights have to be tested to TSO on the plane because the mounting of the lights impact the field of coverage. However, Part 23 doesn't apply to E-AB at all, so no one's going to be checking the specific mounting arrangement on your airplane for degree-spread, so the whole point of the TSO is again rather vague for E-AB. The issue started when certain foreign manufacturers began offering high-performance LED lights at significantly less cost than a certain domestic manufacturer's TSO lights, and the fur flew. Now the foreign manufacturers also have more costly TSO versions of their inexpensive light set that come with the blessed paperwork, and the domestic manufacturer has "non-legal" lights available at significantly less cost, so how you choose to meet 91.205(c) is really up to you, your DAR, and your wallet.

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Permalink Reply by Jim and Amelia Isaacs on September 20, 2021 at 5:40am

Good points Bob. Perhaps I could summarize as follows?

Part 91 are regs the aircraft operator must follow

Part 23  are regs the aircraft manufacturer must follow to obtain a type certificate for a normal category airplane

TSOs are the minimum performance standard a part manufacturer must meet in order for that part to be eligible to be used on a type certified aircraft. 

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Permalink Reply by Bob Johnson on September 20, 2021 at 10:57pm

Given IANAAL (I am not an aviation lawyer) that's my understanding as well.

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Permalink Reply by Mel Asberry on September 20, 2021 at 7:30am

The DAR has no say in the legality of lights.  The requirement is spelled out in the operating limitations.

"Night flight operations are authorized if the instruments specified in §91.205(c) are installed, operational, and maintained per the applicable requirements of part 91."

The owner/operator of the aircraft is responsible for the legality of the lights for night time operations.

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Permalink Reply by Bob Johnson on September 20, 2021 at 11:22pm

That's my understanding as well. However, in my research on the topic (because I ran into the same decision-making issues as the OP) I came across posts indicating that some DARs have a different (and IMO incorrect) take on it.

My eventual conclusion was that for E-AB the ultimate 'by the regs' solution is to install any lights you want (with the right colors in the right spots of course) and then measure the actual candela and field of coverage for your particular airplane and note the results in the aircraft logs, verifying compliance the E-AB way. A solution that works well enough until the aviation lawyers get involved is to install lights that spec the appropriate colors and candelas and verify by walking around that the coverage appears 'about right'. TSO is only required if you're buying the lights for a certified plane (along with a form 337 and etc etc). Like the OP, I believe if the TSO is the only difference between light sets than the manufacturers statement the OP quoted is inapplicable to E-AB and somewhat misleading, at least as I understand the regs. If anyone is aware of a different take by the FAA I'd love to hear about it.

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