Landing lights

Skylane81E said:
For the same reason the fresh pick is, it is spelled out in FAR.

The FAA has taken a very strict stance on what the term "basic design" means. They consider the guts of the lamp part of the electrical system and have decided that an incandescent bulb and a bank of multiple diodes are not basically of the same design.

Were I king it would be a minor alteration that could be installed by any airframe mechanic, but I'm not king. While I may not like it, and don't feel that in this case requiring an STC is in the best interests of safety, legally they aren't wrong to do so.

Come up with a petition to reclassify PMAed LED lights as a minor alteration (the same way they just dropped GPS updates from the list of preventative maintenance items) and you will have my signature.

For now though we have to play by the rules in place.
Click to expand...
Very well said. And with that said, I cannot follow this one anymore. I am in the camp, that STC requires 337, obviously some do not. I personally don't care. I also personally don't agree that it should be like that, but I am not king either. Until then I will live in the world I am surrounded by. Get your petition, and I will sign it also. Signing out!
 
flyingmoose said:
Very well said. And with that said, I cannot follow this one anymore. I am in the camp, that STC requires 337, obviously some do not. I personally don't care. I also personally don't agree that it should be like that, but I am not king either. Until then I will live in the world I am surrounded by. Get your petition, and I will sign it also. Signing out!
Click to expand...


Hold the door! anything beyond what I have posted is an argument on "basic design" and the precedent has already been set.
 
Skylane81E said:
Save you some time,

14CFR43 maintenance
appendix A major alterations, major repairs and preventative maintenance
(a) major alterations
(1) airframe major alterations
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.
Click to expand...


What changes the basic design? We can install an intercom and not need an STC or a field approval. The voltage is the same. The capacity is the same, battery, master, wiring, protected devices, generators, cables, switches, even the glare requirement is good from seeing it in person.

ELECTRICAL SYSTEMS AND EQUIPMENT
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.681 Installation. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman](a) Electrical systems in airplanes shall be free from hazards in themselves, in their method of operation, and in [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]their effects on other parts of the airplane. Electrical equipment shall be of a type and design adequate for the use intended. Electrical systems shall be installed in such a manner that they are suitably protected from fuel, oil, water, other detrimental substances, and mechanical damage. [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman](b) Items of electrical equipment required for a specific type of operation are listed in other pertinent parts of the Civil Air Regulations. [/FONT]
[/FONT]BATTERIES
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.682 Batteries. When an item of electrical equipment which is essential to the safe operation of the airplane is installed, the battery required shall have sufficient capacity to supply the electrical power necessary for dependable operation of the connected electrical equipment. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.683 Protection against acid. If batteries are of such a type that corrosive substance may escape during servicing or flight, means such as a completely enclosed compartment shall be provided to prevent such substances from coming in contact with other parts of the airplane which are essential to safe operation. Batteries shall be accessible for servicing and inspection on the ground. [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.684 Battery vents. The battery container or compartment shall be vented in such manner that gases released by the battery are carried outside the airplane. [/FONT]
[/FONT]GENERATORS
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.685 Generator. Generators shall be capable of delivering their continuous rated power. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.686 Generator controls. Generator voltage control equipment shall be capable of dependably regulating the generator output within rated limits. [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.687 Reverse current cut-out. A generator reverse current cut-out shall disconnect the generator from the battery and other generators when the generator is developing a voltage of such value that current sufficient to cause malfunctioning can flow into the generator. [/FONT]
[/FONT]MASTER SWITCH
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.688 Arrangement. If electrical equipment is installed, a master switch arrangement shall be provided which will [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]disconnect all sources of electrical power from the main distribution system at a point adjacent to the power sources. [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.689 Master switch installation. The master switch or its controls shall be so installed that it is easily discernible and accessible to a member of the crew in flight. My Cessna 150B arguably doesn't satisfy this one, Its the same knob and color as all the other switches![/FONT]
[/FONT]PROTECTIVE DEVICES
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.690 Fuses or circuit breakers. If electrical equipment is installed, protective devices (fuses or circuit breakers) shall be installed in the circuits to all electrical equipment, except that such items need not be installed in the main circuits of starter motors or in other circuits where no hazard is presented by their omission. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.691 Protective devices installation. Protective devices in circuits essential to safety in flight shall be so located and identified that fuses may be replaced or circuit breakers reset readily in flight. [/FONT]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.692 Square fuses. If fuses are used, one spare of each rating or 50 percent spare fuses of each rating, whichever is greater, shall be provided. [/FONT]
[/FONT]ELECTRIC CABLES
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.693 Electric cables. If electrical equipment is installed, the connecting cables used shall be in accordance with recognized standards for electric cable of a slow burning type and of suitable capacity. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[/FONT]SWITCHES
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.694 Switches. Switches shall be capable of carrying their rated current and shall be of such construction that there is sufficient distance or insulating material between current carrying parts and the housing so that vibration in flight will not cause shorting. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]
[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.695 Switch installation. Switches shall be so installed as to be readily accessible to the appropriate crew member and shall be suitably labeled as to operation and the circuit controlled. [/FONT]
[/FONT]LANDING LIGHTS
[FONT=NFKPBI+TimesNewRoman,Times New Roman][FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.698 Landing lights. If landing lights are installed, they shall be of an acceptable type. [/FONT][/FONT][FONT=NFKPBI+TimesNewRoman,Times New Roman]​

[FONT=NFKPBI+TimesNewRoman,Times New Roman]§ 3.699 Landing light installation. Landing lights shall be so installed that there is no dangerous glare visible to the pilot and also so that the pilot is not seriously affected by halation. They shall be installed at such a location that they provide adequate illumination for night landing. [/FONT]


[FONT=NFKPBI+TimesNewRoman,Times New Roman]At any rate, this topic is getting old don't you think? :lol:[/FONT]


Have a great day guys. It's colder than an Eskimo’s nose in the arctic here and supposed to DUMP white death on us tonight. :sad:
[/FONT]
 
Last edited:
I read one page of all of this and stopped before I started yelling, "It's a ******ned light bulb, people...!" at my monitor and shook my head and know now exactly why Aviation is tanking. Who the hell wants a hobby where it takes four pages of arguments and discussion between even PROFESSIONALS to determine if one can change a flipping light bulb? Only us completely insane people even bother.
 
RotorAndWing said:
Well, it has to do with Privacy Act and a few other things. Some of the additional information available on FSIMS to the Inspectors are not public domain documents.

At least the FAA has made the majority of FSIMS available to the public.
Click to expand...

At least. Considering the public paid for it.
 
denverpilot said:
I read one page of all of this and stopped before I started yelling, "It's a ******ned light bulb, people...!" at my monitor and shook my head and know now exactly why Aviation is tanking. Who the hell wants a hobby where it takes four pages of arguments and discussion between even PROFESSIONALS to determine if one can change a flipping light bulb? Only us completely insane people even bother.
Click to expand...

It's not that simple, especially position lights.
 
denverpilot said:
I read one page of all of this and stopped before I started yelling, "It's a ******ned light bulb, people...!" at my monitor and shook my head and know now exactly why Aviation is tanking. Who the hell wants a hobby where it takes four pages of arguments and discussion between even PROFESSIONALS to determine if one can change a flipping light bulb? Only us completely insane people even bother.
Click to expand...

Agreed 100%
 
Its just a light bulb. So we go to a Cessna 172S and yank the halogen bulbs from the nav lights and replace with an automotive LED one off ebay, its a minor alteration right?

---Evaluation

The nav light assembly itself maybe TSO’ed and the halogen bulb (consider the reflective coated ones on the back of the bulb) is part of that TSO assembly drawing. This alone tells me its not a minor mod, but for the sake of explaining in more detail I will go on. Then we go look at type certificate data sheet No. 3A12 and scroll down to the certification basis of the 172S, and in it we find that the airplane was certificated to 14 CFR 23 effective 02/01/1965 as amended by 23-1 through 23-6... and 23.1385 as amended by 23-43. So crack open your dusty FAR/AIM and start looking through part 23 regulations the Cessna 172S had to meet. We find that the Cessna 172S complied with § 23.1385 Position light system installation as amended by 23-43 which states:
Sec. 23.1385
Position light system installation.
(a) General. Each part of each position light system must meet the applicable requirements of this section and each system as a whole must meet the requirements of Secs. 23.1387 through 23.1397.
[(b) Left and right position lights. Left and right position lights must consist of a red and a green light spaced laterally as far apart as practicable and installed on the airplane such that, with the airplane in the normal flying position, the red light is on the left side and the green light is on the right side.
(c) Rear position light. The rear position light must be a white light mounted as far aft as practicable on the tail or on each wing tip.
(d) Light covers and color filters. Each light cover or color filter must be at least flame resistant and may not change color or shape or lose any appreciable light transmission during normal use.]
Now we also need to look at 23.1387 through 23.1397! 23.1387 position light dihedral angles, 23.1389 position light distribution and intensities, 23.1391 minimum intensities in the horizontal plane of position lights, 23.1393 minimum intensities in any vertical plane of position lights, 23.1395 maximum intensities of overlapping beams of position lights, 23.1397 color specifications.

Are you sure this swap complies with all the listed above regulations? Does it comply with the TSO specs if the assembly is TSO’ed? IF SO, Next go to part 43 appendix A.
Sec. A43.1
Appendix A
(a) Major alterations--
(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:
(i) Wings.
(ii) Tail surfaces.
(iii) Fuselage.
(iv) Engine mounts.
(v) Control system.
(vi) Landing gear.
(vii) Hull or floats.
(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.
(ix) Hydraulic and electrical actuating system of components.
(x) Rotor blades.
(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft.
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.
(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.

Does the mod change the basic design of the electrical system? Now we end up going to see what the airplane was certified to regarding the electrical system and check if the swap affects any regulation. If NOT you at least have a leg to stand on to say the change to electrical system is minor, but it may not be. This is typically whern we start combing advisory circulars or asking the aircraft certification office (ACO) for clarity. That DAY you ask, they may say its minor and NEXT week say major, JUST FOR THE ELECTRICAL PORTION WE ASKED FOR CLARITY ON and it may differ between districts.
 
Last edited:
For what it's worth, I talked to a couple of people from the Milwaukee FSDO at the EAA/Oshkosh show this past summer about installing a Whelen LED landing light on my Cessna 172N. They said that they had no problem with it, and in fact think it's a good idea for people to replace their incandescent lights with LED or HID.
They assured me that since Whelen had a PMA that listed the C172N I did not need to involve an A&P, IA, STC, or 337, and that I could do it myself as long as I logged it.
I installed a PAR46 Parmetheus and I could not be more pleased. It illuminates the whole area of the end of the runway and some surrounding area on short final like a bright full moon, instead of the single bright dot on the runway with dark all around that the old 250 watt incandescent bulb we had did. It makes judging the flare easier, and after landing it lights up a wider area of the taxiway making finding my way around the airport easier and safer.
I had hesitated to spend that much money on the LED light but it's been well worth it. The other nice thing is that I now fly with the light on all the time for collision avoidance. Our old incandescent bulb had a mean time between failures of just a few hours so I only turned it on when I absolutely needed it.
 
denverpilot said:
I read one page of all of this and stopped before I started yelling, "It's a ******ned light bulb, people...!" at my monitor and shook my head and know now exactly why Aviation is tanking. Who the hell wants a hobby where it takes four pages of arguments and discussion between even PROFESSIONALS to determine if one can change a flipping light bulb? Only us completely insane people even bother.
Click to expand...

To find a hobby more regulated that aviation, you would have to recreationally build nuclear reactors in your basement.
 
avnav526 said:
For what it's worth, I talked to a couple of people from the Milwaukee FSDO at the EAA/Oshkosh show this past summer about installing a Whelen LED landing light on my Cessna 172N. They said that they had no problem with it, and in fact think it's a good idea for people to replace their incandescent lights with LED or HID.
They assured me that since Whelen had a PMA that listed the C172N I did not need to involve an A&P, IA, STC, or 337, and that I could do it myself as long as I logged it.
I installed a PAR46 Parmetheus and I could not be more pleased. It illuminates the whole area of the end of the runway and some surrounding area on short final like a bright full moon, instead of the single bright dot on the runway with dark all around that the old 250 watt incandescent bulb we had did. It makes judging the flare easier, and after landing it lights up a wider area of the taxiway making finding my way around the airport easier and safer.
I had hesitated to spend that much money on the LED light but it's been well worth it. The other nice thing is that I now fly with the light on all the time for collision avoidance. Our old incandescent bulb had a mean time between failures of just a few hours so I only turned it on when I absolutely needed it.
Click to expand...

One of the problems that was debated here is that the Whelen LED light IS NOT PMA'ed to replace the GE bulb or a Cessna part #. It IS PMA'ed to replace itself. The authorization to install the light, as shown on the PMA, comes from an Floats Alaska STC.

http://www.aerohilights.com/downloads/HIDAML4MAY2011.pdf

http://www.whelen.com/_AVIATION/pmasupplements/pmasup38.pdf
 
RotorAndWing said:
:rofl::rofl::rofl:
Click to expand...

What's so funny?

I just realized that they did make it possible to remove your address from public view, only... but you have to write a letter requesting it. Unlike every other service on the website. FAA plays the "opt-out is hard" game, similar to online spammers. The data sharing should be opt-in, not the other way around.

FAA v. Cooper being one example of illegal activity under the Privacy Act... the Ninth Circuit flip-flopped like a dying fish back and forth and the guy lost the final roll of the dice by FAA, DOT, and SSA lawyers, via a technicality that he couldn't prove specific monetary damages.

The important point to note is that none of the higher courts overturned the portion of the decision that FAA, DOT, and SSA acted illegally under the Privacy Act.

Basically the court gave a green light to continued database cross-Agency mining -- at least until someone proves monetary damages from such behavior. It takes a lot of money and effort to build database merge software and mine for stuff, and while yes, it can be used for "good", it can also be used for "evil". The Privacy Act's intent was to stop such inter-Agency sharing without a Citizen's knowledge it would happen. Didn't work. Judges said, "mine all you want, but if you screw up and damage someone, then the Court will enforce the Law."

Similarly, Martha King was held at gunpoint via database mining, between Federal and Local Agencies. (Mainly by a group out of New Mexico where various Law Enforcement agencies share data in a large data warehouse system based there.) Most pro-privacy groups agree the joint database is probably illegal in numerous ways under the Privacy Act, also. Since those are LE databases, the legal waters are more murky.

There's lots more where those came from. Those are just ones folks here would remember.

Personally, I'm not one to hide from public databases... they've been so prevalent my whole life, it takes five minutes and $20 to find out damn near everything about anyone. And if they're trying to hide, maybe $500 and a month.

Doesn't make the actions any less illegal or in the case of opt-out, immoral, though. We don't warn folks when they join the aviation ranks that their personal information will be searchable on a Federal website -- for at least the window of time it takes between getting a medical and student certificate and when someone processes their request letter. I doubt there's a good "pre-opt-out" method.
 
Trying to push this thread back on track... Probably futile, but...

Ted DuPuis said:
We did Whelen Parametheus LEDs. Brighter, look nicer, and should last about forever. I'd recommend them. Price is cheap for aviation items.
Click to expand...

This. We put three of the Parmetheus lights in, to replace the Archer's landing light and both the taxi and landing lights on the 182.

Sadly, I haven't flown either one since the replacement 'cuz I've had the Mooney (which is very well-lit!) but I do have some before-after pictures in our large hangar...

Before, looking at the plane. Notice the amount of light that's worthlessly illuminating the airplane, and the floor right around the airplane:

attachment.php


After - You can tell that it looks brighter and puts its light out front where it's needed:

attachment.php


Before, pilot's perspective:

attachment.php


And, after... While it seems a bit less focused, there's a lot more light overall:

attachment.php


The biggest difference, of course, is that we won't have to endure things looking like they do all too often with the old GE 4509's:

attachment.php


:rofl:
 

Attachments

  • IMG_2957.jpg
    IMG_2957.jpg
    271.1 KB · Views: 78
  • IMG_2958.jpg
    IMG_2958.jpg
    192.1 KB · Views: 78
  • IMG_2963.jpg
    IMG_2963.jpg
    235.3 KB · Views: 77
  • IMG_2967.jpg
    IMG_2967.jpg
    298.6 KB · Views: 77
  • black-1.2.jpg
    black-1.2.jpg
    69.6 KB · Views: 76
flyingcheesehead said:
Before, pilot's perspective:

attachment.php


And, after... While it seems a bit less focused, there's a lot more light overall:

attachment.php


The biggest difference, of course, is that we won't have to endure things looking like they do all too often with the old GE 4509's:
Click to expand...
In general it's more difficult to focus the light from today's LED landing lamps because of the multiple sources inside one lamp. The manufacturers try to mitigate this by molding individual lenses for each LED into the exterior surface but that means the lenses are smaller and therefore less effective plus you get unwanted dispersion of the light from one LED that goes through other areas of the lens besides the one right in front of it. Some day they will be able to get enough light from a single LED and use a parabolic reflector to focus the light. When that happens the light will have a better pattern.
 
Just to weigh in on this discussion:

I am the CTO of AeroLEDs. Our Sunspot 36 LED light have an STC via Northern Aviation in Anchorage. From this STC, we were able to get a PMA.

The STC and PMA have recently been updated to include the LX (non pulsing) version in addition to the HX (pulsing) version in both flavors, landing and taxi.

While it is true that the PMA supplement lists the light as a replacement from itself, I was instructed by the Anchorage ACO engineers that the LX version with a PMA can be installed in any part 23 airplane that it fits in since it has a PMA approval.

The PMA means that the part is air-worthy, and it comes with an FAA 8130-3 form filled out by a DMIR to document that fact.

Since the Sunspot 36LX does not require any structural or electrical modifications to install (it fits the existing mount, doesn't weigh more, and draws less current so it can use the same wires and breakers, and has screw terminals that accept the ring terminals just like a glass bulb), it can be installed by the airplane owner with a log book entry.

Only if you wish to install the pulse function by hooking up the additional wires on the HX version do you need the STC or a 337 (minor mod 337 as it is just switches and wires). The existance of the STC for the Cessna 185 models makes it easier to get a 337 since the FSDO has a reference point for their basis of approval (per a discussion with an A&P FSDO representative at the Boise FSDO).

Dean Wilkinson
CTO, AeroLEDs LLC
 
IdaFlyer said:
Just to weigh in on this discussion:

I am the CTO of AeroLEDs. Our Sunspot 36 LED light have an STC via Northern Aviation in Anchorage. From this STC, we were able to get a PMA.

The STC and PMA have recently been updated to include the LX (non pulsing) version in addition to the HX (pulsing) version in both flavors, landing and taxi.

While it is true that the PMA supplement lists the light as a replacement from itself, I was instructed by the Anchorage ACO engineers that the LX version with a PMA can be installed in any part 23 airplane that it fits in since it has a PMA approval.

The PMA means that the part is air-worthy, and it comes with an FAA 8130-3 form filled out by a DMIR to document that fact.

Since the Sunspot 36LX does not require any structural or electrical modifications to install (it fits the existing mount, doesn't weigh more, and draws less current so it can use the same wires and breakers, and has screw terminals that accept the ring terminals just like a glass bulb), it can be installed by the airplane owner with a log book entry.

Only if you wish to install the pulse function by hooking up the additional wires on the HX version do you need the STC or a 337 (minor mod 337 as it is just switches and wires). The existance of the STC for the Cessna 185 models makes it easier to get a 337 since the FSDO has a reference point for their basis of approval (per a discussion with an A&P FSDO representative at the Boise FSDO).

Dean Wilkinson
CTO, AeroLEDs LLC
Click to expand...

Document # 0003-0004 Rev: C and 0010-0004 Rev: C

12. Fill out and submit appropriate form 337 for work accomplished
(unless installed under STC), and enter appropriate logbook entry
detailing work.

Step 12 is saying 337 form is not required for STC'ed installations, mistake?


With all due respect, I'm not sure the person who wrote this understands the function of FAA form 337.
 
Last edited:
If you were to manufacture an LED replacement bulb that was to cover ALL installation that have a GE 4509 etc etc, why wouldn't your PMA say that?

In the eligibility column on the PMA list GE part #s it's a direct replacement for?
 
Obtaining a PMA as a direct replacement for the GE4509 by identicality proved to be an excercise in futility with the FAA. With the technical differences between LEDs and incandescent bulbs, we spent a lot of time chasing our tail with the ACO by trying to go down that path. I suspect that Whelen had the same problem, as they wound up going the same route we did.

An alternate path to a PMA is an STC or to be listed on an OEM's TC. This proved to be the simplest way to get the PMA...

bnt83 said:
If you were to manufacture an LED replacement bulb that was to cover ALL installation that have a GE 4509 etc etc, why wouldn't your PMA say that?

In the eligibility column on the PMA list GE part #s it's a direct replacement for?
Click to expand...
 
IdaFlyer said:
Obtaining a PMA as a direct replacement for the GE4509 by identicality proved to be an excercise in futility with the FAA. With the technical differences between LEDs and incandescent bulbs, we spent a lot of time chasing our tail with the ACO by trying to go down that path. I suspect that Whelen had the same problem, as they wound up going the same route we did.

An alternate path to a PMA is an STC or to be listed on an OEM's TC. This proved to be the simplest way to get the PMA...
Click to expand...


Which essentially proves the original point made a while back by the other A&P IA's, meaning its only a PMA'ed part for the aircraft that have been modified by the STC, not every Part 23 & CAR 3 airplane built. That's why the FAA wouldn't go the direct replacement by identicality for the GE parts, to limit it to aircraft WHICH compliance with the regulations has been shown, via the STC.

Which leaves the mechanic getting a field approval or signing it off as a minor alteration, hence the owner cannot perform the swap.
 
Last edited:
IdaFlyer said:
Since the Sunspot 36LX does not require any structural or electrical modifications to install (it fits the existing mount, doesn't weigh more, and draws less current so it can use the same wires and breakers, and has screw terminals that accept the ring terminals just like a glass bulb), it can be installed by the airplane owner with a log book entry.
Click to expand...

I'm assuming you mean installed under the STC. Which contradicts other A&P IA's positions. They say due to the STC, its an "automatic" major alteration requiring an A&P IA to execute an FAA form 337.

I am unaware of any regulation that states installing an STC is automatically a major alteration, nor any regulation the that states an owner can install an STC if it's just a lightbulb swap, as preventative maintenance.
 
bnt83 said:
I'm assuming you mean installed under the STC. Which contradicts other A&P IA's positions. They say due to the STC, its an "automatic" major alteration requiring an A&P IA to execute an FAA form 337.

I am unaware of any regulation that states installing an STC is automatically a major alteration, nor any regulation the that states an owner can install an STC if it's just a lightbulb swap, as preventative maintenance.
Click to expand...

A very simple question.. How is a STC applied to an N number at OKC?

1 we send them a note to add the equipment?
2 we send them an e-mail
3 we send them a 337 with block 8 saying we have modified the aircraft in accordance with the STC instructions.and showing in block 7 that it has been returned to service by an A&P-IA.
4 we tell FSDO that we modified the aircraft with out any authorization.
 
bnt83 said:
I
I am unaware of any regulation that states installing an STC is automatically a major alteration, nor any regulation the that states an owner can install an STC if it's just a lightbulb swap, as preventative maintenance.
Click to expand...

An STC is a Supplement to the Type Certificate, if that isn't a major I don't know what is.

Owners can apply the STC if doing so is with in the scope of preventive maintenance, they would then fill out the 337 just like another person and take it to a A&P-IA to return to service.
 
Tom-D said:
An STC is a Supplement to the Type Certificate, if that isn't a major I don't know what is.

Owners can apply the STC if doing so is with in the scope of preventive maintenance, they would then fill out the 337 just like another person and take it to a A&P-IA to return to service.
Click to expand...


Tom, did you miss where he says "it can be installed by the airplane owner with a log book entry."?
 
bnt83 said:
Tom, did you miss where he says "it can be installed by the airplane owner with a log book entry."?
Click to expand...

No I didn't miss that, My take on it is that if the STC has been properly applied to the airframe, the pilot can change the bulb/Diode.
 
IdaFlyer said:
The PMA means that the part is air-worthy, and it comes with an FAA 8130-3 form filled out by a DMIR to document that fact.
Click to expand...

I beg the differ. PMA does not mean the part is airworthy. PMA means you have authority to manufacturer the part.

If your product has been run over by a truck after it leaves your facility, is it still airworthy simply because it you have PMA?
 
Tom-D said:
No I didn't miss that, My take on it is that if the STC has been properly applied to the airframe, the pilot can change the bulb/Diode.
Click to expand...


No he can't because WHO returns it to service?

"Owners can apply the STC if doing so is with in the scope of preventive maintenance, they would then fill out the 337 just like another person and take it to a A&P-IA to return to service. "


Oh sure I can do all kinds of undocumented maintenance then pay my A&P to document it... The owner cannot install the STC snd return the aircraft to service. It's not preventative maintenance.
 
Last edited:
bnt83 said:
No he can't because WHO returns it to service?

"Owners can apply the STC if doing so is with in the scope of preventive maintenance, they would then fill out the 337 just like another person and take it to a A&P-IA to return to service. "
Click to expand...

any one can fill out a 337.

it is returned to service by the signature in block 7

I did not insinuate he could return the STC to service.
 
Last edited:
Tom-D said:
Did you miss where I said "when the STC has been properly applied"

Changing light bulbs is a preventive maintenance item.
Click to expand...


You said "after". No argument about after the STC was installed...
 
Last edited:
If I replace one of my three landing lights with an LED style and the proper per work is filed do I need to file for the other two when i change them or just do it?
 
tmyers said:
If I replace one of my three landing lights with an LED style and the proper per work is filed do I need to file for the other two when i change them or just do it?
Click to expand...

Installing an STC then installing more components under a previously installed STC... :goofy:

We run into this when a previously installed STC has optional equippment and later they want the optional stuff. SOP here is to issue a 337 for the work performed.
 
tmyers said:
If I replace one of my three landing lights with an LED style and the proper per work is filed do I need to file for the other two when i change them or just do it?
Click to expand...

Depends on how you word the 337, if it says "replaced cowling landing light" then yes you would need to for the tips as well
 
You must log in or register to reply here.
Back
Top