Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Depends upon how the STC instructions are written.
Landing lights
- Thread starter Theboys
- Start date
Depends upon how the STC instructions are written.
PilotAlan
Pattern Altitude
- Joined
- Sep 26, 2009
- Messages
- 1,775
- Display Name
Display name:
PilotAlan
So, am I the only one here who thinks this is the height of government irrationality, that the basis of the PMA is identicality?
That a PMA is required to replace one part with an exactly identical part, from the same manufacturer, with the same part?
Is this a sign of our craziness, that we have to get approval from the FAA to replace a part with the same part?
The PMA'd lights come with an 8130-3 form. The 8130-3 is an airworthiness approval tag filled out by the DMIR at the facility where the light is built under PMA. This is what make the part airworthy. If the owner is replacing a bulb with one of our PMA'd lights, and is just installing the light and not adding wires for the pulse mode, it can be done by unscrewing the ring terminal connectors, unclamping the old bulb, installing the new LED bulb in the clamp, and screwing the screws in that hold the ring terminals. How anyone can considering this a major mod is beyond me (and the FAA as it turns out agrees as I have emails from ACO engineers to back this up). 
The pilot notes this change in his logbook and inserts the 8130-3 form that came with the light in the logbook to document the airworthiness of the part that was installed (in addition to the PMA tag that is on the light itself).
STC's are not strictly for major modifications. The STC for the installation of our pulse mode landing light covers things that are minor modifications; installing wires and switches are typically minor efforts for an A&P. Since the bulb mount is not changed, there are no structural mods at all, and structural and powerplant mods are typically where you run into major changes.
The reason for getting the STC is twofold. First, it provides a standing approval for the installation of the added wires and switches for the pulse function that has been reviewed by FAA engineers so that field approvals are not needed on an ongoing basis. It also documents the fact that the light was tested and found suitable for the intended purpose (see 14 CFR 23.1383 for landing light requirements). This provides the engineering data needed to obtain a PMA.
I don't intend to engage in a running argument with anyone on this board, just trying to share what I have learned from working through this issue with the FAA.
By the way, how many of you have heard that the FAA is seriously considering putting ALL light single engine airplanes under a certification system similar to the LSA category? I heard this from a reliable FAA source and it could be a very good thing for GA.
The pilot notes this change in his logbook and inserts the 8130-3 form that came with the light in the logbook to document the airworthiness of the part that was installed (in addition to the PMA tag that is on the light itself).STC's are not strictly for major modifications. The STC for the installation of our pulse mode landing light covers things that are minor modifications; installing wires and switches are typically minor efforts for an A&P. Since the bulb mount is not changed, there are no structural mods at all, and structural and powerplant mods are typically where you run into major changes.
The reason for getting the STC is twofold. First, it provides a standing approval for the installation of the added wires and switches for the pulse function that has been reviewed by FAA engineers so that field approvals are not needed on an ongoing basis. It also documents the fact that the light was tested and found suitable for the intended purpose (see 14 CFR 23.1383 for landing light requirements). This provides the engineering data needed to obtain a PMA.
I don't intend to engage in a running argument with anyone on this board, just trying to share what I have learned from working through this issue with the FAA.
By the way, how many of you have heard that the FAA is seriously considering putting ALL light single engine airplanes under a certification system similar to the LSA category? I heard this from a reliable FAA source and it could be a very good thing for GA.
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
What every one needs to know about 8130-3 tags
http://www.faa.gov/documentLibrary/media/Order/ND/Order 8130.21E.pdf
Pay attention to 201 Para (e)
e. If Form 8130-3 is issued as an airworthiness approval of a new product, part, or appliance (this is to include conformity inspections, prepositioning, and splitting of bulk shipments), the issuer should retain a copy of Form 8130-3 for no less than 5 years, unless the issuer’s quality manual stipulates a longer retention period.
http://www.faa.gov/documentLibrary/media/Order/ND/Order 8130.21E.pdf
Pay attention to 201 Para (e)
e. If Form 8130-3 is issued as an airworthiness approval of a new product, part, or appliance (this is to include conformity inspections, prepositioning, and splitting of bulk shipments), the issuer should retain a copy of Form 8130-3 for no less than 5 years, unless the issuer’s quality manual stipulates a longer retention period.
Last edited:
flyingcheesehead
Taxi to Parking
That would be huge! And awesome...
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
I have not heard any thing in that respect, but define light single aircraft.
Cessnas, Pipers, Mooneys, etc.
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Not really, we can deviate, with fit form and function rules and owner provided parts.
When dealing with owners doing maintenance under FAR 43-A who knows where they buy their parts? a NAPA GE bulb is a still a GE bulb.
Last edited:
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Another tidbit about manufacturing parts and products.
(6) Production approval means a document issued by the FAA to a person that allows the production of a product or article in accordance with its approved design and approved quality system, and can take the form of a production certificate, a PMA, or a TSO authorization;
(6) Production approval means a document issued by the FAA to a person that allows the production of a product or article in accordance with its approved design and approved quality system, and can take the form of a production certificate, a PMA, or a TSO authorization;
bnt83
Final Approach
The PMA'd lights come with an 8130-3 form. The 8130-3 is an airworthiness approval tag filled out by the DMIR at the facility where the light is built under PMA. This is what make the part airworthy. If the owner is replacing a bulb with one of our PMA'd lights, and is just installing the light and not adding wires for the pulse mode, it can be done by unscrewing the ring terminal connectors, unclamping the old bulb, installing the new LED bulb in the clamp, and screwing the screws in that hold the ring terminals. How anyone can considering this a major mod is beyond me (and the FAA as it turns out agrees as I have emails from ACO engineers to back this up).
STC's are not strictly for major modifications. The STC for the installation of our pulse mode landing light covers things that are minor modifications; installing wires and switches are typically minor efforts for an A&P. Since the bulb mount is not changed, there are no structural mods at all, and structural and powerplant mods are typically where you run into major changes.
The reason for getting the STC is twofold. First, it provides a standing approval for the installation of the added wires and switches for the pulse function that has been reviewed by FAA engineers so that field approvals are not needed on an ongoing basis. It also documents the fact that the light was tested and found suitable for the intended purpose (see 14 CFR 23.1383 for landing light requirements). This provides the engineering data needed to obtain a PMA.
I don't intend to engage in a running argument with anyone on this board, just trying to share what I have learned from working through this issue with the FAA.
By the way, how many of you have heard that the FAA is seriously considering putting ALL light single engine airplanes under a certification system similar to the LSA category? I heard this from a reliable FAA source and it could be a very good thing for GA.
If you have an ACO saying that an LED landing light swap is minor, then you should post that on your website. Many mechanics disagree with this position simply because an STC exists for other similar makes/models.
To be sure everyone knows, an 8130-3 DOES NOT definitively determine installation eligibility. Yes it says the part was manufactured to a certain standard and is airworthy but installation eligibly MUST be determined by the installer.
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
In his case, and the eyes of the FAA the 8130-3 is used as traceability of the part. as shown in my post above para 201- (e). It shows that the part was made well and with in its design. not that it is airworthy. the installer makes that decision.
Last edited:
Here is the exact quote from an email I received from one of the engineers at the Anchorage ACO as pertains to our STC:
1) LED Landing and Taxi Lights:
a) If the LED installation is a simple replacement with no alteration to the existing certified mounting hardware/wiring/switches, etc - PMA only is required.
b) If there is an alteration to the existing certified configuration, an STC may be required to cover the installation. (case by case basis)
Does this help clarify the point?
1) LED Landing and Taxi Lights:
a) If the LED installation is a simple replacement with no alteration to the existing certified mounting hardware/wiring/switches, etc - PMA only is required.
b) If there is an alteration to the existing certified configuration, an STC may be required to cover the installation. (case by case basis)
Does this help clarify the point?
bnt83
Final Approach
Right.
Mechanic makes the final airworthiness determination at installation...
Then the pilot makes another airworthiness determination at pre-flight...
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Show us a picture of what we are talking about.
FYI, I was told this comes from a draft of a new Advisory Circular that the Small Airplane Directorate is working on to cover LED aircraft lighting to help standardize policy across the FAA. I can't wait for it to come out because right now we are having to live with the 31 flavors of the FAA with all the FSDO's each giving unique interpretations. At least I have correspondence that I can send to our customers to aid them when they get push-back from their local FSDO. The FSDO can then call the ACO engineer and get the guidance directly. Most FSDO reps don't want to stick their necks out but if the ACO says its approved they will proceed. The ACO governs airworthiness and engineering, the MIDO governs manufacturing, and the FSDO governs the application of standards in the field. An AC gives all parties a common set of rules to work from.
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Your first example is a preventive maintenance procedure, the second is a major modification.
As an example here is a photo of a Sunspot 36 installed next to a GE4509 in a Husky A1-C. The LX version of our light has screw terminals on the back and drops right in place of the old bulb and connects to the same #6 ring terminals as the old bulb. With the PMA the GE4509 can be removed and replaced with the Sunspot 36LX.
bnt83
Final Approach
bnt83
Final Approach
So in order to get the PMA you needed the STC on an airplane, the STC wasn’t required to perform the alteration?
But you wanted to sell the part as PMA’ed and since the FAA would not PMA the part as a direct replacement for GE bulbs you were stuck the STC route?
Even though we have no eligibility documents to show it, these bulbs may be installed on like aircraft without an STC or Field Approval if the PMA’ed bulb is drop-in physical installation per your ACO contact?
But you wanted to sell the part as PMA’ed and since the FAA would not PMA the part as a direct replacement for GE bulbs you were stuck the STC route?
Even though we have no eligibility documents to show it, these bulbs may be installed on like aircraft without an STC or Field Approval if the PMA’ed bulb is drop-in physical installation per your ACO contact?
Skylane81E
Final Approach
Can you get the ACO to send you a letter?
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
As an example here is a photo of a Sunspot 36 installed next to a GE4509 in a Husky A1-C. The LX version of our light has screw terminals on the back and drops right in place of the old bulb and connects to the same #6 ring terminals as the old bulb. With the PMA the GE4509 can be removed and replaced with the Sunspot 36LX.
Minor modification and a preventive maintenance issue.
logo book entry to note the owner changed the bulb.
I would have no problem with this action at annual time.
bnt83
Final Approach
http://www.aerohilights.com/downloads/HIDAML4MAY2011.pdf
Perfect! Now you can explain to everyone that STC's for minor alterations EXIST!
I have seen STC's where it's a slide-out slide-in replacement for data loader, that changes no function, no placards, no instructions for continued airworthiness, no wiring changes, the weight is .7 pounds less, the electrical load decreased by .2 amps, not even used in flight, new unit is the SAME TSO as the removed unit.
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
Simple, some one thought it needed one.
bnt83
Final Approach
Tom-D
Taxi to Parking
- Joined
- Feb 23, 2005
- Messages
- 34,740
- Display Name
Display name:
Tom-D
I'll bet the production for that aircraft says " landing light" not what kind.
there is no modification of the structure, no change to the electrical system.
and it is not mentioned in far 43-A as a major modification, So it is up to the installer to decide when or if a 337 is required.
If it has an STC already approved and it is in the paper work received by the buyer, then I would go ahead and submit the 337 to enter the STC in the history records of the aircraft at OKC.
There really isn't a big problem here, it's just paper work.
there is no modification of the structure, no change to the electrical system.
and it is not mentioned in far 43-A as a major modification, So it is up to the installer to decide when or if a 337 is required.
If it has an STC already approved and it is in the paper work received by the buyer, then I would go ahead and submit the 337 to enter the STC in the history records of the aircraft at OKC.
There really isn't a big problem here, it's just paper work.
bnt83
Final Approach
Agreed.
I was trying to determin if installing an HID lighting system in a 1963 C205 as minor till I came across this wonderful work of art, which suggests STC required. I suppose a one time STC could be done or even shop for field approval but that seems like a lot of work I'm not going giving away for free.
http://www.faa.gov/about/office_org...300/media/Major_Repair_Alteration_Job-Aid.pdf
Last edited:
mswmsw
Pre-Flight
- Joined
- Jul 1, 2010
- Messages
- 87
- Display Name
Display name:
mswmsw
Although the many preceding pages containing the discussion of all the regulatory details was fascinating, I would like to renew the conversation specifically as it pertains to the type of landing light itself. I have a 1979 Cherokee Six and my old landing light just died. After reading some of the other comments from the first few pages of this thread, I wanted to solicit some additional input on the following topics:
1. My Cherokee Six has just a single lamp installation; would this technically be considered for landing or taxi purposes? In reality, it never mattered because the old light was virtually worthless for either purpose! ....... just threw out very little light. So I want to upgrade either to an HID or an LED, because I want something significantly brighter/stronger. What are the issues with the installation and placement of the ballast associated with the HID types? Are the HID's sufficiently brighter to justify the extra cost and complexity of the installation, and (presumably), the extra weight (approx how much?) of the ballast? Where would they "put" the ballast? Or is the simpler/cheaper LED "almost" as bright and more the "way to go"?
2. With only a single lamp, should I get the landing style with the more focused beam, or the taxi style with the more diffused beam? I am leaning towards the taxi light, since - as one other commenter mentioned - I think it is more critical for taxiing on dark ramps than for landing. Pros and cons?
Are they any other products folks are aware of that will throw a LOT of light out there, from the single lamp? I will be having my A&P do the install, so I am not worried about the issues surrounding a "do-it-myself job".
1. My Cherokee Six has just a single lamp installation; would this technically be considered for landing or taxi purposes? In reality, it never mattered because the old light was virtually worthless for either purpose! ....... just threw out very little light. So I want to upgrade either to an HID or an LED, because I want something significantly brighter/stronger. What are the issues with the installation and placement of the ballast associated with the HID types? Are the HID's sufficiently brighter to justify the extra cost and complexity of the installation, and (presumably), the extra weight (approx how much?) of the ballast? Where would they "put" the ballast? Or is the simpler/cheaper LED "almost" as bright and more the "way to go"?
2. With only a single lamp, should I get the landing style with the more focused beam, or the taxi style with the more diffused beam? I am leaning towards the taxi light, since - as one other commenter mentioned - I think it is more critical for taxiing on dark ramps than for landing. Pros and cons?
Are they any other products folks are aware of that will throw a LOT of light out there, from the single lamp? I will be having my A&P do the install, so I am not worried about the issues surrounding a "do-it-myself job".
flyingcheesehead
Taxi to Parking
We've been very happy with the Whelen Parmetheus LED lights. I'd suggest you go with a landing light for a single-light install - If you look at the pictures they have in the link above, you'll see that the landing version does throw some additional light out to the sides. The taxi light will be worthless as a landing light, the landing light is OK as a taxi light.
The HID's are brighter than the LED's, but they're also an order of magnitude more expensive to purchase and install.
bnt83
Final Approach
#1 the weight difference between LED & HID will be around a pound.
#2 HID's are top performers
#3 They would locate the ballast near the light, in the cowl.
#4 I don't know of any duel taxi/landing HID type lights. Does the PA32 have one switch? Are there two switches? Is the bulb diffused?
#5 http://xevision.com/hid_337.html has many field approvals listed for their products. Even Embry Riddle installed them fleet wide on PA-44's. There are some basic install instructions showing ballast installation on thier site also.
Purchase price of the HID will be 2x an LED. Installation is still pretty simple.
Other options for you is RMD wingtips with landing lights, altho even MORE $$$ http://www.rmdaircraft.com/piper.htm
LoPresti Boom Beams are an STC source for HID, but I think it's closer to 3x or 4x the LED price http://www.loprestiaviation.com/boom_beam/boom_beam_AML.htm#Piper
Last edited:
EdFred
Taxi to Parking
I just dropped two of those (both of them the landing version) off at the mx hangar this morning.
flyingcheesehead
Taxi to Parking
Nice. That'll be a good setup in the Comanche. If I had a Twink, I'd put the landing ones in the wingtips and maybe add a taxi one to the nosewheel if that's still doable.
EdFred
Taxi to Parking
You would need to add a switch somewhere in the panel to do that. I have individual toggle switches for each landing light.
mswmsw
Pre-Flight
- Joined
- Jul 1, 2010
- Messages
- 87
- Display Name
Display name:
mswmsw
Only one switch, one light. Not sure if the current (inop) light is "diffused" or not. So my decision at this point is: do I get a landing light (with a "tight" beam), or taxi light, with the more diffused beam? Frankly, I don't really feel like I need the light very much for landing; but often times, when taxiing in dimly lit (or no light) areas, I'd really like some bright light out in front of me. Your thoughts?
bnt83
Final Approach
I can relate. I often feel the landing lights aren't all that useful and the taxi lights could be improved. It looks like the light in your bird is not the diffused type. I'm not familiar with this airplane so hopefully some else can help.
I installed a whelen diffused one onto a friends cessna 172 (wing mount) and didn't see much difference in actual visibility. The color temperature much different but not really the visibility.
I'm hoping piper experts have first hand experience for you.
PilotAlan
Pattern Altitude
- Joined
- Sep 26, 2009
- Messages
- 1,775
- Display Name
Display name:
PilotAlan
I have a single landing-light config LED (Whelen Parmethus) in my cowl. There is significantly more side light that the old GE, I am much happier taxiing than with the old bulb.
And there's more light during landing also, definitely improved.
bnt83
Final Approach
Is the mount aim fixed or adjustable on piper?
el con
Line Up and Wait
Late in the posts but,
I have a Cherokee 180 that I put all leds on ( not interior lights)
1. Whelen Led tail beacon-$680- got rid of the old rotating one which got rid of that annoying grinding sound over the radios,( I now have a fricking red laser beam on my tail
.
2. replaced all position lights($60 for all three if I remember correctly) with the replacement led bulbs,red, green and white position on tail.
3. Whelen Led landing light. $239-More light less draw, it will probably last longer than I will live. More of a bright blueish light than the the soft fuzzy yellow glow of the old GE4509
Only problem they draw so little , I used to check ammeter by flipping landing light switch on and then off to check list spec. Needle now does not move draw is so low.
Very happy with all the changes/ improvements
I have a Cherokee 180 that I put all leds on ( not interior lights)
1. Whelen Led tail beacon-$680- got rid of the old rotating one which got rid of that annoying grinding sound over the radios,( I now have a fricking red laser beam on my tail
.2. replaced all position lights($60 for all three if I remember correctly) with the replacement led bulbs,red, green and white position on tail.
3. Whelen Led landing light. $239-More light less draw, it will probably last longer than I will live. More of a bright blueish light than the the soft fuzzy yellow glow of the old GE4509
Only problem they draw so little , I used to check ammeter by flipping landing light switch on and then off to check list spec. Needle now does not move draw is so low.
Very happy with all the changes/ improvements
PilotAlan
Pattern Altitude
- Joined
- Sep 26, 2009
- Messages
- 1,775
- Display Name
Display name:
PilotAlan
Fixed.
Where'd you get the LED bulbs for the position lights?
I now use the pitot heat to check the ammeter, the landing light doesn't do it.
bnt83
Final Approach
mswmsw
Pre-Flight
- Joined
- Jul 1, 2010
- Messages
- 87
- Display Name
Display name:
mswmsw
Seems like the consensus is that the LED light - like the Whelen Parmetheus - is only a little brighter/stronger than the old halogen lights, though they last longer and have significantly less draw. I want a LOT more light, so I am wondering if the HID light is the way to go, even if it costs me a bit more. Has anyone here done a single light install of a LoPresti BoomBeam? Does that one throw a "lot" more light out? I want something where when you turn it on when taxiing at night, you will say "Wow, that is a LOT brighter than what I had before!"