Night equipment

NealRomeoGolf

NealRomeoGolf

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Forgive my ignorance. I have a strobe light that is acting up. I know it doesn't matter for VFR day. I was reviewing VFR night requirements and get here:

(3) An approved aviation red or aviation white anticollision light system on all U.S.-registered civil aircraft. Anticollision light systems initially installed after August 11, 1971, on aircraft for which a type certificate was issued or applied for before August 11, 1971, must at least meet the anticollision light standards of part 23, 25, 27, or 29 of this chapter, as applicable, that were in effect on August 10, 1971, except that the color may be either aviation red or aviation white. In the event of failure of any light of the anticollision light system, operations with the aircraft may be continued to a stop where repairs or replacement can be made.

So does this mean that if I have a red tail beacon but my strobes are inop I am still legal? I can either count the beacon as meeting this requirement or the wing strobes?

My last plane didn't have a beacon so never thought of this.
 
If it is installed as part of the anti-collision system, it must be operational for the aircraft to be airworthy. regardless of whether or not you use them.
 
Here are a couple of LOIs I had to keep close at hand when an employer insisted that I would be "perfectly legal" flying with an INOP strobe.
 

Attachments

  • Nav Lights Letter of Interpretation I.pdf
    502.6 KB · Views: 34
  • Nav Lights Letter of Interpretation II.pdf
    66.1 KB · Views: 16
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NealRomeoGolf said:
Thanks!
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It is steeped in legaleze and a lot of "howevers" and so forth, but in short the first one says that although your aircraft may not be required to have an anti-collision system (based on when it was certified), if it does have an anti-collision system, it must be operational, except "if the pilot-in-command determines that it would be in the interest of safety to tum the lights off."
 
smv said:
It is steeped in legaleze and a lot of "howevers" and so forth, but in short the first one says that although your aircraft may not be required to have an anti-collision system (based on when it was certified), if it does have an anti-collision system, it must be operational, except "if the pilot-in-command determines that it would be in the interest of safety to tum the lights off."
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Well I guess until I can troubleshoot my power supply I have 2/3s of a system. :oops:
 
NealRomeoGolf said:
Well I guess until I can troubleshoot my power supply I have 2/3s of a system. :oops:
Click to expand...

Just went through this again couple days ago. Picked up an airplane from an extensive maintenance period and the beacon was INOP. "It is okay", said they, "The strobe still works..."

Nope. Fix it.
 
NealRomeoGolf said:
So does this mean that if I have a red tail beacon but my strobes are inop I am still legal?
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FYI: you can also apply for a waiver to run just the beacon from your local FSDO or in some cases you can remove the strobe system under 91.213(d)(3)(i) depending on the manner in which the strobe system was installed.
 
What aircraft is being discussed?
 
And which light is inop? The tail beacon light or a wingtip/tail flashing strobe light?

Are the strobes part of the required lighting system or supplemental? Does your equipment list show the strobes as being required or an option?
 
JAWS said:
Are the strobes part of the required lighting system or supplemental? Does your equipment list show the strobes as being required or an option?
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FYI: after the Letts LOI came out (Post 3 above) it didn't define the difference between strobes or beacons or their installation history. Instead the feds opined if it's part of the anti-collision lights "system" it collectively has to work per 91.205(c). :rolleyes:
 
Bell206 said:
FYI: after the Letts LOI came out (Post 3 above) it didn't define the difference between strobes or beacons or their installation history. Instead the feds opined if it's part of the anti-collision lights "system" it collectively has to work per 91.205(c). :rolleyes:
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Hence my question of how they are listed in the equipment list. If they are supplemental or optional, the strobes do not have to work. Same with the beacon light. Some aircraft have no beacon light, just strobes. Some just have a beacon.
 
JAWS said:
Hence my question
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Read the LOI. Doesn't matter if OEM, STC'd, or put on by the tooth-fairy. They all have to work for night VFR. There's a number of articles on the subject. The FAA at one of their more finer moments.;)
 
Bell206 said:
Read the LOI. Doesn't matter if OEM, STC'd, or put on by the tooth-fairy. They all have to work for night VFR. There's a number of articles on the subject. The FAA at one of their more finer moments.;)
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Not just night, unfortunately... From the first LOI:

"The FAA agrees that there will be incidents where an airplane will be temporarily grounded from daylight operations until a failure in the light system can be repaired. However, the additional safety cue provided to pilots by operating anticollision light systems will outweigh the cost of maintaining the light system." (61FR5158; February 9, 1996)."
 
Bell206 said:
Read the LOI. Doesn't matter if OEM, STC'd, or put on by the tooth-fairy. They all have to work for night VFR. There's a number of articles on the subject. The FAA at one of their more finer moments.;)
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DOH! My bad. I still think what the FAA wrote is wrong, but if that is what the letter of the law says, so be it.
 
smv said:
Not just night, unfortunately... From the first LOI:
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JAWS said:
I still think what the FAA wrote is wrong,
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The other problem with this situation is that it sets a pilot up for a major fall as there is zero correlation between the LOI and other existing FAA guidance on required equipment, installations, etc. It’s this regulatory discrepancy that led to other discussions and where I learned from a PMI that you could get a waiver from the FSDO to operate with one anti-coll system inop, or remove the inop system per 91.213, as mentioned above. A 3rd option is if the aircraft has an approved MEL which lists the different anti-coll systems for deferment.
 
Bell206 said:
The other problem with this situation is that it sets a pilot up for a major fall as there is zero correlation between the LOI and other existing FAA guidance on required equipment, installations, etc. It’s this regulatory discrepancy that led to other discussions and where I learned from a PMI that you could get a waiver from the FSDO to operate with one anti-coll system inop, or remove the inop system per 91.213, as mentioned above. A 3rd option is if the aircraft has an approved MEL which lists the different anti-coll systems for deferment.
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The waiver is addressed in the footnotes of page 3 the first LOI.
 
Interesting discussion.

Isn't the G1000 equipped 172 different? The KOEL lists the strobe lights as required, but the beacon as not required. The KOEL is in the Limitations section, which is "approved" by the FAA.

Not to muddy the waters more, but interesting discussion.
 
smv said:
The waiver is addressed in the footnotes of page 3 the first LOI.
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Good to know. Too bad LOIs aren't easily available as well...
JAWS said:
The KOEL is in the Limitations section, which is "approved" by the FAA.
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And that’s the regulatory discrepancy I mentioned. Part 21 and Part 43 both give guidance on methods to deal with or solve this specific issue which was used prior to this LOI and another.

The problem is Part 91 is an operational standard and only applies when the aircraft is operated by definition. So while all of the Part 21/Part 43 guidance is legit, even with our names/certificates in the books deferring the strobes, the pilot will still get violated when they fly per how Part 91 is now defined in the LOI. There is some relief based on the date of certification/aircraft configuration, but I never seen or heard an official explanation of that relief. But it’s definitely a goat rope especially for the pilot.

It’s also my understanding there’s more to the story of why this even became an LOI.
 
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