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Re: Europa-List: Nav lights

Subject: Re: Europa-List: Nav lights
From: n3eu@comcast.net
Date: Fri, 31 Oct 2003 04:46:13

I'll try 'n field this one.  First, "PMA" is not "approved" as contemplated in
the Part 91 rule that nav and anti-collision must be approved.  It's only 
authorization
to hit the green start button on a production line for a part approved
under other rules.

Second, it doesn't follow that if an FAA inspector or DAR under delegation does
not question the system that it becomes "approved" either.  There's a classic
NSTB decision where a local FAA office "approved" per 337 the installation of
a monster turboprop on something like a C-172.  Obvious mistakes in the extent
of local office approval authority don't count said NTSB, and the operator was
found to have been operating an unairworthy aircraft and should have known
better.

Thirdly, for approval of these systems, FAA has a detailed advisory circular 
describing
test procedures for compliance with Part 23 rules, but far beyond the
capability of a homebuilder and providing easy FAA basis for "approved."
Part 23 does not apply to homebuilts, but it's the only place FAA sets out 
specifics
for lighting, and a law student past the course on federal adminstrative
law can answer that one without much contemplation. 

The potential jeopardy: 1) insurance, because it will be the op lims letter 
which
allows night flight if the system is "approved."  Allowing the insurer to define
approved per above.  2) a violation case is possible where there's a near
collision, especially like with an airliner under visual separation and 
complaining
that the other aircraft's lights were not clearly visible.

Thus also my approach to this, namely heck with FAA rules.  I'd prefer to be 
clearly
seen at night especially by that airliner or bizjet at 250 indicated, meaning
the more intensity the better, meaning an "approved" system, like Whelen
or Grimes makes.

Best,
Fred F.

> I am a little puzzled with the way the discussion here goes in regards of
> the NAV lights. I know that the most responses are coming from the people
> who have to adhere to the FAA regulations, and in particular the FAR Sec.
> 91.205 section c).
> It say's you need  1: minimum required instruments 2: "approved" position
> lights and 3: "approved" aviation red or aviation white anti-collision
> lights.
> 
> I original liked the Aeroflash system but there are not "PMA"ed, so I come
> more and more to the conclusion that I have to use the "approved" Whelen
> wingtip position/strobe/pos lights.
> 
> The question I guess, I should ask. What does "approved" mean?
> 
> I think it even becomes more important if you want to get your plane
> IFRapproved.
> 
> How do you folks see that?
> 
> Thanks
> 
> Michael Grass
> A266 tri gear




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