All the anticollision light questions

LifeAsBen

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LifeAsBen
I went down the anticollision light rabbit hole and I wanted to put my scenarios and assumptions out there for comment to see if others interpret this the same.

First, as a reminder these are the pertinent regs:

FAR 91.205 (b)(11) Day VFR For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made.

FAR 91.205 (c)(3) Night VFR 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.
And this is the pertinent AIM 4-3-23 (a & b)
  1. Aircraft position lights are required to be lighted on aircraft operated on the surface and in flight from sunset to sunrise. In addition, aircraft equipped with an anti-collision light system are required to operate that light system during all types of operations (day and night). However, during any adverse meteorological conditions, the pilot-in-command may determine that the anti-collision lights should be turned off when their light output would constitute a hazard to safety (14 CFR Section 91.209). Supplementary strobe lights should be turned off on the ground when they adversely affect ground personnel or other pilots, and in flight when there are adverse reflection from clouds.
  2. An aircraft anti-collision light system can use one or more rotating beacons and/or strobe lights, be colored either red or white, and have different (higher than minimum) intensities when compared to other aircraft. Many aircraft have both a rotating beacon and a strobe light system.
Scenario A
You're flying a 1946 Piper Cub that has been outfitted with an electrical system and a beacon. The beacon has burned out, you are legal fly to VFR day because the plane was manufactured before March 1996.

Scenario B
You'd like to take your sweet 1951 Cessna 140 up for a joy ride. However, one of the wing tip strobes stopped working. You are legal to fly VFR Day with only the beacon on. During the flight your beacon burns out but you remain legal to fly VFR day without any anticollision lights turned on because the plane was manufactured after March 1996.

Scenario C
You enjoyed your flight in the 140 so much it's stretched into the evening, it's now 2 hours after sunset. Your beacon you notice has started working again and you have turned on the position lights, but you are still are not legal because part of the anticollision light system, your wing tip strobes, are not functioning.

Scenario D
You take up your friends 1939 Waco in VFR day conditions that's been retrofitted with anticollision wing tip strobes but no beacon. You switch on the strobes. The plane has no beacon. You're legal because the plane was built before March 1996.

Scenario E
You preflight your 2004 Cessna 172 and discover a wing tip strobe light is burned out. You cannot fly it until this is remedied because the strobes are part of the anticollision light system and must be functioning (unless it burned out in mid air, then you can continue to your destination where it will be fixed).


It all seems straight forward but I feel like I'm missing a "gotcha".
 
Timely. Just discussed this with a student of mine yesterday because the beacon was out on the plane.
 
It all seems straight forward but I feel like I'm missing a "gotcha".
Agree. But you're missing how Part 91.209(b) and Part 91.213(d) figure into your scenarios as they contain additional requirements to check. There are also a couple FAA LOIs on this that further "gray" this topic. If I find them I'll post it. FYI: the listed built/certification dates will also dictate the path you can take to defer those inop lights.
 
Oh yeah, scenario B, should be "was manufactured before 1996"
 
I think you might be missing one pertinent reg...

91.209. No person may
(b) Operate an aircraft that is equipped with an anticollision light system, unless it has lighted anticollision lights.​
 
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Agree. But you're missing how Part 91.209(b) and Part 91.213(d) figure into your scenarios as they contain additional requirements to check. There are also a couple FAA LOIs on this that further "gray" this topic. If I find them I'll post it. FYI: the listed built/certification dates will also dictate the path you can take to defer those inop lights.
Yep. You are referring to the ones which say that if your anticollision light "system" has both a beacon and wingtip strobes, all must be operating.

2011 Murphy letter
2017 Letts letter
 
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