Landing lights

Love our Whelen LED lights. Better light, lower draw, etc etc etc. And no more fussing with incandescents burning out in the cowl and having to drop the lower cowl to replace them.
 
So if I can summarize. HID is the best light but has more initial cost and installation cost due to the ballast, requires A&P involvement. LED is second best because it requires no rewiring and is basically plug and play, requires A&P involvement.

Is that correct?

Best for my three light system would be HID at the wingtips and LED in the center with a taxi diffuser?

Better for my three light system would be LED with landing diffuser at wingtips and LED at center with taxi diffuser?
 
So if I can summarize. HID is the best light but has more initial cost and installation cost due to the ballast, requires A&P involvement. LED is second best because it requires no rewiring and is basically plug and play, requires A&P involvement.

Is that correct?

Best for my three light system would be HID at the wingtips and LED in the center with a taxi diffuser?

Better for my three light system would be LED with landing diffuser at wingtips and LED at center with taxi diffuser?


Pretty much.

What's the goal of your swap? I have trouble seeing in a couple airplanes when I taxi around, so to me the traxi light is far more important than the landing light. I'm not paying that much attention to the BRIGHT SPOT on the runway when landing. I'm looking down it, and using heavy peripherals for sink rate and flare information. But when I turn off onto an unlit taxiway with faded markings, it SUCKS.


One of these airplanes has no way to dim the overhead lighting so that doesn't help.
 
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My current light setup really lights the way up pretty well. The wingtip lights are adjusted to merge with the center light to give me a pretty good view of the whole runway and taxiway. My initial thoughts are that the LED's all around will be just fine. My plan is to replace the old incandescent with LED as they burn out.
 
My current light setup really lights the way up pretty well. The wingtip lights are adjusted to merge with the center light to give me a pretty good view of the whole runway and taxiway. My initial thoughts are that the LED's all around will be just fine. My plan is to replace the old incandescent with LED as they burn out.


Then I would go the least painful route. LED for the nose position as you mention. Just like this Falcon 900EX has sitting here at work B)

Get a PMA'ed one that replaces the bulb you have, and sign off yourself as the owner.

I'm not sure if the ballast harness is long enough on these aftermarket kits to mount them in the nose gear well or what the alternative is for HID's on the landing gears.

IMAG1901_zps1c0bb1f4.jpg
 
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I'd suggest letting your IA have a chat with Stan first, just to cover everyone's butts Tim.

I suspect that no one would care but even if the change is considered a minor alteration you will need an A&P
 
I'd suggest letting your IA have a chat with Stan first, just to cover everyone's butts Tim.

I suspect that no one would care but even if the change is considered a minor alteration you will need an A&P


If the PMA Supplement for part #5678 says it's a direct replacement for part # 1234, and the airplane has part #1234 and it is the correct part per the IPC, how is that an alteration and why would he need an A&P, for a LIGHT BULB? :dunno:


Here is a link to a PMA Supplement...

http://www.whelen.com/_AVIATION/pmasupplements/pmasup37.pdf
 
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Because a PMA does not constitute approval to alter an aircraft? :dunno:

Why did I need an STC and form 337 for my flap gap seals? They were/are PMA parts.

Trust me I have had this conversation with the FAA, while I may not agree with it I do have to abide by their decision.
 
Because a PMA does not constitute approval to alter an aircraft? :dunno:

Why did I need an STC and form 337 for my flap gap seals? They were/are PMA parts.

Trust me I have had this conversation with the FAA, while I may not agree with it I do have to abide by their decision.

The guy you were talking with at the FSDO that day was wrong or didn't understand your question.

The light bulb PMA's LIST ELIGIBLE AIRCRAFT...

This is just like replacing a 6.00 x 6.00 6 ply tire part #1234 from Manufacturer A with 6.00 x 6.00 6 ply tire part #5678 from manufacturer B on a typical GA SE airplane.
 
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So if I can summarize. HID is the best light but has more initial cost and installation cost due to the ballast, requires A&P involvement. LED is second best because it requires no rewiring and is basically plug and play, requires A&P involvement.

Is that correct?
YEs that is correct, the FAR 43-A © covers a bulb replacement, but does not cover the light fixture.

Best for my three light system would be HID at the wingtips and LED in the center with a taxi diffuser?

Better for my three light system would be LED with landing diffuser at wingtips and LED at center with taxi diffuser?

That's a nice system, and many owners are changing to it.

Ask your A&P-IA who will be doing your annual, what paper they want to see.

The lighting system I bought all parts had a STC attached, all it requires is a 337 filled out and sent in signed by the A&P-IA to get the STC recorded in your aircraft history records at OKC.

That way there is no confusion at the next inspection or pre buy, no arguing about which is right.
 
If my Cessna 172M has a factory throttle cable part # 1234 and I buy a McFarlane replacement part # MC-5678, and the PMA supplement for the MC-5678 says its a direct replacement for Cessna part # 1234, I don't need ANYTHING else to install it on my 172M.
 
If my Cessna 172M has a factory throttle cable part # 1234 and I buy a McFarlane replacement part # MC-5678, and the PMA supplement for the MC-5678 says its a direct replacement for Cessna part # 1234, I don't need ANYTHING else to install it on my 172M.

That is because Cessna used a McCauley cable at the factory, and McFarland has PMA to build the after market replacement. There is no modification of the aircraft with this method.
 
That is because Cessna used a McCauley cable at the factory, and McFarland has PMA to build the after market replacement. There is no modification of the aircraft with this method.


Exactly. Not all PMA's are the same, so owners and A&P's need to get ahold of them and read exacly what they say.
 
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When I am flatly told that installing an LED light into an aircraft not so equipped for the factory is an alteration, any and all LEDs regardless of PMA status....


It then becomes a matter of is it major or minor, and then you fall to a debate on the semantics of "basic design"

Boy will that make your head hurt
 
When I am flatly told that installing an LED light into an aircraft not so equipped for the factory is an alteration, any and all LEDs regardless of PMA status....


It then becomes a matter of is it major or minor, and then you fall to a debate on the semantics of "basic design"

Boy will that make your head hurt


So your saying we need seperate approval for ALL THOSE PMA'ed parts for Benix magnetos, brake pads, light bulbs, throttle cables etc... when there is no other approval documents other than the PMA which says which parts they are a replacement for? Clearly that's wrong.


If I have a signed FAA approved document that says Part A is a direct replacement for Part B, it's not an alteration at all. It's just maintenance. Since the owner/operator can replace light bulbs under 43 appendix A (17), the owner can change to the LED bulb using the PMA supplement data. No A&P required.
 
Doesn't say direct replacement, just says very similar, exact wording "minor differences"
Also says that the whelen LED lamp in question replaces itself...
The basis for approval is a licensing agreement between whelen and the STC holder for the lights...


And engine alterations are classified completely differently than airframe, so trying to argue about mag/starter swaps is moot
 
Doesn't say direct replacement, just says very similar, exact wording "minor differences"
Also says that the whelen LED lamp in question replaces itself...
The basis for approval is a licensing agreement between whelen and the STC holder for the lights...


And engine alterations are classified completely differently than airframe, so trying to argue about mag/starter swaps is moot


Whooo Hass. Not Starter or Mag assembly swaps. Talking about aftermarket magneto PARTS. Aero Accessories Breaker points vs OEM breaker points etc.
 
If the PMA supplement DOES NOT show the new LED bulb eligible to replace the one you have, then the owner needs help from the A&P.


Many of these PMA's say "replaces Cessna part # xxx, replaces Beech part XXX" but since thats a lot of work and research I'm guessing the PMA holder doesn't want to come up with that data and list it on the PMA
 
If the PMA Supplement for part #5678 says it's a direct replacement for part # 1234, and the airplane has part #1234 and it is the correct part per the IPC, how is that an alteration and why would he need an A&P, for a LIGHT BULB? :dunno:


Here is a link to a PMA Supplement...

http://www.whelen.com/_AVIATION/pmasupplements/pmasup37.pdf

If the PMA supplement DOES NOT show the new LED bulb eligible to replace the one you have, then the owner needs help from the A&P.


Many of these PMA's say "replaces Cessna part # xxx, replaces Beech part XXX" but since thats a lot of work and research I'm guessing the PMA holder doesn't want to come up with that data and list it on the PMA

So here we have the PMA you posted for the LED lights, what P/Ns may you replace with these lights?
 
Here's the PMA for the PAR36 landing light, with PMA basis being identicality:
http://www.whelen.com/_AVIATION/pmasupplements/pmasup37.pdf

How does that effect the conversation?

I just looked up the part number for a landing light buld on a cessna 120 (since its listed on the supplement you linked) the pn for the bulb is M4522 (Grimes Bulb) it is not an owner replaced part. However, if you have previously installed the STC from float alaska LLC, you can then replace the bulb.

I'd guess that it would be very similar situations for all the aircraft listed on your PMA supplement. Does that make sense?


-VanDy
 
I just looked up the part number for a landing light buld on a cessna 120 (since its listed on the supplement you linked) the pn for the bulb is M4522 (Grimes Bulb) it is not an owner replaced part. However, if you have previously installed the STC from float alaska LLC, you can then replace the bulb.

I'd guess that it would be very similar situations for all the aircraft listed on your PMA supplement. Does that make sense?


-VanDy


I think you're on the right track.
 
I think you're on the right track.

Here is the key: licensing agreement between Whelen Engineering Company Inc. and Floats Alaska, LLC, Assist Letter, dated 11/22/10
DWG No: 71424
Rev: -
Date: 3/4/10
or later FAA-approved revisions


That is listed under approval basis and approval design data on your link from wheelen.




-VanDy
 

The answer is none, as it is the PMA for the part to be installed under an STC,
01-0771424-10 can replace only 01-0771424-10 lamps per the PMA, so the aircraft as certificated or in its properly altered state must use the 01-07714240-10 lamp for the installation of this part to only be maintenance.
 
Order 8110.42 PMA approval procedures

3. Basis for Design Approval.
These methods are:
a. Identicality by Showing Evidence of a Licensing Agreement.
(1) The applicant sends the appropriate MIDO document from the TC, STC, or TSO authorization holder authorizing use of their data package. Evidence of a licensing agreement is
6 6/23/08 8110.42C
 
not a separate approval method, but is a way to show identicality. The applicant uses this evidence to show that the data submitted are FAA-approved and identical to the original part. For FAA purposes, the licensing agreement (in any form) only needs to authorize the applicant to use the specified type design data. See FAA Order 8120.2, Section 5, for more information.
(2) Following the current industry practice, TC holders prepare "assist letters" for applicants to send to the MIDO. This practice meets the requirements of showing evidence of a licensing agreement under 14 CFR § 21.303(c)(4). Find a sample assist letter in FAA Order 8120.2, Figure 10.
(3) PMA Assist Letter. In the assist letter, the licenser (usually a TC holder or a PAH) may identify critical parts to aid MIDO processing of the PMA application.
b. Identicality without a Licensing Agreement.
The applicant sends the appropriate ACO a statement certifying that the design is identical in all respects to an approved design (for example, TC, STC or TSO authorization). The applicant also provides the data supporting the identicality claim for review and approval. These data verify the identicality in dimensional and material characteristics, special processes and coatings, and test and acceptance criteria. Identicality without access to the original design data is nearly impossible for sophisticated parts with proprietary processes or coatings. Identicality to another PMA is unacceptable because 14 CFR § 21.303(c)(4) restricts identicality to only parts covered under type certificates.
c. Test and Computation.
The applicant sends the ACO a data package for review and approval. This data package describes the part design, which includes materials, processes, test specifications, system compatibility, maintenance instructions, and part interchangeability. The package also includes a test and substantiation plan to show compliance with applicable airworthiness standards. See chapter 2, paragraph 5 for more details about the data package.
d. Supplemental Type Certificate (STC).
The applicant stipulates use of the approved data from the STC and refers to the STC number.
4. Draft PMA Supplements.
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]After approving the PMA, we will assign a PMA and supplement number. Use the following samples as guides for preparing FAA-PMA supplements:
• Appendix F, Sample FAA-PMA Supplement for Identicality (Non-Licensing Agreement) or Test and Computation, is a supplement based on either identicality without a license agreement or test and computation.
• Figure 11 of Order 8120.2, Sample FAA-PMA Supplement for Licensing Agreement and STC, is a supplement based on either an STC or licensing agreement.


5. Verification of Installation Eligibility.
a. A manufacturer’s IPC offers information about installation eligibility, but the IPC is usually not FAA-approved. Consider using the IPC with other data like purchase orders from the PAH, service bulletins, maintenance manuals, a technical publications index, or a master drawing list. We cannot use the IPC to make any engineering finding leading to approval of the applicant’s design data. Also we cannot use the IPC to determine part conformity. Other acceptable documentation is a combination of the following:
• FAA airworthiness approval tag (FAA Form 8130-3),
• Other PMA supplements, and
• “Weight of evidence” evaluations using enough information from various sources to show eligibility.
b. Accept use of the IPC alone as a means for verifying installation eligibility on non-critical parts. When the IPC is the sole means of verifying installation eligibility, confirm the authenticity of that IPC.
c. If the application lacks documentation from the TC or TSO authorization holder (or other FAA-approved data), then the ACO may consider other evidence from the applicant. To verify installation eligibility, check other documents including the type design’s master drawing



[/FONT][/FONT]
 
The answer is none, as it is the PMA for the part to be installed under an STC,
01-0771424-10 can replace only 01-0771424-10 lamps per the PMA, so the aircraft as certificated or in its properly altered state must use the 01-07714240-10 lamp for the installation of this part to only be maintenance.

That's my take as well.


-VanDy
 
So here we have the PMA you posted for the LED lights, what P/Ns may you replace with these lights?

The STC explicitly calls out currently installed HID or LED as being owner-replaced. But...for just about everything else it explicitly calls out aircraft (manufacturer & model) but not part number.

However....for example for the PA28 in the Notes section there's this caveat "Installation is limited to previously approved landing/taxi locations" but not allowed if the light is on the retract portion. But because it's an STC, still need A&P signoff.
 
Bnt83, what you just post is the same thing we are telling you. If you have the STC for the LED upgrade from Floats Alaska already installed and recorded via 337, the bulb is a legal good to go because the TC for your aircraft has been modified via the STC to use the LED bulb from wheelen. But an owner can not buy the bulb and legally install it with out the STC or a field approval. Which will require an A&P/IA.


-VanDy
 
That's my take as well.


-VanDy

So we have established that the initial install of the lamp is an alteration, we are up to needing at least an airframe license to install,

Now minor or major, a loaded question, but IMO the existence of a STC to install the thing is a clue
 
So we have established that the initial install of the lamp is an alteration, we are up to needing at least an airframe license to install,

Now minor or major, a loaded question, but IMO the existence of a STC to install the thing is a clue

Exactly, I asked our PMI specifically about STC's and he said they are automatically major.


-VanDy
 
I'm missing something and I haven't found it yet.
 
Exactly, I asked our PMI specifically about STC's and he said they are automatically major.


-VanDy


Your PMI is unaware of the STC coverpages that exist with the statement "This is a minor alteration. Do not files FAA form 337"
 
Your PMI is unaware of the STC coverpages that exist with the statement "This is a minor alteration. Do not files FAA form 337"



If it were minor no STC would be needed as you could just install with a log book entry
 
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