LED Landing Light Replacement

idahoflier

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idahoflier
Apologies in advance if this has already been covered in another post that I couldn't find...

I would like to replace my burned out landing light with a LED replacement, specifically a Whelen Parmetheus Plus. My question is am I able to do this myself with a suitable logbook entry or do I need an IA to sign off the installation and file a 337?

If I am able to do this myself, what would need to be in the logbook entry?

Thanks!
 
Apologies in advance if this has already been covered in another post that I couldn't find...

I would like to replace my burned out landing light with a LED replacement, specifically a Whelen Parmetheus Plus. My question is am I able to do this myself with a suitable logbook entry or do I need an IA to sign off the installation and file a 337?

If I am able to do this myself, what would need to be in the logbook entry?

Thanks!
Yes you may install yourself with appropriate logbook entry. You can find samples many places. Make sure you print a copy of the Whelen STC and directions. I think the directions (or the STC) has the text for the logbook.

Originally, an A&P had to sign, but that changed a few years ago. Make sure you install with correct polarity.
 
Yes you may install yourself with appropriate logbook entry. You can find samples many places. Make sure you print a copy of the Whelen STC and directions. I think the directions (or the STC) has the text for the logbook.

Originally, an A&P had to sign, but that changed a few years ago. Make sure you install with correct polarity.

Thanks for the reply.

I think I know what to put in the logbook, but I'm still not sure this would be legal. I reviewed the Whelen site and they don't really address the log entry other than the last step in the instructions "Update records in accordance with 14CFR 91.407."

Whelen has an STC, but I don't believe that can be applied to a specific aircraft without a 337 and I don't think I can file a 337 as an owner (I'm not an A&P).

Whelen does have a PMA, but in the PMA under the Approved Replacement for Article Number column it has "Modification Part" listed for my make and model. This is in contrast to a PMA for a Teledyne light which actually lists the Cessna part number in the Approved Replacement for Article Number column. Because of that it seems like installing the Whelen light would be interpreted as a modification and something I couldn't do as an owner.

I hope I'm incorrect in my above thinking!
 
Three schools of thought.
1 - because of the STC your A&P needs to file a 337
2 - because Whelen & the FAA agreed it's now PMA'd, it's just like putting different tires on the airplane, e.g. Condors vs Goodyears. You don't file a 337 when you change tires.
3 - go ahead and install the light and ask the A&P next time you see them.

Worst case? Call Whelen in the morning and ask them.
 
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You can replace light bulbs on your plane if you hold at least a PPL. Has to be exact or an approved replacement and make a logbook entry. I want to do this too. I have the nose and 2 wing lights and I cringe when I see the current draw when all 3 are on. Current draw equals the possibility of heat (especially if a connection is loose) and heat in the wiring of a flying tin can...well, I think we all can agree that is undesirable.
 
Whelen does have a PMA, but in the PMA under the Approved Replacement for Article Number column it has "Modification Part" listed for my make and model.
As long as the PMA lists includes your specific aircraft the part is a direct replacement for the OEM part. As for "modification part" that does not mean it is an "alteration." FYI: since you are a PPL I always recommend referencing a PMA authorization over a STC if they are similar as sometimes the STC may have a install requirement that a PPL can't perform under preventative maintenance.
I think I know what to put in the logbook, but I'm still not sure this would be legal.
Any time you perform preventative maintenance you are bound by the same rules as an A&P: Part 43.13 and Part 43.9. The log entry must conform to 43.9 and you must use a reference to install bulb per 43.13. Also you should be familiar with 43 Appx A(c) as that is was authorizes you to change that bulb. There are several FAA ACs that walk you through the above which may help with future projects.
 
Thanks everyone!

For anyone that comes across the post, I contacted Whelen and they also believe their PMA allows replacement by an owner...
 
I am not entirely sure. Sure the form fit and function is there. But the Whelen light is specifically noted as a modification part and does not note the part number it is meant to replace. Hence why the STC is provided, to legitimise the installation.

I do agree that from a practical POV, it isn't rocket science. My thoughts are more from the legal side. I have installed these prevously following the STC.
 
I am not entirely sure. Sure the form fit and function is there. But the Whelen light is specifically noted as a modification part and does not note the part number it is meant to replace. Hence why the STC is provided, to legitimise the installation.

I do agree that from a practical POV, it isn't rocket science. My thoughts are more from the legal side. I have installed these prevously following the STC.

I completely understand your skepticism. FWIW, the STC was granted in 2014 and the PMA in 2016. I *think* the PMA removes the need for the STC...
 
Hence why the STC is provided, to legitimise the installation.
Not quite. You'll find that most vendors marketing a part that is applicable to a wide range of aircraft, like LED lights or batteries, will obtain an STC first, then create a PMA listing afterwards. On the other side, for parts that are applicable to a specific aircraft like throttle cables, a vendor will only pursue a PMA for each cable. The reasons vary but it falls to the cost of approving the part. The main difference is once a part is listed as a PMA part, it becomes an approved replacement part to the aircraft model whereas an STC--in general terms-- is still considered an "alteration."

Also once a part is listed as a PMA its installation is "legitimized" and no longer needs the STC approval to install provided it is a true replacement to the OEM part. And that determination still falls to the installer.

As for the "modification part" term it is not applicable to the part installation but rather terminology used for the PMA listing only. If you look at the PMA list the same STC approval is used for all 59 pages of PMA listings.
 
I *think* the PMA removes the need for the STC...
Close. The STC provides the approved data for the PMA plus allows the part installation in case of extenuating circumstances.
 
OOOOkay, let's take these one by one.

Part 21 says that you have to have PMA (Parts Manufacturing Approval) for ANY part a company produces and sells for use on an aircraft. It does NOT specify which aircraft it goes on. It is simply a license to PRODUCE (manufacture parts) and sell them as airplane parts. One major exception to this rule is 21.303(b)(2) which says that any OWNER can manufacture parts for their own aircraft.

An STC is an approval to change the way that a particular airplane (or series of airplanes) is modified but remains in compliance with the Type Certificate under which the aircraft is manufactured. It is a MAJOR change to the way the airplane left the factory. Since it is a MAJOR change, a 337 form is required that references the STC and how the change was made in compliance with the STC.

A 337 can also be used as a field approval for MAJOR modifications (the definition of MAJOR is how an airplane flies, operates, or is changed from the flight characteristics listed in the POH or other published operations data (like the owner's manual for elderly airplanes)). The FAA goes on to say in a few Advisory Circulars (see below) how a mechanic can determine MAJOR from MINOR, but the overall responsibility for this determination is the INSTALLING MECHANIC. Now, the clever INSTALLING MECHANIC goes to the INSPECTION AUTHORIZATION mechanic who is going to do the next annual and they jointly determine which is major and which is minor. Minor is simply signed off as a logbook entry.

The FAA has issued a series of Advisory CIrculars "ACs"(which are non-binding opinions of one or more divisions of the FAA) on how stuff ought to be done. NON BINDING, but disregard them at your peril.

A TSO is a Technical Standard Order. A TSO references a non-FAA document produced by an industry consortium (that's a bunch of guys sitting around the table) that says that if you want to build (for example) a TSO transponder it has to put out so much power, it has to have so much sidelobe suppression, it has to work from this temperature to that temperature, it has to survive the following shake-rattle-and-roll regimen, and a whole bunch of other stuff. Now you have your choice. Since the FAA (in their infinite wisdom) have chosen to write most of the FARs that stuff must MEET the TSO rather than BE TSOd, you can sell your stuff as MEETING the TSO. Getting the TSO means that you submit all your test data to the FAA, wait until the first virgin of Spring has been sacrificed,and then MAYBE if Jupiter aligns with Mars you will get the TSO approval back in the mail the following millenium. Maybe.

I stand ready to defend my thesis ...

Jim
 
It does NOT specify which aircraft it goes on.
Not quite. Each PMA article application requires the aircraft, engine, or propeller identified on which the PMA article will be installed. Part 21.303(a)(1)

Since it is a MAJOR change, a 337 form is required that references the STC and how the change was made in compliance with the STC.
A major change to type certificate and a major alteration are not the same thing. There are a number of FAA references to this. And not every STC is a major alteration requiring a 337. Part 21 defines design/production rules (STC) and Part 43 defines alteration rules (337). I discussed this in a previous post with additional references here:
https://pilotsofamerica.com/community/threads/newbie-battery-question.107934/
 
Each PMA article application requires the aircraft, engine, or propeller identified on which the PMA article will be installed.

That is where my confusion lies. The Whelen Prometheus LED light PMA denotes "modification" under the "Approved Replacement for Article Number" heading. There is no part number for which it is considered as a replacement. Therefore it must be considered an alteration, which can be installed with the STC. It could be done as a minor mod I suppose. Either way it is beyond preventive maintenance (elementary maintenance north of the 49th).
 
That is where my confusion lies.
You're reading too much into "modification" term. It depends on which approval process was used to obtain the PMA for the LED that determines the PMA references. I would bet in this case the STC data package was used to obtain the PMA approval. Not every PMA process requires a Part X for Part Y reference. For example, under a license PMA the holder would use the exact P/N as the OEM so there would be no reference table. So it depends.

Remember a PMA and STC are separate design/production approvals each with their own requirements. So long as the aircraft, engine, or propeller model number and if necessary S/N is listed that PMA part is applicable. There are a number of detailed explanations available on the PMA process that may assist in understanding this fully.
 
The Part X for Part Y thing is what I am most familiar with.

FAA PMA parts were only allowed to be installed on Canadian aircraft somewhere around 2005. That was fun when an aircraft was imported!

PS Sorry, early 2000's. http://www.aviationpros.com/article/10387548/replacement-parts-standard-571

Nope. The no-PMA-in-Canada thing applied to aircraft and engines type-certified in Canada, such as the deHavilland series or the PT-6. There were PMA'd parts available for Canadian types being used in the US but Canada had no provision for recognizing them as eligible on Canadian types. Transport Canada resolved that in the early 2000s as you say. It was nonsensical anyway.

FAA-PMA parts were previously eligible in Canada for US type-certified airplanes, like Cessnas and Pipers and so on. We used them with no trouble at all even before the ruling from TC that cleared them for use on PT-6's, for instance.

Now, the PMA thing: PMA'd parts that can be directly installed without STC are those that are designed to be equivalent to the OEM part. McFarlane, for instance, makes a lot of stuff for Cessnas and Pipers, and simply prefix the OEM part number with "MC" to make it obvious that it's the same thing. You can order a throttle cable from them using the part number from the airplane's IPC and it will come with that "Mc" in front of the part number, and you can install it legally. While the Parmetheus LED lamp is a PMA'd part, which means that Whelen has manufacturing approval to make and sell it as an aircraft part, it is not the same as an incandescent landing light at all and the STC is necessary to qualify it for use on a particular model of aircraft. Whelen would have had to prove that installing that LED in any model listed in their Approved Models List (AML) did not cause other problems by doing so.

Think about it. An incandescent landing light is all glass. It can take a lot of ambient heat. If it's in a cowling that places it close to a hot exhaust pipe, it might suffer a short life due to the vibration and heat, but that's about it. The LED lamp is plastic and, in that spot, could melt and burn and cause a whole lot of sweat in flight. It wouldn't qualify for an STC in such an airplane. There could be further considerations such as the much lower amperage requirements and RF noise generated by the LEDs.
 
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Nope. The no-PMA-in-Canada thing applied to aircraft and engines type-certified in Canada, such as the deHavilland series or the PT-6. There were PMA'd parts available for Canadian types being used in the US but Canada had no provision for recognizing them as eligible on Canadian types. Transport Canada resolved that in the early 2000s as you say. It was nonsensical anyway.

Thank you for the clarification. I forgot that it applied only to Canadian TC stuff (been a while). The company I worked for at one time had to change brand new PMA filters in a Cheyenne PT6 that was overhauled in the US. I have only ever seen one or two PDA parts, again for the PT6.
 
PMA'd parts that can be directly installed without STC are those that are designed to be equivalent to the OEM part
There are 4 or 5 methods to obtain a PMA. Most vendors who make parts equivalent or identical to the OEM part don't even bother with the STC process. I believe McFarlane uses the licensed PMA process which allows the use of Cessna's or Piper's approved data packages for the cables.

While the Parmetheus LED lamp is a PMA'd part, which means that Whelen has manufacturing approval to make and sell it as an aircraft part, it is not the same as an incandescent landing light at all
And it doesn't have to be. When a vender uses a PMA process outside the Identicality (?) processes like the Test and Compatibility (?) process or STC process, they must demonstrate the fit-form-function of the new part to the original part but it doesn't have to be identical or made from the same materials. The new part must also pass the same certification tests, etc as the original part. Regardless, once the part receives its own PMA and approved eligibility list it can be installed as a replacement part without the need for the STC.

Think about it. An incandescent landing light is all glass. It can take a lot of ambient heat......
All these issues have to be tested and confirmed during the PMA process otherwise no PMA authorization will be given if there are any safety or failure potential outside acceptable limits for each eligible aircraft model.

There are FAA and 3rd party materials out there that explain the PMA process a lot better than I can.
 
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I have never been able to find the GE Landing Light PMA it may be hidden in the Jet Engines. Or the Bendix King Radios PMA.
 
OOOOkay, let's take these one by one.

Part 21 says that you have to have PMA (Parts Manufacturing Approval) for ANY part a company produces and sells for use on an aircraft. It does NOT specify which aircraft it goes on. It is simply a license to PRODUCE (manufacture parts) and sell them as airplane parts. One major exception to this rule is 21.303(b)(2) which says that any OWNER can manufacture parts for their own aircraft.

An STC is an approval to change the way that a particular airplane (or series of airplanes) is modified but remains in compliance with the Type Certificate under which the aircraft is manufactured. It is a MAJOR change to the way the airplane left the factory. Since it is a MAJOR change, a 337 form is required that references the STC and how the change was made in compliance with the STC.

Close - actually any modification is a change to the type design and any Major change to a type design requires approved data (minor changes only require 'data acceptable to the Administrator'. The S in STC is a hint - Supplemental Type Certificate. Once an STC is incorporated, the aircraft (or appliance) no longer conforms to the original TC, it now conforms the the original TC except in those areas where it now conforms to the STC... An STC is one method of obtaining approval for the data associated with a major change, an 8110-3 (which is issued by a properly delegated DER) is another, FAA Approved Service Bulletins are another...)

A 337 can also be used as a field approval for MAJOR modifications (the definition of MAJOR is how an airplane flies, operates, or is changed from the flight characteristics listed in the POH or other published operations data (like the owner's manual for elderly airplanes)). The FAA goes on to say in a few Advisory Circulars (see below) how a mechanic can determine MAJOR from MINOR, but the overall responsibility for this determination is the INSTALLING MECHANIC. Now, the clever INSTALLING MECHANIC goes to the INSPECTION AUTHORIZATION mechanic who is going to do the next annual and they jointly determine which is major and which is minor. Minor is simply signed off as a logbook entry.

14CFR Part 43 actually lists those things which constitute Major repair/Major alteration, but it is laughable and it is indeed the mechanic performing the work's responsibility to make the Major/Minor determination. As an aside, Part 121 carriers are required to develop their own Major/Minor policy which is subsequently accepted by the FAA. generally, the Engineering department of the airline is responsible for generating the policy and the engineering department necessarily falls under the jurisdiction of the ACO, but the FSDO accepts the policy. Can be a great source of consternation, but I digress.

The FAA has issued a series of Advisory CIrculars "ACs"(which are non-binding opinions of one or more divisions of the FAA) on how stuff ought to be done. NON BINDING, but disregard them at your peril.

Advisory Circulars are absolutely non-binding, you cannot be punished for not complying with an AC unless you claim to have complied with it and did not in fact comply with it, but that falls under the auspices of falsification of aircraft records. In FAA speak, an AC "provides a means, but not the only means, of complying with a regulation... they do not create or change a regulatory requirement... (they may) contain explanations of regulations, other guidance material, best practices..." You may absolutely disregard them, but in general they do prove rather useful and painless - AC 43-13 being the greatest example - compared to developing your own means of compliance. Another aside - Part 121 carriers and OEM's routinely develop their own means of compliance but most GA folks have neither the technical prowess nor, perhaps more importantly, the financial resources to develop their own means of compliance. Not to mention the associated liability...

A TSO is a Technical Standard Order. A TSO references a non-FAA document produced by an industry consortium (that's a bunch of guys sitting around the table) that says that if you want to build (for example) a TSO transponder it has to put out so much power, it has to have so much sidelobe suppression, it has to work from this temperature to that temperature, it has to survive the following shake-rattle-and-roll regimen, and a whole bunch of other stuff. Now you have your choice. Since the FAA (in their infinite wisdom) have chosen to write most of the FARs that stuff must MEET the TSO rather than BE TSOd, you can sell your stuff as MEETING the TSO. Getting the TSO means that you submit all your test data to the FAA, wait until the first virgin of Spring has been sacrificed,and then MAYBE if Jupiter aligns with Mars you will get the TSO approval back in the mail the following millenium. Maybe.

The whole "meet the TSO" is an interesting, and I personally believe, legitimate loophole. Worth noting that NO ONE may approve a change to a TSO'd product other than the TSO holder. In other words, you can't do anything to a TSO'd product except as specified by the OEM - Major/Minor, doesnot matter. Which brings up an interesting point - that requirement does not apply to an article that MEETS as TSO, it only applies to TSO'd articles. Hmmmm.

I stand ready to defend my thesis ...

No particular reason why I selected this post to make comments other than that it was fairly well organized and speaks to several things with I am intimately familiar. Just pitching in to try and help clarify this mess that the FAA has created. It amazes me how much I don't know - I am an A&P/IA, FAA-DER, pilot and have been working in the capacity of aircraft mechanic and/or Engineer (Mechanical by degree, Aerospace by practice) for damn near 40 years, yet I constantly have to dig into the regs to try to figure out yet another issue that I am confronted with. In other words, I ain't throwing any stones here and I damn sure don't know it all. I do keep learning more every day and that's what keeps me going!

Jim

Not exactly a fresh thread, but I was digging for some guidance for signoffs and came across this thread. Sorry for hijacking....

T
 
Note that the PMA (and owner produced) parts aren't the only way to make legal aircraft parts. The TC manufacturer and the STC holder typically has manufacturing authority. TSOAs also include manufacturing authority.
 
As Ron noted above, anybody that owns an airplane and hasn't thoroughly researched FAR 21.303 (b)(2) [owner produced parts] is just throwing money away. That is a hole in the FARs that Granny Prichard could make 20 yards against the Steelers with. Learn it, believe in it, use it and your "legal replacement part" goes WAY, WAY down.

Jim
 
As Ron noted above, anybody that owns an airplane and hasn't thoroughly researched FAR 21.303 (b)(2) [owner produced parts] is just throwing money away. That is a hole in the FARs that Granny Prichard could make 20 yards against the Steelers with. Learn it, believe in it, use it and your "legal replacement part" goes WAY, WAY down.

Jim

That paragraph tells you that you don't have to comply with that rule, but it does not tell you what you do have to do or what you could do.

AC 20-62E provides guidance:
b. Acceptable Parts. The following parts may be found to be acceptable for installation on a TC’d product: (1) Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification. (2) Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform to FAA-approved data.

In other words, if it ever comes down to it, you will have to demonstrate that the part(s) you produced conform to FAA-approved data - either the original Type Data or some other data (see above). In many cases we don't have the original data (OEM's are loathe to give up drawings and data) and have to perform reverse engineering and determine the original part properties, structural strength, fatigue properties, etc. If you do an analysis and determine that the part is 2024-T3 Clad sheet 0.032-in thick, its pretty easy; if the part is carbon fiber reinforced plastic, it is not at all easy.

The AC also states:
n. Owner/Operator Produced Part. Parts that were produced by an owner/operator for installation on their own aircraft (i.e., by a certificated air carrier). An owner/operator is considered a producer of a part, if the owner participated in controlling the design, manufacture, or quality of the part. Participating in the design of the part can include supervising the manufacture of the part or providing the manufacturer with the following: the design data, the materials with which to make the part, the fabrication processes, assembly methods, or the quality control (QC) procedures.

This means that you can hire someone to fabricate your OOPP, which is pretty badass.

Here we go again, that SB is a means, but not the only means by which a regulation may be complied with....

 
In the case of lots of older aircraft, the drawings for the parts are available (or you have an existing part to copy that's unserviceable).
 
That paragraph tells you that you don't have to comply with that rule, but it does not tell you what you do have to do or what you could do.
Note that I said "*THOROUGHLY researched" (emphasis author). Thorough research takes you through a myriad of opinions and such, one of which comes from the FAA Office of the General Counsel and it pretty well gives you the nuts and bolts (you should pardon the expression) of what is required.

In the case of the OP's question about landing lights, the original equipment part number can quite trivially be researched as to candlepower, beamwidth, lux, and the like. Creating a better mousetrap with leds is quite easy.

Jim
 
I didn't install it...yet. I hooked it up to a 12v battery for comparison.
 
awjeeznotthisshitagain2sa2_zps8154a347.jpg
 
And now there are better (read: less expensive) LEDs out there. I just bought a spare LED (yeah, like I need one) for $34.

http://www.goodiesforpilots.com/par-36

It's brighter than my $285 Alphabeam :rolleyes:
FWIW I installed these and had pretty substantial RFI, then installed the Whelen Parmetheus Plus's and had none. That being said, my plane is the ONLY one I have heard of that has had issues.
 
FWIW I installed these and had pretty substantial RFI, then installed the Whelen Parmetheus Plus's and had none. That being said, my plane is the ONLY one I have heard of that has had issues.

Good tip, I'll keep that in mind.
 
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