Beacon help, the final word, Part 1

[Greg Bockelman]

I don't know what it will take to convince you guys. What will you accept as the final word? Here's my stab at it.

We may be arguing 2 separate issues here. One issue is whether or not our Taylorcrafts that do not have an anticollision light system can be flown at all. The answer to that is yes, they may. That is supported in part by FAR 91.205(b)(11). You all can look it up. I suspect that this is the question that Ian Twombly at AOPA answered for David Price in the other thread. On this point I have no issues.

The other issue is whether or not our Taylorcrafts can be flown at NIGHT without an anticollision light system. This is the point that I have been arguing in the other thread. I have quoted FAR 91.205(c)(3) in support of the reqirement for the anticollision lights. So far, no one has offered any reference to the contrary. All I have gotten was to take Norm's word for it.

I have been corrosponding with Denny Pollard. He is a maintanence inspector at the Oakland FSDO. As far as I am concerned, that is the final word. Attached are three letters that I received from him on this subject. In each letter, his response is first, followed by my original question.


Greg

To answer the question on anticollision lights I will need to know if the aircraft was certificated under CAR-3 or part 23 rules.

The older aircraft CAR-3 built before March 1, 1979 are usually Civil Air Regulations (CAR-3) those built after March 1979 are part 23. Anticollision lights are required on part 23 aircraft and not all CAR-3 depending on the year they were built. If they are installed they should work in accordance with part 23.1401. However having said that to operate at night ALL aircraft are required to have an anticollison light installed that works.

Part 91 covers ALL aircraft CAR-3, part 23, part 25 transport category and part 27 and 29 rotorcraft. You are correct in stating they must have an anticollision light to fly at night. Aircraft such as CAR-3 have to install them in accordance with the field approval or STC process to meet the part 91 rule.

There is no grandfather clause in the FAR's for older aircraft.

I hope this answers your question.

Denny

[email protected]
To: Dennis D Pollard/AWP/FAA@FAA
03/30/2004 12:11 cc:
PM Subject: Anticollision Lights

Hi Denny.

I own a Cessna 195 and lurk on that board on a regular basis. I also own a Taylorcraft and lurk on that board, also. There is a debate going on about whether or not anticollision lights are required for night flight. 91.205(c)(3) states that all U.S.-registered aircraft are required to have the anticollision light system to fly at night. 91.209(b) states that if the system is installed it must be turned on unless ...

I have sited 91.205(c) as my proof that the system is required. The other gentleman states that the older aircraft are grandfathered under a different part of the regulations. However, he will not cite his references. He also implies that 91.205 only applies to transport category airplanes.

I have been upfront in stating that I may be wrong, but I need difinitive proof. As in an FAR reference. Can you help prove me right, or wrong, either way? As of now, I am standing by my view that the anticollision system must be installed to fly at night as per the regs I have cited.

Thanks.

Greg Bockelman





Greg,

In accordance with part 91.209(b) would require that airplanes equipped with an anticollision light system be operated with the anticollision light system lighted during all types of operations, except when the pilot determines that, because of operating conditions, it would be in the interest of safety to turn the lights off.

However part 91.205 Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a powered civil aircraft with a standard category U.S. airworthiness certificate in any operation described in paragraphs (b) through (f) of this section unless that aircraft contains the instruments and equipment specified in those paragraphs (or FAA-approved equivalents) for that type of operation, and those instruments and items of equipment are in operable condition.

What this is trying to say is you have to have an anticollison light system installed for night flying. So the Taylorcraft is required by part 91 to have one installed even if it was built in 1950 without the system.

This is from the Preamble:

New ¡× 91.209(b) requires airplanes equipped with an anticollision light system to operate those lights during all operations, including daytime VFR. The incremental cost of this provision consists of light bulb replacement. The FAA estimates that a light bulb for an anticollision light system costs approximately $50 and that this provision would necessitate an incremental bulb replacement every two years. Accordingly, the cost is projected to equal $25 per year, per affected operating airplane.

The FAA holds that any grounding of an airplane due to a faulty bulb or light system will be rare and quickly corrected. The cost of such grounding will be negligible, when compared with the safety benefits of operating anticollision light systems.

In summary, the FAA holds that the benefits of the rule, though not directly quantifiable, will exceed the expected costs. Each of the provisions, as well as the entire final rule, w§c be cost beneficial.

Denny

[email protected]
To: Dennis D Pollard/AWP/FAA@FAA
04/03/2004 09:21 cc:
AM Subject: re: Anticollision Lights

Hi Denny.

Thanks for your response. I think your resopnse answers my question. However, to be 100% sure, let me ask the question this way:

Can a Taylorcraft, certified before 1950 or so, legally fly at night
without an anticollision light system?

Greg Bockelman



Greg

Still requires a anticollison system to be legal at night.

Denny

[email protected]
To: Dennis D Pollard/AWP/FAA@FAA
04/03/2004 10:28 cc:
AM Subject: re: Anticollision Lights

Denny,

A follow up question about the anticollision lights.

Does it make any difference whether or not the airplane has an electrical system? There is the argument that if not, it does not require the AC system to fly at night.

Thanks.

Greg


Denny has made it perfectly clear that ALL airplanes MUST be equiped with an anticollision light system if they want to operate legally at night.

I don't know what more you guys could ask for in the way of verification.

Part 2 comes on Monday after I talk with Ian Twombly or someone similar at AOPA to verify some questions.

[Greg Bockelman]

Beacon help, the final answer, Part 2

I just got off of the phone with Craig Brown at AOPA. According to him, ALL aircraft MUST have an anticollision light system to fly at night. His reference is 91.205(c)(3). He also said that there are no grandfather provisions in the FARs for older aircraft certified without the anticollision light system.


That is the same reference that Denny Pollard at the Oakland FSDO cited for his same answer.

So, now you have 2 separate sources for whether or not an anticollision system is required.

To add to it, FAR 91.209(a) stipulates that the nav lights and AC lights are required from sunset to sunrise. Not end of Civil twilight to begining in the morning.

[jrzangger]

I've missed the running dialog but just got caught up. Interesting reading! It does appear that the regulations dictate an operable anti-collision light to legally operate at night My concern is that the question was generally posed without the phrase "non-electrical" and this may lead the response in a different direction. Personally, I have operable position lights operated from a portable gell-cell battery. I have only flown at "night" once and I strapped a portable, battery operated strobe to the tail spring (probably not an authorized installation, but it was visible!). No one asked about the necessity for panel lighting. I know landing lights aren't needed but I think panel lights are. I used a battery powered camp light!

I've always questioned why people want to take this great little plane and try and make it something it isn't! I really don't intend to fly much at night as I consider it a day VFR airplane. The nav lights may come in handy at the end of a trip with a stronger headwind than anticipated but I'm not going to destroy the originality of my plane with the installation of an anti-collision light. I don't have an extended baggage compartment and I don't have the cowl bumps for shielded plugs either. I don't have a skylight or a big engine. I don't have vortex generators on it or oversize tires. Mine is as original as I could make it.

I want to encourage everyone to enjoy their Taylorcrafts as much as possible, but if you wanted to fly at night, carry a lot of baggage, or go fast, maybe there is another plane that fits the bill a little better! I really enjoy mine and have flown it on many long trips so I know it is a very capable airplane within it's design limits. Let's go fly and have fun. The flight breakfast season has started and there's places to fly again!

[Greg Bockelman]

Hi Jim

Actually the non electrical question was posed to Denny Pollard at Oakland FSDO. The answer was that it didn't make any difference. AC still needed for night flight. See the third corrospondence with Denny in Part 1.

See you around the circuit.

Greg

[stormman]

Omega word from the Supreme Being

GREAT JOB Greg
Now you have some body in the FAA confused too
YOU doing the old , " the more i talk the more they will see it my way thing."
Keep it up and someone will tell you you have to fly dual pilot too with full IFR . Let use not forget the 2 D cell flashlight with SPARE batteries .. C and AA batteries no good . Can't use 200 hour LEDs , got to be D cell flashlight.
Still love you man but you and your cronies are still wrong. Go to an airshow and see how many fly in after dark
Have it your way
ME? i will just do the right thing
Hell you might want to try the "tell tail thing"
The first anti-colisio0n lights were on the tails of beeches and cessna in the late fifties to meet the certification process of that time. You didn't see the DC3's AND beech 18's going out and putting lights on then did you?
In 71 the beacon rating went up to 400 candle power on new planes built after that date. Anyone remember updating beacons then? Of course not because it was only for new aircraft and the FAA does not go back and require Douglas , Lockheed, etc to retrofit and recert there already certified aircraft. Want to recert T' Crafts and who knows what else over a light?
In 1994 my FAR /AIM says the exact same thing it says now in 91.05 C 3 about al US aircraft.
Also 91.209 says the same thing word for word in 1994 as it does in 2004
Just wait til i find a really old one!
Now if your Germ , Jap or Saudi, i guess you can dam well do as you please as long as you get , Drop your inport shit off and get out of the USA

SOO YOU NON BELIEVERS, Tell me this . You can't be a day late at Blockbuster Video or the IRS tax bill and they get your ASS. and you believe the FAA can't Figure this out by now?

IT TOOK US 10 + YEARS TO FIGURE THIS OUT.? BUULLLL SHITTTTTTTTTTTTTTT.

ITS ALL IN PART 23.401 READ IT .
99 percent of the FAA guys did and still do UNDERSTAND it. JUST because you found one or two IDIOTS that you somehow convinced you were right , Don't think ALL the FAA boys are with you on this
NOW go work on Abortion or hug some friggen tree and let the real Aviators get on with their lives and rights here in the old USA
!@#$%^ ASSHOLE whiners

YES Jim , we do need panal lights
I have post lighting but they punch a hole in the head in a crash
Wear a helment?

A first grade teacher explained to her class that she was a liberal
> Democrat. She then asked her students to raise their hands if they were
> liberal Democrats, too. Not really knowing what a liberal Democrat was,
but
> wanting to please their teacher, hands exploded into the air like fleshy
> fireworks. There was, however, one exception. A girl named Lucy had not
gone
> along with the crowd. The teacher asked Lucy why she decided to be
> different. "Because I'm not a liberal Democrat," Lucy said. The teacher
> asked, "Then what are you?" "I'm a proud conservative Republican" said the
> little girl. The teacher (a little perturbed & red-faced) asked Lucy why
she
> was a conservative Republican? Lucy proclaimed, "Well, I was brought up to
> trust in myself and freedom, instead of relying on an intrusive government
> to care for me and do all of my thinking. My Dad and Mom are conservative
> Republicans, and I am a conservative Republican too." The teacher calmly
> pointed out, That's no reason. What if your Mom and Dad were both morons?
> What would you be then?"
>

> Lucy answered, "Then, I'd be a liberal Democrat."



Guess i got myself confused with someone who gives a rats ass
>
IM THROUGH GOOD NIGHT AND GOOD BYE
>