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Thread: 1951 PA-18 Strobe Light 91.205

  1. #1

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    1951 PA-18 Strobe Light 91.205

    Can you placard INOP for daytime VFR a 1951 Supercub that has a wing strobe out?

    Under 91.205 I thought it was not required as it was certificated before March 11, 1996- but someone said that if you ever installed a strobe it has to be operational regardless of certifation date and its only not required if never installed.

  2. #2
    wireweinie's Avatar
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    Turn the switch off.

    Web
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  3. #3

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    Quote Originally Posted by wireweinie View Post
    Turn the switch off.

    Web
    Web- Does that mean it is not required?

    I am doing a rescheduled checkride in the plane in question.


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  4. #4
    wireweinie's Avatar
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    If you do not need it during the daytime, turn it off. Even if someone asked about it, just state that it's not required for day VFR flight. Not sure why it would be any type of issue.

    Any of you high time pilot types ever been questioned about this?

    Web
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    I think I agree - but for a while there, folks were saying that if a beacon were installed it had to be on for engine start. I do not recall seeing a regulation.

    Around here they taxi with strobes on day and night. I can think of only a few things less polite.

  6. #6
    wireweinie's Avatar
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    Quote Originally Posted by bob turner View Post
    I can think of only a few things less polite.
    Well, at least that we can discuss publicly, lol.

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    Funny thing - had an instructor type state that if your plane didn’t posses a beacon, it had to have strobes. And apparently they had to be on. I still don’t know if that’s accurate. So another worthless hearsay.

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    wireweinie's Avatar
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    Quote Originally Posted by Kid Durango View Post
    Funny thing - had an instructor type state that if your plane didn’t posses a beacon, it had to have strobes. And apparently they had to be on. I still don’t know if that’s accurate. So another worthless hearsay.
    91.205 requires 'anti collision' lights for day VFR if the aircraft is certificated after 11Mar96 (FAR 23). Optional before that.

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    Quote Originally Posted by bob turner View Post
    I think I agree - but for a while there, folks were saying that if a beacon were installed it had to be on for engine start. I do not recall seeing a regulation.

    Around here they taxi with strobes on day and night. I can think of only a few things less polite.
    Brilliant! Turn on all the lights and kill the battery. My old man woulda kicked my butt for starting with the lights on draining the battery. Then again, we didn't wear white shirts and black ties.
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  10. #10
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    This is likely the source of the information related to the use of anticollision lights

    https://www.faa.gov/about/office_org...rpretation.pdf
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    Interesting read. He did not address an aircraft with strobes only. I guess Mark has to fix his flasher?

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    wireweinie's Avatar
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    Quote Originally Posted by Grant View Post
    This is likely the source of the information related to the use of anticollision lights

    https://www.faa.gov/about/office_org...rpretation.pdf
    According to this letter, if you don't have an anti collision light installed, you cant start the engine.

    Web
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    Quote Originally Posted by wireweinie View Post
    According to this letter, if you don't have an anti collision light installed, you cant start the engine.
    I think that interpretation would only have any validity if the engine was to be started with the intention of "air navigation". Without the intent of air navigation the aircraft is not being "operated".

    Start and taxi around the airport for an hour, crossing all runways multiple times, and no need for anti-collision lights as long as you didn't intend to fly. Taxi the same route in the same visibility condition without the lights and then fly - busted.

    My PA-28 tail beacon is on all the time the master is on. My FX-3 strobes are on for run-up if not performed in a normal run-up area, for night runway crossing, and for flight. No complaints from ground or tower controllers and I don't plan to change.

    We pay tax dollars for these idiot rulings.
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  14. #14
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    Here’s the entire text of 91.209b:

    (b) Operate an aircraft that is equipped with an anticollision light system, unless it has lighted anticollision lights. However, the anticollision lights need not be lighted when the pilot-in-command determines that, because of operating conditions, it would be in the interest of safety to turn the lights off.

    It only applies if the aircraft is actually equipped with anti collision lights.


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    Quote Originally Posted by sjohnson View Post
    It only applies if the aircraft is actually equipped with anti collision lights.
    Sure, but the requirement to be equipped with anti collision lights is specified in 14 CFR 91.205 (b) (11).

    Whether they need to be lighted if fitted, but are not required to be fitted, is another rabbit hole.

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    Quote Originally Posted by Cardiff Kook View Post
    Web- Does that mean it is not required?

    I am doing a rescheduled checkride in the plane in question.


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    Use it as an opportunity to learn. Ask your DPE. Lights burn out. It shouldn’t be a game stopper.

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    Depends on the DPE. Some are so protective of their designation that a missing sheet metal screw will cancel the ride.

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    So lets pull this string.

    91.213 (d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided--
    (1) The flight operation is conducted in a--
    [(i) Rotorcraft, nonturbine-powered airplane, glider, or lighter-than-air aircraft, powered parachute, or weight-shift-control aircraft, for which a master minimum equipment list has not been developed; or]
    (ii) Small rotorcraft, nonturbine-powered small airplane, glider, or lighter-than-air aircraft for which a Master Minimum Equipment List has been developed; and OK, we are a non-turbine airplane so this paragraph applies
    (2) The inoperative instruments and equipment are not--
    (i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated; CAR 3 airplane certificated prior to March 11, 1996 (more later on this), not part of the VFR day certification
    (ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted; Don't have a Kinds of Operation List, and the Equipment List would not have Anti Collision Lights as required equipment since they aren't required under CAR 3 and not even listed on the TCDS.
    (iii) Required by Sec. 91.205 or any other rule of this part for the specific kind of flight operation being conducted; or Under 91.205, anti collision lights are not required on aircraft certificated prior to March 11, 1996, so not required.
    (iv) Required to be operational by an airworthiness directive; and There are no ADs requiring anti collision lights
    (3) The inoperative instruments and equipment are--
    (i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with Sec. 43.9 of this chapter; or
    (ii) Deactivated and placarded "Inoperative." If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and Must be deactivated (CB pulled and collared, wire disconnected and properly stowed, fuse removed . . .) the switch placarded and a maintenance record entry made by someone authorized to perform that maintenance task
    (4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft. An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator. So long as each of these provisions are met, the anti-collision light system can be rendered inop and placarded and the aircraft can still be legal to operate.

    91.209 (b)
    (b) Operate an aircraft that is equipped with an anticollision light system, unless it has lighted anticollision lights. However, the anticollision lights need not be lighted when the pilot-in-command determines that, because of operating conditions, it would be in the interest of safety to turn the lights off. Technically based on 91.213 actions above, it is no longer equipped, so this paragraph of the regulation no longer applies

    So long as you comply with the above, the aircraft is Airworthy (with regards to the anti collision system) and legal to operate that aircraft.
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  19. #19
    frequent_flyer's Avatar
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    Ok, I'll bite. Where can I find a "Master Minimum Equipment List" for a PA-18?







  20. #20
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    Quote Originally Posted by dgapilot View Post
    91.213 (d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided--
    (1) The flight operation is conducted in a--
    [(i) Rotorcraft, nonturbine-powered airplane, glider, or lighter-than-air aircraft, powered parachute, or weight-shift-control aircraft, for which a master minimum equipment list has not been developed; or]
    (ii) Small rotorcraft, nonturbine-powered small airplane, glider, or lighter-than-air aircraft for which a Master Minimum Equipment List has been developed; and OK, we are a non-turbine airplane so this paragraph applies
    I think you have selected the wrong paragraph. Since a PA-18 has no MMEL or MEL it is par (i) that provides the relief not para (ii).

  21. #21
    wireweinie's Avatar
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    Hey Cardiff. If this is worrying you, why not just fix the strobe?

    Web
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  22. #22
    wireweinie's Avatar
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    Quote Originally Posted by dgapilot View Post
    So lets pull this string.

    91.213 (d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List provided--
    (1) The flight operation is conducted in a--
    [(i) Rotorcraft, nonturbine-powered airplane, glider, or lighter-than-air aircraft, powered parachute, or weight-shift-control aircraft, for which a master minimum equipment list has not been developed; or]
    (ii) Small rotorcraft, nonturbine-powered small airplane, glider, or lighter-than-air aircraft for which a Master Minimum Equipment List has been developed; and OK, we are a non-turbine airplane so this paragraph applies
    (2) The inoperative instruments and equipment are not--
    (i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated; CAR 3 airplane certificated prior to March 11, 1996 (more later on this), not part of the VFR day certification
    (ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted; Don't have a Kinds of Operation List, and the Equipment List would not have Anti Collision Lights as required equipment since they aren't required under CAR 3 and not even listed on the TCDS.
    (iii) Required by Sec. 91.205 or any other rule of this part for the specific kind of flight operation being conducted; or Under 91.205, anti collision lights are not required on aircraft certificated prior to March 11, 1996, so not required.
    (iv) Required to be operational by an airworthiness directive; and There are no ADs requiring anti collision lights
    (3) The inoperative instruments and equipment are--
    (i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with Sec. 43.9 of this chapter; or
    (ii) Deactivated and placarded "Inoperative." If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and Must be deactivated (CB pulled and collared, wire disconnected and properly stowed, fuse removed . . .) the switch placarded and a maintenance record entry made by someone authorized to perform that maintenance task
    (4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft. An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator. So long as each of these provisions are met, the anti-collision light system can be rendered inop and placarded and the aircraft can still be legal to operate.

    91.209 (b)
    (b) Operate an aircraft that is equipped with an anticollision light system, unless it has lighted anticollision lights. However, the anticollision lights need not be lighted when the pilot-in-command determines that, because of operating conditions, it would be in the interest of safety to turn the lights off. Technically based on 91.213 actions above, it is no longer equipped, so this paragraph of the regulation no longer applies

    So long as you comply with the above, the aircraft is Airworthy (with regards to the anti collision system) and legal to operate that aircraft.
    DGA, serious question here: Can I sum up 91.213 by saying you can't fly with inop instruments/equipment that are required under the appropriate rules (VFR day or night, IFR day or night), unless it's to get maintenance done?

    Web
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  23. #23

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    Quote Originally Posted by wireweinie View Post
    DGA, serious question here: Can I sum up 91.213 by saying you can't fly with inop instruments/equipment that are required under the appropriate rules (VFR day or night, IFR day or night), unless it's to get maintenance done?

    Web
    Not sure I fully understand the question. If you are asking that to take advantavge of 91.213 you need to have maintenance performed, the answer is yes. That may fall under preventive maintenance in the form of pulling a CB to "Deactivate" an item and install the appropriate INOP placard. In any case, it does require a 43.9 record entry.

    If you are asking if an item that is INOP that is a required piece of equipment under 91.205 for DAY VFR (Altimeter, ASI, Compass, tach, fuel gages . . .) then no the aircraft cannot be legally flown until it is fixed unless it is on a special flight permit.

    If you are asking if something can only be inop to fly to a place where it can be repaired, the answer is no, see what follows.

    Under 91.213, if you read (d)(4) it says . . . An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator. In other words, once it is placarded and the required maintenance record entry is made, it has an acceptable minor alteration. Where it may get sticky is when we then go to 91.405(c) & (d) "Shall have any inoperative instrument or item of equipment, permitted to be inoperative by Sec. 91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and
    (d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by Sec. 43.11 of this chapter."

    So you are good to go until the next REQUIRED inspection then it needs to be repaired, replaced, removed, or inspected. The placard requirement of 43.11(b) says Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or Sec. 135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under Sec. 91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it "Inoperative," and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.
    Last edited by dgapilot; 06-09-2022 at 02:39 PM.

  24. #24
    wireweinie's Avatar
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    Quote Originally Posted by dgapilot View Post
    If you are asking if an item that is INOP that is a required piece of equipment under 91.205 for DAY VFR (Altimeter, ASI, Compass, tach, fuel gages . . .) then no the aircraft cannot be legally flown until it is fixed unless it is on a special flight permit.

    That's what I was getting at. Just making the point that if the equipment is required and inop, the aircraft is down. If the equipment is NOT required and inop, then the aircraft is also not down. Example being a com radio. As a radio is not required on the TCDS or for VFR flight, the aircraft may still be flown.

    Web
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  25. #25
    BC12D-4-85's Avatar
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    If something required under 91.205 except (11) goes inop in flight do we have to land as soon as practicable or continue to the intended destination for repairs?

    Gary

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    Quote Originally Posted by BC12D-4-85 View Post
    If something required under 91.205 except (11) goes inop in flight do we have to land as soon as practicable or continue to the intended destination for repairs?

    Gary
    I think that depends on what breaks and the pilots ability to cope with the issue considering weather, fuel, available runways and a lot of other issues. The regulation is silent on how soon you would have to land.

    I’ve spent a good part of my career flying broken airplanes. It is always a risk management issue. Keep in mind that AerBulletin 7a airplanes weren’t required to even have an ASI or compass. In my youth, I towed banners for several years. One airplane I flew was an L-19 that the ASI didn’t work, the battery wouldn’t charge, and the pressure carb had a leak in one of the diaphragms so it would not idle. Being young and stupid, I flew it that way the entire summer. Again, it is all about risk management!


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    Quote Originally Posted by frequent_flyer View Post
    I think you have selected the wrong paragraph. Since a PA-18 has no MMEL or MEL it is par (i) that provides the relief not para (ii).
    isn’t this considered a mmel for a pa-18? https://fsims.faa.gov/wdocs/mmel/se%20rev%201.pdf

  28. #28
    frequent_flyer's Avatar
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    Quote Originally Posted by MoJo View Post
    isn’t this considered a mmel for a pa-18? https://fsims.faa.gov/wdocs/mmel/se%20rev%201.pdf
    Well that's a very interesting find - thanks!

    The existence of a generic Single Engine MMEL seems to conflict with the definition of MMEL in AC 91-67 para 6 (o). That definition says an MMEL is for a "specific type of aircraft".

  29. #29
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    Quote Originally Posted by wireweinie View Post
    Hey Cardiff. If this is worrying you, why not just fix the strobe? Web
    I'm amazed that Web is the only person to suggest this.
    That would be my first thought.
    Just fix it.
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  30. #30
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    Cardiff
    Assuming an old school strobe/camel back. Take the one screw out of the cover that holds the nav lens and strobe tube in place. Remove the three screws that hold the mount plate to the wing tip bracket. You may or may not need to remove the wing tip bracket (only one screw). Leave the nav light connected and separate the white, nylon, three pin connector for the strobe tube. Take that strobe tube and, after removing the opposite strobe tube, plug it into the connector on the opposite wing tip. Power up the strobes and see if it flashes. If no flash, the strobe tube is bad. If it flashes nice and bright, you have a power supply problem (if single power supply to each tube) or you have a bad wire connection (one power supply for all tubes). The majority of the time it's a burned out tube.

    Web
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  31. #31

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    Good suggestion. Just posted another thread about this but need to read up here. Somehow I missed the recent posts.

    Quote Originally Posted by wireweinie View Post
    Cardiff
    Assuming an old school strobe/camel back. Take the one screw out of the cover that holds the nav lens and strobe tube in place. Remove the three screws that hold the mount plate to the wing tip bracket. You may or may not need to remove the wing tip bracket (only one screw). Leave the nav light connected and separate the white, nylon, three pin connector for the strobe tube. Take that strobe tube and, after removing the opposite strobe tube, plug it into the connector on the opposite wing tip. Power up the strobes and see if it flashes. If no flash, the strobe tube is bad. If it flashes nice and bright, you have a power supply problem (if single power supply to each tube) or you have a bad wire connection (one power supply for all tubes). The majority of the time it's a burned out tube.

    Web

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