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Does the Name of something really matter?

claycookiemonster

Well Known Member
I started another thread in the General Discussion about Red Beacons, and where they might, or might not be mounted. In the course of that discussion, it was mentioned that if something was called a "beacon" you were required to have it operational, but somehow, if it was considered simply an indication of whether the Master was on, then it didn't matter whether it worked or not. I may have misunderstood what was being said, so please edu-macate me if I got that wrong.

In my previous airline life, we had an MEL, or Minimum Equipment List which listed various combinations of equipment which could be inop, and compensations that might have to be made sometimes. For example, the main engine generator could be INOP, but we'd run the APU in flight and could legally substitute that generator, and all was well.

Do we have the same capability here? Suppose I install two red beacons. Can I write somewhere in my operating limitations that only one needs to be operational for flight? If I have two alternators, an I grounded if one is inop, but the other is operational? Can I simply placard the beacon as "Battery On Indicator" and dodge the inop legality?

How does this work?
 
Well, my 0.02, FWIW. I believe you don't write Ops Limitations... your DAR on behalf of the FAA does.

As the builder, I guess you can write a BEL in your operating manual. For what that's worth.

As I recall the discussion, it was really about the FARs and what the FARs consider for anti-collision lighting. I think someone was trying to thread the needle of the regs and say that since their 'red flashing thingy' wasn't bright enough to be a legal (per the FARs) beacon light, it therefore ISN'T a beacon light, just some sort of other accessory not covered by the FARs.

Of course then, my issue is... what good is it? Folks were talking about strobe blinding people at night... when an anti-collision light is required. So you turn off your strobes and turn on the 'thing'. OK, no longer blinding people, but not legal. So I'm not sure what just got solved.

Requirements...
https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_20-30B.pdf

FAR 91.209
FAR 25.1401
 
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The FARs already allow the PIC to turn off anti-collision lighting ‘in the interest of safety’, e.g., blinding pilots on the ground.
 
Names for things

So you hit one of my peeves. We use names for things to communicate clearly. It works best when we use the correct names.

plate nut, or nut plate? (Plate nut is correct)

Sorry for the thread drift, you are asking about the requirement to operate a beacon if you have one. (yes). You are also required to operate a transponder if you have one. Giving it a different name doesn't help.
 
This thread started after the faa cited a pilot for flying day vfr with an inoperative anti-collision light. The pilot pointed out it wasn’t required equipment for day vfr, but the faa countered that if it was installed it was required to be used during the day. Above thread was a proposal to get around this rule by having a day-time beacon that didn’t meet the specs so if it wasn’t a real beacon it couldn’t be required! I think it’s easier to not placard a non-working beacon as ‘inoperative’, but rather, as ‘uninstalled’ or ‘removed from service’. As an EAB owner we can do that.
 
This thread started after the faa cited a pilot for flying day vfr with an inoperative anti-collision light. The pilot pointed out it wasn’t required equipment for day vfr, but the faa countered that if it was installed it was required to be used during the day.

In my previous airline life, we had an MEL, or Minimum Equipment List which listed various combinations of equipment which could be inop

Precisely why I have a Minimum Equipment List in my POH. Don’t know if it truly would stand up against FAA scrutiny but thought having one at least would give me something to check myself against on what was safe and legal (GOOSE A CAT + APES philosophy from my pp training 40 years ago) to fly if something was inop. Best to think it through way in advance and not when I have get-home-itis.
 
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Maybe I'm adding even more to the semantics discussion.

At work, the paperwork in the airplane logbook will say " deterred as per MEL..."

Why couldn't we deferr a broken beacon by writing "deferred as per FAR 123.45(example)". Basically write the regulation in the logbook that specifies the required equipment for day VFR or whatever you intend to, and can do.

Certified airplanes might be a bit different with a list of installed equipment, or similar in the POH.
 
I'm not trying to be sneaky here. I'm not interested in legalistic ways to fly an unsafe aircraft. However, from previous experience, I know there are ways to temporarily fly an aircraft, while awaiting repairs to an item which does not really affect airworthiness. Just curious how that might work in this realm.
 
Interpretation #duck

I would approach this like a math problem. Facts. Not a poetry interpretation.
I think the FAA would agree that things that look like, walk like, and quack like…They are ducks.

If you install the equipment, service it. If you don’t want to service it then don’t install it.
 
Just to clarify a couple of points;

You can't just make up your own minimum equipment list- it's part of the cert basis.

If the aircraft doesn't have a minimum equipment list, equipment list in section 6 of the POH (cessna) or a KOEL, then FAR 91.205 becomes the ruling document.

If it's required per FAR91.205, then it's obviously minimum equipment and legally required to be installed and working. If it's not something that's required, it can be removed or safetied and placarded "inoperative"

An example would be if you discover your landing light burned out and you then placard the switch INOP until you get around to replacing the bulb.

Yeah, I get, that landing lights can be part of the anti collision system, on the KOEL, whatever. It's just an example, work with me here :)
 
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