In an airplane which is only equipped with a beacon for anticollision lights (1967 Piper Cherokee, for this example), what is the effect of an inoperative beacon? Obviously, per part 91.205, anticollision lights are required equipment for VFR Night. But, since the aircraft was certificated before 1996, it is not required under 91.205 for VFR Day.

Now, the interesting part is, under 91.209, since the aircraft was equipped with anticollision lights, it sounds like the aircraft would not be airworthy.

The guidance I've heard on this seems to be conflicting. One argument was since the equipment was disabled and placarded, it doesn't qualify. Alternatively, in 91.213(d)(2)(iii) (also referenced by AC 97-61 figure 2), it states that if the equipment is required by part 91 FARs, (91.209 seems to apply here), it is unairworthy (and deactivating/placarding is not an option).

A final point of confusion, specific to this in example: the beacon was an optional feature of the 1967 Cherokee according to the manual... which brings me here: any other opinions, short of a more formal clarification? I'm inclined to err on the side of caution, especially since the definition of "equipped" isn't getting any clearer (other than seeing that little red light on there and the "inop" marking on the panel).


The answer to your question is in FAR 91.205:

91.205(b) - Visual-flight rules (day):

(11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made.

and 91.205(c) - Visual-flight rules (night):

(3) An approved aviation red or aviation white anticollision light system on all U.S.-registered civil aircraft. (it goes on to talk about color, which I've cut out) In the event of failure of any light of the anticollision light system, operations with the aircraft may be continued to a stop where repairs or replacement can be made.

So as you surmised in your question, a 1967 Cherokee is required to have an operating anti-collision light for Night-VFR operations (because the night anti-collision requirement is retroactive and doesn't care about certification date), but not for day Day-VFR operations (because it was certificated prior to 1996).

If you HAVE an anti-collision light it is required to be operating subject to FAR 91.213. The relevant part of that regulation says that you can take off with inoperative equipment provided that equipment is 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

You're OK for Day VFR because CAR3 (and FAR 23 prior to 1996) didn't require an anti-collision light for daytime operations.

(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;

Your Cherokee predates the concept of a Kinds of Operations Equipment List in small aircraft by several decades, so your reference is 91.205.

(iii) Required by §91.205 or any other rule of this part for the specific kind of flight operation being conducted;

If the kind of flight is "Day VFR" the anti-collision light is not required by 91.205, but if you want to fly at night it is required (as we determined previously from 91.205).

(iv) Required to be operational by an airworthiness directive

No such Airworthiness Directive exists for anti-collision lights on the PA-28 family.

…so per 91.213 you can placard the beacon switch INOP and "deactivate" the anti-collision light (simply putting a bit of masking tape on the switch holding it in the off position & writing INOP on that is generally considered adequate) and fly in Day-VFR conditions (ideally to an airport where you can get a replacement lamp for your beacon).

Note that the fact that your beacon was optional equipment doesn't enter into the decision tree for 91.213: Any installed equipment gets evaluated according to this regulation. As an example my (1965) Cherokee has both a tail beacon (originally installed by Piper) and a belly strobe (added by someone over the years): if either is inoperative it needs to be "deactivated and placarded" appropriately.

  • 1
    $\begingroup$ Well, whoever said flying was easy... $\endgroup$
    – Radu094
    Mar 24 '15 at 16:45
  • 11
    $\begingroup$ @Radu094 Flying is easy. Landing is hard. Comprehending the regulations is impossible. $\endgroup$
    – voretaq7
    Mar 24 '15 at 18:10
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    $\begingroup$ Yeah, the confusion comes in because as you mention, 91.213(d)(2)(iii) says "or any other rule of this part" and 91.209(b) requires lighting it if "equipped." Still, thank you for the extremely thoughtful answer! $\endgroup$
    – dougk_ff7
    Mar 24 '15 at 18:30
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    $\begingroup$ @dougk_ff7 Ah, I forgot about 91.209(b) - That could be interpreted to require you to have a working anti-collision light if the aircraft is equipped with one (same logic as 91.209 - optional or added later doesn't matter) unless "If because of operating conditions, it would be in the interest of safety to turn the lights off". (See what I mean about "Comprehending the regulations is impossible"? Everything is in at least 3 places :-P) $\endgroup$
    – voretaq7
    Mar 25 '15 at 15:25
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    $\begingroup$ @dougk_ff7 & voretaq7 Does anybody want to volunteer to ask the FAA for clarification? 91.209(a) deals with lighting requirements during nighttime operations (or what passes for such in the Alaskan summer). This leads me to think that 91.209(b) is primarly intended to explicitly allow pilots to switch off the anticollision strobe lights during nighttime operations on taxiways and ramps (where they could blind other pilots), and in IMC conditions (where they can be disorienting). $\endgroup$
    – habu
    Apr 30 '15 at 9:02

A working anti collision light is not required for the 1967 Cherokee because the key statement in 95.205b11 is for aircraft certificated in accordance with FAR part 23. A Piper Cherokee was certified under CAR (civil aviation regulations) part 3, not FAR part 23 (See TCDS 2A13). Therefore this sub paragraph does not apply to that aircraft. If, and only if, this aircraft is operated at night (as specified in 91.209 the light would be required...but not for Day VFR.


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