Our flying club is operating an SLSA that has all the exterior lights as required by FAR 91.205(c). But don't the instruments that are also required by 91.205(b) need lights as well?

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    $\begingroup$ note SLSA planes are not operated with a "standard category U.S. airworthiness certificate", as 91.205(a) targets. It comes back to op limits from the manufacturer- for instance, the RV12SLSA POH says "Night flight is prohibited (unless equipped with optional lighting)." $\endgroup$ Feb 26, 2022 at 17:34

2 Answers 2


An SLSA does not have a "standard airworthiness certificate," and thus 91.205 does not appear to apply at first glance.

However, 91.327(f) applies:

The FAA may prescribe additional limitations that it considers necessary.

Some of these "additional limitations" can be found in FAA Order 8130.2J:

Night flight and instrument flight rules (IFR) operations are authorized if allowed by the AOI and if the instruments specified in § 91.205 are installed, operational, and maintained per the applicable requirements of part 91.

This is a standard "operating limitation" for SLSA aircraft, and so should appear on the special airworthiness certificate, and means that 91.205 applies to SLSA the same as for normal category aircraft, when used for night or IFR flight.

That said, cockpit lighting simply isn't legally required by part 91 for night VFR flight. Unless it says otherwise in the POH, flying without cockpit lighting is perfectly legal. But remember that legal doesn't always mean safe!


Cockpit lighting is not required to be present as required Night VFR equipment under Part 91 general flight rules. That being said, there is the following Part 23 Certification Requirement for external and cockpit lighting.

§23.2530 External and cockpit lighting. (a) The applicant must design and install all lights to minimize any adverse effects on the performance of flightcrew duties.

Under the terms of this regulation one could make the argument that an OEM applying for a normal category type certificate will need some type of effective cockpit illumination to minimize adverse effects on aircrews.


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