If the map (reading) light bulb is burned out in my own Cessna 210, what are my options if I want to fly FAR Part 91 under night-time VFR staying in the traffic pattern doing touch and goes?
It comes down to the complexity of the work.
For many years, the FAA treated the 32-item list in 14 CFR Appendix A to Part 43 as exhaustive. The interpretation was that if an item or procedure did not appear in section (c), then it was not preventive maintenance. Case closed.
However, in 2009 the Coleal Legal Interpretation, produced by the FAA's Office of Chief Counsel, superseded the prior rules. It specifically calls out and contradicts the understanding that the 32-item list is exhaustive.
Even though the introductory text of subparagraph (c) states that “[p]reventive maintenance is limited to the following work ....” (emphasis added), in view of the broader definition of preventive maintenance in section 1.1, we believe that such limitation is not controlling. Similarly, for the same reason, we also believe that the following sentence in Advisory Circular 43-12A … is overly restrictive. That sentence, found in Paragraph 3(b)(1), states: “If a task or maintenance function does not appear in the list, it is not preventive maintenance.” As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category – they cannot be considered all-inclusive. There are, no doubt, many “simple or minor preservation operations [tasks]” and many “replacement[s] of small standard parts not involving complex assembly operations” performed daily, especially on small general aviation aircraft that the agency would consider to be preventive maintenance, though they are not included in the 32 listed items. It is our understanding that Flight Standards' Aircraft Maintenance Division is planning to clarify this issue in a future revision to the AC.
In short, the list of 32 items is not exhaustive.
So we know that there is preventive maintenance which can be done which does not fall on the list. However, this does not imply that all maintenance is preventive. The specific question has to do with the map light.
Looking through 14 CFR Appendix A to Part 43, we find:
(c)(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
So it is clearly within the domain to replace exterior bulbs. The question becomes whether accessing the interior map light bulb in a Cessna 210 is low complexity or high complexity.
Your A&P might be able to give you some guidance, although IMHO a good yardstick is that any part designed to be IRAN'ed with nothing more than a Swiss-army knife is pretty clearly "low complexity" and should fall under owner preventive maintenance.
First, is the map light required for night VFR under part 91? 91.205(b) and (c) list required VFR equipment for day and night operations, and a map light isn't on the list.
Second, is the aircraft airworthy for night VFR without it? That depends on what the POH says. I Googled a couple of 210 POHs and found wording like this:
The airplane is equipped for day VFR and may be equipped for night VFR and/or IFR operations. FAR Part 91 establishes the minimum required instrumentation and equipment for these operations. The reference to types of flight operations on the operating limitations placard reflects equipment installed at the time of Airworthiness Certificate issuance.
I believe that means the aircraft is airworthy for night VFR if it meets the part 91 equipment requirements, but it's also a reminder that you have to operate it in accordance with all placards (per 91.9). As far as I can see, the type certificate for the 210 doesn't include a placard requiring the map light to be operable. In fact, it doesn't seem to mention the map light at all. (Some more modern Cessnas have a detailed list of equipment required for airworthiness; see this question.)
So unless your POH says something different, it looks to me like you're good to go as long as you placard the light as inop first, or deactivate/remove it (and log that, if required). 91.213 talks about "inoperative instruments or equipment", which is a pretty broad description and it would be best to comply even if it's unlikely that anyone would notice or care if you didn't.
As for changing the light bulb, at least one POH I found includes instructions for the pilot on how to replace the map light bulb in flight. It seems unlikely that they put that in there only for pilots who routinely fly around with an A&P on board :-) Having said that, part 43 Appendix A only includes landing and position light bulbs in preventive maintenance, and AC 43-12A says that the list isn't open to interpretation:
Part 43, appendix A, paragraph (c) contains the Federal Aviation Administration’s (FAA) list of tasks that meet the requirements of the preventive maintenance definition. If a task or maintenance function does not appear in the list, it is not preventive maintenance.
So far, it looks like you do need an A&P. But, there's a generic exception in the list of preventive maintenance tasks in Appendix A:
The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program
If there's a "special inspection and preventive maintenance program" (whatever that means exactly) for the 210 that includes the map light, then you would be allowed to change it without requiring an A&P.
In reality, I'd be willing to bet that 99% of pilots would just change the lightbulb themselves, whatever part 43 says. They could always point to the POH instructions as evidence that Cessna considers it to be preventive maintenance.
Change the light bulb yourself (non- A&P mechanic) and go. Owner maintenance is legit for minor items like that.
A map or reading light is not part of the Required Equipment List for night VFR or night IFR.
You are free to go with just a flashlight if you want.
(Technically, you don't even need that)
