Oil Temperature & Landing Light

[chanik]

Chanik,

I recommended a LOA for the LED landing lamp for two reasons. First is because I do know of ASI's who seem to be on point with regard to LED lamps. If one of those types of inspectors was familiar with the CT, and saw one taxi in with an LED lamp, I can invision a possibility for a discussion with the pilot. Doubtful that it would go anywhere, but landing lamps may as well have a bulls-eye on them when you are on the ramp. An LED dome lamp alteration for example would be much more benign.

 

I did just mean an MR16 drop in replacement, not an alteration. I have alot of experience with EE stuff and with regulatory legal language, but the bulb thing is indeed a grey zone. When I got my plane converted to E-LSA, working directly with the FAA, I found myself walking them through the regs, not the other way around. Since landing lights are non-essential, I doubt the ASI would care. They are really after serious saftey of flight violations. I doubt there are any enforcement actions ever on this front, but they would be impossible to find if ever there were one. The FAA database is not searchable and the detailed reports they do reference are not even online. If they were to try to violate an S-LSA, they would have to argue that the new LED bulb was not a standard part (which the FAA does define http://www.faa.gov/aircraft/safety/programs/sups/standard_parts/media/standard_parts.pdf ) Note the reasoned FAA intent is to make it easier to use equiavalent parts by forcing the part OEM and Type certificate holder to describe their parts to published spec's. FD just calls out an MR16 bulb holder assembly in their parts manual; nothing in the AOI or maintenance. So there is no real regulatory restriction on landing light bulbs from FD so long as the thing fits. Any ASI pursuing this is likely to get chastised by his boss for wasting time on minutia more than anything else. But it can often be helpful to be able to quote the regs to bolster your case. Like I said, many of these guys are fuzzy on the detailed regs themselves.

 

BTW the transponder is a very special case as it is covered directly by the FARs. That and ELTs are required to be TSOd equipment.

[Doug Hereford]

Chanik,

 

FAA can be fuzzy on the Regs. for sure. In my experience, they don't much understand the concept of wasted time (government?).

 

If it is not an alteration, no LOA needed. I would put myself in a firm position to explain this.

 

Like I said, landing lamps are not inconspicuous. I do know of inspectors that might make an issue of this especially in a setting where they see 15 aircraft of a certain type operating with incandecent lamps one day an then LED the next. It would probably start with him saying "Wow those sure are nice bright lamps. Bet you saved the owner a bunch of money switching to LED landing lamps on the training fleet. I didn't know those were approved."

 

As for the transponder example, I got a little of topic, but I do believe that the FAA has done a poor job of making SLSA MFG comply with their responsibilities regarding continued airworthiness. That is no relief for us in the field however, and FAA approved parts with AD's against them are a part of SLSA. The GTX-330 is just one example.

 

Doug Hereford

[chanik]

That I think is the real risk, some caviling ASI with too much time on his hands. The regulatory, letter of the law defense, if antagonised by such a person on a ramp check, is that the new bulb fully complies with the standards set forth by the manufacturer, FD. Complies, in this case, just meaning it is a light bulb that fits. ;-)

 

The FAA complaints about SLSA OEMs, incidently, is largely about doing a poor job assuring ASTM compliance with their 'standard' parts and more egregiously, pencil-whipping the inspections of major parts really manufactured elsewhere by some local person at the importing location who does not even have the knowledge to certify compliance.

[Doug Hereford]

I guess I can start using the 3 cell mag lite lamps in my two cell mag lite. Ha. Ha.