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08/30/10 01:15PM

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FAA

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LED

How the FAA Works Against Safety

AvWeb Blog

By Paul Bertorelli

I know by firsthand experience that AVweb finds its way into the upper reaches of the FAA's HQ

at 800 Independence Avenue in Washington. What I don't know is this: Do the gentle people

inhabiting FAA's mahogany row have a clue of how their lower minions are carrying out their

jobs? Do they have even the vaguest control over the far flung offices? Do they even care?

Would they be surprised to know that the FAA's actions are sometimes counter safety?

Here's where I'm going with this. For Aviation Consumer, I've been doing some extensive

research on LED lighting, specifically landing lights. This is, by the way, fabulous technology. It's

improving in leaps and bounds, it's getting ever cheaper and is becoming a significant market

force in the general lighting market. Yet the FAA has done its level best to keep these benefits

from trickling down to aviation.

Here's how: All of the manufacturers of these products have approached the FAA for some kind

of approval, even though it's not clear that any is needed. The FARs are vague on the subject,

requiring only that bulbs have enough light for night operations and not present a fire hazard.

That's it. The venerable GE 4509 bulb—the gold standard for landing lights—carries no TSO or

PMA of any kind. It's just a bulb.

Yet, say the makers of LEDs, they are often asked by regional FAA ACO offices to conduct a

battery of tests on LED products to prove…to prove what? A reading of the FARs would suggest

all they need to prove is that the bulb generates sufficient light and isn't a fire hazard. Even basic

common sense knowledge of LEDs can answer these questions without requiring expensive

tests, which one manufacturer told me ran to high five figures — and it still doesn't have the

approval.

Another said its ACO insisted that the LED behave just like a 4509--same too-narrow asymmetric

beam width and even the same mounting notch in the rim (wholly unnecessary). When I asked if

this didn't dumb down potentially improved technology to the limitations of the old, I was told

that...why yes, it does. That the product is still better than the 4509 is a testament to LED

technology.

Yet another company told me its ACO refused to approve a LED bulb, refused to explain how

such a product could be tested and approved and then said it was too busy to take on the project

anyway. This has forced some companies to shop for ACOs that have a more realistic approach

to the FAA's oversight and safety role. What that involves is an ACO culture that lucidly balances

benefit against risk. In other words, any fool with a lick of sense would know that LEDs are a

huge improvement over failure-prone incandescent bulbs and the risk of them causing any harm

to the aircraft is too trivial to worry about.

It's probably not unreasonable to ask a manufacturer to do simple RFI trials. But even that might

be overkill. At the FSDO level, some offices routinely approve Form 337 requests (good for them)

for LED installs while others refuse, for no imaginable reason other than they can.

Where the FAA's actions turn strikingly counter safety is that if more LEDs were out there, pilots

would tend to leave them on constantly, thus improving conspicuity and reducing the risk of mid-

airs. Moreover, LEDs can easily be configured as always-on flashers—some of the products out

there do that. Yet manufacturers have been reluctant to pursue the flasher approach because it

complicates an already Byzantine—and entirely unnecessary—approval process. So the bottom

line is, thanks to FAA actions, valuable safety technology is kept from the market for no particular

reason other than bureaucratic intransigence. Even when it does make it to market, it is more

expensive by dint of the make-work testing.

How the FAA Works Against Sa... http://www.aviationservicesdirec...

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Summary of content (2 pages)

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How the FAA Works Against Sa... 1 of 2 08/30/10 01:15PM http://www.aviationservicesdirec... AvWeb Blog, FAA, FAR, LED How the FAA Works Against Safety AvWeb Blog By Paul Bertorelli I know by firsthand experience that AVweb finds its way into the upper reaches of the FAA's HQ at 800 Independence Avenue in Washington.
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How the FAA Works Against Sa... 2 of 2 http://www.aviationservicesdirec... And by the way, if I wanted one of these LEDs for a certified airplane—and I do—I'd simply install it, approval or not. My interpretation of the FARs indicates I'm in compliance if the lamp provides sufficient light and doesn't present a fire hazard. I deem myself smart enough to determine both. Furthermore, since there's no such thing as an approved landing light bulb anyway, I'm miles away from the stench of unapproved parts.