PSA Paddle Bulbs

[HRM]

8 hours ago, Marauder said:

Is that the Benz with mood lighting? There is one parked next to me at work. Always afraid I'm going to back into it when I back-in park.

Possibly, I didn't buy it for the lighting 

Anyway, it has little lights all over the place, including a lighted AMG logo on the door sills. It projects a MB logo on the ground when you open the door at night.

I fear Benz rage...

[Marauder]

8 hours ago, Marauder said: Is that the Benz with mood lighting? There is one parked next to me at work. Always afraid I'm going to back into it when I back-in park.

Possibly, I didn't buy it for the lighting 

Anyway, it has little lights all over the place, including a lighted AMG logo on the door sills. It projects a MB logo on the ground when you open the door at night.

I fear Benz rage...

The lady that owns the Benz next to me showed me the mood lights that she could change the colors. I will have to ask her about the logo on the ground thing.

[ArtVandelay]

let's assume the brightness is equivalent and there is no safety issue:

I change the nav lights to these paddle bulbs.  What can happen?  FAA sees it and asks me to switch back?  anything else?  Insurance company finds out?  any blowback from that?  What are the negative consequences if someone gets OCD and brings it up?

I would think keeping the old bulbs and switching them would be the worst that could happen or am I being naive?

Worst case is you have an incident or near miss and the other aircraft claims they could not see you.

[DXB]

1 hour ago, teejayevans said:

Worst case is you have an incident or near miss and the other aircraft claims they could not see you.

Yes that would indeed be a bad one. The lights themselves pose no hazard and likely even add a bit of safety for a modest price.  But right before I click "order" on Aircraft Spruce, I start hearing the voice of a rapacious plaintiff's lawyer going on about how my negligent and reckless decision to put in non-PMA'd paddle bulbs created widows and orphans.

[Yetti]

Then you realize the Grimes bulbs that are currently in there are not PMA, TSO, or STC either.  The best they have going for them is defacto standard.

If there were not regs and such.  My plane would look like a christmas tree. There would be steerable landing lights on the nose gear and wig wags all over the place.   Other pilots would want to fly near me just to enjoy the show.

Edited January 5, 2016 by Yetti

[DaV8or]

Interesting. I went to Spruce and checked these out. Indeed the red and green paddle lights come with this FAA/FAR logbook sticker saying things are all good, but they don't seem to offer any such drop in replacement with log entry sticker for the white tail light. When you check out those, they say "This is not PMA" these are not for certified aircraft. They don't seem to offer the quasi legal part for the tail. I find this weird.

[rbridges]

 

2 hours ago, teejayevans said:

Worst case is you have an incident or near miss and the other aircraft claims they could not see you.

47 minutes ago, DXB said:

Yes that would indeed be a bad one. The lights themselves pose no hazard and likely even add a bit of safety for a modest price.  But right before I click "order" on Aircraft Spruce, I start hearing the voice of a rapacious plaintiff's lawyer going on about how my negligent and reckless decision to put in non-PMA'd paddle bulbs created widows and orphans.

ironic how they could see an experimental plane with the same bulbs, but point taken.  Thanks.

[1964-M20E]

The only person I see saying anything about it is your IA and if you are really worried about it put the old bulbs in go to annual and then change them out when you get the plane back.

 

 

 

 

[HRM]

4 hours ago, Marauder said:

The lady that owns the Benz next to me showed me the mood lights that she could change the colors. I will have to ask her about the logo on the ground thing.

If that's what mood lighting is (colors), then I don't have it.

 

[philiplane]

 

The actual benefits of these bulbs seem to far outweigh the risks.   Can anyone articulate a definitive basis for calling these bulbs NOT legal?   If it's just a grey area and seemingly defensible, I'd install in a heartbeat.   Per manufacturer, their  compliance with FAR section 23.183-23.191 requirements would get you pretty close?  I assume the incandescent it replaces isn't an aviation specific bulb.  

The definitive basis is very simple. These lamps are not legal since they are not manufactured under a PMA. Anyone making replacement parts for Type Certificated aircraft must have a PMA. That's in 14CFR Part 21

The company does not have an FAA approval to produce aircraft parts. Because nav lights are required by regulation and the reg specifies TSO-C30c as the basis, any lamp you use must be conform to the TSO. Which means the company has to apply for evaluation of their product, pass the tests, be granted a PMA to produce them, and them mark them with the TSO number, FAA approval, and so on.

From the FAA: Who Needs A PMA? 
a. General Requirements. Title 14 of the Code of Federal Regulations (14 CFR) § 21.303(a) requires any person producing replacement or modification parts for sale for installation on a type-certificated product to get a PMA. A PMA is a combined design and production approval for replacement parts. Also we may use a PMA for the production of modification parts from supplemental type certificates (STC). The prior STC approves the design and installation of these modification parts in products. However, if any replacement part alters a product by introducing a major change, then 14 CFR § 21.113 requires an STC for the approval of these parts. See FAA Order 8110.4, Type Certification, for STC procedures.

Edited January 7, 2016 by philiplane

[PTK]

 

This is what came with the bulb.  They are not TSO, but they do satisfy the requirements.  Is the Grimes light TSO?  Just wondering.  I pulled an automotive bulb out of the tail. 
 

 

Two things:

The Grimes were installed by the factory and at the factory they can install anything they want!

That sticker expresses the "opinion" of the vendor selling these things and as such has no regulatory value. According to them they're not TSO'd but do satisfy the requirement. Well then, it stands to reason they can easily TSO them or alternatively, get Mooney to say they can be installed!

Legal Disclosure: I have no association with IHG. Furthermore, I did not sleep at a Holiday Inn last night!

[PTK]

 

let's assume the brightness is equivalent and there is no safety issue:

I change the nav lights to these paddle bulbs.  What can happen?  FAA sees it and asks me to switch back?  anything else?  Insurance company finds out?  any blowback from that?  What are the negative consequences if someone gets OCD and brings it up?

I would think keeping the old bulbs and switching them would be the worst that could happen or am I being naive?

Worst case I think would be having an accident or incident even and some sharp plaintiff's paralegal digs it up and finds out. Real worst case would be an injury or worst and have insurance co. decide to deny claims!

[N201MKTurbo]

I have asked 2 insurance adjusters about this. They both said that they won't deny a claim for unrelated maintenance issues. unless it was responsible for the accident. the reason is that if the word gets out, which it will, that company X denies claims for little BS items, people will stop buying insurance from them.

A lawyer suing you for the accident is another matter.

[philiplane]

If you did get asked about them by a curious FAA Airworthiness or Operations Inspector, and they wanted to press the issue, it gets ugly very fast. It doesn't matter what the part is or does, an Unapproved Part is the same big deal to the FAA.

They would cite you for operating an unairworthy aircraft, and each flight is an individual violation. As a Civil action, that's a $500 per flight fine, and as a Certificate action, it's generally 30 days per violation, but they have some discretion. If you installed them as a private pilot, you might get away with a letter of warning. If a mechanic installed them and was dumb enough to use the log entry shown above, he would probably get a 90 day suspension. This is based on similar Unapproved Part cases in the last few years.

The penalty all depends on how big of a deal it becomes. 

But the reality is quite clear, as nice as these might be, they aren't approved. Whelen has a great product in the Orion series, and there are some other options but they are also complete lamp assemblies. The main reason there are no drop in replacements is that is impossible to meet the "field of view" requirements with a drop in LED. You get blind spots, of which some people here have already noted.

[DaV8or]

 

If you did get asked about them by a curious FAA Airworthiness or Operations Inspector, and they wanted to press the issue, it gets ugly very fast. It doesn't matter what the part is or does, an Unapproved Part is the same big deal to the FAA.

They would cite you for operating an unairworthy aircraft, and each flight is an individual violation. As a Civil action, that's a $500 per flight fine, and as a Certificate action, it's generally 30 days per violation, but they have some discretion. If you installed them as a private pilot, you might get away with a letter of warning. If a mechanic installed them and was dumb enough to use the log entry shown above, he would probably get a 90 day suspension. This is based on similar Unapproved Part cases in the last few years.

The penalty all depends on how big of a deal it becomes. 

But the reality is quite clear, as nice as these might be, they aren't approved. Whelen has a great product in the Orion series, and there are some other options but they are also complete lamp assemblies. The main reason there are no drop in replacements is that is impossible to meet the "field of view" requirements with a drop in LED. You get blind spots, of which some people here have already noted.

Yep... Gotta get an experimental one of these days soon. This kind of crap is ridiculous. I have this pointless fantasy that the FAA will one day allow us to "de certify " our certified airplanes into the same sort of category as the E/AB folks have, but from what people say who are close to the FAA, that will never ever happen.

I've been looking at Velocities lately.

[Yetti]

Which is why I still can't understand and there could be a great case made.   My $1000.00 of flying electronics 100s of times more navigational/self flight  capabilities with 6 propellers is a FAA authorized aircraft able to operate in the NAS with old technology certified planes that can't use LED technology and will fall out of the sky if you let go of the yoke.

[HRM]

The simple reality is that the notion of a certified aircraft was created to protect life and property.

You cannot separate the notion of a certified aircraft from that of a licensed pilot.

As technology advanced, the idea of an idiot taking a ton or more of metal into the air and then having it come down at high speed pretty much anywhere is not an idea that I subscribe to.

At some point, they realized that the rules had to be partitioned to accommodate different aviation uses.

Always understand that the they is us. Non-aviators did not write the rules (they influenced them, yes). As Pogo famously said: we have met the enemy and he is us.

Since this is federally managed, nothing moves quickly. Just ask a physician about the FDA, or a telecom engineer about the FCC. Don't bother asking an attorney about the law in general, they will take a long time in responding and then bill you for their opinion. The fact that attorneys dominate the regulatory space in general is predominantly why the problem exists. Can we do without them? Regrettably, no.

We realized, as Americans, that we did not want to stifle ingenuity and personal invention. That is what the homebuilt space is for. If you want to play in that space, go there.

Lastly, we still ask incredulously: Why can't we just stick a better, cheaper product in our <certified> plane? The answer lies with the way the bureaucratic machine works. There is a concept at work here called rule and context regression. It affects how one rule change can have a devastating impact on other rules. Not unlike the so-called Butterfly Effect. It is too complex to go into here, just suffice it to say that one way around it is just do what you want to do and take your chances. Myler's law of insignificance comes into play and states that the more incredulously ridiculous and penny-ante the law is applied to your situation, the more likely you are to get away with infracting it.

[Yetti]

I think you just described several scenes  in Office Space

 

On the other hand there is the never talk to the cops theory of there are an uncountable (efforts have failed that tried to count them all) number of federal laws.   More than likely we all violate one per day.

[Shadrach]

 

The main reason there are no drop in replacements is that is impossible to meet the "field of view" requirements with a drop in LED. You get blind spots, of which some people here have already noted.

Really?  So it would be your contention that none of the new certified aircraft being delivered today have LED nav lights?

Could you expound upon this impossibility? Is it due to the nature of the technology? The shape of the diodes themselves? What is it that makes this an "impossiblity"?

[DaV8or]

 

Really?  So it would be your contention that none of the new certified aircraft being delivered today have LED nav lights?

Could you expound upon this impossibility? Is it due to the nature of the technology? The shape of the diodes themselves? What is it that makes this an "impossiblity"?

Remember, he is talking about a "drop in replacement" and by that I think he means a replacement LED bulb. The certified airplanes being delivered today with LED lights have complete LED fixtures and not just different bulbs. Having said that, I think he is wrong to say impossible. It is possible, just nobody really wants to spend the money to do it and get the government's blessing I guess.

[Shadrach]

 

Remember, he is talking about a "drop in replacement" and by that I think he means a replacement LED bulb. The certified airplanes being delivered today with LED lights have complete LED fixtures and not just different bulbs. Having said that, I think he is wrong to say impossible. It is possible, just nobody really wants to spend the money to do it and get the government's blessing I guess.

The paddle is a drop in, it requires zero modification to the existing fixture yet contains multiple diodes.  I have seen it compared to an incandescent in a dark hangar. It casts a wider, brighter light. In addition to the forward facing diodes, it also has diodes positioned around an arc that is 90 degrees off the nose.  It is superior to an incandescent in every way that counts: visibility, current draw, heat and longevity. I appreciate that we have and need regs and an enforcement agency to go with them. However, today's lighting is so vastly superior to what our planes were delivered with, the enforcement agency ends up stifling what should be an emerging market. The FAA should stay out of light approval, and just regulate specs. It is obnoxious that a mechanic cannot be trusted to verify a light installation. Think about how much wasted energy goes into writing, analyzing and enforcing something that many aircraft are exempt from (exp)... It's a waste of resources.

Edited January 9, 2016 by Shadrach

[DaV8or]

Testing the color, the intensity and the viewing angle of a bulb, or fixture is really, really easy. It seems too me that the FAA should just allow a simple demonstration test for each new bulb and fixture, then they would go on an "approved" list for all certified airplanes. In the case of the fixtures, as long as they use MIL spec, or AN hardware and conform to standard wiring practices they would be good to go. No silly STC procedures required. Basically a list of field approvals done at FAA HQ and valid everywhere. This is how the FAA could deal with things like this and save everybody lots of money and time, get new tech out there and be efficient with their budget.

[Shadrach]

 

Testing the color, the intensity and the viewing angle of a bulb, or fixture is really, really easy. It seems too me that the FAA should just allow a simple demonstration test for each new bulb and fixture, then they would go on an "approved" list for all certified airplanes. In the case of the fixtures, as long as they use MIL spec, or AN hardware and conform to standard wiring practices they would be good to go. No silly STC procedures required. Basically a list of field approvals done at FAA HQ and valid everywhere. This is how the FAA could deal with things like this and save everybody lots of money and time, get new tech out there and be efficient with their budget.

This is precisely the kind of program that would work beautifully when it comes to something as simple as lighting. It will never happen. 

[philiplane]

well, tracking us will be easy when everyone is ADS-B compliant. Then your transponder will allow Uncle to track your every move, and scarier yet, that information is kept basically forever if they store it like they store every other piece of aircraft and airmen documentation. 

It's probably coming for cars too, since they need a way to track mileage of electric and alternate fuel cars that aren't paying road tax...and to be fair, they'll just have to track everyone and send a nice bill every month.

[N201MKTurbo]

What are you talking about? Google and Apple are already tracking our every move. the government already records every transmission our phones make. They just need a court order to look it up.

It all became clear about two weeks after the Boston bombings when I heard a news story that said the FBI was able to retrieve a cell phone call made by one of the bomber's sister a month earlier. At that time she was just a random citizen. How can they do that unless they are recording everything. 

They keep talking about limiting their ability to store our metadata. Who needs metadata when you have the data? I think they are trying to pull the wool over our eyes.

if you don't want the government tracking you, get rid of your phone and computer, buy a shack in the woods and read books and live off the land.

Edited January 9, 2016 by N201MKTurbo