How the FAA Works Against Safety
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.
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. Like I said, common sense. There are little capillaries of it in the FAA, but the veins run dark with baffling illogic and flawed thinking.