Date:
December 16, 2005 10:48:39 PM EST
Subject:
COZY: DAR Update on my LED/Strobe
lights for Phase II
For all of you who have
read my posts since June 05 relating to my very tough DAR on my wingtip
LED/strobe lights, here is an update.
As you will recall, I have non-TSO'ed lights from gs-air.com. They are really
cool, bright and uses 4 amps for two strobes and four position lights. My DAR
would not sign off Phase II with those lights with the language of "Unless
appropriately equipped for night or IFR flight, ..." which would allow me
to make a logbook entry to fly at night. My DAR would only give me Phase II
with VFR day only restriction because he interpreted the words "approved
anti-collision light system" in FAR 91.205(c) to mean only approved by the
Administrator. My DAR's boss in the Louisville FSDO office sent me an email
saying that their position is that I must have "approved"
anti-collision lights, i.e., TSO or PMA or a field approval. Since PMA does not
exist for experimentals and Atlanta
or any DER would not give me a field app roval, I was told that if I wanted to
flight at night, all of which night equipment is required for IFR, I must have
TSO'ed wingtip lights. Nat and everyone else said to get another DAR, so the
following is my report.
I have talked with EAA in Oshkosh (Joe Norris
who was very helpful) and they put my in touch with a DAR in Illinois
in the MIDO office, whose boss/Prinicipal Investigator (PI) is in Vadalia, OH.
Vadalia is in my region or district. They told me today that although my
analysis of the FARs and evidence showing that my wingtip lights meet or
exceeds the airworthiness standard for approved position/anti-collision lights,
that they would have issued me the above quoted language if I had originally
applied for my airworthiness certificate from them, BUT that since I started
out in FSDO, I am subject to their mercy as I can not escape from the FSDO
office in Louisville. So, there you have it. I must change my very cool, slick
LEDs for old technology which draws about 15 amps (strobes and nav lights) from
Whelen as they are the only TSO'ed lights that I have found. Of course, Whelen
lights are almost $900. So, the little man has lost and the moral to this story
is GO TO THE NATIONAL EAA TO GET A DAR FROM YOUR LOCAL MIDO OFFICE BEFORE YOU
APPLY FOR AN AIRWORTHINESS CERTIFICATE, even if a local FSDO DAR was recommended
to you. After my problem with my lights, need I say more. All of you guys still
building (which I am after flying 25 hours--you know, still tweaking) MUST
learn from my mistake. Don't get involved with the FSDO office as you will be
in a world of hurt ($$$$) very fast.
Matt Bunch
Lexington, KY
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