LOA For LED Strobes

H. Paul Shuch is a Light Sport Repairman with Maintenance ratings for airplanes, gliders, weight shift control, and powered parachutes, as well as an independent Rotax Maintenance Technician at the Heavy Maintenance level. He holds a PhD in Air Transportation Engineering from the University of California, and serves as Director of Maintenance for AvSport of Lock Haven.

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JJ Campbell
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LOA For LED Strobes

Post by JJ Campbell »

Due to the Pandemic, the Italians are only processing LOAs for ADS-B. I put my newly acquired SLSA Tecnam P92 Eaglet in for several service items a month ago. One of the repairs was replacing the incandescent strobe lights with LED lights. After a month in the shop all the repair items are almost complete. However, the mechanic is not sure if she can sign off on the plane's airworthiness until after the Italians issue an LOA for the new strobes.

Tecnam in Florida says that it is up to the mechanic and they imply that it won't be a problem since an incandescent to LED change is no big deal and the Italians have never denied one of these LOAs and "strictly speaking an LOA for the strobe lights is not required."

Does anyone have definitive answer as to whether or not the mechanic can sign-off on the aircrafts airworthiness and then get the LOA approval whenever the Italians are back up and running?
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Re: LOA For LED Strobes

Post by drseti »

A proper logbook endorsement for any modification to an SLSA should state that the work was performed "in accordance with..." and specify the document number and date of issue of the LoA. I personally would not even begin a modification without having an LoA in hand, let alone signing off the work. Your mechanic may feel otherwise, and I know of no FAR that would prevent him or her from signing it. But, if the aircraft comes due for a condition inspection before the LoA materializes, and the inspector happens to notice the modification, he or she may hesitate to sign it off! So, there's always a risk of proceeding before the LoA is issued.

I am on the verge of replacing a 7" Dynon SkyView in my panel with a 10" one. I have secured the device, planned the install, and applied for an LoA a couple of months ago. The person who will issue the LoA was off work for a month due to a COVID-19 related shutdown, is back now, and I expect the LoA within a few days. However, I am NOT taking my plane out of service to do the modification until I have the LoA in hand. Perhaps an overabundance of caution, but that is my approach.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
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AvSport LLC, KLHV
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Re: LOA For LED Strobes

Post by drseti »

JJ Campbell wrote:"strictly speaking an LOA for the strobe lights is not required."
I don't doubt that's what Tecnam USA told you, but as I read the ASTM standard, it appears that any modification to an SLSA does indeed require an LoA, unless the equipment being installed already appears on the manufacturer's approved equipment list.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
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Re: LOA For LED Strobes

Post by 3Dreaming »

Part of the LOA process is to make sure that the aircraft is maintained within ASTM standards. Another part of the LOA process is for the manufacture to keep records of any change made to one of their aircraft. This is also a ASTM requirement. If you are confident that the change complies with ASTM standards, and you have formally notified Tecnam of the change you should be okay. The only problem would be if they chose not to approve the installation for some reason. Then you would hqave to remove or modify your installation to meet their requirements.

As far as regulations are concerned I am not aware of anything that requires having the LOA in hand before the modification. Considering the circumstances I doubt there would be an issue unless you don't do your due diligence in making sure the paperwork is in order as soon as possible.
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Re: LOA For LED Strobes

Post by Type47 »

Once again, Tecnam refuses to come out with an approved equipment list and burns one of their customers.
Someone else has no doubt already installed the same led strobes on their Tecnam with a Loa.
Tecnam probably installs the same ones on their new aircraft.
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JJ Campbell
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Re: LOA For LED Strobes

Post by JJ Campbell »

Type47 wrote:Once again, Tecnam refuses to come out with an approved equipment list and burns one of their customers.
Someone else has no doubt already installed the same led strobes on their Tecnam with a Loa.
Tecnam probably installs the same ones on their new aircraft.
Oh, it is worse than that. Tecnam was a late adopter of the LED lights despite the fact that the incandescent lights caused numerous problems due to drawing too much power and were prone to burning out the light's power supply - my used plane had two power supply replacements and were INOP again when I purchased the plane. The Eaglet I used for primary training was issued an LOA for the LEDs and Tecnam in FL indicated that is was pretty much a rubber stamp deal (when the Italians are not under lockdown).

Despite all this, Tecnam has only issued a blanket LOA for the headlight. Why, why I ask...
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Re: LOA For LED Strobes

Post by 3Dreaming »

Have your mechanic call your local FSDO and ask them to provide an approval so the aircraft can be returned to service. Explain that the approval is stalled because of the COVID 19 pandemic in Italy, and that you have made a formal request. Also let them know that you have been told by the US representative that the same installation has been previously approved.

Maybe suggest that the approval only be valid until the LOA is provided by the manufacture.
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Re: LOA For LED Strobes

Post by JJ Campbell »

3Dreaming wrote:Have your mechanic call your local FSDO and ask them to provide an approval so the aircraft can be returned to service. Explain that the approval is stalled because of the COVID 19 pandemic in Italy, and that you have made a formal request. Also let them know that you have been told by the US representative that the same installation has been previously approved.

Maybe suggest that the approval only be valid until the LOA is provided by the manufacture.
That sounds like a great idea! Thanks. Although I'm not sure that the FAA has any say over an ASTM Standards A/C but it is worth a shot.
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Re: LOA For LED Strobes

Post by 3Dreaming »

In the regulations there is nothing preventing the mechanic from signing the aircraft off, but there is a regulation regarding operation of the aircraft that requires approval of the alteration. If you don't have approval you can't fly it. The regulation that covers this is CFR 91.327, (b), (5) Each alteration accomplished after the aircraft's date of manufacture meets the applicable and current consensus standard and has been authorized by either the manufacturer or a person acceptable to the FAA;
I would think a maintenance inspector with the FAA should be acceptable under these circumstances.
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Re: LOA For LED Strobes

Post by drseti »

I don't know about your FSDO, JJ, but mine is closed, with all the inspectors working from home. The good news is, that leaves nobody to enforce the FARs. :wink:
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
[email protected]
AvSport.org
facebook.com/SportFlying
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Type47
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Re: LOA For LED Strobes

Post by Type47 »

Tecnam went back and forth on mine when I replaced the artificial horizon with a G5. They made us redraw the schematic and re-install the steam gauge airspeed indicator as backup even though the new Tecnams being sold at the same time used only a G5 as primary.
Their excuse for not giving a blanket approval was “liability”.
They were worried about how it would be installed. Ridiculous because Garmin specifies all installation requirements.
We all know that the approved equipment list can, and always does, specify that installation must meet astm and manufacturer standards.
I changed my SLSA to ELSA last spring.
Best day ever.
Type47
LSRI
INTJ
2006 Tecnam P92 Echo Super
Don’t do the thing that almost killed you until you at least get the staples taken out of your head first….
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