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Just ask your friendly Fed which light he'd rather have stuck in his face. A dull maglite or the built-to-blind SureFires and the like.
It's nay the length nor the breadth that counts, it's the squirt..........
The only problem with your statement is that you are not qualified to make that determination.That sounds equivalent to me.
Just out of curiosity, do the planes you fly not have flashlights provided within them (i.e. attached in some way to the plane at each pilot's station)? I guess some do and some don't... anyway, the "2 D-cell equivalent" only seems to apply to "flying equipment required" in Part 91, (FAR 91.503(a)(1)) and thus to the flashlights provided for you within the plane. Part 121 only references a "flashlight in good working order" and does not specify a cell size (that I can find, anyway). So unless your ops specs require D-cells or equivalent, I don't know why you would carry one.
I carry a Surefire A2 and it's brighter than hell, and no FAA guy or girl has ever given me a problem about it when I have been ramped. Only occasionally have they ever even wanted to see that I had a flashlight in my flight bag. I don't think any of them has ever asked me to turn it on.
Just out of curiosity, do the planes you fly not have flashlights provided within them (i.e. attached in some way to the plane at each pilot's station)?
Where I work, using the aircraft flashlights for walk around inspections is verboten; we must carry and use our own. The idea, I'm told, is to keep the aircraft flashlights fully charged at all times. Also, I just went through recurrent brainwashing class, and it was explained that the D-cell requirement is not applicable, because it is not listed in our OpSpecs.