I don't find it particularly useful after para 2.1.3. We should respond to this - closing date is 11th Nov.
Of course the topical subject is external camera installation which is mentioned in para 2.1.4:
For the purposes of this AC, external equipment is a piece of equipment that protrudes into the airflow (e.g. cameras, sensor units, nightsuns, forward looking infrared system).
Then goes on to state:
2.3.1 An aircraft is eligible to remain in its currently approved category if the operational
airspeed/flight envelope is:
defined
flight tested
within the airspeed/flight envelope defined for the type design
compliant with applicable airworthiness standards that have been identified in the
compliance summary for the design change.
All very vague which of course it has to be as the method of showing compliance will depend on stuff like the size/shape (including number) of camera, location of the camera(s) and characteristics of the aircraft but not every installation would need to be flight tested. I also would've expected mention of "minor" and "major" with a pointer to AC 21-15, Supplemental Type Certificates.
I always like to consider the extremes of the scope to test the sensibility of something like this. I recently saw a photo of an Otter carrying a Cessna fuselage externally - OK, the draft AC covers this. So does common sense in my opinion.
Now for my mini digital camera. I am sure that I could find a place to put this on my biplane such that some conservative calculations (per Hoerner, no need for CFD) would demonstrate no "appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the aircraft, aircraft engine or propeller." Leading to a much more simple approval process than directed by the conclusion of the AC.
This sentence in para 2.2.3.1: "it may be necessary for CASA or an authorised person to request flight test validation" is quite sensible but contrary to para 2.3.1 quoted above.
Perhaps some-one could ask CASA to define "modification"at the same time?
J.T. and O Akro, what do you think?