Mounting Cameras etc.
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Mounting Cameras etc.
http://www.casa.gov.au/wcmswr/_asset...ftac23-1-0.pdf
Folks,
Several threads, over time, have discussed external mounting of cameras etc. The above is a draft AC that outlines what is needed for a normal cat.Part 23 certified aircraft.
The requiremenst will not be greatly different for aircraft in other categories, just the details of the who and how of making the modification legally.
Tootle pip!!
Folks,
Several threads, over time, have discussed external mounting of cameras etc. The above is a draft AC that outlines what is needed for a normal cat.Part 23 certified aircraft.
The requiremenst will not be greatly different for aircraft in other categories, just the details of the who and how of making the modification legally.
Tootle pip!!
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:
Then goes on to state:
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?
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).
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.
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.
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?
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djpil wrote:
The draft AC implies (by para 2.2.3.1 and 2.3.1) that everything needs to be tested:
Is there a conceivable ground test that would meet the intent of this (i.e. not requiring actual flight test?)
but not every installation would need to be flight tested
2.2.3.1: "the operational flight envelope must be defined and tested. This will require the applicant to propose and demonstrate, by test, their operational flight envelope"
There are legitimate ways an aeronautical engineer would calculate such a thing... but that would be too sensible 
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VD Design Drive Airspeed
Just wait until Mr CASA Inspector figures out that every fixed gear Cessna with spats removed needs to have it's operational flight envelope flight tested.
Suddenly, I feel very tired. Seriously, are we paying people to write this?
Firstly, there is no definition provided for equipment or airflow. Nor is there any definition of airframe.
What constitutes a piece of equipment protruding into the airflow? An HF antenna? VHF, GPS, etc? We are required to install new antennae for ADSB & 406 MHz ELT's. To the letter of this circular we now need flight testing when we change the GPS & Transponder antennae when an aircraft is upgraded to ADS-B or if a 406 HHz ELT is fitted. Want to remove a redundant ADF? That will require a report & flight test to remove its antenna too.
Thinking about installing a JPI engine monitor? If you take the OAT option, that will require a report & flight test.
How about a new aircraft cover? Aren't the press studs equipment that protude into the airflow?
The circular only gives guidance for airflow. Where does one look for issues such as structural integrity, free control movement or CofG.
It does not define " Flight test validation". Does it need to conform to the CASA guidelines for Flight Testing? Is it required to be conducted by a specialist? Can the owner do the test flight? Is a flight test report required according to the CASA Flight Test Guide? Is a risk management assessment according to AC 21-47 required?
It does not define "an authorised person" who is required to create the application. Is this what we currently refer to as CASR 21.M Authorised person? There are less than 30 of these people outside the airlines. They might be about to be busy.
After DJP going into detail with me about how CASA has omitted the minor mod exemption that exists in US law, I'm surprised he didn't get into this. The biggest problem is that CASA is treating a camera mount the same way as the modification to carry a space shuttle on the back of a 747.
Firstly, there is no definition provided for equipment or airflow. Nor is there any definition of airframe.
What constitutes a piece of equipment protruding into the airflow? An HF antenna? VHF, GPS, etc? We are required to install new antennae for ADSB & 406 MHz ELT's. To the letter of this circular we now need flight testing when we change the GPS & Transponder antennae when an aircraft is upgraded to ADS-B or if a 406 HHz ELT is fitted. Want to remove a redundant ADF? That will require a report & flight test to remove its antenna too.
Thinking about installing a JPI engine monitor? If you take the OAT option, that will require a report & flight test.
How about a new aircraft cover? Aren't the press studs equipment that protude into the airflow?
The circular only gives guidance for airflow. Where does one look for issues such as structural integrity, free control movement or CofG.
It does not define " Flight test validation". Does it need to conform to the CASA guidelines for Flight Testing? Is it required to be conducted by a specialist? Can the owner do the test flight? Is a flight test report required according to the CASA Flight Test Guide? Is a risk management assessment according to AC 21-47 required?
It does not define "an authorised person" who is required to create the application. Is this what we currently refer to as CASR 21.M Authorised person? There are less than 30 of these people outside the airlines. They might be about to be busy.
After DJP going into detail with me about how CASA has omitted the minor mod exemption that exists in US law, I'm surprised he didn't get into this. The biggest problem is that CASA is treating a camera mount the same way as the modification to carry a space shuttle on the back of a 747.
Thread Starter
The biggest problem is that CASA is treating a camera mount the same way as the modification to carry a space shuttle on the back of a 747.
One can't be to careful can one, seeing that the "aims and objects" of the Civil Aviation Act 1988, as interpreted by the present management of CASA, allow for no "common sense" interpretations, only "minimizing accidents and incidents" no matter how unlikely, and regardless of the cost of such minimization.
After all, those beastly Senate chappies, goaded by the members of the Ills of Society Society, might ask difficult questions.
Seriously, the "one size fits all" approach embedded in the current act and regulations, and being reinforced in the so called "reformed" regulations, marches on, to the cost of all sectors of what remains of Australian GA.
Tootle pip!!
This seems to be the official action to follow on from this magazeine article CASA Confirms External Camera Ruling
On the other hand if the AC was not intended to change the current approval process for little OAT sensors and antennae then it should be clearly stated.
This AC is aimed at design approval holders, maintenance organisations and applicants for approval of modifications.
My opinion is that design approval holders should not be authorised if they don't know basic stuff - they deserve something like this FAA AC: http://rgl.faa.gov/Regulatory_and_Gu...C%2021-40A.pdf
Maintenance organisations likewise should know that changes require approval but perhaps they could do with guidance as to whether something would be "major", "minor" or (my new category) trivial whereby a LAME can put a -6 screw in the wingtip fairing of my aeroplane rather than the approved -4 screw.
Applicants don't seem to be helped by this as they don't need to know about stuff like "Design Drive Airspeed". Applicants could do with knowing about who to go to and how to apply to get a change approved.
Perhaps aircraft owners and pilots could do with knowing what they cannot do without getting approval.
- from that magazine article. I wonder why that statement didn't make it into the AC - my opinion is that the AC would be much better than it is if that sentence was the only content.
Thinking about installing a JPI engine monitor? If you take the OAT option, that will require a report & flight test.
This AC is aimed at design approval holders, maintenance organisations and applicants for approval of modifications.
My opinion is that design approval holders should not be authorised if they don't know basic stuff - they deserve something like this FAA AC: http://rgl.faa.gov/Regulatory_and_Gu...C%2021-40A.pdf
Maintenance organisations likewise should know that changes require approval but perhaps they could do with guidance as to whether something would be "major", "minor" or (my new category) trivial whereby a LAME can put a -6 screw in the wingtip fairing of my aeroplane rather than the approved -4 screw.
Applicants don't seem to be helped by this as they don't need to know about stuff like "Design Drive Airspeed". Applicants could do with knowing about who to go to and how to apply to get a change approved.
Perhaps aircraft owners and pilots could do with knowing what they cannot do without getting approval.
"Attaching anything to the external surfaces of an aircraft, whether it is the wing or not, is considered a modification," CASA's spokesperson said.
DJP
I don't see anything that exempts things already covered by an STC. I'm thinking mainly about things like the JPI OAT sensor, or maybe an AoA sensor (which are becoming more popular). Our aeroplane has the LoPresti hub caps fitted, that should now require a flight test (despite its STC) and ditto LoPresti spats, gear lobes, and other fairings.
Also the AC talks about replacing items (substitution of a part or appliance), which theoretically says if you replace a TXP antennae with an ADS-B one, or a GPS antennae with a WAAS one of an ELT antenna with a 406 one then you need a flight test. Technically, its saying that if you replace a landing light you need a test flight.
"anything attached to external surfaces..." also catches the press studs for aircraft covers and the unique Australian requirement for grounding tabs adjacent to fuel caps. It probably also covers fitment or replacement of static wicks. Taken to the extreme, this covers self adhesive aircraft registration or other decals.
I also think flight test requires some definition. Is it a circuit? Is it a local flight with clean & dirty stalls? Does it include VNE dives? Does it require a flutter test regime? What constitutes a flight test pass? Flight testing is a qualitative thing, so it needs guidelines. Does the flight tester need to fly the aircraft before and after to look for differences? Many, many GA aircraft are mis-rigged. Should this be checked & rectified first so the pilot is test flying the mod on an aircraft rigged within the TC spec?
To me there needs to be something that allows discretion. Component replacement should be exempted, fitment of items according to an STC should be exempted (unless required by the STC) and minor items that don't materially affect the airflow or are within the boundary layer should be exempted.
The trouble is that CASA has a bee in its bonnet specifically about cameras and they are getting small enough to fall within most exemptions you might draft. There are already cameras smaller than GoPro's.
I don't see anything that exempts things already covered by an STC. I'm thinking mainly about things like the JPI OAT sensor, or maybe an AoA sensor (which are becoming more popular). Our aeroplane has the LoPresti hub caps fitted, that should now require a flight test (despite its STC) and ditto LoPresti spats, gear lobes, and other fairings.
Also the AC talks about replacing items (substitution of a part or appliance), which theoretically says if you replace a TXP antennae with an ADS-B one, or a GPS antennae with a WAAS one of an ELT antenna with a 406 one then you need a flight test. Technically, its saying that if you replace a landing light you need a test flight.
"anything attached to external surfaces..." also catches the press studs for aircraft covers and the unique Australian requirement for grounding tabs adjacent to fuel caps. It probably also covers fitment or replacement of static wicks. Taken to the extreme, this covers self adhesive aircraft registration or other decals.
I also think flight test requires some definition. Is it a circuit? Is it a local flight with clean & dirty stalls? Does it include VNE dives? Does it require a flutter test regime? What constitutes a flight test pass? Flight testing is a qualitative thing, so it needs guidelines. Does the flight tester need to fly the aircraft before and after to look for differences? Many, many GA aircraft are mis-rigged. Should this be checked & rectified first so the pilot is test flying the mod on an aircraft rigged within the TC spec?
To me there needs to be something that allows discretion. Component replacement should be exempted, fitment of items according to an STC should be exempted (unless required by the STC) and minor items that don't materially affect the airflow or are within the boundary layer should be exempted.
The trouble is that CASA has a bee in its bonnet specifically about cameras and they are getting small enough to fall within most exemptions you might draft. There are already cameras smaller than GoPro's.
Actually, thinking about mounting a Go-Pro, I think the things that would worry me more than disturbing airflow (unless it mounted somewhere totally dumb) would be:
a) that it fell off
b) that it fell off and struck the tail or somewhere else as it went or
c) that it detached from the mount and was retained by a strap and banged against the aircraft
d) that it mounted in a way that damaged the aircraft (ie self tapping screws into aircraft skin)
Also, you'd have some concern about embrittlement of the plastic case that might cause it to fail. And GoPro don't use self locking screws on any of the attachments, which might also allow the camera to fall.
These are probably reasons to make it easy for someone (eg a LAME) to fit one properly rather than forcing it all "underground" through overly arduous and clumsy regulation.
a) that it fell off
b) that it fell off and struck the tail or somewhere else as it went or
c) that it detached from the mount and was retained by a strap and banged against the aircraft
d) that it mounted in a way that damaged the aircraft (ie self tapping screws into aircraft skin)
Also, you'd have some concern about embrittlement of the plastic case that might cause it to fail. And GoPro don't use self locking screws on any of the attachments, which might also allow the camera to fall.
These are probably reasons to make it easy for someone (eg a LAME) to fit one properly rather than forcing it all "underground" through overly arduous and clumsy regulation.
This FAA Order explains how flight tests are normally arranged. http://www.faa.gov/documentLibrary/m...D/8130.29A.pdf
Something needing a flight test requires the aircraft to be in Experimental category (as, until the test is successfully completed and assessed then compliance with airworthiness regs has not been shown or found). It must be flown by an approved pilot to a plan approved by CASA.
Yes, I agree, there are certainly issues with external fitment of GoPro cameras etc but this draft AC contributes diddly squat.
An Operational Flight Check is a lesser activity to check function for example. So, for a camera, CASA doesn't care if the camera works or not, just that the installation is safe and complies with the applicable regs.
My mini camera is smaller than my thumb. Easy enough for an approved person to assess a safe place for it to go and determine a safe installation. Less significant than a small antenna.
You don't need an exemption for your STC as it is approved but worth reading the relevant STC with the note on checking applicability wrt other STCs fitted.
PS: aircraft should always be rigged within TC tolerances. Flight tests may want it rigged specifically at one extreme of the tolerances.
Something needing a flight test requires the aircraft to be in Experimental category (as, until the test is successfully completed and assessed then compliance with airworthiness regs has not been shown or found). It must be flown by an approved pilot to a plan approved by CASA.
Yes, I agree, there are certainly issues with external fitment of GoPro cameras etc but this draft AC contributes diddly squat.
An Operational Flight Check is a lesser activity to check function for example. So, for a camera, CASA doesn't care if the camera works or not, just that the installation is safe and complies with the applicable regs.
My mini camera is smaller than my thumb. Easy enough for an approved person to assess a safe place for it to go and determine a safe installation. Less significant than a small antenna.
You don't need an exemption for your STC as it is approved but worth reading the relevant STC with the note on checking applicability wrt other STCs fitted.
PS: aircraft should always be rigged within TC tolerances. Flight tests may want it rigged specifically at one extreme of the tolerances.
Is there a conceivable ground test that would meet the intent of this (i.e. not requiring actual flight test?)
I can remember getting involved in the certification of an ultra-light aircraft here many years ago where the designer had done some ground tests for certification in another country. Towing the aeroplane tied down to a trailer behind his Porsche down a motorway at Vd instead of flight tests did not show conformance, in my opinion, to the specific requirements nor did it seem very smart to me. Well, it was smart in that it kept the risk low to the test pilot who didn't fly it above Vne but left future participants at risk.
I should note that I have been out of this business for a few years but thinking of getting involved again. Perhaps people do things differently here now (and differently from in the USA) and perhaps my comments are way off track.
Surely the main issue here is that the damned thing could fall off and kill someone?
250 grams or so of camera from 1000 feet - that's quite a big hole?!!
The airflow interference with a static port or pitot tube is perhaps valid (although you'd have to be an absolute goose to mount it near either) but they're hardly going to contribute to a stall or some other drastic airflow change are they?
They're great things - we suction mounted our one to the inside of a 152 windscreen to get a shot of our 11 year old boy's first flying lesson.
But personally I think anyone other than a LAME who mounts a Go-Pro on a wing or the fuse is bloody nuts!
I've read anecdotal stories of people using the Go-Pro supplied suction mounts to do so... I hope to God they're not true.
250 grams or so of camera from 1000 feet - that's quite a big hole?!!
The airflow interference with a static port or pitot tube is perhaps valid (although you'd have to be an absolute goose to mount it near either) but they're hardly going to contribute to a stall or some other drastic airflow change are they?
They're great things - we suction mounted our one to the inside of a 152 windscreen to get a shot of our 11 year old boy's first flying lesson.
But personally I think anyone other than a LAME who mounts a Go-Pro on a wing or the fuse is bloody nuts!
I've read anecdotal stories of people using the Go-Pro supplied suction mounts to do so... I hope to God they're not true.
Not the subject of this AC but do you think that a GoPro mounted internally does not require design approval? It is the very same regulation that powers this AC.
Incidentally, the EFB CAAP states that EFB mounted to structure only requires design approval. (is my cabin door part of the structure?) Silly to mount anything like an iPad or GoPro on the flimsy interior trim in my airplane but sensible onto a convenient steel tube.
Incidentally, the EFB CAAP states that EFB mounted to structure only requires design approval. (is my cabin door part of the structure?) Silly to mount anything like an iPad or GoPro on the flimsy interior trim in my airplane but sensible onto a convenient steel tube.
250 grams or so of camera from 1000 feet - that's quite a big hole?!!
GoPro cameras and similar are regularly used in motorsport now. In the old days we had quite stringent requirements for the mounting of video cameras require steel cages and things like that, but its becoming less and less of an issue. In say a 25g impact, the restraint only needs strength of about 3.2 kgf or say 4.5 kgf with a safety factor. But there are some issues. The standard GoPro pivot bolt becoming loose under vibration is at the top of these. For motorsport, we require the tether to be used. On an aircraft this probably should not be used.
Well, that Advisory Circular – AC 23-1 v1.0 – Airspeed airworthiness standards for the installation of equipment that protrudes into the airflow has been published.
I expect FOIs to quote it ad nauseam at ramp checks if they see a little camera.
I expect FOIs to quote it ad nauseam at ramp checks if they see a little camera.
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I expect FOIs to quote it ad nauseam at ramp checks if they see a little camera.
I even put a submission into CASA on this one, no acknowledgement and evidently no consideration of this issue.
Better get your test flight organised if you don't have spats on...
Friend has some public YouTube videos taken in flight from aeroplane - the reason given by two FOI's seen inspecting the aeroplane recently. Nothing found as the camera was (temporarily) mounted in the cockpit. I wonder if CASA has been looking at other aeroplanes which star on YouTube?