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!!

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?

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?)

:confused:

There are legitimate ways an aeronautical engineer would calculate such a thing... but that would be too sensible :ugh:

High quality editorial work as usual.


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.

Folks,
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.

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.

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.

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.

I could postulate situations where I might want to do a ground test (eg a wind-tunnel test) to indicate the effect of something prior to undertaking flight tests. If the change is substantial enough to warrant wind-tunnel tests then my view is that subsequent flight test would be essential.

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.

What about the risk to the Porsche?

but thinking of getting involved again

Laurie got out a while ago due to the cost's outweighing the benefit .. are you sure ?

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.

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.

More like 130g including the enclosure for a GoPro and others are lighter. Plus I think the terminal velocity may be quite low. But it is a risk.

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.

Or any equipment not installed, such as spats missing on fixed gear Cessnas.

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?

Reading the advisory circular I'm not sure if they are more interested in how the aircraft performs with additional kit dangling in the wind or if they are interested in ensuring the kit is adequately attached so it doesn't fall off.


If it is the former what have they got to say about 100 years of hand held aerial photography where potentially much larger interference with slip stream occurs?



Mickjoebill

Volumex has referred to the spats a couple of times.

I would think there is ample provision for this procedure, just as there always has been.
The TCDS and other manufacturer data would be referred to as part of the certification required by the local regulators.
Some aircraft have requirements that need to be met, exactly the same as the engineer must check when thinking about releasing an aircraft with the spinner removed.

The TCDS are all available online, under the FAA website for most aircraft.

Seems the Americans don't care about mounting GoPro's... in my inbox this morning...



http://members.iinet.net.au/~bc_j400/gca1.jpg

http://members.iinet.net.au/~bc_j400/gca2.jpg

WingItMounts GoPro-01 Products Page

link to the product.

like that a logbook entry may be required from your LAME and no responsibility accepted if your fitment results in damage...as if that will keep the sharks away....other than that, a bloody solid looking piece of kit.

Lol I should have looked a bit further like you did!

I wonder how many would go to the effort of talking to their LAME. Hire Cessna, affix mount, remove mount, return aircraft.

Reading between the lines...a couple of young bucks get together and come up with a brutally simple mount for a popular camera. Hope it makes them a boatload of dollars:ok:

Too bad for PA28 drivers .. hehe ;)

:E....yeh but you could make one to wrap around the inside of the step.

Page 28 of the Jan/Feb 2014 FAA Safety Briefing gives quite clear advice. http://www.faa.gov/news/safety_brief...janfeb2014.pdf
Very similar rules there and a similar approach - the difference is that the FAA's advisory documents are very clear and it is much easier to get approval for a minor mod there than it is here.

Latest from CASA, in Flight Safety Australia of Mar/Apr 2014:
Obviously, CASA know little about their own rules. TSO is the USA's Technical Standard Order "A TSO is a minimum performance standard for specified materials, parts, and appliances used on civil aircraft."

Australia has ATSO "As per CASR Part 21, Subpart O, an Australian Technical Standard Order contains minimum performance standards for specified articles (ie. materials, parts, processes and appliances) used on civil aircraft."

The main point is that “all installations ... require formal engineering approval.” Nothing about temporary installations excepted as stated in the CAAP on EFBs.

Does this mean temporary camera mountings don't require an EO?

Would this be different for, say, temporary mountings on a wing or inside the cockpit?

Sometimes PeterC it's better to get someone who is qualified to do the job for you and do it properly the first time....

Peterc005,
The answers are NO and NO.
Every mod. to an Australian aircraft requires a minimum of an Engineering Order or an STC. The US system for minor modes is far more simple, with a thing called a "field approval" via FAA Form 337 ( I hope I remembered the form number correctly)

Tootle pip!!



Had to tidy up your post Leadie due to, sadly, near miss no longer being active in this thread!

Tail Wheel

@Leadsled - I thought the FAA Form 337 was pretty much the equivalent of a CASA Form 442?

Recently I had another EO done for a fuel level indicator and, apart from needing an electrical load analysis, it seemed much easier that earlier EOs.

Bob MacGillivray down at West Sale did the EO. Great job and he was very fast in knocking it over. Seemed ten times easier than earlier EOs, so I assume the regs have changed in the past few years.

And don't post the films on YouTube :ok:

FAA Form 337 is for a major mod which must be approved by the FAA (typically do an STC for the same mod on multiple aircraft).
Minor mods, see my earlier post.

Why are you worried about putting a go pro on externally if your aircraft is experimental? If you built 51% of it you're the manufacturer and you can put it where you want.

We need someone like DJP to comment. But I think CASA would say that a homebuilder may be the manufacturer, but not the designer and that if there is a modification to the design that it requires design approval.

DJP posted recently (on FB or here - forget) about one of his friends who found CASA inspecting the aircraft to determine where the camera had been fitted to take video after the CASA FOI saw a video clip of the aircraft somewhere. Camera's are clearly flavour of the month and CASA seem to be looking for blood.

Folks,
Due to CASA lack of knowledge of what their own rules say and mean re. Experimental Amateur Built, CASA are saying the above, and they are wrong.
This is part of the trials and tribulations of RAOz right now, CASA making up rules that do not exist.
If you want to fit a camera to an Experimental Amateur Built, as the minimum 51% builder, you are responsible for the mod., you must talk to whoever issued the certificate, they will determine whether any test flying must be done to re-issue the Operations Limitations Annex to the certificate.
Tootle pip!!

PS: PeterC005,
I know what the title of the 337 says, but it doesn't have to be a "very" major mod, for -337 to apply, but in many cases, a DER will not be required, the changes will be signed off by an IA, having been accomplished by an A&P, using the guidelines of AC43.13A & B.

You are right lead, you must talk to the AP, post fitment. Matter of logging it as well. We had 3 permanent hard wired external mounts prior to issue of CofA, all good :ok:

With a decent AP who's prepared to challenge CAsA's blatantly wrong interpretation of their own 'rules' things may change but it may take a challenge. I know of one chap who'll be taking CAsA to the small claims tribunal after he obtains his IFR CofA. Can't wait for that :ok: