I was aware of an STC for GoPro cameras to be mounted externally on specific aircraft types however I knew that it wasn’t cheap so not viable for the typical GA aircraft owner. So, while visiting Oshkosh in July 2015, I was pleasantly surprised to see this company: Flight Fix http://www.flightflixcameras.com/ They mentioned that in the USA allowed their mounts to be used externally without an STC or other engineering approval as they were temporary. That surprised me as I had seen an FAA Safety Briefing on the subject http://www.faa.gov/news/safety_briefing/2014/media/janfeb2014.pdf
There are some inconsistencies with this internal FAA memo of about the same time: FAA-camera-memo 13Mar2014. I see that many are taking that memo as equivalent to law so it was good to see that the FAA has since clarified that in their May/June 2016 Safety Brief:
CASA’s view of the requirements for external camera installations is defined in Reference 1 (at least for certified airplanes).
Quite clear isn’t it.
Reference 2 is quite general with much more information and includes the following clear statement regarding camera installations:
With respect to external camera mounts it is consistent with Reference 1. It also provides some guidance on internal camera mounts. Note that there is nothing in either of those Advisory Circulars which distinguishes between permanent and temporary installations as far as the requirement for needing specific approval – as an engineer I don’t have a problem with that.
Let’s move onto Electronic Flight Bags. From an engineering point of view the considerations are quite similar to a camera of about the same size. Obviously we are only interested in internal installations so we have all of the requirements from Reference 2 to consider.
But now look at Reference 3.
If attached to the aircraft structure then an EFB mount requires approval. Let’s consider two simple aeroplanes for discussion.
Firstly, the Airtourer. Where can we mount an EFB that is not aircraft structure?
I know that windscreens and windows have been used by some people however, being a former student of Henry Millicer, I know that the canopy and windscreen take about 20% of the total lift so therefore they are both part of the structure. The instrument panel must support the instruments and avionics up to the design loads so that is also a structural part. The instrument panel coaming supports the instrument panel and, as Henry told me, in an accident it was designed to fail at a particular load to allow the instrument panel to move forward.
That doesn’t leave many options for the Airtourer apart from the internal cabin trim.
Secondly, the Citabria/Decathlon series. Is the windscreen and skylight part of the structure? I’d say so as there are quite high loads on them in flight. As above, the instrument panel needs to support instruments and avionics so that is structural. Interior trim is not really viable. Window and door maybe? There are some very nice steel tubes in the cabin however that is primary structure so definitely cannot be used to attach an EFB notwithstanding that people hang onto them during aerobatics. Not many options there to mount an EFB.
Para 7.4.1 refers to temporary as “not considered to be airworthy” and must be stowed during take-off and landing, turbulent conditions etc. Presumably somewhere there is an exemption for temporary EFB mounts (whether temporary or permanent) to be attached to non-structural parts without approval? I cannot find it on the CASA website.
Furthermore, it gives Velcro and suction mounts as examples of temporary mounts but no other guidance – I have seen GoPro mounts which require a screwdriver which I would regard as temporary?
From and engineering point of view, the mounting of a small camera internally is quite similar to an EFB. We don’t appear to have any exemption (not that I believe one exists for EFBs) allowing pilots to temporarily mount small cameras internally on non-structural parts. Regardless, pilots like to get video in situations where Reference 3 (assuming it applies) would require that it be stowed.
So, any camera mounted on an aircraft, whether external or internal and whether permanent or temporary requires approval. (see update below)
Personally, I use a kneeboard for my main EFB and my backup EFB goes in a pocket.
I hold a camera or fix it to my headset rather than mount it on an airframe part.
Finally, Flight Fix told me that they expect to have an STC within a year (i.e. at Oshkosh in 2016) for their external camera mounts.
PS Feb 2016: I have just seen this very sensible CAP 1369 Policy and guidance on mounting cameras on aircraft from the UK CAA.
A further revision July 2010 with this magazine article following a revision to AC 21-08 https://www.flightsafetyaustralia.com/2020/07/small-cameras-in-aircraft-take-care-of-your-selfie/
Something sensible from CASA, as far as it goes. I doubt that more than a handful of pilots would understand “mounted in a way that does not affect the approved design of the aircraft”.
The magazine article states that “The approved design of the aircraft would be affected by physical changes to a part of the aircraft, such as drilling holes. The approved design of the aircraft would not be affected by mounting inside the aircraft by means such as a suction cup or zip ties.” but the AC does not mention zip ties, that is the opinion of the “staff writer” who was the author of that article.
The AC goes on. Note the inconsistencies with CAAP 233-1(1):
“3.7.6 Under CAO 20.16.2, a small camera, or similar device, that meets the above criteria is cargo. It is therefore the operator and pilot in command’s responsibility to ensure that the device is used, restrained and stowed in compliance with CAO 20.16.2 and such that the safety of the aircraft is not adversely affected for the particular operation. A formal approval from CASA or an ADO or authorised person is not required in these circumstances.
3.7.7 The assessment by the operator and pilot in command will necessarily be on a case by case basis considering the device, the mounting means, the mounting location inside the aircraft and the operation. The physical size of the device is a relevant consideration for mounting and safe operation, in particular, the mass and dimensions of the device are relevant for determining the suitability of the mounting means and the mounting location.”
- CASA AC 23-1 v1.0 Airspeed airworthiness standards for the installation of equipment that protrudes into the airflow
- CASA AC 21-08 v2.0 Approval of modification and repair designs under Subpart 21.M
- CASA CAAP 233-1(1) Electronic Flight Bags
Things changed in 2020 with this advice from CASA: https://www.casa.gov.au/aircraft/airworthiness/mounting-small-cameras-aircraft