Jump to content

GO PRO MOUNTS?


Recommended Posts

  • 2 years later...

I've had a few discussions with my local FSDO on the subject. Unless installed on an experimental aircraft, even a "temporary" mount requires an STC/337 as it is considered an external load requiring an engineering analysis. I designed a temporary camera mount that connected to the R44 tow ball, the project was abandoned because the cost of approval would have been upwards of $5K. I opted for a see though the glass suction cup mount instead.

 

Mike

Link to comment
Share on other sites

I've had a few discussions with my local FSDO on the subject. Unless installed on an experimental aircraft, even a "temporary" mount requires an STC/337 as it is considered an external load requiring an engineering analysis. I designed a temporary camera mount that connected to the R44 tow ball, the project was abandoned because the cost of approval would have been upwards of $5K. I opted for a see though the glass suction cup mount instead.

 

Mike

 

If you’re concerned with the letter of the law, there is an approval process for major changes. However, your GoPro could be classified as a “minor change” under §1.1 and Part 43. Minor changes are defined as having no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the aircraft. Minor alterations or repairs under Part 43 do not require FAA approval.

 

You also have major/minor type design changes under Part 21, were minor type changes falling under §21.93 and §21.95 may require FAA approval:

 

 

§21.95 Approval of minor changes in type design.

 

Minor changes in a type design may be approved under a method acceptable to the FAA before submitting to the FAA any substantiating or descriptive data.

 

ALL TAKE NOTE: However, you should first look at who may attach an item to the outside of the helicopter. With only an FAA pilot certificate (non-A&P), you’re only allowed to perform preventive maintenance (§43.3[g]). There’s no provision for attaching a camera to the outside of your helicopter under Part 43 Appendix A as a preventive maintenance item.

 

This type of minor alteration would normally be accomplished by, require, an A&P pursuant to §43.3 [b}.

 

Minor changes don’t require a STC. The major change process requires FAA Form 337 with the substantiating or descriptive data documented, sometimes in the form of a supporting STC. Moreover, AC 43.13-1B and AC 43.13-2B have prior FAA acceptable methods (supporting data) you can also use to help complete form 337.

 

As an example, AC 43.13-2B contains methods, techniques, and practices acceptable to the FAA for the alteration of civil aircraft of 12,500 lbs. gross weight or less. This data generally pertains to minor alterations; however, the data may be used as approved data for major changes when the AC chapter, page, and paragraph are listed in block 8 of FAA Form 337.

 

Also common, AC 43.13-2B, Chapter 2, describes installation considerations and requirements for basic stand-alone, installations of communication, navigation, and emergency locator transmitter (ELT) equipment.

 

Portable items like GPS units, not connected to or requiring aircraft power, which you carry in and out of the cockpit, don’t normally require FAA approval or Form 337.

 

Normally an A&P can combine substantiating data from prior approved methods to get the required FAA approval for major changes, or those minor alterations the FAA insist are major. Problems not resolved at the FSDO level with respect to minor or major changes require the assistance of the Aircraft Certification Office(ACO).

 

 

REF: 8900.1, Vol. 4, Chapter 9

FAA Order 8300.16

2-1. Eligibility.

a. ASIs must review the data packages for each requested approval for a major repair or major alteration in order to ensure that a field approval is necessary and appropriate. ASIs who deny field approval requests to operators for alterations or repairs that do not need or qualify for field approvals must explain to the operator the reason for the denial and, if requested, provide the reason(s) in writing or electronically. The applicant or operator can then retain the reason(s) within the aircraft records for future reference.

b. When determining the basic eligibility of a proposed major repair or major alteration for field approval, the ASI must consider whether the repair or alteration is major or minor. Refer to Title 14 of the Code of Federal Regulations (14 CFR) 1.1 and part 43, appendix A. If determined to be a major repair or major alteration, a field approval may be granted.

c. Minor alterations or repairs do not require FAA approved data and therefore must not receive field approval.

d. Repairs and alterations that have all the necessary approved data also do not require field approval.

CLICK PHOTO TO ENLARGE

ScreenShot2014-10-15at94806AM_zps9f9d83c

REF: FAA Order 8300.16

Edited by iChris
Link to comment
Share on other sites

I think the suction cup would be he best bet but I don't know if I fully trust it. Safety wiring it would probably be sensible. www.eyeofmine.com make some cool custom mounts for it!

I think I'll order the glasses:

 

http://www.eyeofmineactioncameras.com/eyeview_s/1885.htm

Link to comment
Share on other sites

I've had a few discussions with my local FSDO on the subject. Unless installed on an experimental aircraft, even a "temporary" mount requires an STC/337 as it is considered an external load requiring an engineering analysis.

 

Mike

 

I’m surprised by that response from an individual at your local FSDO. This small GoPro camera, case, and mount, amount to less than 10 ounces overall, is in any case an “external fixture” that could be attached and classified as a “minor change” under §1.1 and Part 43, having no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the aircraft.

 

Advisory Circular 27-1B defines such attachments as “external fixtures.” That definition is quoted in a Chief Counsel’s opinion as valid and binding as the FAA’s conclusion that these items are “external fixtures” and not “external loads.”

 

Advisory Circular 27-1B indicates that the FAA would characterize equipment, such as the nightsun spotlight, microwave downlink antenna, FLIR gimbal and night scanner permanently mounted on your helicopter as an "external fixture" instead of an "external load." The AC defines an external fixture as "[a] structure external to and in addition to the basic airframe that does not have true jettison capability and has no significant payload capability in addition to its own weight."

 

An example is an external float. Like the external float, the nightsun spotlight, microwave downlink antenna, FLIR gimbal and night scanner do not have any "payload capability" in addition to their own weight. Also, those external structures are not designed or approved to transport any object that can be added or removed from the external load attaching means as the specific operation may require (e.g. a hoist attached by a hook to the aircraft).

 

For the above reasons, we conclude that the equipment attached to your helicopters – a nightsun spotlight, microwave downlink antenna, FLIR gimbal and night scanner - do not require part 133 certification because these items are external fixtures.

 

Owens - (March 2010) Chief Counsel Legal Interpretation

 

 

External fixture: A structure external to and in addition to the basic airframe that does not have true jettison capability and has no significant payload capability in addition to its own weight. An example is an agricultural spray- boom. These configurations are not "External Loads" approvable under § 27.865.

 

Advisory Circular AC 27-1B; Page D-112

Edited by iChris
Link to comment
Share on other sites

Like any government agency, FSDO's are strange beasts that often don't even agree with one another. An interesting trait they share in common with the IRS is that the advice they render is not binding.

 

Problem is that they still wield the power of the ramp check. Hey, "I noticed you have something hanging off the tow ball on your ship...", and so the trouble begins. One of the driving forces behind my getting into experimentals.

 

Mike

Link to comment
Share on other sites

At least in this case there is consistency with what I was told by the FSDO -- suction cup mounts are OK, but bolt on or clamp on mounts are not because they are not considered "temporary".

 

Mike

 

That’s a misinterpretation of the memorandum. This is how misinformation is propagated. The use of suction cups, or other temporary methods of attachment (not including permanent mechanical attachments to the aircraft) are not OK. They just aren't subject to the regulatory purview of 14 CFR part 43.

 

The memorandum follows up with:

 

The use of these type attachments however are not supported by the FAA, and may (in the case of an in-flight detachment) lead to "careless operations" as provided for in 14 CFR sections 91.13 and 91.15.

 

When the work is done correctly by an A&P using sound mechanical attachments (not suction cups, adhesive, etc.) and documented in the maintenance log your insurances is the installation meets 14 CFR 43 (Performance rules §43.13).

  • Like 1
Link to comment
Share on other sites

As I read it, the FAA does not specifically prohibit external suction cup attachments, they say they do not support them. I personally would not trust an external suction cup mount due to the likelihood of detachment leading to a violation of 14 CFR sections 91.13 and 91.15 (careless operation). As mentioned earlier; if your going to use a suction cup mount, don't let it fall off.....

 

The gotcha in 43.13 is the reference to structural strength, resistance to vibration and deterioration, according to my local FSDO office, this is the reason for an engineering analysis.

 

(B) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

Link to comment
Share on other sites

  • 3 weeks later...

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Loading...
×
×
  • Create New...