Legality and Law interpertation of CARS on Mounting Camera

[CropDuster]

Hey Guys,

The new era of small cameras like Go Pro HD, CountorHD and others are making there way into aviation.

I also have one and I would like to mount it on the plane I fly.

I know mounting it inside the cockpit is legal, just like mounting a PDA or IPAD mount. As longest it is not permanent modification. Example would be the yoke mount or suction cups.

I have been rooming the CARS, and from my understanding as longest it is not a Major modification it does not need a STC. There is a questioner you have to answer and if any are YES it is Major.

Now I would like to find a section in CARS, or some form of document that could protect me from a transport inspector if his interpretation is different then mine. I know I would lose that argument, and id have to go to court or something. I wish I could wip out my document saying, see this, Its legal.

Does anyone know which section in the CARS would refer to mounting cameras? The mounts are just roll bar or handle bar clamps. No damage, or modification to the plane. Once it is removed, no one would know it was there.

I am sure many of us on here would like to know the official version from transport on this topic, so I will call someone at Transport and seek a more clear understanding of laws. In the mean time, I would ask for AvCanada membership help me and others on this subject.

Also, is there a difference regarding this topic on an aircraft that is restricted compared to a standard C of A?

[Colonel Sanders]

I know mounting it inside the cockpit is legal

How do you know that?

[CFR]

... so I will call someone at Transport and seek a more clear understanding of laws. In the mean time, I would ask for AvCanada membership help me and others on this subject.

Many of the shows currently on TV obviously use the small cameras mounted externally to the aircraft. I have seen this done locally for commercial shoots as well, using gaffers tape (expensive Duct Tape) to hold the mount on to A/C. As there are numerious examples on youtube, I would like to think that if TC had a problem they would be issuing something. I suspect that as there have been no reported instances of accidents caused by these activities (to the best of my knowledge) they are simply leaving it alone. Asking an official question will get an official answer that you may not like.

We have discussed this where I fly and the most obvious violation would be the prohibition against dropping something from an aircraft causing injury to persons or property on the ground. 602.23 No person shall create a hazard to persons or property on the surface by dropping an object from an aircraft in flight.

Camera doesn't fall off = no violation, camera falls off with no injury or property damage = no violation ... maybe (iffy if a "hazard" existed ie: dropping it into a crowd but through luck alone not hitting anyone). Camera falls off with injury or property damage = violation.

I cannot comment on any interactions with TC, but it has been my experience working with other government regulatory agencies to never seek approval to do something as their default position seems to be that unless something is specifically permitted, they will interpret any existing rules to prohibit the request.

Never ask a question you don't want a negative answer to.

edited - OK you made me go and look! A search of the TC site for "camera mount" and "external camera" found nothing that applied. "external load" found this http://www.tc.gc.ca/eng/civilaviation/r ... fr-328.htm While a camera is not a canoe it would seem to me that offically a "proving flight" as applicable to a private aircraft might be sufficient to allow you to do it.

edited again - If you do choose to ask TC about this I would suggest the question be worded something like "Do the recommendations of the External Loads Working Group apply to the small sports cameras currently available?"

[old_man]

Many of the shows currently on TV obviously use the small cameras mounted externally to the aircraft.

Just because you saw something on TV does not mean you can do it. Do you know if they had an STC or not? I have seen some heavily modded aircraft on TV as well. Doesn't mean I have about to go the hanger and try the same thing on my own.

I have seen this done locally for commercial shoots as well, using gaffers tape (expensive Duct Tape) to hold the mount on to A/C.

That seems legit

As there are numerious examples on youtube, I would like to think that if TC had a problem they would be issuing something.

Good legal defence. 'But the other guy did it'

Asking an official question will get an official answer that you may not like.

Much better just not to ask and do whatever you want?

Camera doesn't fall off = no violation, camera falls off with no injury or property damage = no violation ... maybe (iffy if a "hazard" existed ie: dropping it into a crowd but through luck alone not hitting anyone). Camera falls off with injury or property damage = violation.

You're joking right?

Never ask a question you don't want a negative answer to.

You're right. It's much better to just stick your head in the sand and continue to do things that may or may not be illegal. Ignorance of the law is a valid excuse right?

[CFR]

Many of the shows currently on TV obviously use the small cameras mounted externally to the aircraft.

Just because you saw something on TV does not mean you can do it. Do you know if they had an STC or not? I have seen some heavily modded aircraft on TV as well. Doesn't mean I have about to go the hanger and try the same thing on my own.

I have seen this done locally for commercial shoots as well, using gaffers tape (expensive Duct Tape) to hold the mount on to A/C.

That seems legit

As there are numerious examples on youtube, I would like to think that if TC had a problem they would be issuing something.

Good legal defence. 'But the other guy did it'

Asking an official question will get an official answer that you may not like.

Much better just not to ask and do whatever you want?

Camera doesn't fall off = no violation, camera falls off with no injury or property damage = no violation ... maybe (iffy if a "hazard" existed ie: dropping it into a crowd but through luck alone not hitting anyone). Camera falls off with injury or property damage = violation.

You're joking right?

Never ask a question you don't want a negative answer to.

You're right. It's much better to just stick your head in the sand and continue to do things that may or may not be illegal. Ignorance of the law is a valid excuse right?

see edited original - a search found some info that seems to apply.
The working group seems to recognize that not all external loads can be covered by STCs.
I did not address the issue of if it should be done or how to do it, merely the concerns I have with asking. By the way "never ask ..." does not mean do it, it means be prepared to deal with the negative answer.
You will also note that I did not (and do not) resort to the apparent AVCanada norm of cutting responses, ridicule and personal attack to express my point (make no mistake I can be very good at it, but choose not to engage).
Carry on!

[Bolter]

Not a CARS expert but have done some testing & have worked with Test Pilots so am familiar with some of the issues
Search for temporary modifications - might be something there.
Issues with this sort of thing - restrictions to flight controls (anything mounted on the yoke or close enough to interfere).
Security during critical phases of flight, turbulence, aerobatics, etc. i.e. You don't want it falling off and getting jammed in the rudder pedals.
Distracting the pilot during critical phases of flight. i.e. perhaps best stowed during TO & Ldg.
Power source & interference with instrumentation.
Obstructing the pilots view of aircraft instrumentation.

Good luck.

[CID]

Since cameras aren't required by any certification or operating standard, you won't find anything in the CARs specifically addressing them. In that case, the certification basis of the airplane applies.

As far as "major" modifications go, it really depends on the airplane. Fitting an "external shape" to a 172 is much different affair than doing it on a Falcon 50. Sticking it on a wing is much different than mounting it on a strut.

And as for your comment on mounting things to your yoke, sorry. That's a major mod. And so is installing an iPod mount. Check AC 120-176B for more information on that.

And no...you don't necessarily need an STC for a major mod. Again it very much depends on the airplane. Major mods must be done in accordance with "approved" or "specified" data. Check CAR 571.06. For "small" aircraft, under certain conditions, major mods can be done in accordance with AC 43.13 as long as a mod reporting form is submitted by a properly authorized person.

And (again) no...affixing something to the outside of your airplane and having it fall off does not invoke 602.23. It would likely invoke something much more fundamental namely the fact that your C of A wasn't in force with that unapproved major mod installed or taking off when your aircraft was not "safe for flight".

If you want to clamp a small camera to a strut it's usually not a big issue but get an AME to help you out. A couple of decades ago I read a report about a fellow who clamped an antenna to the strut on his Piper Cub (I think). For some reason he though it was a solid piece of metal and tightened it up real good. The resultant damage eventually caused a strut failure.

[Dagwood]

Change to a Type Design

521.152 (1) Subject to section 521.153, no person shall undertake a change to the type design of an aeronautical product that has other than a negligible effect on the weight and centre-of-gravity limits, structural strength, performance, power plant operation, flight characteristics or other qualities affecting its airworthiness or environmental characteristics except in accordance with sections 521.155 to 521.160.

(2) In any other case, no person shall undertake a change to the type design of an aeronautical product except in accordance with section 521.154.

Ok, so assuming that an externally mounted camera has a negligible effect on the above menioned quailites, 521.154 is applicable:

Change Other than a Change to the Type Design

521.154 The holder of a design approval document who proposes to make a change to an aeronautical product, other than a change to the type design referred to in subsection 521.152(1), shall establish procedures to ensure that the changed aeronautical product continues to conform to its certification basis and make the change after the Minister accepts the procedures.

So it looks like you need a design approval document, you have to establish procedures to ensure safety, and you need the Minister's approval.

Seems simple enough

[Grantmac]

Isn't it just this easy:

Private Aircraft - The pilot is to make an entry in the aircraft journey log stating the: date, time and location of the proving flight; pilot licence number of the pilot who conducted the proving flight; a definitive technical description of the external load configuration that was tested (the item - its orientation and location relative to the aircraft); the readily repeatable means of securing the load to the aircraft; and the operating limitations referred to in the "MITIGATION" for "RISKS 1, 2, 4, 7 and 9, using the following formula."

"I have flown this aircraft and consider it safe to fly with (a definitive technical description of the external load configuration that was tested [the item, - its orientation and location relative to the aircraft]); externally mounted by (identify and detail the means of mounting the load) and operated in accordance with the limitations and procedures detailed in this aircraft journey log.

Location_________________ Date_________ Time________

Licence Number___________ Signed__________________"

I'd love to install a GoPro mount on my strut facing inwards and I've seen a LOT of aircraft use the suction mounts. I use one mounted on the inside of my windows.

-Grant

[CFR]

Isn't it just this easy:

Private Aircraft - The pilot is to make an entry in the aircraft journey log stating the: date, time and location of the proving flight; pilot licence number of the pilot who conducted the proving flight; a definitive technical description of the external load configuration that was tested (the item - its orientation and location relative to the aircraft); the readily repeatable means of securing the load to the aircraft; and the operating limitations referred to in the "MITIGATION" for "RISKS 1, 2, 4, 7 and 9, using the following formula."

"I have flown this aircraft and consider it safe to fly with (a definitive technical description of the external load configuration that was tested [the item, - its orientation and location relative to the aircraft]); externally mounted by (identify and detail the means of mounting the load) and operated in accordance with the limitations and procedures detailed in this aircraft journey log.

Location_________________ Date_________ Time________

Licence Number___________ Signed__________________"

I'd love to install a GoPro mount on my strut facing inwards and I've seen a LOT of aircraft use the suction mounts. I use one mounted on the inside of my windows.

-Grant

That was my thought when I read that section.

If you own the plane it should be that simple, if you rent you would have to discuss with the owner.

[cgzro]

What many of us do is attach to our helmet or headset so less issues with CARS etc.

[Grantmac]

Isn't it just this easy:

Private Aircraft - The pilot is to make an entry in the aircraft journey log stating the: date, time and location of the proving flight; pilot licence number of the pilot who conducted the proving flight; a definitive technical description of the external load configuration that was tested (the item - its orientation and location relative to the aircraft); the readily repeatable means of securing the load to the aircraft; and the operating limitations referred to in the "MITIGATION" for "RISKS 1, 2, 4, 7 and 9, using the following formula."

"I have flown this aircraft and consider it safe to fly with (a definitive technical description of the external load configuration that was tested [the item, - its orientation and location relative to the aircraft]); externally mounted by (identify and detail the means of mounting the load) and operated in accordance with the limitations and procedures detailed in this aircraft journey log.

Location_________________ Date_________ Time________

Licence Number___________ Signed__________________"

I'd love to install a GoPro mount on my strut facing inwards and I've seen a LOT of aircraft use the suction mounts. I use one mounted on the inside of my windows.

-Grant

That was my thought when I read that section.

If you own the plane it should be that simple, if you rent you would have to discuss with the owner.

I own, but I ironically don't meet the TT requirements. Of course I don't know anyone who meets the time in type requirements

Attached to a window or headset seems pretty legit. With it hanging from the back of the windscreen I forget about it pretty quicly, so much so that I sometime accidentally film myself pushing back into the hangar before I notice the blinking LED.

Its is the external mount that really interests me, both from a cool factor and also to do some post-flight analysis to see exactly where I can improve.

-Grant

[KK7]

From a practical perspective, completely disregarding what the CARs say...

There's more to it that whether the camera simply falls off and knocks someone in the head on the ground or causes ground property damage. There are also potential effects on the flight characteristics of the aircraft. I don't know what type of aircraft is being referred to in the original post, but judging by the poster's name, it's some sort of crop dusting aircraft, probably not a C172.

In a simple light aircraft, it may not affect much except adding a little drag assuming it's not put around any critical surface, but how do you really know? You might have a pretty good idea about it, but from the point of view from the regulator you probably don't have the qualifications to really say.

The other aspect is the camera or pieces of it letting go may also strike your aircraft, and it could be akin to or worse than a bird strike. Could it hit the horizontal stabilizer? If you're flying a fabric covered aircraft this could do a fair bit of damage.

Just going and doing it probably won't raise any eyebrows with the regulator, I'm guessing, until something wrong happens. Then you can be sure that if you don't have all your I's dotted and T's crossed, you'll get the book thrown at you. There are a multitude of regulations that can be brought in against you, the easiest one of all that I can think of is 602.01 - No person shall operate an aircraft in such a reckless or negligent manner as to endanger or be likely to endanger the life or property of any person. This is the catch-all regulation.

I'm not saying it can't be done, of course it can! And it doesn't necessarily have to be complicated either. But analyze the risk, take the time to determine all the hazards, how to reduce that risk. If it's not your airplane though, ie it belongs to a company you work for, I would highly suggest don't do it unless they want you to.

[iflyforpie]

I've flown with a few external cameras, STC'd and not.

I had an STC for this one. Vibrated like crazy and produced noticeable yaw when it turned.



Then I had a Contour HD that was stuck on with 3M adhesive. It is somewhere at the bottom of Kootenay lake after the adhesive broke down under the heat of the day.

This is what I use now. The mount has an LSTC for telemetry antennas, but we don't do much telemetry anymore so we repurposed it. The plastic camera mount is also screwed rather than just stuck on.

[High and Behind]

The Otter I fly part time has 2 field approvals for carrying external loads. We operate under the private operater certificate (604)
One is for boats and canoes and the other is for antenea for wildlife surrvey. Each one has an amendment in our POH specific to each installation with new C of G and peformance figures, and is part of our yearly training to meet with the aproval.

Call you local inspector and ask him if you do all this would he approve it.

Ask for his help in getting this put through and you might be surprised how quick this might happen. We actually had a third party do all the paper for the approvalss not TC.

[JDW]

I feel like the colonel can offer some insights here...and maybe some video

[old_man]

see edited original - a search found some info that seems to apply.
The working group seems to recognize that not all external loads can be covered by STCs.
I did not address the issue of if it should be done or how to do it, merely the concerns I have with asking. By the way "never ask ..." does not mean do it, it means be prepared to deal with the negative answer.

Cool.

You will also note that I did not (and do not) resort to the apparent AVCanada norm of cutting responses, ridicule and personal attack to express my point (make no mistake I can be very good at it, but choose not to engage).
Carry on!

Fair enough. Truth be told it was not meant as a personal attack. I am just sometimes too sarcastic for my own good. It was not my intent to come across as a personal attack, rereading my post I see how it could be interpreted that way. I blame early morning and no coffee yet. In any case, my apologies.

[CFR]

see edited original - a search found some info that seems to apply.
The working group seems to recognize that not all external loads can be covered by STCs.
I did not address the issue of if it should be done or how to do it, merely the concerns I have with asking. By the way "never ask ..." does not mean do it, it means be prepared to deal with the negative answer.

Cool.

You will also note that I did not (and do not) resort to the apparent AVCanada norm of cutting responses, ridicule and personal attack to express my point (make no mistake I can be very good at it, but choose not to engage).
Carry on!

Fair enough. Truth be told it was not meant as a personal attack. I am just sometimes too sarcastic for my own good. It was not my intent to come across as a personal attack, rereading my post I see how it could be interpreted that way. I blame early morning and no coffee yet. In any case, my apologies.

Apology accepted. It was early morning here as well and I probably did not offer my comments in the clearest of terms and perhaps with a bit too much cynicism with respect to approaching “big brother” with a question.

cheers

[CropDuster]

I've flown with a few external cameras, STC'd and not.

I had an STC for this one. Vibrated like crazy and produced noticeable yaw when it turned.



Then I had a Contour HD that was stuck on with 3M adhesive. It is somewhere at the bottom of Kootenay lake after the adhesive broke down under the heat of the day.

This is what I use now. The mount has an LSTC for telemetry antennas, but we don't do much telemetry anymore so we repurposed it. The plastic camera mount is also screwed rather than just stuck on.

Where can i buy this mount? That is perfect. If it has a STC, it might be just perfect for a PA-25, or is it just for C172? Darn cool airplane. I just want to document it for others to enjoy.

[CFR]

Where can i buy this mount? That is perfect. If it has a STC, it might be just perfect for a PA-25, or is it just for C172? Darn cool airplane. I just want to document it for others to enjoy.

Well now this becomes interesting, since I too want to mount a camera on a Pawnee wing strut at some point in the future to tape towing gliders! If the external load - proving flight is the way to go, I know lots of pilots with the minimum PIC and time on type that could do the certification flight.

[Grantmac]

I want to mount it on a PA-16, which knowing Piper probably uses the same strut profile.
The other view I'd like is under the rear of the fuseage facing forward. Easy with a metal plane, not so much with fabric.

-Grant

[CID]

High and Behind, there is no "field approval" process in Canada. You likely had it installed under the provisions of CAR 571.06 which allow installers to use AC 43.13 as "specified data". Same result but the term "field approval" has a very specific meaning in aviation as a means to certify installations on the FAA side of the fence.

[CropDuster]

CID, can you explain the AC 43.13?

[CID]

Crop Duster, CAR 571 (Regualtion) which you can find here :

http://www.tc.gc.ca/eng/civilaviation/r ... htm#571_06

states that a major mod or major repair must be done in accordance with "approved" or "specified" data. (I'm paraphrasing here)

If you further read the standard which you can find here:

http://www.tc.gc.ca/eng/civilaviation/r ... tm#571s_06

you will find that one definition of specified data is:

(d) FAA Advisory Circulars AC 43.13-1 and AC 43.13-2, subject to the following conditions:

(i) the aircraft is a small aircraft, and the alteration does not affect dynamic components, rotor blades, structure that is subject to pressurization loads, or the primary structure of a rotorcraft;

(ii) the alteration does not affect an existing limitation (including the information contained on mandatory placards) or change any data contained in the approved sections of the Aircraft Flight Manual, or equivalent;

(iii) the data are appropriate to the product being altered, and are directly applicable to the alteration being made; and,

(iv) the data are not contrary to the aircraft manufacturer’s data.(données specifies)
(amended 2009/12/01; previous version)

If your modification meets that criteria, you can use AC 43.13 which can be found here:

http://www.faa.gov/regulations_policies ... ntID/74417

and here:

http://www.faa.gov/regulations_policies ... ntID/99861

or on pretty much every AME's library (at least good ones). Just remember to have someone authorized to fill out a mod reporting form and submit it to TC after.

[185_guy]

This little camera weighs practically nothing, is smaller than a business card and takes surprisingly good video with a class 10 micro SD card. The card will be more than the camera. I have a 16GB card and it will do over 2 hrs of video.

http://www.hobbyking.com/hobbyking/stor ... _CMOS.html

I attach this onto my 6oz small foamie r/c plane (with hot glue) that we fly in a school gym. I also fly it around my neighborhood in town to see what everyone is up to =)

http://www.youtube.com/watch?v=_YH3OMm6 ... r_embedded