Fly the Wing

Shame on Aircraft Spruce for advertising and selling something they know will make your airplane unairworthy. They advertised a camera mount for Cessna wing struts in a recent issue of Plane & Pilot magazine and in email ads.

Now, I happen to know that an STC’d external camera mount, such as you would mount on a helicopter skid, can cost more than a $1,000 (click here). So I was intrigued by a strut mount for “Cessna aircraft including 150, 172, 182 and 210” for just $130. I asked whether it was STC’d for those aircraft, and Spruce sent me this reply: “Per the supplier: The part itself is not STC'd for certified aircraft.” Well, the part itself is what I would be attaching to a certified aircraft, so there you go. Apparently Spruce didn’t connect the dots on that one, as they continue to advertise and sell the part itself.

NOT UNSAFE ≠ LEGAL

Bolting something to the exterior of your airplane is considered an “external load” (14 CFR 1.1). With the exception of some rules that give you some latitude to do so in Alaska, you can’t just bolt stuff onto your airplane. Will it adversely affect lift or drag? I don’t know and it doesn’t really matter. You can’t do it without getting a field approval from the FSDO (for certificated airplanes) or a sign-off from the manufacturer for S-LSA aircraft. And good luck getting anyone from the FSDO to sign anything that creates liability that could later come back to haunt them and has the potential to adversely affect their pending government pension.

You can dispute whether this constitutes a “minor change” or a “major change” (FAR 21.93) and who has to approve each. But don’t think that just because you consider it “temporary” or because you may not need tools to install it that it doesn’t count as an external load. Anything you were to attach to your airplane would only be temporary once you later removed it, right? And you don’t need tools to attach vortex generators to the top of your wing, but they sure do need to be STC’d for your airplane; one of the reasons those little pieces of plastic cost $1,500 for a Cessna 172. Even then you’ll need a Form 337 completed by an IA before you can return the airplane to service.

IT’S NOT A PROBLEM UNTIL IT’S A PROBLEM

My guess is the FAA is not overly concerned about people bolting GoPro cameras to their aircraft at this time. They usually don’t act, but rather react. If and when something bad happens, you might see them become more assertive and actually issue a cogent statement on the matter. But here are a couple worst-case scenarios to consider.

•If you attach a camera and it falls off, you may have personal injury or property damage issues waiting for you when you land. It wouldn’t be too hard to determine who owned the camera based on video files on the SD card, the camera’s serial number, and a review of LiveATC tower archives to determine airplanes flying in the vicinity during that time.
•If you leash the camera to the airplane so it doesn’t fall off, but it comes off the mount, it could damage the airplane by banging around in the airstream until you land. The noise alone is sure to get your attention.
•Any damage to the airplane, control surfaces, etc. will surely not be covered by insurance. Unlike the FAA, insurance companies are pro-active. They know that bolting something on your airplane makes it unairworthy, and every insurance policy requires that the airplane be airworthy in order for insurance to be in force. Claim denied; case closed.

TWO WRONGS DON’T MAKE A RIGHT

Sporty’s is also advertising an external mount for action video cameras. While they do not suggest that you can use it on a

certificated Cessna wing strut like Spruce does; they also do not say that you can’t. They suggest removing a screw or bolt from your airplane and attaching “Exhibit A” (as the NTSB might label it during their post-crash investigation) to the airplane in that manner.

Would it be that hard to add a disclaimer line to the ad such as “Not approved for certificated aircraft”, or “For use only on experimental aircraft”? They either don’t know, or they don’t care, and would rather just make a couple bucks from selling this to unsuspecting pilots or airplane owners.

Here’s an NTSB report of an accident last year where a feller in Alaska attached caribou antlers and a rifle to his wing struts and augered in. As the NTSB mentions, he “had no restricted airworthiness certificate authorizing external load operations”, which is what you would need if you attached something that wasn’t STC’d for your aircraft.

Attaching a GoPro may not be a huge safety issue, but you should consider the legal implications and weigh the risk before you take to the skies in an airplane that you know is not airworthy. Until and unless we get clear guidance from the FAA, you won’t see me post any videos online that include footage from externally-mounted cameras.

5/27/14

5/6/16 Update:

This article has been viewed thousands of times in the past two years. One person who read it is the designer and owner of the NFlightCam mount. A few weeks ago, he asked me to re-visit this topic, as he said an FAA “ruling” (he used the word “ruling” three times in his email), now deems the external GoPro mounts ‘legal’.

He sent me a document from the FAA Maintenance Division (it was a memo, broadly answering two questions relating to whether these external mounts were “major” or “minor” repairs; it is in no way a “ruling” or a “change of law”; it’s a memo to one FSDO). You can read it by clicking the image.

I don’t see where the FAA is giving clearance to mount these things externally; in fact, they say “these types of mounts are not supported by the FAA” and that a pilot could be in violation of FARs 91.13 & 91.15 (careless operations and dropping objects from an aircraft) if they do use the mount.

But a bigger issue, as I alluded to two years ago (see article to the left), is where the insurance industry stands on this. I reached out to insurance companies and received responses from three leading aircraft insurers; AIG says that aerial photography is not included in their policy- not even for your own personal use. The underwriter said that you can take "casual pictures" from the plane, but no aerial photography. Another underwriter, who does not have a specific exclusion in their policy for aerial photography, said that there would be no coverage for damage if the camera came off the aircraft, and no coverage for damage to the camera itself. So, this is a worthwhile question to ask other underwriters. Old Republic has no specific exclusion for aerial photography, but, as all policies for pleasure aircraft, you can not make a profit for use of the aircraft.

So, I have re-visited the topic of externally mounting GoPro cameras on light airplanes, and I still recommend that you not do it.