GA1309

7th July 2022

Camera & Equipment Mounts

Initial Report

I am concerned by what seems to be a lack of awareness of the requirements when fitting cameras and tablet computer holders to an aircraft, particularly within GA. It appears that, just because pilots/owners are able to buy these mounts, both suction cups and self-adhesive, then they are permitted to fit them to their aircraft. Only on two occasions have pilots approached me to ask if there is a specific requirement to follow to have such mounts installed, and were totally unaware that there are CAA documents that regulate such installations.

CAP 1369 and [CS-STAN] Standard Changes CS-SC104 and CS-SC105 give clear instructions yet pilots seem to be unaware of their existence or are just ignored. A brief search on YouTube will show an abundance of pilots sharing videos of their flights online, many of which have tablets mounted to the yoke or suction cups holders on the windows and canopies, with no secondary lanyards and in positions likely to cause a problem should they become detached. I’m raising this in the hope that pilot / owners will be made aware that there are rules to be followed when installing these mounts.

Background Information

CAP1369 ‘Policy and guidance on mounting cameras on aircraft’ was withdrawn on 10 May 2022 following CHIRP’s engagement with the CAA. This had referred to internal mounting of cameras (Page 5) but only addressed small camera installations mounted internally or externally on aircraft structures that were self-contained, such as GoPro and similar. Such installations would be expected to have low or negligible effect with regard to mass, centre of gravity, structural strength and drag, and would thus be expected to have no appreciable effect on aircraft systems, handling or performance. The CAA commented that CAP1369 had been withdrawn due to its content now being covered in other areas of the CAA website in general terms and also within CS-STAN.  They said they will review the CAP in the future, although they were unable to provide any timescale.  In its place, the CAA website now informs the user that “for certified aircraft the method for approval is included in [CAA] CS-STAN – Standard Change CS-SC105a (Installation of mounting systems to hold equipment). For type accepted aircraft overseen by the British Microlight Aircraft Association or Light Aircraft Association those organisation’s requirements apply”.

Note that the CAA UK document in the CS-STAN link above is the old EASA document Issue 3.  EASA have since updated theirs to Issue 4, which contains the same information in this respect but re-paragraphed as CS-SC105b, not as CS-SC105a. EASA CS-STAN Issue 4 section CS-SC105b ‘INSTALLATION OF MOUNTING SYSTEMS TO HOLD EQUIPMENT’ includes, inter alia, considerations for where equipment should not be mounted; location of brackets; lanyards for suction mounts; push/pull testing; and mount security.

LAA Comment

LAA Technical Leaflet TL 3.24: Camera Installations refers. In addition to this, care should be taken to consider aerodynamic effects if cameras are mounted to exterior surfaces.  For example, the website article VAF – GoPro Mount RV-9A reported an increase in the stall speed of 12kts for a fuel-cap-mounted GoPro.

BMAA Comment

Aerial photography is a popular activity amongst pilots. However, cameras and associated mountings can become loose and cause damage, or if badly positioned affect the aircraft’s aerodynamics or structural strength. Therefore, it is vital that when fitting a camera to a microlight, good design practice is followed and the installation is approved by the BMAA as a modification. Except in very unusual circumstances, the modification will be classed as minor and will be processed by the BMAA in only a few days. BMAA Technical Information Leaflet No.017 dated March 2018 refers.

CHIRP Comment

There are some great cameras and equipment available these days that are small and self-contained and which can provide an important addition to safety and instructional efficiency because they give valuable insights and factual evidence as to what was going on both in the cockpit and externally. However, although the carriage of some electronic equipment in the cockpit can be very beneficial, care must be taken to ensure that appropriate risk assessments are made so that any mountings and equipment are secure and safe. Also, as we said previously in GA FEEDBACK Ed84, the use of recording devices that could be a distraction should be avoided, and pilots should also avoid providing a running commentary to any recoding equipment because this can sap mental capacity and distract from the conduct of the flight.

These days we’re so used to simply attaching such equipment to car windscreens etc that we can sometimes forget about the unique requirements that come with their use in aircraft. The key things to think about are that they must not interfere with any cockpit controls; not obstruct the pilot’s view of the instruments (or the pilot’s external view); must not cause a distraction to the pilot; and a Push/Pull test should be carried out to make sure the item is secure when installed (see the CAA/EASA CS-STAN references for advice on suitable test loading). Also, if suction mounts are used inside the cockpit or cabin, a secondary retaining lanyard or strap should be attached to the unit to prevent any damage or a control jam if the suction mount were to become detached. In that respect, it’s also important to consider where and to what part of the aircraft the lanyard is attached; drilling holes randomly in the flight deck would effectively be an unapproved modification. Secondly, lanyard length should be based on restricting freedom of movement of the equipment were it to become “unstuck”, and not on the ease of attachment/detachment of the equipment in use. Equally important, lanyards (and any connecting cables and leads) can present their own problems if they’re at risk of fouling things or getting in the way, and so their positioning and length also require careful consideration. Finally, multi-installations that end up festooning the cockpit with equipment should also be carefully reviewed; ultimately, we need to consider why we are putting things in the cockpit in the first place and limit them to those that are absolutely valuable to the flight’s purpose.

The CAA reacted swiftly to CHIRP’s suggestion that the old CAP1369 was outdated by withdrawing it from use. However, many pilots were probably not even aware that CAP1369 existed. CHIRP agrees that the issue of cockpit installation of electronic equipment needs greater awareness, and we have suggested that the CAA could include an article in relevant safety channels such as Clued-Up, SkyWise or ‘Safety Sense’, even if just to publicise the withdrawal of CAP1369 and point people towards the appropriate website links.

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