Letters: October 2014

Thanks for your coverage of angle of attack systems for general aviation aircraft in the September 2014 issue of Aviation Consumer. The MMOPA (Malibu-Mirage Owners and Pilots Association) has taken the position that this technology is an important enhancement to safety and we applaud the FAA for working to streamline the installation approval process as a minor alteration in many aircraft.

However, as owners and pilots of a pressurized aircraft, we were disappointed that the FAA guidance excludes pressurized aircraft, and that the installations for which must be “evaluated on a case-by-case basis.” Of course, that means subject the interpretation of one’s local FSDO, which is the can of worms everyone is trying to avoid. I thought your readers would be interested in some important progress the MMOPA has made, which might be helpful for other type clubs.

Earlier this year, MMOPA initiated a project with Alpha Systems (with guidance from the FAA and Piper Aircraft) to define an AoA installation procedure for the PA46. That installation was successfully completed earlier this summer and all parties agree it falls within the boundaries of a minor alteration and the authority of a mechanic to install and return the aircraft to service with a simple log entry. This means there is no field approval, FAA 337 form or STC required. That’s a photo of the Alpha Systems indicator, above, installed on the PA46 windshield post.
Our goal is to encourage installation of this potentially life-saving technology throughout the Malibu and GA fleet. Details of the PA46 installation are available free to our members at mmopa.com. Non-members may email me for a copy at [email protected].
Jonathan Sisk, Ombudsman Malibu-Mirage Owners and Pilots Assoc.

Your excellent GoPro/Garmin VIRB action camera comparison article in the September 2014 issue briefly mentioned external camera mounting. Do you have any concrete insights or information on the current legality of doing so on certificated aircraft? What I’ve read in the past ranges from “can’t legally be done” to “grey area.” Have there been updates in regulations or interpretation? Or has it reached the point that so many pilots are doing it that it’s being ignored?

Greg Brown
via email

Good question, Greg. There’s no specific regulation that addresses camera installations, but we suspect there might be one soon. We heard from a reader that’s being threatened with an FAA violation because a camera mount was glued to the fuselage of his Cessna, even though a mechanic signed it off in the aircraft logbook as a minor alteration. Based on our research, a violation might be difficult to prove.

We presented the topic to the FAA’s aircraft certification division in Washington, D.C., and were provided with a FAA memo (it’s guidance, not regulation) that addresses external camera mounting and its alteration status.
In it, the FAA’s Aircraft Maintenance Division, in coordination with the Small Airplane Directorate, ACE-100, states (in part) that because of the varying installation possibilities of this equipment, determining a major versus minor alteration is done on a case-by-case basis and is made by the installer.

The key here is understanding the definition of a major alteration. Those are alterations that have an appreciable effect on weight, balance, structural strength, performance, powerplant operation, flight characteristics or other qualities affecting airworthiness.

The memo also says (in part) that the use of suction cups or other temporary methods of attachment (not including permanent attachments to the aircraft) would not be considered a major modification to the aircraft.
However, the memo goes on to say that the use of these types of attachments are not supported by the FAA, and may (in the case of an inflight detachment) lead to “careless operations” as provided for in FAR 91.13 and 91.15.

You should bear in mind that attaching a camera mount—particularly the surface mounts offered by GoPro—using the strong adhesive on the mount will likely result in a permanent installation, unless you want to use a heat gun to remove it. According to an FAA safety inspector we spoke with, that’s a good reason to have the installation evaluated and signed off as a minor alteration by a certificated mechanic.

Editor Larry Anglisano’s commentary on affordable trainers in your September 2014 issue was right on the money, no pun intended.

As he pointed out, AOPA is doing the right thing to present affordable trainer solutions, but for $90,000, I demand more than what the Yellow Bird 152 can deliver. On the other hand, maybe it will finally drive down the cost of overpriced LSAs.

William Hastings
via email