Narrative:

I was hired to participate in the filming of a segment for a tv show. The production company had been filming similar episodes all around the country using the same basic set-up. They were using [small] hd cameras; mounted using a very strong suction cup under the wing behind the strut. I have seen numerous videos online that are shot in a similar manner. I had been told; and was under the impression that no paperwork is required for such a setup; because the suction-cup mount is rated for 200mph+ (well under vne) doesn't require any physical alteration of the airplane (no modifications; tools; fasteners; etc.) and is so small that presumably the aerodynamic effect is trivial. We took appropriate precautions to mount the camera where it wouldn't physically interfere with any controls. As it was behind the strut; beneath the wing and inboard of the airflow to the ailerons; I knew that the very small camera should not generate any significant aerodynamic issues (no more than opening a window and holding my hand out in flight). The suction cup mounting system is incredibly strong; so the likelihood of the camera falling was negligible. And we mounted it in a position where; if it did fall off; it would fall away from all parts of the airplane (avoiding in-flight damage to the airframe). The camera's weight (less then 2 pounds; including the mounting system) was accounted for in the weight and balance calculations. Believing that all was safe and legal; we flew the flight; filmed the segment; and landed without incident. There had been no noticeable change to flight characteristics or performance. The cameras were then removed. Several months later; I read an article from AOPA which suggested that; even though the far's do not specifically address this issue; it may be necessary to produce paperwork; even for such a temporary installation. AOPA stated that the experts do not agree on which exact rules are applicable; or what paperwork is necessary: whether an a&P mechanic can simply make a log entry; or if the plane must be temporarily placed in the restricted category; or if an stc is required. So; it seems probable that I have violated a regulation without knowing it. I feel that the FAA should provide guidance on the subject as these types of cameras continue to proliferate. Many well-intentioned pilots may be unintentionally violating whichever regulations apply (again; AOPA wasn't specific as to which regulation is applicable; since 'experts' disagreed on the interpretation of existing rules). Even after a fair amount of research; I could find no clear answer as to what procedure would enable this kind of temporary installation to be accomplished; even though there was unanimous agreement that it was possible to do legally; and without adverse effects to the airplane. Consider too that; with these sorts of cameras; it is tempting and possible to mount it on a different part of the plane to get different viewing angles each flight--would a separate stc be required every time? Would separate paperwork be required each time the suction cup is attached; and again each time it is removed (a process that takes about 5 seconds)? Or would a single log entry account for mounting and removing the camera multiple times; as long as it is done in the same fashion; with the same attention to safety? Personally; I feel that such camera installations should be permitted with little or no paperwork; provided that the PIC understands the responsibility to take appropriate precautions to: 1) mount the camera securely without structurally modifying the aircraft; 2) mount the camera in a location that is not aerodynamically sensitive (i.e. Away from control surfaces; pitot/static ports; air inlets or vents; and aerodynamic devices); 3) mount the camera in locations where there is no possibility of physical interference with moving components of the airplane; or blocking of critical visual references for the pilot. In anycase; I recommend that the FAA provide more clarity on the topic. I think I've done as much or more research on the topic than most pilots would; and I still am not sure how to accomplish this type of mission legally in the future. It seems that interpretation (and potential enforcement) in this area could very well be subject to the whim of any individual FAA inspector.

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Original NASA ASRS Text

Title: Reporter mounted a small HD camera on an aircraft wing to film for a TV show and afterward was uncertain if he had violated an FAR because he had no log book entry; STC or other permission to modify the aircraft.

Narrative: I was hired to participate in the filming of a segment for a TV show. The production company had been filming similar episodes all around the country using the same basic set-up. They were using [small] HD cameras; mounted using a very strong suction cup under the wing behind the strut. I have seen numerous videos online that are shot in a similar manner. I had been told; and was under the impression that no paperwork is required for such a setup; because the suction-cup mount is rated for 200mph+ (well under Vne) doesn't require any physical alteration of the airplane (no modifications; tools; fasteners; etc.) and is so small that presumably the aerodynamic effect is trivial. We took appropriate precautions to mount the camera where it wouldn't physically interfere with any controls. As it was behind the strut; beneath the wing and inboard of the airflow to the ailerons; I knew that the very small camera should not generate any significant aerodynamic issues (no more than opening a window and holding my hand out in flight). The suction cup mounting system is incredibly strong; so the likelihood of the camera falling was negligible. And we mounted it in a position where; if it did fall off; it would fall away from all parts of the airplane (avoiding in-flight damage to the airframe). The camera's weight (less then 2 pounds; including the mounting system) was accounted for in the weight and balance calculations. Believing that all was safe and legal; we flew the flight; filmed the segment; and landed without incident. There had been no noticeable change to flight characteristics or performance. The cameras were then removed. Several months later; I read an article from AOPA which suggested that; even though the FAR's do not specifically address this issue; it may be necessary to produce paperwork; even for such a temporary installation. AOPA stated that the experts do not agree on which exact rules are applicable; or what paperwork is necessary: whether an A&P mechanic can simply make a log entry; or if the plane must be temporarily placed in the Restricted category; or if an STC is required. So; it seems probable that I have violated a regulation without knowing it. I feel that the FAA should provide guidance on the subject as these types of cameras continue to proliferate. Many well-intentioned pilots may be unintentionally violating whichever regulations apply (again; AOPA wasn't specific as to which regulation is applicable; since 'experts' disagreed on the interpretation of existing rules). Even after a fair amount of research; I could find no clear answer as to what procedure would enable this kind of temporary installation to be accomplished; even though there was unanimous agreement that it was possible to do legally; and without adverse effects to the airplane. Consider too that; with these sorts of cameras; it is tempting and possible to mount it on a different part of the plane to get different viewing angles each flight--would a separate STC be required every time? Would separate paperwork be required each time the suction cup is attached; and again each time it is removed (a process that takes about 5 seconds)? Or would a single log entry account for mounting and removing the camera multiple times; as long as it is done in the same fashion; with the same attention to safety? Personally; I feel that such camera installations should be permitted with little or no paperwork; provided that the PIC understands the responsibility to take appropriate precautions to: 1) mount the camera securely without structurally modifying the aircraft; 2) mount the camera in a location that is not aerodynamically sensitive (i.e. away from control surfaces; pitot/static ports; air inlets or vents; and aerodynamic devices); 3) mount the camera in locations where there is no possibility of physical interference with moving components of the airplane; or blocking of critical visual references for the pilot. In anycase; I recommend that the FAA provide more clarity on the topic. I think I've done as much or more research on the topic than most pilots would; and I still am not sure how to accomplish this type of mission legally in the future. It seems that interpretation (and potential enforcement) in this area could very well be subject to the whim of any individual FAA inspector.

Data retrieved from NASA's ASRS site as of April 2012 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.