Flight worthiness proof for new hardware? what's needed 1

[Higgler]

A friend is developing a new stabilized camera mount platform for aircraft. He's flying one in February on an experimental helo aircraft and says the unit has to be "flight worthy", but says no certificate is needed or planned for that test, which surprised me.

Question: What's needed to be able to sell them commercially. Is there a rating systems based on airspeed or aircraft type and location?

thanks,
kch

 

[berkshire]

He is right for an experimental aircraft.
However for a standard certified aircraft he would need an STC or at the very least a 337 form with a field aproval.
B.E. Evans.

 

[debodine]

berkshire is right about standard certificated aircraft needing an FAA approval. And to sell commercially, an STC is always a more viable basis (in the eyes of the FAA) for applying the modification to additional aircraft of that type than a field approval.

However, an STC typically requires significantly more work and costs significantly more to accomplish.

Actually a field approval is for a single aircraft and is not supposed to be expandable to cover more aircraft. It can, however, sometimes be acceptable to the FAA to use a field approval as part of the substantiation to get an approval on other aircraft.

Even with an STC the installer is still required by the FAA to accomplish all the due diligence to make sure the modification does not negatively impact the airworthiness of the added aircraft. However, since most of the really significant legwork is done to initially obtain the STC, adding additional aircraft is usually easier down the road.

debodine

 

[berkshire]

I guess when I wrote my reply, I should have expanded it a little more.
Debodine lays this out a little more.However one of the things to be careful about is : Is this camera mount going to be internal shooting through a hole in the belly or side of the aircraft, or external mounted in a pod?
If it is external, then you are going to have to demonstrate that it will not, have any adverse effects upon the handling or flight characteristics of the aircraft you choose to fit it to.
You may have to take a standard certified aircraft and temporarily place it in the experimental, flight research and development category while you are testing this unit.
B.E.

 

[Higgler]

The camera mount is an external pod.
Does "demonstrate that it has no adverse affects" mean flight testing only?

Thanks all,
kch

 

[berkshire]

You may need a bit more tha flight testing.
As a general rule you will have to show that it does not mess up the flying characteristics. You also will have to show adequate reserve strength or beef up whatever you mount it to.
Check AC 43.13-2a acceptable methods techniques and practices aircraft alterations.
B.E.

 

[SAITAETGrad]

Hold the phone. I am a bit confused on the situation and the question. There are of course many thousands of experimental aircraft flying in the US. If the camera pod is for use on experimental aircraft i.e. kit aircraft, there are no requirements (to my knowledge) for selling the product commercially. The aircraft builder is responsible for the airworthiness of the aircraft configuration. Yes, there is an inspection process with an FAA delegate before the first flight but these delegates are often just other kit builders without formalized training. Experimental aircraft are modified all the time by owners without controls. If your friend ties his SonyCam to his pitot tube with some hay wire and declares it airworthy, then it is airworthy.

 

[SAITAETGrad]

Sorry, post above was unclear. For experimental kit aircraft, owner=builder=manufacturer. The owner of the aircraft is responsible for airworthiness. You can sell an accessory to an experimnetal kit aircraft owner without fulfilling any FAA requirements. This is not to say you don't have a legal or ethical obligation.

 

[debodine]

SAITAETGrad:

In the original post, Higgler asked on behalf of his friend, "What's needed to sell them commercially." Berkshire and I were describing what would be needed for non-experimental certificated aircraft. However, your point is well taken that perhaps he only meant to sell commercially for other experimental aircraft.

In my world an STC to approve our modifications on Part 25 aircraft is always our goal, and I just ran with my assumption without asking Higgler.

debodine

 

[berkshire]

Saitaetgrad,
You are correct as far as you go.
And this is what I said in my original reply.
His friend is right as are you. The fun with this thing starts when as Higgler, indicates in his original question, he wants to sell them commercially. If he only sells to people with experimental aircraft there is no problem.
He probabaly would not have much of a problem installing one on a Restricted category aircraft either.
The jumping through hoops starts when he wants to sell the mount to people with aircraft Licenced in the standard category.
B.E.

 

[Higgler]

Gentlemen,
thanks for the inputs. We hope to sell these items to both experimental and standard aircraft owners such as;
police, military, fire and rescue, border patrol, etc.

Sounds like experimental is easy, do a good design and let the experimental owner test the units. For sales to say a police helo, that requires proof and certification of an airworthy design.

Primarily the camera mount will be on helo's, so the speed is fairly low. Actually, one of the units is for a two person powered ultralite.

kch

 

[debodine]

Higgler:

Much success to you and your friend on the project. I hope I see your design successfully marketed sometime in the near future!

debodine

 

[planedr]

Higgler
I've been in on a few of these

Develope a good stress package for the camera and it's mounts. This will have manouvers and aero components.

Depending on the aircraft and it's envelope you can then cherry pick the critical elements. Then do the load interface to the aircraft.

If you do the aero bit right you can determine the effects on the given aircraft for handling etc. Flight test if required to determine what supplements will be required.

337's are great but hardly commercial. STC's are expensive and type certificate limited. Find a friendly DER and go 8110. Unless you have a rich friend who wants multiple STC's then give me a call......

SAITAETGRAD - what year? 97 myself

 

[debodine]

Higgler:

Planedr has an interesting idea for you, and I wanted to give just a little bit more info.

He suggests having a DER approve the data with an FAA Form 8110-3, rather than go for an STC or an FAA Form 337 approval.

As long as you keep in mind the differences between an 8110-3 approval and an STC, you may find his suggestion to just seek DER approval of your data may be the way to go. It is important to remember that a DER may approve engineering data, but may not approve installations.

To install a product (that causes a change to the original type certificated configuration) on an aircraft that is certificated with a standard airworthiness certificate (as opposed to a special airworthiness certificate, which includes experimental), there is typically a two step process. First, is approval of the engineering data to make the configuration change. Second is approval of the installation.

Lets consider each step individually. Keep in mind that I may not be recording all the various nuances of the process, and others more experienced than I may chime in here. Also, although I worked in general aviation years ago, now I work almost exclusively with Part 25 aircraft in the transport catagory, so I don't know (or remember) all the possible approval paths that may exist in other catagories.

Engineering data approval. May be accomplished by an FAA engineer (normally from the Aircraft Certification Office, ACO) or by an appropriately rated DER (who stands in place of the FAA for the purpose of data approval). This approval will be documented on an FAA Form 8110-3 (I am ignoring the DAS process for now, as I am assuming you and your friend are not a DAS nor associated with one). Once the data is approved, then the installation may take place. What planedr is suggesting is that you go this far and stop, if I understand correctly.

Installation approval. May be accomplished by an FAA inspector (normally from the Maintenance and Inspection District Office, MIDO) or by an appropriately rated DAR or DMIR. This approval will be documented on an FAA Form 8130-9. Once the installation is approved, the aircraft may be returned to service.

Keep in mind that if you sell the customer a DER approved data package, the customer must bear all the costs and logistics of finding an appropriately rated installer, making the findings of compliance with the prototype installation, performing the testing and analysis necessary to substantiate the installation, performing required ground/flight testing as needed, etc. This will have to occur for every single aircraft into which your DER approval data package is installed.

If you sell the customer the right to install an STC, then for the aircraft type covered by that STC, all the customer needs to do is find an appropriately rated installer who will install the STC kit in accordance with the STC data, and perform any operational testing (usually significantly less detailed than the ground/flight testing required for the issuance of the STC, because the really rough and costly stuff (making the findings of compliance with the prototype installation, performing the testing and analysis necessary to substantiate the installation, performing required ground/flight testing as needed, etc) has already been accomplished to obtain the STC.

Consequently, you must consider your target market. If your target market will be fleets of similar aircraft in the transport/commuter catagories of the standard certificate, you may want to bear the cost upfront of one STC package for each fleet type you believe you can sell to profitably. Those types of fleet operators will almost always prefer a product that already has an STC.

If you will market to a mixed bag of aircraft (such as general aviation and some levels of business aviation), usually each one owned by a different customer, rarely have similar types, etc...then get a DER approval of your engineering data as planedr said.

Sorry to provide a long and probably boring breakdown, but from what you describe (that your intended market is general aviation rather than commercial fleets of transports or commuters), you are probably much better off to consider seriously the suggestion by planedr to just get DER approval of your data. If I am wrong though, I hope you can use the information above to more clearly define your options.

debodine

 

[debodine]

My grammar sucks today...in the post above, of course data is plural and every case I typed of "data is" should have been either "data package is" or "data are".

My use of parentheses sucks also, but I won't bother with the details.

Maybe I should not create emails anymore while eating lunch. I guess I was concentrating too much on enjoying my sandwich.

debodine

 

[planedr]

I guess I could have elaborated but debodine basically nails it. Although I wouldn't put the installation onus on my customer. I would get the 8110-3 package for the equipment so the equipment "loads" are approved. Then installation and interface loads and modifications approved for each aircraft, and then have a DAR approve the installation. Or the good old 337.....

In Canada all you need would be an LSTC much simpler that way.

 

[thruthefence]

Just to "muddy" the waters alittle more, aren't most "Police Helicopters" , (one of his potential markets" considered "Public aircraft" and thus are not subject to the surveillance of the FAA?