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Safety Recommendation Details

Safety Recommendation A-03-064
Details
Synopsis: Since January 2000, the National Transportation Safety Board has investigated numerous accidents involving turbine-powered aircraft not required to operate with either a cockpit voice recorder (CVR) or a flight data recorder (FDR). These accidents involved aircraft operating under 14 Code of Federal Regulations (CFR) Parts 91 and 135. Included among these accidents was the October 25, 2002, accident involving a Raytheon (Beech) King Air that crashed on approach to Eveleth-Virginia Municipal Airport, Eveleth, Minnesota, killing all eight persons on board, including Senator Paul Wellstone. The airplane was not equipped with either a CVR or an FDR at the time of the accident, nor did Federal regulations require it to be so equipped.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Require all turbine-powered, nonexperimental, nonrestricted-category aircraft that are manufactured prior to January 1, 2007, that are not equipped with a cockpit voice recorder, and that are operating under 14 Code of Federal Regulations Parts 91, 135, and 121 to be retrofitted with a crash-protected image recording system by January 1, 2007. (Supersedes A-99-60) (Superseded by A-09-10)
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action/Superseded
Mode: Aviation
Location: Eveleth, MN, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA03MA008
Accident Reports: Loss of Control and Impact With Terrain Aviation Charter, Inc., Raytheon (Beechcraft) King Air A100, N41BE
Report #: AAR-03-03
Accident Date: 10/25/2002
Issue Date: 12/22/2003
Date Closed: 2/9/2009
Addressee(s) and Addressee Status: FAA (Closed - Unacceptable Action/Superseded)
Keyword(s): Image Recorders,Part 135,Recorders

Safety Recommendation History
From: NTSB
To: FAA
Date: 2/9/2009
Response: This recommendation was superseded by A-09-10 in the following letter to the FAA]: The Safety Board notes that the accident helicopters were not required to have a cockpit voice recorder (CVR) or a flight data recorder (FDR) installed but that they would have been subject to the requirements for a cockpit image recorder that were included in Safety Recommendation A-03-64 (which was issued on December 22, 2003, along with Safety Recommendations A-03-62 and -65) if the FAA had implemented this recommendation. The Safety Board notes that government and industry representatives have been participating since 2007 in a European Organization for Civil Aviation Equipment (EUROCAE) working group to develop a flight recorder specification titled, Minimum Operational Performance Specification for Lightweight Flight Recorder Systems” (ED-155). (Both the Board and the FAA are members of this working group.) When finalized, ED-155 is expected to address recent improvements in technology by establishing the minimum performance requirements for flight recorder systems that could be used on board smaller aircraft (such as the accident helicopter models). This specification targets a more affordable flight recorder option for smaller aircraft than traditional CVRs or FDRs and addresses the recording of audio, image, and parametric information. As currently written, ED-155 identifies parameters that should be recorded according to the type of aircraft (that is, airplane or helicopter). Also, ED-155 accommodates variations in aircraft complexity by identifying parameters that should always be recorded and parameters that should be recorded if an information source for the parameter is used by aircraft systems and/or the flight crew to operate the aircraft. ED-155 is expected to be issued by June 2009. It is also important to note that Bell Helicopter Textron and American Eurocopter have been developing digital imaging recorders as FAA nonrequired safety-enhancing equipment hardware. According to the safety department managers at Bell Helicopter Textron and American Eurocopter, the recorders (which are not required under Parts 27, 29, 91, or 135) are expected to provide digital imaging of the cockpit and its instruments at a sampling rate of between one and eight frames per second. The recorders are also expected to record ambient cockpit noise and flight data.

From: NTSB
To: FAA
Date: 5/8/2006
Response: Between December 22, 2003, when these recommendations were issued, and February 6, 2006, the day before the Safety Board's meeting concerning the Hendrick Motorsports accident, the Board investigated 22 accidents involving Beech King Air aircraft in which no recorder of any type was available to investigators. Of these 22 accidents, 9 were fatal; a total of 43 people died. The Board emphasizes that these numbers only involve the model of aircraft involved in the Hendrick Motorsports accident, and do not include all accidents involving the turbine powered, nonexperimental, nonrestricted-category aircraft that these recommendations address. The Board also emphasizes that Safety Recommendation A-03-63 does not ask for the installation of video image recorders; rather, it recommends that already-available CVR technology be required in this type of aircraft. The FAA should be able to move quickly to implement this recommendation without waiting for development of image recording technology and products. To date, Safety Recommendations A-03-62 thru -65 are classified OPEN—UNACCEPTABLE RESPONSE; the FAA has taken no specific action in response to Safety Recommendation A-03-63. The Safety Board asks the FAA to re-evaluate the importance of these recommendations and to initiate action as soon as possible.

From: NTSB
To: FAA
Date: 4/26/2006
Response: The FAA indicated that it believes that the intent of these recommendations is primarily to collect parametric data from images of the cockpit instrumentation. The FAA also indicated that current CVR and FDR regulations are performance-based rules and, as a result, must specify what parameters or actions must be recorded and the minimum accuracy of the recorded information. Because of these beliefs and concerns, the FAA initiated a project to identify what should be recorded and whether an image recorder is sufficient for recording parameter data. What should be recorded? The FAA notes that while the European Organization for Civil Aviation Equipment's (EUROCAE's) Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112) has detailed resolution and accuracy requirements, the FAA believes that there has never been an image recorder system manufactured or installed for the purpose of obtaining parametric data from cockpit instrumentation. To address these issues, the FAA is developing a "proof-of-concept" test that will install an image recorder system in a simulator and on an FAA airplane. The simulator and the aircraft will be flown, and images of the flight deck instrumentation will be recorded at the resolution and rates defined by ED-112. These images will be analyzed to derive parametric data, which will be compared to actual data recorded on the airplane to determine the accuracy of the derived data. Other factors affecting image recording will also be reviewed, including lighting condition changes, instrument glare, and blockage resulting from normal crew actions. Safety Board personnel are working with FAA staff on these evaluations. The FAA indicated that the tests had been concluded in June 2005, that the evaluations are currently in progress, and that they should be completed soon. Although one of the primary benefits of an image recording system is the potential to obtain parametric data from images of the cockpit instrumentation, the Board does not agree with the FAA that the intent of these recommendations is primarily to collect parametric data. In the letter that transmitted these recommendations to the FAA, the Board stated the following: Such [video image] recorders obtain not only audio information like that from CVRs and event data like that from FDRs, but also information about the environment outside the cockpit window. The parametric data study the FAA is conducting concerns issues related to "event data like that from FDRs," but even if a video recorder cannot capture this data, it will still provide valuable audio information and can provide information on pilot actions and on the environment outside the aircraft. This is particularly relevant in aircraft where no other information is recorded or available. While recognizing the value of the FAA's study, the Board does not believe it is a valid basis for delaying the recommended actions. Even if the study determines that parametric data cannot be obtained, there will be great value to the Board's investigations in obtaining audio information and information on pilot actions and on the outside environment. In order for the FAA's actions in response to these recommendations to be acceptable, the FAA must prepare and issue the recommended regulations. Pending the FAA's taking the recommended actions, Safety Recommendations A-03-62 through -65 remain classified OPEN—UNACCEPTABLE RESPONSE.

From: NTSB
To: FAA
Date: 3/23/2006
Response: Notation 7764: The National Transportation Safety Board has reviewed the Federal Aviation Administration (FAA) Notice of Proposed Technical Standard Order (TSO) C176, Aircraft Image Recorder Systems, which was published in the Federal Register, Volume 71, Number 17, on January 26, 2006. This proposed TSO provides manufacturers and installers of aircraft image recorder (AIR) systems with the information they need to seek a TSO authorization or letter of design approval, and the minimum performance standards (MPS) their AIR systems must meet. New models of AIR systems identified and manufactured on or after the effective data of this TSO will be required to meet the MPS as specified in the TSO, which is based on the European Organization for Civil Aviation Equipment (EUROCAE) document ED-112, Minimum Operational Performance Specifications (MOPS) for Crash Protected Airborne Recorder Systems, dated March 2003, or the most current revision. The Safety Board believes that incorporation of EUROCAE’s ED-112 into a TSO represents a good first step toward developing a standard for crash-protected airborne image (video) recording systems. However, certain requirements in the underlying ED-112 document must be modified to ensure that useful data are obtained from any airborne image recorder manufactured and installed under this TSO. The Safety Board has made recommendations to require cockpit image recorders in larger commercial aircraft and in smaller turbine-powered aircraft. For larger aircraft, image recorders would be in addition to the traditional cockpit voice and flight data recorders normally installed on this category of aircraft. Such cockpit image recorders would record the general cockpit environment and would capture additional data that may not be recorded on existing recorders, including who is in the cockpit, non-verbal crew interactions, and characteristics of the cockpit environment (for example, smoke). The recommendation for larger transport aircraft asks the FAA to accomplish the following: Require that all aircraft operated under Title 14 Code of Federal Regulations Part 121, 125, or 135, and currently required to be equipped with a cockpit voice recorder (CVR) and digital flight data recorder (DFDR) be retrofitted by January 1, 2005, with a crash-protected cockpit image recording system. The cockpit image recorder system should have a 2-hour recording duration, as a minimum, and be capable of recording, in color, a view of the entire cockpit including each control position and each action (such as display selections or system activations) taken by people in the cockpit. The recording of these video images should be at a frame rate and resolution sufficient for capturing such actions. The cockpit image recorder should be mounted in the aft portion of the aircraft for maximum survivability and should be equipped with an independent auxiliary power supply that automatically engages and provides 10 minutes of operation whenever aircraft power to the cockpit image recorder and associated cockpit camera system ceases, either by normal shutdown or by a loss of power to the bus. The circuit breaker for the cockpit image recorder system, as well as the circuit breakers for the cockpit voice recorder and the digital flight data recorder, should not be accessible to the flight crew during flight. (A-00-30) The Safety Board has also issued recommendations to address the lack of recording devices on smaller turbine-powered aircraft. Although Safety Board investigators can sometimes partially compensate for the lack of CVR and FDR data by using radar data or air traffic control recordings, this information does not provide the same level of detail about the aircraft’s flight path, flight conditions, and operations. Furthermore, when accidents occur outside radar or ATC coverage, radar data or air traffic control recordings are not available. The Safety Board addressed the need for video image recording systems in smaller turbine-powered aircraft in Safety Recommendation A-99-59, issued to the FAA on February 8, 2000, and in Safety Recommendations A-03-62, A-03-64, and A-03-65, issued to the FAA on December 22, 2003. The Safety Board understands the significant economic impact to an operator if both a CVR and an FDR are required on smaller aircraft. As a solution to this problem, the Safety Board recommendations proposed that all smaller turbine-powered aircraft in this class be equipped with a single crash-protected video image recorder: Incorporate the European Organization for Civil Aviation Equipment’s [EUROCAE] proposed standards for a crash-protective video recording system into a technical standards order [TSO]. (A-99-59) Require the installation of a crash-protected image recording system on all turbine-powered, nonexperimental, nonrestricted-category aircraft that are manufactured after January 1, 2007, that are not equipped with a flight data recorder, and that are operating under 14 Code of Federal Regulations Parts 135 and 121 or that are being operated full-time or part-time for commercial or corporate purposes under Part 91. (A-03-62) Require all turbine-powered, nonexperimental, nonrestricted-category aircraft that are manufactured prior to January 1, 2007, that are not equipped with a cockpit voice recorder, and that are operating under 14 Code of Federal Regulations Parts 91, 135, and 121 to be retrofitted with a crash-protected image recording system by January 1, 2007. (A-03-64) Require all turbine-powered, nonexperimental, nonrestricted-category aircraft, that are manufactured prior to January 1, 2007, that are not equipped with a flight data recorder, and that are operating under 14 Code of Federal Regulations Parts 135 and 121 or that are being used full-time or part-time for commercial or corporate purposes under Part 91 to be retrofitted with a crash-protected image recording system by January 1, 2010. (A-03-65) In March 2003, EUROCAE issued a technical standard for cockpit image recording systems: ED-112, MOPS for Crash Protected Airborne Recorder Systems. This standard established crash/fire survivability requirements, stipulated recording duration, video frame rate, and video resolution, and established the minimum acceptable cockpit view. The Safety Board believes that the proposed TSO, which incorporates ED-112 standards into the manufacture of airborne image recording systems, is responsive to Safety Recommendation A-99-59, and recognizes this effort as a positive step forward. However, the Safety Board notes that a TSO based solely on the ED-112 MOPS may not adequately specify all of the requirements needed to produce and field a cockpit image recording system in all turbine-powered aircraft operating within the U.S. To evaluate the issues involved in developing a TSO minimum specification for an aircraft image recording system, the FAA and the Safety Board have participated in a “proof-of-concept” flight test, using an FAA-owned Beechcraft BE200 King Air fitted with special image recording equipment. The test was conducted on June 27, 2005. Engineers from the Safety Board, along with engineers from the FAA and industry, participated in this test, which was specifically designed to evaluate the effectiveness of the ED-112 MOPS. The results of this test indicated several areas in which the minimum requirements specified in the ED-112 MOPS must be modified to ensure that the imaging system produces useful data. These areas include the recording of cockpit audio, the spatial resolution of the recorded images, the minimum acceptable frame rate, the use of color displays and aural warnings to present information to the pilot, the capability to capture a view of the environment outside the cockpit, and the ability to recover data from a crash-damaged recorder. Although the ED-112 specification for spatial resolution is thought to be sufficient for accident investigation purposes, the Safety Board believes that the frame rate specified in ED 112 will prove insufficient to adequately capture all important cockpit information and that a higher frame rate is required to faithfully capture potentially critical information, such as rapid flight control movements and the activation of flashing warning lights in the cockpit. Although preliminary tests indicate that a frame rate of 10 Hz may be adequate, further research is required to determine a suitable minimum frame rate. Additionally, the ED-112 requirement to capture the entire instrument panel with a single camera may be inappropriate for certain aircraft, and multiple cameras may be required to capture all needed information in those cases. Furthermore, given the extensive use of color in presenting information to the pilot, the Safety Board believes that the acquisition and collection of color information should be required for all image recorder installations. Similarly, when the image recorder is the only recorder installed on an aircraft, cockpit audio should also be recorded, given the extensive use of aural warning sounds and speech for presenting information to the pilot. Based on the results of the FAA’s proof-of-concept flight test, the Safety Board believes that capturing a view of the environment outside the cockpit would prove extremely valuable in the analysis of many accidents, and that this option should be included in any airborne image recorder specification as a minimum requirement. In addition, the Safety Board believes that cockpit image recording systems capable of capturing a general view of the cockpit interior would aid significantly in the evaluation of certain human performance issues and would provide vital information concerning the pilot’s interaction with the aircraft. Finally, the Safety Board is concerned that extraordinary methods above and beyond those normally provided by the manufacturers will be necessary to successfully recover data from a solid-state image recorder that has been damaged or burned beyond the stated specifications in the TSO. Such efforts may require removal of the memory chips from the storage array and the recovery of the data from each chip individually. Further, successful reconstruction of the original data will require specific information that describes how the data is encoded and stored on the individual chips. This type of information is available only from the original manufacturer and designer of the recorder. The Safety Board understands the manufacturer’s need to protect its proprietary designs in order to maintain competitiveness in the marketplace. However, the Board believes that its need for this detailed design information is essential, especially given the historically long service life of recorders in the industry. The Safety Board believes that this detailed information should be an integral part of any FAA approval process and that it should be kept and made available throughout the life of the product. The TSO approval process should therefore require the manufacturers either to provide the necessary software re-assembly program needed to recover the original data from individual chips, or to provide the necessary technical instructions needed to reconstruct the original data from the information that is stored on the individual memory chips. In conclusion, the Safety Board believes that incorporation of EUROCAE’s ED-112 in a TSO represents a good first step toward developing a standard for a crash-protected airborne image (video) recording system. However, the Board notes that the ED 112 specification is not sufficient to ensure that an image recording system based on the TSO provides useful data when installed aboard turbine-powered aircraft operating within the U.S. Some of these modifications are enumerated and discussed in detail in Safety Board’s report NTSB-C176, Cockpit Image Recorder Proof of Concept Test, under development. The Safety Board appreciates this opportunity to comment on the proposed TSO and will support the FAA’s efforts to develop a useful TSO to support future regulations concerning airborne image recording systems.

From: FAA
To: NTSB
Date: 3/1/2006
Response: In its 3/1/2006 annual report to Congress, Regulatory Status of the National Transportation Safety Board's "Most Wanted" Recommendations to the Department of Transportation, the DOT wrote: This recommendation would require use of an image recorder to collect flight data in lieu of a CVR or DFDR for post accident or incident investigation. While the industry has published minimum operational performance criteria (EUROCAE ED-I 12) for such a system, to date, no such system has been installed on an aircraft that meets these requirements. The FAA is currently working with the NTSB to accomplish a proof-of-concept test to determine if an image recording system could be used to collect specific parametric data and other flight information. As part of the test, several imagerecording systems were installed on a FAA aircraft, The aircraft was flown in various operational and environmental conditions. The data that was recorded on those flights is being analyzed to determine if aircraft parameters such as altitude, attitude and airspeed can he accurately derived from the images. The derived data will be compared to the data that was recorded on the installed DFDR. The results of this analysis will he published in a FAA report that will be used to determine if an image recorder is an acceptable method for collecting flight data information on the aircraft that are subject of this recommendation. The FAA will use the results of this analysis along with other required considerations, to determine if rulemaking for this recommendation is warranted.

From: FAA
To: NTSB
Date: 10/11/2005
Response: Letter Mail Controlled 10/24/2005 2:37:14 PM MC# 2050494 Marion C. Blakey, Administrator, FAA, 10/11/05 The FAA has been actively working to address these safety recommendations, and is collecting data to establish an FAA position on aircraft image recorders. In order to develop an FAA position on this issue, some questions must be addressed: What would we record? By design, the current CVR and FDR regulations are performance-based rules. As such, the regulations specify what parameters or actions must be recorded and how accurate the information must be. The Board recommendations do not specify what data the image recorder should capture. The FAA believes that the intent of these recommendations is primarily to collect parametric data from the images of the cockpit instrumentation. Would an image recorder be sufficient for recording parametric data? While EUROCAE's Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112) has detailed resolution and accuracy requirements, to the best of our knowledge there has never been an image recorder system manufactured or installed for this specific purpose. Since this has never been done, the vendor claims for producing a low-cost camera and recorder system that can be installed on the subject aircraft that will meet the resolution necessary to derive parametric data from recorded images are unsubstantiated. To address these issues, the FAA is working with the Board to develop a "proof-of-concept'' test that will install an image recorder system in a simulator and on an FAA Beechcraft King Air airplane. The simulator and the aircraft will be flown and images of the flight deck instrumentation will be recorded at the resolution and rates defined by ED-112. These images will then be analyzed and Board and FAA accident investigators will derive parametric data from these flights. The derived data will be compared to actual data recorded on the airplane to determine the accuracy of the derived data. Other factors affecting image recording will also be reviewed. These include things such as lighting condition changes, instrument glare, and blockage due to normal crew actions. Tests were concluded during the month of June 2005 at the FAA's Technical Center. The final report, including the findings from this testing, should be completed by December 2005. I hope that this helps explain ongoing FAA activities and illustrates the amount of time and work that is required to evaluate fully and properly respond to these safety recommendations. I will keep the Board informed of the FAA's progress on this safety recommendation.

From: FAA
To: NTSB
Date: 2/1/2005
Response: In its 2/1/2005 annual report to Congress, Regulatory Status of the National Transportation Safety Board's "Most Wanted" Recommendations to the Department of Transportation, the DOT wrote: Despite numerous improvements in recorders of all kinds that have been mandated over the years, safety recommendations in this area continue to be uniquely difficult for the FAA to respond to in a manner that the Board finds acceptable. At present there are 26 open recommendations relating to CVRs, FDRs, or video recorders. Nine of these recommendations are on the Most Wanted list and are currently classified as "open-unacceptable." While the FAA works to address every safety issue identified by the Board and our overall record of success is excellent, our results in the recorder area have been mixed. Regarding image recorders specifically, the FAA participated in the Board's public hearing on this subject in July 2004, both as a party and by providing testimony on related technical and rulemaking issues. Strong opposition to image recorders was voiced by pilot groups. The FAA expects to have a position on this recommendation, which it will provide the Board within 6 months.

From: NTSB
To: FAA
Date: 12/15/2004
Response: The FAA's March 29, 2004, letter indicates that safety recommendations concerned with recorders of all kinds are uniquely difficult for the FAA to respond to in a manner that the Safety Board finds acceptable. On June 3, 2004, staff from the FAA and the Board met to discuss the FAA's responses to recommendations in this area. The discussion focused on general difficulties in applying conventional cost-benefit analyses to regulations regarding recorders. The discussion also focused on the differential feasibility of recommendations that affect both newly manufactured aircraft and aircraft in the existing fleet, and it was observed that although the Board has addressed its recorder recommendations separately to these two populations of aircraft, the FAA has seldom made a distinction between them in its responses. Although the June 3 meeting was constructive, the substance of Safety Recommendations A-03-62 through A-03-65 and A-99-59 was not discussed. A discussion of the implementation issues related to these and other image-recorder recommendations was accomplished during the Safety Board's Public Hearing on Aviation Image Recording on July 27 and 28, 2004. Witnesses from recorder and camera system manufacturers testified that image-recording systems compliant with EUROCAE's Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112, issued in March 2003) could be commercially available within a year of the FAA's issuance of a TSO based on ED-112. One witness estimated that a single-camera image recorder for smaller aircraft would cost between $3,000 and $5,000. Two other recorder manufacturers estimated that the equipment cost for a single camera installation in large aircraft would be about $10,000. These witnesses also noted that installation costs would vary widely but that they would be substantially less for installations in newly manufactured aircraft than as retrofits to existing aircraft. Witnesses who had participated in the EUROCAE Working Group that developed ED-112, as well as the manager of the FAA's Aircraft Engineering Division, testified that ED-112 provided a solid basis for the development of a TSO on an expedited schedule. The Safety Board notes that concerns have been expressed about privacy issues that could arise if cockpit image recorders were installed. At the recent hearing on image recorders, attention was focused on the effectiveness of privacy protections currently established for CVRs and their extension to cockpit image recorders. Testimony indicated that, since the 1990 Congressional passage of legislation protecting CVRs, no CVR recordings have been disclosed to the public in the United States. In that same period, witnesses could cite only one international instance of the public disclosure of a CVR recording. Counsel representing both plaintiff and defendant positions in civil litigation stemming from aircraft accidents testified that the statutory protections and judicial procedures regarding the use of CVR recordings in evidence were effective both in supporting litigation and in preventing public release of the recordings. Testimony revealed the need for other countries that lack similar protections to enact national legislation and rulemaking to extend those protections worldwide. Finally, hearing participants discussed the possibility of encrypting data that are recorded by the cockpit image recorders. Several witnesses testified that encryption is technically feasible, but the issues surrounding encryption, including who would have control over encryption keys and how that information would be shared in the international arena, were not resolved. At the hearing, FAA witnesses testified that even though virtually all of the specifications are already established in ED-112, a TSO addressing image recorders would not be released for public comment before the end of 2005. The FAA also stated that previous recorder system TSO efforts have taken 3 to 3 1/2 years to complete even with established EUROCAE documents in place. The FAA further testified that no action has been taken to initiate rulemaking in response to the Safety Board's image-recorder recommendations or to establish a priority for such rulemaking. The Safety Board continues to believe in the need for these recommendations and urges the FAA to take the recommended actions as quickly as practical. Because the FAA has not initiated action to issue an image-recorder TSO based on the EUROCAE's Minimum Operational Performance Standard for Crash Protected Recorder Systems (ED-112), Safety Recommendation A-99-59 was classified "Open--Unacceptable Response" at a November 9, 2004, meeting of the Safety Board that reviewed the List of Most Wanted Safety Improvements, which includes Safety Recommendation A-99-59. At that same meeting, Safety Recommendation A-03-64, which is also on the Most Wanted List, was classified "Open--Unacceptable Response" because the FAA has not yet taken any action in response to the recommendation. In neither its letter of March 29, 2004; the June 3, 2004, meeting between Safety Board and FAA staff; nor its testimony at the July 27 to 28, 2004, Safety Board Public Hearing on Aviation Image Recording has the FAA indicated that any action is being taken in response to Safety Recommendations A-03-62, -63, or -65. Accordingly, Safety Recommendations A-03-62, -63, and -65 are classified OPEN—UNACCEPTABLE RESPONSE. To assist the FAA in its consideration of these recommendations, the Board wishes to clarify that Safety Recommendation A-03-64 applies to full- and part-time commercial and corporate purposes under 14 CFR Part 91, as well as to Parts 135 and 121.

From: NTSB
To: FAA
Date: 11/9/2004
Response: In its November 9, 2004, meeting on the Board's Most Wanted List of safety improvements, the Board voted to classify this recommendation OPEN—UNACCEPTABLE RESPONSE.

From: NTSB
To: FAA
Date: 4/26/2004
Response: The FAA indicated that it believes that the intent of these recommendations is primarily to collect parametric data from images of the cockpit instrumentation. The FAA also indicated that current CVR and FDR regulations are performance-based rules and, as a result, must specify what parameters or actions must be recorded and the minimum accuracy of the recorded information. Because of these beliefs and concerns, the FAA initiated a project to identify what should be recorded and whether an image recorder is sufficient for recording parameter data. What should be recorded? The FAA notes that while the European Organization for Civil Aviation Equipment's (EUROCAE's) Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems (ED-112) has detailed resolution and accuracy requirements, the FAA believes that there has never been an image recorder system manufactured or installed for the purpose of obtaining parametric data from cockpit instrumentation. To address these issues, the FAA is developing a "proof-of-concept" test that will install an image recorder system in a simulator and on an FAA airplane. The simulator and the aircraft will be flown, and images of the flight deck instrumentation will be recorded at the resolution and rates defined by ED-112. These images will be analyzed to derive parametric data, which will be compared to actual data recorded on the airplane to determine the accuracy of the derived data. Other factors affecting image recording will also be reviewed, including lighting condition changes, instrument glare, and blockage resulting from normal crew actions. Safety Board personnel are working with FAA staff on these evaluations. The FAA indicated that the tests had been concluded in June 2005, that the evaluations are currently in progress, and that they should be completed soon. Although one of the primary benefits of an image recording system is the potential to obtain parametric data from images of the cockpit instrumentation, the Board does not agree with the FAA that the intent of these recommendations is primarily to collect parametric data. In the letter that transmitted these recommendations to the FAA, the Board stated the following: Such [video image] recorders obtain not only audio information like that from CVRs and event data like that from FDRs, but also information about the environment outside the cockpit window. The parametric data study the FAA is conducting concerns issues related to "event data like that from FDRs," but even if a video recorder cannot capture this data, it will still provide valuable audio information and can provide information on pilot actions and on the environment outside the aircraft. This is particularly relevant in aircraft where no other information is recorded or available. While recognizing the value of the FAA's study, the Board does not believe it is a valid basis for delaying the recommended actions. Even if the study determines that parametric data cannot be obtained, there will be great value to the Board's investigations in obtaining audio information and information on pilot actions and on the outside environment. In order for the FAA's actions in response to these recommendations to be acceptable, the FAA must prepare and issue the recommended regulations. Pending the FAA's taking the recommended actions, Safety Recommendations A-03-62 through -65 remain classified OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 4/7/2004
Response: Letter Mail Controlled 4/7/2004 11:54:09 AM MC# 2040154

From: FAA
To: NTSB
Date: 3/29/2004
Response: Letter Mail Controlled 8/18/2004 3:13:14 PM MC# 2040154 Despite numerous improvements in recorders of all kinds that have been mandated over the years, safety recommendations in this area continue to be uniquely difficult for the FAA to respond to in a manner that the Board finds acceptable. At present there are 25 open recommendations relating to CVRs, FDRs, or video recorders. Seven of these recommendations are on the Most Wanted list and currently classified as "open unacceptable." While the FAA works to address every safety issue identified by the Board, and our overall record of success is excellent, our results in the recorder area have been mixed. Recorder recommendations present unique challenges, including difficulties in cost/benefit analysis, technical hurdles, retrofit problems, issues about the use of data, and privacy concerns. All of these challenges are presented in these latest recommendations. This situation calls for a fresh approach. Our staffs have agreed that we should convene a meeting of top FAA and Board officials over the next few weeks to try and achieve a consensus on how to approach these issues across-the-board. This will not be a SWAT meeting where specific recommendations are targeted, but rather a meeting to work toward some conceptual agreements on how we can best meet the need for recording devices for effective accident investigation. Preparations for this meeting are underway. I give this effort my full support, and am confident you will do the same.

From: NTSB
To: FAA
Date:
Response: At the 1995 Board meeting addressing the NTSB’s Most Wanted List of Transportation Safety Improvements (MWL), the Board voted to place Safety Recommendations A-95-26 and A-95-27 on the Federal MWL under the issue category “Flight Data Recorders: Expanded Parameters.” In 1998 the name of this category was changed to “Automatic Information Recording Devices.” It became an intermodal category at the May 5, 1998 Board meeting addressing the NTSB’s Most Wanted List of Transportation Safety Improvements, when the Board voted to add Safety Recommendations H-90-28, M-95-6, R-96-46 and R-96-47. At the 1998 MWL Board meeting, the Board voted to change the category’s name to “Automatic Information Recording Devices.” In 1999 the category was renamed "Improve Audio and Data Recorders/ Require Video Recorders" and the Board voted to add Safety Recommendations A-98-54, A-99-16, A-99-17, A-99-18, A-99-28, A-99-29, A-99-59, and A-99-60 to the category. Safety Recommendations A-00-30, A-00-31, A-03-64, and A-09-10 were added at later dates.