EASA Launch Rule Making Team on In-flight Recording for Light Aircraft
The European Aviation Safety Agency (EASA) has launched a Rule Making Team (RMT.0271 & 0272 [MDM.073 (a) & (b)]) on in-flight recording for light aircraft. The Terms of Reference (ToR) and Group Composition (GC) are here. By way of definition the ToRs state:
…‘in-flight recording’ means recording by an airborne system of data that can be easily used to reconstruct the history of the flight for the purpose of a safety investigation. In-flight recording solutions include, but are not limited to, flight recorders.
EASA note that aircraft that aren’t required to carry data recorders include:
- Aeroplanes <5 700 kg used for commercial air transport (CAT) operations
- Helicopters <3 175 kg used for CAT
- Lighter Than Air aircraft used for CAT
- Light aircraft operated for General Aviation
One could argue that this initiative is particularly important now that EASA have issued a notice of proposed amendment on commercial air transport operations at night or in IMC using single-engined turbine aeroplane (NPA2014-18). The likely aircraft types are the Cessna C208 Caravan, Pilatus PC-12 and Socata TBM700/850. Eight safety recommendations have previously been addressed to EASA recommending the introduction of in-flight recording for lighter aircraft (listed below in chronological order of accident date):
- SPAN-2012-011 Swearingen SA226 registered EC-GDG, 18/02/1998 (accident report);
- UNKG-2005-101 Bell 206 registered G-BXLI, 22/01/2005 (accident report);
- FRAN-2009-008 Beech C90 registered F-GVPD, 18/10/2006 (accident report);
- HUNG-2008-002 Eurocopter EC135 registered HA-ECE, 31/07/2008 (no report online);
- NETH-2012-001 Pilatus PC12 registered PH-RUL, 16/10/2009 (accident report);
- FRAN-2013-012 Cessna 208 registered F-OIXZ, 05/09/2010 (accident report);
- NORW-2012-010 Aerospatiale AS350 registered LN-OXC, 04/07/2011 (accident report);
- FINL-2014-001 Cessna 206 registered OH-AAA, 08/11/2012 (accident report).
Aerossurance has previously reported on recommendations made in other countries (such as Canada). The US National Transportation Safety Board (NTSB) has had wider recorder use on its ‘most wanted list’ too.
EASA notes that industry standards for flight recorders for light aircraft are available (e.g. EUROCAE ED155 [Minimum Operational Performance Specification for lightweight flight recording systems] issued in July 2009). In 2006 the UK Civil Aviation Authority (CAA) published a research report on “The Effectiveness of Image Recorder Systems in Accident Investigations (CAP 762). In their conclusions they stated:
…the research indicates that image recording systems can, if properly installed and appropriately analysed together with conventional recording systems, provide additional information that would assist in accident investigation.
EASA also point out that:
Other equipment mandated or usually carried on board light aircraft has also some recording capability. Advantage could be taken of this equipment as an alternative solution to a dedicated in-flight recording solution.
The team is tasked with:
Assessment of the need for in-flight recording for each combination of aircraft category, aircraft mass or occupancy, and type of operation indicated [above]. This assessment should take into consideration the cost constraints peculiar to light and general aviation;
Identification, where in-flight recording is justified, of the recording function(s) needed (flight parameters, or audio, or both);
Establishment of a list of in-flight recording solutions that ranges from the cheapest and lightest solution to the conventional crash-protected flight recorder. This list may include alternative solutions, such as using or enhancing airborne equipment designed for other purposes;
Proposal of definitions and requirements, for the elected in-flight recording solutions;
Draft provisions on the use, preservation and serviceability of in-flight recording solutions.
Aerossurance observes that the use of this recorded flight data routinely for flight data monitoring purposes (known in the US as Flight Ops Quality Assurance) would be an even greater enhancement to safety and thus aid the economic justification for new equipment. EASA has previously funded research on FDM on small helicopters.
UPDATE: The NTSB has issued a report analysing data from a Appareo GAU2000 fitted to a Lockheed P2V7 aerial fire-fighting tanker N14447 that crashed in 20 miles north of Modena, Utah on 3 June 2012. The recorder suffered extensive heat and fire damage in the accident but the data card containing data was recovered and downloaded. It enable the NTSB to compared the penultimate and accident drops:
Comparing the two flights, certain aspects tend to stand out. The same drop zone was identified for both the first and second retardant drops. Tanker 11 approached the drop zone from the south, in a right-hand turn, and the direction of the final drop course was exactly the same for both flights. Tanker 11′s rate of turn on to the final course for both drops was performed at the same rate. The most significant difference between the first drop approach and the accident drop approach was that Tanker 11′s first approach into the drop zone was initiated from a higher altitude, about 1,000 feet above the ridge line surrounding the west side of the fire, and had a relatively steady rate of descent on to the final drop course. In comparison, the accident flight approached the final drop course from a lower altitude that approximated the elevation of the ridge lines surrounding the west side of the drop zone in level flight while it turned onto the final drop course. The track and altitude data that depict the first drop shows that Tanker 11 flew over the west ridge line and then rapidly descended to get to the proper drop altitude while on the final drop course. The track and altitude data that depict the accident flight shows that Tanker 11 was turning inside and below the shallow valley formed by the western ridge line, which would have reduced the amount of altitude needed to descend in order to establish the proper drop altitude as the airplane rolled out onto its final drop course.
UPDATE 5 November 2014: NTSB held a board meeting on a loss of control accident in 2013 to an Alaskan State Trooper AS350B engaged in a search and rescue mission. NTSB made a number of findings and recommendations and again emphasise the value of recorders such as, in this case, the Appareo Vision 1000 (discussed in detail in an earlier Aerossurance article).
UPDATE 23 October 2015: UK AAIB made recommendations on recorders in their report into the fatal accident involving EC135T2+ G-SPAO that crashed onto the Clutha Vaults Bar in Glasgow, Scotland on the night of Saturday 29 November 2013. See our article: AAIB Report on Glasgow Police Helicopter Accident
UPDATE 27 May 2016: Other recommendations came from Belgium after a structural failure of a Pilatus PC-6 OO-NAC‘s wing after a significant negative g manoeuvre, while being flown for parachuting on 19 October 2013.
UPDATE 29 October 2016: An NPA is expected in Q1 2017.
UPDATE 22 December 2016: Following the Clutha accident UK CAA issue safety directive SD-2016/006: State Helicopter Flight Recorder Requirements applicable to operators conducting State emergency services Public Transport (PT) helicopter operations in the UK and requiring either an FDR or cockpit image recorder.
UPDATE 3 April 2016: NPA 2017-03 ‘In-flight recording for light aircraft’ is issued. Comments required by 3 July 2017. EASA say there will now be definitions for:
… ‘crash-protected’ flight recorders and ‘lightweight’ flight recorders.
A lightweight flight recorder is designed to meet less demanding crash-protection requirements, and therefore it can be lighter.
This NPA proposes to mandate the carriage of lightweight flight recorders for some categories of light aeroplanes and light helicopters when they are commercially operated and manufactured 3 years after the date of application of the amending regulation.
In addition, this NPA proposes to promote the voluntary installation of in-flight recording equipment for all other light aeroplanes and light helicopters and for all balloons.
They also note that new Standards (recently introduced in ICAO Annex 6) require the carriage of lightweight flight recorders for light aeroplanes and light helicopters.
UPDATE 30 June 2017: UK CAA have published their comments on the NPA.
UPDATE 9 July 2018: In a safety investigation report released last week, the TSB said that the operator of a survey Piper PA-31 Navajo C-FQQB, was unaware that the accident pilots “had frequently flown at very low altitudes” while transiting between survey areas and their base. The Navajo was flying between 40 ft and 100 ft AGL when it struck power cables on 30 April 2017. TSB reiterated a call for flight recorders on smaller aircraft.
UPDATE 22 February 2019: EASA issue Opinion 02/2019
The NTSB asked the manufacturers – Airbus Helicopters, Bell, Leonardo, MD Helicopters, Robinson and Sikorsky – to act since the Federal Aviation Administration has not implemented a series of NTSB recommendations made in 2013 and 2015. Those recommendations were issued after NTSB investigators found the lack of recorded data hindered their understanding of several crashes that could have serious flight safety implications.
Helicopters meeting specific criteria established by the FAA are required to have crash-resistant systems to record flight data and cockpit audio. None are currently required to have image recording capability. Despite the lack of action from the FAA, some helicopter operators have equipped their aircraft with recording systems, including image recording capability, even though they are not required to do so.
Example accidents cited by NTSB:
Aerossurance is pleased to sponsor the 2017 European Society of Air Safety Investigators (ESASI) 8th Regional Seminar in Ljubljana, Slovenia on 19 and 20 April 2017. Registration is just €100 per delegate. To register for the seminar please follow this link. ESASI is the European chapter of the International Society of Air Safety Investigators (ISASI).
Aerossurance is also pleased to sponsor an RAeS HFG:E conference at Cranfield University on 9 May 2017, on the topic of Staying Alert: Managing Fatigue in Maintenance. This event will feature presentations and interactive workshop sessions.