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  3. NTSB A-15-002
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NTSB · Safety Recommendation

Safety Recommendation A-15-002

Recommendation

TO THE FEDERAL AVIATION ADMINISTRATION: Require that all aircraft used in extended overwater operations and operating under Title 14 Code of Federal Regulations (1) Part 121 or (2) Part 135 that are required to have a cockpit voice recorder and a flight data recorder, be equipped with an airframe low frequency underwater locating device that will function for at least 90 days and that can be detected by equipment available on military, search and rescue, and salvage assets commonly used to search for and recover wreckage.

Safety Issue and Context

The NTSB has long been concerned about rapid recovery of recorded information to guide investigations, help determine accident causes, and develop recommendations to prevent recurrences. To focus attention on this issue, the NTSB convened its Emerging Flight Data and Locator Technology Forum on October 7, 2014, in Washington, D.C. Forum discussions among government, industry, and investigative experts helped identify the following safety issues: • Need for improved technologies to locate aircraft wreckage and flight recorders following an accident in a remote location or over water

• Need for timely recovery of critical flight data following an accident in a remote location or over water This letter presents recommendations to address these safety issues and discusses open recommendations regarding cockpit image recorders and the need to protect flight recorder systems against intentional or inadvertent deactivation.

Response History

November 20, 2024 · NTSB Correspondence · FAA

On November 20, 2024, FAA staff informed us that the agency is continuing the work described in its May 23, 2023, letters regarding Safety Recommendations A-13-12 and -13 and A-18-30, and its May 30, 2023, letter regarding Safety Recommendations A-15-1 through -4, -7, and -8.  We look forward to receiving your next update.

November 8, 2023 · NTSB Correspondence · FAA

We note that you are continuing your research with ICAO to determine if the SBA ADS-B’s quality and effectiveness would meet the intent of a LF-ULD. Although we believe the research you are conducting is responsive, we remind you that, to satisfy this recommendation, a 90-day operating requirement is needed in any standard that you implement.

We look forward to reviewing the findings from your research. In the meantime, pending a mandate that the specified aircraft be equipped with LF-ULDs that will function for at least 90 days, Safety Recommendation A-15-2 remains classified OPEN-- ACCEPTABLE RESPONSE.

May 30, 2023 · Recipient Response · FAA

-From Billy Nolen, Acting Administrator: As mentioned in our previous letters, the Federal Aviation Administration (FAA) continues to work with the International Civil Aviation Organization (ICAO) and our international partners to:

Better define the Global Aviation Distress and Safety System (GADSS) and Location of an Aircraft in Distress Repository;

Research Space-Based Automatic (SBA) Dependent Surveillance – Broadcast (ADS-B);

Research SBA ADS-B for Low Frequency-Underwater Location Device;

Define Timely Recovery of Flight Data (TRFD);

Update Minimum Operational Performance Standards (MOPS) in European Organisation for Civil Aviation Equipment Document ED-112B, MOPS for Crash Protected Airborne Recorder Systems;

Read Recommendation

Recommendation Facts

Status
Open - Acceptable Response
Issued
January 22, 2015
Priority
CLASS II
Recipient
FAA
Adopted
January 20, 2015
Related Investigation
DCA14SS009
Related Report
None

Develop an advisory circular (AC) on TRFD once ED-112B is updated;

Modify RTCA DO-260C, MOPS for 1090 MHz Extended Squitter ADS-B and Traffic Information Services-Broadcast, to better accommodate Autonomous Distress Tracking (ADT);

Participate in writing an ICAO document to provide guidance for operators wishing to install ADT as well as TRFD;

Develop an ICAO GADSS AC; and

Improve industry knowledge and understanding of ADT and TRFD.

The results of this work will inform the FAA on how this technology can be leveraged to improve safety by working to better harmonize our regulations with ICAO standards and recommended practices.

The FAA also initiated a rulemaking (2120-AL92) that would propose newly-manufactured aircraft to be equipped with cockpit voice recorders (CVRs) capable of recording for 25 hours, along with operational rules that would require the use of those CVRs when installed. Furthermore, the FAA is launching an Aviation Rulemaking Committee (ARC) that will provide a forum for the U.S. aviation community to discuss, prioritize, and provide recommendations to the FAA concerning requirements for the installation of existing, new, and upgraded investigative technologies that affect applicable airworthiness standards and operating rules.

The ARC will also specifically consider the Board’s safety recommendations as part of its discussions.

I will keep the Board informed of the FAA’s progress on Safety Recommendations A-15-1 through 4, -7, and -8, and provide an update by May 31, 2024.

July 20, 2022 · NTSB Correspondence · FAA

We note that you are conducting research to determine if the SBA’s quality and effectiveness would meet the intent of a LF-ULD. In addition, we note that you intend to pursue rulemaking to update the rules related to the LF-ULD.

Although we believe the research you are conducting is responsive, we remind you that, to satisfy this recommendation, a 90-day operating requirement is needed in any standard that you implement. Pending a mandate that the specified aircraft be equipped with LF-ULDs that will function for at least 90 days, Safety Recommendation A-15-2 remains classified OPEN-- ACCEPTABLE RESPONSE.

November 18, 2021 · Recipient Response · FAA

-From Steve Dickson, Administrator: The FAA has begun research to determine the quality and effectiveness of SBA to meet the intent of a Low Frequency-Underwater Location Device (LF-ULD). The results of this research will inform the FAA if and how this technology can be leveraged to improve safety through the use of existing systems to better pinpoint the location of a crash. An application for rulemaking to update the rules related to the LF-ULD was submitted for FY 2020 but was not chosen due to competing priorities. The application has been resubmitted for consideration in FY 2021.

The FAA will inform the NTSB if the rulemaking is approved to consider mandating LF-ULD in the United States.

October 26, 2020 · NTSB Correspondence · FAA

We previously told you that issuing Technical Standard Order (TSO) C200, “Airframe Low Frequency Underwater Locating Device (Acoustic) (Self Powered),” partially satisfies Safety Recommendation A-15-2. We are aware that TSO C200a uses SAE International Aerospace Standard AS6254 revision A, which requires a 90-day battery; however, because of your desire to harmonize with ICAO, we remain concerned that your planned mandate for airframe-mounted LF-ULDs may only include the 30-day requirement in the ICAO standard. As we’ve pointed out in previous correspondence, to satisfy this recommendation, a 90-day operating requirement is needed in any standard that you implement.

We note that you are determining the feasibility of requiring LF-ULDs on all newly built Part 121 and Part 135 aircraft. Pending a mandate that the specified aircraft be equipped with LF-ULDs that will function for at least 90 days, Safety Recommendation A-15-2 remains classified OPEN--ACCEPTABLE RESPONSE.

June 12, 2020 · Recipient Response · FAA

-From Steve Dickson, Administrator: This is in further response to Safety Recommendations A-15-1 through 4, -7, and -8 issued by the Board on January 22, 2015, and supplements our previous letters. The Board issued these safety recommendations following the Emerging Flight Data and Locator Technology Forum on October 7, 2014. Forum discussions among government, industry, and investigative experts identified the following safety issues: • The need for improved technologies to locate aircraft wreckage and flight recorders following an accident in a remote location or over water; and

• The need for timely recovery of critical flight data following an accident in a remote location or over water.

These recommendations address safety issues and discuss open recommendations regarding cockpit image recorders and the need to protect flight recorder systems against intentional or inadvertent deactivation.

Overall Comment. The FAA is currently evaluating a rulemaking project for Fiscal Year (FY) 2020 that would address these safety recommendations. As part of this effort, the team will review various standards and methodologies. The FAA will provide further information on this rulemaking project if it is approved.

On June 26, 2012, the FAA published Technical Standard Order (TSO)-C200, Airframe Low Frequency Underwater Locating Device Acoustic Self Powered. A revised version, TSO-C200a, was published on May 3, 2016. This TSO provides the basis for manufacturers to design and produce airframe mounted low frequency locating devices. The 2016 revision directs users to meet Society of Automotive Engineers Aerospace Standard AS6254 revision A, which requires a 90-day battery.

As described in our response to safety recommendation A-15-1, the FY 2020 rulemaking project team will review various standards and methodologies to include determining the feasibility of mandating unit load devices (8.8kHz), on all newly-built part 121 or part 135 aircraft.

December 13, 2018 · NTSB Correspondence · FAA

In previous letters to you about this recommendation, we noted that the ICAO standard regarding LF-ULDs specified only a 30-day operating requirement, and we pointed out that a 90 day operating requirement was needed in any standard that you implement to satisfy this recommendation. We note that, in May 2016, you published a revision to Technical Standard Order (TSO) C200, “Airframe Low Frequency Underwater Locating Device (Acoustic) (Self Powered),” providing the basis for manufacturers to design and produce airframe-mounted LF ULDs. The revised TSO uses Society of Automotive Engineers Aerospace Standard AS6254 revision A, which requires a 90-day battery.

Issuance of TSO C200a partially satisfies Safety Recommendation A-15-2, but we note that, after ICAO finalizes its work pertaining to the GADSS, you plan to address requirements for airframe-mounted LF-ULDs as part of a larger rulemaking effort to align US and European rules and ICAO annex requirements.

We remain concerned that, because of your desire to harmonize with ICAO, your planned mandate for airframe-mounted LF-ULDs may only include the 30-day requirement in the ICAO standard. Pending a mandate that the specified aircraft be equipped with LF-ULDs that will function for at least 90 days, Safety Recommendation A-15-2 remains classified OPEN--ACCEPTABLE RESPONSE.

September 21, 2018 · Recipient Response · FAA

-From Daniel K. Elwell, Acting Administrator: In May 2016, the FAA published revised Technical Standard Order (TSO)-C200a, Airframe Low Frequency Underwater Locating Device (Acoustic) (Self Powered). The revised TSO provides the basis for manufacturers to design and produce airframe-mounted low frequency locating devices by directing users to meet Society of Automotive Engineers Aerospace Standard AS6254 revision A, which requires a 90-day battery.

This exceeds the 30-day requirement instituted by ICAO. After ICAO finalizes its work pertaining to the GADSS, the FAA plans to address requirements for Airframe Mounted Underwater Locating Devices as part of a larger rulemaking effort to align U.S. rules with European rules and ICAO annex requirements.

January 6, 2017 · NTSB Correspondence · FAA

In our previous letter to you about this recommendation, we noted that ICAO planned a standard requiring LF-ULDs, but the standard specified only a 30-day operating requirement. We said that a 90-day operating requirement is needed in any standard that you implement to satisfy this recommendation.

We note that Technical Standard Order (TSO)-C200, “Airframe Low Frequency Underwater Locating Devices (Acoustic)(Self Powered),” references SAE Aerospace Standard (AS) 6254, “Minimum Performance Standard for Low Frequency Underwater Locating Devices (Acoustic)(Self Powered),” and that you plan to soon finish a revision of TSO-C200 that will reference an update to SAE AS 6254, which requires a minimum 90-day operating requirement.

Additionally, we note that you are considering rulemaking requiring LF-ULDs to be installed on newly manufactured aircraft used in oceanic operations, and that you are committed to harmonizing requirements with ICAO. We are encouraged that the revision of TSO-C200 will include a 90 day operating requirement and that you plan to mandate LF-ULD installation, but we are concerned that, because of your desire to harmonize with ICAO, your planned mandate may only include the 30-day requirement in the ICAO standard. We ask that you clarify your planned action regarding the operating requirement in any LF-ULD mandate.

Pending an acceptable clarification as to how you will harmonize the length requirement with ICAO standards, issuance of the revised TSO with a 90-day life for the LF-ULD, and a mandate for LF ULD installation, Safety Recommendation A-15-2 remains classified OPEN—ACCEPTABLE RESPONSE.

September 13, 2016 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: On June 26, 2012, the FAA published Technical Standard Order (TSO)-C200 Airframe Low Frequency Underwater Locating Devices (Acoustic)(Self-Powered). This TSO references SAE Aerospace Standard (AS) 6254, Minimum Performance Standard for Low Frequency Underwater Locating Devices (Acoustic)(Self-Powered). The next revision of this TSO will reference SAE AS 6254A which requires a minimum 90-day operating requirement. TSO-C200A is expected to be published in calendar year 2016.

The FAA is considering rulemaking to require installation of low frequency underwater locating devices (LF ULDs) on newly manufactured aircraft used in oceanic operations. The FAA notes the ICAO mandate requires LF ULD installation on all airplanes, operating long-range nights over water with a maximum certificated take-off mass of over 27,000 kg. by no later than January I, 20 18. The FAA is committed to harmonizing with ICAO and other regulatory authorities to the maximum extent possible.

I will keep the Board informed of the FAA· s progress on this recommendation and provide an update by May 31, 2017.

November 19, 2015 · NTSB Correspondence · FAA

We note that ICAO’s standard states that, no later than January 1, 2018, airplanes weighing over 27,000 kg flying over water must install a 30-day LF-ULD; our recommendation is for the device to last 90 days. We believe that you should issue a regulation specifying a 90 day LF-ULD rather than the 30-day LF-ULD required by the ICAO standard. Pending issuance of a regulation adopting the ICAO standard modified to require a 90-day LF-ULD instead of one lasting 30 days, Safety Recommendation A 15-2 is classified OPEN—ACCEPTABLE RESPONSE.

April 22, 2015 · Recipient Response · FAA

-From Michael P. Huerta, Administrator: These recommendations have created a lot of discussions and activities within the avionics community and multiple policy offices within the Federal Aviation Administration (FAA). The International Civil Aviation Organization has tasked the Flight Recorder Working Group with the issue of tracking aircraft in remote locations and over water. The FAA is a member of this working group. Once the working group has reviewed the concerns raised at the Emerging Flight Data and Locator Technology Forum, it will determine the best feasible course of action. We will provide an updated response by June 2016.