TO AIRBUS HELICOPTERS, BELL, LEONARDO HELICOPTER DIVISION, MD HELICOPTERS, ROBINSON HELICOPTER COMPANY, AND SIKORSKY: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight.
Safety Issue and Context
These recommendations address the need for crash-resistant flight recorder systems and crash-protected image recorder systems on existing and newly manufactured turbine-powered helicopters. These recommendations are derived from several NTSB investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Response History
November 10, 2021 · NTSB Correspondence · Bell Helicopter Textron, Inc.
You reported that these recommendations, as written, require cooperation from the Federal Aviation Administration (FAA) and other global regulators to revise privacy laws and ensure that voluntarily installed equipment is not removed by operators, and, for in-service helicopters, to update the essential equipment. You also reported that few companies currently manufacturer ED 155-compliant devices, and that these devices may be too expensive and heavy to ensure widespread voluntary adoption.
We point out that, in 2013, we issued similar recommendations to the FAA ; however, because the FAA has not taken the recommended actions, we believe helicopter manufacturers should voluntarily install this equipment on their helicopters.
We do not believe the concerns you raised should prevent you from voluntarily adopting these recommendations. We are aware of two helicopter manufacturers (Airbus and Robinson) that are currently delivering certain models of newly manufactured helicopters with voluntarily equipped cockpit image recorders. We recognize that there are limited commercial off the shelf (COTS) crash-resistant recorder systems currently available.
In addition, some COTS recorder systems, such as the Appareo Vision 1000, are neither crash-resistant nor crash protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire. We point out that between 2013 and 2021, only 59 percent of the Appareo Vision 1000 devices we reviewed had recoverable accident data, which supports the need for robust crash-resistant features to ensure flight data survivability.
We believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant, but that has crash-resistant features or other attributes that ensure flight data survivability, that still meet the intent of these recommendations. We encourage you to partner with industry to develop a customized solution if a COTS solution is not viable for your helicopters. Pending our review of a plan to evaluate technology or work with other manufacturers to develop a solution, and completion of the recommended actions, Safety Recommendations A-20-27 through -30 remain classified OPEN-- UNACCEPTABLE RESPONSE.
November 10, 2021 · NTSB Correspondence · Sikorsky Aircraft
We note that you support the intent of these recommendations and are currently evaluating image recorder and carry-on-board technologies for all of the helicopters in Sikorsky’s commercial product line; however, you are concerned that these recommendations do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that more affordable commercial solutions are available that record flight data and cockpit sound and images and have some crashworthy features.
We continue to believe that survivability of flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We point out that between 2013 and 2021, only 59 percent of the Appareo Vision 1000 devices we reviewed had recoverable accident data, which supports the need for robust crash-resistant features to ensure flight data survivability. We also point out that a crash resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.
These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, other acceptable alternative solutions, including those that are not TSO-compliant, may be developed that could sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire.
Furthermore, for those helicopters that are manufactured with a crash-protected CVR and FDR, equipment approved under TSO-C176a could accommodate flight data, cockpit voice, and cockpit image recording functions in a single combination recorder. Data from crash-protected image recorders would complement CVR and FDR recordings by providing critical information related to the conditions within the cockpit, such as crew actions, visibility, instrument indications available to crewmembers, and any degradation of aircraft systems.
October 26, 2021 · NTSB Correspondence · Airbus
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
October 26, 2021 · NTSB Correspondence · Airbus
We are encouraged to learn that you are continuing your work to expand the capabilities of your flight recorder system to include additional data sources and to improve data integrity. We continue to believe your actions to install these systems on all your newly manufactured helicopters, develop service bulletins on retrofit installation of these systems for operators of your in-service fleet, and encourage operators to voluntarily install these systems are responsive to these recommendations.
Pending our review of updates on your progress to improve the crash survivability of your onboard recording systems and completion of the recommended actions, Safety Recommendations A-20-27 through -30 remain classified OPEN-- ACCEPTABLE RESPONSE.
Please update us at ExecutiveSecretariat@ntsb.gov on your progress toward implementing these recommendations, and do not submit both an electronic and a hard copy of the same response.
October 26, 2021 · NTSB Correspondence · Bell Helicopter Textron, Inc.
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
October 26, 2021 · NTSB Correspondence · Leonardo Helicopters
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
October 26, 2021 · NTSB Correspondence · MD Helicopters
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
October 26, 2021 · NTSB Correspondence · MD Helicopters
We note that you are working with industry leaders who develop and produce these systems, to find an innovative solution for your existing helicopters. You also reported the challenges that this recommendation poses for some of your older helicopters, which do not have modern avionics systems, and existing helicopters that have been customized by operators after delivery.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments provide investigators with additional flight data parameters without installing additional sensors or wiring necessary for an FDR.
We continue to believe that a TSO C197 compliant flight recorder system that is connected to an imaging device would provide a means to collect a multitude of data, including a view of the instrument panel, and would not require the extensive modifications that a traditional CVR and FDR require. We understand that existing helicopters may have been customized by operators after delivery, but we feel that it should not prevent you from developing a retrofittable crash-resistant flight recorder option for a baseline helicopter configuration or a configuration that is compatible with the majority of the fielded fleet.
Pending our review of periodic updates on your progress, and completion of the recommended action, Safety Recommendation A-20-29 remains classified OPEN-- ACCEPTABLE RESPONSE.
October 26, 2021 · NTSB Correspondence · Robinson Helicopter Company
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
October 26, 2021 · NTSB Correspondence · Robinson Helicopter Company
We note that you have developed a cockpit video camera recording system that simultaneously records video, audio, and GPS position on two microSD memory cards—one mounted in an external USB adapter and one internally mounted. We also note that, although the memory cards are not fire resistant, they are rated for 500 G impact and 72-hour submersion in 1 meter of salt or fresh water. In addition, you reported that the camera is in the ceiling of the cabin to provide better protection from impact forces during an accident.
We are encouraged to learn that your cockpit video camera recording system includes some crash-resistant features and is currently available as standard equipment on all 2021 model year turbine helicopters, as optional equipment on piston models, and as a retrofit kit for helicopters manufactured within the last year. However, because your system is not TSO C197 compliant, we remain concerned that the data are at risk of being lost if an aircraft is in involved in a severe ground impact or postcrash fire. Therefore, we urge you to consider improvements that would mitigate the risk of data loss in the event of a crash, including postcrash fire.
We believe improvements such as storing duplicate data in a secondary location, like the tail, or designing an interface for connecting an ED-155-compliant or equivalent box with robust postcrash fire protection could be an acceptable alternate solution to these recommendations. Pending our review of future updates as you progress toward this goal, Safety Recommendations A-20-27 and -29 remain classified OPEN-- ACCEPTABLE RESPONSE.
October 26, 2021 · Recipient Response · Robinson Helicopter Company
-From Kurt Robinson, President, Robinson Helicopter Company: Thank you for taking the time to review our cockpit video camera design in relation to Safety Recommendations A-20-27 and A-20-29 and for the “Open – Acceptable Response” classification.
To date, the system has performed well in the field with positive feedback from our operators. There are not too many units in service yet, but we are encouraged by the early results. We are continuing to consider measures to further improve robustness including some similar to what you have suggested.
We will keep you updated on any design improvements we make.
October 26, 2021 · NTSB Correspondence · Sikorsky Aircraft
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE SAFETY RECOMMENDATION RECEIPIENT: Thank you for your April 27, 2021, letter regarding Safety Recommendations A-20-27 through -30. We issued some or all these recommendations to six helicopter manufacturers on June 2, 2020, as a result of several investigations of turbine-powered helicopter accidents in which the lack of a crash-resistant or crash-protected flight recording system that records parametric data, cockpit audio, and images hindered our understanding of the accident circumstances and, thus, allowed potential safety issues to go unaddressed.
Although we did not issue these recommendations to the General Aviation Manufacturers Association (GAMA), we appreciate your response and interest in this important safety issue.
These recommendations specify installing a recorder system that is TSO-compliant because the TSO includes minimum operational performance standards that are most likely to ensure the survivability of flight data following an accident involving severe ground impact or postcrash fire. Although a TSO-compliant recorder system is the traditional and proven way to mitigate the risk of data loss during a crash, alternative solutions that are not TSO-compliant but sufficiently mitigate the risk of data loss in the event of a crash, including postcrash fire, may be available or developed and could satisfy the intent of these recommendations.
We would appreciate your support in encouraging the recipients of these recommendations to work together to develop solutions that will ensure the survivability of flight data so that investigators can use this information to identify critical safety issues and better understand flight crew actions within the cockpit.
Again, we appreciate your interest in this safety issue.
June 7, 2021 · Recipient Response · MD Helicopters
-From Chris Jaran, Chief Operating Officer, MD Helicopters: Although MDHI has taken considerable steps to research installation plans for systems such as crash resistant cockpit voice recorders, crash-resistant cockpit video cameras, and crash-resistant flight data recorders for all current models of MD Helicopters, we have not commenced an active development program. MDHI understands the need for such systems and is working with industry leaders who develop and produce these systems, to find an innovative solution that will accommodate present MD Helicopter owners.
Safety Recommendation A-20-29 poses particular challenges with respect to in-service helicopters, which are outside of manufacturer configuration control. MDHI has no control over owners/operators customizations made post-delivery, making it significantly more technically difficult, and costly, for MDHI to develop and implement FDR/CVR retrofit solutions. It will require multiple configurations that will need to be specifically tailored to fit each operator's aircraft.
Recognition should also be given to the complexities of upgrading certain sectors of the existing rotorcraft fleet that do not have modem avionics to supply the necessary flight data parameters, structural provisions and electrical loads capacity to support compliance with existing regulations. This leads the OEM down the path of unique customizations for every single aircraft in operation. To retrofit the existing fleet would be complex and cost-prohibitive given the invasive nature of the required installation of sensors and wiring.
Accordingly, alternate approaches should be consid~red to enable a more flexible set of retrofit solutions to be implemented by each individual aircraft owner/operator to upgrade inservice rotorcraft fleet to be compliant with the intent of the NTSB recommendation.
As stated in our previous response, older models of MD helicopters certified under CAR 6, present a uniquely complex challenge in regards to integrating compatible FDR/CVR systems on a case-by-case basis dependent on operator customizations. MDHI has not undertaken any effort at this time to field retrofit aircraft with compliant FDR/CVR systems.
As crash-resistant recording system suppliers progress and innovate their technologies, MDHI will be proactive in evaluating these new airworthy systems for installation consideration on MD Helicopters aircraft. MDHI remains committed to innovation on all our helicopter platforms and continues to meet or exceed all flight safety requirements in compliance with
June 2, 2021 · Recipient Response · Airbus
-From Gilles Bruniaux, VP Product and Aviation Safety Expert, Airbus Helicopters: Airbus Helicopters acknowledges receipt of your letter provided on the 25th of February and again welcomes the NTSB initiative striving to enhance safety with the follow-up safety recommendation.
Airbus Helicopters remains supportive and we maintain our commitment to safety by constantly working on future safety enhancements in many directions.
By writing this, we want to refer to our first reply dated 3rd of September 2020, where we explained the development history, design features, and achievements with recorders being implemented on Airbus Helicopters products to date. The policy and phased approach described in this letter is unchanged. In fact, we are currently about to realize the so-called “Step 2”, in which will provide additional data sources and improve the data integrity of the recording systems. However, we are working to develop the best synergy in finding compliance with the NTSB safety recommendations, while also considering the mandatory requirements prescribed by certification and operational regulations.
Neverhteless, we remain committed in exploring solutions which will fulfill the NTSB recommendations, and yet which must also complement new operational regulations that have a higher priority.
Safety Recommendation A-20-29 (and A-20-30) / AAR-21-01:
Airbus Helicopters cooperated in establishing the reply on this safety recommendation issued by GAMA on the 27th of April 2021. Airbus Helicopters fully supports the statements of GAMA’s letter.
With experience gathered following the implementation of our “Step 1” policy, Airbus Helicopters had issued service bulletins (SB’s) that provided solutions for retrofit installations of the “Vision 1000” system and CVFDRs.
However, despite numerous marketing efforts from Airbus Helicopters, market demand for those retrofits remains close to zero. Airbus Helicopters therefore concludes that implementation of recorders should be mandated by regulation, or market demand is created by other incentives. If not, the decisions by operators will remain unchanged, in spite of our initiatives offered by the Airbus Helicopters recorder product policy. We would be pleased to discuss the elements, difficulties, and ambitions in an exchange with you and other aviation authorities any time (e.g. with virtual conferencing).
April 27, 2021 · Recipient Response · Airbus
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 27, 2021 · Recipient Response · Bell Helicopter Textron, Inc.
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 27, 2021 · Recipient Response · Leonardo Helicopters
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 27, 2021 · Recipient Response · MD Helicopters
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 27, 2021 · Recipient Response · Robinson Helicopter Company
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 27, 2021 · Recipient Response · Sikorsky Aircraft
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION -From Peter J. Bunce, President and CEO: The General Aviation Manufacturers Association (GAMA) appreciates the National Transportation Safety Board’s (NTSB’s) response, dated March 17, 2021, to our October 11, 2020 letter regarding NTSB Safety Recommendation Report ASR-20-04. Although the NTSB did not issue any recommendations in that report specific to GAMA, the safety recommendations concerned issues of significance to the general aviation manufacturer and maintainer community.
GAMA greatly appreciates the opportunity to continue to work with the NTSB on advancing recommendations to improve general aviation safety, including the broader adoption of flight data analysis and Safety Management Systems (SMS).
GAMA strongly supports the installation and use of flight data recorder systems to enable flight data monitoring programs as well as accident and incident investigation. We also strongly support the NTSB’s recommendations to increase attention to and the use of SMS. To ensure the broadest safety impact, GAMA encourages the NTSB to promote recommendations in these areas that are both holistic and performance-based. This will advance the development, installation, and use of existing and future technology solutions in safety data monitoring programs—offering far-reaching proactive and reactive safety opportunities to the aviation community.
Survivability.
As the NTSB recognizes, existing and emerging technologies with “crash-resistant features” and systems that are either “TSO-compliant or incorporate crash and fire protection”“meet the intent” of NTSB’s recommendations.” NTSB’s specific recommendations and safety items, including the 2021-2022 Most Wanted List, however, call for crash-resistance and TSO-compliant systems. It is important to distinguish the survivability of a recorder from whether it is a certified crash resistant or crash protected article. Recorders can be hardened to survive accidents and incidents and yet not meet crash resistant or crash protected certification standards.
As GAMA highlighted in its industry response, the extensive certification program for crash resistant and crash protected recorders substantially increases cost, and the impact and flammability requirements in
April 21, 2021 · Recipient Response · Bell Helicopter Textron, Inc.
-From Mitch Snyder, President and CEO: Thank you for your letter of January 25th• Bell shares the NTSB's belief in the importance of safety enhancing equipment for both new and fielded aircraft. We remain committed to the implementation of safety equipment designed to prevent the most prolific causes of accidents as identified in Bell's own data and by data driven initiatives such as those provided by the United States Helicopter Safety Team. It is these same statistics that led to our implementation of flight data recording devices as standard equipment in all our current in production models over the last decade.
More recently, Bell has completed certification of the 407 for instrument flight rules (IFR) operations providing pilots a lower cost alternative for conducting IFR flight, introduced a 3 axis autopilot and synthetic vision for the 505 providing high end safety features to our entry level model, and developed a one touch auto couple for our model 429 greatly simplifying engagement in emergency situations. On the horizon, Bell is nearing certification of the 525, the first commercial fly by wire rotorcraft. This system will provide unprecedented levels of control augmentation to enhance safety.
Within our safety initiatives, Bell will continue to explore additional opportunities to include the NTSB recommendations provided in A-20, 27 through 30. However, challenges exist for the adoption of the recommendations as written. Achieving them will require substantial assistance from NTSB, along with the cooperation of FAA, Transport Canada, EASA, and other global regulators:
• Privacy laws in Europe and elsewhere may complicate the ability for non-commercial operators to adopt these devices. If pilot consent is required by law to record cockpit video or audio, the operator could not lawfully fly the aircraft if consent was withheld by the pilot, assuming the recording equipment was classified as essential. Resolving this issue may require a regulatory or legislative solution.
• For rotorcraft currently in service, manufacturers lack a legal mechanism to redefine "essential equipment" from what was required at the time the aircraft was delivered, creating a hurdle to making the equipment essential on existing rotorcraft, as stated in Safety Recommendations A-20, 29 and -30. Resolving this issue will require a regulatory solution.
• Like other rotorcraft OEM's, Bell is not a developer of avionics or cockpit recording devices and would need to source this equipment from industry specialists. A few companies are beginning to offer ED-155 compliant recording and imaging devices for rotorcraft, but they are relatively new to the market. An inexpensive, light weight, affordable solution will be essential to widespread voluntary adoption of these systems, and fully ED-155 crashworthy solutions may not meet these expectations.
April 20, 2021 · Recipient Response · Sikorsky Aircraft
-From Paul Lemmo, President: In response to Island Express Helicopters Inc.’s Sikorksy S-76B accident in Calabasas, California, the NTSB reiterated a previously issued recommendation (A-20-29) to Sikorsky and five other manufacturers.
Sikorsky has been, and continues to be, an industry leader in helicopter aviation safety. While our fundamental focus is accident prevention and the integration of equipment that promotes situational awareness and accident avoidance, we have installed certificated CVR/FDR on every delivered S-92A. Further, every S-76 aircraft delivered since 2007 was equipped with certificated CVR/FDR/EGPWS as well. This demonstrates our commitment to safety.
As stated previously in response to ASR-20-04, dated 19 May 2020, Sikorsky supports the intent of A-20-29 with two recommendations.
First, we recommend adding alternate methods of compliance (AMOC) to enable more widespread fleet incorporation, thus increasing overall safety. Recent history shows that even a technically ‘non-survivable’ image recorder has remarkable survivability in helicopter crashes, even those with post-crash fires. The Alaska State Trooper (N911AA) AS350-B3 accident is probably the most well-known event involving the ‘nonsurvivable’ Appareo Vision 1000 that produced usable investigative data.
The energy involved in a typical crash and the quantity of fuel carried are significantly less in helicopters than in the large transport airliners that are considered in crashworthiness specifications such as ED-112.
Second, the OEMs are a significant technical resource during an investigation. While we are afforded the opportunity to conduct detailed analyses on FDR data, there are significant limitations with respect to CVR data, even with cockpit area microphone (CAM) only data, as frequently used in sound spectrum analysis. It would be a significant detriment to the overall investigative rigor if cockpit image recordings were to be restricted as severely as CVR data. The purpose of the “video” is to capture onboard instrumentation and flight control positions as much as voice.
Establishing clearly prescribed protocols to ensure that cockpit indications and aircraft-related data (including sound spectrum) can be made available to the airframe and engine OEM party representatives, while preserving the protections afforded to traditional CVR voice data, would certainly optimize resources and enhance the overall investigation.
April 9, 2021 · Recipient Response · Sikorsky Aircraft
-From Paul Lemmo, President: In response to the Air Methods Airbus BK 117B-2 accident in July 2017 (CEN17FA252), Sikorsky and five other manufacturers received three recommendations related to flight data, cockpit voice and image recorders. We offer the following response in support of these recommendations.
Sikorsky has been, and continues to be, an industry leader in helicopter aviation safety. While our fundamental focus is accident prevention and the integration of equipment that promotes situational awareness and accident avoidance such as EGPWS, we have installed certificated CVR/FDR on every delivered S-92A. Further, every S-76 aircraft delivered since 2007 was equipped with certificated CVR/FDR/EGPWS as well. This demonstrates our commitment to safety.
Sikorsky supports the intent of NTSB recommendation A20-28, A20-29, and A20-30 with two recommendations.
First, we recommend adding alternate methods of compliance (AMOC) to enable more widespread fleet incorporation, thus increasing overall safety. Recent history shows that even a technically ‘non-survivable’ image recorder has remarkable survivability in helicopter crashes, even those with post-crash fires. The Alaska State Trooper (N911AA) AS350-B3 accident is probably the most well-known event involving the ‘non-survivable’ Appareo Vision 1000 that produced usable investigative data.
The energy involved in a typical crash and the quantity of fuel carried are significantly less in helicopters than in the large transport airliners that are considered in crashworthiness specifications such as ED-112.
Second, the OEMs are a significant technical resource during an investigation. While we are afforded the opportunity to conduct detailed analyses on FDR data, there are significant limitations with respect to CVR data, even with cockpit area microphone (CAM) only data, as frequently used in sound spectrum analysis. It would be a significant detriment to the overall investigative rigor if cockpit image recording were to be restricted as severely as CVR data. The purpose of the “video” is to capture onboard instrumentation and flight control positions as much as voice.
Clear protocols should be established to ensure that cockpit indications and aircraft-related data (including sound spectrum) be available to the airframe and engine OEM party representatives, while preserving the protections afforded to traditional CVR voice data.
March 17, 2021 · NTSB Correspondence · Airbus
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 17, 2021 · NTSB Correspondence · Bell Helicopter Textron, Inc.
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 17, 2021 · NTSB Correspondence · Leonardo Helicopters
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 17, 2021 · NTSB Correspondence · MD Helicopters
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 17, 2021 · NTSB Correspondence · Robinson Helicopter Company
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 17, 2021 · NTSB Correspondence · Sikorsky Aircraft
LETTER TO THE GENERAL AVIATION MANUFACTURERS ASSOCIATION, NOT THE RECOMMENDATION RECIPIENT: We note that you strongly support the installation and use of flight data recorder (FDR) systems; however, you are concerned that these recommendations are too prescriptive and do not consider existing solutions or future technologies that could offer greater safety opportunities. You reported that, because the majority of 14 CFR Part 27 helicopters do not have modern avionics systems from which to capture flight data, retrofitting a current recorder system would be complex and cost prohibitive.
We point out that a crash-resistant flight recorder that records both cockpit audio and images of the cockpit environment is a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR. These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters. We also point out that these recommendations are limited to turbine-powered helicopters, which are typically larger helicopters with fewer weight restrictions.
We continue to believe that survivability of the flight data, whether derived from a cockpit image recorder, traditional CVR and FDR, or onboard avionics, is critical to ensuring that potential safety issues are identified during an accident investigation. Although the Appareo Vision 1000 cockpit camera system has been helpful in some of our investigations, we are concerned because this system is neither crash-resistant nor crash-protected and, as a result, data are at risk of being lost if the system is involved in a severe ground impact or postcrash fire.
We recognize that there are limited crash-resistant recorder systems currently available; however, we believe emerging technologies could allow manufacturers to develop a recorder system that is not TSO-compliant but that has crash-resistant features that still meet the intent of these recommendations. We have also identified at least 4 systems currently available that are either TSO-compliant or incorporate crash fire protection that would meet the intent of these recommendations. These systems range from 2 to 8 pounds in weight.
We agree that an FDM program, which is integrated into a safety management system, could identify and mitigate risks within an operation and prevent accidents, and we have long advocated for these programs. We point out that crash-resistant flight recorders and devices intended to support an FDM program do not need to be mutually exclusive, as a single device could support an FDM program and also ensure data survival in the event of an accident.
March 6, 2021 · Recipient Response · Robinson Helicopter Company
-From Kurt Robinson, President: Thank you for your review of our responses to Safety Recommendations A-20-27 and A-20-29. We agree that recorded data can be very valuable in accident investigations. Data survivability is important, but equally important is widespread adoption of the technology through retrofit of existing aircraft. Widespread adoption is only likely to occur if the system is reasonably priced, easily retrofitted, and includes features that make it attractive to operators. We believe our system effectively combines data survivability with attributes that promote widespread adoption.
One of the features of our system supporting both adoption and survivability is its dual recording architecture. The data, including video, audio, and GPS position, is recorded simultaneously to two MicroSD memory cards. One card is mounted in an external USB adapter. Recording to this card can be switched on and off by the operator, and the card can be periodically removed to transfer flight video to a computer. This provides operators the benefit of using the video as a training tool, air tour souvenir, etc. The second card is internally mounted, not accessible to the operator, and records any time the aircraft battery power is on.
The choice of MicroSD as the recording media was a result of an engineering review of survivability. Further, we chose a specific brand and model based on its ruggedness. Our memory cards are rated for 500 G impact compared to TSO C197's 1000 Gs, but the camera's location in the cabin ceiling should provide additional attenuation of impact forces in an accident. The cards are also rated for 72 hour submersion in 1 meter of salt or fresh water. TSO C197 does not appear to have a waterproofness requirement. The cards themselves are not fire resistant and we are unable to provide a fire resistant camera case with a reasonable size and weight.
However, we have retrofitted our entire fleet with crash resistant fuel systems and incidences of post-crash fires are quite low.
In addition to ruggedness of the storage media, latency of data transfer to the media is of concern during the final moments of an accident sequence. Assuming the active recording stops at the moment of impact, any data not yet written to the card is lost. The latency period for many popular action cameras can be over 15 seconds, but we worked with the manufacturer to reduce our latency period to less than one-half second.
A great deal of additional detailed information about our system is available on our website, and we have attached a copy of the Cockpit Camera User's Guide for your reference.
February 25, 2021 · NTSB Correspondence · Airbus
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
February 25, 2021 · NTSB Correspondence · Bell Helicopter Textron, Inc.
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
February 25, 2021 · NTSB Correspondence · Leonardo Helicopters
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
February 25, 2021 · NTSB Correspondence · MD Helicopters
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
February 25, 2021 · NTSB Correspondence · Robinson Helicopter Company
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
February 25, 2021 · NTSB Correspondence · Sikorsky Aircraft
Reiterated in NTSB Aviation Accident Report AAR-21-01 “Rapid Descent Into Terrain Island Express Helicopters Inc. Sikorsky S-76B, N72EX Calabasas, California January 26, 2020.” Published on February 25, 2021.
2.7 Crash-Resistant Flight Recorder Systems
Certain circumstances of this accident could not be conclusively determined, including the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s penetration of clouds and entry into IMC. A crash-resistant flight recorder system capable of capturing audio and images could have provided this valuable information, possibly enabling the identification of additional safety issues and the development of safety recommendations to prevent similar accidents in the future.
The NTSB has previously issued recommendations to require recorders on helicopters, such as on the Sikorsky S-76B helicopter involved in this accident. The first of these helicopter-specific recommendations resulted from our participation in the 2005 foreign-led investigation of a fatal accident involving a Sikorsky S-76C+ helicopter, registered in Finland, that experienced an upset and crashed into the Baltic Sea due to an airworthiness problem.71 This was the first time that we participated in an accident investigation involving a helicopter that was equipped with a flight data recorder (FDR), which was required equipment per Finland’s regulations.
Importantly, without the FDR data, the investigation would not have been able to identify and address the airworthiness issue that caused the accident.
71 The accident, which killed both pilots and all 12 passengers, occurred on August 10, 2005, and involved a Sikorsky S-76C+ helicopter that departed Tallinn, Estonia, en route to Helsinki, Finland.
72 The types of CVRs and FDRs that are required by regulation to be installed on certain aircraft are designed to stringent crash-survivability standards. Crash-resistant flight recorders, which are designed to a less stringent survivability standard, are generally less expensive, lighter weight, and able to record much of the same information as CVRs and FDRs, as well as cockpit images.
As a result, we not only issued three urgent NTSB safety recommendations to address the airworthiness issue, but we also issued Safety Recommendations A-06-17 and -18 to the FAA to address recorders for helicopters in the United States. These recommendations asked the FAA to require all rotorcraft operating under
January 25, 2021 · NTSB Correspondence · Airbus
We note that service bulletins (SBs) on retrofit installation of the Appareo Vision 1000 cockpit camera system are available for operators of your in-service fleet. We also note that you have developed information on the potential safety benefits of these systems and recommendations on managing the collected data.
We believe the SBs and supplemental information that you have developed about the Appareo Vision 1000 are partially responsive to these recommendations; however, as we stated above, we are concerned because this system is neither crash-resistant nor crash-protected. We note that you are assessing methods to improve the survivability of cockpit camera data by storing it on an existing crash-protected flight recorder system. We look forward to receiving additional information on the progress of these assessments and a plan to implement a cockpit image recorder whose data is crash-protected.
Pending our review of additional information and completion of the recommended actions, Safety Recommendations A-20-29 and -30 are classified OPEN--ACCEPTABLE RESPONSE.
January 25, 2021 · NTSB Correspondence · Bell Helicopter Textron, Inc.
We note that all of your newly manufactured helicopters are equipped with devices that capture data via embedded nonvolatile memory; however, these components are neither crash resistant nor do they record cockpit audio or images.
We believe a crash-resistant flight recorder system that records parametric data, cockpit audio, and images is crucial to identifying potential safety issues in accidents and incidents, and that Bell’s voluntary installation on newly manufactured helicopters would help proliferate this crucial equipment. We are concerned, however, that you did not indicate any plans to incorporate the recommended recorder systems on your newly manufactured and existing turbine-powered helicopters that are not equipped with an FDR or a CVR. Pending our review of such a plan, and completion of the recommended actions, Safety Recommendations A-20-27 and -29 are classified OPEN--UNACCEPTABLE RESPONSE.
January 25, 2021 · NTSB Correspondence · Leonardo Helicopters
We note that cockpit voice flight data recorders (CVFDRs) are available as optional equipment on most of your normal category helicopters. We also note that you are considering new recorder systems for these helicopters that would record data, audio, and images.
We are pleased to learn that you are looking at ways to expand the capabilities of your recording systems to include cockpit images. We would like to know if the recording systems that you are considering comply with the requirements of TSO C197 and if they will be available as a retrofit kit for your existing turbine-powered helicopters that are not equipped with a CVFDR. We believe a crash-resistant flight recording system that records parametric data, cockpit audio, and images is crucial to identifying potential safety issues in accidents and incidents.
Pending our review of this additional information, and completion of the recommended actions, Safety Recommendations A-20-27 and -29 are classified OPEN--ACCEPTABLE RESPONSE.
January 25, 2021 · NTSB Correspondence · MD Helicopters
As mentioned above, we note that you are in the process of testing and evaluating different crash-resistant flight recorder systems (including audio, images, and data) that are compatible with your existing helicopters; however, we understand that you are concerned about identifying a recorder system that is compatible with your helicopters that were certified under the old Civil Air Regulations Part 6.
We recognize the challenges that this recommendation poses for some of your older helicopters; however, we point out that a TSO C197-compliant flight recorder system that is connected to an imaging device would provide a means to collect a multitude of data, including a view of the instrument panel, and would not require extensive modifications. We continue to believe that providing a way to install a crash resistant flight recorder system on these aircraft is crucial to identifying potential safety issues in accidents and incidents.
Pending our review of periodic updates on your progress, and completion of the recommended action, Safety Recommendation A-20-29 is classified OPEN--ACCEPTABLE RESPONSE.
January 25, 2021 · NTSB Correspondence · Robinson Helicopter Company
We note that you are in the process of developing a flight recorder system for your newly manufactured and existing helicopters that records cockpit video, audio, and some parametric data. We also note that, although the system offers some protections, it is not compliant with TSO C197.
We believe your efforts thus far are responsive to these recommendations; however, we continue to believe that data survivability is a key component to identifying potential safety issues in accidents and incidents. Although systems such as the Appareo Vision 1000 have been helpful in some of our investigations, we are concerned that their data are at risk of being lost if they are involved in a severe ground impact or postcrash fire. We point out that TSO C197 includes standards that were developed to provide protections in these scenarios.
However, we recognize that emerging technologies could allow for the development of a recorder system that is not TSO compliant but that has robust crash-resistant features that still meet the intent of these recommendations. Therefore, we request additional information on the standards used to develop your recorder systems. Pending our review of this additional information, and completion of the recommended actions, Safety Recommendations A-20-27 and -29 are classified OPEN--ACCEPTABLE RESPONSE.
Our Office of Research and Engineering will be contacting you to schedule a meeting to discuss your concerns regarding our policy for handling flight recorder data during an investigation.
October 12, 2020 · Recipient Response · Airbus
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
October 12, 2020 · Recipient Response · Bell Helicopter Textron, Inc.
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
October 12, 2020 · Recipient Response · Leonardo Helicopters
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
October 12, 2020 · Recipient Response · MD Helicopters
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
October 12, 2020 · Recipient Response · Robinson Helicopter Company
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
October 12, 2020 · Recipient Response · Sikorsky Aircraft
FROM GENERAL AVIATION MANUFACTURERS ASSOCIATION: -From Peter J. Bunce, President and CEO, General Aviation Manufacturers Association: In June of this year, we discussed preliminary industry perspectives on NTSB’s recent Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters.
As you are aware, this report contains four recommendations to helicopter manufacturers concerning crash-resistant recorders. GAMA and the broader rotorcraft manufacturer community are concerned that the recommendations advanced in the report are prohibitively prescriptive and fail to consider technologies that have the potential to provide even greater safety benefits.
GAMA coordinated a series of meetings with aircraft and avionics manufacturers to understand their perspectives on the recommendation report. These meetings included representatives from Airbus Helicopters, Inc.; Bell; Boeing Military Rotorcraft; Enstrom Helicopter Corp.; Garmin International, Inc.; Gulfstream Aerospace Corp.; Honeywell Aviation; Leonardo; Lilium; MD Helicopters; Robinson Helicopter Company; and Sikorsky, a Lockheed Martin Company. Attached is an analysis providing industry feedback on the recommendations and discussing alternate solutions to meet the intended safety goals.
Specifically, our industry encourages the Board to consider a more flexible approach to data collection solutions, which would facilitate adoption and appeal to an even wider portion of the helicopter community.
As always, we appreciate your willingness to engage in candid, open conversation on this issue of substantial mutual importance. We would be happy to provide any additional information that the NTSB would find useful.
Industry Response to NTSB Safety Recommendation Report ASR-20-04
On behalf of the rotorcraft community, GAMA recommends that the National Transportation Safety Board (NTSB) consider an approach to aircraft data collection solutions that appeals to a wider portion of the general aviation community and facilitates both proactive and reactive safety benefits. In doing so, the Board, and regulators implementing NTSB recommendations, should recognize the unique challenges presented by making retrospective changes to the in-service fleet.
Technically and economically viable solutions are essential to facilitate equipage that can improve safety.
September 4, 2020 · Recipient Response · Airbus
-From Gilles Bruniaux, Vice President Product Safety, Airbus Helicopters: Airbus Helicopters wants to acknowledge receipt of the letter provided on the 2nd of June and welcomes the NTSB safety recommendations. This initiative is indeed in line with Airbus Helicopters’ commitment to safety and our ongoing efforts that strive to save lives by understanding and even better preventing accidents through all feasible means.
In order to underline the Airbus Helicopters’ commitment to safety, Airbus Helicopters’ approach of implementing recorders in our fleet, began ten years ago. This initiative resulted in the development of an Airbus strategy to implement recorders in all our new civil aircraft, as formalized in our recorder policy known today as “Step 1”.
With “Step 1”, Airbus Helicopters decided to equip all newly manufactured helicopters (whether equipped or not equipped with Cockpit Voice Flight Data Recorder (CVFDR)) with an Appareo “Vision 1000” cockpit camera. This device features removable data storage on a SD card and additionally features a shock-hardened internal memory module that provides redundant memory backup.
We can state today that Airbus Helicopters achieved this target in 2016 for all in-production helicopters (refer to NTSB recommendations A-20-27 and A-20-28). Airbus Helicopters subsequently developed service bulletins (SB’s) that provided for the retrofit installation of the “Vision 1000” system and, in 2017, we published Information Notice No 3022-I-25, Usage of data recorded in AIRS (Airborne Image Recorder System) "VISION 1000", which detailed the safety benefits and provided recommendations on how to manage “Vision 1000” data. This “Step 1” policy encompassed retrofit offers for CVFDR and cockpit camera systems alike, and provided affordable pricing for their purchase.
It is to be highlighted that Airbus Helicopters made another key extension of the “Step 1” policy with the decision to equip all newly manufactured
August 25, 2020 · Recipient Response · Bell Helicopter Textron, Inc.
-From Mitch Snyder, President and CEO: This letter is a collective response to the NTSB Recommendations (A-20-27, A-20-28, A-20-29, A-20-30) identified in your communication of June 2, 2020. Bell takes the safety of our customers and products seriously and welcomes industry engagement on the topic of flight data utilization to enhance the safety posture of the industry.
Bell is a proponent of data to improve safety, especially proactive operator Flight Data Monitoring (FDM) programs. All our current in-production models include multiple devices that capture data via embedded non-volatile memory (NVM) and are equipped with memory units that are removable or downloadable for FDM programs. Though none of these components meet specifications required in a crash resistant TSO, our recent experience indicates that they have been extremely useful in the investigation of accidents and serious incidents. Indeed, when the remains of the vehicle were available, we have successfully recovered data more than 80% of the time that was relevant to the investigation.
In addition to these on-board devices, the current Bell 429 and 412 production models offer customers a cockpit voice and flight data recorder (CV/FDR) as a kit option. The Bell 505 and 407 models come standard with these capabilities embedded. Based on recent experience with post-accident data, we believe the current products meet the intent of the NTSB's recommendations.
Moreover, STC systems are currently available on the market that, while not meeting the mentioned TSOs, do meet the intent of the recommendations (e.g. the Appareo Vision 1000 for the Bell 206 and 407 family of helicopters). Though not Bell produced, we believe that these recording devices meet the intent for our legacy fleet should an operator choose to install a device.
In short, there are a wide range of features and equipment that are available today - either standard on our equipment or aftermarket - that Bell believes satisfies the intent of the NTSB's recommendations. We appreciate your continued diligence in assessing rotorcraft safety and are committed to maintaining an open dialogue.
August 7, 2020 · Recipient Response · Leonardo Helicopters
-From Gian Piero Cutillo, Managing Director, Leonardo Helicopters Division: In-Flight recording systems, such as Cockpit Voice Recorders (CVRs) and Flight Data Recorders (FDRs), have proven valuable in identifying the root causes of accidents and preventing or minimizing the occurrence of similar events. In the absence of data on the aircraft condition and operation, it might be very difficult to reconstruct the sequence of events that led to the accident or the serious incident.
Because of this, CVR/FD Rs are mandated for installation on Part 29 rotorcraft by the Federal Aviation Administration (FAA) as well as by the European Aviation Safety Agency (EASA) (ref. to 29.1457 and 29.1459). LH products such as AW139, AW169 and AW189 are compliant to such specifications. Additionally, cockpit image recording systems (either crash resistant or non-crash resistant) are also available as Optional Kits for installation upon Customer request or National Authority specific operational requirement.
On the other hand, neither FAA nor EASA are currently mandating certification requirements for installation of Cockpit Voice Recorders {CVRs) and Flight Data Recorders (FDRs) on Part 27 rotorcraft.
It is known that, after critical events, many recommendations were raised by Investigation Authorities, to compel the Certification Authorities to take action in order to mandate their installation also on Part 27 rotorcrafts.
To date, Certification Authorities have not acted on these repeated recommendations, although they have encouraged helicopter operators to voluntarily use either crash-resistant or non-crash resistant flight recording systems.
Similarly, to FAA, EASA conducted systematic studies of safety investigation reports in order to assess the expected benefit of in-flight recording for either preventing accidents or minimizing the associated rate (refer to NPA 2017-03, Appendix E19).
July 20, 2020 · Recipient Response · Robinson Helicopter Company
-From Kurt Robinson, President: Robinson Helicopter Company (RHC) is committed to the safety of our products, and we welcome your recommendations. We had independently reached similar conclusions regarding the benefits of flight recorders. As detailed below, we are already well along on a program to offer equipment both on new helicopters and as field retrofits. In addition to retrieval of post-accident data, we envision the use of recorded data in the training and fleet management environments as a means of breaking the accident chain before one occurs.
The industry as a whole is realizing the value of flight recorders, and we are aware of other efforts to bring systems to market. Developments in recent years in the areas of electronics and data storage have enabled consideration of systems for smaller aircraft that otherwise could not accommodate the weight and cost of such equipment. However, your recommendation that all data recording equipment be installed as required equipment fully qualified to TSO-C197 would put it out of reach for us. Your ASR-20-04 report gives the Appareo Vision 1000 as an example of non-TSO equipment and cites concerns over its inability to survive a postcrash fire.
However, you also cite several good examples of it providing valuable data. It certainly is a net benefit to have such equipment onboard. Even non-TSO'd, the Appareo has a list price of approximately ten thousand dollars. TSO qualification limits the use of the latest technology, resulting in less capable systems with significantly increased weight and cost. Installation as required equipment involves high engineering costs and long FAA lead times to achieve the required level of testing and documentation.
As noted in your recommendations, FAA has not made data recorders a regulatory requirement. Short of a regulation, adoption rates will be largely dependent on making the system economical, lightweight, and easy to install. Therefore, we consider a system that can use commercial components and be certified on a no-hazard basis essential to the intended purpose of encouraging widespread data gathering.
We have been working on such a system and have arrived at a viable design which we will begin fielding in the next few months. Our system records cockpit video (including instruments and outside view), audio (audio system and ambient), and some parametric data. In addition to being available for new helicopters, it can be easily installed in the field, which constitutes the vast majority of the fleet. Careful design consideration was given to data retention after an accident, including a buffer for sudden power loss, but the system is not TSO-C197 qualified.
July 9, 2020 · Recipient Response · MD Helicopters
-From Jeffrey S. Adamcik, Deputy General Counsel and Secretary, MD Helicopters, Inc.: MD Helicopters, Inc. (MDHI) is writing in response to a letter dated June 2nd, 2020 in which a perceived safety issue was requested to be addressed. The NTSB has stipulated that, the FAA t hrough a sustained lack of regulatory progress, has yet to require a technical standard order compliant crash-resistant recorder system and crash-protected image recorder system be installed on all turbine-powered helicopters.
As a result, the NTSB is recommending MDHI install on newly manufactured turbine powered helicopters a flight data/cockpit voice recorder (CVR/FDR) along with a camera that records cockpit/cabin audio, parametric flight data, and images with a view of the cockpit environment to include as much of the outside view as possible. This CVR/FDR needs to be in compliance to Technical Standard Order C197 "Information Collection and Monitoring Systems". This recorder system installation will be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
The NTSB also recommends the means to install on all existing MDHI turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, as specified in Technical Standard Order C197 "Information Collection and Monitoring Systems".
The recorder system installation, once completed, will be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29) MDHI will evaluate installation of essential equipment in compliance with 14 CFR Part 27.
The aforementioned safety recommendations and concerns of the NTSB are currently being addressed by MDHI. MDHI has taken considerable steps to research installation plans for systems such as crash-resistant cockpit voice recorders, crash-resistant cockpit video cameras, and crash-resistant flight data recorders for all current models of MD Helicopters. MDHI understands the need for such systems and is working with industry leaders, who develop and produce these systems, to find an innovative solution that will accommodate future and present MD Helicopter owners.
June 2, 2020 · NTSB Correspondence · Airbus
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-27 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
June 2, 2020 · NTSB Correspondence · Bell Helicopter Textron, Inc.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives.
We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-27 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public.
Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
June 2, 2020 · NTSB Correspondence · Leonardo Helicopters
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives.
We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-27 though -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public.
Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
June 2, 2020 · NTSB Correspondence · MD Helicopters
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-27 and -29). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
June 2, 2020 · NTSB Correspondence · Robinson Helicopter Company
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives.
We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-27 and -29). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public.
Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
June 2, 2020 · NTSB Correspondence · Sikorsky Aircraft
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters.
The attached letter from the NTSB Chairman provides information about the NTSB’s May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives.
We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, A-20-28 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations will be stored by the NTSB and viewable by the public.
Please do not send privileged or confidential communications in response to this/these recommendation(s). Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters.
Concerning your comments about the availability of cockpit audio and image recordings to party members, the handling of all such recordings during our investigations is governed by federal statute, regardless of the specific source of such recordings (whether from a CVR or other recording device). Similar to CVR groups, we form investigative groups with party representatives to review cockpit audio and image recordings and participate in group transcription activities within the bounds of the federal statute.
If a safety issue is identified during the group activity, we disseminate necessary information to other parts of the investigation team prior to releasing the transcript or summary report. Further, any parametric data extracted from an image recording can be shared with the parties in the same manner as FDR data.
Accordingly, pending our review of the findings from your evaluation, and completion of the recommended actions, Safety Recommendations A-20-28 through -30 are classified OPEN-- ACCEPTABLE RESPONSE.
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
(flight data recorders) substantially increases weight. The cost and weight increase can extend the implementation timeframe and limit the feasibility of installation of recorders on certain vehicles and for certain operators. Crash-hardened systems, however, are sufficient for even most severe accidents.
Industry and the NTSB have demonstrated the ability to extract data—including from avionics systems, non-volatile-memory items, and engine control devices—that has been recovered from numerous accidents and incidents to support investigations. Additionally, as noted during the February 9th NTSB Board Meeting, crash protection is not needed for flight data monitoring—programs that are critical to reducing accidents and incidents before they occur.
Accordingly, GAMA encourages the NTSB to recognize in its recommendations and safety promotion products the value of sufficiently ruggedized systems that provide the features to support flight data collection and analysis but do not require crash-protected design and extensive qualification. This recognition will help to advance the broader voluntary adoption of these important technologies, flight data analysis and SMS for which NTSB is advocating.
Technology that supports FDM-type programs.
Data recording technology does not itself convey a safety benefit. To advance general aviation safety, data recording technology must be used. Although industry strongly supports the introduction and use of cockpit audio and image recorder options as part of a structured flight data monitoring (FDM)-type program, not all recorder technologies are well-suited for use in proactive general aviation safety programs. For example, voice recorders and image recorders generally provide limited, if any value for use in such programs, no matter how much data is recorded—the collection of flight data must be paired with an active operator FDM program assisted by appropriate FAA oversight.
At the NTSB’s Board Meeting on February 9th, Member Graham asked about the benefit of a flight monitoring device without a flight data monitoring program. IIC English astutely replied that they must go hand-in-hand. GAMA wholeheartedly agrees and encourages the NTSB to advocate for the use of recorder technologies that facilitate proactive flight data analysis.
Retrofit challenges.
GAMA’s industry response to NTSB’s Safety Recommendation Report underscored the challenges with retrofitting recorder technologies into older aircraft without modern avionics. In your reply, you indicate that there are lightweight cockpit audio and image recorders that are “a viable alternative to equipping newly manufactured and existing helicopters without modern avionics with the sensors and wiring required for a traditional CVR and FDR.” You have noted that “These recorders can be designed to be lightweight and, if installed with an unobstructed view of key cockpit instruments, provide investigators with additional flight data parameters.”
Safety Recommendation Report ASR-20-04, however, specifically calls for recorders meeting TSO C197, C176a, and 14 CFR 25.1457. GAMA is only aware of two that currently meet these specifications. A performance-based approach to recommending recorder technology could better address the challenges of retrofitting certain segments of the industry and substantially broaden the safety benefit of this important recommendation.
Operational factors.
To achieve equipage goals, we encourage the NTSB to consider operational aspects of the issue as well. Safety Recommendation Report ASR-20-04 directs its recommendations only to aircraft manufacturers. As discussed at the February 9th Board Meeting, the accident aircraft was equipped with a CVR when it was manufactured; the operator removed it. Manufacturers cannot control post-delivery changes. This also makes it technically difficult— and costly—for manufacturers to develop and implement retrofit solutions as new rotorcraft configurations can vastly differ from previously delivered technological configurations.
As the NTSB acknowledges, the FAA has not mandated that all aircraft operators install recorder technology, citing privacy, security, cost, and other concerns. For voluntary adoption by manufacturers and operators, providing the rotorcraft community with flexible solutions that nonetheless meet the NTSB’s safety intent is absolutely essential. Although the NTSB limited its recommendations to turbine aircraft, a performance based recommendation could be addressed to an even broader audience with more significant safety benefits.
* * *
GAMA looks forward to continuing to support the NTSB in the Board’s essential role in advancing aviation safety. We would welcome the opportunity to coordinate a meeting with the NTSB to provide more information. We understand that the COVID-19 pandemic continues to present unprecedented challenges for the NTSB, and we greatly appreciate your time and consideration. Please contact our colleagues, Lauren Haertlein and Jonathan Archer with any questions!
• Voluntarily installed equipment can be voluntarily removed, particularly for models that were type certified without it. Without a regulatory mandate in place requiring the devices, market acceptance of OEM installed recording equipment could be low. It will be critical for the FAA and the NTSB to educate operators on the value of the equipment both during an accident investigation and as part of operators Safety Management Systems.
As stated above, Bell is committed to advancing the safety of rotorcraft and is actively developing and implementing safety enhancing equipment and technologies. Bell will continue to evaluate possible means to implement the Safety Recommendations as proposed by NTSB.
We look forward to NTSB's feedback and proposals on the challenges identified above, which should be common for all manufacturers.
Although STCs for CVR/FDR and EGPWS exist for all S-76 types, the cost to an operator to install a certificated FDR can easily exceed the entire hull value of the aircraft. While certificated CVR and EGPWS installations are less costly than an FDR, they still represent a significant portion of the hull value; and few, if any, operators could afford to install them. Currently available off the shelf hardware presents an alternative solution to allow the intent of the recommendation to be complied with, for a much larger percentage of the fleet, at a reasonable cost.
Commercial off the shelf (COTS) solutions to flight data recording, cockpit sound recording, and image recording exist. While many of these solutions do not meet the crashworthiness and fire survival requirements of ED-112, they have been shown to survive most helicopter accidents. Their far lower acquisition cost, relative ease of installation, and general fleet acceptance will enable a much more rapid and widespread usage. It is Sikorsky’s belief that incorporating the entire passenger-carrying fleet of helicopters with an AMOC ‘90% solution’ is far more desirable than incorporating a much smaller portion of the fleet with a certificated ‘100% solution’.
Many of these COTS solutions have the added benefit of supporting a flight data monitoring (FDM) program as prescribed in recommendation A-21-8 of AAR-21-01.
Sikorsky is an advocate for solutions that improve customer safety. Sikorsky is actively evaluating image recorder and carry on board technologies to provide cost effective solutions with a proven safety enhancement for all aircraft in Sikorsky’s commercial product line.
Although STCs for CVR/FDR and EGPWS exist for all S-76 types, the cost to an operator to install a certificated FDR can easily exceed the entire hull value of the aircraft. While certificated CVR and EGPWS installations are less costly than an FDR, they still represent a significant portion of the hull value; and few, if any, operators could afford to install them.
Currently available off the shelf hardware presents an alternative solution to allow the intent of the recommendation to be complied with, for a much larger percentage of the fleet, at a reasonable cost.
Commercial off the shelf (COTS) solutions to flight data recording, cockpit sound recording, and image recording exist. While many of these solutions do not meet the crashworthiness and fire survival requirements of ED-112; they have been shown to survive most helicopter accidents. Their far lower acquisition cost, relative ease of installation, and general fleet acceptance will enable a much more rapid and widespread usage. It is Sikorsky’s belief that incorporating the entire passenger-carrying fleet of helicopters with an AMOC ‘90% solution’ is far more desirable than incorporating a much smaller portion of the fleet with a certificated ‘100% solution’.
Sikorsky is an advocate for solutions that improve customer safety. Sikorsky is actively evaluating image recorder and carry on board technologies to provide cost effective solutions with a proven safety enhancement for all aircraft in Sikorsky’s commercial product line.
Thank you for your interest in improving aviation safety.
Thank you for your interest in improving aviation safety.
Thank you for your interest in improving aviation safety.
Thank you for your interest in improving aviation safety.
Thank you for your interest in improving aviation safety.
Thank you for your interest in improving aviation safety.
Our data recording system, the Cockpit Video Camera, is now available on new production helicopters. It is standard equipment on all of our 2021 model year turbine (R66) helicopters. We are also offering it as a $2500 option on our piston (R22 and R44) models. Helicopters built within the last year are pre-wired for easy retrofit, and kits are available for those helicopters. Retrofit kits for older helicopters are in-work at this time.
Our previous correspondence with you also included the topic of efficiently sharing data from recorders among investigative parties including airframe and engine manufacturers. Mr. Dennis Hogenson has made initial contact with us regarding this issue, and we look forward to further discussions.
Please let us know if you have further questions regarding our data recording system.
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
and 135 with a transport-category certification (such as the Sikorsky S-76-series helicopter) to be equipped with a cockpit voice recorder (CVR) and an FDR, and to not permit exemptions or exceptions to the flight recorder regulations that allow such rotorcraft to operate without recorders (NTSB 2006).
As a result of the FAA’s decision not to take these actions, we classified both A-06-17 and -18 “Closed—Unacceptable Action” on September 11, 2014.
On May 6, 2013, the NTSB issued Safety Recommendation A-13-13 to recommend that the FAA require a crash-resistant flight recorder system compliant with Technical Standard Order (TSO) C197, “Information Collection and Monitoring Systems,” as a retrofit on existing turbine-powered, nonexperimental, nonrestricted-category aircraft that are not equipped with an FDR or CVR and are operating under Parts 91, 121, or 135.72 The crash-resistant flight recorder system should record cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible, and parametric data per aircraft and system installation(NTSB 2013).73
In the 7 years since we issued Safety Recommendation A-13-13, we have reiterated it five times based on our findings from investigations of other fatal accidents (NTSB 2014, 2017a, 2017b, 2018, and 2020a).We have been issuing similar recommendations since 2000 (NTSB2000).74 During this 20-year period, the FAA has replied that it does not disagree with these recommendations but that it is unable to create a cost-benefit analysis for such a mandate that would satisfy the requirements of the Office of Management and Budget for new federal regulations. The FAA has not been able to identify quantifiable benefits associated with a mandate for recorders.
During 2017, staff from the FAA and the NTSB met to discuss what information from the NTSB would help the FAA develop the needed cost-benefit analysis to justify the recommended mandate.
On July 19, 2017, NTSB staff provided the FAA a list of all accidents in our database from 2005 through 2017 that involved turbine powered, nonexperimental, nonrestricted-category aircraft and in which flight crew were killed. There were 185 such accidents. For159 of these, the accident aircraft had no form of recording equipment and involved advanced aircraft with complex systems that are more difficult to investigate due to the lack of information.
Of the 159 accidents, the probable cause for 18contained “unknown” (for example, if the aircraft crashed after take off for unknown reasons). On October 2, 2017, we noted that, although doing the cost-benefit analysis needed to issue the recommended mandate would be challenging, the FAA now appeared to be examining how to accomplish it. Pending the FAA taking the recommended action, Safety Recommendation A-13-13 was classified “Open—Acceptable Response.”
In addition, on June 2, 2020, the NTSB issued Safety Recommendation A-20-29 to six helicopter manufacturers (including Sikorsky) to recommend that they provide, on existing turbine-powered helicopters that are not equipped with an FDR or CVR, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in TSOC197.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight (NTSB 2020b).75
Thus, the NTSB concludes that a crash-resistant flight recorder system that records parametric data and cockpit audio and images with a view of the cockpit environment to include
73We also issued Safety Recommendation A-13-12, which applied to newly manufactured helicopters; see appendix C for more information.
The accident helicopter, as operated by Island Express (per its OpsSpecs) for VFR flights, was not required to be equipped with a CVR because only one pilot was required. (Per 14 CFR135.151[a], a CVR was required for multiengine, turbine-powered airplanes and rotorcraft having a seating configuration of six or more and for which two pilots were required by certification or operating rules.)
74See appendix C for more information.
75Safety Recommendation A-20-29 is classified “Open—Acceptable Response” overall (with the recipient classification for Sikorsky “Open—Await Response”); see appendix C for more information.
On October 5,2020, the General Aviation Manufacturers Association sent us a letter stating that, although it (on behalf of the rotorcraft community) supported the objective of our safety recommendation, it found it to be prohibitively prescriptive.
as much of the outside view as possible could have provided valuable information about the visual cues associated with the adverse weather and the pilot’s focus of attention in the cockpit following the flight’s entry into IMC. Therefore, the NTSB reiterates Safety Recommendations A-13-13 and A-20-29.
Also, on September 29, 2020, the FAA provided us with an update stating that it submitted a rulemaking project for fiscal year 2020 to review various standards and methodologies to determine the feasibility of requiring aircraft operated under Parts 91, 121, and 135 to be equipped with a crash-resistant fli
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
I. Background
On June 2nd, 2020, the NTSB issued Safety Recommendation Report ASR-20-04, Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters, derived from certain accidents involving rotorcraft that lacked crash-resistant or crash protected recorders that record parametric data, cockpit audio, and images. The report contains four recommendations to rotorcraft manufacturers:
1. “To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, and Robinson Helicopter Company: Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27).
2. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Install on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, "Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28).
3. To Airbus Helicopters, Bell, Leonardo Helicopter Division, MD Helicopters, Robinson Helicopter Company, and Sikorsky: Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in the Technical Standard Order C197, "Information Collection and Monitoring Systems."
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29).
4. To Airbus Helicopters, Bell, Leonardo Helicopter Division, and Sikorsky: Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is complaint with Technical Standard Order C176a, " Cockpit Image Recorder Equipment," or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30).”
GAMA represents over 100 of the leading manufacturers of general aviation aircraft, engines, avionics, components, and related services, including recipients of the recommendations above. GAMA’s members also operate repair stations, fixed-base operators, and pilot and technician training facilities and manage aircraft fleets. This white paper provides an industry1 analysis of the recommendations in NTSB Safety Recommendation Report ASR-20-04 and discusses alternate solutions to meet the intended safety goals.
II. Discussion
Industry strongly supports the installation and use of flight data recorder technologies and recognizes the safety benefits that these systems can provide, both in accident/incident investigation and in the prevention of accidents through use in flight data monitoring programs. The recommendations in NTSB Safety Recommendation Report ASR-20-04, however, focus too narrowly on crash-resistant or crash-protected equipment and post-accident investigation, rather than considering embedded or “light” recording technologies that also can offer proactive safety benefits.
Additionally, the technologies available to meet the specific recommendations in ASR-20-04—especially for lighter helicopter models—are extremely limited, presenting substantial near-term challenges to implementation. As an overarching matter, industry encourages the NTSB to make performance-based recommendations that do not unduly limit the current solutions available, as well as exclude future solutions as technology evolves.
The majority of 14 C.F.R. Part 27 helicopters do not have modern avionics systems from which to capture the flight data to meet the recommendations. For these aircraft, installing recorders that meet the recommendations in NTSB Safety Recommendation Report ASR-20-04 is an extremely costly and invasive process. Retrofitting current recorder systems would be complex and cost-prohibitive, given the invasive nature of the required installation
helicopters weighing more than 10,000 pounds with fully crash-protected and regulation-compliant CVFDRs.
In the years following implementation of “Step 1” policy, Airbus Helicopters received significant positive feedback and experience in using recorders to support Helicopter Flight Data Monitoring (HDFM) and in the investigation of aircraft incidents and accident across our aircraft fleet. Based on the success, lessons learned, and benefits of “Step1”, Airbus Helicopters recently took the positive decision to further evolve our recorder policy to “Step 2”, which is currently in development.
The primary goals for the new “Step 2” initiative include providing additional data sources, while also improving data integrity of the recording systems. For example, Airbus Helicopters sees benefits in capturing other video streams, including external camera sources (such as those installed in the tail fin) in addition to an internal camera. Similarly, Airbus Helicopters envisions an architecture that provides cockpit camera data to be stored in the CVFDR, which provides the advantage that the CVFDR certification already incorporates requirements for crash protection and an independent power supply.
This architecture has already been certified in our H160 and H225 fleet, and is pending certification in our other aircraft models.
In reviewing the recommendations of A-20-27 and A-20-28, Airbus Helicopters notes that our Step 1 and Step 2 recorder policies meet the “spirit” of the NTSB recommendations, even though several gaps exist in meeting full compliance. For example, Airbus Helicopters’ early commitment to integrate recorders in all newly manufactured helicopters came before any regulatory or performance requirements existed, implying that some requirements regarding crash hardening, fire protection, or independent power supply may not be achieved (particularly in our light helicopter fleet).
Nevertheless, Airbus Helicopters has seen significant safety benefits in utilizing these systems, even in situations that resulted in substantial aircraft damage or destruction. Accordingly, we remain commited to exploring solutions which will fulfill the NTSB recommendations, while also consider new operational regulations, such as EASA CAT.IDE.H.191 (with a light recorder crash-“hardening”, in line with TSO-C197).
Airbus Helicopters has additionally performed a market survey comparing these criteria with available technologies. Our analysis indicate potential challenges, as there are no off-the-shelf complete solutions available today. Additionally, a recently published EASA regulation will be implemented in September 2022. While we are confident that we will develop and certify technical solutions fully compliant with all European and U.S. regulatory requirements, while also considering the NTSB’s recommendations, it is too early to assess the development time.
In reviewing the recommendations of A-20-29 and A-20-30, we note that our customers have clearly demonstrated a lack of interest to retrofit such equipment even with pricing incentives. For example, SBs published to support installation of both the cockpit camera and CVFDR systems, which targeted a fleet of ~7,700 eligible helicopters, resulted in the retrofit of only a small number of kits in the last six years. In spite of their safety benefits, many customers view such recorder equipment, as “nonessential”, since they are not required by the certification or general aviation operating regulations.
Consequently, Airbus Helicopters believes that a more effective means of deploying affordable recorders on the legacy fleet would be through implementation of an effective regulatory framework.
Airbus Helicopters firmly believes that recorders play an essential role in the exploitation and analysis of recorded data to support training and other safety enhancements through HFDM, in addition to supporting accident investigations. By developing dedicated tools to download and analyze the cockpit images and the recorded data, then transforming it into 3-D visualization aids, we are able to promote the use of the data for customer internal safety briefings, awareness sessions, ground and flight training, and HFDM.
Similarly, imagery from exterior cameras (such as those mounted to the tail fin) will provide feedback to the flight crew in real-time, enhancing their situational awareness during ground and flight operations, mitigating potential hazards.
In conclusion, Airbus Helicopters proudly reflects on the proactive approach we have taken and the accomplishments we have achieved in leading the helicopter industry with our recorder initiative. In light of the new NTSB safety recommendations, Airbus Helicopters welcomes the new challenges that will serve to enhance safety throughout the entire aviation community. Much work lies ahead of us, to which we look forward in doing collaboratively.
Should you be interested, we would be pleased to prepare an update of our ongoing development and certification activities, and to exchange with you, other aviation authorities, and the helicopter industry in the development of common recorder standards that comply with the NTSB recommendations.
Should you have any further remarks or questions which we can clarify, please feel free to contact me at any time.
The conclusion of these studies is that in-flight recording brings moderate benefit when considering light rotorcraft, so that requirements applicable to all kinds of light rotorcraft in operations have not deemed to be proportionate. Hence, EASA focused on those light rotorcraft that are used for commercial and special operations (CAT and SPO) and are capable of transporting several passengers (refer to Commission Implementing Regulation (EU) 2019/1387 dated 01 August 2019 which established CAT.IDE.A.191 and CAT.IDE.H .191 requirements).
Besides, the potential safety benefit of facilitating and promoting voluntary installation of in-flight recording equipment was also identified by EASA which published the Service Information Bulletin N. 2019-15 (further updated in January 2020). Within this SIB, EASA is recommending all owners and operators of small (light) rotorcraft, registered in the EASA member States, to consider installing a flight data recorder and keep this serviceable through the applicable equipment manufacturer's maintenance instructions.
Additionally, EASA is recommending TC and STC holders to include installation of a flight recorder as part of the basic rotorcraft configuration or as an option for in-service retrofit, and to timely provide the affected operators with maintenance instructions in order to keep the equipment serviceable.
Based on the above considerations, in the frame of the European Plan for Aviation Safety (EPAS) 2020 - 2024, anticipating the new European Operational Requirements which will affect the aircraft operating CAT and SPO starting from September 2022, Leonardo Helicopters is already discussing with EASA a list of safety-related actions which, among others, includes the installation of in-flight recording systems (including data, audio and image), mainly but not limited, to Part 27 rotorcrafts.
Different scenarios are currently under assessment addressing both newly manufactured and in-service rotorcrafts and ranging from full ED-112 / ED-155 compliance to a combination of CVR/FDR integrated with non-crash resistant video cameras which experience have demonstrated to be effective in supporting investigation even after high-energy impacts. It is worth noting that CVR/FDR Optional kits are already certified and available for installation, also as a retrofit, on the majority of LH's rotorcrafts models certified in accordance to Part 27, including: A109E, A109S, AW109SP and AW119Mkll. A dedicated Kit is currently under development for installation on the AW119Kx.
Although the EPAS 2020-2024 is aimed to address EU registered rotorcrafts, Leonardo Helicopters is going to extend the resulting safety policies to the worldwide LH fleets, including US registered rotorcrafts.
Leonardo Helicopter will inform NTSB and the rotorcraft Community confirming within reasonable time the Company's proposed policy.
A/C Model: A109E
Certification Basis: CS27/FAR27
Recorder Type: CVFDR
Memory Type: Solid State
Note: Available as optional kit.
A/C Model: A109S
Certification Basis: CS27/FAR27
Recorder Type: CVFDR
Memory Type: Solid State
Note: Available as optional kit.
A/C Model: AW109SP
Certification Basis: CS27/FAR27
Recorder Type: MPFR
Memory Type: Solid State
Note: Available as optional kit.
A/C Model: A109S Trekker
Certification Basis: CS27/FAR27
Recorder Type: CVFDR
Memory Type: Solid State
Note: Available as optional kit.
A/C Model: A119
Certification Basis: CS27/FAR27
Recorder Type: Video Camera STC available in US
Memory Type: Video Camera STC available in US
Note: Video Camera STC available in US
A/C Model: AW119MKll/Ke
Certification Basis: CS27/FAR27
Recorder Type: CVFDR
Memory Type: Solid State
Note: Available as optional kit.
A/C Model: AW119Kx G1000H
Certification Basis: CS27/FAR27
Recorder Type: Video Camera STC available in US
Memory Type: Video Camera STC available in US
Note: Video Camera STC available in US
A/C Model: AW119Kx NXi
Certification Basis: CS27/FAR27
Recorder Type: Video Camera STC available in US CVR/FDR Kit Under Development as TC
Memory Type: Video Camera STC available in US CVR/FDR Kit Under Development as TC
Note: Video Camera STC available in US CVR/FDR Kit Under Development as TC
A/C Model: AW139
Certification Basis: CS29/FAR29
Recorder Type:
MPFR Solid State, Solid State Basic Configuration.
VIDEO SD Card Available as optional kit (Partially protected)
Memory Type:
MPFR Solid State, Solid State Basic Configuration.
VIDEO SD Card Available as optional kit (Partially protected)
Note:
MPFR Solid State, Solid State Basic Configuration.
VIDEO SD Card Available as optional kit (Partially protected)
A/C Model: AW169
Certification Basis: CS29/FAR29
Recorder Type:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration.
Memory Type:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration.
Note:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration.
A/C Model: AW189
Certification Basis: CS29/FAR29
Recorder Type:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration. Cockpit Camera (Available as optional kit)
VIDEO SD Card Available as optional kit (Partially protected)
Memory Type:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration. Cockpit Camera (Available as optional kit)
VIDEO SD Card Available as optional kit (Partially protected)
Note:
MPFR Solid State Basic Configuration.
EAFR Solid State Basic Configuration. Cockpit Camera (Available as optional kit)
VIDEO SD Card Available as optional kit (Partially protected)
Such qualification, in particular fireproof requirements, would make the system such a cost and weight burden that it would be impractical for our application.
Operators and investigators are interested in having the most complete data picture regardless of details of the source. To this end, a wealth of data is also available from glass cockpit avionics. Although not universal, glass cockpits are increasingly popular and rapidly becoming pervasive. Like our recording system, they are not designed to have TSO-C197 survivability per-se, but have been shown to be quite robust in many accidents. There are inconsistencies in data format, and some devices do not retain data after a power cycle. A safety recommendation or FAA regulation relating to data retention for onboard avionics would help standardize this piece of the data picture.
We also note that portable satellite trackers are available which transmit aircraft position and text messages. We encourage adoption of this type of system in conjunction with data recorders. Safety benefits include immediate notification of accidents, location of downed aircraft (we have seen better results than with EL Ts), and communication with pilots in distress. We would be interested in further development of technology to transmit data for storage off the aircraft thus reducing the need to physically protect recording equipment.
Finally, we would like to address an issue we have seen with NTSB's data retention policy. There have been helicopter accidents where data was available from mobile phones or on board avionics, but OEM investigators were restricted or delayed access due to privacy concerns or other NTSB policies. In the interest of safety, we hope the NTSB will establish policy that balances data privacy with accessibility for investigative purposes. Data accessibility helps manufacturers improve their products and encourages widespread adoption of recorders.
In summary, RHC has developed a flight recorder that meets the safety intent of your recommendations. We intend to certify it as non-required equipment and although it is not TSO-C197 certified, the system's low weight and cost should lead to widespread adoption. The volume of data then available, used for training and fleet management in addition to accident investigation, will more than offset the occasional loss due to a severe impact or post-crash fire.
We welcome the opportunity to continue to work with the NTSB.
MDHI has been taking steps towards the integration of these systems through feasibility and airframe reviews, weight and balance analysis, and avionics compatibility. All of these steps must be performed in order to provide a certifiable installation in compliance with 14 CFR Part 27 Regulatory Requirements.
MDHI continues to evaluate essential compliant equipment to ensure they meet the regulatory requirements for MD Helicopter aircraft. MDHI continues to work with industry suppliers to test and evaluate systems that will meet installation requirements for current produced models of helicopters. Older model of MD helicopters that were certified under CAR 6 present a uniquely complex challenge with regards to integrating a compatible FDR/CVR systems on a case-by-case basis dependent on operator customizations.
As crash-resistant recording system suppliers progress and innovate their technologies, MDHI will be proactive in evaluating these new airworthy systems for installation consideration on MD Helicopters aircraft. MDHI remains committed to innovation on all our helicopter platforms and continues to meet or exceed all flight safety requirements in compliance with 14 CFR Part 27 Regulatory Requirements.
We are providing the following information to urge Airbus Helicopters to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to Airbus Helicopters:
Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
Install, on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent.
The cockpit image recorder system should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457. The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations.
When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-27 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released.
We are providing the following information to urge Bell to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to Bell:
Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
Install, on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent.
The cockpit image recorder system should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457. The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations.
When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-27 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this
We are providing the following information to urge Leonardo Helicopter Division to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to Leonardo Helicopter Division:
Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
Install, on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent.
The cockpit image recorder system should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457. The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations.
When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-27 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations.
Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be public
We are providing the following information to urge MD Helicopters to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to MD Helicopters:
Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-27 and -29). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov.
If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive.
In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
We are providing the following information to urge Robinson Helicopter Company to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to Robinson Helicopter Company:
Install, on your newly manufactured turbine-powered helicopters that are not equipped with a flight data recorder and a cockpit voice recorder, a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-27)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-27 and -29). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov.
If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive.
In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.
We are providing the following information to urge Sikorsky to act on the safety recommendations in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary.
This letter also includes information about our May 19, 2020, report Install Flight Data, Audio, and Image Recorder Systems on all Turbine-Powered Helicopters NTSB/ASR-20/04. The details of our analysis and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issue:
• A sustained lack of regulatory progress by the Federal Aviation Administration in requiring technical standard order-compliant crash-resistant recorder systems and crash-protected image recorder systems on all turbine-powered helicopters.
Accordingly, the NTSB makes the following safety recommendations to Sikorsky:
Install, on your newly manufactured turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a crash-protected cockpit image recorder system compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent. The cockpit image recorder should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457.
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-28)
Provide, on your existing turbine-powered helicopters that are not equipped with a flight data recorder or a cockpit voice recorder, a means to install a crash-resistant flight recorder system that records cockpit audio and images with a view of the cockpit environment to include as much of the outside view as possible and parametric data per aircraft and system installation, all as specified in Technical Standard Order C197, “Information Collection and Monitoring Systems.”
The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-29)
Provide, on your existing turbine-powered helicopters that are equipped with a flight data recorder and a cockpit voice recorder, a means to install a crash-protected cockpit image recorder system that is compliant with Technical Standard Order C176a, “Cockpit Image Recorder Equipment,” or equivalent.
The cockpit image recorder system should be equipped with an independent power source consistent with that required for cockpit voice recorders in Title 14 Code of Federal Regulations 29.1457. The recorder system installation should be considered essential equipment that remains installed for the life of the helicopter and have provisions to ensure it remains operational during each flight. (A-20-30)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations.
When replying, please refer to the safety recommendations by number (Safety Recommendations A-20-28 through -30). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e-mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to these recommendations.
Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto-generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.