Safety Recommendation A-20-030

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.

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.

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.

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.

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.

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.

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.

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 14 C.F.R. § 29.1457(e)

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

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

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

-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.

-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.

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.

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.

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.

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.

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.

We note that cockpit voice flight data recorders (CVFDRs) are available as optional equipment on some of your newly manufactured helicopters; however, crash protected cockpit image recorder systems are not available on any of your helicopters.

We believe the routine installation of crash-protected cockpit image recorders on newly manufactured and existing helicopters is necessary to identify and understand flight crew actions within the cockpit and to mitigate risks to public safety. We are concerned that you did not indicate any plans to incorporate the recommended recorder systems on your newly manufactured and existing turbine-powered helicopters that are equipped with a CVFDR. Pending our review of such a plan, and completion of the recommended actions, Safety Recommendations A-20-28 and -30 are classified OPEN--UNACCEPTABLE RESPONSE.

We note that partially protected video and cockpit cameras are available as optional kits on your AW139 and AW189 helicopters, but not the AW169.

We believe your efforts thus far are responsive to these recommendations. We continue to believe that data survivability is a key component to identifying potential safety issues in accidents and incidents; 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 “partially protected” systems. We would also like to know if your kits are available for existing helicopters as a retrofit.

Finally, we encourage you to install crash protected cockpit image recorders as standard equipment on all newly manufactured turbine helicopters with CVFDRs. Pending our review of this additional information and completion of the recommended actions, Safety Recommendations A-20-28 and -30 are classified OPEN--ACCEPTABLE RESPONSE.

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.

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.

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.

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.

-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

-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.

-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).

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.

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.

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.

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.