Comments on the Flight Recorder Proposal

Air Safety Week, August 1, 2005

Extracts of the comments submitted To the FAA docket

On ejectable flight data recorders

From Reps. Harold Rogers (R-Ky.) and David Price (D-N.C.), members of the Homeland Security Appropriations Subcommittee:

"The events of Sept. 11, 2001, proved that our current CVR/DFDRs [cockpit voice recorders/digital flight data recorders] are vulnerable to extreme crash scenarios. For the four airliners involved in the terrorist attacks, only two of the four FDRs were recovered. The other two FDRs have never been found. Likewise, only two CVRs were recovered, and one of those was burned beyond use, rendering it useless to investigators."

From Reps. John Duncan (R-Tenn.) and William Pascrell (D-N.J.), members of the Transportation and Infrastructure Subcommittee and sponsors of the Safe Aviation Flight Enhancement (SAFE) Act calling for the installation of deployable recorders (see ASW, July 25):

"It is our understanding that very detailed commercial deployable recorder standards, called ED 112, have been developed that define the minimum specifications that must be met for the deployable recorder's design and installation on civil aircraft ? The FAA has confirmed in a recent letter to us that deployable recorders that meet the ED 112 standards would be deemed safe and suitable for installation on commercial aircraft."

From the National Air Disaster Alliance/Foundation, representing the survivors and relatives of air crashes:

"The use of deployable recorder technology as a second, back up system would provide investigators with a viable, complementary approach to augment the current fixed recorders by meeting the aviation industry's demand for survivable and quickly recoverable flight recorders."

From the Airline Pilots Association (ALPA):

"We support 'dual combi' recorders [to] significantly reduce the risk of losing most or all recorded information in a hull-loss accident ? ALPA agrees that deployable devices, when not used as the sole means of data capture, could provide safety and security benefits."

From Boeing:

"We consider the survivability and recoverability of the current fixed recorders to be acceptable and do not find sufficient benefit to justify the expense of implementing deployable recorders; therefore, we do not support the use of deployable recorders."

From the International Air Transport Association (IATA):

"IATA does not believe that an introduction of an additional deployable flight recorder brings any safety benefit. To the contrary, the risk of inadvertent deployment over populated areas or on an active runway needs to be considered, especially in automatic deployment conditions."

From DRS Technologies (manufacturer of deployable recorders for military aircraft):

"Deployable recorders are complementary to fixed recorders as they protect the data in a different way: leaving the crash site versus attempting to survive the crash and post-crash environment. In this scenario, redundancy is provided like seatbelts and airbags protect a passenger of an automobile in different ways, increasing their survival rate more than two seatbelts or two airbags would. The result of this combination of recorders is increased probability that flight data is recovered, thus increasing the safety of our transportation system."

On the incorporation of combination recorders

From the NTSB:

"Recommendations discussed in the NPRM, but rejected or not addressed ? are the use of forward- and aft-mounted combination voice and data recorders ? The Safety Board hoped this rulemaking effort would take full advantage of this opportunity to require implementation of dual combined voice data and image recorders in the Airbus A380 and Boeing 787 while both were in pre-production, when installation costs would be at a minimum."

"There are a number of instances in which the circumstances of a catastrophic accident could have resulted in a forward-mounted recorder surviving and the aft-mounted recorder being lost to fire or impact.

"One example is the Air France Airbus A320, which crashed in Strasburg, France, in 1992. In this accident, the aft-mounted FDR was destroyed by fire while the unprotected quick-access recorder mounted below the cockpit survived.

"The NPRM also implies that a crash resulting in the loss of an aft- mounted recorder would most certainly result in the loss of a forward-mounted recorder. Accident history does not support this position, as illustrated in those accidents in which the aft-mounted recorders were lost. The explosion of Pan Am Flight 109, a Boeing 747 over Lockerbie, Scotland, separated the cockpit, which landed relatively intact far clear of the burning fuselage wreckage."

From Northwest Airlines (NWA):

"NWA agrees with the FAA that little or no benefit would be gained from a second CVR and DFDR. In the event of a catastrophic accident that destroyed the existing recorders, the likelihood that a second CVR and DFDR located in the front of the aircraft surviving is remote at best."