Safety Board Urges Deployment Of Cockpit Image Recorders

Air Safety Week, August 2, 2004

One date already has come and passed since the National Transportation Safety Board (NTSB) urged the installation four years ago of cockpit video recorders, and another is fast approaching. At a symposium hosted by the board last week to apply pressure for action on its unrequited recommendations for video recorders, a Federal Aviation Administration (FAA) official conceded that the laborious eight-step process to put the recommendations into effect has not even begun.

To use a Vietnam War metaphor, there is no light at the end of the tunnel. In fact, the regulatory tunnel, as it were, hasn't even been entered.

Since 2000, the NTSB has called for cockpit image recorders to be installed in transport category aircraft as a necessary complement to cockpit voice and digital flight data recorders (CVR/DFDR) already required in these aircraft. Known by the acronym CIR, for cockpit imagery recorder, the NTSB wanted them to be installed in new aircraft coming off the production line as of Jan. 1, 2003, and CIR retrofits on current aircraft to commence Jan. 1, 2005. Unless done so voluntarily by manufacturers and operators, neither date has any effect without an FAA-decreed requirement.

For smaller turbine powered aircraft engaged in full or part-time carriage of passengers, the NTSB wants crash-protected CIRs installed starting in 2007 for new airplanes and retrofitted in existing airplanes starting 2010. Of an estimated 18,000 airplanes in this class, about half are engaged in purely private use. The NTSB wants CIRs installed in the other half engaged in carrying passengers. Presently, these airplanes are not required to be equipped with either a CVR or DFDR, and the NTSB recommendations basically take the course that CIR equipage is a cost-effective substitute, on the grounds that recording the imagery is better than the present situation where nothing is recorded - confounding accident investigations.

The full set of recommendations lies in bureaucratic limbo.

Carol Carmody, the NTSB member who chaired the hearing, said, "The safety board has investigated more than 100 accidents on aircraft without recorders [e.g., CVRs or DFDRs] since the 2000 recommendations were issued."

"Frequently, we are hampered [by lack of information] in our investigations, and it took longer to reach a probable cause," she added.

In the last two months, the safety board has investigated 11 accidents in which the aircraft had no recorders.

Carmody and other board members believe that for airplanes already equipped with CVRs/DFDRs, imagery recording can play a vital role, filling in gaps regarding cockpit displays and pilot actions.

Yet the FAA has not yet acted. Tony Fazio, head of the FAA's office of rulemaking, outlined an eight-step process every rule undergoes. One step includes a cost-benefit analysis and, Fazio said, "Clearly, we would have to be concerned about the costs and benefits." With more than 10,000 airplanes subsumed under the NTSB's recommendations (transport category and smaller turbine powered aircraft), and assuming installation costs anywhere from $1,000 to $10,000 per airplane, the total package could range from $10 million to $100 million.

Moreover, Fazio said it takes anywhere from three to five years to put out a new rule. Thus, even if the rulemaking process were begun today, it likely would not cover two aircraft now in development, the Boeing [BA] 7E7 and the Airbus A380.

Carmody asked, "For your eight-step process, you haven't gotten to step one yet?"

Fazio: "That's correct."

Fazio indicated that items mandated by Congress are the top priority, going to the head of the line for rulemaking as a matter of course. Thus, the "country of final assembly" rule was issued within weeks of receiving the congressional requirement (see ASW, July 12). Meanwhile, the cockpit video recorder recommendations have languished for years.

If and when the FAA does issue a proposed rule for CIRs, pilots' unions are likely to object strongly, decrying the constant video surveillance as an intrusion on their privacy and the imagery of doomed pilots' last moments as likely to find its way onto the Internet or evening newscasts - the human penchant for voyeurism and the media's penchant for sensationalism being what they are.

The pilots' likely objections could be speed bumps on the path to a video recording requirement, or they could turn out to be a major roadblock. "The cockpit image recorder is not the answer" to missing or uncertain data in accident investigations, declared Capt. John Cox, executive air safety chairman for the Air Line Pilots Association (ALPA). Manufacturers' objections may also need to be taken (Cont'd on p. 4) into account. Ron Swanda of the General Aviation Manufacturers Association (GAMA) said flatly, "Under no circumstances do we see a CIR substituting for a CVR or DFDR."

March of technology

The argument over cockpit imagery recorders is playing out against an advancing technology. The cameras and the recording technology are increasing in capability while shrinking in terms of size and weight, while at the same time reducing in cost.