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Information gathering regarding flight recorders

ANAC is developing studies to assess the feasibility of changing flight recorders rules for general aviation aircraft (RBAC 91).

The objective of this research is mainly to collect information on related costs, but other aspects that contribute to maintaining the safety level are also considered.

The questionnaire can be filled out without identification and does not require an access key (single response). All information registered will be used only for statistical purposes as a complement to the regulatory impact analysis to support decision-making.

The questions were customized according to the target audience (owner or operator, pilot, maintenance organizations, aircraft manufacturers, associations and class bodies and others). Select all the categories you are interested in answering to display the questions pertaining to the group.

Only questions marked with * are required, but all contributions are welcome.

If you miss any aspect not covered in the questionnaire, there is a free field at the end that even allows you to upload files.

If the decision is made by changing the rule, a public consultation is planned for the proposal at a later time.

Identification (optional) and qualification

If you want, please fill out the identification data below. Your identification is optional, but will allow ANAC to contact you for clarifying any answer or request further information.

(This question is mandatory)
Which groups better define your professional area?
Which aircraft models do you operate?
Please refer to the formal Manufacturer / Model designation. E.g., refer to Piper PA-34-220T rather than "Seneca".
Questions for aircraft operators and pilots
Do the aircraft operated or piloted by you have any installed flight data recorder (FDR)? If yes, please inform the recorder manufacturer, model and other information present in the recorder identification plate or label.
Do you know if there is an approved configuration for installation of a flight data recorder in the aircraft you operate? If yes and if you know the costs, please inform it in the comments field below.

Do the aircraft operated or piloted by you have any installed cockpit voice recorder (CVR)? If yes, please inform the recorder manufacturer, model and other information present in the recorder identification plate or label.
 

Do you know if there is an approved configuration for installation of a cockpit voice recorder in the aircraft you operate? If yes and if you know the costs, please inform it in the comments field below.

In order to ANAC evaluate the impact related to any changes in recorder rules, it is important to know the average operational cost and the condition in which the aircraft is placed in terms of year of manufacture and passenger capacity. Which is the average utilization and average operating costs of the aircraft operated by you? Please inform also the year of manufacture and passenger capacity.

Important: Submitted information will be used solely for statistical purposes regarding the operational cost per type and size of aircraft. No cost information linking these data to your name or to your organization will be made public.

Notes:

1) Consider as fixed costs those related to maintenance, hangar, insurance, fees, etc. As variable costs, the cost of fuel, crew hiring if it is not a fixed cost, and other relevant expenses for the operation of the aircraft must be considered.

2) The average operational cost might have been affected by the COVID-19 pandemics. In case your average cost has been significantly affected by the effects of the pandemics, please adjust the values to a non-pandemic scenario.

3) In case you operated multiple aircraft of the same model, please inform the newest year of manufacture and the largest seating capacity for that model.

4) For costs in a foreign currency, please convert to BRL using as exchange rate 5.00 BRL/USD.
Lightweight image and voice recorders

As a result of image recording technology advancements, with cameras and memory devices more and more compact, new lightweight recorders were made available in the market, allowing the recording of audio and video in the flight deck, monitoring instrument panels and commands.

Such lightweight recorders have good impact resistance in low and medium-energy accidents, as well as cost and weight much lower than conventional voice and data recorders, which are designed to withstand much more severe impacts.

Considering the expected gains in the accident investigation in aircraft which currently do not need to be equipped with either data or voice recorders, ANAC is considering the possibility of including new requirements for such lightweight recorders. The questions below aim at assessing the regulatory impact associated to such possible new requirements, including privacy issues.

Do you pilot or have you ever piloted aircraft having an installed cockpit voice recorder (CVR) or flight data recorder (FDR)? Was there any situation in which recorded data have been used (e.g. incident or accident investigation, FOQA, FDAP etc.)? If any data has been used, please detail in the comments field.

FOQA - Flight Operations Quality Assurance

FDAP - Flight Data Analysis Program

Which is your perception regarding the utilization of recorded flight data or voice? Please comment below.
Please leave your comments regarding crew privacy on recorded data.

The European Union Aviation Safety Agency (EASA) introduced rules for lightweight recorders for certain operations, including the following requirement: "If the flight recorder records images or audio of the flight crew compartment, then a function shall be provided which can be operated by the commander and which modifies image and audio recordings made before the operation of that function, so that those recordings cannot be retrieved using normal replay or copying techniques." (CAT.IDE.A.191(e))

Associated guidance material explains that "the purpose of the function modifying the image and audio recordings is to allow the flight crew to protect their privacy by making such recordings inaccessible using normal techniques. The activation of this function is subject to the commander’s approval (refer to CAT.GEN.MPA.105). However, the equipment manufacturer or a safety investigation authority might still be able to retrieve these recordings using special techniques." (GM1 CAT.IDE.A.191(e))

Which is your opinion about this requirement? Please feel free to comment.

The regulations referred above are listed in the COMMISSION REGULATION (EU) No 965/2012, in items CAT.IDE.A.191(e), CAT.IDE.H.191(e), SPO.IDE.A.146(e) e SPO.IDE.H.146(e). This regulation and associated Guidance Material may be accessed in the following link: https://www.easa.europa.eu/document-library/easy-access-rules/easy-access-rules-air-operations.

In the question, the regulation from Commercial Air Transport (CAT) using airplanes was cited. Similar requirements exist for the other points above.

Recorder installation costs

In order to ANAC assess the impact of rule changes, it is important to know the costs linked to the installation of recorders. The question below aims at estimating such costs.

It is known that the design change costs are deeply dependent on the aircraft model, its PRE-MOD configuration, the sensors to be installed and the required recorders. Therefore, we expect answers containing cost estimates, or actual previous cases.

Which is the cost estimate associated to the design, design approval, equipment acquisition and installation of recorders? Please fill out only information you have.

Please use values in Brazilian Reais (BRL). In case of costs in a foreign currency, convert to BRL using a rate of 5.00 BRL/USD.

Traditional Cockpit voice recorder (CVR); equipment, components, materials, design and design approval costs
Traditional Cockpit voice recorder (CVR); installation cost in an approved maintenance organization
Traditional Flight Data Recorder (FDR); equipment, components, materials, design and design approval costs (without additional sensors)
Traditional Flight Data Recorder (FDR); installation cost in an approved maintenance organization (without additional sensors)
Additional required sensor when information source is not available; average cost per sensor; materials, design, design approval and installation in an approved maintenance organization
Lightweight Image and Voice recorder; equipment, components, materials, design and design approval costs
Lightweight Image and Voice recorder; installation cost in an approved maintenance organization
Additional questions to manufacturers
Amongst the models produced by your organization, which ones have data or voice recorders factory-installed or as field installation option? Please list in the specific comment field which models swicht in each group.

Do you know if any Civil Aviation Authority (CAA) has ever required the installation of a recorder, or the system change for recording additional parameters for any aircraft model produced by your organization? Please detail in the comments field, specifying the aircraft model, the CAA country and its requirement.

Has any aircraft model produced by your organization ever received an exemption from a Civil Aviation Authority (CAA) related to cockpit voice recorders (CVR) or flight data recorder (FDR)? Please detail in the comments field.
Additonal question to maintenance organizations
Does your maintenance organization has experience related to the installation of flight data recorders (FDR) or cockpit voice recorder (CVR), or the modification of existing FDR or CVR systems? Please detail in the comments field the particularities and difficulties in this kind of installation.
Free comments regarding this subject
Please feel free to provide us with any comments regarding the subject of this information gathering, such as existing regulatory problems, difficulties, costs, improvement opportunities, action proposals, etc.
You may upload any file below to complement any of your previous answers or to illustrate your position in this information gathering. Only PDF filed may be uploaded.
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