Conflicting Flight Data Recorder Standards May Confuse Operators

June 8, 2011

A series of standards and recommended practices from the International Civil Aviation Organization (ICAO), regarding flight data recorder (FDR) equipage has led to confusion among some operators about what equipment is required, and where.

At the heart of this issue lies ICAO Annex 6, Parts 1 and 2. Part 1 applies to commercial aircraft; Part 2 is for non-commercial operations. The basic standards for both Parts are essentially similar, calling for:

• Type I flight data recorders to be installed in all aircraft first issued individual certificates of airworthiness on or after January 1, 1989, with maximum certificated takeoff weights (MCTW) over 27,000 kg (59,525 lbs)
• Type IA FDRs be installed in all aircraft issued certificates of airworthiness after January 1, 2005, with maximum certificated takeoff weights exceeding 5,700 kg (12,566 lbs).

Part 2 also contains a recommendation calling for aircraft between 5,700 kg and 27,000 kg MCTW to have Type II flight data recorders installed, if certified on or after January 1, 1989.

Operators of aircraft based in the United States face additional challenges, as Federal Aviation Administration (FAA) requirements differ substantially from the ICAO standards. Where ICAO standards are based on the aircraft’s weight, FAA requirements are dependent on the number of seats available for passengers. In general, if your multi-engine, turbine-powered aircraft was manufactured after October 11, 1991 and is equipped with 10 or more passenger seats, you will need an FDR.

If you’re confused by now…well, you’re not alone, and there’s still another factor to consider: cost. Neither the ICAO nor FAA standards address this fundamental factor for most operators. While installations are specific to the aircraft type and condition, industry estimates place the likely cost of retrofitting a midsize business aircraft with a flight data recorder at over $80,000.

So, where does that leave the operator who wishes to fly a U.S.-based Cessna Citation Sovereign, without a flight data recorder, to England, France, or Spain? At this time, there really is no clear answer to that question, apart from consulting the aviation authority in your destination country for specific guidance.

“NBAA always recommends that operators follow all applicable ICAO standards when conducting international flights; however in certain cases that may be difficult or cost prohibitive,” says Scott O’Brien, project manager for NBAA’s Operations Service Group. “In these situations, working with an international service provider or the applicable civil aviation authority to determine country-specific requirements is recommended.”

At least one country has adopted a more pragmatic approach to the matter. The Bermuda Department of Civil Aviation recognizes ICAO standards under most circumstances, but also realizes strict adherence to the Annex 6 guidelines could scare off US and Canadian operators from flying to the island nation.

“This dilemma has been considered…and it has been agreed as satisfactory that the CFR and CAR requirements be accepted as an alternate means of compliance with the Annex Standard when requesting flight permits to Bermuda,” the DCA notes in its ruling.

For additional information contact the NBAA Operations Service Group at (202) 783-9451 or info@nbaa.org.