Notice of Proposed Amendment 2017-03

4. Impact assessment (IA) ....................................................................................................................... 43 4.1. What is the issue .....................................................................................................................................44 4.1.1. Definition of the issue ......................................................................................................................44 4.1.2. Safety risk assessment .....................................................................................................................50 4.1.3. Who is affected ................................................................................................................................61 4.1.4. How could the issue/problem evolve ..............................................................................................62 4.2. What we want to achieve — objectives..................................................................................................63 4.3. How it could be achieved — options ......................................................................................................64 4.3.1. Requiring, facilitating or promoting ................................................................................................64 4.3.2. The options ......................................................................................................................................65 4.4. Methodology and data ............................................................................................................................69 4.4.1. Methodology applied.......................................................................................................................69 4.4.2. Data collection .................................................................................................................................70 4.5. What are the impacts ..............................................................................................................................70 4.5.1. Safety impact ...................................................................................................................................70 4.5.2. Environmental impact .....................................................................................................................75 4.5.3. Social impact ....................................................................................................................................76 4.5.4. Economic impact..............................................................................................................................78 4.5.5. General aviation and proportionality issues....................................................................................87 4.5.6. Impact on better regulation and harmonisation .............................................................................89 4.6. Conclusion ...............................................................................................................................................93 4.6.1. Comparison of options ....................................................................................................................93 4.7. Monitoring and evaluation......................................................................................................................99 4.7.1. Monitoring implementation ............................................................................................................99 4.7.2. Evaluating the effectiveness of options (after implementation) ....................................................99 European Aviation Safety Agency NPA 2017-03 Table of contents TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 3 of 178 An agency of the European Union 5. Proposed actions to support implementation.................................................................................... 101 6. References ....................................................................................................................................... 102 6.1. Affected regulation ...............................................................................................................................102 6.2. Affected decisions .................................................................................................................................102 6.3. Other reference documents ..................................................................................................................102 7. Appendices ...................................................................................................................................... 103 7.1. Appendix A: Comparison of European Air Operations rules and provisions of ICAO Annex 6 .............103 7.2. Appendix B: Statistics of accidents and serious incidents.....................................................................113 7.3. Appendix C: Safety recommendations related to in-flight recording for light aircraft .........................116 7.4. Appendix D: Promoting the benefits of in-flight recording for light aircraft ........................................126 7.4.1. Potential benefits of in-flight recording for stakeholders .............................................................126 7.4.2. The privacy issue ............................................................................................................................130 7.5. Appendix E: Systematic studies of investigation reports ......................................................................133 7.5.1. General principles applied for conducting the studies ..................................................................133 7.5.2. Study 1 ...........................................................................................................................................134 7.5.3. Study 2 ...........................................................................................................................................138 7.5.4. Study 3 ...........................................................................................................................................142 7.5.5. Study 4 ...........................................................................................................................................144 7.6. Appendix F: Alternatives to dedicated in-flight recording equipment .................................................147 7.6.1. Identified alternative solutions......................................................................................................147 7.6.2. Assessment of the alternative solutions........................................................................................148 7.6.3. Recommendations for alternative solutions .................................................................................149 7.7. Appendix G: Results of the survey on cost and benefits of dedicated in-flight recording....................162 7.8. Appendix H: General principles of the safety risk assessment .............................................................171 7.8.1. Common methodology used for the safety risk assessment ........................................................171 7.9. Appendix I: Requirements related to indications of instruments on board aeroplanes and helicopters 175 7.9.1. Aeroplanes .....................................................................................................................................175 7.9.2. Helicopters .....................................................................................................................................177 7.10. Appendix J: Examples of in-flight recording systems ............................................................................178 European Aviation Safety Agency NPA 2017-03 1. About this NPA TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 4 of 178 An agency of the European Union 1. About this NPA 1.1. How this NPA was developed EASA developed this NPA in line with Regulation (EC) No 216/20081 (the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is included in the EASA Rulemaking and Safety Promotion Programme for 2017-20213 under RMT.0271 (former task number MDM.073(a) & (b)). The text of this NPA has been developed by EASA based on the input of the Rulemaking Group RMT.0271 & RMT.0272. It is hereby submitted to all interested parties4 for consultation. 1.2. How to comment on this NPA Please submit your comments using the automated Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/5. The deadline for submission of comments is 3 July 2017. 1.3. The next steps Following the closing of the public commenting period, EASA will review all comments and decide on the need to set up a review group to assist EASA in providing answers to the comments. Based on the comments received, EASA will develop an opinion containing the proposed amendments to Regulation (EU) No 965/20126 on Air Operations. The opinion will be submitted to the European Commission, which will use it as a technical basis in order to prepare an EU regulation. Following the adoption of the regulation, EASA will issue a decision containing the related acceptable means of compliance (AMC)/guidance material (GM). The comments received, and the EASA responses thereto, will be reflected in a comment-response document (CRD). The CRD will be annexed to the opinion. 1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal- content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216). 2 EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management- board/decisions/easa-mb-decision-18-2015-rulemaking-procedure). 3 https://www.easa.europa.eu/document-library/rulemaking-programmes/rulemaking-and-safety-promotion-programme-2017-2021 4 In accordance with Article 52 of Regulation (EC) No 216/2008, and Articles 6(3) and 7) of the Rulemaking Procedure. 5 In case of technical problems, please contact the CRT webmaster (crt@easa.europa.eu). 6 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0965&rid=1). European Aviation Safety Agency NPA 2017-03 2. In summary — why and what TE.RPRO.00034-005 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 5 of 178 An agency of the European Union 2. In summary — why and what 2.1. Why we need to change the rules — issue/rationale Since 2010, accidents and serious incidents that occur over the territory of an EASA Member State (MS) must be subject to safety investigation. However, almost all categories of light aircraft fall outside the scope of current requirements to carry flight recorders. In the absence of data on the aircraft condition and operation, it can be very difficult to reconstruct the sequence of events that led to an accident or a serious incident; knowing the sequence of events though is essential for defining actions in order to prevent future occurrences. This is why recent Standards in ICAO Annex 6 prescribe, for some categories of light aeroplanes and helicopters operated for commercial air transport (CAT), the carriage of in-flight recording equipment. In addition, 12 safety recommendations related to in-flight recording for light aeroplanes and helicopters were addressed to EASA by several safety investigation authorities. Finally, CAT statistics indicate a significantly higher rate of accidents with balloons compared to aeroplanes and helicopters, which raises the question of the need for in-flight recording on-board balloons with a large passenger capacity. Several studies of safety investigation reports were performed in order to assess the expected benefit of in-flight recording for preventing accidents through facilitation of safety investigations. The conclusion of these studies is that in-flight recording brings moderate benefit, so that requirements applying to all kinds of light aircraft would not be proportionate. Hence, rulemaking should be focused on those light aircraft used for commercial operations and capable of transporting several passengers. Besides rulemaking, the potential safety benefit of facilitating and promoting voluntary installation of in-flight recording equipment was also identified. Note: See Chapter 4, Section 4.1, for detailed explanations. 2.2. What we want to achieve — objectives The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation. This proposal will contribute to the achievement of the overall objectives by addressing the issues outlined in Section 2.1 above and in Chapter 4, Section 4.1. The specific objectives of this proposal are to: — enhance the identification and prevention of safety issues affecting light aircraft by means of data recorded in flight; — achieve harmonisation with ICAO Standards in Annex 6, Parts I, II and III; — produce a proportionate regulation which takes into account the General Aviation Roadmap; and — identify avenues other than requirements for in-flight recording equipment. European Aviation Safety Agency NPA 2017-03 2. In summary — why and what TE.RPRO.00034-005 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 6 of 178 An agency of the European Union 2.3. How we want to achieve it — overview of the proposals 2.3.1. Changes to the Air Operations requirements Note: The proposed changes to the implementing rules, AMC and GM are presented in detail in Chapter 3. 2.3.1.1. New concepts and definitions The concept of ‘flight recorder’ is extended to in-flight recording equipment for light aircraft, which requires limited crash protection. This makes the introduction of definitions for ‘flight recorder’, ‘flight data recorder’ (FDR) and ‘cockpit voice recorder’ (CVR) necessary in Annex I to the Air Operations Regulation. The new concept of flight recorders now encompasses ‘crash-protected’ flight recorders and ‘lightweight’ flight recorders. A crash-protected flight recorder is capable of withstanding very severe crash conditions such as those encountered during some accidents of large aeroplanes and large helicopters (FDRs and CVRs are crash-protected flight recorders). A lightweight flight recorder is designed to meet less demanding crash-protection requirements, and therefore it can be lighter. 2.3.1.2. New recording requirements for commercial operations with light aeroplanes and light helicopters New rules are created in Annex IV (Part-CAT) and in Annex VIII (Part-SPO) to Regulation (EU) No 965/2012. These rules require that aeroplanes and helicopters which: — are commercially operated; — are manufactured on or after [date of application of the amending regulation + 3 years]; — are not specified by the current Part-CAT and Part-SPO requirements on carrying flight data recorders; and — have an MOPSC of more than 9 (for aeroplanes) or are turbine-engined with an MCTOM of 2 250 kg or more (for aeroplanes and helicopters), be equipped with a flight recorder which records flight data and/or images that are sufficient to determine the flight path and the aircraft speed (ground speed or indicated airspeed). The flight recorder shall have a minimum recording duration of 10 hours and an automatic start-and-stop logic. AMC are created in order to provide the operational performance objectives for the new flight recorder carriage requirements. The AMC specify the flight parameters to be recorded and the operational performance target for these flight parameters. The AMC also specify the information to be captured if recording images is preferred to recording flight parameters. Furthermore, the AMC also recommend that the operational performance of the flight recorder meet the specifications laid down in industry standards (EUROCAE Document 155 or EUROCAE 112 or equivalent standards recognised by EASA). 2.3.1.3. Continued serviceability of the flight recorder Paragraph (b) of CAT.GEN.MPA.195 and related AMC and GM are amended in order to address the serviceability aspects when a flight recorder is installed on a light aeroplane or a light helicopter. In summary, three kinds of checks are expected to be performed on flight recorders: European Aviation Safety Agency NPA 2017-03 2. In summary — why and what TE.RPRO.00034-005 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 7 of 178 An agency of the European Union — inspection of the recording to check the quality and completeness of the recorded data (already applicable to crash-protected flight recorders and required for lightweight flight recorders); — daily use of the means for preflight check of the flight recorders for proper operation (already applicable to crash-protected flight recorders and required for lightweight flight recorders); — calibration check of some flight parameters (only applicable to FDRs). Paragraphs (c) and (d) of CAT.GEN.MPA.195 are amended to take into account the new flight recorder carriage requirements. The same amendments are made to SPO.GEN.145 and to related AMC. 2.3.1.4. Protection of image recordings Paragraph (f) of CAT.GEN.MPA.195 is amended in order to address the protection of image recordings: — reference is added to Regulation (EU) 2016/679 on General Data Protection7; — images of the flight crew compartment recorded by a flight recorder may only be used for the following purposes:  as stipulated in Regulation (EU) No 996/2010;  to maintain or improve safety (in which case a procedure related to the handling of images and the consent of all crew members is required); or  to ensure flight recorder serviceability (in which case protecting the privacy of images is required and no other use is allowed except serviceability). AMC are created to address the use of flight crew compartment images recorded by a flight recorder. These AMC follow the same principles as the already adopted AMC, which address the use of CVR recordings. 2.3.2. Promotion of in-flight recording The retained options include promoting the benefit of in-flight recording, in particular: — the recording of flight parameters, images and audio in the flight crew compartment for aeroplanes and helicopters; and — the recording of trajectory parameters, as well as images of the basket interior for balloons. While it is not within the scope of this NPA to produce material for such promotion activities, Appendix D presents the potential benefits which could be promoted to industry and identifies factors that may limit the effectiveness of any future promotion activity. 7 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&qid=1487864197230&from=EN). European Aviation Safety Agency NPA 2017-03 2. In summary — why and what TE.RPRO.00034-005 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 8 of 178 An agency of the European Union 2.4. What are the expected benefits and drawbacks of the proposals 2.4.1. Summary of the impact assessment (refer to Chapter 4) With regard to aeroplanes and helicopters, the following options were considered: — Option A.1: Promote the recording of basic flight parameters, audio and/or a view of the instruments panel for all models of light aeroplanes and light helicopters and for all types of operation (no change to the rules). — Option A.2: Strictly transpose ICAO Standards in Annex 6 for newly manufactured light turbine- engined aeroplanes and newly manufactured light turbine-engined helicopters operated for CAT. — Option A.3: Transpose ICAO Standards in Annex 6 with some differences:  include aeroplanes which have an MOPSC of more than 9;  include commercial specialised operations (SPO) in addition to CAT; and  do not require the recording of audio. — Option A.4: Implement Options A.1 and A.3 together. With regard to balloons, the following options were considered: — Option B.1: Promote fitting balloons with means to record trajectory parameters and images from the basket interior (no change to the rules). — Option B.2: Require newly manufactured balloons used in commercial operations and with an MCTOM of 3 000 kg or more to be fitted with equipment recording the balloon’s trajectory parameters and images from the basket interior. — Option B.3: Implement Options B.1 and B.2 together. Considering proportionality and cost, it was not found appropriate to develop options for sailplanes. Regarding aeroplanes and helicopters, Option A.4 is the preferred one because it combines safety promotion (Option A.1) and rulemaking (Option A.3). Option A.4 has a significant positive safety impact while limiting the economic impact and impact on general aviation, and it is proportionate. Regarding balloons, the rulemaking options (Option B.2 and B.3) have a negative impact on general aviation and proportionality issues, which outweighs the safety benefit. Hence, despite its just slightly positive safety impact, Option B.1 (safety promotion) is the preferred one. Note: Significant increases, compared to current levels, in the MCTOM and/or passenger capacity of balloons that are commercially operated have the potential to cause a number of fatalities in the aircraft and on the ground comparable to that of large aircraft. Therefore, the trade-off between safety benefit and impact on economic and proportionality issues would need to be assessed again. 2.4.2. Proposal retained for aeroplanes and helicopters The proposal combines: — a requirement to record a small set of flight parameters for certain categories of aeroplanes and helicopters; and — promotion of in-flight recording for all other light aeroplanes and helicopters. European Aviation Safety Agency NPA 2017-03 2. In summary — why and what TE.RPRO.00034-005 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 9 of 178 An agency of the European Union This proposal is expected to have a medium positive to very positive impact on safety (by supporting official safety investigations and operational safety monitoring), a slightly positive impact on rules harmonisation (better alignment with ICAO Annex 6), limited social impact (if a framework is adopted for the protection of images of the flight crew compartment), moderate economic impact (requirement limited to CAT and commercial SPO and to newly manufactured aircraft), and no impact on proportionality issues (requirement limited to turbine-engined aircraft with an MCTOM of 2 250 kg or more and aeroplanes with an MOPSC of more than 9). 2.4.3. Proposal retained for balloons The proposal is to promote fitting balloons with means to record trajectory parameters and images from the basket interior (no change to the rules). No rule change is proposed for balloons. This proposal is expected to have a slightly positive safety impact and no other type of impact. Note: For the full impact assessment, please refer to Chapter 4. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 10 of 178 An agency of the European Union 3. Proposed amendments and rationale in detail The text of the amendment is arranged to show deleted text, new or amended text as shown below: — deleted text is struck through; — new or amended text is highlighted in grey; — an ellipsis ‘[…]’ indicates that the rest of the text is unchanged. 3.1. Draft Regulation (Draft EASA opinion) 3.1.1. Draft resulting text 3.1.1.1. Annex I (Definitions) ANNEX I Definitions for terms used in Annexes II to VIII (23) ‘cockpit voice recorder (CVR)’ means a crash-protected flight recorder using a combination of microphones and other audio and digital inputs to collect and record the aural environment of the flight crew compartment and communications to, from and between the flight crew members; (50) ‘Flight data recorder (FDR)’ means a crash-protected flight recorder using a combination of data providers to collect and record parameters that reflect the state and performance of the aircraft; (50a) ‘flight recorder’ means any type of recorder installed on the aircraft for the purpose of facilitating accident/incident safety investigations. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 11 of 178 An agency of the European Union 3.1.1.2. Annex IV (Part-CAT) ANNEX IV COMMERCIAL AIR TRANSPORT OPERATIONS [PART-CAT] SUBPART A GENERAL REQUIREMENTS SECTION 1 Motor-powered aircraft CAT.GEN.MPA.195 Handling of flight recorder recordings: preservation, production, protection and use [...] (b) The operator shall conduct operational checks and evaluations of the flight recorders flight data recorder (FDR) recordings, cockpit voice recorder (CVR) recordings and data link recordings to ensure the their continued serviceability of the recorders. (c) The operator shall save the recordings for the period of operating time of the FDR as required by CAT.IDE.A.190 or, CAT.IDE.A.191, CAT.IDE.H.190 or CAT.IDE.H.191 (as applicable), except that, for the purpose of testing and maintaining the FDR, up to one hour of the oldest recorded material at the time of testing may be erased. (d) When flight parameters are recorded by a flight recorder, Tthe operator shall keep and maintain up-to- date documentation that presents the necessary information to convert FDR raw data into parameters expressed in engineering units. [...] (f) Without prejudice to Regulations (EU) No 996/20108 and (EU) 2016/6799 of the European Parliament and of the Council: [...] 8 Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L 295, 12.11.2010, p. 35). 9 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1). European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 12 of 178 An agency of the European Union (2) FDR recordings or data link recordings Flight parameters or data-link messages recorded by a flight recorder shall only be used for purposes other than for the investigation of an accident or an incident which is subject to mandatory reporting, if such records are: (i) used by the operator for airworthiness or maintenance purposes only; or (ii) de-identified; or (iii) disclosed under secure procedures. (3) Images of the flight crew compartment recorded by a flight recorder shall not be disclosed or used except for ensuring the flight recorder serviceability, or if: (i) a procedure related to the handling of images is in place; (ii) all crew members and maintenance personnel concerned have given their prior consent; and (iii) these images are used only for maintaining or improving safety. (3a) When images of the flight crew compartment recorded by a flight recorder are inspected for ensuring the serviceability of the flight recorder, then: (i) these images shall not be disclosed or used for purposes other than for ensuring the flight recorder serviceability; and (ii) if body parts of crew members are likely to be visible on the images, the operator shall ensure the privacy of these images. SUBPART D INSTRUMENTS, DATA, EQUIPMENT SECTION 1 Aeroplanes CAT.IDE.A.191 Recording of flight parameters on light aeroplanes (a) Turbine-engined aeroplanes with an MCTOM of 2 250 kg or more and aeroplanes with an MOPSC of more than 9 shall be equipped with a flight recorder if: (1) they are not specified in CAT.IDE.A.190, and (2) they are first issued with an individual CofA on or after [date of application of the amending regulation + 3 years]. (b) The flight recorder referred to in (a) shall record flight data and/or images sufficient to determine the flight path and aircraft speed. (c) The flight recorder referred to in (a) shall be capable of retaining the flight data or images during at least the preceding 10 hours. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 13 of 178 An agency of the European Union (d) The flight recorder referred to in (a) shall start automatically to record the data prior to the aeroplane being capable of moving under its own power and shall stop automatically after the aeroplane is incapable of moving under its own power. (e) If the flight recorder referred to in (a) records images of the flight crew compartment, then an erasure function shall be provided which can be operated by the commander and which modifies the recording of these images made before the operation of this function, so that they cannot be retrieved using normal replay or copying techniques. SECTION 2 Helicopters CAT.IDE.H.191 Recording of flight parameters on light helicopters (a) Turbine-engined helicopters with an MCTOM of 2 250 kg or more shall be equipped with a flight recorder if: (1) they are not specified in CAT.IDE.H.190; and (2) they are first issued with an individual CofA on or after [date of publication of the Regulation + 3 years]. (b) The flight recorder referred to in (a) shall record flight data and/or images sufficient to determine the flight path and aircraft speed. (c) The flight recorder referred to in (a) shall be capable of retaining the flight data or images during at least the preceding 10 hours. (d) The flight recorder referred to in (a) shall start automatically to record the data prior to the helicopter being capable of moving under its own power and shall stop automatically after the helicopter is incapable of moving under its own power. (e) If the flight recorder referred to in (a) records images of the flight crew compartment, then an erasure function shall be provided which can be operated by the commander and which modifies the recording of these images made before the operation of this function, so that they cannot be retrieved using normal replay or copying techniques. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 14 of 178 An agency of the European Union 3.1.1.3. Annex VIII (Part-SPO) ANNEX VIII SPECIALISED OPERATIONS [Part-SPO] SUBPART A GENERAL REQUIREMENTS SPO.GEN.145 Handling of flight recorder recordings: preservation, production, protection and use — operations with complex motor-powered aircraft [...] (b) The operator shall conduct operational checks and evaluations of the flight recorders flight data recorder (FDR) recordings, cockpit voice recorder (CVR) recordings and data link recordings to ensure the their continued serviceability of the recorders. (c) The operator shall save the recordings for the period of operating time of the FDR as required by SPO.IDE.A.145 or, SPO.IDE.A.146, SPO.IDE.H.145 or SPO.IDE.H.146 (as applicable), except that, for the purpose of testing and maintaining the FDR, up to 1 hour of the oldest recorded material at the time of testing may be erased. (d) When flight parameters are recorded by a flight recorder,Tthe operator shall keep and maintain up-to- date documentation that presents the necessary information to convert FDR raw data into parameters expressed in engineering units. [...] (f) Without prejudice to Regulations (EU) No 996/2010 and (EU) 2016/679, and except for ensuring the CVR serviceability, (1) CVR recordings shall not be disclosed or used unless: [...] (g2) FDR recordings or data link recordingsFlight parameters or data-link messages recorded by a flight recorder shall only be used for purposes other than for the investigation of an accident or an incident that is subject to mandatory reporting if such records are: (1i) used by the operator for airworthiness or maintenance purposes only; (2ii) de-identified; or (3iii) disclosed under secure procedures. (3) Images of the flight crew compartment recorded by a flight recorder shall not be disclosed or used except for ensuring the flight recorder serviceability, or if: (i) a procedure related to the handling of images is in place; European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 15 of 178 An agency of the European Union (ii) all crew members and maintenance personnel concerned have given their prior consent; and (iii) these images are used only for maintaining or improving safety. (3a) When images of the flight crew compartment recorded by a flight recorder are inspected for ensuring the serviceability of the flight recorder, then: (i) these images shall not be disclosed or used for purposes other than ensuring the flight recorder serviceability; and (ii) if body parts of crew members are likely to be visible on the images, the operator shall ensure the privacy of these images. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 16 of 178 An agency of the European Union SUBPART D INSTRUMENTS, DATA, EQUIPMENT SECTION 1 Aeroplanes SPO.IDE.A.146 Recording of flight parameters on light aeroplanes (a) Turbine-engined aeroplanes with an MCTOM of 2 250 kg or more and aeroplanes with an MOPSC of more than 9 shall be equipped with a flight recorder if: (1) they are not specified in SPO.IDE.A.145; (2) they are commercially operated; and (2) they are first issued with an individual CofA on or after [date of publication of the Regulation + 3 years]. (b) The flight recorder referred to in (a) shall record flight data and/or images sufficient to determine the flight path and aircraft speed. (c) The flight recorder referred to in (a) shall be capable of retaining the flight data or images during at least the preceding 10 hours. (d) The flight recorder referred to in (a) shall start automatically to record the data prior to the aeroplane being capable of moving under its own power and shall stop automatically after the aeroplane is incapable of moving under its own power. (e) If the flight recorder referred to in (a) records images of the flight crew compartment, then an erasure function shall be provided which can be operated by the pilot-in-command and which modifies the recordings of images in the flight recorder made before the operation of this function, so that they cannot be retrieved using normal replay or copying techniques. SECTION 2 Helicopters SPO.IDE.H.146 Recording of flight parameters on light helicopters (a) Turbine-engined helicopters with an MCTOM of 2 250 kg or more shall be equipped with a flight recorder if: (1) they are not specified in SPO.IDE.H.145; (2) they are commercially operated; and (3) they are first issued with an individual CofA on or after [date of publication of the Regulation + 3 years]. (b) The flight recorder referred to in (a) shall record flight data and/or images sufficient to determine the flight path and aircraft speed. (c) The flight recorder referred to in (a) shall be capable of retaining the flight data or images during at least the preceding 10 hours. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 17 of 178 An agency of the European Union (d) The flight recorder referred to in (a) shall start automatically to record the data prior to the helicopter being capable of moving under its own power and shall stop automatically after the helicopter is incapable of moving under its own power. (e) If the flight recorder referred to in (a) records images of the flight crew compartment, then an erasure function shall be provided which can be operated by the pilot-in-command and which modifies the recordings of images made before the operation of this function, so that they cannot be retrieved using normal replay or copying techniques. 3.1.2. Rationale 3.1.2.1. Annex I (Definitions) While there was no definition of the term ‘flight recorder’, it was used in the Air Operations rules to designate crash-protected flight recorders required to be carried on-board large aircraft, such as the flight data recorder or the cockpit voice recorder. Crash-protected flight recorders are capable of withstanding very severe crash conditions and they can record a wealth of data from multiple sensors and sources. However, in the recent amendments to ICAO Annex 6, the term ‘flight recorder’ encompasses lightweight equipment as well, which meets less demanding crash-protection requirements and records only a smaller set of data. Hence, a definition of ‘flight recorder’ is introduced for clarification in Annex I to Regulation (EU) No 965/2012. This definition complies with the concept used in ICAO Annex 6. It is also consistent with the definition of a flight recorder in Regulation (EU) No 996/201010. As a consequence, the provisions applicable to the preservation of the recordings after an accident or a serious incident become de facto applicable to the recordings of lightweight flight recorders as well (please refer to AMC2 ORO.MLR.100(q), AMC3 ORO.MLR.100(g), AMC4 ORO.MLR.100(a)(A)(11), CAT.GEN.MPA.105(a)(10), CAT.GEN.MPA.195(a), SPO.GEN.107(a)(9), and SPO.GEN.145(a)). In addition, definitions of ‘flight data recorder’ and ‘cockpit voice recorder’ are introduced in order to provide a clear understanding of these types of flight recorders and avoid confusion with lightweight flight recorders. 3.1.2.2. Annex IV (Part-CAT) and Annex VIII (Part-SPO) 3.1.2.2.1 New recording requirements for commercial operations with light aeroplanes and light helicopters A new rule CAT.IDE.A.191 is created in Annex IV (Part-CAT) to Commission Regulation (EU) No 965/2012, Subpart D (Instruments, data, equipment), Section 1 (Aeroplanes), which is entitled ‘Flight parameters recording on light aeroplanes’. — In this new rule, it is required that aeroplanes which:  are manufactured on or after [date of application of the amending regulation + 3 years]; 10 Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L 295, 12.11.2010, p. 35). European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 18 of 178 An agency of the European Union  are of a model not specified in CAT.IDE.A.190 (which covers aeroplanes with an MCTOM of over 5 700 kg and multi-engined turbine-powered aeroplanes with an MOPSC of more than 9); and  have an MOPSC of more than 9 or are turbine-engined with an MCTOM of 2 250 kg or more, shall be equipped with a flight recorder. This flight recorder may be crash-protected or lightweight (while CAT.IDE.A.190 requires the carriage of a flight data recorder which per definition is crash- protected). — It is also required that the flight recorder record flight data or images sufficient to determine the flight path and aircraft speed. Indeed, the lightweight flight recorder models available on the market record, as a minimum, images of the aircraft instruments, or 3D-position and acceleration data provided by dedicated GNSS receiver and accelerometric sensors: in both cases, the recorded information is sufficient to determine the flight path and aircraft speed. — A minimum recording duration of 10 hours is required in order to ensure that the flight recorder is capable of recording a complete flight on the aeroplane models that are within the scope of CAT.IDE.A.191. — In order to prevent the use of unreliable technologies and facilitate the processing of recorded data in case of an accident investigation, the flight recorder is required to use a digital method of recording and storing the data, such as the one used in all modern models of lightweight flight recorders. This requirement forbids, for example, the use of photographic film to record images. — The flight recorder is required to have an automatic start-and-stop logic in order to ensure recording as soon as the aeroplane is capable of moving under its own power. In practice, it is sufficient for the flight recorder to be capable of detecting when the aircraft engine delivers power. — If the flight recorder records images of the flight crew compartment, then:  an erasure function shall be provided, which can be operated by the commander, in order to modify the recordings of images in the flight recorder so that they cannot be retrieved using normal replay or copying techniques. This is to allow the flight crew to protect their privacy by making the recording of images inaccessible using normal techniques after an uneventful flight. The decision to activate this function is to be made by the commander because they are responsible for the preservation of flight recorder recordings (refer to CAT.GEN.MPA.105). However, this function does not erase recorded data which can still be retrieved using special techniques available to the equipment manufacturer and/or safety investigation authorities. This is consistent with the specifications of ED-155 for the recording of images (refer to ED-155, Part III Airborne Image Recording Systems, paragraph III-2.1.11) and also identified as necessary by the Flight Recorder Specific Working Group (FLIRECSWG) of ICAO. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 19 of 178 An agency of the European Union A new rule CAT.IDE.H.191 is created in Part-CAT, Subpart D, Section 2 (Helicopters), which is entitled ‘Flight parameters recording on light helicopters’. — In this rule, it is required that helicopters which:  are manufactured on or after [date of application of the amending regulation + 3 years];  are of a model not specified in CAT.IDE.H.190 (which covers helicopters with an MCTOM of over 3 175 kg); and  are turbine-engined with an MCTOM of 2 250 kg or more, shall be equipped with a flight recorder. This flight recorder may be crash-protected or lightweight. — This rule also requires that the flight recorder record flight data or images sufficient to determine the flight path and aircraft speed. — A minimum recording duration of 10 hours is required in order to ensure that the flight recorder is capable of recording a complete flight on most light helicopter models that are within the scope of CAT.IDE.A.191. — Similar to CAT.IDE.A.191, the flight recorder is required to use a digital method of recording and storing the data. — Similar to CAT.IDE.A.191, the flight recorder is required to have an automatic start-and-stop logic. — Similar to CAT.IDE.A.191, if the flight recorder records images, then an erasure function shall be provided. A new rule SPO.IDE.A.146 is created in Annex VIII (Part-SPO) to Commission Regulation (EU) No 965/2012), Subpart D (Instruments, data, equipment), Section 1 (Aeroplanes), which is entitled ‘Flight parameters recording on light aeroplanes’. — In this rule, it is required that aeroplanes which:  are manufactured on or after [date of application of the amending regulation + 3 years];  are used for commercial SPO operations;  are of a model not specified in SPO.IDE.A.145 (which covers aeroplanes with an MCTOM of more than 5 700 kg); and  have an MOPSC of more than 9 or are turbine-engined with an MCTOM of 2 250 kg or more, shall be equipped with a flight recorder. This flight recorder may be crash-protected or lightweight. — This rule also requires that the flight recorder record flight data or images sufficient to determine to flight path and aircraft speed. — Similar to CAT.IDE.A.191, a minimum recording duration of 10 hours is required. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 20 of 178 An agency of the European Union — Similar to CAT.IDE.A.191, the flight recorder is required to use a digital method of recording and storing the data, and to have an automatic start-and-stop logic. — Similar to CAT.IDE.A.191, if the flight recorder records images, then an erasure function shall be provided. A new rule SPO.IDE.H.146 is created in Part-SPO, Subpart D, Section 2 (Helicopters), which is entitled ‘Flight parameters recording on light helicopters. — In this point, it is required that helicopters which:  are manufactured on or after [date of application of the amending regulation + 3 years];  are used for commercial SPO operations;  are of a model not specified in SPO.IDE.H.145 (which covers helicopters with an MCTOM of over 3 175 kg); and  are turbine-engined with an MCTOM of 2 250 kg or more, shall be equipped with a flight recorder. This flight recorder may be crash-protected or lightweight. — This rule also requires that the flight recorder record flight data or images sufficient to determine to flight path and aircraft speed. — Similar to CAT.IDE.H.191, a minimum recording duration of 10 hours is required. — Similar to CAT.IDE.H.191, the flight recorder is required to use a digital method of recording and storing the data, and to have an automatic start-and-stop logic. — Similar to CAT.IDE.A.191, if the flight recorder records images, then an erasure function shall be provided. 3.1.2.2.2 Continued serviceability of the flight recorder Paragraph (b) of CAT.GEN.MPA.195 is amended to cover the requirements of the new CAT.IDE.A.191 or CAT.IDE.H.191. Indeed, experience with crash-protected flight recorders installed on large aircraft has shown that without rules the continued serviceability of the flight recorders is not consistently addressed. Flight recorders are considered ‘maintenance-significant items’ in accordance with the MSG-3 methodology; however, the instructions for continued serviceability vary — in particular, they do not always include checking of the quality of the recorded data (i.e. that the values of flight parameters are reasonable and consistent with each other, and that images are of sufficient quality to be able to read instrument indications). In addition, since a flight recorder failure has no effect on the safe conduct of the flight, repairing it is not considered priority if it is not required by law. Paragraph (c) of CAT.GEN.MPA.195 is amended to cover the requirements of the new CAT.IDE.A.191 and CAT.IDE.H.191. Paragraph (d) of CAT.GEN.MPA.195 is amended to include lightweight flight recorders in the requirement to maintain the flight parameters decoding documentation up to date. Up-to-date European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 21 of 178 An agency of the European Union decoding documentation is essential for investigation purposes and for checking the quality of the recorded flight parameters. The wording of SPO.GEN.145 is amended in a similar manner to CAT.GEN.MPA.195. 3.1.2.2.3 Protection of image recordings Since compliance with CAT.IDE.A.191 and CAT.IDE.H.191 may be achieved by recording images of the flight crew compartment, and since the crew members may appear entirely or partly on these images, paragraph (f) of CAT.GEN.MPA.195 has been amended in order to address the protection of such image recordings. The introduction of a rule to frame the handling of image recordings is necessary in accordance with Standard 6.1 in Appendix 3 of ICAO Annex 19 (Second Edition, applicable on 7 November 2019): ‘States shall, through national laws and regulations, provide specific measures of protection regarding the confidentiality and access by the public to ambient workplace recordings.’ In addition, a Standard restricting the use of audio and airborne image recordings was adopted recently11 for inclusion in Chapter 3 of ICAO Annex 6 Part I (Tenth Edition, Amendment 40-B, applicable on 7 November 2019). The rules proposed in subparagraph (f)(3) and (f)(3a) of CAT.GEN.MPA.195 implement this ICAO Standard for airborne image recordings. Hence the following principles are proposed: — If images of the flight crew compartment contain parts of the bodies of crew members, they could be considered personal data. In that case, European operators will have to comply with Regulation (EU) 2016/679 on General Data Protection when it becomes applicable (on 25 May 2018). Therefore, reference to this Regulation is added besides reference to Regulation (EU) No 996/2010, in paragraph (f). — Similar to the recordings of the cockpit voice recorder, images of the flight crew compartment recorded by a flight recorder may not be used for purposes other than:  as stipulated in Regulation (EU) No 996/2010;  maintaining or improving safety; or  ensuring the flight recorder serviceability. — Similar to the recordings of the cockpit voice recorder, when images of the flight crew compartment recorded by a flight recorder are used for maintaining of improving safety, then:  a procedure for the handling of these images shall be in place; and  all crew members concerned shall have given their prior consent. 11 Text of this ICAO Standard: ‘3.3.4 States shall not allow the use of recordings or transcripts of CVR, CARS, Class A AIR and Class A AIRS for purposes other than the investigation of an accident or incident as per Annex 13 except where the recordings or transcripts: a) are related to a safety-related event identified in the context of a safety management system; are restricted to the relevant portions of a de-identified transcript of the recording; and are subject to the protections accorded by Annex 19; b) are sought for use in criminal proceedings not related to an event involving an accident or incident investigation and are subject to the protections accorded by Annex 19; or c) are used for inspections of flight recorder systems as provided in Section 7 of Appendix 8.’ European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 22 of 178 An agency of the European Union — Similar to the recordings of the cockpit voice recorder, when images of the flight crew compartment recorded by a flight recorder are used for ensuring the serviceability of this flight recorder,  the operator shall ensure the privacy of these images (except if there is no body part of crew members visible on the images) and  these images shall not be disclosed or used for purposes other than ensuring the flight recorder serviceability. In that case, it is not practical to request each time the prior consent of the crew. However, if such a recording is inspected for serviceability, it shall not be disclosed or used for other purposes. Note: Subparagraphs (f)(3) and (f)(3a) of CAT.GEN.MPA.195 only address images of the flight crew compartment. Hence, images of other parts of the aircraft are not within the scope of these subparagraphs. In addition, images captured ‘at the back’ of electronic flight instrument displays (reproducing an exact copy of the information presented on the display) are also not within the scope of these subparagraphs. The new rules CAT.IDE.A.191 and CAT.IDE.H.191 require that if the flight recorder records images of the flight crew compartment, an erasure function be provided. Indeed, the flight crew should be given the technical possibility to erase the recording after an uneventful flight, as a measure to protect their privacy. Modern flight recorders allow the retrieval of data even after activation of the erasure function using special tools, which are usually reserved for the equipment manufacturer and/or safety investigation authorities. Paragraph (f) of SPO.GEN.145 is amended to address the protection of recorded images of the flight crew compartment. The new rules SPO.IDE.A.146 and SPO.IDE.H.146 require that if the flight recorder records images of the flight crew compartment, an erasure function be provided (in a manner similar to CAT.IDE.A.191 and CAT.IDE.H.191). European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 23 of 178 An agency of the European Union 3.2. Draft Acceptable Means of Compliance (AMC) and Guidance Material (GM) (Draft EASA decision) 3.2.1. Draft resulting text 3.2.1.1. Draft AMC & GM to Definitions GM16 Annex I Definitions FLIGHT RECORDER A flight recorder may be crash-protected or lightweight. Crash-protected flight recorders are capable of withstanding very severe crash conditions such as those encountered during some accidents of large aeroplanes and large helicopters. Lightweight flight recorders are usually designed to meet less demanding crash-protection requirements, which allows them to be lighter. 3.2.1.2. Draft AMC & GM to Part-ORO (Annex III) ANNEX III ORGANISATION REQUIREMENTS FOR AIR OPERATIONS [PART-ORO] SUBPART AOC AIR OPERATOR CERTIFICATION AMC1 ORO.AOC.130 Flight data monitoring — aeroplanes [...] (l) Airborne systems and equipment used to obtain FDM data should range from an already installed full quick access recorder (QAR), in a modern aircraft with digital systems, to a basic crash-protected flight recorder in an older or less sophisticated aircraft. [...] AMC3 ORO.MLR.100 Operations manual — general CONTENTS — CAT OPERATIONS [...] 11 HANDLING, NOTIFYING AND REPORTING ACCIDENTS, INCIDENTS AND OCCURRENCES AND USING THE CVR RECORDING [...] (g) Procedures for the preservation of recordings of the flight recorders following an accident or a serious incident or when so directed by the investigating authority. These procedures should include: (1) a full quotation of paragraph (a) of CAT.GEN.MPA.195(a); and European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 24 of 178 An agency of the European Union (2) instructions and means to prevent inadvertent reactivation, repair or reinstallation of the flight recorders by personnel of the operator or of third parties, and to ensure that flight recorder recordings are preserved for the needs of the investigating authority. 3.2.1.3. Draft AMC & GM to Part-CAT (Annex IV) ANNEX IV COMMERCIAL AIR TRANSPORT OPERATIONS [Part-CAT] SUBPART A GENERAL REQUIREMENTS SECTION 1 Motor-powered aircraft AMC1 CAT.GEN.MPA.195(b) Handling of flight recorder recordings: preservation, production, protection and use INSPECTIONS AND CHECKS OF RECORDINGS Whenever a flight recorder is required to be carried: [...] (b) when a flight recorder, other than an FDR, is carried on an aircraft in order to ensure compliance with CAT.IDE.A.191 or CAT.IDE.H.191, the operator should perform an inspection of the recording of this flight recorder at time intervals not exceeding 2 years. (cb) [...] (dc) when installed, the aural or visual means for preflight checking of the flight recorders for proper operation should be used on each day whenevery day the aircraft is used. When no such means is available for a flight recorder, the operator should perform an operational check of this flight recorder at time intervals not exceeding 150 flight hoursseven calendar days of operation. (ed) [...] GM1 CAT.GEN.MPA.195(b) Handling of flight recorder recordings: preservation, production, protection and use INSPECTION OF THE FLIGHT RECORDERS’ RECORDINGS [...] European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 25 of 178 An agency of the European Union (d) The inspection of flight data recorded by a lightweight flight recorder usually consists of the following: (1) making a copy of the complete recording file; (2) converting the recording to parameters expressed in engineering units in accordance with the documentation required to be held; (3) examining a whole flight in engineering units to evaluate the validity of all mandatory parameters. When applicable, each parameter should be expressed in engineering units and checked for different values of its operational range for reasonableness — for this purpose, some parameters may need to be inspected at different flight phases; and (4) retaining the most recent copy of the complete recording file and the corresponding recording inspection report that includes references to the documentation required to be held. (e) The inspection of recorded images usually consists of the following: (1) checking that the flight recorder operates correctly for the nominal duration of the recording; (2) examining, where practicable and in compliance with paragraph (f) of CAT.GEN.MPA.195, a sample of images recorded in different flight phases for evidence that the images of each camera are of a quality sufficient for reading the instruments’ indications; and (3) preparing and retaining an inspection report. AMC1 CAT.GEN.MPA.195(f)(1) Handling of flight recorder recordings: preservation, production, protection and use USE OF CVR RECORDINGS FOR MAINTAINING OR IMPROVING SAFETY (a) The procedure related to the handling of cockpit voice recorder (CVR) recordings should be written in a document which should be signed documented and signed by all parties (airline managementaircraft operator, crew member representatives nominated either by the union or the crew themselves, maintenance personnel representatives if applicable). This procedure should take into account Regulation (EU) 2016/67912 and, as a minimum, define: [...] AMC1 CAT.GEN.MPA.195(f)(3) Handling of flight recorder recordings: preservation, production, protection and use USE OF IMAGE RECORDINGS FOR MAINTAINING OR IMPROVING SAFETY (a) The procedure laid down in point (f)(3)(i) of CAT.GEN.MPA.195 should be documented and signed by all parties involved (aircraft operator, crew member representatives nominated either by the union or the crew themselves, maintenance personnel representatives if applicable). This procedure should take into account Regulation (EU) 2016/679 and, as a minimum, define the following aspects: 12 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1). European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 26 of 178 An agency of the European Union (1) an access and security policy that restricts access to the image recordings to authorised persons identified by their position; (2) a retention policy and accountability, including the measures to ensure the security of the image recordings and their protection from misuse; (3) a description of the uses made of the image recordings; (4) the participation of flight crew member representatives in the assessment of the image recordings; (5) the conditions under which advisory briefing or remedial training should take place; this should always be carried out in a constructive and non-punitive manner; and (6) the conditions under which actions other than advisory briefing or remedial training may be taken for reasons of gross negligence or significant continuing safety concern. (b) Each time a recording file containing images of the flight crew compartment is read out for purposes other than ensuring the serviceability of the flight recorder, the operator should retain, and when requested, provide the competent authority with: (1) information on the use made (or the intended use) of the recording file; and (2) evidence that the crew members concerned consented to the use made (or the intended use) of the flight crew compartment images. (c) The safety manager or the person identified by the operator to fulfil this role should be responsible for the protection and use of the recordings of flight crew compartment images, as well as the assessment of issues and their transmission to the manager(s) responsible for the process concerned. (d) In case a third party is involved in the use of recordings of flight crew compartment images, contractual agreements with this third party should, when applicable, cover the aspects enumerated in (a) and (b). AMC1 CAT.GEN.MPA.195(f)(3a) Handling of flight recorder recordings: preservation, production, protection and use IMAGE RECORDING INSPECTION FOR ENSURING SERVICEABILITY (a) When an inspection of recorded images of the flight crew compartment is performed for ensuring the serviceability of the flight recorder and any body part of a crew member is likely to be visible on these images: (1) the privacy of the image recordings should be ensured (e.g. by locating the replay equipment in a separated area); (2) access to the replay equipment should be restricted to authorised persons; (3) provisions should be made for the secure storage of the image recording medium, the image recording files and copies thereof; (4) the image recording files and copies thereof should be destroyed not earlier than 2 months and not later than 1 year after completion of the image recording inspection; images that do not European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 27 of 178 An agency of the European Union contain any body part of a person may be retained for enhancing the image recording inspection (e.g. for comparing image quality); and (5) only the accountable manager of the operator and, when identified to comply with ORO.GEN.200, the safety manager should be entitled to request a copy of the image recording files. (b) The conditions enumerated in (a) should also be complied with if the inspection of the image recording is subcontracted to a third party. The contractual agreements with the third party should explicitly cover these aspects. GM1 CAT.GEN.MPA.195(f) Handling of flight recorder recordings: preservation, production, protection and use FLIGHT CREW COMPARTMENT If there are no compartments to physically segregate the flight crew from the passengers during the flight, the ‘flight crew compartment’ should be understood, in paragraph (f) of CAT.GEN.MPA.195, as the area including: (a) the flight crew seats; (b) aircraft and engine controls; (c) aircraft instruments; (d) windshield and windows used by the flight crew to get an external view while seated at their duty station; and (e) circuit breakers accessible by the flight crew while seated at their duty station. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 28 of 178 An agency of the European Union SUBPART D INSTRUMENTS, DATA, EQUIPMENT SECTION 1 Aeroplanes AMC1 CAT.IDE.A.191 Recording of flight parameters on light aeroplanes OPERATIONAL PERFORMANCE REQUIREMENTS (a) The flight recorder may record images or flight data, or a combination thereof. (b) If the flight recorder records flight data, it should record at least the following parameters: (1) relative time count, (2) pitch attitude or pitch rate, (3) roll attitude or roll rate, (4) heading (magnetic or true) or yaw rate, (5) latitude, (6) longitude, (7) positioning system: estimated error (if available), (8) pressure altitude or altitude from a positioning system, (9) time, (10) ground speed, (11) positioning system: track (if available), (12) normal acceleration, (13) longitudinal acceleration, and (14) lateral acceleration. (c) If the flight recorder records images, it should capture views of the main instrument displays at the pilot station, or at both pilot stations when the aeroplane is certified for operation with a minimum crew of two pilots. The recorded image quality should allow reading the following indications during most of the flight: (1) magnetic heading, (2) time, (3) pressure altitude, (4) indicated airspeed, (5) vertical speed, (6) turn and slip, European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 29 of 178 An agency of the European Union (7) attitude, (8) Mach number (if displayed), and (9) stabilised heading. (d) If the flight recorder records flight data and images, each flight parameter listed in (b) should be recorded as flight data or by means of images. (e) The flight parameters listed in (b), which are recorded as flight data, should meet the performance specifications (range, sampling intervals, accuracy limits and resolution in read-out) as defined in the relevant table of EUROCAE Document 112 (Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems) dated March 2003, or EUROCAE Document ED-155 (Minimum Operational Performance Specification for Lightweight Flight Recording Systems) dated July 2009, or any later equivalent standard accepted by EASA. (f) The operational performance requirements for the flight recorder should be those laid down in: (1) EUROCAE Document ED-155 or any later equivalent standard accepted by EASA for lightweight flight recorders; or (2) EUROCAE Document 112 or any later equivalent standard accepted by EASA for crash-protected flight recorders. GM1 CAT.IDE.A.191 Recording of flight parameters on light aeroplanes ADDITIONAL USEFUL INFORMATION While only flight data or images sufficient to determine the flight path and aircraft speed are required to be recorded, experience has shown that recording information related to the positions of flight controls and an external view is very useful for analysing incidents or accidents. SECTION 2 Helicopters AMC1 CAT.IDE.H.191 Recording of flight parameters on light helicopters OPERATIONAL PERFORMANCE REQUIREMENTS (a) The flight recorder may record images or flight data, or a combination thereof. (b) If the flight recorder records flight data, it should record at least the following parameters: (1) relative time count, (2) pitch attitude or pitch rate, (3) roll attitude or roll rate, (4) heading (magnetic or true) or yaw rate, (5) latitude, (6) longitude, European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 30 of 178 An agency of the European Union (7) positioning system: estimated error (if available), (8) pressure altitude or altitude from a positioning system, (9) time, (10) ground speed, (11) positioning system: track (if available), (12) normal acceleration, (13) longitudinal acceleration, and (14) lateral acceleration. (c) If the flight recorder records images, it should capture views of the main instrument displays at the pilot station, or at both pilot stations when the aeroplane is certified for operation with a minimum crew of two pilots. The recorded image quality should allow reading the following indications during most of the flight: (1) magnetic or true heading, (2) time (if presented on the front instrument panel), (3) pressure altitude, (4) indicated airspeed, (5) vertical speed, (6) slip, (7) outside air temperature, (8) attitude (if displayed), and (9) stabilised heading (if displayed). (d) If the flight recorder records flight data and images, each flight parameter listed in (b) should be recorded as flight data or by means of images. (e) The flight parameters listed in (b), which are recorded as flight data, should meet the performance specifications (range, sampling intervals, accuracy limits and resolution in read-out) as defined in the relevant table of EUROCAE Document 112 (Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems) dated March 2003, or EUROCAE Document ED-155 (Minimum Operational Performance Specification for Lightweight Flight Recording Systems) dated July 2009, or any later equivalent standard accepted by EASA. (f) The operational performance requirements for the flight recorder should be those laid down in: (1) EUROCAE Document ED-155 or any later equivalent standard accepted by EASA for lightweight flight recorders; or (2) EUROCAE Document 112 or any later equivalent standard accepted by EASA for crash-protected flight recorders. European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 31 of 178 An agency of the European Union GM1 CAT.IDE.H.191 Recording of flight parameters on light helicopters ADDITIONAL USEFUL INFORMATION While only flight data or images sufficient to determine the flight path and aircraft speed are required to be recorded, experience has shown that recording information related to the positions of flight controls and an external view is very useful for analysing incidents and accidents. 3.2.1.4. Draft AMC & GM to Part-SPO (Annex VIII) ANNEX VIII SPECIALISED OPERATIONS [PART-SPO] AMC1 SPO.GEN.145(b) Handling of flight recorder recordings: preservation, production, protection and use INSPECTIONS AND CHECKS OF RECORDINGS Whenever a flight recorder is required to be carried: [...] (b) When a flight recorder, other than an FDR, is carried on an aircraft in order to ensure compliance with SPO.IDE.A.146 or SPO.IDE.H.146, the operator should perform an inspection of the recording of this flight recorder at time intervals not exceeding 2 years. (cb) [...] (dc) When installed, the aural or visual means for preflight checking of the flight recorders for proper operation should be used every day on each day the aircraft is used. When no such means is available for a flight recorder, the operator should perform an operational check of this flight recorder at time intervals not exceeding 150 flight hoursseven calendar days of operation. (ed) [...] GM1 SPO.GEN.145(b) Handling of flight recorder recordings: preservation, production, protection and use INSPECTION OF THE FLIGHT RECORDERS’ RECORDINGS [...] (d) The inspection of flight data recorded by a lightweight flight recorder usually consists of the following: (1) making a copy of the complete recording file; (2) converting the recording to parameters expressed in engineering units in accordance with the documentation required to be held; European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 32 of 178 An agency of the European Union (3) examining a whole flight in engineering units to evaluate the validity of all mandatory parameters; when applicable, each parameter should be expressed in engineering units and checked for different values of its operational range for reasonableness — for this purpose, some parameters may need to be inspected at different flight phases; and (4) retaining the most recent copy of the complete recording file and the corresponding recording inspection report that includes references to the documentation required to be held. (e) The inspection of recorded images usually consists of the following: (1) checking that the flight recorder operates correctly for the nominal duration of the recording; (2) examining, where practicable and in compliance with paragraph (f) of SPO.GEN.145, a sample of images recorded in different flight phases for evidence that the images of each camera are of a quality sufficient for reading the instruments’ indications; and (3) preparing and retaining an inspection report. AMC1 CAT.GEN.MPA.195(f) Handling of flight recorder recordings: preservation, production, protection and use USE OF CVR RECORDINGS FOR MAINTAINING OR IMPROVING SAFETY (a) The procedure related to the handling of cockpit voice recorder (CVR) recordings should be written in a document which should be documented and signed by all parties (airlineaircraft operator, crew members, maintenance personnel if applicable). This procedure should take into account Regulation (EU) 2016/679 and, as a minimum, define: [...] AMC1 SPO.GEN.145(f)(3) Handling of flight recorder recordings: preservation, production, protection and use USE OF IMAGE RECORDINGS FOR MAINTAINING OR IMPROVING SAFETY (a) The procedure indicated in point (f)(3)(i) of SPO.GEN.145 should be documented and signed by all parties (aircraft operator, crew members, maintenance personnel if applicable). This procedure should take into account Regulation (EU) 2016/679 and, as a minimum, define the following aspects: (1) an access and security policy that restricts access to the image recordings to authorised persons identified by their position; (2) a retention policy and accountability, including the measures to ensure the security of the image recordings and their protection from misuse; (3) a description of the uses made of the image recordings. (b) Each time a recording file containing images of the flight crew compartment is read out for purposes other than to ensure the serviceability of the flight recorder, the operator should retain and, when requested, provide the competent authority with: (1) information on the use made (or the intended use) of the recording file; and European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 33 of 178 An agency of the European Union (2) evidence that the flight crew members concerned consented to the use made (or the intended use) of the flight crew compartment images. (c) The safety manager or the person identified by the operator to fulfil this role should be responsible for the protection and use of the recordings of flight crew compartment images, as well as the assessment of issues and their transmission to the manager(s) responsible for the process concerned. (d) In case a third party is involved in the use of recordings of flight crew compartment images, contractual agreements with this third party should, when applicable, cover the aspects enumerated in (a) and (b). AMC1 SPO.GEN.145(f)(3a) Handling of flight recorder recordings: preservation, production, protection and use IMAGE RECORDING INSPECTION FOR ENSURING SERVICEABILITY (a) When an inspection of recorded images of the flight crew compartment is performed to ensure the serviceability of the flight recorder and any body part of a crew member is likely to be visible on these images: (1) the privacy of the image recordings should be ensured (e.g. by locating the replay equipment in a separated area); (2) access to the replay equipment should be restricted to authorised persons; (3) provisions should be established for the secure storage of the image recording medium, the image recording files and copies thereof; (4) the image recording files and copies thereof should be destroyed not earlier than 2 months and not later than 1 year after completion of the image recording inspection. Images that do not contain any body part of a person may be retained for enhancing the image recording inspection (e.g. for comparing image quality); and (5) only the accountable manager of the operator and, when identified to comply with ORO.GEN.200, the safety manager should be entitled to request a copy of the image recording files. (b) The conditions enumerated in (a) should also be complied with if the inspection of the image recording is subcontracted to a third party. The contractual agreements with the third party should explicitly cover these aspects. GM1 SPO.GEN.145(f) Handling of flight recorder recordings: preservation, production, protection and use FLIGHT CREW COMPARTMENT If there are no compartments to physically segregate the flight crew from the passengers during the flight, the ‘flight crew compartment’ should be understood in paragraph (f) of SPO.GEN.145 as the area including: (a) the flight crew seats; (b) aircraft and engine controls; (c) aircraft instruments; European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 34 of 178 An agency of the European Union (d) windshield and windows used by the flight crew to get an external view while seated at their duty station; and (e) circuit breakers accessible by the flight crew while seated at their duty station. SUBPART D INSTRUMENTS, DATA, EQUIPMENT SECTION 1 Aeroplanes AMC1 SPO.IDE.A.146 Recording of flight parameters on light aeroplanes OPERATIONAL PERFORMANCE REQUIREMENTS (a) The flight recorder may record images or flight data, or a combination thereof. (b) If the flight recorder records flight data, it should record at least the following parameters: (1) relative time count, (2) pitch attitude or pitch rate, (3) roll attitude or roll rate, (4) heading (magnetic or true) or yaw rate, (5) latitude, (6) longitude, (7) positioning system: estimated error (if available), (8) pressure altitude or altitude from a positioning system, (9) time, (10) ground speed, (11) positioning system: track (if available), (12) normal acceleration, (13) longitudinal acceleration, (14) lateral acceleration. (c) If the flight recorder records images, it should capture views of the main instrument displays at the pilot station, or at both pilot stations when the aeroplane is certified for operation with a minimum crew of two pilots. The recorded image quality should allow reading the following indications during most of the flight: (1) magnetic heading, (2) time, European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 35 of 178 An agency of the European Union (3) pressure altitude, (4) indicated airspeed, (5) vertical speed, (6) turn and slip, (7) attitude, (8) Mach number (if displayed), and (9) stabilised heading. (d) If the flight recorder records flight data and images, each flight parameter listed in (b) should be recorded as flight data or by means of images. (e) The flight parameters listed in (b), which are recorded as flight data, should meet the performance specifications (range, sampling intervals, accuracy limits and resolution in read-out) as defined in the relevant table of EUROCAE Document 112 (Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems) dated March 2003, or EUROCAE Document ED-155 (Minimum Operational Performance Specification for Lightweight Flight Recording Systems) dated July 2009, or any later equivalent standard accepted by EASA. (f) The operational performance requirements for the flight recorder should be those laid down in: (1) EUROCAE Document ED-155 or any later equivalent standard accepted by EASA for lightweight flight recorders; or (2) EUROCAE Document 112 or any later equivalent standard accepted by EASA for crash-protected flight recorders. GM1 SPO.IDE.A.146 Recording of flight parameters on light aeroplanes ADDITIONAL USEFUL INFORMATION While only flight data or images sufficient to determine the flight path and aircraft speed are required to be recorded, experience has shown that recording information related to the position of flight controls and an external view is very useful for analysing incidents and accidents. SECTION 2 Helicopters AMC1 SPO.IDE.H.146 Recording of flight parameters on light helicopters OPERATIONAL PERFORMANCE REQUIREMENTS (a) The flight recorder may record images or flight data, or a combination thereof. (b) If the flight recorder records flight data, it should record at least the following parameters: (1) relative time count, (2) pitch attitude or pitch rate, European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 36 of 178 An agency of the European Union (3) roll attitude or roll rate, (4) heading (magnetic or true) or yaw rate, (5) latitude, (6) longitude, (7) positioning system: estimated error (if available), (8) pressure altitude or altitude from a positioning system, (9) time, (10) ground speed, (11) positioning system: track (if available), (12) normal acceleration, (13) longitudinal acceleration, and (14) lateral acceleration. (c) If the flight recorder records images, it should capture views of the main instrument displays at the pilot station, or at both pilot stations when the aeroplane is certified for operation with a minimum crew of two pilots. The recorded image quality should allow reading the following indications during most of the flight: (1) magnetic or true heading, (2) time (if presented on the front instrument panel), (3) pressure altitude, (4) indicated airspeed, (5) vertical speed, (6) slip, (7) outside air temperature, (8) attitude (if displayed), (9) stabilised heading (if displayed). (d) If the flight recorder records flight data and images, each flight parameter listed in (b) should be recorded as flight data or by means of images. (e) The flight parameters listed in (b), which are recorded as flight data, should meet the performance specifications (range, sampling intervals, accuracy limits and resolution in read-out) as defined in the relevant table of EUROCAE Document 112 (Minimum Operational Performance Specification for Crash Protected Airborne Recorder Systems) dated March 2003, or EUROCAE Document ED-155 (Minimum Operational Performance Specification for Lightweight Flight Recording Systems) dated July 2009, or any later equivalent standard accepted by EASA. (f) The operational performance requirements for the flight recorder should be those laid down in: European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 37 of 178 An agency of the European Union (1) EUROCAE Document ED-155 or any later equivalent standard accepted by EASA for lightweight flight recorders; or (2) EUROCAE Document 112 or any later equivalent standard accepted by EASA for crash-protected flight recorders. GM1 SPO.IDE.H.146 Recording of flight parameters on light helicopters ADDITIONAL USEFUL INFORMATION While only flight data or images sufficient to determine the flight path and aircraft speed are required to be recorded, experience has shown that recording information related to the position of flight controls and an external view is very useful for analysing incidents and accidents. 3.2.2. Rationale 3.2.2.1. AMC & GM to Definitions A new GM indicates that a flight recorder can be ‘crash-protected’ or ‘lightweight’, and it defines these terms. 3.2.2.2. AMC & GM to Annex III (Part-ORO) Minor editorial corrections are made to AMC1 ORO.MLR.100 and AMC3 ORO.MLR.100. 3.2.2.3. AMC & GM to Annex IV (Part-CAT) and Annex VIII (Part-SPO) 3.2.2.3.1 AMC & GM to the new recording requirements AMC1 CAT.IDE.A.191 is created to provide the operational performance requirements of the flight recorder required in CAT.IDE.A.191. — In the case where the flight recorder records flight data, AMC1 CAT.IDE.A.191(b) specifies what flight parameters should be recorded in order to ensure that sufficient information is recorded to determine the aircraft flight path and speed. The listed flight parameters are already required to be recorded by the FDR, but they can also be obtained by means of dedicated sensors (accelerometric sensors and GNSS receiver), in the case where there is no flight data acquisition unit or if a stand-alone recorder is preferred. — In the case where the flight recorder records images, AMC1 CAT.IDE.A.191(c) specifies that views of the main instrument displays at the pilot station(s) should be captured, and that the recorded images should allow reading the instruments’ indications. In addition, a list of indications to be captured is provided. These indications correspond to instruments required on-board all aeroplanes in accordance with CAT.IDE.A.125 (operations under VFR by day) and CAT.IDE.A.130 (operations under IFR or at night), hence they can be captured by images (refer to Appendix I for more information). When the indication may not be required under some types of operation, then the indication should be recorded ‘if displayed’. — AMC1 CAT.IDE.A.191(a) allows combining the recording of images and flight data, at the operator’s convenience. However, the flight parameters recommended in European Aviation Safety Agency NPA 2017-03 3. Proposed amendments and rationale in detail TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 38 of 178 An agency of the European Union AMC1 CAT.IDE.A.191(b) do not contain the same information as the indications recommended to be recorded by means of images in AMC1 CAT.IDE.A.191(c). To resolve this discrepancy and ensure that a minimum data subset is recorded whatever the elected solution is, AMC1 CAT.IDE.A.191(d) recommends that when both flight data and images are recorded, each flight parameter listed in AMC1 CAT.IDE.A.191(b) is recorded as flight data or by means of images. — AMC1 CAT.IDE.A.191(e) clarifies the applicable flight parameter performance when flight data is recorded, taking into account that the operator may choose to record the data on a crash- protected FDR or on a lightweight aircraft data recording system (ADRS). The performance of flight parameters should then meet the applicable performance specifications (i.e. range, sampling intervals, accuracy limits and resolution in read-out) either given by Table II-A.1 of EUROCAE Document 112 (ED-112) dated 2003, or by Table II-B.1 of EUROCAE Document 155 (ED-155) dated 2009. This is consistent with the flight parameter performance prescribed in ICAO Annex 6 Part I. It should be noted that although ED-112 was superseded by ED-112A in 2013, compliance with ED-112 is still considered acceptable: this is because the flight parameters performance provided by ED-112 is considered sufficient for investigation purposes in the case of a light aircraft. — AMC1 CAT.IDE.A.191(f) recommends that the operational performance of the flight recorder should in any case meet the specifications of either ED-155 or ED-112. This is consistent with the operational performance prescribed for flight recorders in ICAO Annex 6 Part I, which refers to ED-112 and ED-155. In addition, EUROCAE standards are the reference industry standards in the Air Operations rules applicable to crash-protected flight recorders (see for instance AMC1 CAT.IDE.A.190), as well as in the CS-ETSO addressing flight data recorders (ETSO-C124b), airborne image recorders (ETSO-C176) and ligh