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Steve Zerkowitz

Proposal for a Solution of the Problems Raised by the ICAO Data Link Communications Recording Requirements. Steve Zerkowitz. In this presentation…. We review an Annex 6 requirement Identify the problem Describe its impact on an important programme Propose a solution. Annex 6.

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Steve Zerkowitz

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  1. Proposal for a Solutionof theProblems Raised by the ICAO Data Link CommunicationsRecording Requirements Steve Zerkowitz

  2. In this presentation…. • We review an Annex 6 requirement • Identify the problem • Describe its impact on an important programme • Propose a solution

  3. Annex 6 • According to Annex 6, Part I, Flight Recorders, as amended by Amendment 26: • “All aeroplanesfor which the individual certificate of airworthiness is first issuedafter 1 January 2005, which utilize data link communications and are required to carry a cockpit voice recorder, shall record on a flight recorder, all data link communications to and from the aeroplane. The minimum recording duration shall be equal to the duration of the CVR, and shall be correlated to the recorded cockpit audio.” • “From 1 January 2007, all aeroplanes which utilize data link communications and are required to carry a cockpit voice recorder, shall record on a flight recorder, all data link communications to and from the aeroplane. The minimum recording duration shall be equal to the duration of the CVR, and shall be correlated to the recorded cockpit audio.”

  4. Why is this a problem? • Recording for accident investigation, no direct safety benefit • Opposed by the airspace users • Need for more clarity • Need for technical standards • Cost prohibitive • Cost issue remains • If enforced, LINK2000+ impacted!

  5. What is LINK2000+? • EUROCONTROL programme to implement CPDLC over VDL Mode 2/ATN: an important capacity and safety enabler • Supported by airlines and ANSPs • Three step approach: • Pioneers (150 aircraft) • Incentives (25 % of traffic, steepen equipage curve) • Mandate (2010 new aircraft, 2012 all aircraft) • Business case solid, but minimum 25 % equipped traffic needed for measurable capacity benefits

  6. Recording requirement impact • New aircraft: cost delta absorbed in price of aircraft = impact limited • Other aircraft: recorder has to be replaced, possibly wiring changes: 15 -17 K€ for recorder only • On-board implementation of CPDLC: 28-41 K€ • Recorder adds > 50 % to initial cost with no additional safety benefit!

  7. Facts of life • If initial investment too high, even a positive business case is no guarantee of airlines equipping early • If recording requirement is enforced for other than new aircraft, CPDLC implementation will slow down or stall • Capacity and safety benefits will be delayed • Self defeating exercise

  8. Proposed solution – 1 • Longer term rationale for recording digital communications is recognized • Impact on LINK2000+ must be contained • Compromise solution developed together with the airlines • It is proposed that States in the LINK2000+ implementation area, supported by the JAA, agree to file a difference from the Annex 6 requirements, stating the following:

  9. Proposed solution - 2 • “All aeroplanes for which the individual certificate of airworthiness is first issued after 1 January 2010, which utilize data link communications and are required to carry a cockpit voice recorder, shall record on a flight recorder, all data link communications related to air traffic services to and from the aeroplane.” • “The requirement for recording of digital communications on all other aircraft is not applied at least until 2015, before which time the need for such recording, its feasibility and cost implications will be reassessed with a view to establishing a new date, if needed, for the application of this requirement.” • Appropriate rationale as required by ICAO

  10. Recommendation It is recommended that: • the JAA support the above proposal and request EUROCONTROL to develop a standard text for filing the difference; • EUROCONTROL co-ordinate the necessary action with the States in the LINK2000+ area to ensure filing of the difference as soon as possible and inform the airspace users; • the JAA, EUROCAE and EUROCONTROL undertake to clarify and align the corresponding requirement texts in the technical documents with particular attention to the exact definition of what is to be recorded.

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