In part because of two-high profile fatal crashes–one involving eight federal government employees and the other a U.S. senator–the National Transportation Safety Board held two days of hearings in late July on its recommendations that a cockpit image recorder (CIR) be installed in nearly all turbine-powered aircraft.

The Safety Board wants the FAA to order that all turbine aircraft manufactured after Jan. 1, 2007, and operated under Parts 135, 121 or full-time or part-time for commercial or corporate purposes under Part 91, be equipped with a CIR. Aircraft that were built before Jan. 1, 2007, would be required to retrofit a CIR by that date unless they are equipped with a cockpit voice recorder.

Organizations representing the interests of general aviation met the NTSB recommendations with skepticism. The General Aviation Manufacturers Association conceded that information provided by crash-survivable video “might be useful” where a CVR and/or an FDR are not installed. GAMA has estimated that more than 18,000 aircraft would be eligible for some type of cockpit image recording system.

“However, GAMA does not believe that the benefits of installing such recorders on small aircraft currently justify the costs,” said Ron Swanda, GAMA senior v-p of operations (and interim leader in the wake of Ed Bolen’s move to lead NBAA). “Operator investments in aircraft safety equipment are much better justified in equipment that directly contributes to the margin of safety, not in equipment that contributes only after an accident.”

The National Air Transportation Association noted that while the cost of video recording technology is dropping, the installation costs for the Part 135 and 91 fleets would still be high due to the wide variation and customization of the turbine fleet.

“The fact remains that the feasibility and benefits of cockpit image recorders in small aircraft have not been specifically studied, nor has any true cost-benefit analysis occurred,” said Jacqueline Rosser, NATA manager of flight operations. NATA is concerned that the Board is focusing on image recorders rather than actively considering other solutions for small aircraft that could assist in accident investigation and provide direct benefits to operators as well.

The NTSB’s Case for CIRs

The NTSB said in a safety recommendation letter to FAA Administrator Marion Blakey late last year that it has investigated numerous accidents since January 2000 that involved Part 91 and 135 turbine-powered aircraft not required to operate with either a CVR or FDR. Included was the Oct. 25, 2002, accident involving a Beech King Air A100 that crashed on approach to Eveleth-Virginia Municipal Airport in Eveleth, Minn., killing all eight people on board, including Sen. Paul Wellstone (D-Minn.).

The Board first formally recommended crash-protected image recorders in February 2000 following its investigation of the 1997 crash of a Cessna 208B Caravan near Montrose, Colo. The accident aircraft was operated under Part 135 as an on-demand air charter for the federal Bureau of Reclamation. Eight employees of the bureau and the pilot were killed.

The Board expressed concern that two categories of smaller aircraft that have experienced numerous accidents are not required to be equipped with any crash-protected recorder. They are single-pilot-certified turbine-powered aircraft and dual-certified aircraft for both cargo and passenger duty.

The first category includes Beech King Airs, smaller Cessna Citations, Cessna Caravans and the Piper Cheyenne PA-31T series airplanes, the Board said, as well as Bell 407 and Bell 206L helicopters. It said these single-pilot-certified aircraft are heavily used in Part 135 passenger charter and other commercial operations.

Under Part 91 and 135 operations, a CVR is required only if the aircraft are certified to operate with two pilots. Moreover, because these aircraft are configured for fewer than 10 passenger seats, they are not required to have an FDR installed. According to the NTSB, aircraft in this category have been involved in more than 100 accidents it investigated since January 2000. Most were not equipped with CVRs and in only one case was the CVR operating at the time of the accident.

“Without data recorders, the Safety Board is disadvantaged in its ability to thoroughly investigate the large number of accidents occurring among these aircraft,” it said in the letter to the FAA. “The Safety Board notes that, had the FAA implemented the prior recommendations in a timely manner, a crash-protected recorder would have been required to be operating on the Beech King that crashed, killing Senator Wellstone.”

The second category of aircraft, which includes many Dassault Falcons and the Embraer EMB-120 Brasilia, has dual certification for both passenger and cargo use. When configured for six or more passengers these aircraft are typically used in executive passenger charter operations.

This dual certification allows the same model aircraft to operate either with or without a CVR or FDR depending on seating configuration, the Board said. Specifically, the passenger/cargo certification allows the operator to remove the FDR if the aircraft is configured for fewer than 10 passenger seats and to remove the CVR if the aircraft is configured for fewer than six passenger seats.

Since January 2000, the Falcon and the Brasilia have been involved in 18 accidents that the Board has investigated. One-third of the aircraft involved were being used for cargo and therefore were not required to carry CVRs. One accident involved a cargo-configured Brasilia that was equipped with both an FDR and a CVR although neither was required because of the aircraft’s type certificate. Other accidents involved Dassault cargo aircraft that were neither equipped nor required to be equipped with a CVR or an FDR.

“Considering the number of accidents occurring among the aircraft cited previously, the Safety Board has identified the need to install crash-protected recording devices on all turbine-powered aircraft,” Blakey was told. “The Board recognizes the economic impact of requiring both a CVR and an FDR on smaller aircraft and consequently proposes that all smaller turbine-powered aircraft be equipped with a single crash-protected recorder: the video image recorder. Such recorders obtain not only audio information like that from CVRs and even data like that from FDRs, but also information about the environment outside the cockpit window.”

In an opening statement, Board member Carol Carmody, who served as chair for the two-day hearing, recalled that in 2000 the Board addressed larger aircraft when it recommended installation of crash-protected image recorder systems for aircraft operated under Parts 121, 125 or 135 and currently required to be equipped with a CVR and a digital flight data recorder (DFDR).

The recommendations were based on the NTSB’s investigations of a number of accidents in which CVR and DFDR information alone did not provide definitive information on crew actions, the cockpit environment or graphic information displayed to the flight crew.

Carmody said these accidents included the 1996 crash of ValuJet 592 into the Everglades near Miami; the 1997 crash of SilkAir Flight 185 in Indonesia; the 1998 crash of Swissair Flight 111 near Peggy’s Cove, Nova Scotia; and the 1999 crash of EgyptAir Flight 990 south of Nantucket Island, Mass. These accidents claimed the lives of all 550 people aboard the four aircraft.

Professional Pilots Weigh In

While general aviation questioned the need for data recorders largely on economic grounds, the Air Line Pilots Association and the Allied Pilots Association brought up privacy issues. ALPA called the proposals to install video cameras in the cockpits of airliners the “fool’s gold” of accident investigation, claiming pilots are universally opposed to the idea.

ALPA, which represents 64,000 airline pilots, and the APA, which has 11,500 American Airlines pilots in its ranks, said they are strongly opposed to CIRs because the benefits are vastly overrated and because far more effective and efficient tools exist that will not only obtain the safety data necessary to accurately investigate an accident, but also help prevent future accidents.

They also argue that imagery information from cockpit visual recorders is subjective and open to interpretation, while data from sources such as the DFDR is unambiguous and not subject to analytical shortcomings associated with video.

But the real issue that rankles the rank-and-file is the question of pilot privacy. Pilots are especially bitter over the American Airlines 757 crash near Cali, Colombia, in 1995, after which the Colombian authorities released the CVR tape to NBC’s Dateline.

“History has shown that in the current environment it is impossible to safeguard the privacy of cockpit voice recorders, much less cockpit image recorders,” said Capt. Paul Rice, ALPA’s v-p of administration. “When cockpit voice recorders were originally installed, it was done with clear expectations about pilot privacy. These expectations have not been met, even with strong legislative protections enacted in later years.”

While conceding that “misuse of data” is a downside of CIRs, Ken Smart, chief inspector of the UK’s Air Accidents Investigation Branch, said that video data is complementary to CVR and FDR and “will provide information on all of the accidents that we investigate.”

Smart said that cockpit image recordings would have helped investigators in the July 2000 crash of the Air France Concorde at Paris. “The CVR and FDR didn’t give adequate representation” of the “confusing warnings the crew was presented with.”