Flight recorders have long been perceived as heavy and expensive equipment reserved for accident investigators. However, cheap and lightweight recording systems can be voluntarily installed on small aircraft and they bring valuable safety benefits.
This article focuses on the benefit of such equipment for owners and operators of light helicopters and supports two objectives:
- Promoting helicopter technologies with safety benefits. This objective is tracked by safety action SPT.095 in the European Plan for Aviation Safety1; and
- Enhancing the collection of safety data about helicopter operations. This objective is stated as part of the vision and strategic objectives in the Rotorcraft Safety Roadmap2.
What is meant by the term “Flight Recorder”?
While the term ‘flight recorder’ is used in official documents to designate mandatory equipment, in this article we use the term 'recording system' to designate any system that is:
- Dedicated for recording data and/or audio and/or images/video,
- Installed on board the helicopter (not portable), and
- Continuously recording from take-off to landing.
The recording system does not need to be crash-protected or to meet industry standards applicable to a flight recorder.
Equipment that is not dedicated for recording, or that is portable, or that does not continuously record throughout the flight is out of the scope of this article.
Are helicopters required to carry a Recording System?
Large helicopters (those with a maximum certificated take-off mass of more than 3,175 kg) are required to carry an FDR and CVR if they are used for commercial air transport or were manufactured after 1 January 20163.
Turbine-engined helicopters with a maximum certificated take-off mass between 2,250 kg and 3,175 kg and manufactured on or after 5 September 2022 will be required to carry a flight recorder if they are used for commercial air transport or commercial specialised operations4.
But even if your helicopter does not fall into any of these categories, it is really worth considering the installation of a recording system.
I am a helicopter owner or operator. Why should I install a Recording System if it is not required?
There are many potential benefits, but to name a few:
- Support operational safety monitoring by providing accurate data for analysing incidents.
- Monitor compliance with standard operating procedures.
- Monitor compliance with procedures that limit aircraft usage, and be able to supplement data recorded by a usage monitoring system5 (if installed) with data on the handling of the helicopter.
- Monitor compliance with airspace restrictions.
- Decreased risk-taking by pilots because data of their flight can be checked afterward.
- Pilot training better tailored (focused on actual risks as shown by the recorded data) and closer to reality (based on situations with which pilots are familiar).
- Accurate data in case of dispute with third parties (other airspace users, aircraft manufacturer, airfield neighbours, overflown persons on the ground, insurance companies, etc.).
Isn’t the installation of a Recording System on a Light Helicopter too great in terms of cost or weight?
As a voluntarily installed recording system does not need to meet any performance objective, the cost can be much less than for the crash-protected flight recorders required on board large aeroplanes.
In addition, the installation of a recording system might be taken into account by insurance companies in the computation of the aircraft insurance premium.
The purchase price of a recording system without a Technical Standard Order (TSO/ETSO) authorisation is typically in the range of 1,000 to 8,000 Euros. The certification and installation cost are often limited, because most aircraft manufacturers already offer this equipment as an option and installation can be approved as a minor design change.
The weight of a recording system can be less than 1 kg (including dedicated wires, sensors and the installation kit).
In addition, if the maximum weight of the recording system does not exceed 300 g, it is possible under certain conditions to get the recording system installed as a standard change (installation by a qualified maintenance engineer, without prior change approval6).
But isn’t it simpler to use portable equipment, rather than installing a Flight Recorder?
A portable GPS (Global Positioning System) /GNSS (Global Navigation Satellite System) receiver, an action camera or an app on a smartphone may be interesting occasionally (e.g. to replay the flight) but they usually don’t have an automatic start and stop logic: they rely on the pilot to start and stop the recording. Also the quality and the relevance of the data recorded by a recording system is often better than data recorded by portable equipment. From the perspective of an owner or operator, a recording system remains a more appropriate solution than portable equipment.
I am eager to install a Recording System. What functionalities do you recommend?
It is advised that the recording system records at least information sufficient to determine the flight path, the speed and the attitude (pitch, roll and heading). This can be captured by the means of a GPS/GNSS receiver, small accelerometers and gyros or by images of the flight instruments.
Information on the handling of the helicopter (such as the position of flight controls) and an external view often prove useful. This information can be captured by means of an integrated camera.
For flight parameters, a recording duration of at least 5 hours is advisable. If audio or images are recorded, a recording duration of at least 2 hours is advisable.
Means to retrieve data from the recorder should also be considered. In particular recorded flight parameters are worthy of being routinely analysed, which in turn means that their retrieval should be quick and easy. Wireless retrieval of recorded flight parameters from the aircraft is worth considering.
If I install a Recording System on my Light Helicopter, how do I deal with pilot privacy?
The EU rules for air operation contain requirements regarding the use of recordings of flight recorders. In essence:
- Recorded flight parameters can be used as long as the recordings are de-identified or disclosed under secure procedures.
- The use of recorded audio and recorded images are subject to more stringent protection due to their privacy content: a procedure related to their handling must be in place, pilots must have given their prior consent and the recordings can only be used by the operator for maintaining safety or ensuring the serviceability of the flight recorder7.
These requirements are only applicable to complex helicopters and to helicopters used for commercial operations.
However, the General Data Protection Regulation8 addresses the protection of personal data, and it is advised to consider this EU Regulation for any aircraft equipped with a recording system. In this Regulation, the most important principles to abide by are enumerated in article 5(1):
Personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
- collected for specified, explicit and legitimate purposes (…) (‘purpose limitation’);
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
- accurate and, where necessary, kept up to date (…) (‘accuracy’);
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (…) (‘storage limitation’);
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage (…) (‘integrity and confidentiality’).
Ensuring compliance with these requirements requires some initial time investment, but it then pays off by providing a robust framework and by facilitating acceptance of the recording system.
Am I creating new obligations for myself if I install a Recording System on my Helicopter?
The installation of voluntary equipment should not trigger additional requirements by your national aviation authority, except if needed to address a risk for safe flight and landing, for other airspace users or for persons or property on the ground. Hence in most cases it cannot be required that a voluntarily installed recording system is maintained serviceable or that it meets certain performance objective.
However, why bother carrying recording equipment if it is not serviceable? As explained earlier in this article, there are many potential benefits stemming from a recording system, provided that it works and that the recorded data are used.
Note: except in the case of a criminal investigation or of an ICAO Annex 13 investigation, the EU aviation rules do not entitle authorities to seize the flight recorder or its recordings.
Industry examples
On several light helicopter models, the installation of a flight recorder or a recording system is an option offered by the aircraft manufacturer. In addition, equipment manufacturers have already installed such equipment on many light helicopter models. Examples of helicopter models (illustrative and non-exhaustive list):
- Airbus Helicopters: H125, H135, EC120, EC130, AS350, AS355, EC135
- Bell: Bell 206
- Robinson: R22, R44, R66
New IHSF FDM toolkit launched
The IHSF have also released the Second Edition of the Flight Data Monitoring (FDM) Toolkit - you can download that from the IHSF website's technology resources.
References:
[1] The European Plan for Aviation Safety documents the coordination between EASA, European Union Member States and the European Industry to manage the safety risks for aviation in the European Union. This document is published on EASA website (https://www.easa.europa.eu/document-library/general-publications/european-plan-aviation-safety-2019-2023).
[2] The Rotorcraft Safety Roadmap is a strategy to reduce the number of accidents and incidents with helicopters in Europe. This document is published on EASA website (https://www.easa.europa.eu/download/Events/Rotorcraft%20Safety%20Roadmap%20-%20Final.pdf)
[3] Annex IV to Commission Regulation (EU) 965/2012 (‘Part-CAT’), CAT.IDE.H.185 to CAT.IDE.H.200 for commercial air transport, Annex VIII to Commission Regulation (EU) 965/2012 (‘Part-NCC’), NCC.IDE.H.160 to NCC.IDE.H.175 for non-commercial operations and Annex VII to Commission Regulation (EU) 965/2012 (‘Part-SPO’), SPO.IDE.A.140 to SPO.IDE.A.155 for specialised operations. A consolidated version of the EU rules for air operations can be consulted on EASA website (https://www.easa.europa.eu/document-library/general-publications/easy-access-rules-air-operations )
[4] Part-CAT, CAT.IDE.H.191 and Part-SPO, SPO.IDE.H.146.
[5] According to Part-CAT, CAT.POL.H.305, operations without an assured safe forced landing capability during the take-off and landing phases requires the implementation of a usage monitoring system.
[6] Certification Specifications for Standard Changes and Standard Repairs (CS-STAN), Subpart B (Standard Changes), CS-SC104a — Installation of lightweight in-flight recording systems.
[7] Part-CAT, CAT.GEN.MPA.195 point (f) and to Part-SPO, SPO.GEN.145 (f).
[8] Regulation (EU) 2016/679 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data. This Regulation can be consulted on EUR-Lex website (https://eur-lex.europa.eu/)