Type IVA FDRs JAR-OPS 3

2. Type IVA FDRsJAR-OPS 3 OST WP-04-07 HSST WP-06/3.7

3. Requirement • The Type IVA FDR is mandated by ICAO Annex 6 Part III Section II • Helicopters with a maximum certificated take-off weight in excess of 3180 (3175) kg • With the first individual certificate of airworthiness issued after 1st January 2005 • The Type IVA FDR can capture an increased range of data derived from the most recent developments in helicopter technology and avionics with up to 47 parameters being recorded • JAR-OPS 3 does not yet cover this requirement

4. Background • After the completion of the approval process of NPA OPS-25, the OST tasked the Flight Recorder Study Group (FRSG) to introduce the new ICAO flight recorders standards for helicopters into JAR-OPS 3 • This was conducted and WP FRSG 03-04 was produced • WP not progressed • OST Action 06-2/23 tasked HSST with EQSG • Significant updating completed by HSST with agreement of EQSG to produce WP-06/03.7 • Considerable liaison with ICAO FLIRECP conducted

5. Draft NPA Proposal to amend JAR-OPS 3 to align with ICAO Annex 6 Part III Section II in requiring an enhanced level of parameters to be recorded by FDRs and also to incorporate consequential changes. This will require the fitment of a FDR with at least Type IVA capabilities.

6. Harmonisation • The proposal will bring JAR-OPS 3 in line with FAR Part 135 and ICAO Annex 6

7. Proposal • Introduction of a new requirement (3.712) and associated Appendix and ACJ • Significant number of consequential changes to both Section 1 and 2 and corrections following previous amendments

8. Main Amendment JAR-OPS 3.712 Flight Data Recorders –1 (See Appendix 1 to JAR-OPS 3.712) (See ACJ OPS 3.712)  (a) An operator shall not operate a helicopter first issued with an individual Certificate of Airworthiness on or after 1st January 2010 which has a maximum certificated take-off mass over 3175 kg unless it is equipped with a flight data recorder that uses a digital method of recording and storing data and a method of readily retrieving that data from the storage medium is available.  (b) The flight data recorder shall be capable of retaining the data recorded during at least the last 10 hours of its operation.  (c) The flight data recorder must, with reference to a timescale, record:  (1) The parameters listed in Table A of Appendix 1 to JAR-OPS 3.712  (2) Any dedicated parameters relating to novel or unique design or operational characteristics of the helicopter as determined by the Authority during type or supplemental type certification.

9. Options • Option 1. - Do nothing. • This would result in the loss of the safety benefits accruing from the superior range of flight data parameters available from the Type IVA FDR, over the Type IV or Type V FDR • JAA Member States would not be in compliance with ICAO and would have to file a difference

10. Options • Option 2. - To mandate the recording of the enlarged range of flight data parameters necessitating the fitting of Type IVA FDRs according to the timetable specified by ICAO Annex 6 Part III Section II. • This course of action would avoid the unsatisfactory effects of Option 1, but would, inevitably, involve the operators of existing aircraft in the considerable expense involved in upgrading from the current requirement of a Type IV or Type V recorder

11. Options • Option 3. - To mandate the recording of the enlarged range of flight data parameters necessitating the fitting of Type IVA FDRs to affected helicopters first issued with an individual CofA on or after 1 January 2010 and, thereby, avoid retro-fitment to existing aircraft. • This would result in the avoidance of significant expense for operators of existing aircraft, whilst mandating the fitting of Type IVA FDRs to all affected new aircraft. However, helicopters first issued with a Certificate of Airworthiness between 1 Jan 05 and the proposed JAR-OPS 3 implementation date of 1 Jan 10 would not be ICAO compliant and, consequently, JAA member states would require to file a difference with ICAO. • This is the preferred Option

12. Impacts • Helicopter operators purchasing affected new aircraft • They would be spared the high costs of retro-fitting existing fleets • Helicopter manufacturers would be affected by having to install Type IVA FDRs during the manufacture of all affected new aircraft • Economic effect likely to be neutral • Accident Investigation • Likely improvements in identification of cause

13. Consultation • Considerable consultation was conducted by the FRSG/ HSST / EQSG in drafting this NPA including liaison with representatives of the FLIRECP • The primary consultation prior to the adoption of the JAR will be through the NPA process. (JAR 11.065).

14. Summary and Final Assessment • The proposed changes to JAR-OPS 3 will ensure alignment with the ICAO Annex 6 • The retro-fitting of helicopters first issued with Cs of A after 1st January 2005 (Annex 6) would be largely impracticable and would involve unreasonable expense • The preferred option is to mandate the fitting of Type IVA FDRs in helicopters first issued with an individual Certificate of Airworthiness on or after 1st January 2010