ATM Modernization, Commercial, Embedded Avionics

FAA Seeks Comments on Updated DLC Recording Policy

By Woodrow Bellamy III  | March 16, 2015
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[Avionics Today 03-16-2015] Airlines and operators could soon have an easier path toward equipping their aircraft for air traffic Data Link Communications (DLC) under the FAA's requirements. The agency has requested comments on an updated policy that would clarify airworthiness requirements through June 1 for DLC recording. 

Boeing 737. Photo: Boeing.

The policy clarification, if eventually adopted in the rulemaking process, refers to an update to several amendments promulgated to the airworthiness regulations for Cockpit Voice Recorders (CVR) and Digital Flight Data Recorders  (DFDR) originally published in 2008. Back then, the FAA started requiring DLC sent to or from an aircraft to be recorded if DLC equipment is installed on the aircraft. Those change were based on recommendation issued by the National Transportation Safety Board, intended to improve the quality and quantity of information recorded and retained for accident and incident investigations. The rule became effective on Dec. 6, 2010. 

According to the policy clarification issued by the FAA in the federal register on March 2, since 2010 "implementation of the Controller Pilot Data Link Communications (CPDLC) recording requirement has become more complex than anticipated." Most notably, aircraft manufactured prior to the effective date, require "widely varying levels of additional CPDLC equipment or software to be fully functional."

The data link recording rule is the number one issue preventing operators from retrofitting their legacy aircraft with the CPDLC or FANS 1/A avionics that would allow them to perform data communications between their pilots and air traffic controllers," Armin Jabs, president of International Communications Group (ICG) Commercial Aircraft Systems division, told Avionics Magazine. ICG is a manufacturer of Iridium satellite data units with its NxtLinkSeries of flight deck communications systems. ICG also participates in the major industry forums leading the way towards global Data link ATS communications;  groups such as the Data link Users Group (DLK), FAA  Performance Based Operations Rulemaking Committee (PARC),  and various RTCA committees.

In October 2014, PARC submitted a report to the FAA determining whether datalink recording is required on individual aircraft manufactured before Dec. 6, 2010 is preventing operators from installing DLC avionics on their aircraft. This is thwarting equipage despite the safety benefits that FAA research shows from the implementation of the two primary DLC systems: the Future Air Navigation System (FANS 1/A) CPDLC, and Automatic Dependent Surveillance-Contract (ADS-C). 

Specifically, the ability for pilots and Air Traffic Controllers to send reviewable messages helps reduce verbal communication errors, such as "read-back and hear-back, and audio interruptions," according to the FAA. However, the expensive cost of installing a datalink recording capability on an aircraft that does not feature the capability right off of the production line is preventing many operators from upgrading, PARC found.

"PARC took the initiative to send recommendations to the FAA to change this rule," said Jabs. "Our first recommendation was to better clarify when an airline had to upgrade their system for data link recording, which is one of the single most expensive aspects of outfitting for FANS."

According to the FAA's federal register notice sent out to operators and manufacturers with its proposed intention to change the rule, the reported cost of installing the datalink recording functions is $135,000 per aircraft. Among the equipment required is CVR hardware, a CVR control panel, a new Communications Management Unit (CMU), CMU software, wiring and installation labor among other equipment.

"The operators couldn’t make a business case for enabling FANS anymore," said Anthony Rios, vice president of sales at Avionica, a Miami, Fla.-based manufacturer of airborne satellite communications hardware. "The report released by the PARC recommended that, in order to have these particular operators participate in FANS, some interpretation of the 2008 rule should be published so that it alleviated the requirement to install datalink recording on those aircraft if they wanted to activate the FANS capability.

Now, the FAA is seeking industry comments on an updated policy statement that it is proposing to clarify when an aircraft is required to have the datalink recording capability installed. Effectively, the updated policy statement would require only those airplanes or rotorcraft manufactured on or after the effective date, Dec. 6, 2010, to record all DLC when the following conditions are met:

1. The aircraft is required to have both a cockpit voice recorder and a flight data recorder

2. The aircraft has datalink equipment installed that uses an approved message set

Additionally, aircraft manufactured before the effective date must record all DLC when the following conditions are met:

1. The aircraft is required to feature both a CVR and FDR.

2. The aircraft did not have any certified DLC equipment installation design approval prior to the effective date of Dec. 6, 2010.

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