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Photo of CVR from NTSBThe NTSB is again calling on the FAA to mandate that all existing planes that require a cockpit voice recorder and flight data recorder be retrofitted with devices capable of recording 25 hours of audio instead of the standard two hours. The agency commented on the FAA's Notice of Proposed Rulemaking to extend the CVR requirement on all new aircraft, asking that the ruling extend to existing airplanes.
Since 2018, the NTSB has been pushing for a revision of flight recorder systems on aircraft, citing many investigations that have been hindered due to overwritten data. Current devices record two hours of data before being overwritten. On Nov. 30, 2023 the FAA announced its proposal to extend the CVR requirement to 25 hours for all newly manufactured aircraft. The FAA announced its plans to align with rules and standards in place in Europe and at the International Civil Aviation Organization, but the proposal does not extend to the current fleet, even planes that will be in service for decades. While the NTSB said it is pleased the FAA is proposing to implement the action called for by its Safety Recommendation A-18-030, it is disappointed the NPRM does not introduce a similar requirement to retrofit existing planes, as recommended in Safety Recommendation A-18-31.RELATED STORIES:Tennessee Congressmen submit comments on FAA proposed rule extending CVR requirementFAA follows NTSB recommendation, proposes requiring 25-hour cockpit voice recordersFAA proposes CVR recording extension, response to NTSB 'Most Wanted' list of recommendationsThe NTSB challenged the FAA's assertion that retrofitting the entire fleet is too expensive, stating a retrofit would apply to roughly 13,500 aircraft, less than half of the 29,561 the FAA had estimated in its cost/benefit analysis. The estimate includes non-military, turbine-powered multiengine in-service planes on the U.S. registry with 10 or more passenger seats. The comments given by the NTSB also noted that the FAA did not address how many planes would be retired, scrapped or removed from the U.S. registry during the 5-year retrofit period estimated in A-18-31. The 5-year retrofit period also allowed operators to schedule the CVR replacement during regular CVR maintenance, further reducing compliance costs.
The initial recommendation was made in 2018 after a 2017 incident in which an Air Canada Airbus A320 lined up to land on a taxiway occupied by several aircraft, descending below 100 feet above ground level before starting to climb. The CVR data was overwritten before the Air Canada officials learned of the severity of the incident, prompting A-18-30 and A-18-31. The NTSB also identified 33 other events where CVR data was overwritten because of a delay between the event and the flight crew recognizing it to be a serious incident or accident, or the flight continued to operate for more than two hours after the event took place. Since the two recommendations were issued, at least 14 other investigations have been hindered by a lack of CVR data that was overwritten, including seven serious runway incursions in 2023 and the rapid depressurization event on an Alaska Airlines 737-9 MAX flight on Jan. 5.RELATED STORIES:Boeing 737 MAX 9 was missing bolts before depressurization eventLatest on 737 MAX 9 Alaska Airlines emergency - aircraft had prior issues before panel ripped off mid-flight
"In the recent Alaska Airlines door plug blowout accident, our investigators don't have the CVR audio to fully understand all of the challenges the flight crew faced in response to the emergency," NTSB Chair Jennifer Homendy said. "Any investigation in which the CVR audio is overwritten and unavailable to us, means that we may miss opportunities to address safety issues identified on recordings. And that's unacceptable."
CVR data allows investigators to gain better insight into what transpired in the cockpit before an incident. A longer duration for CVR recordings will provide authorities with better information on events and procedures in the flight deck and improve investigations.
"CVRs are among the most valuable tools for accident investigation because they provide contemporaneous information on flight crew intentions and coordination as well other factors, such as procedural compliance, workload, fatigue, and situational awareness," NTSB Office of Aviation Safety Director Tim LeBaron said. "This information is critical to our ability to conduct more thorough investigations and target safety recommendations more effectively."
The NTSB said it cannot fully support the proposed rule in its current form. The agency believes the FAA should include a requirement to retrofit existing planes, stating that the retrofit requirement would apply to less than half the number of planes the FAA estimates. Additionally, the five-year retrofit period would allow operators to update CVRs during regular maintenance, leading the NTSB to believe the FAA has inappropriately estimated the retrofitting cost. The NTSB is urging the FAA to reconsider its position and issue a final rule applicable to both newly manufactured planes as well as existing planes that are required to carry a CVR and FDR.