In response to Transport Canada's notice of a proposed amendment (NPA) to require the installation of lightweight flight data recorders (LDR) on virtually all general and business aviation aircraft registered in Canada, a number of alphabet aviation organizations have raised issues about the feasibility of the proposal. Those concerns were raised by the General Aviation Manufacturers Association (GAMA) and through a joint submission by the Canadian Business Aviation Association, Canada Owners and Pilots Association, Helicopter Association of Canada, and several other aviation trade organizations.
Because information from flight recorders can reveal information that accident investigators would not otherwise have learned, the organizations said they might consider supporting a flight recorder equipage mandate if it provides for compliance flexibility, alternate means of compliance, minimizes costs and unnecessary burdens on manufacturers and aircraft operators, is not a one-size-fits-all approach, and is harmonized with globally accepted standards. But this proposal does not meet any of those conditions, according to the organizations.
If Transport Canada determines to promulgate a final rule in this proceeding, GAMA “respectfully urges Transport Canada to adopt a flexible performance-based and risk-based standard that considers the type of operation, passenger capacity, whether or not the operation is conducted over water, related risk factors, and that also permits operators to implement alternative methods of capturing information about an accident flight.”
In sum, the organizations recommended that Transport Canada “temporarily suspend or rescind the NPA until all the issues are analyzed and addressed.”