FAA-02-11705

FAA-02-11705

Airbus

FAA-02-11705	February 26, 2002	Petition for Rulemaking	Digital flight data recorder parameters
		Appendix - Suggested regulatory language to effect requested changes

Petition of Airbus for rulemaking to modify certain detailed data recording requirements for several digital flight data recorder parameters on Airbus airplanes.

By: Airbus, Wolfgang Didszuhn, 202.331.2239

Airbus

OST-02-11705

April 22, 2002

Notice of Petition for Rulemaking Received; Request for Comments

Airline Operations - Digital Flight Data Recorder

Although not required under part 11 of Title 14, Code of Federal Regulations (14 CFR), this document contains a summary of a petition for rulemaking to amend certain requirements of 14 CFR. While the FAA considers the best course of action on this matter, we believe the public should be made aware of this petition for rulemaking, and we specifically request comments from other aircraft manufacturers who may be experiencing problems similar to those encountered by the petitioner, Airbus. Neither publication of this document nor the inclusion or omission of information in the summary is intended to affect the legal status of any petition or its final disposition. The facts presented in this summary are as presented by the petitioner. DATES: Comments on petitions received must identify the petition docket number involved and must be received on or before May 22, 2002.

By: Forest Rawls

Airbus

FAA-02-11705

May 22, 2002

Request of Boeing for an Extension to File Comments

Airline Operations - Digital Flight Data Recorder

By: Boeing, Jim Draxler

Airbus

FAA-02-11705

June 13, 2002

Comments of Boeing

Airline Operations

Boeing concurs that the requested revisions to the parameter 83 and parameter 84 resolutions are minor and would not significantly affect the ability of accident investigators to perform their investigation. However, Boeing questions the need to revise the accuracy requirement for parameter 88.

In general, the Boeing design for the rudder pedal system is similar to the Airbus design. As we have discussed with both the FAA and the National Transportation Safety Board (NTSB), the rudder pedals in Boeing airplanes can be adjusted to accommodate the height of the pilot, and the force data can vary with respect to the position of the pedal. However, Boeing has not attempted to address this with respect to accuracy requirements. The Airbus interpretation of parameter accuracy appears to be total system or end-to-end accuracy. Boeing does not agree with this Interpretation, and notes that the term "Sensor Input," as stated In the "Accuracy" column in Appendix M to 14 CFR Part 121, does not support Airbus' interpretation of total system accuracy.

Boeing's interpretation had been discussed with the FAA and NTSB during the development and certification of parameters to comply with parameter 88 of §121.344. Both the FAA and NTSB concurred with Boeing's interpretation of accuracy as being applicable to the sensor only. Boeing suggests that it would not be appropriate to make changes to the regulations to address issues related to this item, as we have already implemented on multiple Boeing airplane models a force parameter recording scheme that is based on the previously agreed-upon interpretation.

By: Boeing Commercial Airplanes, Jim Draxler