Recommendation

The Civil Aviation Safety Authority will analyse the cost
benefit of the recommendation regarding the carriage of on-board
recording devices to this type of operation

On the issue of on board recording devices, this is a cost and
maintenance burden with existing equipment. Low cost/new technology
units are not currently available.

CASA will continue to monitor this.

In reference to ATSB recommendation R20060004 (issued following
the Benalla accident) on page 34 of the draft report [relating to
200502662]:

The Australian Transport Safety Bureau recommends that the
Civil Aviation Safety Authority (CASA) review the requirements for
the carriage of on-board recording devices in Australian registered
aircraft as a consequence of technical developments.

As you are aware, on 11 May 2006 CASA advised of an intention to
conduct a cost/benefit analysis of the recommendation regarding the
carriage of on-board

recording devices to this type of operation.

I understand that CASA has previously investigated this matter
and, based on the equipment available at the time, could not
justify mandating carriage of recording devices on low capacity
aircraft. However, given other priorities, this has not yet been
confirmed by way of a cost/benefit analysis.

I have now directed that a cost/benefit analysis be undertaken.
I expect to have a result before the end of the year and will
forward the results to you.

I refer to the letter dated 11 October 2007 from the Deputy
Director, Information and Investigations to General Manager,
Corporate Relations[CASA], enclosing an advance copy of amended
Transport Safety Investigation Report on the fatal accident
involving a Piper PA-31-350 aircraft registered VH·PYN, which
occurred near Condobolin, New South Wales on 2 December 2006.

The draft Cost Benefit Analysis for on-board recording devices
will be completed by the end of this week [21 Dec 2007].
Consideration of this is to be completed and CASA will write to you
again by the end of January 2008.

ATSB Note:

On 31 January 2008, CASA advised that the cost benefit analysis
was being evaluated.

I refer to my letter of 7 September 2007 regarding the
Australian Transport Safety Bureau (ATSB) Recommendation R20060004
relating to the Civil Aviation Safety Authority (CASA) reviewing
the requirements for the carriage of on-board recording (OBR)
devices in Australian registered aircraft.

As you would be aware, there has been extensive liaison between
CASA and the ATSB on this matter over the last twelve months. I can
now advise that CASA has completed its cost benefit analysis (CBA).
The CBA results confirm CASA's initial view that there is no
justification to mandate the carriage of recording devices in
smaller aircraft. The analysis considered 7 categories of small
aeroplane operations, from Low Capacity RPT and Charter, down to
aerial work, business and private operations and did not find
fitment justified on safety grounds.

CASA believes that the safety regulator's focus should be on
passenger carrying operations and preventing accidents by fitment
of new generation technologies such as Airborne Collision Avoidance
Systems, Terrain Avoidance and Warning Systems and Automatic
Dependent Surveillance Broadcast equipment, rather than mandating
fitment of OBR devices to assist in determining the cause of an
accident.

The CBA determined that the industry was unlikely to make this
investment on its own accord. The use of quick access recorders by
larger airlines provides considerable economic and business
benefits which outweigh the costs involved. With the recent
emergence of low cost and light weight recorders for small aircraft
it is expected that the take up of recorders may gather momentum
over the next couple of years once suppliers become more active in
the market and prices come down. In the interim, CASA will be
monitoring voluntary fitment of OBRs.