Call recording requirements at Flight Information Service (FIS) aerodromes

We proposed that the requirement for the recording of a Flight Information Service (FIS), currently mandatory within CAP 797, but recommended within CAP 670 are harmonised and that both documents make the requirement mandatory. 

We asked about the impact of this change and proposed that all units offering a FIS service ensure they are providing recording facilities within a reasonable time scale. 

We proposed that so called ‘Custom PC based’ solutions where recording software is employed on a standard desktop computer are permitted as a temporary measure, and that such systems could be used as an interim solution for up to 5 years, by which point an appropriately approved recording system should be installed.

We received 13 responses to our consultation.  8 from FIS units impacted and 5 from other stakeholders.  The majority of responses were in favour of the proposal, many appreciating the safety benefits such a requirement would bring, many identifying specific examples where the provision of recording has provided critical evidence or would have been beneficial if installed at the time.  A number of responses suggested that such recording should already be mandatory.  The addition of the availability of an audio recording when investigating an accident or incident brings significant evidence and reduces the reliance on evidence from memory.  Many responses appreciated the additional protection this brings for FISO staff.

Specific feedback included:

• Concern that the requirement for minimum specifications would add additional cost.  The CAA believe that a set of minimum specifications is critical to ensure interoperability when playing back recordings and ensures that the recording recovery team can interpret recording files.  Additionally a minimum set of requirements also ensures the credence of recordings which is a critical factor in the protection and retention of evidence.
• Another response highlighted the additional cost of recording land lines due to the technical complexities and differences in recording differing telephone systems.
• One response highlighted the requirement for a safety case and the burden this places on units that will have to produce it.
• A number of units expressed concern regarding the immediate cost of such a system and the continued maintenance cost of such equipment, along with the additional costs due to the requirement to ensure equipment is appropriately accommodated and powered.

Following feedback we are maintaining our proposed approach, in light of some specific elements of the feedback we have made some minor modifications to the proposal and are investigating ways in which we can reduce the burden on individual units who have to install equipment.

As proposed in the consultation, The CAA will not require a full solution to be installed immediately, and for an interim period a PC based solution will be permitted.  Our research has shown that such a system can be purchased at a cost of between £600 and £1000 with little requirement for ongoing maintenance.  This system can be used for up to 5 years before a full system is required.  We believe this is a compromise that will allow time for units to establish funding for equipment whilst maintaining momentum behind the adoption of recording.  It also addresses units that have already made the investment in a PC based system and ensures a reasonable duration of use is achieved from such systems.  This time scale also considers the approaching introduction of the ATM-IR, which is likely to mandate recording of FIS.

The CAA understands that maintenance costs can be kept low and that some manufacturers offer maintenance packages as low as £400 per year.  Whilst the requirement will add some additional costs we believe the ongoing costs that would be passed onto the flying public are acceptable and that the safety benefits of mandating recording outweigh the financial impact.  As discussed within the original consultation, we are aware that a significant majority of FIS units already record radio transmissions.

We have reviewed the requirement for the recording of telephone systems and will modify this requirement to be highly recommended to reflect the considerable costs that could be incurred by having to record a wide range of different systems including VOIP (Voice Over Internet Protocol). 

Overall following feedback we believe the introduction of recording for FIS and the harmonisation of requirements as discussed in the consultation is beneficial for all.

What happens next?

Our intention, following this consultation is to update the relevant documentation to clarify this requirement.  As originally indicated, it is our intention to require all FIS units to provide recording services through appropriate recording equipment within 1 year, this includes the use of a custom PC based recorder, provided it is configured as required by the consultation document.  Finally, within 5 years recording should be provided through the use of appropriately approved systems (as specified within CAP 670).

Please Note:

Please note that the introduction of Regulation 2017/373 (ATM-IR)  may have an impact on the equipment requirements in future.  The CAA will provide updates on the rule making process as it progresses.  Any units making a purchase of equipment are recommended to discuss their requirements with the CAA so the latest information can be considered.