Revised IGC-approvals for some types of legacy recorder

Mike Borgelt wrote:
On Tue, 18 Nov 2003 05:39:03 GMT, Marc Ramsey wrote:
I'd make the simple point that if RSA was required when the first flight
recorder specification was issued in 1995, there were no existing flight
recorder designs which could have been approved.


So what? If RSA had been required at that time there soon would have
been.

I wasn't involved at the time, but the reason appears fairly obvious to
me, it's called "jump-starting a market" over here.

RSA (or equivalent
asymmetric algorithm) has been required for "all flights" approval since
1997, I believe...

So it has been perfectly acceptable to fly world records for the last
5 to 6 years without RSA security with loggers approved before 1997.

Yes.

If lack of RSA security was an issue why weren't legacy loggers given
say 12 months to comply or lose "all flights" approval back in 1997?

The only alternative available at the time was the Diamond-level
approval. I can imagine the outrage of the early adopters when told
they would need to spend more money to upgrade their already expensive
boxes a couple of years after they bought them. Mike, you know as well
as I do that most of those early designs would need a board swap to be
able to adequately handle RSA and the like.

Why the change now?

Would someone tell us why this is suddenly an issue?

The gap between what is needed to be approved now, and what was needed
back then, is just too large. Among other things, it is unfair to those
who are trying to get new designs approved to have to compete against
'grandfathered' designs.

Which world record flights are suspect?

None that I am aware of. Would you prefer to wait until there were some
before an effort is made to shift the flight recorder requirements
toward those currently required for approval?

Isn't it a remarkable coincidence that this action is being taken
right after CAI Model 20 and 25 loggers are no longer in production?

As far as I know, they are still considered to be "in production".

So a would a new design without RSA security would be acceptable for
all but World Records?

If not, why not?

The whole point behind adding the all badges/diplomas approval was to
allow more sensible security requirements for flight recorders used to
document flights other than world records. If you have something
specific to propose, you are welcome to contact GFAC for a formal answer.

Marc

On Tue, 18 Nov 2003 08:38:21 GMT, Marc Ramsey wrote:

The gap between what is needed to be approved now, and what was needed
back then, is just too large. Among other things, it is unfair to those
who are trying to get new designs approved to have to compete against
'grandfathered' designs.

And it has been since the RSA security requirements were introduced in
1997. Why is it suddenly so unfair now after 6 years ?


The whole point behind adding the all badges/diplomas approval was to
allow more sensible security requirements for flight recorders used to
document flights other than world records. If you have something
specific to propose, you are welcome to contact GFAC for a formal answer.

Marc

I think you need to read the r.a.s. archives before making statements
like this. All of the above was done by myself and others when the F.R
proposals were first mooted but all were ignored
You are either ignorant of what really happened or being deliberately
obtuse. I suggest you do a google search for r.a.s. for IGC flight
recorders.

You had better privately ask Mr Strachan about the meeting at Lasham
at which reasons were invented not to approve loggers which met the
rules as written and approved by the IGC at the time. Ask him who most
of the participants had business associations with either before, at
the time or subsequently. Also ask where the principal of that
business was at the time.

The history of F.R.s on the FAI site is inaccurate as it omits these
details and others.

How about a straight answer in public to - is it the intention of GFAC
to approve new designs for "all but World records category"?

I'm sure GFAC have a policy, it may just not be the written down
official one based on past history.


p.s.

"jump starting the market" in that way as you put it would most
likely contravene the Trade Practices Act (1974) in Australia and land
you with a large fine. Ask the freight companies who were fined after
the ACCC(Australian Consumer and Competition Commission) used an
electronic barograph to prove that goods being sent by "airfreight"
were in fact going by truck between Brisbane- Sydney- Melbourne.

Mike Borgelt

Borgelt Instruments

Mike Borgelt wrote:
And it has been since the RSA security requirements were introduced in
1997. Why is it suddenly so unfair now after 6 years ?

A) There is now a better (for the pilots) option than a downgrade to
Diamond-level approval, and B) the process was only approved by the IGC
this year.

I think you need to read the r.a.s. archives before making statements
like this. All of the above was done by myself and others when the F.R
proposals were first mooted but all were ignored
You are either ignorant of what really happened or being deliberately
obtuse. I suggest you do a google search for r.a.s. for IGC flight
recorders.

As you well know, I was not a member of GFAC at that time. Anything I
state about then (or now, for that matter) is simply my opinion. If you
want the official word, you know how to contact Ian.

How about a straight answer in public to - is it the intention of GFAC
to approve new designs for "all but World records category"?

Obviously yes, since there is a new design (THEMI) that is approved in
this category.

I'm sure GFAC have a policy, it may just not be the written down
official one based on past history.

There is no written policy at this moment, as the category is less than
a year old, and it's not clear whether any other manufacturers will make
use of it. The whole point is to keep it fairly flexible, so those who
can't or won't go for all flights approval have another category to work
with.

"jump starting the market" in that way as you put it would most
likely contravene the Trade Practices Act (1974) in Australia and land
you with a large fine. Ask the freight companies who were fined after
the ACCC(Australian Consumer and Competition Commission) used an
electronic barograph to prove that goods being sent by "airfreight"
were in fact going by truck between Brisbane- Sydney- Melbourne.

I have no idea what you are talking about.

Marc

On Wed, 19 Nov 2003 04:24:46 GMT, Marc Ramsey wrote:




There is no written policy at this moment, as the category is less than
a year old, and it's not clear whether any other manufacturers will make
use of it. The whole point is to keep it fairly flexible, so those who
can't or won't go for all flights approval have another category to work
with.

Great. What you mean is that any manufacturer could be screwed around
by the GFAC as there is no publicly stated, openly available policy.
It has happened before.

"jump starting the market" in that way as you put it would most
likely contravene the Trade Practices Act (1974) in Australia and land
you with a large fine. Ask the freight companies who were fined after
the ACCC(Australian Consumer and Competition Commission) used an
electronic barograph to prove that goods being sent by "airfreight"
were in fact going by truck between Brisbane- Sydney- Melbourne.

I have no idea what you are talking about.

Writing a specification around one manufacturer's product, approving
that product and others from the same manufacturer and then changing
the rules for new entrants into the market to make it more difficult
and expensive for them while still leaving the old rules for the
original manufacturer's products would be not only considered
unethical in Australia but most likely illegal. The ACCC does have
teeth and uses them regularly.


Mike Borgelt

Hi,
let me try to add my 2cents to this thread. We should not see proposed
modification as downgrade of approval level for particular flight recorder
but rather as an increase of security measure for particular type of flights
(e.g. world records). And some of approved flight recorders do not meet
these requirements.

Seeyou
Erazem

"Mike Borgelt" wrote...
Great. What you mean is that any manufacturer could be screwed around
by the GFAC as there is no publicly stated, openly available policy.
It has happened before.

Clearly, the requirements will be somewhere in the continuum between
Diamond-level and all flights approval. What isn't clear (in my opinion,
anyway) is exactly where those requirements should ultimately be positioned.
Discussions with those seeking to gain approval in this category is one way
this positioning could be determined.

Writing a specification around one manufacturer's product, approving
that product and others from the same manufacturer and then changing
the rules for new entrants into the market to make it more difficult
and expensive for them while still leaving the old rules for the
original manufacturer's products would be not only considered
unethical in Australia but most likely illegal. The ACCC does have
teeth and uses them regularly.

I see flight recorders from 5 different manufacturers which received all
flights approval under the original specification. All of those recorders
will be reduced to badge/diploma approval as of 1 January 2004 (with one
possible exception, which is under review). All manufacturers who submitted
new models after the change were required to have them meet the new
requirements for full approval, including those who had older models
approved under the old requirements. The recorders approved since the
requirement change are, almost universally, lower in price than those that
were approved under the earlier requirements. I still fail to see your
point.

Marc