5.6. Voice and data recording

Regulation (EU) 2017/373 [4] specifies recording requirements for aeronautical mobile service (air-ground communications) (ATS.OR.400 (b) and ATS.OR.455 (a)), aeronautical fixed service (ground-ground communications) (ATS.OR.435(c) and ATS.OR.455(a)(2)), surface movement control service (ATS.OR.445) and aeronautical radio navigation service (ATS.OR.450 and ATS.OR.455). Furthermore, ‘Note 1.’ to ICAO Doc 4444 [14] Chapter 7.1.1.2.1 (introduced by ‘Amendment No. 8’ applicable as of 8 November 2018) clarifies that ‘For the purposes of automatic recording of visual surveillance system data, Annex 11, 6.4.1 applies’.

The philosophy of the EU provisions is to record and retain all data used to support the provision of ATS — and in a way that the recorded data is the same as or at least similar to the information presented to the ATCO/AFISO. For the particular case of remote aerodrome ATS, the recording and retention of data should therefore be extended to include constituents specific to remote aerodrome ATS, including the visual presentation, the binocular functionality and other technical support systems such as the aerodrome sound reproduction (if implemented). The data recorded should be normally recorded from two sources:

— data obtained from the sensors directly or through the network (through the wall),

— data recorded as seen by the ATCO/AFISO on the screen, captured by a screen capture device(at the glass).

With reference to the above, it is recommended that the image presented to the ATCO/AFISO (i.e. the processed data presented to and used by the ATCO/AFISO as support in their decision-making, including both the view of the aerodrome and its vicinity, as well as any overlaid data/information/decision support; sometimes referred to as ‘screen recording’), is recorded and retained to support an effective accident and incident investigation^[29].

When recording the image as presented to the ATCO/AFISO, it is implicit that the image is recorded with the same picture quality as presented/used in the system (number of pixels, frame rate, etc.).

Additionally, the recording and retention of the aerodrome sound reproduction data (as presented/reproduced to the ATCO/AFISO) should also be considered, if such functionality has been implemented (refer to Section 5.4.). Note that Regulation (EU) 2017/373 [4], ATS.OR.460 stipulates recording of background communication and aural environment at ATCO/AFISO workstations (and retention of the last 24 hours of operation), unless otherwise prescribed by the competent authority. Meeting the requirement under ATS.OR.460, it is likely that the aerodrome sound reproduction will be recorded/captured inherently.

It should be noted that integrity issues may result from the recording and retention of optical/video/sound data from public spaces (which could be the case for an aerodrome, depending on the national legislation). Such integrity and privacy issues are different from state to state depending on national integrity and surveillance legislation and would need to be taken into account.