IAOPA Comments on AN-WP/8152, Search and rescue requirements for ELTs and communications
While the working paper sets forth the response and desires of many states with regard to ELT installations, it is felt that these comments may not have had the benefit of some essential facts. Some of the more pertinent facts are shown below.
IAOPA does not oppose the carriage of survival beacons where there is a clear need for doing so, such as operations over terrain where SAR would be difficult or over extender over water flights. Yet, the practicalities of funding and equipping the worldwide fleet of general aviation aircraft brings a significant expense to aircraft owners and may not be possible in the time allocated, due to aircraft maintenance organization capacity.
Significantly, the international introduction of more than 100,000 personal locator beacons (PLB), approved by both COSPAS-SARSAT and states alike, provides a suitable alternative to ICAO ELT requirements for light general aviation aircraft. This is a proven device.
We are still disappointed that GA aircraft operating internationally must carry a 406 ELT even if they will be operating over benign terrain. The original requirement to be equipped only if operating over extended over water areas or those considered difficult for SAR made very good sense. Many border crossings are over territory considered benign even for all types of GA aircraft.
Airliners and large general aviation aircraft possess the speed and range to operate over a variety of challenging environments during a single flight; light general aviation aircraft (under 5,700 kgs MTOM) do not have this capability. Since their performance does not permit wide-ranging operations in a single flight, ELT carriage requirements for all international operations has little meaning.
Carrying a survival beacon on cross-border flights that feature no challenging terrain or extended over water flying is like requiring the carriage of life vests for all flights, since an aircraft may crash in a lake rather than on dry land.
Comments made in the referenced working paper indicate that a 406 MHz ELT may be purchased for less than US$1,000 and installed for approximately $1,500. While this may be true in North America, the installed price in many areas of the world may easily be twice that figure. Since few of the world's 370,000 general aviation aircraft are currently equipped with the 406 MHz ELT, equipping the fleet at a conservative $3700 per aircraft will require well over $1 billion.
Importantly, there is probably insufficient capability among either equipment manufacturers or aircraft maintenance organizations to build and install that many ELTs over the next two years. While not all aircraft will choose to equip with this device due to their limited scope of operations, the financial impact on aircraft owners will be considerable, especially for those operating older, lower value aircraft. This equipage requirement will effectively limit the scope of operation of many general aviation aircraft.
Our major disappointment is not being permitted to choose a personal locator beacon (PLB) over an ICAO approved ELT. Equipping an older aircraft with an expensive "ELT of any type" means that a portable, fixed or automatic device is acceptable. If it is a portable device, it is not an integral part of the aircraft and not necessarily subject to ICAO standards. Rather, if a portable device meets the COSPAS-SARSAT standards it should be satisfactory as a portable device.
If a portable survival beacon meets the "Specification for COSPAS-SARSAT 406 mhz Distress Beacons, C/S T.001" and is approved in accordance with "COSPAS-SARSAT 406 mhz Distress Beacon Type Approval Standard, C/S T.007," it makes little difference whether it meets either RTCA DO-204 or Eurocae ED62 standards for ELTs.
- Faulty or poorly designed installation of the ELT, associated wiring or the fixed antenna (the ELT built-in self-test feature will not reveal these faults)
- Covering of the antenna by aircraft wreckage after the crash
- Poor post-crash orientation of the fixed antenna
Each of these faults may be mitigated by use of a portable ELT or PLB not subject to installation error or post-crash fixed antenna problems. In the post-crash phase survivors will be equally able to activate a PLB as they will a portable ELT, especially in smaller aircraft.
Approved PLBs have saved many lives since their introduction a few years ago. These wonderful devices meet the spirit and intent of the ICAO ELT provisions and should be permitted to be used as an alternative to those specified in this proposed change.
Modify the Annex 6, Part II ELT equipage requirements to;
- Be required only when operating in areas where SAR is considered difficult, and
- Permit the carriage of an approved PLB for aircraft with a MTOM of less than 5,700 kgs.as an alternative to the existing ELT requirement.