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COPA opposes mandatory 406 MHZ ELTs

 

Would you be in favour of paying $5,000 or more to install a new Emergency Locator Transmitter (ELT) in 2009?

If not, how will you be found should you go down after 2009 when satellite monitoring of 121.5 MHz no longer exists? That is the dilemma facing every aircraft owner if Transport Canada decides to adopt an ICAO requirement, originally proposed in 1998 and actively opposed by COPA since that time.

This article summarizes the history of the issue, explains why COPA opposes any mandatory requirement and highlights options COPA is advocating for with the government for more realistic, affordable ways to find downed aircraft.

The issue began in 1998, when ICAO was proposed to shut down satellite monitoring of 121.5 MHz and require all aircraft to equip with new ELTs (meaning attached to the aircraft so that they can be automatically activated using a G switch), transmitting on 406 and 121.5 MHz.

Satellite monitoring of 406 was already in place. All new aircraft would equipped starting in 2001, existing aircraft would convert in 2003 and satellite monitoring on 121.5 would discontinue in 2005.

The reason for the change was to reduce the number of false alerts on 121.5. A combination of low power transmitters (121.5 ELTs put out just 5 milliwatts), congestion on the emergency frequency and interference from such devices as garage door openers and certain TV sets was making it difficult to sort out the wheat from the chaff.

The new specification, TSO 129, created by the search and rescue community, provides a more robust alerting environment – a more powerful transmitter (bursts at 5 watts every 50 seconds), a cleaner, dedicated frequency and, most importantly, the capability to receive a code from each ELT to identify a particular ELT which is broadcasting.

The ICAO proposal was introduced at a Canadian Aviation Regulations Advisory Council (CARAC) meeting in June 1998 and industry was requested to provide comments. COPA submitted an extensive position paper following an examination of the advantages and disadvantages of the proposed change.

We concluded that a detailed cost/benefit analysis would be required before any commitment could be made. The reasons given for this position were that the cost to equip, estimated at that time to be in excess of $3000, was extreme given the limitations inherent in the ELT concept that were not corrected by switching to the new TSO.

COPA gave the following reasons for a thorough investigation of alternatives to 406 ELTs: “COPA’s study of accident reports for the period since ELTs came into existence until 1998 also revealed that in as many as 78% of the accidents where an ELT was needed to find the wreckage, the ELT failed to operate as desired.

If the failure rate is in fact as high as this, will a change to 406 appreciably improve the statistics?”

Our position went on to say that “Many of the existing ELT limitations will remain; such as broken antennas, submersion, masking by wreckage, etc. Also, technology is changing rapidly such that there may be alternatives to this technology at significantly less cost and better reliability.

Given the past experience of the community with ELT problems, it is imperative that a proper investigation be undertaken to establish the benefits of this technology and whether or not it will provide an appreciably better alerting and search aid than the present or alternative technologies.”

COPA’s preliminary investigation of ELT statistics in 1998 also revealed additional issues. For example, a review of statistics from the Rescue Coordination Centres (RCC) showed relatively few search and rescue incidents are generated by aircraft.

One could understand that the RCCs on either coast would generate a large number of marine incidents, but it is surprising that Trenton, being inland, also is busiest with marine incidents.

In 1997, they were involved in 2,363 cases of which 1,682 were marine, 149 humanitarian, 81 civil aid, and 128 unknown, but only 323 incidents involved aircraft; only 13% of the cases.

For the RCCs on the two coasts, the statistics show an even lower percentage of incidents generated by aircraft. So, in 1998 we asked: “This begs the question, why are aircraft being singled out for mandatory equipping with expensive ELTs?”

COPA called for the formation of a Task Force, including Transport Canada (Airworthiness, General Operating Rules), TSBC, DND (Rescue Coordination Centres and National Search and Rescue Secretariat), CASARA, Transport Canada’s Transportation Development Centre (development of a next generation ELT), Canadian Coast Guard and other marine agencies and interest groups, Parks Canada, NAV CANADA, equipment manufacturers, insurers, ATAC and COPA, to investigate the following issues:

1. Accident statistics: How many times have ELTs actually been instrumental in finding an accident site and saving lives. How often did fixed ELTs work as desired versus the number of times that they worked because they were manually activated.

2. 406 experience so far: What has been the success rate with 406 ELTs so far. Has there been a measurable improvement in location/rescue.

3. DND experience: How much is being spent on SAR? What percentage of search costs is from aviation versus other modes? Is it possible to quantify the savings from reductions in false alarms with 406? What is the false alarm rate with 406 so far?

4. Manufacturers: What is a realistic cost projection for various ELTs, including fixed aviation ELTs and portable, general use ELTs in the 2005 timeframe? If the aviation community carried non-aviation ELTs and ELTs were made mandatory for marine, hikers etc, what would the cost projections be?

5. Alternative ELT technologies: TDC is working on a more reliable 406/121.5 ELT. What are the cost projections and how will these improvements improve reliability?

6. Cost sensitivity of the aviation community: What is the resistance point for non-commercial, commercial aviation?

 

Some of the options COPA wanted investigated were:

1. Non-mandatory carriage or mandatory for commercial aircraft, non-mandatory for private aircraft.

2. Fixed versus portable locating devices.

3. Carriage only in sparsely settled areas and/or beyond a certain distance from an aerodrome.

4. Price reduction through subsidy or trade-in program, commensurate with the savings that the government may realize in reduced false alarms.

5. Various surveillance techniques such as use of transponders in conjunction with radar coverage in southern latitudes.

6. Automatic Dependent Surveillance – Broadcast for flight following.

7. Insurance premiums for non-equipped aircraft to cover the cost of searches.

Regarding the ICAO-proposed transition dates, COPA recommended delaying the implementation dates significantly in order to allow the typical seven-year compliance transition period to apply after a thorough study takes place in Canada.

Since that time, the implementation dates have slipped for a variety of reasons including the manufacturers not meeting their targets for equipment availability and governments being slow to amend their regulations.

Most recently, ICAO proposed to slip the mandatory date to 2007 for new ELT installations and 2009 for mandatory equipage. COPA provided our comments to IAOPA, who in turn responded to ICAO.

COPA’s call for a Task Force was actioned in the form of a working group led by the National Search and Rescue Secretariat. Not all of the invited agencies chose to participate but the key ones were there.

One of the first items on the agenda was to deal with the cost issue. Some of the major cost drivers for 406 are the tight specifications for frequency stability (key to accurate location), power requirements (battery reliability) and mounting correctly for G-loading, remote cockpit switch and in some cases dual antennas for 406 and 121.5. 121.5 would still be needed for homing, mostly because the cost to equip the search fleet with 406 homers was considered by DND to be too expensive.

COPA was pleased that the Transportation Development Centre (TDC) committed to spend money on the development of a low-cost 406 ELT. At that time, COPA stated that the absolute maximum resistance point for a 406 ELT would be $1,000 Canadian, installed, including taxes.

In 2004, development work was complete and the TDC proudly stated that the low-cost ELT should be available in 2005 for about $1,000 US, plus installation and taxes. COPA’s response was “too much.”

Our surveys of manufacturers in 2004 also revealed that some were about to release a low-cost version for around $1,000 US, plus installation and taxes, so it was evident that the installed cost would remain too high for the foreseeable future.

In addition to a series of working group meetings to explore alternatives, COPA managed to secure a commitment from the then Director General of Civil Aviation, Art Laflamme, not to mandate 406 ELTs for our sector of aviation. It took several CARAC meetings to develop a draft amendment to the ELT regulation, but we managed to put together a draft that would mandate 406 ELTs only for international flights.

Although this was a step in the right direction, it would require such additional measures as a bi-lateral agreement with the U.S., who were also indicating they would not mandate 406 ELTs, so our aircraft could travel there.

Unfortunately, the final level of government review for the amended regulation rejected the draft regulation for various reasons, and the response from the current DG Civ Av, Merlin Preuss, left COPA wondering if Transport Canada was reneging on its commitment not to mandate 406 ELTs.

As of this writing, it is unclear in what direction Transport Canada will proceed, except to say that a revised regulation is in the works. COPA is working closely with the drafters to get it right.

In order to emphasize COPA’s opposition to mandatory 406 ELTs and an apparent back-tracking by Transport Canada, a COPA Board resolution to this effect was sent to Transport Canada, along with several suggestions for a performance-based regulation that would make much more sense.

The government has committed to a different approach to regulation in recent years. They want to define basic safety goals, but leave it to industry on how best to achieve those goals. So, COPA took this approach in its investigation of practical alternatives.

First, we updated the cost of 406 ELTs by getting a quote from a reputable avionics installer for a compliant 406 ELT. We were surprised to find that the estimate from 1998 had actually increased to $5,500. And even a quote for a soon-to-be-released low-cost version from one manufacturer still put the installed cost at close to $4,000.

It seems, the promises of mass production and technology improvements have not helped to reduce the cost and there is no assurance from any source, the cost will ever come down.

Some proponents of the ELTs counter COPA’s cost estimates by saying, volume production will reduce the price significantly by the time they will be required. So, COPA investigated what is happening in other countries with large GA populations.

The U.S. has not committed to a mandatory requirement and appears not likely to do so. They are by far the largest market for ELTs, followed by Canada and Australia. The rest of the world combined is a distant fourth.

Australia has committed to require the Personal Locator Beacon (PLB) as a minimum but not mandate 406 ELTs.

The beauty of the PLB alternative is the price. At well under $1,000 Canadian, including an integral GPS to send exact position with the alerting and identification signal, the device can be shared, such as borrowed from a flying club when renting an aircraft, used for other purposes such as when hiking, and most of all, there are no installation costs.

COPA also investigated alternatives such as the results of a test that was performed in Alaska with Automatic Dependent Surveillance – Broadcast, where aircraft can be tracked in real time.

The concept is the reverse of the current search concept. Instead of the activation of something as the means of alerting, it is the cessation of tracking that alerts the monitoring stations to a downed aircraft.

Unfortunately, the cost to equip each aircraft with the technology is still years away from being affordable. But what it indicates is that alternative technologies are coming along to replace the outdated Doppler method of locating a signal from a downed aircraft.

So, COPA has proposed that a requirement to carry an ELT remain as it is now, so that some automatic means of alerting remain available. If an owner chooses to equip with a 406 ELT, nothing else would be required.

If, however, he/she chooses to retain the current 121.5 ELT, then there must be a means to contact a Rescue Coordination Centre when the aircraft goes a certain distance from the departure airport, travels over certain areas of Canada (to be defined) or is not otherwise being followed, such as radar flight following with ATC.

The means of contact could be a satphone, PLB or whatever else comes along that could fill the role (OnStar for aircraft?).

DND and some other agencies continue to insist that automatic detection by satellite must be retained in the regulation. Their reason is primarily to find the unconscious (usually dead) occupants. The dilemma is – how much is it worth to get this kind of assurance, and given 406 ELTs continue to have limitations that will not significantly increase the probability they will activate automatically.

How much is reasonable to pay for, speaking frankly, closure?

The cost to equip with ELTs will be as much as five times what it will cost for alternatives. How much will owners pay for what is in effect insurance?

COPA’s estimate to equip the Canadian private fleet is in excess of $80 million. DND’s own estimate of search cost savings because of the 406 ELTs is at best about $6 million per year. The benefit is definitely in favour of the government at an extreme cost to the aviation industry.

Logically, if the primary benefit of an $80 million expenditure is to the government, then the government should pay to equip the fleet. COPA has proposed this solution, but of course, government priorities are elsewhere.

COPA has provided space over the years and appreciates the commentary and educational information provided by Bob Merrick concerning Search and Rescue efforts, technology and education for pilots to maximize survival prospects and being found. Over the next period of time, we will keep you informed in the Newsletter section about the progress toward the development of an amended regulation.

We are hopeful that a performance-based regulation will provide options for pilots and aircraft owners to assess the risks for their particular situation and choose a combination of equipment that best suits their needs.

To that end, the ELT Commentary section will continue to provide educational information, but when we know the direction chosen for Canada, we will begin to concentrate on helping pilots and owners assess the risks and determine what equipment is appropriate. Stay tuned to both the Newsletter and ELT Commentary for details (contact Kevin Psutka).