By Kevin Psutka
Debate draws to a close as 2009 approaches
Whether you own, rent or borrow an aircraft this article may help you make some important choices. Most aircraft owners will have to spend money in the next year or so to comply with a revised Emergency Locator Transmitter (ELT) regulation. And even if you do not own one of the aircraft that are affected by the regulation, you may wish to invest in a device to provide you with adequate protection wherever you fly.
THE DRAFT REVISED REGULATION
A draft revised regulation was recently tabled at a Transport Canada CARAC meeting. At this point it is not known when it will come into effect. Normally, I would not report in detail on any draft regulation because it can change significantly as it works its way through legal vetting to its final form, however, given the short time remaining until the monitoring system for ELTs will change (Feb. 1, 2009), it is important to understand the issues and the two options that are available.
Option 1: A 406 MHz ELT
The wording of the regulation is being revised as a result of my input at the CARAC meeting so the full text is not available. However, the basics of the regulation are as follows.
It will require replacing your current 121.5/243.0 MHz ELT with an ELT that broadcasts on 406 and 121.5 MHz (I will refer to this as 406 ELT in this article) and meets Technical Standard Order (TSO) C126, it is required to be coded for Canada (I will explain) and must be approved for use in Canada (I will explain where to find out which ELTs are approved).
COPA’s research over years of monitoring this issue indicates the installed cost of this option will be between $3,000 and $4,000 depending on the 406 ELT model selected and even more if additional options are selected.
Option 2: Alternative Means
Alternatives to 406 ELTs will be permitted but they must do the following. A Rescue Coordination Centre must be alerted, without any action from the aircrew, within 60 minutes of someone becoming aware of an occurrence (missing, accident, incident or forced landing) and the alternative device and/or service must provide the location of the aircraft within 40 nm. The cost of this option can be as low as $0 (in the case of positive radar control, for example) but is expected to be less than the 406 ELT installed cost, as explained below.
Flight training aircraft within 25 nm of their base as well as ultralights, gliders, balloons and gyroplanes remain exempt from any requirement.
Again, this could all change as the revised regulation moves through the government approval process but assuming that the intent from the CARAC meeting remains intact, the revised regulation will permit tracking services, including positive radar surveillance and devices that provide a breadcrumb trail (device report its location periodically), but it will not permit devices such as Personal Locator Beacons (PLBs), satellite phones and other devices that require someone on board to activate them during or following an occurrence.
Changes to regulations can take many years to work their way through legal vetting and promulgation but Transport Canada is trying to get this in place by early 2008.
Readers who have been following the articles in COPA Flight over the past number of years know that on Feb. 1, 2009, satellite monitoring and processing of older ELTs that broadcast on 121.5 MHz and 243.0 MHz will cease. There are a number of reasons why the change is necessary, including degradation of the satellite network, an unacceptably high false alarm rate and high failure rate of the ELTs to automatically notify the authorities via satellite.
The preferred replacement option by the Search and Rescue authorities and regulators is more expensive ELTs that broadcast on 406 MHz for detecting and narrowing the search area by satellite using Doppler techniques, and 121.5 MHz for homing by airborne or ground searchers.
COPA has been active on this issue since we first heard about the change in 1998 because any alerting concept that relies on a device surviving an accident and on Doppler techniques for roughly determining the location may not be the most cost effective, timely and reliable way to maximize your prospects of being found.
COPA’s Board of Directors passed a resolution several years ago opposing mandating 406 ELTs and encouraging Transport Canada to develop a revised regulation that permitted affordable, reliable options. That resolution gave me marching orders to advocate for alternatives.
A form of Insurance
To put the issue in perspective, consider ELTs as a form of insurance. Insurance is a personal matter, with some consideration for public protection. For autos and aircraft alike, the government requires a certain minimal level of insurance to protect others. You normally research your options and shop around before making a decision.
How much additional insurance you pay for is dependent upon several factors including your own assessment of risk as well as the cost and the perceived value. COPA has a competitive aircraft insurance program with several options available and we also offer life, home/hangar and auto insurance but we do not make any recommendations on how much to purchase.
It is a matter of choice according to your level of risk, as it should be. And so it should be for alerting devices, which are a form of insurance in the unlikely event of an aircraft accident.
It’s not so simple anymore
It used to be relatively simple. The government regulated a minimum requirement for most aircraft to equip with a 121.5 ELT, similar to a minimum amount of liability insurance coverage. For the most part, ELTs were affordable, costing less than a thousand dollars to purchase and install and about $40 to recertify each year (you can still purchase some models for less than $200).
Most would agree that the relatively low cost of the mandatory requirement was good insurance. Aircraft owners could invest in upgraded capabilities, including purchasing additional alerting devices such as satellite phones, Personal Locator Beacons (PLBs) and even cell phones (recognizing their limited coverage area) as additional insurance if they wished, but these devices could not fulfill the ELT requirement, whose main job is to automatically signal that an aircraft is in distress.
The original ELTs were designed to Technical Standard Order (TSO) C91 for detection by overflying aircraft and ground search teams. With the development of satellite detection networks by the international agency COSPAS-SARSAT, the existing ELTs were used to provide more reliable notification and a means of narrowing down the location of the signal using Doppler techniques, although the low power of these devices made them less than ideal for detecting and tracking by satellite, due mainly to interference from other RF sources.
As time went on, the limitations of this method of distress notification and location became apparent. First there was exploding lithium sulphur dioxide batteries. Owners were required to change them and/or replace their ELTs. Although the rest of the world permits these batteries following a revised battery Standard TSO C97, Transport Canada continues to refuse to permit them.
The number of false alerts was alarming, due in large part to faulty G switches and inadvertent activation. An updated Standard C91a was developed to incorporate some improvements including a cockpit switch, but false alerts continued because of increasing interference from our electronic world and mishandling of the ELTs. Owners of existing C91 devices were permitted to retain them but all new purchases had to be to the C91a Standard.
Since alert signals could not be easily traced to a specific device owner, it was necessary to painstakingly search for the device, including conducting expensive airborne searches. The search and rescue authorities wanted a way to connect a signal with an ELT so that they could reduce the work involved in determining whether or not an alert was false.
In addition, accident statistics indicated that the failure rate of ELTs was high. There are various rates given by government and industry sources. My own review of Transportation Safety Board accident reports indicated that in 78% of accidents, ELTs failed to automatically activate and get a signal out to the satellites because they were being destroyed on impact, antennas broke off or were shielded from the sky by wreckage, the devices sank or other inherent problems stemming from dependence on a device that has to survive an accident.
A costly alternative to 121.5 ELTs
Despite the limitations of this technique of alerting, the international authorities decided to proceed with creating a new requirement to at least partially solve the problems and significantly decrease the false alert rate. TSO C126 employs a cleaner frequency (406 MHz), more broadcast power for satellite detection (although the 121.5 MHz signal has been reduced in strength, which may make it more difficult for airborne or ground searchers) as well as more robust ELT construction and mounting requirements. An upgraded cockpit switch includes a light to indicate when it is in operation and for test purposes.
But of most interest to the search and rescue authorities, the new Standard incorporates the requirement for a unique coded message that each ELT sends to the satellites, which can then be traced to a registered owner of the device.
So, the first action when a signal is detected is to contact the owner to determine where the device is supposed to be at that time. Many false alerts will be resolved in minutes with one phone call.
Another optional feature, if equipped with an additional interface device and a GPS on board the aircraft, is that ELTs can send location information to the rescue agencies with GPS accuracy.
But all of this enhanced capability comes at a cost.
The international authorities liked the new TSO so much that in 1998 they decided to mandate 406 ELTs and turn off satellite monitoring of 121.5. When I heard of the decision, I researched the cost for aircraft owners and was alarmed to learn that in the 2002 timeframe (originally the date that was set for conversion to 406) it would be in the $4,000 range to purchase and install one in a certified aircraft. I also got quotes for the annual recertification at $160 versus $40 for 121.5 ELTs.
Although attempts were made to assure me that mass production and technology improvements would reduce the cost, my research indicated that there were major cost drivers in the stringent TSO C126 that would most likely never significantly reduce the costs. I did not believe that $4,000 or more for faulty technology plus annual recertification of $160 was good value for this form of insurance. So, in 1998 I called for a thorough investigation by Transport Canada of the cost versus the benefit, with a view to finding affordable, reliable alternatives.
Development of the revised ELT regulation in Canada
To Transport Canada’s credit, they did look into my concerns and made some investments in research.
My cost concerns were validated in 1999 when Northern Airborne Technology (NAT), a Canadian developer and manufacturer of specialized aircraft communication equipment, investigated the possibility of reducing the cost of 406 MHz ELTs for Transport Canada’s Transportation Development Centre (TDC) www.tc.gc.ca/tdc/summary/13400/13496e.htm.
NAT confirmed that TSO C126 presented a cost problem but with some development effort and a relaxation of Transport Canada’s ban on lithium sulphur dioxide batteries, they estimated that it would be possible to reduce the purchase price to the $1000 to $1500 U.S. range, plus installation.
In meetings with government authorities I said that the resistance point for many aircraft owners to convert to 406 ELTs, given the failure rate of this alerting concept, was in the range of $1,000 Cdn, including installation.
I sought quotes from avionics shops and discovered that due to the more stringent mounting requirements and wiring needed for the new cockpit switch and light to replace the C 91a compliant cockpit switches, the additional installation cost would be approximately $1,500, bringing the absolute minimum cost to equip to about $2,500; still too much in my opinion.
So, there was some work to do if my $1,000 target was ever to be reached.
TDC awarded a contract to the Canadian branch of EMS Technologies to develop a low cost ELT. After several years of development effort, they reported that it was possible to reduce the cost so that a production version could sell for around $1,000 U.S. EMS sought Transport Canada approval for their low cost concept but, for undisclosed reasons, the ELT was not approved.
I have learned from TDC sources that EMS has decided, for commercial reasons, not to continue the development and production program.
There are other so-called low cost ELTs on the market today, but not approved for Canada, at least not yet. For example, Artex offers their ME406 ELT, which sells for around $1,000 plus additional installation hardware is required. None of the low cost ELTs permit interfacing with a GPS.
These more capable ELTs start at around $2,000 but you need to purchase an additional interface box for about $1,500 plus I can only imagine that the total installation costs will be even higher than $1,500. There are extra wires to run and certification issues when interfacing with an IFR GPS, for example.
As part of the process leading to a revised regulation, I participated on several working groups over a seven year period including most recently an extensive risk assessment exercise to examine alternatives to mandating 406 ELTs.
First on my to-do list was to look for a way to get away from the requirement for a device that has to survive an accident. The same or similar notification could be provided by devices or services that track your progress.
If they stop their periodic reports at other than an airport, it is a good sign that there may be a problem to investigate and there is a trail leading to the vicinity of the accident. Positive radar control is another way to provide this tracking. Of course, radar has coverage limits.
I also pushed for non-automatic means of alerting, such as PLBs, satellite phones and other devices. My reasoning was that in the majority of accidents ELTs only work because the crash forces were low enough that someone was able to turn them on if they failed to automatically activate. So, why not permit devices that may have a better chance of surviving the accident (PLBs are normally carried on the person and most likely will not sink with the wreckage, for example).
However, Transport Canada and the search and rescue authorities remained fixed (sorry for the pun) on ELTs because these devices at least are designed for notification without action from any crew member, even if in the majority of accidents the ELTs may fail to do so.
A significant limitation of 406 ELTs
In selling the concept of 406 ELTs, claims of "immediate" notification via satellite are being made by some manufacturers and government officials. This is misleading.
A not-so-well-known fact is that when the G switch is activated during a crash sequence, only the 121.5 homing signal is activated immediately. After Feb. 1, 2009, when these signals will no longer be processed using satellites, 121.5 signals will only be detected by overflying aircraft or ground searchers who are equipped to home on the signal. According to TSO C126, it is permissible to take up to one minute (Artex for example claims 47-50 seconds) for an ELT to generate and send the first 406 signal to the satellite; a very long time when the aircraft is being torn apart during the crash sequence, is burning or is sinking.
SO WHY 406 ELTS?
It would seem the authorities like 406 ELTs because of the anticipated reduced false alert rate, not because our chances of being found are significantly improved. One government report indicated that savings to the Canadian government will amount to $6 million per year.
I agree the Standard will decrease the failure rate somewhat and this will in turn free up the search and rescue people to concentrate on real searches, but no one has yet demonstrated the increased reliability of the system is enough to justify our sector of aviation spending up to $100 million on these devices.
You may be thinking – if reduced false alert searches are going to save the government money at our expense with no significant increase in our chances of being found, they should subsidize the purchase of these expensive devices. Good point. I have tried that argument several times over the past 10 years to no avail.
Which ELTs are approved now?
Existing 121.5 ELTs meeting C91 or C91a remain valid at least until Feb. 1, 2009. Transport Canada has not addressed the issue of how long they will permit aircraft owners to make the change (see unresolved issues below). So, you do not have to do anything yet.
The existing regulation does permit you to replace 121.5 ELTs with a 406 ELT now (the detection network is in place) as long as it is coded for Canada and registered with the National Search and Rescue Secretariat www.nss.gc.ca.
There are lots of advertisements for low-cost ELTs but none are approved for Canada as of the writing of this article, primarily because they all use the prohibited lithium sulphur dioxide batteries.
I understand that Artex has just received approval from Transport Canada for their ME406 with lithium manganese dioxide batteries and I also understand from their representatives that there is no price change. Perhaps other ELT providers will follow. But Transport Canada approval does not mean that it is approved to install on any aircraft.
Where do you find a list of approved ELTs?
One would think Transport Canada has the final say but that is not true for radio devices. The information that is contained on various websites can be misleading. I have tried several times to get Transport Canada to produce and advertise a clear list of approved ELTs, but to date there is none on their website.
The people in charge of the satellite monitoring network, COSPAS-SARSAT, list a number of devices that are "type-approved"
http://www.cospas-sarsat.org/Beacons/typeApprovedList.htm - meaning that they are OK to use as far as COSPA-SARSAT are concerned, but several on this list contain the prohibited lithium sulphur dioxide batteries. Transport Canada has a list contained in an Airworthiness Notice http://www.tc.gc.ca/civilaviation/MAINTENance/aarpc/ans/B014.htm
but it has not been updated since 2002.
The Notice highlights that Transport Canada does not have the final say on what is approved; Industry Canada does, but the link in the Notice is wrong. The correct one is http://strategis.ic.gc.ca/app/sitt/reltel/search/newRadioSearch.do?language=eng
In order to find approved ELTs, you must enter RSS147 (for 121.5) or RSS187 (for 406) in the Radio Specification box on the above-mentioned Industry Canada link. Be sure to enter a high number in the "Maximum number of results returned" box to ensure you get them all.
Note several of the listed devices are not available because the companies no longer offer them. Others are not meant for small GA fixed-wing aircraft and others are PLBs.
My check of the 89 listed models revealed only about 15 are approved for our aircraft.
Before you purchase an ELT from any source, be sure they can show you it is Industry Canada approved and it is coded for Canada.
If you purchase one from the U.S., it will have to be sent to a Canadian shop that can change the code, but that will add about $75 plus shipping costs, according to my check with one shop.
Make sure you ask the seller for the location of a Canadian shop that can install the Canadian code.
Some great ideas are out there at more affordable prices that can fulfill the notification and location requirements and provide many more features than an ELT. I have personally tested one of the devices called SPOT (see evaluation at the end of this article).
There are other services available such as Skytrax, offered by Guardian Mobility www.guardianmobility.com. These services are aimed at commercial users and fleet tracking so are priced a bit high for most private aircraft owners.
Automatic Dependent Surveillance – Broadcast (ADS-B) is another system that has been tested and in fact used for rescue purposes in Alaska (Google "Capstone Alaska" for more information).
The system is being expanded into the rest of the U.S. over time and is being introduced into Canada to fill a radar gap in Hudson Bay. Although it will be many years until this form of surveillance will be widely available and affordable for our sector of aviation, it is good to see the regulation is flexible enough to permit this for alerting purposes.
These types of tracking and alerting devices and services are growing in number and sophistication so it is only a matter of time until they will most likely leap-frog 406 ELTs in reliability.
I have some concerns that were not resolved at the Transport Canada meeting.
My research indicates the manufacturers are incapable of supplying tens of thousands of the relatively few models of ELTs that are approved for Canada in time for the 2009 deadline. Transport Canada will have to make allowance for a period of time after Feb. 1, 2009, for aircraft owners to purchase an approved ELT, otherwise many may be grounded for lack of availability.
Even if there may be a sufficient supply, there are not enough avionics shops to handle the installation demand for potentially thousands of aircraft. I pointed out to Transport Canada that the installation issue can be reduced somewhat by permitting AMEs to do the work.
Currently, installation of ELTs is considered specialized work. Transport Canada agreed to look into this issue.
Transport Canada has not considered what they will do about foreign aircraft that are not equipped to meet our regulation. At this point in time, the U.S. position is they will not mandate 406 ELTs but it is unknown what they will mandate, if anything.
I have emphasized for many years Canada should harmonize with the U.S. to avoid possible prohibitions of thousands of aircraft or very expensive equipage requirements just to transit each other’s airspace.
Options to consider now
If you decide a 406 ELT is what you want, you should install one before 2009. The monitoring system is in place now.
The advantages of this option are it is purpose built to use a system designed specifically for search and rescue. When everything works as it is supposed to, the system will respond to signals from these devices.
However, given the many outstanding issues with a system that depends on the device surviving the accident, you should consider carrying another device in addition to the 406 ELT.
Since you will be complying with the existing and revised regulation by carrying a 406 ELT, you can carry anything, including a PLB, satellite phone, cell phone or one of the tracking devices and services. Do your research and decide what is best for your risk assessment. There are some very affordable options for this additional insurance.
If you do not install a 406 ELT now, you must retain your 121.5 ELT until the new requirement comes into effect in order to remain in compliance with the existing regulation. You should consider purchasing another device now for the same reasons given above.
When the regulation comes into effect and you decide not to install a 406 ELT, in addition to acquiring a device/service that complies with the regulation you should consider retaining your 121.5 ELT for as long as parts and annual verification are available because, although the rescuers will have a fairly accurate indication of your location from the tracking device or last known radar plot, 121.5 MHz will still be used by the rescuers for the foreseeable future as their means to home in on a crash site. Retention of your 121.5 ELT will provide an additional means to locate you.
Remember, if you purchase any 406 MHz device (ELT or PLB), be sure to register it with the National Search and Rescue Secretariat www.nss.gc.ca to minimize the delay from sorting out false alerts.
If you acquire any of the tracking devices now, or have any other device on board such as a PLB, satellite phone or cell phone, you should provide details in the remarks section of your flight plan so that Nav Canada can include this in their initial search and/or relay this to the rescue coordination centre for further investigation.
A SUCCESS STORY
The development of a revised regulation that includes alternatives to 406 ELTs is the culmination of a long process. Affordable alternatives will be available and exemptions have been retained due mainly to COPA remaining on this issue for 10 years.
Saving lives or bringing closure to the uncertainty of the fate of a loved one are very sensitive issues for pilots and their families, rescuers and regulators alike. I am pleased that a compromise has been reached and I am hopeful that the final version of the regulation will reflect the intent of the compromise that was reached.
COPA does not have the resources to independently verify the performance of any device or service, including any ELT. Notwithstanding my reservations about 406 ELTs, COPA and I are not recommending any particular solution, except of course any that will comply with the regulation.
You owe it to yourself, your passengers and your loved ones to educate yourself, just as you would in shopping for insurance. Ask questions of the providers and then decide what is best for you. COPA makes no warranties regarding the performance of any device, including 406 ELTs.
SPOT – an evaluation of an alternative to 406 ELTs
SPOT www.findmespot.com is a tracking system based on a battery-powered, self-contained GPS receiver and a transmitter that sends periodic messages, including device identification and location, via satellite for tracking, alerting and status purposes.
For aviation use, pilots would turn on the device in track mode before take-off, clip it to the sun visor or place on the instrument panel with a good view of the sky and from that point on, until it is turned off or runs out of battery power, it will send a report every 10 minutes to a central server that is accessible to anyone who knows the user name and password for that device.
The report contains the time of the report, identification of the device and, most important, the latitude and longitude which, when clicked, leads to placement on the Google Maps site.
If an accident occurs and the device survives, it will continue dutifully broadcasting from the same location. With GPS accuracy to a few meters, all that rescuers have to do is to go to that "SPOT."
If the device does not survive, the trail of reports will stop somewhere on the route, thereby helping searches narrow the search area, at least within the last ten minutes of the flight.
There are three other modes that make this device much more useful than 406 ELTs. SPOT has a "check-in" mode. Each time the button is pressed, a message (configurable via Internet before you fly) is sent to any number of email addresses, PDAs or cell phones. The message includes a link to Google Maps to illustrate your exact location on a map or satellite image at that time.
This is a great way to let loved ones know that you have arrived at a remote lake for some fishing and you can send these messages as often as you like to let everyone know things are okay.
A third mode is "help." Similar to the track mode, but reporting more often, when this button is pressed, reports go to a central website every five minutes.
In addition, similar to the check-in mode, a message is sent to any number of email addresses, PDAs or cell phones along with a link to Google Maps to illustrate your exact location on a map or satellite image at that time. This mode can be used to let your contact back home know, for example, that you need assistance because your engine broke down, but you are in good shape so they should not put anyone in jeopardy to come and get you, or in other words, come when the conditions are good.
The help mode functions for one hour and has to be reactivated for additional one-hour periods.
The fourth mode is "911." When this button is pressed, a message including the identification of the device and its latitude and longitude is sent every five minutes to a central agency that monitors for these signals 24/7. When they receive a signal from your SPOT, they will know from your registration process that they should contact a Canadian Rescue Coordination Centre to let them know where you are.
SPOT uses the Globalstar satellite network. Some readers may know Globalstar’s satellite network is suffering reliability problems due to degraded satellites, but they hope to have this corrected by 2010 with the launch of new birds.
According to the company, satellite phones need the full duplex system for two-way communication, and the duplex system is the problem. Since SPOT is one way only (from SPOT to satellite), it uses only the simplex portion of the system, which is apparently working well.
Some basic performance information about SPOT: It operates on two AA batteries for up to one year when turned on, 14 days when reporting every 10 minutes and seven days when reporting every five minutes. It works in cold temperatures and can withstand at least one metre of water.
Coverage is not global but the company claims it is reliable for North America up to about 70 North. A coverage map is at www.findmespot.com/explorespot/coverage.aspx. This claim is subject to verification.
COPA had access to a pre-production unit for a short period of time. It was activated on four flights and I even bicycled around Ottawa to test its features. You can see a presentation of the results on our website home page, including screen shots of the Google Maps images.
There are still some questions about coverage and reliability that I hope to answer through additional flights with a production version and dialogue with the company. I hope to have a more complete report on SPOT before the 2009 deadline for termination of 121.5 monitoring.
There is a more comprehensive review of SPOT provided by Doug Ritter, who specializes in evaluating outdoor gear and survival equipment. I invite you to visit his review at www.equipped.org/SPOT_ORSummer2007.htm.
Doug is reserving judgement on SPOT because there are still some performance claims to be verified with extensive real world testing. He will report on his findings in due course.
The price for SPOT is certainly attractive. The current list price is $170 and service, including the track mode, is $150 per year. As of the writing of this article, the details of distribution in Canada are being finalized and I am working on a deal for COPA members. I will report on progress as it is realized.