February 2, 2009
By Kevin Psutka
To those members who have contacted me about the ELT issue and said “Enough already, give it up and get on with life.” I say I now agree with you to a certain extent (I will never give up on advocating for alternatives), but I ask that you and everyone else indulge me this one last editorial. There is food for thought as we all deal with the choices we must make concerning our safety after 1 February 2009 when monitoring of 121.5 MHz via satellite ceases.
There was (and still is) a great deal of debate regarding the performance of Emergency Locator Transmitters (ELTs) and whether or not a move to more expensive versions that transmit on 406 MHz will improve the prospects of being found. And there is a lot of misinformation out there to lull people into believing that all they need to adequately protect themselves and their passengers is to comply with Transport Canada’s requirement to equip with a new ELT (as of the date of this article the final rule is still in process).
For example, at the height of the debate in 2007, Transport Canada ran a story in its Aviation Safety Letter (ASL) 4/2007 about a Transportation Safety Board of Canada (TSB) accident report (A05Q0208) in which a Cessna 172 with four people on board collided with terrain, flipped over, crashed and burned. One of the report’s findings was “No emergency locator transmitter (ELT) signals were received because the ELT was destroyed after impact. If the aircraft had been equipped with an ELT model that transmits on the frequency 406 MHz, the emergency signal would have been picked up and relayed instantly to a ground station.”
I have some accident investigation training, enough to know that statements such as this do not belong in an accident report unless they are based on fact. The TSB finding was being broadcast through the ASL to every pilot, and in particular, those aircraft owners who will soon be forced to equip with a new ELT. This statement provides a false sense of security that is not based on any fact.
I sent a letter to the Chairperson of the TSB, pointing out that the outcome of this accident, in terms of ELT performance, would likely not have been any different had the aircraft been equipped with 406 MHz ELT. I recommended that the opinion be removed from the report.
I also encouraged the TSB to investigate the performance of ELTs in every accident so that, over time, accurate statistics can be developed on which to compare against alternative alerting devices and systems.
Click here for the full text of my letter.
I am pleased that TSB agreed with these points. In a letter from Chairperson Wendy Tadros she said “As a result of your letter, the final report was amended.” (the finding was revised to remove the second sentence).
The response went on to say “The Director of the Air Investigation Branch has asked his staff to ensure that adequate and accurate data concerning the performance of ELTs is gathered during every investigation where an ELT is on board, regardless of whether the accident was survivable or not.”
Finally, Ms Tadros said that she “applaud(s) COPA’s ongoing efforts with industry and the regulator to ensure that, following an accident, the aircraft, its pilot(s) and passengers will be found without delay through an effective, efficient and affordable alerting system.”
I sent a letter to the Editor of the ASL, requesting that the misinformation about ELT performance be corrected. He responded that it should be in ASL 3/2009.
While this achievement may not change Transport Canada’s decision to effectively mandate 406 ELTs, it at least eliminates misleading information and sets the framework for consideration of the next generation of alerting devices in years to come.
In another ASL 4/2008 Transport Canada’s Franz Reinhardt placed an insert to remind everyone that a change is coming for the ELT regulation and he highlighted some of the anticipated requirements and an exemption that will permit a transition period. It was coincidence, I am told, that the ASL also contained six accident reports that mentioned the ELT and all but one of them reported a failure of the ELT. This can certainly make one think about what message Transport Canada is trying to send.
The evidence is certainly in favour of my long-standing contention that ELTs fail more often than they function, especially with several accidents just in the past couple of years, including many that made the press, where they made the point that survivors were found not because of the ELT but by other means such as a cell phone or luck. Unfortunately, the counter to my argument has been that the failures are all of older ELTs and that the newer ones are so much better. Just like the TSB’s statement about ELT performance, which is unsupportable, so this point of view is not based on any fact. Furthermore, it is simply not logical. The factors that caused the failures of the ELTs in the accidents in the ASLs remain for the new ELTs. Although the boxes may be more robust, they are still plastic and can burn, wreckage will sink, antennas will break off etc.
If the TSB makes good on its promise to collect data on ELT performance for every accident, we will eventually prove or disprove my position on ELTs. Of course, I cannot advocate for non-compliance with the regulations but I do know that several people, including some that would surprise you, have informed me that they will not comply. What I will say, however, is that as you consider your options for dealing with the impending changes to the regulation, you should seriously consider carrying an alternative device to improve your chances of being found. Personal Locator Beacons, SPOT tracking devices (COPA has a deal on service fees for COPA members), satellite phones and other devices and services provide options to in many ways compensate for the failure rate of ELTs. File and accurately follow a flight plan whenever possible and always brief a responsible person about your flight.
Regarding which ELT to choose, I cannot recommend one over another. If they are on the list of approved ELTs, they can be installed. What I will say, however, is that the best ELT is one that is portable (referred to as Automatic, Portable or AP). It may cost a bit more, but at least if the antenna breaks off or the cable gets crushed or the wreckage is inverted, you can remove the ELT, hook up the separate antenna and get a signal out. A good example is a recent accident on Garibaldi Glacier, where a pleasure flight turned into a rescue situation when a 172 tail dragger overturned. It turned into a race to see whether the ELT or the SPOT would get the notice to the rescue coordination center first (SPOT won) but the point is that the pilot had options, including an ELT(AP) on board and was able to set it up in the snow. Eventually, a distress signal was received.
The pilot reported to me that had they not been located that evening, a series of storms would have trapped them there for many days. SPOT provided an exact GPS location. The 121.5 ELT took much longer to determine an approximate location using Doppler techniques, an outdated method that is still relied upon with the new ELTs. The picture of the retrieval that occurred at a break in the weather says it all.
These folks were both lucky and had some
The FAA has decided not to mandate the new ELTs. In fact, their position is exactly what I have been advocating for in the past 10 years. I am on the FAA’s email list for announcements from their Safety website www.faasafety.gov . In an article regarding the impending termination of satellite monitoring of 121.5 MHz they “encourage aircraft owners to consider retrofit of 406 MHz ELTs or at a minimum, consider the purchase of a handheld 406 MHz Personal Locator Beacon (PLB) which can be carried in the cockpit while continuing to maintain a fixed 121.5 MHz ELT mounted in the aircraft’s tail.”
This is a practical, affordable solution that acknowledges that existing ELTs have a continuing role to play for alerting and homing while permitting alternatives that not only make up for ELT shortcomings but provide an additional, flexible alerting capability. The FAA has made the right choice.
The Bahamas has announced that they are exempting GA aircraft from 406 ELTs for now and will review this again in 2011. Click here for text on Bahamas exemption. Although the Civil Aviation Authority may just be hedging its bets for what the U.S. may do in the future, they are at least sensitive to the impact that barring foreign aircraft may have on tourism and their economy.
U.S. statistics indicate that only about 12-15 per cent of the fleet is currently equipped with 406. Despite almost 69,000 foreign private aircraft being cleared by our Customs from 2007 to 2008, our government does not care that these aircraft, 94 per cent of which are U.S. registered, represent millions of dollars in tourism and hundreds of millions of dollars in business transactions that will be severely curtailed when these aircraft are barred from Canada. It is a shame that our government refuses to do the math and then do the right thing.
ELTs are great when they work. The problem is that they fail at an alarming (sorry) rate. Technology is coming up with affordable alternatives. Even if Transport Canada does not get it, we can take advantage of technology to improve our safety. It is all about making the right choices.