AOPA Queries CAPs ELT Rulings

Many of the CAA’s arguments in the ARP were inaccurate or misleading. AOPA then argued that market pressures in the USA had already dictated that satellite capability for 121. 5 243. 0 MHz will extend far beyond the year 2010 rather than the “not beyond 2005” as claimed by the CAA. And, it was not true that the performance of maritime beacons “is not really satisfactory for use in the aviation environment”. While some maritime ELTs may require the use of a ground plane the CAA has conducted at least one demonstration of a maritime ELT (Kinetic Technology) which was readily located by the satellite within two kilometres of its actual position in a park.

The ARP further stated that 406 MHz ELTs were available with manufacturers indicating “that the cost of the impact activated 406 MHz ELT is of the order of $800 with fitting likely to cost a further $300 or more, depending on the individual aircraft”. In July 1992, when AOPA received this ARP, there were no 406 MHZ ELT’s available for general aviation, and certainly not for $800. The Australian Maritime Safety Authority got it right in its 1992 booklet “Safety via Satellite” where they stated “The recommended choice for the private boat owner who goes offshore is a 121. 5/243 MHz satellite compatible EPIRB. For long range craft and larger vessels, whether private or commercial, the 406 MHZ beacon is the appropriate equipment. The price of a basic 406 MHz EPIRB starts at about $3000 ranging up to about $4500 for the ‘float- free’ type. ” One can only wonder where the CAA found one suitable for aviation use for $800.

AOPA could only agree with the CAA’s statement that “the chances of being located and rescued are significantly in creased if an ELT is carried and activated”. But that does not justify a minimum requirement for a fixed installation, impact activated ELT. Not every such ELT will survive impact, nor will it be effective if the aircraft is submerged, consumed by fire or has the external antenna damaged. A portable ELT has the advantage of being removable prior to the aircraft being submerged or consumed by fire. Certainly, as claimed by the CAA, the lack of survivors would preclude manual activation of an ELT but this has to be balanced against the likelihood of the survivors perishing because of the destruction of the fixed installation in the aircraft crash. Each system has its advantages and disadvantages and AOPA believes the most cost effective solution for general aviation, to provide for adequate detection and rescue of survivors, is the portable ELT.

Notwithstanding AOPA’s arguments, the CAA issued a directive in December 1993 requiring all aircraft to be fitted with an ELT, to the new C91a standard, by July 1 1994 (refer p32 Mar 94 AA). This allowed a mere six months for an estimated 8000 aircraft to acquire one of the new beacons and have it installed to unknown specifications. A C91a standard ELT could be purchased for approximately $300. However, in January 1994 the CAA provided AOPA with a copy of the draft Airworthiness Instruction for installation of these ELTS. These mandatory requirements were so stringent that installation estimates varied from $1500 to $3000 – a far cry from the $300 being bandied about by the CAA. The ELT had to be mounted as far aft in the tail section of the aircraft as was practicable, had to be attached to the aircraft’s primary load bearing structure in an approved mounting capable of with-standing specified static deflection loads and had to have a control switch on the instrument panel with three positions on, armed and off. This meant the pilot had to ensure that the ELT was armed before each flight otherwise it would not automatically activate on impact. This procedure alone significantly reduced the argued benefit of the fixed installation.

Following further representations from AOPA, and presumably others, the CAA eventually announced in March the deferment of the ELT requirement for a further 12 months on the grounds that there were “insufficient quantities of the TSO C91a ELTs, particularly the lower priced units, presently available in Australia for all owners to comply with the July deadline”. The CAA also then advised AOPA that “airworthi- ness guidance, in the form of a Civil Aviation Advisory Publi- cation, will be issued where necessary to supplement manufacturers mounting instructions in lieu of an Airworthi- ness Instruction” – an Airworthiness Instruction which, until then, was still in the drafting stage some four months after the initial requirement for installation was announced. But what about the poor aircraft owners whose aircraft were due for annual inspections in the intervening period and had had C91a ELTS installed without such presumably important guidance? The CAA also advised that they had now decided that “there be no need for remote switching, provided the pilot has ready access to the ELT controls, although the warning light will need to be within the pilot’s normal field of vision”. If the pilot can now have access to the controls and be able to see the warning light, does this mean the ELT can now be installed in the cockpit? If so, what of the crash survivability requirement which previously dictated the ELT be installed as far aft as practicable? This further weakens the CAA’s arguments for a fixed impact activated installation.

Why can’t the CAA accept the simple argument for a portable, satellite compatible, ÉLT as a minimum requirement for general aviation? Its only cost is the purchase price and, in certain circumstances, its performance is superior to the more expensive fixed installation. If incapacitation of the survivors is an insurmountable problem there is now a New Zealand developed portable ELT, expected. to retail for $320, which can be activated from the search aircraft.

AOPA accepts the requirement for all aircraft to carry a satellite compatible ELT – it does not accept that the requirement can only be met by an expensive fixed installation which is of minimal benefit to the aircraft occupants. A $200 portable ELT should be as acceptable to the CAA as it is to those who have to purchase, maintain and hopefully never have to use it. If the government wants the more expensive installation to reduce its search costs then let it subsidise the difference in cost to the industry. And, please, let the requirement be deferred until the CAA can get its act together.