ELT Saga Continues
The Aircraft Owners and Pilots Association of Australia (AOPA) remains locked in conflict with the Civil Aviation Safety Authority (CASA) over the latter’s requirement that Emergency Locator Transmitters (ELTs) be fitted to civil aircraft, by June 30 1996. The only exemptions to the requirement, which is spelt out in CAR 252A, are high capacity RPT aircraft, balloons, airships and gliders, and aircraft operating within 25nm (46km) of the departure aerodrome. CASA has mandated that aircraft be fitted with C91a ELTs, which have a much greater crash resistance and better activation system than the earlier C91 ELT. This means there is a much better chance of the C91a surviving a crash and being activated as a result in addition to there being less likelihood of false activation. AOPA recommends that its members carry ELTs but maintains that personal, portable ELTs are a safer and less costly option than fixed types such as the C91a. This is apparently supported by its membership which in a poll to which 2241 members replied, 1723 or 77% declared that they would be in favour of compulsory carriage of an ELT on flights exceeding 50nm (92km), with the choice of ELT type being left to the pilot.
To support the case for the fitting of ELTs, (which AOPA estimates will cost in the order of $10,000,000), the then CAA sought a cost benefit study from the Bureau of Transport and Communications into the effect that the mandatory carriage of ELTs would have had on search costs and survival rates for a given year. The year chosen was 1993-94, in which the cost of searches was unusually high. The CAA estimated “that, of the searches undertaken in 1993/94, 40 were either assisted or would have been assisted by an ELT signal”. The CAA went on to state that “this is the only available estimate of the proportion of searches that would be assisted by an ELT, and so we will use it in our primary cost-benefit calculations to determine a relationship between GA hours flown and the number of searches likely to arise that would be assisted by an ELT signal”.
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The Senior Vice President of AOPA, Boyd Munro, subsequently carried out an exhaustive study of the 40 incidents to determine, whether in his view, an ELT either fixed or portable would have materially assisted in the search, or the search if one had taken place. In the event only limited details of 37 incidents were provided by CASA and of these, Boyd Munro maintains that his study indicates that in terms of lives that could have been saved, three would have stood a good chance if portable ELTs had been carried whereas only two would have had a slight chance if C91a type ELT had been fitted. Of the remaining incidents, he maintains that effectively, none would have had a materially different outcome should a C91a type locator have been fitted. Of particular note is the fact that in some five of the incidents, the aircraft crashed into water which may well have rendered the ELT, if fitted, useless.
AOPA maintains that portable ELTs, in addition to being a better option than fixed ELTs, would cost about a tenth of the costs of the latter, which would theoretically provide some $9,000,000 better spent on the installation of GPSs, or on pilot training.
An additional factor in the equation is that ICAO has recommended the adoption of the much more advanced C126 ELT by the year 2000. The C126 ELT employs digital techniques which identifies the beacon, and in suitably equipped aircraft it also includes the position. Coverage of the C126 ELT is increased enormously by the receiving satellite storing the beacon’s information and transmitting it when in range of an earth station.
CASA maintains that portable ELTs whilst successful in the marine environment, are not as effective as automatic ELTs in aircraft. This is because they are not activated automatically, nor are they crash or fire resistant. Hand held ELTs including Marine Emergency Position Indicating Radio Beacons (EPIRBs) are more prone to inadvertent activation. At the same time however, CASA recognises that portable ELTs are a useful adjunct to automatic ELTs, particularly for overwater flights. It also recognises the value of having an ELT with a portable capability which permits it to be removed from its airframe mounting bracket, thus enabling a survivor to move from the crash site. CASA also has reservations that the more advanced ELT will be introduced as planned as there is strong pressure from the USA and Canada for the retention of existing ELTs for quite some time to come.
Statistically, CASA mounts on average about 150 searches for aircraft each year. Of these, about five per year or 3.3% are for aircraft which have submerged. This is consistent with the NASA study which analysed 3270 crashes from 1983-1987 and found that in 62 cases (1.89%) the ELT failed to operate because it was submerged.
Perhaps the most telling argument for automatic ELTs is that they will activate regardless of the condition of any survivors. Experience has shown that the shock effect of an accident can leave an apparently unharmed survivor incapable of accomplishing even simple tasks.
Finally, the latest situation in the long running saga is that as a consequence of AOPA querying the CASA cost benefit study during a hearing of the Morris Committee on October 23, the CASA CEO, Leroy Keith agreed to re-examine the data provided in the 40 incidents referred to above and to reassess the cost benefit study. This effectively puts the ELT question back in the melting pot.
Comment
There is no doubt that all aircraft should carry some form of ELT, however there is considerable debate as to whether this should be in a fixed installation or a portable unit carried on the pilot’s person. On the one hand AOPA, apparently supported by its membership (though not all responded to the poll), believes that this should be left to the discretion of the pilot. On the other, CASA with the statutory responsibility for ensuring that all aircraft are properly equipped believes that an automatically activated ELT is essential to ensure the optimum chances of finding a downed aircraft. The cost of fixed installations, and the prospect of a short term life for the C91a must figure large in the equation, particularly to AOPA and its membership. Clearly, the rapidly developing technology in the field of locator beacons must raise concerns about forcing the adoption of expensive fixed ELTs in aircraft with every possibility that the technology will soon be overtaken. A final thought on the subject, with all the tabloid media hype associated with anything to do with aviation safety, one can imagine the field day should CASA agree to a lesser standard of safety and an aircraft subsequently crash and could not be located.
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