What’s the Cost?
March 20, 2009 By Ken Armstrong
Virtually all aviators want improved flying safety and survivability – but at what cost? The new regulation requiring installation of 406 Emergency Locator Transmitters (ELTs) in almost all Canadian aircraft may seem like a good safety measure.
Virtually all aviators want improved flying safety and survivability – but at what cost? The new regulation requiring installation of 406 Emergency Locator Transmitters (ELTs) in almost all Canadian aircraft may seem like a good safety measure. Many aviators will opt to pay thousands of dollars to install these slightly better ELTs while discarding their old 121.5 transmitters. However, many financially challenged flyers will find the mandatory aspect of these ELTs excessive and cease flying or become noncompliant! Just as our government agencies constantly assess safety vs. costs, individuals should be allowed to measure the cost/benefit ratio in their own operations.
The 406 devices were first proposed in 1998 by the International Civil Aviation Organization, and the mandatory requirement for this technology was initially set aside by Transport Canada (TC) after industry input. This decision was revisited last year by the Canadian Aviation Regulations Advisory Council (CARAC) process and essentially reaffirmed. However, senior TC management in concert with Canadian Forces overturned this decision for their personal benefits and insisted on 406 installations. The “new” 406 ELTs essentially incorporate recycled technology and reliance on often faulty ‘g’ switches. In an industry report, “consensus from Canadian as well as international sources was that in the majority of accidents ELTs fail.” One such indication of the high failure rate is a Department of National Defence (DND) report acknowledging that in at least 50 per cent of the occurrences where there was “true distress,” the “ELT did not activate.” So why insist on installation of this dated equipment? Simple. The GPS transmitter in these ELTs sends a signal to satellites with the aircraft’s registered owner’s ID so DND can see if the signal is emanating from a home-base airport and phone the operator to see if the aircraft is on a flight.This minimizes unnecessary SAR flights.
As the regulation stands that went to the Gazette process, almost all aircraft will require 406 ELTs in 2009 and this includes our American visitors. Guess what effect this will have on tourism! Moreover, consider the thousands of dollars required to update your aircraft – especially if the 406 is coupled to your panel GPS.
Remember when TC first foisted faulty ELTs upon us with exploding batteries, corrosion issues and faulty ‘g’ switches? This was followed by the “new” 91a specification to solve the previous problems. These ELTs provided minor improvements – albeit with additional purchase and installation costs. However, like the “new” 406 units, they inherited continuing problems and limitations. For instance, the 406 transmitters cannot even meet TC’s own requirement 625.39(2)(a) for immediate transmission on impact. There are very few approved 406 devices available in the Canadian market because TC has dragged its feet for eight years in implementation of revised specifications to allow LiSO2 batteries – as used in many ELTs elsewhere – thereby failing in its mandate to not saddle general aviation with undue costs. It’s time TC looked at new and emerging technologies that actually improve the chances or rapid rescue and location capabilities – not just government cost reductions.
The Canadian Owners and Pilots Association (COPA), representing 18,000 owners of Canada’s 32,000 aircraft, has deplored TC overturning the CARAC decision and unilaterally requiring 406 ELTs. Ditto for the 415,000 members of the Aircraft Owners and Pilots Association in the U.S. because all concerned feel there are superior alerting services that are also much less expensive. Moreover, technology superior to 406 devices is under development and it is senseless to impose high costs for yet another dated ELT with severe limitations.
Similar to COPA’s position, this aviator believes each of us should have the freedom to select from the available options of SAR notification that meets our safety and aviation means and needs. Considering many of Canada’s GA aircraft and their areas of operation, mandatory 406 ELTs are not only costly, but absurd. An example is my most common flight – between Victoria and Hope, B.C. For the duration of that flight, I would be tracked continuously in the radar environment, my SPOT GPS transmitter would be providing constant track updates to a central server with an immediate emergency service capability, and I would continuously have VHF communications with ATS and cell phone coverage for the flight duration!
While the full complexities of this topic cannot be fully covered in the scope of this column, it’s reasonable to conclude this faulty regulation should be put on hold and returned to the CARAC process.