We went through a similar, albeit less costly, problem some years ago, when CAA (Oz) got hot under the collar with proposals and edicts to fit fixed ELT's in all aircraft. AOPA Australia ran a good lobby, with very similar concerns to those put here, but the overriding point that was made (IIRC) was to give the public servants an option.
In our case, the point was made that fixed ELT's were of dubious value in the case of a ditching, or an aircraft fire. Option was to lobby for ELT's, but leave the choice to the owner/operator, whether to have fixed, portable, or both.
Sanity and common sense prevailed (after a long and hard flog) and that is now the option down here. As an operator, I have put both fixed 6 axis ELT's in each aircraft, plus personal ELT's in lifejackets, plus portables in each cockpit. Not cheap, but a bl**dy good insurance. Most contract pilots regularly turn up with a personal ELT clipped to their belt, quite commonplace these days.
Might I suggest that any lobbying done be well researched, and provide options/alternatives, rather than "don't agree, won't agree"? For instance, the certification and engineering costs associated with fixed ELT's is generally horrendous, and unacceptable to the average GA owner. Make that a supporting point for the option of portables, along with the other anti fixed installation issues.
Floats? Well, a difficult one, and hard to argue against on a purely safety issue. But how many other ICAO signatories comply with this standard? Present the case well, and it may get modified for >50nm offshore, or similar. No reason why personal liferafts, as described by Nigel, wouldn't be approved, if presented properly as an option. Especially as it is the most likely way that a Robbo driver will get to have one with him/her when exiting the aircraft in a hurry!
Just a few thoughts on a Friday afternoon
