Well done!
Document that headsethair quotes ref floatation equipment is
here
Document referencing ELT is
here
Changes to the proposal
Having considered all the comments received (1-8-1 to 1-8-21), this proposal has been amended to require either an automatic ELT or a survival ELT (ELT(S)) for extended flights over water. Since the implications for survival after ditching are similar, irrespective of the class of aircraft flown, the disparities between the ICAO standards for aeroplanes and helicopters seem unjustified. Therefore it is proposed that the circumstances in which aeroplanes and helicopters will be required to carry an ELT will be the same.
In assessing the likelihood of ditching it seems that the most important factor to be considered is the amount of time that will be spent exposed to the risk of flying over water (see 1-G-7) and this is more significant than any perceived differences between different classes of aircraft (see comments made in relation to other emergency equipment, 1-10-15 and 1-10-17). The revised proposal gives responsibility for the commander to decide if an ELT is to be carried, e.g. on shorter flights when the prescribed distances will not be exceeded and the time exposed to the risks of flight over water may be limited.
Views are sought regarding two alternative proposals for Article 43A. Option A makes explicit that the survival equipment to be considered includes ELTs. This option reflects the approach being developed in JAR-OPS 0; and would more clearly demonstrate an alternative means of compliance with the relevant ICAO standards. Option B provides a more general formulation. Each of these options needs to be read in conjunction with the other equipment (including radio apparatus) requirements specified elsewhere in the Air Navigation Order. Each option is intended to have the same substantive effect. If expressing a preference for either one or the other, please explain the reasoning behind your preference. It is suggested that the relative merits of these options should be considered in conjunction with the Appendix 10a proposals.
Full Comments and Responses document is
here
RC