Is it just me or is this another example of ill conceived, ill thought out legislation, followed by a lack of publicity or transparency, never mind a dubious regulatory impact assessment?
I have the following issues:
1. Why on earth was the criteria based on powered distance to land. Surely the key issue is the glide distance?
2. In terms of the continent, without an ELT and as others have commented what this does is create and even narrower corridor between south east Kent and France. How can that make sense?
3. What about ultralights, microlights, PFA and the other slower machines - presumably they now have no way to France? Are they aware? The Cis, Deauville, Eire, etc are of course all out of the question now unless the aircraft complies.
4. Why is flying over the Channel (or any body of water) any more or less relevant than the Highlands?
5. Why is it there would seem to have been so little consultation. I have not seen mention in the aviation press, AOPA or elsewhere and it would seem even the CAA have rolled out the legislation before informing the GA community of the changes?
6. Why is it the CAA themselves don’t know what units would and would not qualify?
7. Is there actually a proven case that ELTs in light aircraft materially enhance safety over the sea? In most cases the aircraft is likely to sink pretty quickly. If the ELT is panel mounted it will sink with the aircraft and cease to work.
8. What about the cost? One of the aircraft I fly has a panel mounted ELT. However I would imagine to retrofit the kit on most aircraft will prove very expensive.
9. What about the regulatory impact assessment? Apparently it has been done. Has anyone read it?
Personally without authorative and justified answers to these basic questions I feel dreadfully let down yet again by the regulators, AOPA and those that work for GA generally.
