seems to me that the Dutch document would permit "survival ELT-S" which is removable and activated by the survivors. i.e. McMurdo, GME, etc.
'Survival ELT-S' as used by ICAO in their Annex 6 and Annex 10 recommendations is defined in both US and European standards: RTCA DO-204 or EUROCAE ED-62.
The PLBs we are using (McMurdo, GME, etc) do
NOT meet these standards and cannot be approved as such.
Various ELT-S units
are available, but:
a) they are typically >$2,000; and
b) they are not GPS-enabled, and therefore have a much slower precise-location time than our GPS-enabled PLBs.