ELT Now a legal requirment

[Fuji Abound]

This from another thread might be news to many.


As of the 15th March 2007 there is now a legal requirement to carry an ELT if you are flying over water more that ten minutes cruising time away from land.

I was not aware and clearly a very important change.

If anyone has a reference to the amending legislation in the ANO that would be very helpful.

It would mean a great many aircraft (including a lot of the rental fleet) will no longer be capable of going to France. If it is crusing time, as contrasted with glide distance, even L2K will be out.

[Phoenix09]

The amendment to the ANO can be found here (http://www.opsi.gov.uk/si/si2007/20070274.htm).

I was slightly incorrect in my previous post. The amendment came into force on the 15th March 2007 but table 3 within the amendment actually says on or after 1st January 2007 when at a distance of more than 10 minutes flying time at normal cruising speed away from land suitable for making an emergency landing it then goes on to quote KK 1 or 2 which is an ELT conforming to certain specifications.

[EastMids]

IMHO beaches are suitable to land on if push really comes to shove. Surely, 10 minutes at 100kts+ (most in the rental fleet will do this or close to it) is 16.6 nautical miles, meaning the crossing cannot be more than about 33 nautical. I'd have thought the shortest crossing to France would therefore be quite doable without an ELT.

Andy

[IO540]

OK, this is the mandatory-ELT and mandatory-oxygen amendment that has been in the proposal stage for a couple of years.

Fuji is right that nearly all of the UK GA fleet is now illegal to fly to France. There has not been any real publicity given to this.

It applies to G-reg only, but N-reg have to carry ELTs anyway and the FAA mandates oxygen use above certain altitudes.

The curious thing, and I am away from home and don't have time to look up the "K" references, is that the CAA had assured people that a portable ELT i.e. an EPIRB would be acceptable. A fixed ELT makes sense for the USA with its large expanses of empty land but is plain stupidity for the UK where by far the greatest risk is ditching and you want the ELT with you in the raft. Nearly all CFITs are totally fatal. A portable ELT does away with the silly installation cost too - I was quoted 2000 quid for the paperwork to install a different kind of ELT to my N-reg and a G-reg would be roughly similar; there are legally significant (if hardly practically relevant on a nonpressurised hull) structural issues on the antenna mounting. The cost of fitting a fixed ELT i similar to fitting a Mode S transponder.

Mandatory oxygen is not a problem for the UK; only on airways routes would one (generally) need it and anybody doing that can buy a portable kit for a few hundred quid.

[London Mil]

IO5440, from the ANO

Scale KK
(1) A survival emergency locator transmitter capable of operating in accordance with the relevant provisions of Annex 10 to the Chicago Convention, Volume III (Fifth Edition July 1995) and of transmitting on 121.5 MHz and 406 MHz.
(2) An automatic emergency locator transmitter capable of operating in accordance with the relevant provisions of Annex 10 to the Chicago Convention, Volume III (Fifth Edition July 1995) and transmitting on 121.5 MHz and 406 MHz.
(3) An automatically deployable emergency locator transmitter capable of operating in accordance with the relevant provisions of Annex 10 to the Chicago Convention, Volume III (Fifth Edition July 1995) and transmitting on 121.5 MHz and 406 MHz.

I suppose the exam question is whether the PLBs that you can currently buy (McMurdo etc) comply with Annex 10.

[Rod1]

“Nearly all of the UK GA fleet is now illegal to fly to France”

Nope

About 18nm across the short route, beach to beach, so 10 min at NCP no problem for even a 152. remember you only have to be 10 min flying time from the beach, so mid channel you are 9nm from two, so at 60kn you are ok.

Rod1

[S-Works]

Makes it very restrictive for routing an a potentially fatal bottleneck on a typical LFAT mobbing day.

I paid £240 for a McMurdo fast find GPS ELT. I never leave home without it whether airways or in the Cub local area.

[gasax]

Well I'm sure many of the people commenting on the Oban crash will be delighted.

Another bit of kit that 99.99% of the GA fleet will never use - but still have to buy if for instance they visit the NW of Scotland or cross the Channel at anything over a 30 odd mile gap (or the Isle of Man).

Was there a regulatory impact undertaken or did it just slid through on the basis of being 'a good idea'?

[Mark 1]

I bought one of the McMurdo units last year with a healthy discount at Aeroexpo expecting it to comply with KK(1), but I'm still not sure if it complies.
At least it can be shared (hired) with your mates and is easy to carry and use.

I gather that the 406MHz sattelite system can take upto 3 hours to get reception - which isn't an awful lot of use if you're down in the channel with only a lifejacket!

Anyway, I did the Normandy/ Channel Islands route last week. They don't seem to have changed the bottom of the flight plan form (does this qualify as UHF emergency radio?)

[blue up]

I have a Clutton FRED. It cruises at about 50 knots. On a windy day I might not get across the BRISTOL channel, let alone the other one.:E

I'll have to stick it next to the Mode S, the mandatory insurance papers and the chuffin' great battery that I'll need to run all this kit.:uhoh:

How heavy is the lightest COMPLIANT E.L.T.?

[Phoenix09]

I bought one of the McMurdo units last year with a healthy discount at Aeroexpo expecting it to comply with KK(1), but I'm still not sure if it complies.


According to the man from the CAA that I spoke to yesterday there are no personal ELT's that conform to the CAA/EASA specification. :(

Anyway, I did the Normandy/ Channel Islands route last week. They don't seem to have changed the bottom of the flight plan form (does this qualify as UHF emergency radio?)

I flew back from Deauville last week and filed my flightplan via OLIVIA and that now comes with the ELT box pre-checked.

I agree entirely with bose-x. On a sunny summers day you are going to end up with large amounts of aircraft all trying to cross the Channel Dover to Calais causing potential conflicts.

[robin]

>> ...At least it can be shared (hired) with your mates and is easy to carry and use.<<<

Is that strictly true? Aren't they supposed to be registered with some maritime SAR organisation so they know what they are loking for?

[Phoenix09]

Is that strictly true? Aren't they supposed to be registered with some maritime SAR organisation so they know what they are loking for?
I believe that is correct. More information on 406 MHz beacon coding, registration and type approval can be found here. (http://www.cospas-sarsat.org/DocumentsGSeries/G5OCT06.pdf)

[englishal]

But a fixed ELT is no good if the hull sinks! Which is what I suspect will happen.

If PLBs are not allowed then this is a typical case of ruling in the name of safety, without actually doing and research. I'd rather ditch and have a GPS PLB attached to my lifejacket than watch the plane sink and with it the ELT. Ships have hydrostatic release systems for this reason, and if we're going to have to fit "deployable" ELTs we'll never get off the ground!

[skydriller]

I flew back from Deauville last week and filed my flightplan via OLIVIA and that now comes with the ELT box pre-checked.

Are you sure it wasnt like that already? I believe F- aeroplanes have needed to have ELTs for a while now, at least I have not yet seen a french aeroplane without one installed.

Regards, SD..

[Rod1]

I have two problems with the PLB.

Number one is the up to 90 min for the satellite to see you and respond. If you are in the water off the UK, this is 30 min too long to be of any help at all.

The second is the registration. The unit must be registered to a mobile phone number and an aircraft reg. I had hoped that the flying club would buy two and hire them to members, but it does not look as if this is possible.

The bottleneck over the short crossing will now be even more of a problem, but it will still be legal to fly to France in the club spam can.

Rod1

[robin]

I've just read the CAA's response to the RIA on the ELTs back in 2004.

http://www.caa.co.uk/docs/224/srg_gad_ICAO%20final%20comment-response.pdf

Its attitude to the situation is typical of the CAA. Despite many comments about the cost and practicality of the full-blown product, they come back repeatedly to the 'value per life' calculation as well as the costs involved in SAR.
The PFA, for example, raised the issue of the 'approved' product costing a minimum of £1500, or 30% of the value of the aircraft.
At the end of the consultation, the CAA made no real changes to their original idea, and there is still confusion over what a 'survival ELT' is that is different from the McMurdos.
They do go on about the life-saving properties of the system, but as Rod has said, they'll either find the wreckage, not the survivors, or they will be too late to do any good in the channel.
This bodes well for the M*d* S issue, doesn't it.......:ok:

[Russell Gulch]

I think many flyers are going to carry on regardless, and ignore this law as being impractical & unsafe to comply with.:ugh:

I'll continue to use my "unapproved" PLB because it's the safest device I can use.

It'd need a prosecution to liven up the debate...any volunteers?

[Fuji Abound]

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. :{

[MikeJ]

This really does seem dreadful.
This is taken from the ANO amendment:

15) From 1st January 2007 an aeroplane or a helicopter flying for a purpose other than public transport more than 10 minutes flying time away from land must carry an emergency locator transmitter (ELT). The ELT must either be removable from the aircraft and be manually activated by survivors or be permanently attached to an aircraft and automatically activated in an emergency (an automatic ELT). When flying over areas in which search and rescue would be especially difficult an automatic ELT must be carried. (Article 4(11) and (13)).

I had puchased a McMurdo Fastfind believing it met the first option of being removable and manually activated by survivors. Like previous posts say, it is obvious that one fixed in the a/c is useless for nearly all a/c which sink within minutes. The McMurdo comes with a spec which assures it meets relevent international standards.

If it is correct that the CAA are saying that there are no approved portable PLB's, then there is NOTHING LEGAL you can carry which is of any use after ditching.

I also agree that the satellite system on 406 is not likely to be useful, at least for my own over water flying. Believing myself to be legal, carrying lifejackets, liferaft, and the McMurdo clipped to the raft, I flew to Guernsey yesterday. I used the unofficial Class G 'airway', KATHY to ORIST, at quadrantals FL40 out and FL50 back, cleared into and out of the Jersey Zone SVFR at those levels. The whole time over the water I was either with a Plymouth Mil or Jersey Zone squawk, and had I come down, my position would have been known immediately, possibly over an hour before the satellite info was triggered.

What is unbelievable is that this new requirment has not caused an absolute uproar, unless at least some of the currently sold portable PLB's meet the legal requirement.

MikeJ

[S-Works]

The ELT does not have to be registered to an aircraft, it can be registered to a dustbin for all the MCA care as long as the know who to contact if it goes off. A flying club would buy them and register them to the club. When you file the flight plan you put the EPIRB Hex ID onto the flight plan at the bottom. If the ELT is activated they contact the registered holder and the holder will then confirm via the booking out system log if the flight is real or it is a false alarm.

The average location time in Europe for a GPS transmitting EPIRB is 12 minutes not 90. A multi frequency unit improves the rescue rate to an average of 30 minutes from activation.

[Fuji Abound]

The average location time in Europe for a GPS transmitting EPIRB is 12 minutes not 90. A multi frequency unit improves the rescue rate to an average of 30 minutes from activation.

So lets see, what happens if the aircraft sinks in ten?

Moreover if you get into the liferaft (which you are not legally obliged to carry I suppose) how far will the liferaft have drifted from the aircraft?
(and I appreciate that if the ELT was detected the coastguard do have some reasonable technology to extrapolate where you may have drifted to).

[Mixed Up]

I think something is missing from our understanding of the law here. Surely if this really did become a change in the law, the CAA would have informed us, if not directly as a/c owners, then through GASIL, the clubs, the mags, the safety evenings etc. Until I hear through such a more formal route (as opposed to no doubt well-intended rumour on this thread) I'll simply ignore it.

[S-Works]

Sorry Fuji, I was referring to the portable option. I happen to think fitting an ELT to an aircraft is just stupid. You are totally right what happens if the aircraft sinks?

I will stick with the McMurdo!

[Rod1]

Bose,

The info I have is from Harry M, so give them a call. You have registered yours; did you enter aircraft reg and your mobile number? Your top end device (according to Harry) will have a position in 3 min and be desperately trying to find a satellite. The satellites overfly every 90 min (for UK). If you are in the water you need rescue a lot faster than 30 min. The unit, for water rescue, is about as much use as a chocolate teapot. If you go down in the highlands then 30 min to know your position may be ok, but for radio equipped aircraft flying high, we will have a Maday out and the unit would be close to redundant. I carry a transceiver which would be much more use.

Rod1

[S-Works]

I have a radio as well. And in the airways I can glide clear from a very long way when crossing the channel. Airways to LFAT I can glide to the runway!
I still think carrying an ELT is a good idea. The 90mins figure is the worst case scenario. The AVERAGE times are minutes. In Europe we are generally in the footprint of the sats for longer. However if I was concerned about being in the water for 90 mins I would wear a dry suit. Having spent 12hrs in the water after a dive boat broke down following a 6hr dive, 90 mins is a walk in the park!!!
I just dont think fixed ELT are a good idea, in fact I think they are stupid and just another way for the regulators to make money from us.

My ELT is registered to me personally with no aircraft details, they have my home number and mobile. So I can and do lend it to people.

[Kanu]

Can we assume that our flight plans will not be approved if we cross out ELT then? That is ofcourse we file to cross say from LYD dct as apposed DVR to Cap gris-nez:ugh:

[Fuji Abound]

Until I hear through such a more formal route (as opposed to no doubt well-intended rumour on this thread) I'll simply ignore it.

Good idea .. .. ..

but as is usually the case ignorance is no excuse and all that .. .. ..

it would seem it HAS been sneeked into the ANO as an amendment and the amendment has been given Royal ascent - so it is law.

[Daysleeper]

The satellites overfly every 90 min (for UK).

The GEOSAR 406 MHz system provides
"Near instantaneous alerting in the GEOSAR coverage area" which includes the UK

From the horses mouth at www.cospas-sarsat.org (http://www.cospas-sarsat.org/MainPages/indexEnglish.htm)

[ericferret]

There are ELT's that are quick detachable from their racks and have a manually deployable aerial.
However they are not designed for a water emergency. They are designed for use following an accident on land where the survivors can remove it and use it manually.

Who in their right mind is going to hang around in a sinking aircraft trying to undo fasteners that they are probably not familiar with.

The only sensible comparison is with offshore going helicopters.
They have a deployable beacon which floats.
The crews carry personal locator beacons.
They do have ELT's but these would only work while the aircraft floats, given that helicopters have emergency floatation devices this makes sense.

If the quotes from the ANO are accurate then someone at the CAA needs to come forward and explain exactly what is required.

No one should rush out to buy a fixed ELT for water crossing purposes, it is not what they are designed for.

[Keef]

The "right answer" for me was a GPS EPIRB - the McMurdo Fastfind Plus seems to do the job.

£470 from Tr@ns@ir or £380 from yottie shops (for the same unit). Fill in the card with the details and post it off.

I'm told the EPIRB will take up to ten minutes to work out where it is from the GPS satellites, but yell for help immediately, and will be heard within a couple of minutes. I've not researched it, but aren't there two sets of satellites - one set geostationary for fast identification, and one set moving that take bearings to work out where you are?

[Rod1]

"Near instantaneous alerting in the GEOSAR coverage area" which includes the UK
Correct, BUT the coverage area is dependent on the satellite position and can take a max of 90 min in the UK, this is CLEARLY shown on the fastfind data sheet. 30 min is average.
QUOTE
“The Fastfind standard 406MHz Personal Location Beacon provides an alert signal to the rescue services within 90 minutes maximum, depending on the satellite passes and gives a positional accuracy to within 3nm.
UNQUOTE
Have a look at if you want a full independent report;
http://www.equipped.org/key_west_beacon_test_report.pdf
Rod1

Edited to add, for those who do not want to read the test in full.

You appear to have a 57% chance of the thing working at all if you are in the water!!!!!

[BEagle]

I spoke with an old chum at the Belgrano today, who provided me with the relevant weblink. See http://www.caa.co.uk/docs/224/srg_gad_Appendix%208b%20revised.pdf

Here is the amended requirement:

Scale KK
(i) A survival emergency locator transmitter capable of operating in accordance with the relevant provisions of ICAO Annex 10, Volume III and transmitting on 121.5 MHz and 406 MHz;
(ii) An automatic emergency locator transmitter capable of operating in accordance with the relevant provisions of ICAO Annex 10, Volume III and transmitting on 121.5 MHz and 406 MHz;

The McMurdo FastFind Plus would thus seem to meet the requirement. I will try to obtain confirmation of this.

Without an ELT, the 10 min 90 KIAS sectors for the south UK are:

http://i14.photobucket.com/albums/a341/nw969/ELT.jpg

So, to avoid the Golf Alfa Lunch At Letookay rat run, £480-ish for an ELT(S) isn't too bad. If my information is correct, I will probably buy one and hire it out as required to club members for a deposit and nominal fee.

[IO540]

The star prize goes to the person who spots a potentially more significant and much more suprising piece in that ANO amendment. I give you one clue: "IFR" ;)

[BEagle]

Take another look!

(a) (ii) (aa) - (cc) apply only to IFR; however (a) (v) (bb) is not so restricted!

Mind you, the table seems almost designed to mislead!!

[London Mil]

For those of us in the UK, I wouldn't worry too much about satellite pick-up times. Your 121.5 transmission will be picked-up almost instantaneously by the majority of civil overflights (you know the same guys who whinge about practice pans :ouch: ). Within second RCC Kinloss, D&D and MCGA would be slurping their last swig of coffee and starting to look for you.

[BEagle]

I can assure you that the RCC folks wouldn't waste time drinking coffee - they react like coiled springs to any 121.5 call!

[Mariner9]

The McMurdo FastFind Plus would thus seem to meet the requirement.

Apparently not according to the CAA- they're not approved to TSO 2C126. (Details on the flyer forum)

[IO540]

No Beagle, this one is nothing to do with ELTs or oxygen.

[Whirlybird]

I've only skimmed this thread, so forgive me if this has already been mentioned, but....

You can hire an ELT from SEMS incredibly cheaply, which makes sense if you only make continental trips once a year or so.

[Islander2]

My ELT is registered to me personally with no aircraft details, they have my home number and mobile. So I can and do lend it to people.Are you not, therefore, registered with the MCA? I understood this to be mandatory. The registration/continuation form I have completed for them over the past six years requires a vessel identification!

The star prize goes to the person who spots a potentially more significant and much more suprising piece in that ANO amendment. I give you one clue: "IFR" Go on, then IO540, I've studied the S.I. very closely and I can't see ANYTHING that's particularly damning for IFR flight (other than mandatory oxygen above FL100 for >30mins, which of course can be satisfied with CAA/EASA-approved portable oxygen equipment ... who cares that there isn't any CAA/EASA-approved portable O2 equipment!!!).

[S-Works]

Islander, instead of blindly following rules in the British way, try a bit of free thought and actually contact them just like I did. You can register a dustbin with an ELT if you really want.

All they the MCA want is someone to call when the damn thing goes off.

[Islander2]

Islander, instead of blindly following rules in the British way, try a bit of free thought and actually contact them just like I did. You can register a dustbin with an ELT if you really want.Sorry? What rules??? My (actual) contact with them resulted in a form for completion. Amongst other questions, it wanted to know what the vessel was! They've subsequently asked me at two-yearly intervals whether or not the vessel has changed. Of course, they probably recognised me as someone lacking in the free spirit !!.

[IO540]

Islander2 - The ANO amendment appears to ban DIY instrument approaches. They are trying to mimic FAR 91.175, except that the USA gets away with this because they have so many IAPs over there, whereas in Europe a lot of pilots do their own descent profiles.

That business about the McMurdo ELTs with built-in GPS being more or less useless is news which is several years old. I remember reading it c. 2002. It's probably still on google but I think they fixed them a long time ago.

A beacon won't help you in +5C water in a life jacket, because by the time they get to you (which, for much of southern UK, is at least an hour by helicopter) you will be dead. That's why a raft is essential if you want a reasonably assured escape route in a ditching.

I am puzzled as to why the CAA has mandated ELTs, unless it's an ICAO requirement and the CAA seems to be gradually getting out of the "differences" business. There aren't enough CFITs in the UK where there was the slightest chance of survival.

Sweden mandates ELTs for all own-reg planes (but Sweden mandates practically everything) and the USA does of course but the USA doesn't yet mandate 406MHz.

I am on N-reg so this doesn't affect me directly, but does anybody have a reference for the oxygen kit having to be CAA approved?

When I was looking at portable kits c. 2003 I came across a UK firm selling "CAA approved" kits which were simply the standard off the shelf Aerox kits (same as I have had since) but with some paperwork, and the price was around double of the US price. Presumably, this firm was running the standard scam (standard not just in aviation but that's where it is particularly cynical) where you obtain the authority (from the CAA or EASA) to generate certification forms, buy the items on the open market, "inspect" them, write down their serial numbers on a form, stamp the form, and sell the items for much more, with the said form.

It would be a travesty of justice if the CAA mandated "certified" oxygen kits, given the rate of new developments (e.g. demand regulators) in this field and the certainty of CAA approvals lagging years behind, while multiplying the costs.

[S-Works]

That was kind of my point. The forms were aimed at boat users so I called them up and asked. It was they that came up with the comment about only really wanting the information on who held the unit in case it went off.

[Islander2]

The ANO amendment appears to ban DIY instrument approaches.You must be reading a different Statutory Instrument to me! I see nothing that could be even remotely interpreted in that manner ... and I was looking for same, it having been foreshadowed by the January 2003 RIA.

I am on N-reg so this doesn't affect me directly, but does anybody have a reference for the oxygen kit having to be CAA approved?Try ANO Article 19 for size!!

[Islander2]

That was kind of my point. The forms were aimed at boat users so I called them up and asked. It was they that came up with the comment about only really wanting the information on who held the unit in case it went off.So, for the avoidance of doubt, you do have a GPS/PLB code (prefixed by the letters CSTA) issued by the Maritime and Coastguard Agency? Or is that just being slavishly British?

And while we talking ridiculous rules, you have also registered the device (in accordance with those annoying UK aviation guidelines - AIC 57/2003) with the UK Mission Control Centre at RAF Kinloss? I know, blind obedience on my part ... but I was never strong on free thought!!

[IO540]

Sch 19 says

Equipment of aircraft
19. —(1) An aircraft shall not fly unless it is so equipped as to comply with the law of the country in which it is registered, and to enable lights and markings to be displayed, and signals to be made, in accordance with this Order and any regulations made thereunder.

(2) In the case of any aircraft registered in the United Kingdom the equipment required to be provided (in addition to any other equipment required by or under this Order) shall—

(a) be that specified in such parts of Schedule 4 as are applicable in the circumstances;

(b) comply with the provisions of that Schedule;

(c) except that specified in paragraph 4 of the said Schedule, be of a type approved by EASA or the CAA either generally or in relation to a class of aircraft or in relation to that aircraft; and
................ etc

and Schedule 4 gives type approval exemptions for things like megaphones, etc.

I wonder if this is the end of it. It doesn't seem to have been the intended result. The oxygen equipment will clearly have to be portable (installing a fixed oxygen system is totally impractical) and portable items are traditionally exempt from approvals. They certainly are under FAA. In fact looking at the exemptions in Sched 4 one could debate whether a handheld GPS is permitted.

[IanSeager]

In fact looking at the exemptions in Sched 4 one could debate whether a handheld GPS is permitted.

A GPS isn't 'required equipment' though (OK, it is by me, but not the CAA)

Ian

[S-Works]

So, for the avoidance of doubt, you do have a GPS/PLB code (prefixed by the letters CSTA) issued by the Maritime and Coastguard Agency? Or is that just being slavishly British?

And while we talking ridiculous rules, you have also registered the device (in accordance with those annoying UK aviation guidelines - AIC 57/2003) with the UK Mission Control Centre at RAF Kinloss? I know, blind obedience on my part ... but I was never strong on free thought!!

UK 406 EPIRB Registry
24hr Tel +44 01326 317573

Hex ID 1D160355BF81xxx
GPS 500-22445 S/N 17XX
Proof of Reg 25/09/06



Kinloss

01895 426150

Quote Ref No XXXX

Yes I have registered, I was not saying don't register, I was pointing out that it does not have to be registered to a craft.

Still spoiling for a fight because I said use a bit of free though?

[IO540]

That's very true Ian, about the GPS.

AIUI, the way this works is that non-required equipment has no approval requirements **

Any equipment whose carriage (or use) is mandated, has to be CAA/EASA type approved - unless it's one of the exemptions in schedule 4:

(a) the equipment referred to in Scale A (2); [Maps, charts, codes and other documents and navigational equipment ]
(b) first aid equipment and handbook, referred to in Scale A;
(c) time-pieces, referred to in Scale F;
(d) torches, referred to in Scales G, H, K and Z;
(e) whistles, referred to in Scale H;
(f) sea anchors, referred to in Scales J and K;
(g) rocket signals, referred to in Scale J;
(h) equipment for mooring, anchoring or manoeuvring aircraft on the water, referred to in Scale J;
(i) paddles, referred to in Scale K;
(j) food and water, referred to in Scales K, U and V;
(k) first aid equipment, referred to in Scales K, U and V;
(l) stoves, cooking utensils, snow shovels, ice saws, sleeping bags and arctic suits, referred to in Scale V;
(m) megaphones, referred to in Scale Y.

If I have this right, and it's the full picture, then this has been widely misrepresented by e.g. certain GPS manufacturers who have claimed that CAA approval is mandatory.

What the CAA has done, on say the oxygen front, is they published a proposal (still on their website here (http://www.caa.co.uk/docs/224/Appendix%205a.pdf)) which few people would have objected to. OK, it takes the FAA limits and in normal Euro-superior practice it gold plates them despite a total lack of evidence for doing so, but I doubt many people knew that the moment anything becomes required equipment it becomes subject to type approval - unless it is in the above exemption list.

People would have objected much more strongly if they had realised that the proposal will create a nice ripoff gravy train for suppliers of off the shelf gear but with the "right" paperwork included and sold at a much higher price.

** this is where the FAA regime is superior because they don't have this requirement. You can use any off the shelf oxygen kit in an N-reg, that meets the FAA specified o2 flow rate.

[bookworm]

Islander2 - The ANO amendment appears to ban DIY instrument approaches.

I don't see how you deduce that. The amendments to Art 49 deal with the case of an IFR flight to an aerodrome with no suitable alternate.

[Islander2]

Bookworm,

That gives the appearance of being attributable to me! It was IO540 that made the assertion ... I was setting him straight.

[bookworm]

That gives the appearance of being attributable to me! It was IO540 that made the assertion

Indeed it was.

[Droopystop]

Bit of a shocker this ELT business. I am with the masses who regard a handheld device as sufficient. To have a built in one, it requires (in my mind) the following to be worthwhile: Automatic deployment and activation on immersion in water (it needs to be floating upright on the surface to work), automatic activation in the event of a crash (for CFIT if you are lucky enough to survive the impact but otherwise incapacitated). That means a really sophisticated and heavy bit of kit which is pretty much inappropriate for private type flying.

A Macmurdo Fast Find Plus seems on paper ideal. Relatively quick response time and gives an accurate position so must give as good a chance of being found quickly as is available. BUT, DOES IT FLOAT? (a genuine question, because it doesn't make it clear in the literature I have read for it). If it doesn't, you are going to get a sore arm holding it up to the sky and if you drop it in the oggin......

So now ELTs are mandatory, when are they going to mandate lifejackets and survival suits so that when the helicopter arrives at the ELT it is looking for survivors instead of bodies? Or indeed ejector seats to ensure you are going to get out in the first place. There I go giving them more ideas.

[IO540]

What are the views, with references if necessary, on the usability of handheld ELTs for compliance with this particular requirement?

The FAA (for N-reg) mandates a fixed ELT which is activated either by the pilot or by a forward deceleration of something like 3G. They don't yet mandate 406MHz however.

[B Fraser]

A built-in ELT will assist in finding the wreckage at the bottom of the Irish Sea whereas a handheld EPRB / ELT will help find the shark (http://news.bbc.co.uk/1/hi/uk/430437.stm) that ate you.

IMHO, 5 point harnesses with a central buckle will make the ditching more survivable. A central buckle will be more easily reached by the arm that wasn't broken in the crash. How you get past your dead pals as you scramble from the rear seat of a PA-28 towards the single door is another question. What next, mandatory axes, explosive panels in the roof or as Droopystop has already mentioned, Martin-Baker armchairs ?

[IO540]

A built-in ELT will assist in finding the wreckage at the bottom of the Irish Sea

It won't; it's a radio transmitter only. There is no emission that will work underwater. Flight data recorders etc have acoustic emissions so the submersed wreckage can be located.

[david viewing]

McMurdo Fastfind
A Macmurdo Fast Find Plus seems on paper ideal. Relatively quick response time and gives an accurate position so must give as good a chance of being found quickly as is available. BUT, DOES IT FLOAT?

In December, I thought it was ideal as well.
Doubts set in as soon as I opened the supplied instruction booklet ('manual' would be too strong a word) which says "Although the PLB is buoyant when fitted with the -20 C battery pack, it is not designed for use while floating in water". It does have a photo of the thing free floating with the antenna extended, but unfortunately this illustration is labelled 'AVOID'. It further states that the Fastfind "is not designed for operation in water".

There seems to be a design problem with water becoming pooled around the antenna base. According to the booklet, the preferred position is clipped to your lifejacket and clear of the water. However there is no way to do this with the supplied equipment. Apparently an optional carrying pouch with belt clip is available.

Even if you did contrive to wear it as illustrated in the booklet, the device is quite bulky and heavy and must represent a potentially injurious object during a crash if placed next to your face as illustrated by McMurdo. You also have to wonder if it would survive the crash after being smashed against the instrument panel.

As supplied with a coily lanyard, you can almost guarantee that it will vanish and become trapped beyond reach in a crash, the Lanyard becoming yet another obstacle to escaping the aircraft. And the sheer bulk of the device would be an incumbrance if you did manage to hold onto it. Some people think of stowing it for retrieval after crashing and they may have more experience of these situations than me.

I am convinced that if you are not securely wearing it, it's unlikely you will have the use of it after ditching. (I have a wearable, water activated 121.5 beacon with a secure neckstrap antenna that would probably escape the aircraft with me and might help a helicopter locate my position based on the information that I would have given ATC prior to ditching.)

Like others, I am now considering which boat owning relatives would benefit from the gift of a Fastfind. As far as the aircraft is concerned, there seems no be no avoiding the prodigious expense of a fixed ELT since I don't want no invest in another bulky and impractical PLB. (That fixed ELT would be a replacement for the serviceable though not 406Mhz ELT previously removed from the aircraft at the CAA's whim).

[robin]

"Like others, I am now considering which boat owning relatives would benefit from the gift of a Fastfind............"

This is what I fail to undersatnd. The FastFind and equivalents seem to be a popular choice for yotties and they spend 100% of their time on the oggin.

So why should our usage be different. What is fundamentally different about us aviators that we have to carry "prodigiously expensive fixed ELTs" for the rare occasions when we have to ditch.

[david viewing]

So why should our usage be different.

Because they have time to plan their exit. Leaving a boat, you might have time to climb the rail while still holding onto the gadget. Who can say what the situation after a ditching is going to be? And a yottie is likely to be uninjured when entering the water.

Maybe the best way of using a Fastfind is to install it inside the liferaft. A rather 'eggs in one basket' solution!

[ericferret]

Having a beacon in a life raft is a good second option if you have the money for more than a couple of beacons. What if your raft goes down with the aircraft?

Decent aircrew jackets have pockets for the beacons built in.

In other words if you get out so does the beacon.

[Ni Thomas]

Just a thought .....
Could the McMurdo Fastfind PLB Plus be CAA 'approved' by association?
At the last CAA Safety Evening thingy I attended (in the dark recesses of last winter) - They the CAA Safety whallahs, provided for a presentation from a McMurdo representative, during which, said McMurdo rep. extolled the virtues of said apparatus with lots of nodding of head from the CAA safety bloke. Could a simple soul such as I, take that as a type of seal of approval.

I've got an old ELT in my aeroplane but I still bought a McMurdo Fastfind Plus PLB (£340 - by shopping around) as I wanted something with me when I ditched into the oggin and the ELT sank with my pride and joy.

I drive big ships for a living and they all have EPIRB units which hydrostatically detach and float to the surface when ones boat departs from beneath ones welly boots to meet Davy Jones. My Aero ELT doesn't similarily detach and float, leaving me to go all puce and rather cross with Lycoming as hypothermia sets in and I slowly become crab fodder.
Nope! Give me a personal locator beacon that will at least give me a chance.

By the way- IIRC, Austria too, demands ELT for its territory.

[robin]

Same for us.

We went to a CAA Evening and we had a similar presentation. The McMurdo dealer took a h*ll of a lot of orders as a result. And yes, the CAA bloke was nodding wisely throughout.

Unfortunately, the lads in the Paper Generation Plant at the Belgrano don't do much flying and probably don't know what an aircraft looks like (well the one I spoke to didn't). They just enforce the ANO as it is stated.

But wouldn't it be nice to put that in front of a court if someone with a McMurdo were prosecuted.

[IO540]

A CAA prosecution is highly unlikely, and if it was attempted it would likely fail, for the reasons given above (the CAA rep nodding through the presentation, etc). The CAA wouldn't even try it in the first place, IMHO.

The CAA read these forums daily and no doubt find all this highly amusing. They might just possibly be wondering how the hell did they create this mess.

A prosecution is also unlikely because the stuff is required only when flying too far from land or, in the case of oxygen, above 10k feet. The evidence for the former would probably have to be a radar track and they aren't kept for ever. The evidence for the latter likewise if VFR and with a Mode C transponder but again radar tapes are not kept for ever. On an IFR flight plan filed for FL150 it might be a problem...

IMHO the real issue here is airworthiness of the aircraft. If you have mandatory but non-approved kit then the CofA is invalid. Again, a CAA action on this is unlikely (reasons as above) but the insurance would quite likely be void. Insurance does cover pilot negligence (contrary to what most people on pilot forums say) but it doesn't cover flying with a void CofA. What I don't know is how this is affected by the fact that the violation occurs only if over water or above 10k ft. In effect, you have a valid CofA but it ceases to be valid over water or above 10k ft.

In the FAA case (which the ANO doesn't apply to) I am sure that with say no oxygen on board the CofA remains valid but not using o2 as prescribed is a violation on the pilot. Not having an ELT is a CofA violation however, because on an N-reg it has to be carried continuously.

[rjakw]

I don't think an alleged nodding man means much. He could have been suffering from Tourettes or Parkinsons - or maybe just struggling to stay awake.

The "CAA Regulatory Review of GA in the UK" dated June 2006 (see http://www.caa.co.uk/docs/1/reg%20review.pdf) proposed 19 recommendations which, if implemented, were supposed to "improve the regulatory environment". Preventing most of the UK GA fleet from travelling legally more than 15-20 miles off the coast was not among them - but they've done it.

[Rod1]

http://www.artex.net/products/oneproduct.php?categoryid=23&productid=40

Portable unit with the right bit of paper.

Rod1

[david viewing]

This situation is much more serious in the case of flights to Ireland. Even the 'short crossing' from Stranraer (itself a colossal diversion for most people) is frequently blocked by danger area activity.

[London Mil]

David, you mean that 402A and 403 complex which is permanently NOTAMed but a quick call to Scottish info will invariably recieve a "range is cold" response? Just one of my bug-bears about the West Freugh ranges.

[2close]

I think that maybe a letter (or several letters) to EASA outlining in a vey objective manner the practicalities and benefits of using hand-held PLBs within the aircraft as opposed to fixed installations may be in order, together with a request for an EASA approval to carry said PLB in aircraft.

This may then have the effect of obtaining an EASA approval that will overrule any CAA 'non-approval'.

Any views?

[Islander2]

2close

You and one or two others are missing the point. The new legislation does NOT require the ELT to be a fixed installation. A hand-held 'Survival ELT' per ICAO definition IS explicitly stated in the ANO (as amended) to be an acceptable means of compliance.

The real problem is that many of us already have COSPAS-SARSAT 406MHz hand-held beacons (a significant proportion of which have been purchased in view of the impending legislation with the tacit approval of the CAA), and now find that despite them being amongst the most popular PLBs in use (McMurdo, ACR, etc) they are an unacceptable means of compliance ... not because they don't meet the ICAO specifications, merely because they don't have either CAA or EASA approval!

And exactly the same situation exists with lifejackets, now they are mandated - few, if any, of the popular GA lifejackets are CAA or EASA approved.

And exactly the same situation exists with portable oxygen systems, now oxygen is mandated - few, if any, of the popular GA portable O2 systems are CAA or EASA approved.

Overnight, a large number of conscientious pilots have been put into a position where either they curtail their flying activities or they fly illegally. Transitional arrangements could have been provided, but haven't.

And that is p*ss poor regulation!!

[S-Works]

Any idea what is needed to get approval?

[robin]

I've written to McMurdo to ask whether or not they are seeking CAA/EASA approval for the product, given that on their website they have a section devoted to aviation use of the equipment.
I wonder what the cost would be for this?
It is the classic example of the CAA's approach for kit. ie they will mandate the requirement and leave it to the market to deliver the product to the specification.
They forget that there is a lead time so, for a period, we are either flying illegally or not flying at all while the market get themselves organised. We also have to junk perfectly serviceable equipment and pay over the odds for replacements.
This is turning into a trial run for the Mode S implementation.......:ugh:

[IO540]

A hand-held 'Survival ELT' per ICAO definition IS explicitly stated in the ANO (as amended) to be an acceptable means of compliance

I realise that a handheld unit isn't banned as such and is thus permitted but where is the ICAO bit? All I see is CAA/EASA type approval which is nothing to do with ICAO.

This is a totally stupid regulation especially w.r.t oxygen systems.

I am on N-reg so it doesn't affect me but if I was on G-reg I would be seriously cheesed off about getting shafted in this way.

[Islander2]

I realise that a handheld unit isn't banned as such and is thus permitted but where is the ICAO bit? All I see is CAA/EASA type approval which is nothing to do with ICAO.The ANO amendment extends the requirement for Schedule 4 Scale KK (1) or (2) equipment to non public transport flights. Scale KK requires the equipment to operate in accordance with the relevant ICAO provisions. Article 19 requires the equipment to be CAA or EASA approved. 'Survival ELT' as specified in Scale KK (1) is defined by ICAO as 'an ELT which is removable from an aeroplane, stowed so as to facilitate its ready use in an emergency, and manually activated by survivors.'

[Fuji Abound]

Can someone please provide a reference to the ANO change requiring the carriage of APPROVED life vests?

[Islander2]

Can someone please provide a reference to the ANO change requiring the carriage of APPROVED life vests?Statutory Instrument 2007 No274 - Article 4(11) for aeroplanes and 4(13) for helicopters - mandates the carriage of life jackets (equipped with whistles and survival locator lights) for non public transport flights over water beyond gliding distance from land.

Article 19 of the ANO requires all ANO-mandated equipment to be CAA or EASA approved, unless exempted by paragraph 4 of Schedule 4. No such exemption is listed for lifejackets!!

[Rod1]

Islander2

It appears I have made an invalid assumption. I had assumed that the 10 min flying time at cruse power applied to the life jacket requirement as well as the ELT issue. You have just mentioned “within gliding distance” which is a completely different can of worms. Is there a list of approved life jackets? Can we throw the guy who came up with this crap into the north sea to “test the system”.

My aircraft is out of gliding range for about 90 sec on the short crossing…

What is the penalty for using a non approved vest? I assume almost all the pilots who have visited France this year will have broken this rule, and if the penalty is a letter asking politely for me not to do it again…

Rod1

[vulcanpilot]

Dunno if this document is relevant

http://www.caa.co.uk/docs/33/CASPEC05.PDF

I use ex-MOD Mk25 life preservers (if they are good enough for the MOD.....) which are serviced by SEMS annually. I also have an (oldish) Satfind 406MHz PLB (registered with MCA).

Re. 406MHz PLB's - don't ever be tempted to buy one cheap from the USA (or anywhere abroad) as MCA will ONLY register PLB's that have been programmed with a UK designator...

This is an 'interesting' problem, particularly flying in the Channel Islands where you rarely get an inter-island transit above 1000' - not much chance to glide in midway there....

[david viewing]

London Mil

David, you mean that 402A and 403

That's right. It's a long way to route up there in the hope of a crossing, which if declined means turning back or a lot more than 10mins of sea to skirt around. Do you know if crossings can be pre-arranged?

[Droopystop]

Has anyone considered / tried getting an exemption for all this from the CAA. Exemptions exist in the commercial world, why not for private?

[rjakw]

There was a consultation. Why would they grant exemptions after such process? See -

http://www.caa.co.uk/docs/224/srg_gad_LoI%20290305.pdf

Note that several correspondents, including the PFA, expressed a view at the time consistent with those voiced here & on many other forums. Despite this, the CAA went ahead.

In the report, they said
"(12), (13) and (14) [PFA, AOPA & RAC] commented that a reasoned safety case with costs and benefits was required to support one element of the proposal that would require some owners to purchase new equipment, i.e. an Emergency Locator Transmitter (ELT). The cost of such equipment was thought to be unwarranted without such safety justification having been demonstrated. Correspondent (4) [PPL IR] expressed a reservation with regard to the proposed 10 minutes' offshore distance rule for ELT carriage, and correspondent (12) [PFA] thought this would be a significant inconvenience to many pilots."

"Correspondent (15) [the MOD] expressed support for this part of the proposal, from its perspective as a major provider of rescue services. Accordingly, the relevant appendix to the RIA (Appendix 8b) has been expanded to provide more detailed information showing that the proposal is justified."

Private pilots vs the MOD? No contest.

We know from wider world events how good an understanding the MOD has of front line service ops. This includes SAR.

[baldwinm]

Quote:
David, you mean that 402A and 403
That's right. It's a long way to route up there in the hope of a crossing, which if declined means turning back or a lot more than 10mins of sea to skirt around. Do you know if crossings can be pre-arranged?
You could call West Freugh on the phone before setting off to find out what's going on. IIRC correctly the phone number is in the margin of the 1:500000 chart and/or in the flight guide entries for Castle Kennedy.

[Flik Roll]

Surely if you can't get an ELT a PLB would be just as efficient? I don't know much about civvy stuff but doesn't anyone manufacture a life preserver with a PLB in?

[VP959]

I have asked the CAA to consider an exemption to the ANO for recreational aircraft, to allow the use of any suitable lifejacket or any approved EPIRB/ELT/PLB, not one specifically approved by the CAA/EASA. It is within the CAA's authority to grant such exemptions and is something that they have done in the past.

If I get anything useful back I will pass it on.

As it happens, I know the chap at the CAA pretty well, he's a dedicated light aircraft person, an all round good bloke and almost certainly feels as badly about this "gotcha" as we all do.

As far as I can gather, none of the bodies involved in the consultation, including the CAA, fully realised the implications of the pre-existing ANO requirement for CAA/EASA approval for all mandatory fit equipment.

Let's hope that common sense prevails, knowing the CAA chap I feel sure that he will make every effort to seek a sensible solution.

VP

[IO540]

A list of EASA approved equipment is here (http://www.easa.eu.int/doc/Certification/Design_Appro/etsoa.pdf).

No mention of oxygen equipment.

The CAA has messed up badly on this.

[robin]

Just seen an even more disturbing note on the PFA website which seems to make the current situation even worse (see item 9 on the first post)

http://www.pfa.org.uk/cgi-bin/ultimatebb.cgi?ubb=get_topic;f=6;t=000090;p=2

If this is true, the ICAO are looking to have all aircraft fitted with ELTs from next July. I cannot believe that this can happen so soon after this latest imposition, and we haven't yet sorted out the situation with PLBs.

Oh, and I've just had a note from McMurdo confirming that whilst there is nothing wrong in carrying the FastFind, it does not conform with the legislation. The one useful bit of information is that :

"McMurdo understands that the CAA is currently considering the wider
issues sounding the fitment and use of ELT's by light non commercial
aircraft on the UK aviation register and in respect of Air Navigation
Orders. "

[Phoenix09]

If this is true, the ICAO are looking to have all aircraft fitted with ELTs from next July.

As I understand it this only applies to new aircraft registered after that date. Unfortunately I have become so boggle eyed reading legislation over the last few days that I can't find the document that refers to this.

[robin]

That makes more sense. Thanks