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ELT Now a legal requirment

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Old 12th Apr 2007, 21:41
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ELT Now a legal requirment

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.
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Old 12th Apr 2007, 21:51
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The amendment to the ANO can be found here.

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.
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Old 12th Apr 2007, 22:53
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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
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Old 13th Apr 2007, 06:59
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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.
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Old 13th Apr 2007, 07:25
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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.
 
Old 13th Apr 2007, 07:42
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“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
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Old 13th Apr 2007, 07:52
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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.
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Old 13th Apr 2007, 07:54
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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'?
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Old 13th Apr 2007, 08:01
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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?)
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Old 13th Apr 2007, 08:10
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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.

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.

How heavy is the lightest COMPLIANT E.L.T.?
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Old 13th Apr 2007, 08:18
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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.
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Old 13th Apr 2007, 08:20
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>> ...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?
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Old 13th Apr 2007, 08:25
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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.
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Old 13th Apr 2007, 08:35
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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!
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Old 13th Apr 2007, 08:41
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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..
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Old 13th Apr 2007, 09:15
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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
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Old 13th Apr 2007, 09:48
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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_ga...t-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.......

Last edited by robin; 13th Apr 2007 at 09:49. Reason: Addition of link
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Old 13th Apr 2007, 11:01
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I think many flyers are going to carry on regardless, and ignore this law as being impractical & unsafe to comply with.

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?
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Old 13th Apr 2007, 11:10
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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.
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Old 13th Apr 2007, 11:12
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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
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