ELT Now a legal requirment
 

This from another thread might be news to many.


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.

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 it then goes on to quote KK 1 or 2 which is an ELT conforming to certain specifications.

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

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.

IO5440, from the ANO

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

“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

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.

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'?

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?)

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.?

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. :(

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.

>> ...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?

I believe that is correct. More information on 406 MHz beacon coding, registration and type approval can be found here.

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!

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..

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

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.......:ok:

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?

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. :{

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

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.

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).

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.

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!

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

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.

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:

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.

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

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.

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?

"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!!!!!

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_ga...%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:


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.

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" ;)

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!!

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.

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

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

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

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.