It seems to me that verifying the code every 2 years when doing the performance test should be enough.
This is where our limited experience in our one-owner General Aviation airplanes limits our perspectives.
The regulations are written to cover a broad range of contingencies. We tend to consider the regulation solely from our perspective, from our one use case.
In this instance the requirement to verify the code stems from the challenge fleet operators encounter when they move ELT's from airplane to airplane. This requirement came about as a result of an incident where a fleet operator's aircraft crashed and its ELT signal was detected by JRCC. In turn, JRCC used the beacon registry information to contact the operator to tell them aircraft XYZ had an active ELT. Nope, says the operator, that airplane is sitting on the ramp here. It took a little while to figure out the crashed aircraft was indeed a valid ELT activation and that it was carrying an ELT coded for an airplane that was sitting on the ramp back at home base.
Clearly this is not a good situation and it's one that our current regulations try to help us avoid.
I don't believe we in the "single owner" GA fleet are well served by this regulation - it's akin to swatting a small fly with a large cast iron frying pan - overkill.
The matter of the CBR Registry Verifier is entirely different. It was developed by a now-retired JRCC commanding officer as a hobby project. It has never been funded or supported - we're darned lucky to have it at all. This week it seems to have gone U/S - who knows when it might work again, if at all. The Verifier simply is not intended to be a diagnostic tool for the purposes of providing an end-to-end ELT operational check.
Realistically, it would take precious little to develop a highly useful end-to-end beacon test tool (after all, one person did it as a hobby project!). While our government talks big about public safety and drives multi-thousand-dollar "safety" equipment mandates down our throats they also ensure the public purse is never opened to make a true safety enhancement available to Canadian citizens.
Keep in mind it's not just ELT's that use the 406MHz signal, it's EPIRBs on boats, PLBs in the hands of hikers and mountain bikers. We could very easily provide a broad swath of Canadians with a very worthwhile method of verifying the operational readiness of their distress beacons. Instead, our government has opted to craft legislation which specifically removes themselves from the role of providing a public service, all so they can avoid some perceived liability.
What an opportunity missed.
OK, rant mode off.