I wrote my letter to TC a couple weeks ago and received a reply letter thanking me for my response yesterday. I hope they listen to all of us.
 
Comments due today - 23 October

Here is my comment sent to

[email protected]

To the Civil Aviation Regulatory Affairs Division

What Canada does in this regard is your decision. However, there are two
big issues to consider.

1) If it applies to US aircraft entering Canada, it will dramatically drop tourism
because I will not equip with a 406 MHz unit.

2) ELTs are old technology. One article suggests that they fail to activate in as
many as 50% of crashes. When there are systems such as Spot and APRS
(ham frequency) that provide exact location prior to a crash, mandating an ELT
just using a new frequency is shortsighted and will not help as much as Spot or
APRS.

Ron Lee

That email address did not work.
 
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This is not....

Ron Lee said:
Here is my comment sent to

[email protected]

To the Civil Aviation Regulatory Affairs Division
......, mandating an ELT just using a new frequency .....
Ron Lee

......
Click to expand...

...quite true.

The new ELTs are also transmitting on the "old" frequency of 121.5 most of the time. The 406 frequency is used for a short burst about every minute.

There are other reasons to complain - such as compliance with unelected International Agencies (in this case, an IATA mandate), which the US is thankfully ignoring for now - but you need to keep the facts correct.

It is an "additional" frequency, not a "replacement" frequency.

The article in the first post also contained other factual errors - I guess one of these days Journalism Schools will emphasize accuracy over story....:rolleyes:
 
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You are right Gil but my comment is adequate. I understand the whole idea behind the improvement using 406 MHz (especially if GPS enabled). Look at the main thrust of my comment.....actually two

1) It will reduce tourism from the USA

2) It may not really help locate people compared to other technologies available.
 
isn't everyone else except us here in NA using 406Mhz for aviation? PLB's are 406 now too. Marine locators are 406 as well.
i think the SPOT technology is pretty good... they should definitely have done more to the devices if they are mandating a change. from what i've read and understood, the push is to get off the 121 frequency and move to the more common 406.
 
Not really...

swixtt said:
isn't everyone else except us here in NA using 406Mhz for aviation? PLB's are 406 now too. Marine locators are 406 as well.
i think the SPOT technology is pretty good... they should definitely have done more to the devices if they are mandating a change. from what i've read and understood, the push is to get off the 121 frequency and move to the more common 406.
Click to expand...

...the push is for coded beacons on 406 for satellite pick up, but still to have 121.5 - which not coded - for short range homing. I believe the marine ones are also dual band with a 121.5 output.

It is an IATA mandate (an unelected international body)- and nearby, Canada and Mexico are moving that way, the US has chosen not to (yet...:)...)

Since there is an element of socialism vs, free choice involved - I would assume most of the European countries have moved to the 406 beacons - can any of our VAF members on the other side of the Atlantic confirm?
 
Here's my letter to Transport:
-------------------------------

Chief, Regulatory Affairs (AARBH)
Civil Aviation, Safety and Security Group
Department of Transport
Place de Ville, Tower C,
330 Sparks Street
Ottawa, Ontario K1A 0N5

Dear Sir:

Re: Canada Gazette, Part 1, Vol. 142, No 32, August 9, 2008 ? Regulations Amending the Canadian Aviation Regulations (Parts I and VI ? ELT)

I am a pilot and owner of a small general aviation aircraft, and a professional engineer. I am writing to express my displeasure with the proposed change to the regulations regarding 406 MHz emergency locator transmitters.

I am sure that you have many letters objecting to 406 ELTs. Rather than re-hash the severe economic harm to aircraft owners and the almost complete elimination of private American pilot-tourists flying into Canada, I would like to discuss the bigger picture.

I worked for the (Canadian) company that developed the first commercial 406 beacons, called EPIRBs that are used on many ships and are the basic of personal locator beacons (PLBs) used by hikers. This is the technology base for the 406 ELTs proposed for use in Canadian aircraft.

This technology was developed over 20 years ago, pre-dating the availability of commercial global positioning satellites (GPS) which are now the backbone of navigation systems worldwide.

GPS, combined with other available technologies has rendered 406 MHz ELTs obsolete for their intended purpose.

ELTs, by their nature, must survive an accident in order to be useful. That means they must survive impact, fire, sinking and damage to the antenna or cables as well as the unit itself. The built-in G-switch must trigger and up to one minute must elapse after impact for the ELT to begin transmitting.

One minute is a long time when you are on fire or sinking. Survivors may have time to egress, but then they are alone, with no functioning ELT to help search and rescue find them. Up to 50% of aircraft accidents do not have their ELT survive or trigger.

There are much better systems available today or in the near future that are vastly superior. These devices use GPS positioning to transmit breadcrumb trails to satellites or ground stations. Should an aircraft go missing, or an old-style ELT is triggered it is a simple matter to go to a web site and find a breadcrumb trail for any or all aircraft in an area.

This does not require the survival of any equipment after a crash! Simply being overdue on a flight plan will allow search and rescue to locate a downed aircraft reliably.

Here is an example:

<snip APRS track>

If I had gone missing, It would be obvious where to look. This type of technology has many other uses other than search and rescue, and the relatively modest cost is easy to justify. The total system cost me $100, installed. Commercial systems will cost more, but not thousands of dollars!

It is vastly superior to the obsolete 406 ELT technology that was developed when MS-DOS was popular on every desktop computer.

Please consider this. 406 ELT offer very little for a great cost. There are better alternatives.

Sincerely

Vernon R. Little, P.Eng.
 
No 121.5 on water

The new epirb's carried on boats and ships no longer transmit on the 121 freq. The older ones did. The 121.5 is definately being phased out on water, if it isn't already done. I bought a old 121.5 elt for my plane and it isn't even done yet with the knowledge that probably within 5 years or so, I will have to upgrade, but dang those 406 machines are expensive.
 
ELT Quandry

I am about 1 year from the point where I will need to install an ELT.

Will I have to use the more expensive 406 by that time?
Do you think the FAA will have some sort of "phase out" with the older 121.5 elt's.

Thanks
 
Terry,
There is no way of predicting what FAA will do or when they will do it. My gut feeling is that they will eventually phase out the current 121.5 MHz ELT requirement. But I don't think it will be any time soon. I suspect when they do, it will be like the last revision in that you may keep your old unit until it fails, and at that point you will be required to replace with the 406 unit.
My guess!
 
Phase out?

I don't think the FAA has anything to do with the phase out and it will be a "cutoff"!. Here's a quote from the Cospas-Sarsat website.

The International Cospas-Sarsat System will cease satellite processing of 121.5/243 MHz beacons from 1 February 2009. All beacon owners and users should begin taking steps to replace their 121.5/243 MHz beacons with 406 MHz beacons as soon as possible...

...Beginning in 2009, only 406 MHz beacons will be detected by the Cospas-Sarsat satellite system. This affects all maritime beacons (EPIRBs), all aviation beacons (ELTs) and all personal beacons (PLBs). However, other devices (such as man overboard systems and homing transmitters) that operate at 121.5 MHz and do not rely on satellite detection will not be affected by the phase-out of satellite processing at 121.5 MHz.

Bevan
RV7A wiring now:cool:
 
Bevan said:
I don't think the FAA has anything to do with the phase out and it will be a "cutoff"!.
Click to expand...

While the FAA does not have any thing to do with the phase out, they have EVERYTHING to do with the requirements for US aircraft. That's what we're talking about here. Since there are other entities that will continue to monitor 121.5 for a while, I don't think that FAA will require our ELTs to activate on 406 for some time.
 
vlittle said:
Here's my letter to Transport:
-------------------------------

Chief, Regulatory Affairs (AARBH)
Civil Aviation, Safety and Security Group
Department of Transport
Place de Ville, Tower C,
330 Sparks Street
Ottawa, Ontario K1A 0N5

Dear Sir:

Re: Canada Gazette, Part 1, Vol. 142, No 32, August 9, 2008 ? Regulations Amending the Canadian Aviation Regulations (Parts I and VI ? ELT)

I am a pilot and owner of a small general aviation aircraft, and a professional engineer. I am writing to express my displeasure with the proposed change to the regulations regarding 406 MHz emergency locator transmitters.

I am sure that you have many letters objecting to 406 ELTs. Rather than re-hash the severe economic harm to aircraft owners and the almost complete elimination of private American pilot-tourists flying into Canada, I would like to discuss the bigger picture.

I worked for the (Canadian) company that developed the first commercial 406 beacons, called EPIRBs that are used on many ships and are the basic of personal locator beacons (PLBs) used by hikers. This is the technology base for the 406 ELTs proposed for use in Canadian aircraft.

This technology was developed over 20 years ago, pre-dating the availability of commercial global positioning satellites (GPS) which are now the backbone of navigation systems worldwide.

GPS, combined with other available technologies has rendered 406 MHz ELTs obsolete for their intended purpose.

ELTs, by their nature, must survive an accident in order to be useful. That means they must survive impact, fire, sinking and damage to the antenna or cables as well as the unit itself. The built-in G-switch must trigger and up to one minute must elapse after impact for the ELT to begin transmitting.

One minute is a long time when you are on fire or sinking. Survivors may have time to egress, but then they are alone, with no functioning ELT to help search and rescue find them. Up to 50% of aircraft accidents do not have their ELT survive or trigger.

There are much better systems available today or in the near future that are vastly superior. These devices use GPS positioning to transmit breadcrumb trails to satellites or ground stations. Should an aircraft go missing, or an old-style ELT is triggered it is a simple matter to go to a web site and find a breadcrumb trail for any or all aircraft in an area.

This does not require the survival of any equipment after a crash! Simply being overdue on a flight plan will allow search and rescue to locate a downed aircraft reliably.

Here is an example:

<snip APRS track>

If I had gone missing, It would be obvious where to look. This type of technology has many other uses other than search and rescue, and the relatively modest cost is easy to justify. The total system cost me $100, installed. Commercial systems will cost more, but not thousands of dollars!

It is vastly superior to the obsolete 406 ELT technology that was developed when MS-DOS was popular on every desktop computer.

Please consider this. 406 ELT offer very little for a great cost. There are better alternatives.

Sincerely

Vernon R. Little, P.Eng.
Click to expand...

Here's the Minister of Transport's response to all of the objections from the Pilot community. We win (for now).

Canada Backs Off 406 ELTs

Canada's Minister of Transport, John Baird, has overruled his bureaucracy and suspended implementation of a controversial rule that would have required almost all aircraft to have certified 406 Mhz emergency locator transmitters installed by February of 2011 in order to fly legally in Canada.

The rule would have applied to aircraft trying to enter Canada from other countries. In an interview with AVweb at Canadian Aviation Expo in Hamilton, Ontario, earlier this week, Kevin Psutka, president of the Canadian Owners and Pilots Association (COPA), said the minister refused to sign the rule as presented by Transport Canada because it didn't include any viable alternatives to 406 ELTs, even though it included language that indicated an alternative method of compliance was possible. "There is no technology that exists today that could meet those (alternative) requirements," Psutka said. He said the minister has ordered his staff to draft a rule that gives new technology a fighting chance for acceptance.

Psutka and COPA have been fighting the mandatory equipage with 406 ELTs for 10 years, arguing the new ELTs, while somewhat improved in the level and types of information they provide rescuers, suffer from the same operational flaws as the old-style 121.5 units. The vast majority of ELT signals are accidental and do not announce any kind of emergency. On the other hand, when a plane does go down, they fail to trigger more than half the time, according to COPA's research.

Psutka was urging Transport Canada and the Canadian Forces (which handles search and rescue) to consider new GPS-based systems that leave a "bread crumb" trail of position reports for rescuers to follow but the rule, as written, excluded all of them, he said. TC's position was that 406 ELTs meet International Civil Aviation Organization (ICAO) standards that changed when the satellite constellation that monitors search and rescue alerts stopped receiving 121.5 signals. The U.S. did not adopt mandatory 406 equipage, but the military and Civil Air Patrol are recommending aircraft owners install the new ELTs.
 
vlittle said:
Here's the Minister of Transport's response to all of the objections from the Pilot community. We win (for now).

Canada Backs Off 406 ELTs

Canada's Minister of Transport, John Baird, has overruled his bureaucracy and suspended implementation of a controversial rule that would have required almost all aircraft to have certified 406 Mhz emergency locator transmitters installed by February of 2011 in order to fly legally in Canada.

The rule would have applied to aircraft trying to enter Canada from other countries. In an interview with AVweb at Canadian Aviation Expo in Hamilton, Ontario, earlier this week, Kevin Psutka, president of the Canadian Owners and Pilots Association (COPA), said the minister refused to sign the rule as presented by Transport Canada because it didn't include any viable alternatives to 406 ELTs, even though it included language that indicated an alternative method of compliance was possible. "There is no technology that exists today that could meet those (alternative) requirements," Psutka said. He said the minister has ordered his staff to draft a rule that gives new technology a fighting chance for acceptance.

Psutka and COPA have been fighting the mandatory equipage with 406 ELTs for 10 years, arguing the new ELTs, while somewhat improved in the level and types of information they provide rescuers, suffer from the same operational flaws as the old-style 121.5 units. The vast majority of ELT signals are accidental and do not announce any kind of emergency. On the other hand, when a plane does go down, they fail to trigger more than half the time, according to COPA's research.

Psutka was urging Transport Canada and the Canadian Forces (which handles search and rescue) to consider new GPS-based systems that leave a "bread crumb" trail of position reports for rescuers to follow but the rule, as written, excluded all of them, he said. TC's position was that 406 ELTs meet International Civil Aviation Organization (ICAO) standards that changed when the satellite constellation that monitors search and rescue alerts stopped receiving 121.5 signals. The U.S. did not adopt mandatory 406 equipage, but the military and Civil Air Patrol are recommending aircraft owners install the new ELTs.
Click to expand...

thanks for the posting!
 
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