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ELT and Part 135 ops

CASA revives a dead dog – opinion

Posted by:  Posted date: August 31, 2012 | comment : 0

The Civil Aviation Safety Authority has exhumed what one of its AOC holders describes as “a long-forgotten dead dog from about 12 years ago. I thought that smell had completely gone away.”

No such luck it seems. A consultation draft dated 11 July 2012, set out in 16 late additions to CASA’s proposed Part 135 rules, covering a wide range of highly significant proposed changes, including one that blandly states: “emergency locator beacons [are] required to be fitted for all flights, however for flights up to 50 nautical miles the beacon can be portable.”

What all this means is that if you’re flying 51 nautical miles or more, under this proposal you’ll need to have a fixed ELT fitted to your aircraft. The relevance of the relationship between ELT types and distance travelled before the mishap remains unexplained.

The closing date for comment, Friday, August 24 (last week) provided just six weeks for an industry already buried under a mountain of “regulatory reform” paperwork, to identify the dead dog and TO prepare and submit responses.

The current rules about carrying ELTs were put in place in and around 1997. Prior to 1996 there had been a set of rules that cited the familiar mantra that “we must comply with ICAO” and every aircraft in Australia that was going to fly more than 50 nautical miles had to carry an ELT. The cost to the general aviation fleet of affected aircraft was about $16 m in 1990s dollars, but when the consultation draft was published, CASA said its regulatory impact study (RIS) was incomplete and would be published during the six weeks comment period. Cost benefit studies were not mentioned. Two days after the closing date for submissions, CASA admitted the RIS “took longer than expected. It is now scheduled for release in 2 weeks,” i.e. three weeks after the response deadline.

The proposed requirement comes despite an AOPA study back in the nineties which established that fixed ELTs had a 90% failure rate, and of course a 100% failure rate in water. Other research only created more doubt. AOPA studies further identified three Airbus crashes where the empennage had been largely intact, the flight and voice recorders were retrieved undamaged, and even in those cases the fixed ELT which was fitted virtually in the same racks as the flight recorders, still failed to work.

Most light aircraft owners quickly figured out that they’d be better off leaving the scene of the accident with a portable beacon or two in their pockets rather than relying on a fixed device attached to an aeroplane that might be underwater, about to catch fire, damaged by impact, or surrounded by undernourished crocodiles. Neither were they wildly enthusiastic about trying to crawl into the aft fuselage of an inverted Cherokee trying to recover the fixed beacon. Further research showed that some owners had experienced skin cracking around the ELT installations because of the localised rigidity the installation caused to the monocoque structure, and many went along with the argument that one or more portable ELTs offered a more sensible fix with less risk. While some newer-version ELTs have improved performance, their overall reliability is still under several unresolved clouds. These include the problem that the only known way to test the impact switch is by doing something we all spend a lot of time avoiding, and that the systems still rely on a remote antenna connected by a wire.

The ATSB’s report on the Norfolk Island ditching accident adds a real-time account that puts the realities of ELTs into further perspective:

The aircraft was fitted with a 406 MHz emergency locator transmitter (ELT), which was designed to transmit a distress signal that could be received by a satellite. The ELT could be manually activated by a switch in the cockpit, and it would also activate automatically if the aircraft was subjected to g-forces consistent with an aircraft accident.

The aircraft was also equipped with four personal locator beacons (PLBs) that could be carried separately and manually activated. Two of these beacons were installed in the life rafts, and one of the remaining beacons was equipped with Global Positioning System (GPS) equipment, which would enable it to transmit its position when it was activated. The aircraft occupants were unable to retrieve any of the PLBs before they exited the aircraft after the ditching.

The aircraft-mounted ELT was not GPS-equipped. A geostationary satellite received one transmission from that ELT and the information associated with that transmission was received by Australian Search and Rescue (AusSAR) 38 8 minutes after the aircraft ditched. AusSAR was able to identify the owner of the ELT, but was not able to assess its location from the one transmission.

Obviously the single transmission was impact-activated; however it seems probable that the airframe damage caused the antenna or its connecting lead to fail after that first transmission.

The cost was another deterrent to fixed ELTs. We’re told that under the old standard you’d have been looking at minimum cost of $3,000 to $5,000 per aircraft, but under new airworthiness rules recently thrown into the ring and yet to be costed, there’s really no way yet to arrive at an implementation cost for the dead dog, except that to be assured that it won’t be discounted.

The controversial law had already been embraced in the regulations but with a forward implementation deadline, and although some aircraft owners had actually fitted fixed ELTs to their aircraft, many sat on the fence until the last moment. That turned out to be a very good idea because when the Howard government came to power in 1997 the incoming minister John Sharp responded to industry input and issued a directive, the law was changed, and the ELT rules were disallowed, in an outcome that was attributed to AOPA’s (then) alertness and influence.

It may be interesting to observe AOPA’s reaction to this and other reversals. A sad but probable outcome will probably be the gradual disappearance of some of the more modern light aircraft from commercial operators’ flight lines as owners reassess the cost of keeping them compliant with CASR 135.

Meanwhile readers may be well advised to study all 16 proposed changes, perhaps imagining that you’re reading them through the eyes of an operator or pilot somewhere in the Cessna 172 to Piper Chieftain range, and let’s see how many more hooks and barbs you can identify.

The following are word-for-word from the CASA draft, and it might be worthwhile to ponder the costs of these and other requirements already published, and perhaps share your cost-benefit analysis with us in the comments box:

Significant changes

  • All Part 135 aeroplanes will be required to be operated in accordance with a Minimum Equipment List (MEL).
  • Aerodromes standards – For aeroplanes less than 5700 kgs, Part 135 requires runway widths as per the Part 139 MOS Chapter 13/other legislative instrument, unless some narrower width is allowed under the operator’s approved exposition (It should be noted that floatplane ‘aerodromes’ standards are still to be written).
  • The ability to use single engine aeroplanes approved under Part 90 for IFR and NVFR operations (Airworthiness Advisory Circular 1-116 requirements are to be incorporated into CASR Part 90 for the aeroplane approval process. Operational procedures must be included in the operator’s exposition.) CASA also proposes to manage the very few turbine powered aeroplane below 5700 kg that can currently carry more than nine (9) passengers but cannot meet the current CAO 20.7.1B through an engine monitoring program under CASR Part 90.
  • The new ICAO fuel-standards for Part 135 fuel planning and fuel use rules have been incorporated, including requirements for operators to monitor the soundness of their fuel policy.
  • The introduction of ICAO take-off alternate requirements where a return to the departure aerodrome is not possible due to weather. An alternate will also be required when planning flights to a ‘relevant external aerodrome’ as defined in Part 135 (Lord Howe, Norfolk, Christmas and Cocos Islands).
  • Inclusion of the ICAO approach-ban criteria.
  • Performance criteria for very light jets and aircraft above 5700 kg are referenced under Part 121. This is to avoid duplication and it is consistent with current CAO 20.7.1B.
  • Additional rules requiring operators to outline specific procedures for determining IFR take-off minima in relation to the performance of the aeroplane used at the time.
  • A new requirement for weather radar to be fitted to aeroplanes with more than 5 passenger seats conducting IFR operations. The commencement date of this requirement will be determined after consideration of any technological developments in weather reporting systems that may be suitable as an alternative to radar systems.
  • Autopilot requirements for single pilot operations in passenger air transport operations with relief for cargo only operations in certain aeroplanes before 30 June 2015.
  • Emergency locator beacons required to be fitted for all flights, however for flights up to 50 nautical miles the beacon can be portable.
  • TAWS B fitment for passenger-carrying IFR operations on aeroplanes configured with more than 5 passenger seats. The commencement date of this requirement will take account of the commencement date of GNSS requirement for IFR aircraft, in order to take advantage of expected technology advancements that will reduce costs of incorporating TAWS functions.
  • Additional criteria for flights over water, including requirements for the wearing of life jackets and the carriage of life rafts when flying beyond gliding distance from a safe forced landing area.
  • The introduction of a portable, emergency proficiency training qualification for pilots for over water operations.
  • Operator and flight crew member’s training, checking and recency requirements based on an operational complexity model. Pilots flying multi-engine aeroplane require two (2) proficiency checks annually but VFR single engine pilots will require one (1) only.
  • The ability for operators to use certified Part 142 organisation for their training and checking activities provided they do so to the requirements of the Part 135 AOC holder’s Standard Operating Procedures.