The FCC has taken the next step in an effort to get Tracme to see the light regarding their misuse of the term “Personal Locator Beacon” to describe their FRS homing transmitter.

For background on this issue, please review the following Equipped.org Blog entries:

Original TracMe Blog Entry: “That’s No Personal Locator Beacon!”

FCC Initiates TracMe Action: “TracMe: Curiouser and Curiouser”

Tracme’s Response to FCC Initiating Action: TracMe to FCC: You Can’t Make Us…

After reported meetings with TracMe in an effort to resolve the issue, and with no apparent resolution as TracMe had expected, the FCC has formally reissued the TracMe grant, essentially revoking, in the eyes of the FCC, their use of “Personal Locator Beacon” to describe their device.

The Grant of Equipment Authorization for TracMe reads:

The FCC reissued this grant on November 2, 2007 with a modified grant note. In its application for equipment authorization the Grantee represented that the subject equipment is marketed as a “Personal Locator Beacon”. The Grantee, however, applied for approval of the equipment as a Family Radio Service device covered by Part 95B of the Commission’s Rules (not as a Personal Locator Beacon covered by Part 95K of the Rules), and this Equipment Authorization is granted for the subject equipment for operation solely as a Family Radio Service device under Part 95B of the Commission’s Rules. (click here to view the Grant document)

I contacted TracMe’s CEO, Joe Rainczuk, for his reaction, asking: “the FCC has reissued the TracMe grant and revoked the approval for use of the term Personal locator Beacon. Can you please advise if it is TracMe’s intention to comply with this or to continue to fight against changing the name?”

Rainczuk’s response was:

FYI,
(1) the FCC’s action last week did not revoke any FCC approval whatsoever,
(2) Tracme has always marketed its device in a manner that complies with its FCC equipment authorization and the FCC’s rules,
(3) the FCC knows that Tracme has always marketed its device in a manner that complies with its equipment authorization and the FCC’s rules,
(4) Tracme will continue to market its device in a manner that complies with its equipment authorization and the FCC’s rules and
(5) there is nothing in the FCC’s action that Tracme needs to fight since the FCC did not revoke any authority or approval that had previously been granted to Tracme.

We attempted to clarify if this meant that TracMe was intending to continue marketing the TracMe as a Personal Locator Beacon, but rather than provide an answer, Rainczuk attempted to assert, retroactively, that this communication and all previous communications we have had were privileged and could not be published on the ETS site and that I must not only not publish this, but demanded that I remove any previously published. So, it may be that we’ll no longer receive any further responses from Rainczuk to our questions. As a result, unfortunately, I don’t really have a clear cut answer to the question; you’ll have to draw your own conclusions.

It was the Coast Guard’s and AFRCC’s hope that this would settle the issue. If it doesn’t, and it would seem at first glance that TracMe isn’t buying into it, then the FCC will need to decide whether to pursue further options. We were unable to get a response from the FCC as to exactly what those options are prior to publication, but we’ll try to keep you abreast of developments.

The ETS evaluation of the TracMe is now available: www.equipped.org/tracme_eval.htm

SPOT has started shipping their new SPOT Satellite Messenger device and are hitting the PR wires heavily, as are their dealers (including some catering to the aviation market), so expect to see a lot of publicity about this new device. The question is, should you consider one in lieu of a 406 MHz PLB?

You can read about SPOT here:

Original SPOT Report from Outdoor Retailer Summer Market

Follow-up Report on SPOT

I have informally tested a pre-production unit in a variety of wilderness settings, but am withholding judgment until we get production units to test and can test them in an organized manner and comprehensively under difficult real-world circumstances. The sort of circumstances that a pilot or backpacker might find themselves in. I am expecting test units from the manufacturer shortly and then will commence our testing. I hope to have results by early December.

Unless you simply must have the latest and greatest gadget, money isn’t an issue, and you’re not really buying it as a distress alerting device, my suggestion for the moment is to sit tight until we have a better idea how well this device really works. Consider that this is the equivalent of version 1.0 software. Most of us know better that to be beta testers when something critical is on the line. While SPOT has received a great deal of publicity, it is not built to any recognized specification, has not been thoroughly tested by any independent authority, nor is there any operational history. It’s got some very cool tricks and a nice feature set, but I’m not inclined to suggest that you bet your life on the device at this time. Let’s see how it really works first.

The fires currently raging in southern California serve to remind us that it isn’t just earthquakes and floods and hurricanes that we must be prepared for. If you are not prepared ahead of time to evacuate quickly, or “bug out” to use the preparedness vernacular, you will not only likely suffer more than necessary, but you stand to lose irreplaceable personal items. We cover the issue of emergency preparedness at length on Equipped To Survive, the 72 hour kit article is a place to start.

However, there’s another element to preparedness that’s often forgotten. Houses and business can be replaced, that’s what insurance is for. However, what can never be replaced are those priceless mementos and family pictures, the family Bible and the like.

If you had less than 30 minutes to evacuate, and many in this latest fire had less than that, what would you choose to take? Would you even have time with all else you need to assemble. The key is preparation.

First off, if all your basic survival and preparedness gear is ready to go, the most basic of preparations, that’s one less thing you have to worry about. If your critical papers are also included with this gear and supplies, you don’t have to think about that either. Make copies or scan all critical paperwork, insurance policies, etc., and place on a USB drive. This will only take a few hours of effort and will save you untold hours of aggravation and money if you ever need them. Remember to keep these updated.

A laptop or notebook computer can be easily grabbed, but if you have only a large desktop, it may be easier to have it backed up to a compact-sized USB hard drive. That’s easier to grab and run with than a larger computer with all sorts of cables to disconnect. You ought to have a back-up anyway.

If you have scrapbooks or treasured personal posessions, the best bet is to store them in one place, ideally in some sort of easily carried package. Plastic totes make it easy to grab and go. If that’s too difficult, at least keep them in one place and have the totes ready, so all you have to do is dump everything in them. If even that’s not going to work, if there’s stuff you want to display, make a priority list with the location and use that to quickly assemble these treasures into the totes. The key is to minimize wasted time when there’s no time to spare.

You also have to realistic as to what you can take. How much can you fit into and/or on your vehicle(s)? Make a priority list, so you don’t have to try and figure out what’s most important when the time comes.

You can’t predict when some crises like fire will strike. You can be prepared so that you don’t end up running around like a chicken with its head cut off. The time to do it is now, when you have time to do it. Don’t put it off.

The NTSB has issued a Safety Recommendation as the result investigating a number of ditchings in the Gulf of Mexico by offshore oil crew helicopter services. Click here to read the letter to the FAA. There were two recommendations, one to do with mounting life rafts externally so they are more likely to be available, the other to do with PLBs:

Require that all offshore helicopter operators in the Gulf of Mexico provide their flight crews with personal flotation devices equipped with a waterproof, globalpositioning-system-enabled 406 megahertz personal locator beacon, as well as one other signaling device, such as a signaling mirror or a strobe light. (A-07-88)

The odds that the FAA will actually require the use of PLBs is infinitesimally small. But, with the NTSB recommendation now officially on the record, it does raise potentially serious liability issues for operators who do not follow the recommendation when it is not a particularly significant burden to do so. This is even more the case since some operators are already doing so. As a result, even without an FAA mandate, it may well prove to be effective at persuading more operators to equip their pax and crew with better survival gear including PLBs.

The NTSB recommendation also provides added support for the advantages that GPS provides for PLBs, quicker and more accurate location. They could have simply left it at PLBs, but they explicitly recommended GPS-equipped PLBs. While they were at it, they also recognized that despite all the advantages that a PLB provides, there’s still a place for the most basic signaling gear as well.

I don’t understand why the NTSB limited their recommendation to just Gulf operations.  The findings are as relevant for any such operations over water.

This NTSB recommendation also serves as another reminder to all pilots that these 406 MHz PLBs are a very effective tool by which to get yourself rescued in a timely manner. In many cases it could be the difference between rescue and simply recovery of your body.

Coming up for air after getting the TracMe Evaluation completed, it is time to update you on SPOT.

Click here to review our First Look article on the SPOT Satellite messenger

Last week I received a preproduction SPOT Satellite Messenger. Over next few weeks I and my associates will be playing with this SPOT to see how it works and figure out how to best test its capabilities for real once we receive production units.

I’ll be taking it with me to Portland, Oregon, this week and Alan will bring it along on a trip up in Northern Arizona, the following week.

After logging in and setting up the account, it’s easy to add emails and wireless accounts to your SPOTteam group and you can also change the default messages that SPOT delivers (see page here – NOTE: pages shown are under development and not final).

Today we took it out to a local park just for grins and to see how the online interface works. We set the SPOT unit down in the middle of a circular pad that’s easy to view on Google Earth and pushed the Check OK button.

We received text message notification, though it took some time on my Verizon phone. This provides the message plus a latitude and longitude for location. We then went home and looked at both the user account interface at findmespot.com and the results of clicking on the link provided via the email alerts. Both utilize Google Earth, just slightly different interface.

• Click here to see the basic online interface.

• Click here for the results of clicking on the emailed link, what one of your SPOTteam members would see.

SPOT also updated us on some of the questions we had or we raised in the First Look article.

While SPOT expects that if the unit does not get a GPS fix it is unlikely to successfully transmit to the Globalstar satellites, they have decided that in any case, they will transmit even if they don’t get a GPS location in Help and 911 modes. Also, they noted that as 911 and Help transmit every 5 minutes, there is a good chance that one of the following messages will come through with GPS coordinates.

This is not the case for Tracking, for obvious reasons. They also still don’t plan to do it for “Check-in” messages, figuring that many will use this to store waypoints, but also because check-in messages already are send in triplicate with the two redundant messages discarded by the backend server. I am partly mollified. I still think the Check-in message should be sent if at all possible, because Mom wants to know Sonny is safe, even if she doesn’t know exactly where he might be. Anything that keeps Mom from call out the SAR dogs is a good thing. By having the Check-in feature, it raises expectations on the part of the recipient. If it doesn’t deliver when expected, the reaction could be very negative. Sure, the user ought to know to make sure it can see the sky and get a GPS location, but stuff happens and people sometimes forget or don’t do what is expected after a long day on the trail.

SPOT apparently always planned to include instructions on the device, but the early prototypes we saw did not include them and that message never got delivered. They will be printed on reflective material permanently affixed to the case. Click for sample of instructions PDF.

Further testing has confirmed that SPOT will function properly on alkaline batteries, sending out 911 messages for several days in limited testing. LED’s will initially show green using fresh high-quality alkaline batteries, and then turned red to indicate low-battery status shortly after. Alerts are sent out regularly while the battery indicator was green, with some messages unsent as the alkaline batteries were depleted.

While SPOT will still strongly recommend lithium batteries, they will include information in the manual on using alkalines in an emergency. It is clear from testing that with no lithium batteries available, alkaline batteries can provide enough power to send out messages for a short period of time. The manual has also been amended to let users know that the low battery warning indicates 30% remaining. We’ll take a look at this ourselves in our testing.

SPOT anticipates that their testing will be completed and the coverage map will be updated from the Globalstar Simplex coverage map by the end of 2007. They do expect it to be expanded somewhat from that currently shown, but cannot say for sure until their tests are complete.

Gerber Legendary Blades has issued a recall for their EAB (Exchange-A-Blade) Pocket Knives which use a standard replaceable utility knife blade. During use, the back of the blade of the knife can slide past the blade support, posing a laceration hazard to consumers. Gerber has received eight reports of individuals cutting themselves while using the knife, including several individuals who required stitches. Owners of these knives should quit using them immediately.

The recall notice can be found on the Consumer Product Safety Commission site. Owners should contact Gerber to arrange for return of the defective knife and a free replacement.

Link: www.gerbergear.com

Well, the TracMe “Personal Locator Beacon” saga continues. For background on this issue, please review the following Equipped.org Blog entries:

Original TracMe Blog Entry: “That’s No Personal Locator Beacon!”

Follow-on TracMe Blog Entry: TracMe: “Curiouser and Curiouser“

In response to the FCC request that TracMe cease using “Personal Locator Beacon” to refer to their device (technically an FRS radio), on August 9th, 2007, American TCB, the Telecommunication Certification Body (TCB) that actually issued the TracMe FCC certification, sent the FCC a terse email that said, “Grant has been revised and sent to client.”

After it was clear that TracMe had not complied with the FCC request, I contacted the TracMe CEO, Joe Rainczuk, and asked him, “do you intend to continue to use this term, despite the FCC’s notice to you that this is not appropriate? If so, on what basis do you intend to do so?”

Here is Rainczuk’s response:

The FCC have not stopped us from using the term ‘Personal Locator Beacon’. I have extracted from our FCC lawyers letter to the FCC, part of the response that legally explains our position. Below is only part of the 6 page letter that will be sent.

There is No Basis for a Name Change in the FCC’s Rules

Nothing in the FCC’s rules supports the Office of Equipment and Technology’s implicit assumption that the phrase “personal locator beacon” can be used only for satellite-connected personal locator beacons governed by Part 95K of the Commission’s rules. To the contrary, the Part 95K rules demonstrate clearly that the phrase “personal locator beacon” refers broadly to equipment used to locate individuals for search-and-rescue purposes. When the rules turn to the particular requirements for satellite-connected personal locator beacons, they stop referring to “personal locator beacons” in general and start referring to the narrower satellite-connected subclass: “406 MHz PLBs.”^[1] These contrasting references – to personal locator beacons in general and to the specific satellite-connected subclass – compels the conclusion that the generic phrase “personal locator beacon” applies to both satellite-based and non-satellite-based devices.

Even if there were policy or regulatory reasons for a change (although, as explained above, there are not), the time for revisiting TracMe’s certification has long since passed. The TCB certified TracMe’s device on June 21, 2005, and the deadline for filing requests for review expired 30 days later.^[2] The Coast Guard’s request for review was submitted two full years after the deadline, and the FCC is therefore precluded from acting on it.^[3]
[1] See 47 C.F.R. § 95.1402 (listing the requirements for use of 406 MHz personal locator beacons).

^[1] See 47 C.F.R. § 2.923 (providing for applications for review pursuant to 47 C.F.R. § 1.115); 47 C.F.R. § 1.115(d) (application for review of action taken pursuant to delegated authority must be filed within 30 days of the challenged action).

^[1] See, e.g., Karen de Brum, Petition for Reconsideration, 22 FCC Rcd. 5069 (2007) (dismissing a petition for reconsideration that was filed four months after the 30-day deadline, holding that “[t]he Commission lacks authority to extend or waive the 30-day filing period for petitions for reconsideration unless the petitioner shows that its failure to file in a timely manner resulted from ‘extraordinary circumstances.’”). The TCB itself could have taken action to correct administrative errors in the certification, but only within the same 30-day period. See 47 C.F.R. § 2.962(f)(4).

I then asked if there was some reason he didn’t want to share the entire 6-page letter? He responded that “the entire letter is privileged information.”

I then asked if it wouldn’t be published in their file in 30 days or less by the FCC? He responded:

“No, my FCC lawyers asked the FCC for a face to face and once this happens and everything is resolved verbally there won’t be a need to publish anything. Status Quo stays. The 6 page letter shows legally why we are able to use the generic term ‘Personal Locator Beacon’. If there was a problem with us using PLB it would have been brought up 2 years ago when we got the certification.

Our competitors should not see us as a threat, but should see us as a complimentary life saving device. I always tell groups that want to buy TracMe to make sure they have at least 1 satellite PLB when they go on an adventure.”

So, this is where things stand at the moment. Why TracMe seems to think that my concerns, and that of others, is somehow the result of influence by the PLB manufacturers is beyond me. They have been clearly advised by numerous members of SAR organizations, by the Coast Guard and the Air Force RCC, and by others such as myself that their use of the term PLB is misleading and will likely lead to loss of lives due to consumer confusion. There is no hidden industry agenda, it’s not the PLB manufacturers out to get them, though they are not happy. All of us involved in SAR are perfectly capable of telling the PLB manufacturers to stick it. It is plain and simple that marketing TracMe as a PLB is a deception, regardless of whether it is legal or not.

It’s unfortunate that TracMe’s attitude appears to be along the lines of “you can’t make us.” TracMe appears to prefer to subvert the process in order to continue to use the term to their marketing advantage. It may well be legal, or it may well be that the FCC’s screw up earlier in the process provides TracMe legal cover so the FCC cannot fix their mistake now, but that doesn’t make it right.

The TracMe homing beacon is NOT a Personal Locator Beacon

The ETS evaluation of the TracMe is now available: www.equipped.org/tracme_eval.htm

In a Safety Recommendation released yesterday, the NTSB has once again recommended that the FAA require all aircraft have 406 MHz ELTs (Emergency Locator Transmitters – 121.5 MHz ELTs are currently required). They first recommended this back in 2000 and after vigorous opposition by AOPA, the FAA declined to do so. This latest recommendation comes in large part as a reaction to the upcoming cessation of 121.5 MHz satellite alerting on February 1, 2009 and is supported by an analysis in the report that looks at two recent accidents, one with a 121.5 MHz ELT and one with a 406 MHz ELT.

As you might expect, in the accident involving the 121.5 MHz ELT rescue was delayed. It took 16 hours to locate the crash and the pilot died as a result of hypothermia (3 died in the crash, 3 others survived). Mind you, part of the delay was due to adverse weather conditions. In the contrasting example, the aircraft with a 406 MHz ELTwas located in less than an hour despite the aircraft being destroyed in a post crash fire (all aboard died in the crash).

Beyond recommending that all aircraft be retrofitted with a 406 MHz ELT, the NTSB also recommends that this be required to be done by the February 1, 2009 end of 121.5 MHz satellite alerting.

Don’t hold your breath. It would be virtually impossible to retrofit the entire General Aviation (GA) fleet of NTSB estimated 180,000 aircraft by that date, even if the FAA jumped on it immediately and by some magic issued such a requirement tomorrow. That isn’t going to happen.

So, the question becomes, is this a good idea? Would replacing all 121.5 MHz ELTs with 406 MHZ save enough lives to justify the considerable expense?

Click here to see a table that compares 121.5 to 406 MHz beacons.

Good question, and I’m not aware of any well founded study that’s really looked at this question. My gut inclination would be that it would save more lives, but not a large number. Let me explain and also consider the alternatives.

In th first place, ELTs are not some magic bullet. They often don’t work in a crash. How often they don’t is subject to considerable debate, but by some estimates it is as high a 70%. Even if it is as low as 30%, the point is, in many cases it is useless. The disappearance of Steve Fossett this week on a flight with no ELT signal is more typical than not.

Right now the typical 406 MHz ELT designed for GA cost about $900 to $1000 and installation can run nearly as much in many cases. In some cases, installation is simple and almost a direct replacement, but this is only for a very small minority of generally later model GA aircraft. Mind you, should the FAA mandate installation of 406 MHz ELTs on a more reasonable timetable, it is possible that the cost would drop due to competition, eventually. But as was seen when the EU required that airlines and others install 406 MHz ELTs, the shortage due to the requirement compared to production capacity actually drove the cost up in the short run. Ramping up production would take a while and require a significant investment and developing new ELTs would take a couple years with all the testing an approvals required. So, lowered cost isn’t a slam dunk, but I feel it would eventually come down.

One alternative that’s been the subject of considerable discussion in the SAR world and among those involved in 406 MHz beacon industry, standards development and regulation has been to require, or at least strongly encourage, use of a 406 MHz Personal Locator Beacon (PLB). Some would like to see it approved as a legal alternative to the required 121.5 MHz ELT.

In 2006 I participated in a meeting convened during COSPAS-SARSAT Joint Committee Meeting in Montreal at the request of ICAO (International Civil Aviation Organization) that looked at these issues. A paper summarizing that meeting was presented at the next ICAO/IMO Joint Working Group on Harmonization of Aeronautical and Maritime Search And Rescue and this report covers most of the issues.

Aviation has already developed into a prime market for PLBs as GA pilots become knowledgeable about the benefits of 406 MHz alerting. PLBs are much less expensive than ELTs to begin with and prices are trending down in an increasingly competitive market. You can get a perfectly adequate PLB today for around $450 and top of the line PLBs are about $650.

By and large, as long as the pilot survives the crash, and the PLB is at hand, they would likely be able to activate it. However, mandating PLB carriage is itself fraught with issues since it is a portable device and can and will be also used for other activities, one reason it is appealing to many. OTOH, there are those aircraft owners who fly around without mandated or at least, functional ELTs. There will always be those too cheap or too anti-authority.

However, in the long run, I think it would likely save as many or more pilots as requiring 406 MHz ELTs, and being less expensive, would be an easier pill for AOPA to swallow. Mind you, I won’t hold my breath for that either.

So, at least in the short term, I don’t expect much to happen. I have been and will continue to encourage pilots to get a PLB. It’s the simple and reasonably affordable solution and it could well save your life. From my point of view, an unreliable ELT is backup to a PLB, not the other way around. If you’re unconscious or immobile and the ELT works, that’s great.

If I had a plane of my own, there’s no question I would install a 406 MHz ELT. I also think that the FAA should require all new aircraft to come with a 406 MHz ELT (many if not most do, but it isn’t required).

So, the bottom line is that the FAA is unlikely to follow the NTSB recommendation, but that doesn’t stop any aircraft owner from doing so. It couldn’t hurt. But, at the least, please get a 406 MHz PLB and carry it within reach on every flight.

SPOT Inc., a subsidiary of Globalstar, introduced its subscription-based “SPOT Satellite Messenger” at Outdoor Retailer Summer Market in Salt Lake City. SPOT is being promoted as a multi-purpose tool that can used as a distress beacon as well as providing options to request help without a full blown Search and Rescue response. It can also be used to notify friends, family or associates that you are okay and as a means to track your location.

Join us as we take a preliminary in-depth First Look to see if we’re willing to consider betting our life on SPOT at this juncture.

http://www.equipped.org/SPOT_ORSummer2007.htm

I have posted my Outdoor Retailer Summer Market 2007 Report on Equipped To Survive.

In years past, Outdoor Retailer hasn’t been a particularly fertile ground for me, SHOT Show is generally where the big influx of new gear comes. However, this year there were quite a few interesting new products in Salt Lake. Combined with the TracMe excitement, it was a very busy four days.

http://www.equipped.org/ORSummer2007.htm

Included is a in-depth FIRST LOOK at the “SPOT Satellite Messenger.” SPOT Inc., a subsidiary of Globalstar, introduced its subscription-based SPOT Satellite Messenger which is being promoted as a multi-purpose tool that can used as a distress beacon as well as providing options to request help without a full blown Search and Rescue response. It can also be used to notify friends, family or associates that you are okay and as a means to track your location. Join us as we take a preliminary First Look to see if we’re willing to consider betting our life on SPOT at this juncture.