|Equipped To Survive Foundation|
Dedicated To Saving Lives
The non-profit 501(c)(3) Equipped To Survive Foundation has completed a series of laboratory and real-world performance tests of 406 MHz Location Protocol (GPS enabled) Distress Beacons (EPIRBs and PLBs). A detailed 200+ page report on the testing and results has been prepared. While summary results will be released to the public upon publication of the full report, this full report is available only via subscription. Background and test details follow below:
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NOAA (U.S. Department of Commerce's National Oceanic & Atmospheric Administration) and the U.S. Coast Guard organized a test of 406 MHz location protocol (GPS enabled) distress beacons in Key West, Florida, in March, 2003, with a limited retest of one company's beacons in May, 2003. The testing was an effort to determine, at the request of COSPAS-SARSAT, why approximately 66% of all actual real-world alerts from GPS enabled beacons (mostly EPIRBs) did not include the GPS derived coordinates, thus potentially slowing response to these emergencies. A report was presented to COSPAS-SARSAT on June 11, 2003.
The testing was based at U.S. Coast Guard Group Key West facilities and has come to be referred to as the "Key West Test." In addition to Coast Guard and NOAA representatives, also attending were representatives from NASA, U.S. Air Force Rescue Coordination Center (AFRCC), COSPAS-SARSAT Secretariat (from the UK) and five beacon manufacturers (ACR Electronics, Artex, McMurdo Pains Wessex, Microwave Monolithics and Techtest). Also present was Doug Ritter, executive director of the Equipped To Survive Foundation, which providing some logistical support to the organizers as well as serving as an independent observer. As part of the agreement to encourage participation by the manufacturers, all results of the testing have been de-identified and participants agreed not to publicly identify particular beacons.
The results of the testing showed that in other than ideal conditions, and in some cases even in ideal conditions, some beacons did not reliably provide location data within the first 30 minutes of operation. That was the limit established relating to the COSPAS-SARSAT regulatory requirements and beacon operating schemes. These beacons ostensibly meet all COSPAS-SARSAT requirements and have been so certified and have been further certified by the FCC for sale in the U.S. In the case of the EPIRBs, the units have been for sale for a number of years.
Retailers report that sales of GPS enabled EPIRBs and PLBs have been very strong, despite incurring a considerable price premium. They suggest that a significant factor in these sales is the expectation on the part of consumers, based on promotion by the beacon manufacturers, of quicker notification and rescue from their distress circumstances. Consumers have been willing to pay a premium of up to 50% for beacons with internal GPS to gain an advanced distress alerting capability that it appeared from the Key West test results they may not necessarily reliably receive from all beacons.
These results have not been able to be made public in a manner that provides the consumer easy access or understanding due in large part to the de-identification of the beacons required of the participants. Moreover, the regulatory bodies have been unable to take any remedial action due to the anonymity promise of the Key West tests and the fact that the beacons have been certified to meet the regulatory requirements and that is the only statutory or regulatory requirement. One of the report's recommendations was, "Consider whether the 406 MHz Beacon Type Approval Standard (C/S T.007) adequately tests the acquisition of GPS location in operational conditions…" Unfortunately, any such change will take considerable time to implement and meanwhile consumers are purchasing these beacons that did not appear to provide the additional lifesaving benefits they are advertised as providing and which consumers have every right to expect to receive.
Up until now the assumption throughout the government entities regulating these devices, the Search and Rescue (SAR) community, retailers and consumers alike has been that COSPAS-SARSAT certification meant that the devices all performed adequately and that there was not a significant difference in alerting performance between beacons utilizing GPS to obtain location information.
In part this assumption may have been aided and abetted because it is so difficult and expensive to conduct independent consumer driven testing. Such reporting on distress beacons has been primarily focused on easily distinguished differences in physical design, ergonomics, size, weight, and price and the gross performance differences that have been assumed to exist between various modes of operation, but not actually tested performance as is the standard for most such reporting.
Assuming the results of the testing were valid, the Key West Test suggested that the certification testing cannot be relied upon, at this time, to ensure a comparable minimum level of performance among the various beacons on the market. Again, assuming the results of the Key West testing were valid, neither did it appear that marketplace competition or concerns over liability have encouraged adequate or better real world performance levels be achieved by all manufacturers.
In another incident at the media event held by the AFRCC (U.S. Air Force Rescue Coordination Center) and NOAA on July 1, 2003, in Vermont, USA, to publicize the legal availability of PLBs to the U.S. public, a similar performance deficit manifested itself when one of the beacons in question failed to acquire GPS signals in what would have normally been considered a not particularly challenging environment; further suggesting that the Key West Test results were unlikely to have been an anomaly.
These apparent performance deficits could have profound and potentially fatal consequences, as well as leaving the industry and COSPAS-SARSAT system open to potentially devastating negative publicity and liability.
The Equipped To Survive Foundation determined that there was a need to conduct an independent test of these beacons unrestricted by the limitations imposed upon the participants in the Key West Test and with results that could be communicated to consumers. Consumers have an expectation that emergency lifesaving equipment will perform reliably and to its maximum potential if needed to save their life. Consumers have a need for a means to determine if lifesaving equipment will reliably meet these expectations and the Equipped To Survive Foundation has a history of testing such equipment in order to provide this independent and unbiased information to consumers. In addition, government regulators and related organizations have a need to determine if their regulations designed to ensure minimum acceptable performance of lifesaving equipment in the real world are actually doing so. Such testing would also serve to determine if the performance witnessed in Key West was an anomaly or if these results were reproducible, and therefor, likely valid.
Equipped To Survive Foundation has completed a series of real-world tests similar to those conducted in Key West, as well as laboratory testing to assess other issues that have been raised regarding possible performance deficits of some beacons. This evaluation has been partially underwritten by the non-profit 501(c)(3 ) BoatU.S. Foundation and West Marine, a major U.S. headquartered marine chandlery chain and purveyor of marine safety equipment, both wholesale and retail.
The following 406 MHz beacon manufacturers who offer GPS enabled beacons were invited to participate on the basis that they either are currently offering their EPIRBs and PLBs for sale in the U.S. or were anticipated to do so in the near future: ACR Electronics (U.S., owned by UK company), McMurdo Pains Wessex (UK), Microwave Monolithics (U.S.), SERPE-IESM (France). Techtest (UK), who offer their PLB as a Survival ELT or as a military PLB in the U.S. and were not originally invited, requested to participate. Microwave Monolithics and SERPE-IESM declined to participate.
In order to ensure that the consumer beacons tested were representative of those being purchased by consumers, West Marine supplied McMurdo and ACR beacons from their stock for the test. Those manufacturers who elected to participate were required by agreement to either provide beacons for testing (9 EPIRBs and 15 PLBs of each model to be tested) in the case of those not readily available in the U.S. or to replace beacons already obtained from West Marine and sequestered by the Foundation. Those manufacturers who elected to participate were allowed to have a representative observe the testing, subject to signing a confidentiality agreement and a personal waiver of liability. McMurdo declined to send an observer, ACR and Techtest did so. These participating manufacturers will also be given a preview of the draft report in order to obtain their reaction, which will be included in the report, and will be provided the raw data from their beacons upon publication of the report.
The following beacons were tested:
All beacons to be field tested were test coded. In the case of the operationally coded beacons supplied from West Marine stock, ACR Electronics' representative recoded their beacons with other test attendees and observers as witness. McMurdo required that the beacons be returned to their UK facilities for recoding and the Foundation made arrangements to ensure that the chain of custody was maintained and was represented at the recoding in the UK by Peter Forey of SARTECH Engineering, UK.
Laboratory testing was conducted at Imanna Laboratory in Rockledge, Florida, the week of December 8, 2003
The laboratory testing was designed to attempt to provide data to answer the following questions which have been asked repeatedly by consumers or which have been raised by various industry members:
1. How do the 406 MHz and 121.5 MHZ signal strengths radiated from the beacon antenna in normal operational configuration compare in performance among beacons? Information provided by manufacturers only indicates the nominal required performance as specified by COSPAS-SARSAT as measured at the circuit board.
2. Does water on the beacon attenuate the distress signal, and if so, by how much? The physical case design of one PLB design line has the likely potential in a wet marine activation or in a terrestrial activation if in the rain of retaining a very small amount of water in the antenna storage well where the base of the antenna is secured in a manner that some industry members claim attenuates the signal from the antenna. While it was not anticipated that other PLB designs would show this potential attenuation problem if it exists in that they lack this specific design characteristic, all PLBs were tested under identical dynamic and static wet conditions in order to ensure fair and unbiased results. The other question related to this if attenuation is found to exist is whether or not it is of a degree as to adversely affect distress signaling performance.
3. Will the beacon batteries last for the prescribed period of time (24 hours @ -40º C for Class 1 PLBs, 24 hours @ -20º C for Class 2 PLBs, 48 hours @ -40 C for EPIRBs) under worst-case conditions providing no worse than minimum allowable distress signal strength for the full period? And, related to this, is there a drop off in signal strength over time, and if so, how much?
The laboratory tests results will be included in the test report.
The draft field test protocols for this evaluation were initially based on those used in the Key West Test. They were then refined and additional tests added based on input from a variety of industry and government sources and the results of the laboratory tests. NOAA's technical support engineers provided valuable suggestions and a NOAA technical representative was present during the field testing as an observer. NOAA provided both GEO and LEO satellite data for the testing via the participating U.S. government partner, the Protection and Survival Laboratory FAA Civil Aerospace Medical Institute. Click here for an abridged copy of the test protocols.
The real-world testing was conducted the week of January 19, 2004 in and offshore of Santa Cruz, California. The actual tests differed only slightly from the protocols as a result of variable natural conditions and resource and time constraints, but virtually all the tests scenarios were satisfactorily completed. Considerable effort was made during the conduct of the tests to ensure that all beacons in any particular test scenario received equivalent GPS satellite availability. Numerous industry, sponsor and other independent observers were present to witness the field tests.
A printed and bound report on the evaluation conducted by the Equipped To Survive Foundation has been prepared. It includes an executive summary, background information and resources, detailed results of the testing, color photographs, analysis, conclusions and recommendations. Serialized copies of this test report are available for purchase.
The subscription price is $7,500 (USD). These funds will be used to cover the considerable expense of conducting the evaluation and producing the report.
The test report is serialized, copyrighted and licenced for use only by the organization or entity purchacing the report. To order a report, see below.
DISCLOSURES: Doug Ritter, Executive Director of Equipped To Survive Foundation, organizer and director of these tests and principle author of the upcoming report has had an ongoing professional and journalistic relationship with most 406 MHz beacon manufacturers for some time with manufacturers providing "dummy" beacons for display and photographic purposes. At various industry events, beacon manufacturers' representatives have treated Mr. Ritter to meals and both ACR and McMurdo have provided PLBs for Mr. Ritter to give away as door prizes during survival equipment presentations promoting 406 MHz PLB usage to various consumer groups. Mr. Ritter has recommended beacons from all the tested manufacturers to consulting clients and at times the beacons have been purchased via his contacts with the manufacturers or manufacturer's distributors. The Equipped To Survive Foundation has received 10% of sales of both ACR and McMurdo PLBs made on the GetRescued.net retail Web site operated by Pulver Technologies, which hosts the Equipped To Survive Web site. BoatU.S. Foundation has received price consideration from ACR for beacons purchased for their EPIRB rental program. West Marine sells both ACR and McMurdo beacons and other products by these companies.
The report may be ordered via this email form or by printing out this form and mailing with check or money order to:
Equipped To Survive Foundation
313 W. Temple Court
Gilbert, AZ 85233-7724
NOTE: For U.S. military use - CAGE Code: 3QQH3
Executive Director: Doug Ritter
Email: Doug Ritter
First Published on: January 28, 2004
Revision: 03 April 24, 2004
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