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Pitts2112
21st Oct 2006, 08:46
To pick up on Mode S again, I visited my MP a week ago to ask his support with the issue. I explained the sham consultation the CAA were holding, the lack of accountability with the DfT, and the desire of the GA community to be part of the solution.

The upshot of the meeting was he asked me to write a formal letter to him (text below) and he would forward it on to Douglas Alexander, SoS for Transport, which he confirmed today he has done. In my letter, I asked for his help in overseeing a proper consultation process. I proposed that the CAA abandon the current Mode S proposal and open up a working group with the GA representative bodies to find a solution to the problem of safe use of the complex airspace in the UK as commercial transport continues to grow over the next 20 years.

I've never seen another issue unite the GA world like this one has. If enough MPs get direct contact from us about it, then they'll have to do something. If you haven't written to your MP, I hope it's not too late to do so and have an impact on this process.

Please feel free to use any or all of the letter below to send to your own MP!

I'll let you know if I get any further word from him. Let's hope the CAA sit up and take notice.

Text of my letter to Jeremy Hunt, Conservative MP:

15 October 2006

Ref: Civil Aviation Authority Consultation on Mode S

Dear Jeremy,

I am writing to ask for your assistance in overseeing the consultation the Civil Aviation Authority is conducting on the issue of Mode S transponders in all aircraft. I am concerned that the CAA are acting unilaterally and are not conducting a fair and open consultation with the General Aviation (GA) community. Time is of the essence as the CAA are expected to issue a final ruling by the end of the year.

The CAA is deciding on a proposed rule to require all aircraft of any type to carry a new piece of equipment known as a Mode S transponder. They have issued a public consultation document (the response period closed on 29 Aug), as required by law, but the wording and tone of the document leaves a strong impression that they have decided on the issue, are not open to genuine input and alternative proposals, and are conducting a sham consultation with the general aviation community.

To briefly explain Mode S, it is a new piece of equipment, replacing an older system, which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless using certain types of airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken this one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors).

The concern the general aviation community has is that Mode S does not actually effect the problem the CAA are trying to resolve. Their own consultation document fails to support their proposal. The problem the CAA are trying to address is the safe use of complex and congested airspace in the UK, by a wide range of users and aircraft types, as commercial traffic continues to grow, and it is a genuine issue.

The concern the general aviaition community has is that the CAA are not acting in our best interest or the best interest of aviation as a whole. The CAA has lost the confidence of the very constituents they are meant to look out for and this issue has undone years of good work in building relationships between GA pilots and the CAA. Mode S is merely one alternative, not the only solution. But it is the only solution the CAA have thought of and they are clearly intent on carrying it through, much to the detriment of the GA industry. The Department for Transport have, in the past, made it clear that they are unwilling to question the CAA on their policies and procedures, implicitly making the CAA an uncontrolled regulatory authority with no accountability or oversight of due process. This is not how a regulatory body should be controlled in a free and democratic society.

I propose, and would like your support in enacting, that the CAA abandon this consultation and the Mode S proposal as it is fundamentally flawed in conception and damaging to the relationships between the GA community and the CAA. To instill a new sense of trust and goodwill, this consultation would be replaced by a working group, overseen by an independent third party arbiter, and including the representative bodies of the aviation community such as the Popular Flying Association, the British Gliding Association, and others. There is enough technical and operational experience in those organisations and the GA community that, given an opportunity to be part of the solution, they may come up with a more creative, more effective, and more democratic answer than the CAA have done by themselves.

Thank you very much for your time and attention on this matter. I look forward to hearing from you soon.

shortstripper
21st Oct 2006, 09:22
Well done Pitts,

Copied (I couldn't word it better) and sent to Andrew Tyrie, MP for my area (Chichester West Sussex).

It might help ... you never know?

SS

pulse1
21st Oct 2006, 09:37
Well done chaps. Funnily enough, I was lying in bed this morning thinking that all PPL's should write to their MP's about Mode S.

Letter going off this w/end to Bob Walter MP. I think it is also worth making the point that the cost to the industry is way higher than that forecast by the CAA. The only way their costs can be right is if the GA community is decimated, which it may well be if this goes ahead.

kevmusic
21st Oct 2006, 10:51
Well done, Pitts, & thank you.

Copied & sent to Bob Marshall-Andrews.

Kev.

stickandrudderman
21st Oct 2006, 11:04
Good idea.
Is it worth mentioning the costs of the equipment to aircraft owners?
If so, what will that be?
(I haven't got room for anything in the Chippy!!)

ChampChump
21st Oct 2006, 11:46
A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..:ok:
Thanks
CC

Pitts2112
21st Oct 2006, 12:08
Good idea.
Is it worth mentioning the costs of the equipment to aircraft owners?
If so, what will that be?
(I haven't got room for anything in the Chippy!!)
I specifically didn't do that for two reasons (though Jeremy did ask me in our meeting).
1. I didn't want the argument to become about money or funding. The issue for me is the CAA's blind insistence that this is the only solution and their bullying tactics to get what they want. If we make the argument about money, it makes us sound like rich toss-pots whinging about having to spend more of our money on our expensive hobby. It also is an argument that be easily discounted or worked around.
2. I didn't expect my MP to become embroiled in the Mode S issue per se, but I did expect him to be interested in a Government controlled organisation not conducting a democratic process in good faith.
The other thing about costs is that there is still no device suitable for all aircraft so talking about cost is pure speculation and fiction. Not a good place to start an argument in Parliament.
Keep going, folks. Put the ideas in your own words and send it off the your MP!
Pitts2112

Pitts2112
21st Oct 2006, 12:11
A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..:ok:
Thanks
CC

CC,

Hadn't heard that and there's nothing on the PFA site to that effect, so I would guess the CAA haven't gone public with the info if that's the case. However, I would argue the letters are still worth sending because if our MPs or the DfT like the idea of a working group, then they might still push for it's establishment regardless of the deadline moving back. If we can get a working group set up now, then it has the full time and attention till 2010 to reach a better solution.

Pitts2112

ChampChump
21st Oct 2006, 12:25
Thanks Piits. I'll resume printing mode and see if the local MP can do something useful. There's always a first time. :hmm:
CC

robin
21st Oct 2006, 12:49
A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..:ok:
Thanks
CC

I'll believe that when I see it in print on the CAA website. I'm not even happy about a postponement - I want a complete reconsideration of the entire issue, as per Pitts note

ChampChump
21st Oct 2006, 12:55
I wish I'd got chapter and verse from him, but was otherwise occupied and it didn't register fully at the time.
I agree that it certainly won't hurt to keep pushing and get the democratic representatives (if not the processes) active.....
CC


Done!

stickandrudderman
21st Oct 2006, 13:39
I specifically didn't do that for two reasons (though Jeremy did ask me in our meeting).
1. I didn't want the argument to become about money or funding. The issue for me is the CAA's blind insistence that this is the only solution and their bullying tactics to get what they want. If we make the argument about money, it makes us sound like rich toss-pots whinging about having to spend more of our money on our expensive hobby. It also is an argument that be easily discounted or worked around.
2. I didn't expect my MP to become embroiled in the Mode S issue per se, but I did expect him to be interested in a Government controlled organisation not conducting a democratic process in good faith.
The other thing about costs is that there is still no device suitable for all aircraft so talking about cost is pure speculation and fiction. Not a good place to start an argument in Parliament.
Keep going, folks. Put the ideas in your own words and send it off the your MP!
Pitts2112

Good call!

kevmusic
6th Nov 2006, 18:56
My MP has just written back to me ask for 'more clarification as to the purposes of this instrument'. Fair enough. Not yet being a PPL and not having covered transponders thoroughly yet, what should I tell him?

Kev.

Zulu Alpha
6th Nov 2006, 21:11
This what I wrote to my MP

Good luck!

To briefly explain Mode S, it is a new, fairly expensive (~£5,500 inc fitting) piece of equipment which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless they wish to enter certain types of restricted airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken the European Aviation Safety Agency requirements one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors), even if operating outside controlled airspace. No other country is extending the requirement to all aircraft. The CAA proposal is that tens of thousands of Mode S transponders will have to be fitted and switched on.

Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal

robin
6th Nov 2006, 21:41
Zulu Alpha

What a great summary. Well done

pulse1
6th Nov 2006, 21:51
My MP has replied to say that he has forwarded my letter to Sir Roy McNulty, head of the CAA, and has asked Douglas Alexander to comment on the accountability of the CAA. Will keep you informed of the outcome.

possel
7th Nov 2006, 11:48
Excellent thread. Going to do this myself when I get home.

DO IT!

Roffa
7th Nov 2006, 12:10
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen.

Can you explain to me exactly what you mean, or think, by that statement?

rustle
7th Nov 2006, 13:03
To briefly explain Mode S, it is a new, fairly expensive (~£5,500 inc fitting) piece of equipment which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless they wish to enter certain types of restricted airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken the European Aviation Safety Agency requirements one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors), even if operating outside controlled airspace. No other country is extending the requirement to all aircraft. The CAA proposal is that tens of thousands of Mode S transponders will have to be fitted and switched on.

Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal

Possibly the worst "explanation" of anything in the history of the world.

:D Well done.

Pitts2112
7th Nov 2006, 16:51
Possibly the worst "explanation" of anything in the history of the world.

:D Well done.

Your point being, Rustle? If we need to be putting something to our MPs that's better than that, let's get some new words on the table. Anything it takes to get the issue properly resolved. :ok:

Folks, generally speaking, I think these last few posts are excellent. MPs seem to be taking some interest and asking the right kinds of questions (accountability of the CAA, for one). Keep up the effort and the good work!

Pitts2112

rustle
8th Nov 2006, 08:20
Possibly the worst "explanation" of anything in the history of the world.

:D Well done.
Your point being, Rustle?

Pitts2112

My point being that if that post (which I referred to above) was sent to an MP to enable them to ask questions of the minister or the caa, it has so many holes in it and is so wrong on so many points that it will do a lot more harm than good.

1. Minister person (with advice) can shoot it down in flames as incorrect
2. CAA can do likewise and will use that as an example of the dis-information that is being spread about

If telling lies about technology is the only way forward for the anti-mode-S mob I guess we'll see you in the avionics shop soon ;)

IO540
8th Nov 2006, 08:43
One should keep threads on here informative at all times. So let me have a go, editing the previous version:


To briefly explain what a Mode S transponder is:

It is a piece of equipment, installed in the aircraft at a cost varying between £2000 and perhaps £4000 (depending on various factors including whether a transponder was installed previously) which the CAA is proposing to make mandatory.

The reason being given is to improve safety. However, the CAA has thoroughly failed to make their case for this, as the attached proposal and the commentary demonstrates [attach CAA proposal and one or more of the [I]informed comments on it from the various GA bodies; some of these are actually OK]

There are many aircraft types on which the transponder installation is impractical; for example due to not having an electrical supply.

Transponders are mandatory in certain classes of airspace but they should not be made mandatory for all light aircraft.

Understandably, other European countries have exempted their general aviation aircraft from this requirement, but the UK CAA is determined to drive it through.

The UK general aviation scene is already suffering from excessive regulation and this will make matters worse.



Or something like that....

However, I think Mode S is a lost cause, for all planes other than those on which installation is technically infeasible.

pulse1
2nd Dec 2006, 15:25
I have now received two replies from my MP re. Mode S.

The first encloses a response from Sir Roy McNulty, Chairman of the CAA, and was probably written by Humphrey Appleby. I haven't finished decoding it yet but it doesn't seem to say too much that is helpful.

The second is from Gillian Merron MP, PUS for Transport. She says that -

"The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft, including microlights, balloons and paramotors, unless the activity is unusual and likely to cause interaction with other types of airspace user (e.g. an endurance flight)............. Until a Mode S Low-power SSR Transponder (LPST) is available commercially for use within UK airspace, all classes of light aircraft will operate under a blanket exemption."

That sounds like good news.

jabberwok
2nd Dec 2006, 16:28
Until a Mode S Low-power SSR Transponder (LPST) is available commercially for use within UK airspace, all classes of light aircraft will operate under a blanket exemption.

So does this suggest the minute an LPST comes on the market the CAA will cancel the exemption? Worrying rather than good news.

Zulu Alpha
2nd Dec 2006, 16:32
I have just returned to this thread as my MP has sent me a copy of a letter he received form the CAA.

I see there is some criticism of my letter. Not sure which bit was being objected to but let me make some points

Cost... £4700 + VAT was what was charged by Extra for fitting a Mode S on a new Extra. Maybe it will reduce but that's an actual number at present. I used it.

The other point was that I could not see any point is having a mode S transponder in a PFA type unless the aircraft has radio and is talking to someone. If I'm buzzing around in uncontrolled airspace in East Anglia with radio off and Mode S on what are the ground stations going to do? Probably use the software to remove my trace from the screen unless I get near controlled airspace? This is what I meant by filtering my signal out.

Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.

I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms. We need this so that MPs can make a judgement between the words from the CAA and opposing words from the PFA etc.
At present I think they see a lot of jargon they don't understand and their response is to ask the experts (the CAA!). The CAA point to their consultation exercise and say how fair it all is and then cloak it in the statement "well you want to make UK aviation safer don't you?".
MPs can only challenge this if they have clarity. Either about how the working of Mode S is being misrepresented or evidence that the CAA have not consulted GA properly.

The reply from the CAA (Sir Roy McNulty, Chairman of the CAA) says they have performed a proper consultation of GA bodies.
I wonder why the PFA felt it necessary to write a 38 page letter starting with the comment that they had not been consulted properly.

I intend to write back to my MP regarding the lack of proper consultation. If Russle would like to create a paragraph or two that uses no jargon to explain why Mode S is not a solution to the problem then I would be delighted to include it.

Lets remember what we are trying to achieve.

shortstripper
2nd Dec 2006, 16:41
The second is from Gillian Merron MP, PUS for Transport. She says that -


I recieved the same reply ... with her name signed in what looked like a thick felt tip pen! Looked like a standard response to me and the fact that microlights, balloons and gliders may be exempted is no comfort to me as mine aeroplane isn't one of those. It doesn't address the issue, just skirts around it in a way that would make the MP think that we are worried about nothing.

SS

VP959
2nd Dec 2006, 18:26
She does mention light aircraft, SS, so I think your nice little machine would be included.............

VP

Lucy Lastic
2nd Dec 2006, 18:36
I just don't trust the CAA on this.

They want this to happen, but the technical and economic arguments are against them. Even worse, the logic of expecting non-radio aircraft or aircraft with no electrical systems to carry Mode S - they still haven't had the radiological report yet - is unarguable, and they know it.

However, never doubt it. They will try to get this through and are working on a damage-limitation exercise to overcome the objections without giving up on the key principle

IO540
2nd Dec 2006, 19:22
Zulu Alpha

Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.
I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms.

The answer is that most people don't get the reason why Mode S is being pushed forward into GA - even the stuff flying outside controlled airspace.

It is to ensure that if the aircraft strays into CAS (which happens hundreds of times a year in the UK, whether anybody likes it or not) its transponder will trigger TCAS systems on transport jets, enabling them to take avoiding action.

There is another argument which is that a certain amount of transport traffic flies through bits of Class G, where it could encounter GA traffic that is currently flying non-radio and non-transponder, and legally so. In this respect, one can regard transponder carriage+use as a reasonable quid pro quo for GA not having to lose chunks of Class G.

It's nothing to do with safety for GA. The statistics for GA/GA mid-airs are much too thin to justify any real expenditure in this area, and in any case the State has very little business in dictating individual risk management.

The slight problem with the above is that Mode C would do this job just as well as Mode S. Mode S does have advantages for IFR within CAS (basically, facilitating some slick ATC software functions) but for OCAS I don't see why they don't just settle on Mode C, as the USA has done many years ago. I suppose the reason is that most GA planes are in fact legally capable of IFR.

Anyway, it looks that large chunks will be exempt, just as I thought all along, which is sensible.

Lucy Lastic
2nd Dec 2006, 19:37
There is another argument which is that a certain amount of transport traffic flies through bits of Class G, where it could encounter GA traffic that is currently flying non-radio and non-transponder, and legally so. In this respect, one can regard transponder carriage+use as a reasonable quid pro quo for GA not having to lose chunks of Class G.

THat is actually at the core of the proposal. Unfortunately, in the area where I fly, I have been starting to hear commercial traffic nagging the local ATCO to get the other traffic out of their way.

They treat Class G as their airspace and as they start to use it more and more, 'negotiating' short cuts, they still want the protection of controlled airspace.

My point - if they need this service, they should be the ones paying for it. But, of course, they won't.

DaveW
2nd Dec 2006, 19:39
I suppose the reason is that most GA planes are in fact legally capable of IFR.

If that's the only reason (I don't know!) then there's a simple solution, though - legally require Mode S for IFR flight in CAS. (c.f. change to require FM Immune kit for Instrument approaches in CAS back in the late 90s.)

VORTIME
2nd Dec 2006, 20:02
I agree with the CAA. Mode S should be required and ADS-B should be widespread. The fault is with society in general, aviation tends to be developed by "pilots", not business people - hence the eejits that setup 90% of new airlines and lose a fortune. The problem is nobody has had the ability or desire to develop and cerify cheap avionics. I.e. Mode S for £200.

If someone could do for avionics what MOL did for Ryanair - it won't be such an issue.

Computers, airline travel, cars (relatively speaking), phones, etc all came down in price. Avionics are "special", they only go up!

VT

IO540
2nd Dec 2006, 20:05
Dave

I suppose the answer to that one must be the occassional transport traffic in Class G.

You can fly IFR OCAS, nonradio and non-xp. And we all know that "IFR" v. "VFR" in Class G is no more than in the pilot's mind.

So, do you want to carry an transponder, or do you want lots of bits of Class D around all the new "London XXXXXX International" airports? This isn't a loaded question. Different people would see it different ways. The typical cost of putting a GTX330 into a GA spamcan is about £3000 inc VAT, and less if you had something in the hole previously. This price will fall if the market is created through legislation, through new products. Is this cost worth the G airspace preservation, or the occassional extra access into D? For some it might be, for others probably not, but let's say you have a syndicate around a PA28; you can forget any members who have gone the extra mile to get an IMCR for example.

Lucy Lastic

ATC has to right to order you about in G, under an FIS (it can under an RIS). You can simply turn off your radio to start with or, more sensibly, run a listening watch on London Info.

Lucy Lastic
2nd Dec 2006, 20:17
Lucy Lastic

ATC has to right to order you about in G, under an FIS (it can under an RIS). You can simply turn off your radio to start with or, more sensibly, run a listening watch on London Info.

I take it you mean that ATC has NO right to order you about..

Agreed. What I was saying was that I was listening to the pilot of the ChavAir bullying the ATCO, which I felt was inappropriate. If they choose to route through Class G then they can't expect the same service as in CAS.

But in any case I would almost never listen out on London Information. That is next to useless for most of my flying. It is next to impossible to find space to get to speak to them and most of those being worked by them seem to be in a completely different part of the world.

Oh, and they aren't much help with Mode S are they, as they are not radar equipped.

VP959
2nd Dec 2006, 20:19
It's worth remembering that there are more recreational pilots flying paragliders, hang gliders (powered or otherwise), paramotors, microlights, PFA types, balloons and gliders than there are flying in club type light aircraft, by a fair margin.

This transponder stuff may be trivial to the small minority of private flyers who fly the expensive kit, but for the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand it's a really big deal.

Remember that the majority of recreational flyers rarely even use radio at the moment..............

VP

IO540
2nd Dec 2006, 22:34
But in any case I would almost never listen out on London Information. That is next to useless for most of my flying

Agreed; I said "listening watch" because it's a good idea to always be on a known working frequency in case of a mayday call. There is little point, in general, in talking to anybody unless they can offer a radar service.

And yes I meant "NO". That ATP had no right to demand anything whatsoever in G. But.... if enough of this goes on then we will get more Class D, because the airlines rule the world, so to speak.

The European angle is another thing... airspace access issues are everywhere.

the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand

Aren't they going to be exempted?

David Roberts
2nd Dec 2006, 22:44
Just catching up on this thread, having been at EASA and Eurocontrol meetings in capacity of UK 'expert' (!) from the S&RA / GA community on working groups etc last few days.

Two points:
1. Mode S requirement does not emanate from EASA (an element of the text of a letter to a MP). It is an ICAO requirement going back some years and as such was specified for aeroplanes (not aircraft). For those who do not know the difference, look it up !
2. CAA core reason for the proposal for all aircraft in all UK airspace to carry Mode S is because of CAT now using (currently) Class G to fly into / out of regional airports, and future growth trends. It's the LoCos. The alternative might be a large expansion of Class D (min) airspace. That is a very real issue.

Simple really. Pity the CAA solution is too.

DGR
Europe Air Sports / RAeC etc etc

pulse1
3rd Dec 2006, 14:50
Now that I have had more time to study the letters from Sir Roy McNulty and Gillian Merrin I have written again to my MP.

Merrin said: "The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft". She ignores the fact that they already have.

She also said: " Until a LPST is available commercially, all classes of light aircraft will operate under a blanket exemption." Why do we need an exemption if there is no proposal to fit them?

McNulty's letter treats the whole of UK airspace as the same. I have explained to my MP the simple difference beween controlled and uncontrolled airspace and what limited value a transponder is in the latter.

Preparing the letter I came to look at CAP722 which is the CAA guidance on UAV's. One of the key requirements for the operation of a UAV operating in anything other than defined exclusion zones is the ability to "sense and avoid". (Didn't it use to be see and avoid?).

I have therefore explained to my MP that the only beneficiaries of a global Mode S system would be the Low Cost airlines and the UAV industry which, it seems to me, will soon be a huge growth industry.

xrayalpha
4th Dec 2006, 12:40
Why do we have to have Mode S?

Am I paranoid to think that it is linked to two recent news stories?

One is that a quarter of all the CCTV cameras in the world are in the UK.

The other is that Unmanned Aerial Vehicles are being proposed for traffic patrols, pylon inspections etc.

So, imagine the news if a spotty teenager wipes out a mum and dad off for a flight in a microlight or Cessna while he sits in his air-conditioned office "flying" the UAV!

Now if the UAV can detect Mode S transmissions.......

tonyhalsall
4th Dec 2006, 13:02
Why do we have to have Mode S?
.............................
Now if the UAV can detect Mode S transmissions.......

That is the whole point - UAV and CAT in Open FIR

A and C
4th Dec 2006, 18:05
It would seem that the CAA has dug it's self into a hole with mandating Mode S without understanding the results of it's actions on the light aviation industry . Of course the real reason for the mode S mandate is so that if an airliner hits a light aircraft in class G airspace the CAA can say that they have "done something" to avoid this happening.

Now the problem is saving face and it is trying to build a techonbabbel smoke screen to fool the MP's that the mode S mandate is a safety issue, if the CAA was interested in safety enhancment they would have put in TIS and WX radar data link with the mode S but that costs money and they would not want to spend any of that would they?

Ten years ago the CAA was refusing point blank to have anything to do with GPS approaches wile the rest of the world was introducing them, only now do we have the "face saving" GPS trial because the CAA can't keep its head in the sand any longer on the GPS approach issue.

It's high time the CAA got out of Aviation house once in a wile and had a look at the real world.

Pitts2112
7th Dec 2006, 10:52
Hello, folks!
Well, as the weather's been so rubbish lately, there's been plenty of time to keep an eye on associated matters of aviation. I received the reply from Gillian Merron that others have recieved, via my MP.
Here is my response to my MP Jeremy Hunt regarding her letter, which rather misses the point, I thought:
"Jeremy,
Thank you very much for your reply.
I'm afraid, however, that Ms. Merron's letter glosses over the real point, which is that the CAA, as a regulatory body authorised by HM Government, has behaved in a very undemocratic and despotic way toward the aviation community on this matter. Ms. Merron's letter mentions that the CAA has been consulting on Mode S with the General Aviation Consultation Committee, but what she fails to mention is that that consultation has completely disregarded the input of the members of that committee.
This concerns me for several reasons:
1. The CAA's own paper demonstrates that this approach does not actually solve the problem of safe airspace use in the future, a matter on which no one in the Government seems able or willing to question the CAA.
2. The CAA seem able to operate with impunity and based only on their own incestuous opinions of safety and the good of aviation, but seem to be held to real account by no one in Government.
3. The CAA appear to our community to be interested only in protecting their position in light of EASA encroachment and not genuinely looking after our best interests. We, the governed, so to speak, do not feel our voices are being heard. The CAA arrogantly rejected the input of the community they regulate on this matter and their consultation has been a sham with no real intent of changing their opinions or actions. They are not accountable to their "constituents".
The real issue which needs to be addressed here is the CAA's approach and intent regarding how they exercise their authority, and how that authority is kept in check by the Government. That was the reason for the last paragraph in my letter, suggesting an open working group overseen by a third party to ensure a genuine consultation takes place, as no one in either the CAA or the Government seem interested in making sure that is the case.
The light aviation business sector is under threat from economic, social, and regulatory pressures. Only by working with the CAA can we ensure the country does not lose this £1.4 billion/annum industry by overburdening it with uneccesary regulation and cost. To lose it would not only risk the livelihoods of those earning the £1.4 billion, but would also reduce the pool of available pilots and support infrastructure upon which the nation's commercial air transport industry depends.
I would be interested to discuss with you further your thoughts on how the Government might better maintain oversight of a quango which has lost sight of it's real purpose. "
We'll see where this gets us, but I really think we've won nothing in the short or long term. Ms. Merron's letter gives me the impression that the CAA have not changed their position, they're just going to bide their time, and that no one that we've written to has really taken any notice and talked to anyone. That, to me, implies we're largely being ignored and pandered to with these letters.
Pitts2112