EASA GPS approach survey

[peterh337]

This (https://www.surveymonkey.com/s/sbas_survey_ga) seems worth doing.

[bookworm]

It certainly is Peter, but it has nothing to do with EASA. The survey is commissioned by the European GNSS Agency (GSA).

[cessnapete]

Not worth it while UK CAA insist on full ATC and 'instrument approach' runway lighting for a UK GPS approch to be approved.
Can't we send the tossers to the USA to see how it should be done!!

[peterh337]

I have indeed sent an email to the email address shown at the end, explaining that this is almost totally pointless because nothing can change so long as UK requires ATC (which most GA airfields cannot afford to employ) or has privatised ATC (which for the same reason prevents the use of the US-style remotely located approach controller (which in the USA is funded by the FAA, i.e. the US taxpayer, as a part of an integrated transport network :) ).

The US system can never happen in the UK because nobody will fund the approach controllers, so while I agree with the principle, sending them to the USA to show how it is done will not achieve anything :)

To bring GPS (or any other) approaches to the bulk of UK's present non-IAP airfields will require a massive sea change in attitudes and despite encouraging noises made by various people attending various meetings with the CAA etc etc (over more years than I can remember) I just cannot see this happening.

One obvious way forward would be to allow an A/G or a FISO to do the approach control, and reportedly some encouraging noises have been heard there, but this will raise hell with ATC pay scales, not to mention ICAO ATCO classifications. Even the move done a few years ago which gave London Information FISOs physical visibility of radar screens (something they are not permitted to mention or in any way indicate on the radio, because they are not radar qualified ATCOs) took years to push through, and it finally happened only because there were (and are) so many serious CAS busts. Providing IAPs (or for that matter any other facilities) to GA is of no interest to the establishment.

[cessnapete]

Totally agree, and after meeting the 'informationless' EASA gentlemen on their Stand at Friedrichsafen, there is no hope there either!!

[mm_flynn]

I have indeed sent an email to the email address shown at the end, explaining that this is almost totally pointless because nothing can change so long as UK requires ATC (which most GA airfields cannot afford to employ) or has privatised ATC (which for the same reason prevents the use of the US-style remotely located approach controller (which in the USA is funded by the FAA, i.e. the US taxpayer, as a part of an integrated transport network :) ).

I am less convinced of this particular aspect of the argument than I was previously. The workload in getting a GPS approach approved into an existing ATC environment seems to be enormous (in terms of time, money, and uncertainty of approval). This must be a major blocker in even getting started. At quite a lot of airports I would have thought a deal can be done with a nearby ATC unit to provide the approach control service (after all it should be able to be a procedural approach in most cases). Any revenue is money for old rope as the controller was already there and the volume is going to be low (otherwise a local ATC would be feasible/probable).

It is the enormously opaque process which one appears to have to go through to design and approve the approach - which in my mind should, for most cases, be a very objective piece of physical analysis with some standard risk assessments regarding specific local risks and interactions with other airspace uses.

[OpenCirrus619]

I'm probably too cynical - but this looks like someone trying to find justifications for the huge waste of money called "Galileo" :eek:

[Tinstaafl]

Don't send the twits to the USA. Send them to Oz, where instrument approaches OCTA are common as mud.

[Genghis the Engineer]

I'm not sure about the Galileo bit.

I certainly agree that unmanned GNSS approaches would massively enhance the ability to get from A to B in Britain (particularly if we continue to hang onto the IMC!). That is as has already been said however, a big political nut to crack.

But, what the heck, let's encourage it, I can see no harm in that.

G

[soaringhigh650]

That is as has already been said however, a big political nut to crack.

In the US, ATC is required to do an instrument approach, but it is done via the Approach controllers at the nearby parent airport.

There is no requirement for there to be a Tower controller. You just change to unicom, etc.

The "uncontrolled" field is mostly Class E as well, so all traffic in IMC is known. There shouldn't be anything from around 500-2000ft where radar coverage may be patchy.

Lots of "political nuts" to crack, it appears. The question is whether it is just rumor due to pilots sitting around on their asses doing nothing, or whether pilots have actually gone to someone and talked about it, and then been rebuked.

I would say that the average resident will not appreciate a mid-air collision and debris spraying all over his house on a cloudy day caused by ATC underfunding...........

[peterh337]

There is no requirement for a tower ATCO here in the UK either.

Walney Island EGNL (http://www.zen74158.zen.co.uk/aviation/egnl-ils35.gif) has a remote approach controller and only AFIS (Walney Info 123.20 - the Jepp plate lists no other comms frequency) in the tower.

At quite a lot of airports I would have thought a deal can be done with a nearby ATC unit to provide the approach control service (after all it should be able to be a procedural approach in most cases). This could be done anywhere. NATS (or whichever agency is applicable) would be delighted to provide an approach controller, for the £££.

The problem is the cost.

These things are always confidential so any open discussion is vulnerable to somebody saying "how the hell do you know" but the annual cost of an H24 ATC desk must be well into 6 figures by the time the establishment fixed costs are factored in. Even taking a normal commercial employment scenario you cannot employ a person with anything vaguely resembling a "qualification" (say an on the road salesman or a field service engineer) for much under £100k in total fixed costs. You only have to pop your nose into Swanwick to see that no expense has been spared. Even the potted plants are pretty nice and of course somebody will be employed to look after those, too :) The place resembles a bank head office, pre-Lehman. And then you have the massive security, fences, guards, the whole works. And since ATC services would be the only billable product of all that huge amount of stuff, I bet that an H24 ATC desk must cost at least £500k.

A bit less at say Farnborough but not that much less.

The next Q is how much of that £300k (say) will be billed to an airfield doing some private IFR, some AOC stuff, and perhaps a fair bit of instrument training. I have no idea but let's say it is 1/4, which would correspond to an airfield with some busy periods due to training going on (look at Cranfield where ATC tell you to sod off on more days than not if you just turn up and ask for an ILS). That's £75k, and say £40k if you want just 8am-7pm.

Without training activity it could be much less but the airfield will probably try to encourage training to get value for the block payment. I don't suppose the ATC unit will do it on a per-IAP basis because that is a very open-ended arrangement which traditional accountants don't like. It might also make approaches very expensive; e.g. Cranfield charges £30 for an ILS and at that rate many people will not use it.

Any revenue is money for old rope as the controller was already there and the volume is going to be low (otherwise a local ATC would be feasible/probable).Sure, any ATC activity comes free all the time the system is below capacity (in the same way as the cost to BT of carrying a phone call is only the ink used to print the line on the itemised phone bill) but the accountants you will find in these establishments are not the sort who want to get into marginal costing :) The supporting evidence for that is in the 4 or 5 figure annual fee that NATS charge for a radar data feed, which costs them virtually nothing.

One would think that imaginative solutions could be found but the fact that nothing has emerged for such a long time suggests it is a tough nut to crack.

GPS approaches are not the only option, historically. It doesn't cost much to run an NDB and a DME (a few k a year on the maintenance contract) and if an airfield could offer a published NDB/DME IAP it would attract some valuable training and AOC business. Obviously the actual procedure will be flown using a GPS ;) ;) but that's not the point.

The "uncontrolled" field is mostly Class E as well, so all traffic in IMC is known. There shouldn't be anything from around 500-2000ft where radar coverage may be patchy.That is the other bit of the US system which quite cleverly makes it all fit together. Any traffic which is in IMC but not under an IFR clearance is automatically illegal, and the FAA has busted some people for it. Even in Class G (where a "clearance" is impossible) there have been some busts, for flying IFR without an IFR flight plan or something like that.

[achimha]

There is no requirement for a tower ATCO here in the UK either.

So where's the issue then? Obviously the airfield needs AFIS and some coordination with ATC (= a telephone + computer). In Germany, small airfield instrument procedures are a very rare thing but it is possible. The way they do it today is via an airspace F, that is essentially uncontrolled airspace like G but with higher minima and with IFR allowed (Germany does not allow IFR in G, if that was to be changed, F would not be necessary at all). ATC vector you onto final and once you descend below their minimum radar vector altitude (or get close to airspace F), they will tell you "radar service terminated, contact XYZ Info on 123.45". AFIS will in turn inform the others: "to all stations, airspace foxtrot active, IFR traffic on 5NM final runway 25". That will tell everybody that circling below a cloud east of the runway is not a good thing to do for the moment.

I have also encountered airfields without instrument procedures here that are hooked up to the ATC network and can issue IFR clearances for Z flight plans. They usually have it when they're close to a big airport.

Examples of this are EDTY Schwäbisch Hall (ILS+RNAV) and EDMS Straubing (RNAV). Both are uncontrolled airfields with AFIS.

[soaringhigh650]

The place resembles a bank head office, pre-Lehman


Peter, you do a fine job of making UK ATC look like top-executive fat cats who care about nothing but money, or else they will go on strike......

Every other country that has some notable GA activity will have sorted out the issue one way or another.

[peterh337]

So where's the issue then? Obviously the airfield needs AFIS and some coordination with ATC

It works because your ATC is taxpayer funded :)

Every other country that has some notable GA activity will have sorted out the issue one way or another. Yes, but none of them has privatised ATC like the UK has.

It's true that when the CAA drew up the obligations for ATC to deliver, prior to privatisation, they could have put in stuff like approach controller provision for GA.

But they didn't.

Perhaps somebody thought of it but the merchant bankers advising would have resisted such an obligation as it would reduce the proceeds from the IPO. So the only obligations were what ICAO demands i.e. a FIS and some other bits.

[soaringhigh650]

NavCanada is privatized and the UK is only part-private.

It's true that when the CAA drew up the obligations for ATC to deliver, prior to privatisation, they could have put in stuff like approach controller provision for GA. But they didn't.

Because GA pilot groups sat around and said nothing, so nothing was done....?

Show me some evidence where something was put forward in a previous consulation which was ignored by your CAA, or the Department for Transport.

The last consultation for fully privatizing ATC wasn't even responded to by AOPA or PPL/IR (http://assets.dft.gov.uk/consultations/dft-2011-15/summary-of-responses.pdf), which suggests most pilots just don't care.

[peterh337]

I recall this discussion coming up before, and some ATCOs said UK GA has only itself to blame.

A fair comment might be that nobody (who had the time + inclination to get involved) foresaw this consequence.

Look at the EASA FCL stuff. You are facing massive documents which only the most obscessive person will have time to read, let alone understand.

UK AOPA and PPL/IR are massively under-resourced, and AOPA would have been concerned mostly with VFR issues anyway.

[soaringhigh650]

And given that you've contributed over 15,000 posts to various forums in the past few years and none to such an important consultation, would you say you're guilty too?

[peterh337]

You have picked the wrong bone there...

I am not even sure if I was flying (IFR) when this was done. I certainly don't recall any consultation. I am also not involved in any UK pilot group.

[Sir George Cayley]

Looking at a recent CAA info note, VFR at night has been introduced ahead of the start of SERA (standardised european rules of the air).

Will SERA affect European States wrt GPS approaches? The design of approaches is contained in an ICAO PANS (Doc 8168) so where ever you are in Europe, you can expect the same level of safety whilst flying the procedure.

So the challenge is the environment around the runway. Can separation in IMC be assured? Can a pilot on approach receive a clearance to land from someone who is not a validated ATCO?

Even if it's a difficult ask doesn't mean a solution shouldn't be looked for. The UKs situation does impose an extra challenge due to privatisation though the introduction of a lowered floor for BRNAV because of radar coverage down to circuit height shows that a service could be provided.

So an equitable way to fund such a service has to be found. If the current provision of radar coverage is fully funded the on cost will be marginal. Surely this is a starter for 10?

SGC

[Tinstaafl]

Why would you need a clearance to land at a non-controlled field?

[AdamFrisch]

Excuse my ignorance, but this is what I don't understand either.

Someone publishes a GPS approach (or you make your own) to an uncontrolled field. You pop out at the minimums set: if you see the airfield, you land. If not, you go elsewhere. It's in G airspace where you don't talk to anyone anyway.

Why is this illegal?

[peterh337]

You don't need a clearance to land, if there is no ATC in the tower. What you do need, apparently (though I have no reference) is a clearance to fly the approach.

For a G-reg, it is not illegal to fly a DIY (unpublished) IAP. And yes this is another reason why GPS approaches are moot in many cases, especially if they don't deliver lower minima than the existing NDB IAP (Shoreham is one example).

For an N-reg, unpublished IAPs are banned by FAR 91.175 and this appears to apply worldwide.

[Tinstaafl]

Most aerodromes in Australia with approaches are OCTA. No clearances required to do the approaches. You just get on with it. Often only a traffic information service is provided. Not even radar derived, just position reporting.

[peterh337]

In that case it doesn't sound like there is something in ICAO rules mandating ATC for all approaches, unless Australia has filed a difference.

[soaringhigh650]

You have picked the wrong bone there...
I am not even sure if I was flying (IFR) when this was done. I certainly don't recall any consultation. I am also not involved in any UK pilot group.


This consultation came out in June 2011 and closed the following month (http://www.dft.gov.uk/consultations?mode=aviation), when you were definitely flying IFR (http://www.peter2000.co.uk/aviation/locarno/index.html).

I may have picked the wrong bone, but I see you are a keen writer, perhaps writing some 200 posts per month of which many find interesting to read.

In my opinion it would have been far better for you to have also been responding to such consultations, either as an individual or through your pilot representative organization.

Your occasional post which targets the unions and "money squandering" at privatized ATC is something that nobody in your country actually cares about, as shown by the (lack of) responses in this consultation.

In a nutshell, GA is responsible for its own death, really.

[bookworm]

The last consultation for fully privatizing ATC wasn't even responded to by AOPA or PPL/IR, which suggests most pilots just don't care.

I think you're confusing how NATS is owned with how ATC in the UK is funded. The consultation was about the former, not the latter. NATS recovered its costs and more from users long before it was privatised. The effect of privatisation from the users' point of view was probably an efficiency improvement, and thus lower costs.

[peterh337]

That's right - the privatisation took place way before 2011.

Also my comments on costs would be exactly the same for any business which charges out its fixed costs divided by the amount of product/service delivered, which arguably it has to in some way. Marginal costing works only until you reach capacity :) The airlines apply a lot of noisy pressure to remove what they see as subsidies for GA or whoever.

That said, aviation is a nice gravy train for large numbers of people, and that is yet another thing which holds back progress.

The key factor is that most countries treat aviation as a part of their transport infrastructure. In the UK, this has been separated out, for far longer than I've been flying. That directly leads to the issues which hold back the development of GA.

[Fuji Abound]

Because GA pilot groups sat around and said nothing, so nothing was done....?

And surely you were not surprised?

On issues such as this it is as much the governments resposibility to decide whether to protect minority interests because usually they are the least able to protect themselves. Rarely can ga have a hope in hell of taking on the enormously well funded machinery of other lobbyists.

Either we want a centrally funded regional infrastructure of airports which incidentally are unlikely to ever be able to fund themselves with the current framework or we dont.

[ShyTorque]

We seem to be suffering from successive UK governments' (plural) attitude to the essential infrastructure of the country. Privatise, allow the private providers to make a good proft for shareholders. But do nothing to protect the actual facility itself.

Water, Electricity, Gas, Road fuels. Police (it's being mooted), NHS? Post office (watch this space; that's all about to go for a ball of chalk). It's all going down the pan (apart from the water, most of that gets lost from leaky mains).

Good grief, even Clinton Cards has gone into administration in the last couple of days; whatever next? :rolleyes: