Letter to MP on Mode S
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.