Does not do much to help the average spam can guys wanting to fly under IFR using an IMCR does it?
bose-x,
I'd have thought that the folk who would want to do that have already invested in appropriate equipment for their aircraft and further investment in a Mode-S transponder is fair play, - in the scheme of things.
I'm involved in a Group with a fairly aged PA28-151 with what was for the time the standard 2 x Comm, 2 x Nav (inc ILS) 1 x ADF 1 x Transponder, OMI receiver. None if this is really fit now for serious Nav in CAS, in my view. We do IMC training on it but of course the practice (and test) ILS are actually conducted as SVFR if we go to an airport in CAS.
The other PA28s I fly are generally Warrior IIIs with more up-to-date fit including Mode-S as standard. In an £90k+ a/c, it's not a lot.
If we ever update the avionics in the -151, no doubt we'll include a Mode-S along the way. No big deal, really, maybe a Garmin 430 which will neatly do everything! (except the ADF, which will sadly be history by then, I'm told).
What IS a big deal, I think, is the possible imposition of Mode-S on day/VFR-only machines; I know of a couple with no electrics whatsoever. It does seem that common sense might actually break out and these will be forever exempt from the requirement.
Cheers,
TheOddOne