Herewith below the CAA response but no answers.
Why won't it be possible for the CAA to answer the very simple questions they have been asked?
They repeatedly give their "opinion" in the Consultation document and all they are being asked for is the basis upon which, and evidence on which they have based their statements in various documents and their stated opinion.
How can a consultee respond to the consultation in a valid way if the CAA have not provided relevant evidence in the consultation document and decline to answer simple questions.
Why can't they name the Companies that they claim are devoloping Low power Transponders that they claim are a "significant part" of their proposals?
Why can't they clearly state whether they have evidence of any relevant trials of low power transpnders?
Why is the CAA proposing Transponder legislation to address "Airspace Infringements" when they have not yet had any formal recommendations from the ASI that was set up to review & make recommendations to addess Airspace Infringements?
Why can't they explain the relevance of the Red Arrows references in the consultaion document.
Why can't they provide the MOR figures they are using and account for the trends in them?
Why can't they give the vertical, horizontal and risk parameters used by NATS to log an airspace infringement?
Why can't they provide the document from the Airprox Board that they refer to?
Why can't they just answer all the very simple questions that they have been asked (and presumably have seriously considered in detail before producing proposals for legislation?)- to clarify the basis of their opinions and recommendations.
Will they answer the questions in detail in their proposed response document or will it be necessary for a Judicial Review?
Is this more evasion and obfuscation by the CAA?
Spin Buster
----Original Message----
From:
[email protected] Date: 19/05/2008 15:44
To: <
[email protected]>
Subj: RE: Mode S Consultation Queries
It will not be possible to provide a detailed response to all the
issues
raised in your e-mail before the end of the consultation period.
Consequently, we intend to treat your correspondence as a formal
response to the Mode S consultation. Having reviewed all the
responses
to the proposals, we propose to publish a 'Response To Consultees'
document on the CAA web pages. This will provide a synopsis of the
various issues raised alongside a CAA response, which will detail any
resulting future investigation deemed necessary by the Authority.
Should you decide to make a further response to the public
consultation,
you may wish to take note of the following general comments:
1. The 2007 figures quoted on the flyontrack website are not for a
full year.
2. A sample of 200 MORs involving airspace infringement revealed
that approximately 15% of infringing aircraft were not carrying and
operating a transponder.
3. No specific ASI recommendations have been received by the CAA
Mode S team.
4. There are a number of transponders on the market which produce a
peak pulse power of 70W and appear to be suitable for use in many
types
of glider.
5. Studies indicate that the key safety benefits of Mode S over
Mode A/C are reduced radio spectrum interference and improved
detection
of aircraft.
Regards
Mode S Team
Surveillance and Spectrum Management
Directorate of Airspace Policy
UK Civil Aviation Authority