Unbelievable!!!!

[robin]

Applying spectrum pricing to the Aeronautical sector - a second consultation | Ofcom (http://www.ofcom.org.uk/consult/condocs/spectrum_pricing/aip/)

This is Christmas and not April 1st, but Ofcom don't seem to think so

[Whopity]

Remember the last time they produced a similar pile of Crap they were put back in their box. Read it, comment seriously on it; that's not difficult as its written by an ignoramus and a delight to tear apart, then get it in by the deadline.

[robin]

Yep, that's true

But they have the gall to ignore everything that was said the last time. With politicos looking for additional income we have to make sure we all respond on this.

But what a time to send out the consultation......:rolleyes:

[The Heff]

So far I've only read the summary, but initially I can see a question which I don't think is likely to be answered in the main text: "What administrative system is the AIP replacing?"

It would be surprising if no-one paid any form of annual fee for control of a frequency, but how much is being paid now compared to the prices outlined in Year 5 following the AIP?

[robin]

At least they seem committed not to charge per aircraft, that's a good thing.

.. and where do you think the money will come from to pay the charge? A hike of a pound a landing, perhaps, so hardly free to us.

[AdamFrisch]

This is just what Britain needs - more expensive flying. Hell, why not more expensive...everything? Rip-off Britain is alive and well.

[The Heff]

Just a random thought, but what about introducing a civilianised version of TOCNET for A/G stations? I don't pretend to understand the detailed complexities of the subject, but generally it works like a radio (PTT switches, only one can talk at one time, etc) but it uses VOIP and wireless technology.

I've seen TOCNET work in military applications, so I presume it can be adapted to General Aviation as well.

[robin]

Again, true

But this would be a cost that gains us nothing. A pound raised that goes to make an airfield more profitable is fine.

A pound raised to go to the dead hand of central government is another thing. Odds are it will go to pay bonuses to the heads of Ofcom

[ak7274]

How many small Airfields will chuck the Ground Station in the bin and go non-radio?
That, to me is the important safety issue. Less radio use at local Airfields in class G airspace can't help either.

[Pilot DAR]

This outside my area of expertise, and I'm on the side of the Atlantic which is not affected, but...

I am aware that Canadian aviation regulation or fee change proposals, include an element of the effect on aviation safety, which could result form the change being implemented. Looks to me that making the use of radio for air traffic awareness and separation less viable, creates a definate safety shortcoming, compared to the present situation. Wave that flag at the money grubbers...

What is the cost of an accident (mid air) comapred to not taking that money in fees, which created a disincentive to use the radio?

Just a thought...

Pilot DAR

[BackPacker]

Couple of thoughts:

- Apart from emergency frequencies, which are free, the height of the fees only seem to be based on the Designated Operational Coverage. That's why a Tower frequency has the same fee as an AFIS or A/G frequency despite the vast difference in type and amount of traffic handled by these services. And anything that's got a DOC that's bigger than that, including things like ATIS and Volmet, get a ridiculously high charge. Doesn't seem fair, does it? This argument obviously works both ways: if you draw things to a logical conclusion then any small A/G station should be able to make a bid for the Heathrow Tower frequency.
- Ofcom seems to think that aviation makes money from these aero frequencies, just like cellphone providers make money from their frequencies. Based on this thinking, they try to apply basic economic principles of scarcity, supply and demand to the spectrum. But this premise is flawed: we don't make money from chatting to each other, we make money by moving stuff and people from one place to another. There are several points in the consultation that can easily be torn apart because of this alone.
- There is no mention whatsoever of "operator frequencies", while these are perhaps the only frequencies with a DOC that's big enough to matter, and where the economic principles of scarcity, supply and demand would work. Not to mention that within the context of a single operator, it would definitely be possible to give up the operator VHF frequency and replace it with a completely different technology (like UHF, cellphone, satphone, ACARS, ADS-B or whatever).

[Torque Tonight]

This proposal runs totally counter to flight safety. This will encourage, or force, many operators to dump ATIS frequencies or split Twr/App setups in order to ensure financial survival in a sector which is economically precarious at the best of times. Aviation safety is an area which really should be completely isolated from 'market forces'.

[robin]

I'm sure our chums at the Belgrano will be making that very point

[chrisN]

Does anybody know if they have to do environmental and/or safety impact assessments before imposing charges such as these?

Chris N.

[peter272]

I would guess this would be a point to be raised by the CAA and our representative bodies.

The history of Ofcom's consultations shows they pay lip service to the idea of safety.

The maritime one looks at exempting (or giving a discounted rate) to charitable and life-saving organisations, such as the RNLI.
What they don't see is the need for even small airfields to have a frequency (often shared between a number of airfields anyway) so that we can get the information we need about traffic and weather.

That part of the case I would guess will be very lightweight against the very real financial benefits of selling off the spectrum.

[hatzflyer]

Please see the note on the LAA website before responding to this.They are making a co ordinated response and ask that people do not respond untill the new year.

[PH-UKU]

Personally I think that charging for ATIS and VOLMET is criminal and is a definite risk to safety. Another tax raising/money grabbing attempt thinly disguised as 'market demands and competition'. Pathetic bean-counting ... albeit very big beans .... and we know what big beans generate .....

How many times have you tuned ahead to get ATIS and VOLMET info on a cross-country ? If that has to be charged for .. who pays ? Or will we just call-up FIR sectors and overload them with hundreds of requests for weather info. Or just get out the mobile orbit a phone mast and download the latest METARs ?

Pretty much every user group in the UK, drivers, farmers, sailors, holidaymakers gets relatively accurate realtime weather for free.

Aviation is a damn sight more critical and 'realtime' especially when you are in the air. But it is difficult to access by conventional means when in the air (TV, radio, internet, phone).

So the most safety critical user is the one that ends up paying. That seems rather ironic.

:mad:

[tmmorris]

You could make a 'market' analysis of the cost, but you'd have to factor the likelihood of a mid-air with a notional cash value per life lost. That sort of calculation is performed, of course, but it's distasteful to most of us.

Who will pay for the Safetycom frequency? :ugh:

Tim

[BEagle]

In a speech in London to the Reform think-tank, Mr Cameron promised: "With a Conservative Government, Ofcom as we know it will cease to exist.

"Its remit will be restricted to its narrow technical and enforcement roles. It will no longer play a role in making policy."

I will, of course, be making my local MP (David Cameron) aware of this latest attempt to tax safety being made by the avaricious nuLabor 'government'.

Notwitshtanding the LAA's request, a large number of individual responses will always carry more weight than a 'co-ordinated response'.

Incidentally, the Ofcon artists are hosting the following meeting in January 2010:

Forthcoming Events
Ofcom will be holding the following events in England in the near future.

Draft Annual Plan 2010/11

Ofcoms England draft Annual Plan 2010/11 event is being held on 18th January 2010 at 3pm until 4pm at Ofcom, Riverside House, 2a Southwark Bridge Road, London, SE1 9HA.

To register your attendance please email [email protected]

I don't know whether this includes any information on their plans for aeronautical VHF spectrum pricing.......

[AliB]

In the details of the report (Appendix 7, Annex 8, Figure 4.5) their own figures suggest that at small, "low movement" airfields (they use Dunsfold as an example) the fee will equate to almost £5 per movement.

Can small airfields afford to swallow such a cost? Can they afford to put up their landing fees by a fiver or go non-radio (both putting pilots off visiting and hurting them again)?

They don't seem to think so: "This does not in itself imply that the landing charges under AIP would be unaffordable, just that there would be a discernable impact."

Ali

[xrayalpha]

Airpolice wrote:

"As for the a/g going up to £50 a week, that will hit places like Strathaven ...."

Actually, Strathaven is on Safety.com - we have no ground station and no-one authorised to operate an air/ground service.

However, other aircraft on the airfield and in the vicinity may make appropriate transmissions. This might confuse you into thinking we have an air/ground.

I can tell you now, we will not be operating air/ground or paying for an operational frequency.

I suggest we take a leaf out of Scottish TV's book when licence fees were being put up for bids about 10 or 15 years ago.

So people, like Granada, paid tens of millions.

STV felt they were the only bidders for the Scottish licnce, so bid £1 - yes, 100p.

So if we all bid the lowest amount, or just abandon air/ground etc, then the market price will be very very very low.

Then re-apply for an air-ground frequency and then offer the going rate.

Let's show them just what the commercial demand is!

[peter272]

In the details of the report (Appendix 7, Annex 8, Figure 4.5) their own figures suggest that at small, "low movement" airfields (they use Dunsfold as an example) the fee will equate to almost £5 per movement.

Can small airfields afford to swallow such a cost? Can they afford to put up their landing fees by a fiver or go non-radio (both putting pilots off visiting and hurting them again)?

They don't seem to think so: "This does not in itself imply that the landing charges under AIP would be unaffordable, just that there would be a discernable impact."

This from the Helios review, so no worries here either.

...Furthermore, the owners of Dunsfold have been attempting to replace the aerodrome with business and private property. Whilst the local council refused the initial application the owners have appealed. The long term future of the airfield must therefore be in doubt.

[Jim59]

Please see the note on the LAA website before responding to this.They are making a co ordinated response and ask that people do not respond untill the new year.


I just looked and the only reference seems to be to the FIRST Ofcom consultation - not the second that came out yesterday. Perhaps it's in the member's area - I'm not a member.

Anyway why should I trust organisations to respond on my behalf - look at what Jim thorpe is doing to the IMCR - he is trying to kill it - yet claims to speak for UK PPLs.

[Min Sink]

Jim,

See Light Aircraft Association :: View topic - OFCOM Charging for Aeronautical VHF frequencies (http://www.lightaircraftassociation.co.uk/bbs/viewtopic.php?t=1793)

[A and C]

This is the thin end of the wedge, the first time ofcom attempted this they took on the whole industry and all aeronautical radio bands.

The first set of proposals would have cost the airlines a lot just for the Rad Alt (£30K per aircraft per year I think) and if that wasnot a tax on safety I don't know what is as the primary use of a Rad Alt in an airliner is GPWS.

As you might have expected the responce from industry was robust to say the least, so what ofcom is up to now is spliting the industry and picking off the radio bands one at a time.

The airlines need to understand that this is just the thin end of the wedge and the whole aviation sector needs to respond in a very robust way before Ofcom get this one past the industry and then start on the next aviation radio band.

The goverment will only understands the harm that this will do to the UK economy when the airlines move the aircraft to another EEC state and dont have to pay this ofcom tax and a lot of other taxes to the UK Goverment.

The bottom line is that if Ofcom get away with this tax it will make the UK aviation sector less compeditive and drive total UK tax income down.

I have writen a very robust responce to this tax, and I urge you all to do the same, as for the LAA I think that they should talk to the airlines to make sure that they understand what Ofcom are up to, The airlines will be very a powerfull force to help us if they know what is good and will help us nip this in the bud.

[robin]

A & C

I don't think airlines are the issue.

The problem affects the UK-based providers who Ofcom can identify and monitor.

No aircraft operator will lose (directly) but the charges to airfield owners and operators will add to our costs indirectly through raised landing fees.

A particularly nasty and focussed attempt at getting more money from an already over-taxed sector.

This needs to be fought, and hard...

[mjc123]

A few thoughts...
- Cameron's comments on abolishing Ofcom were aimed at Ofcom's work on broadcasting and not "technical" issues like spectrum pricing. Whether or not one agrees with this, do nbot hold your breath for a conservative govt to "save" GA here...
- I would suggest that all who are concerned should reply - both organisations and individuals. But just saying that Ofcom are wrong or that this will hurt safety will have little impact. Ofcom are "evidenced based" and to have any chance of influencing them then need to show why will hurt safety with logic or evidence.
- Writing to MPs and getting them on board can also not hurt - especially those with an aviation bent I would have thought.

In terms of the substance here - these charges are meant to influence the incentives to use spectrum efficiently. Any arguments need to be linked back to Ofcom duties to encourage efficient spectrum usage. How is a charge going to increase efficient specturm usage in aviation bands? It will only push all radio usage to those airports and users best able to pay - but "efficient" usage should mean maximising safe use of the skies which is achieved by ALL aircraft and airfields using radio efficiently -not just those most able to pay. Am still reading this document and will post further with any more thoughts.

[Timothy]

Isn't XrayAlpha closest to the RealPolitik? Ofcom simply cannot resell these frequencies, because they are protected by international treaty.

Thus every a/g operator should simply shrug their shoulders, relinquish their frequency, and have Pooleys et al publish what their frequency used to be.

People would then continue to use the frequency, no money would change hands and Status Quo Ante Bellum would prevail.

[A and C]

The Airlines are not the issue with VHF comms but the next thing down the line will be the taxation of another radio band, so lets just look at what you could tax.

Weather radar.

DME.

Radio Altimiter.

HF.

Most airliners are now carrying one Weather radar, Two Rad Alts, Five DME's and at least one HF.

All of these could attract the new tax.......... this is why we need to impress on the airlines that they should help us fight this rubbish now and not let OFCOM drive in the thin end of the taxation wedge.

[S-Works]

I was part of the industry working group that saw off OfCom at the last attempt at this. This is the first industry working group I have sat one where every sector of aviation was united and gave the OfCom team a thorough roasting.

The lady giving the presentation and her manager were completely incapable of understanding the safety implications of these measures or willing to acknowledge that they could not resell the frequencies as there are protected for aviation use. She had the arrogance to assert that other countries would follow the example!!

These people are only interested in raising money for there masters at the treasury to help out a crippled and corrupt government.

[robin]

From my perspective, as a GA pilot the airlines won't want to have to pay extra for service. The airports will not want to take the hit either, but licenced fields with commercial traffic will have little choice.

Other airfields with a choice will decide to go no-radio or use Safetycom. I flew with a pilot yesterday who could not handle working non-radio and it was scary.

We, as pilots should make sure we make our own responses to this consultation - IN OUR OWN WORDS. Don't rely on our representative bodies who have only around 30% of GA pilots on their books.

Ofcom make it clear that safety is the responsibilty of the CAA. They are only interested in the efficient and cost-effective use of the spectrum. We need to focus on the safety element, in particular the risk to commercial aviation if we lose local GA A/G/ATIS etc.

This is a nasty proposal from Ofcom, but government need to hear from us with reasoned arguments to stop this happening