Expensive Mode-S Transponders for R22 Helicopters

[Dick Smith]

CASA/Airservices are bringing in a unique mandatory requirement for transponders. I have not seen it anywhere else in the world. It appears that all helicopters flying into Sydney airport via Cape Banks (even tiny R22s) and only going to the helipad via tower airspace and not mixing with fixed-wing taxiing traffic at all still have to be fitted with a Mode-S transponder.

Can anyone advise why this mandatory requirement is there and whether a Regulation Impact Statement was prepared? I haven’t been able to ascertain this from Airservices even though I have written and waited four weeks for an answer.

So much for the Coalitions policy of removing expensive red tape! Ha Ha ! Mr Truss is going to do the opposite.

[TOUCH-AND-GO]

AIP GEN 1.5-10 :confused:

[triadic]

Para ????:ugh:

[Ultralights]

GA is suffering a slow and painful death in Australia.

sorry to inform you, but GA has been dead in Australia now for quite a few years.. all thats left are the diehards, and the last few kicks of a dying nervous system. just look at YSBK, for many year the busiest airport in the southern hemisphere. more flying schools than you could count..
now, just a few schools left, and countless empty derelict hangars. and about 1 IfR arriving an hour on average. even sunny calm weekends at Bankstown now are a quiet affair.

[Dick Smith]

Can we get movement figures for Bankstown?

Seems to me that there has been a substantial reduction in movements in the last 20 years.

[NOtimTAMs]

Dick: Movements at Australian airports | Airservices (http://www.airservicesaustralia.com/publications/reports-and-statistics/movements-at-australian-airports/)

[Dick Smith]

I am not such an expert in compiling figures. Can an expert advise if the movements are up or down at bk ?

[Hasherucf]

I got a quote to kit out for mode S and WAAS to comply with ADS-B, just shy of 20k.

About right , most of that is equipment cost.

[NOtimTAMs]

Seriously, Dick? As former head of aviation and a businessman with a head for figures, you couldn't do what Raptor did? Or did you need a volunteer personal assistant to look it up for you even when you were given the link?

Boy, your credibility just took a big hit in my eyes.

[triadic]

Dick, et El,
One does not have to examine the numbers, but of course they help when fighting the system (Govt) or seeking public support.

What we as an industry should be doing, and I am sure you are capable of putting forward the case, is that we should be examining what the root cause of these problems might be?

Do we have a govt that understands aviation... Not at all

Do we have a govt that supports the aviation industry.... NO

Do we have too many rules? Certainly YES

Why? To keep public servants employed...?

Are they written with the involvement of industry experts? Mostly not I believe. (And casa certainly don't have a monopoly on experts)

Who is involved in writing all these rules that we really don't need? And are they ALL subject to a safety analysis and any sort of costing?

Answer that and we might be close to the root cause?
Hint: another govt dept
If there is no safety benefit and it costs us even a $1 more, then it should be trashed!

This is not only part 61, and transponders/ADSB etc, but airworthiness who seem to be intent on killing what is left of the GA fleet.

Dick, as you have done in the past, you need to surround yourself with a team of industry experts and come up with a fix that cannot be ignored.
:ok:

[gerry111]

I'm not the expert that Dick asks for. But I was rather fascinated that for example, April 2015 the less than 7 Tonnes Movements were thus:


YSBK: 13376
YMMB: 20690
YPPF: 22152


Those South Australians must be doing something right with their flight training.


"Movements are the sum of Arrivals + Circuits multiplied by 2 ie (A+C) X 2"

[NOtimTAMs]

Graphically:

http://s9.postimg.org/gfarn18tb/YSBK_movts.jpg

[Hasherucf]

Raptor090

The labour is a small part. There isn't much mark up on the Avionics shop side. I rather customers source their own equipment so I am not handling the huge cost for little profit .Of course then people take forever to pay .So yeah they supply the avionics I just do the install.

Really Australia should have gone after the US in implementing ADSB. I think costs would have been lower.

[jas24zzk]

I guess its a sign when the LAME's who get paid to do the work, shake their heads at the costs they are supposed to extract from owners, who will gain no benefit. The LAME would rather see you spend the money on replacing that on-condition engine, or the control cables....something that would be a clear and obvious safety outcome.

There is only one way to instigate the needed change, and that is to force it.
There is only one way to force it, and it will never happen.

There are too many vested interests, too many people willing to have a crack at going broke.

The issue is the same in my own industry, where the insurers (simply replacing Govmnt) are screwing the trade to the wall. They breach multiple sections of the Trade Practices act daily, but the rot continues because the industry will not band together to fight it.

The only way, and the ONLY way to fight CASA is a co-ordinated effort from every industry group in Aviation.....that includes ASA.

Shut it down for a week. NOTHING flies, not even privately.
From the guy polishing hubcaps on 737's to CEO's. Nothing moves.

The only way to hurt a politician, is to hurt the public! Until the politicians hurt, they won't bother touching CASA.

You can lobby and write letters all you like, some of us have been doing it for years. You feel great for writing and sending...but you just have that no hope feeling when you hear your letter hit the bottom of the postbox, because you know thats where its going on the pile of your chosen politician.

It will be the Aviation industries choice if it goes the way of the autobody repair industry.

[Dick Smith]

No tim. Fantastic. Any chance of doing the decade before?

[growahead]

Well, I'll put another view across. Using Dick's example, someone wants to fly their two seat slow helicopter into the country's busiest airport. The controllers could be occupied during a busy sequence;the helicopter maybe posing conflict to multiple aircraft with hundreds of passengers. It may not be unreasonable to expect that helicopter to be equipped such that it's return is not garbled with multiple other targets in a confined area (one feature of mode S, as I understand it), it may be an advantage to have enhanced altitude reporting, and it may save transmission time in knowing the helicopter is on the ground, without having to actively request that information. Maybe.

[OZBUSDRIVER]

13k for fitment and legals....methinks you guys better shop around!

[Dick Smith]

By the look of it. A RIS was not written for this new and unique mandatory requirement ?

Is anyone concerned about that?

[Dick Smith]

Grow ahead. Choppers coming in via Cape Banks are visually sighted by the tower and given traffic. Once sighted the pilot is usually allowed to continue in past the container terminal.

So why the need for expensive Mode S ?

[Howabout]

I have to agree with Dick on a lot of this stuff in relation to unnecessary cost. But the whole environment changed many years ago and there's been a knock-on in respect of govt, CASA, Airservices, etc, being oblivious to the impost of doing business in the real world. And now there's a new generation of bureaucrats that accept this as the norm.

The turning point was 'user pays'. After that line was pushed by the zealots, with no consideration of the possible downstream consequences when they hit 'send,' GA's fate was sealed. Now, nobody in the bureaucracy gives a stuff. They just see any charges, no matter how exorbitant, as par for the course.

Sell HOX? Yeah, sure, it's a commercial environment. Mandate ADS-B? Yeah sure, because we can and it won't cost us. Mandate Mode-S? Yeah sure, because we can and it won't cost us. Approve the sell-off of YSBK? Yeah sure, no problem; it's business.

Clamoring for 'user pays,' IMHO, was the biggest blunder ever made. The zealots that pushed it fostered an attitudinal change in the government and its associated agencies that is now irreversible.

I don't think that I need to join the dots.

[Dick Smith]

I do not know anyone in the industry who was " clamoring" for user pays. Certainly not me.

When the Labor government moved to user pays after the Bosch report I wanted the costs to be transparent. - not hidden in a 16 cent fuel tax.

[triadic]

Howabout.... well said:ok::ok::D:D

[growahead]

Hi Dick. Your initial post states "CASA/Airservices are bringing in a unique mandatory requirement for transponders". It would be helpful to identify which organisation is responsible for the requirement to be mode s capable.
Nevertheless, a four week delay in reply is a poor show. I can't tell you why mode S is being mandated, but if I had to guess, I'd say there's a good chance it may be to reduce or eliminate the occurrence of garbling of targets in close proximity. Sydney would have a high density of targets at times, and it would be undesirable to have returns garbled, if they can be prevented by the use of current generation equipment.
It almost seems like you are asking "Why are we being stuffed around by ASA bureaucracy". The mode S issue that you raise could equally ask other questions, such as why is a piece of electronic equipment so expensive, or should private flights with one or two occupants, as suggested by you with the example of R22's expect to mix it at busy international airports. It's a bit like someone wanting to race in a GP in a Healey Sprite.
You may find that ASA are willing to listen to you, and accommodate you somehow, perhaps by permitting a dispensation, or limiting access to off peak times, or some other solution.
It's easy for someone to slag off at organisations such as CASA and ASA, but if a private chopper was involved in an incident/accident, you can bet there would be a swarm of lawyers looking for a patsy. Sadly, in our society, ar*se covering is a high priority these days. I'd suggest you find the appropriate people to ask, and perservere. A consultative approach is more likely to get a result, rather than a belligerent one. I don't know the current deal, but there was always the option for a dispensation to proceed without a serviceable transponder; it meant the particular situation was considered, including the traffic, weather etc.
Incidentally, I always thought it was a great act of faith to permit a pilot, with perhaps less experience than 20 hours, to be completely responsible for separation with another aircraft that may contain a couple of hundred pax. This happens daily, especially at D towers, and I know from long experience that many pilots of low flying experience often acknowledge instructions with no real idea of what's going on.

[Howabout]

First off growahead, how hard is it to separate a 'private chopper' from jets? Been there and done that. They can stop, hold, hover and wait till the confliction is out of the way. There is no easier traffic to control than a rotary. All that's required is readily identifiable 'hold-points' and a clearance limit to those points until the potential conflict is resolved. They're generally in view, and low-level in a CTR: this really is kiddy stuff to process.

No disrespect, but you make the assertion that:

perhaps by permitting a dispensation, or limiting access to off peak times, or some other solution.

What exactly is 'some other solution?' I'd suggest that it's plain ATC competency. This is not brain-busting stuff. Someone entering a zone in a helo, low-level, shouldn't even need a TPDR, let alone Mode-S.

As regards user-pays, I seem to remember 'Free in G,' which was supposedly going to insulate GA from user-pays. Jeez, I scratch de head mon in remembering who pushed that barrel of monkeys.

[Dick Smith]

I supported free in g. Still do. They have it in Canada and UK. Why not Aus

I am not finished with this. Keep watching !

[growahead]

Dear Howabout, #32
No disrespect meant, but you suggest it's ATC "competency" (sic, I think you really mean incompetency). Thanks, those slack controllers really have it in for helicopters.
Like a minority of pilots, you seem to take the view I'm here, in my helicopter, and I want to go to XXX now. There is a bigger picture. Transponders permit TCAS to enhance situational awareness by pilots, and leading to avoidance procedures if deemed appropriate. It may be that a helicopter, on a converging track and vertical rate, could generate a TA, or even a RA. I'm sure most crews are more comfortable when they have accurate position on traffic in close proximity, and even more comfortable when they can see the traffic, which TCAS assists. I've already explained how mode s addresses the issue of garbling.
Disregarding the difficulty or lack thereof in separating helicopters and other traffic, a helicopter will occupy the frequency. I've been in jets on final into Brisbane and Sydney when, due to frequency congestion, landing clearances weren't received until very late final. Let's have a VFR helicopter in that mix. Ha ha.
You ask exactly what is "some other solution". I'm giving you the opportunity to display your creative side. I gave two examples, I'm sure there are others, do really want me to do all your thinking for you?
I'm not supporting the case for mode s, it may in fact be overkill. I'm trying to add to a conversation, but the correct decision should be reached by industry experts, not a bunch of point scoring amateurs.
I do agree with your summary in post 28. Sadly, the world is being taken over by corporations, but that's another issue.
You finished off with an impressive display of French. Well, allow me to help you a little; "my head" would be "ma tete"(possessive), except the french don't refer to their personal body parts in that way, in context it becomes "la tete". The phrase you are looking for is something like "je me gratte la tete". Your mastery of airspace management, it seems, is matched by you mastery of French. Kiddy stuff, really.

[hiwaytohell]

Dick, or anyone else.

At one of the consultative meetings I seem to recall Greg Russell suggesting that Airservices would subsidise the ADS-B transponder replacement for GA.

I can't recall the exact date but I think it was mid 2008? But it was definitely discussed with a throw away comment "$5,000 for 5,000 aircraft could be accommodated in the budget".
?

[Howabout]

Hi, growahead, as the cricket is on I was speaking West Indian, not French; but I should have actually phrased the line:

'Jeez, I scratch de head mon in remembering who pushed dat barrel of monkeys.'

As regards separating rotary from the 'big stuff,' you seem to be unrealistically reliant on expensive technology, when using the eyeball now seems to be a forgotten technique.

The rotary crowd have no more wish to kill themselves than your average jet pilot. They'll comply with your instructions and hold, if necessary, until the large stuff is out of the way. It used to be called ATC and I gave you the solution when it comes to facilitating rotary in a CTR.

Sadly, your emphasis seems to be on the 'confidence' of the big guys with the air picture, rather than their confidence in you as the 'ringmaster.' Implicit in your post is a disdain for the professionalism of rotary and, dare I say it, an abrogation of the fundamental responsibilities that go to flexibility and controlling traffic.

BTW, I am happy to be labelled as a 'point scoring amateur.' From you, I take it as a compliment. The dog needs his walk.

[growahead]

Dear Howabout,
Thank you for your reply. We can agree to disagree. I would make the observation that aviation is all about technology, especially these days.
In the good old days, we relied on individuals performing exceptionally. These days it's all about systems and procedures. The stats speak for themselves; although skills have been dumbed down, the safety record has improved enormously.
I embrace technology, and would pose the question about price. Smart phones are an example, costing up to $1K to buy, but corporations (I won't mention the A name) making billions (no exaggeration) in less than a year. Look what has happened to the price of GPS units, how can $20k be justified for one transponder?
I have no disdain for pilots of any discipline, in fact I am one myself. As alluded to above, it's no longer so much about the ringmaster, but management. Would you really suggest we abandon TCAS, and rely on ringmasters? Any enhancement of safety should be welcome.
Finally, I didn't refer to you as a point scoring amateur. That would be disrespectful and name calling is a form of bullying.
Let's hope that policy is made based on evidence and reason; what cracks are there, how often do they happen, what can we do about it. Discussion on a forum is ok, but there are better ways to achieve a positive contribution.
Regards, Growahead

[Howabout]

growahed; yep I'm happy to agree to disagree and keep it civil.

I have no issues with most of the technology - who could realistically argue against TCAS for what used to be called RPT?

However, despite your (valid) arguments that technology is unrealistically expensive, that cost remains a fact in the real world; a cost which has to be paid by already cash-strapped GA to be 'compliant' on the whim of bureaucrats. Bureaucrats that take their advice from fellow bureaucrats that live in 'lah-lah land' in CASA and Airservices.

My point was that we don't have to take it to the nth degree, when there are CDF answers. I was merely referring to facilitating low-level visual stuff in a CTR, and questioning the need for something like Mode-S when there are valid, KISS alternatives that won't cripple a GA operator.

Anyway, I am getting goo-goo eyes from the Border Collie for his run.

[Dick Smith]

The law requires a Regulation Impact Statement to be prepared.

It looks as if this was not done.

Is anyone concerned that CASA does not comply with the law of the land What does Creamy think?

[fujii]

This thread started about helicopters at Sydney and rapidly moved to Bankstown. Nowhere is there a link or copy of the document re Sydney. Where is the requirement published?

[null]

Is this the RIS you are looking for?

http://www.comlaw.gov.au/Details/F2012L01739/cad1f392-fc59-4610-b039-3ffd31208b0f

[crossbat]

I put a Trig 21 low power Mode S into my aeroplane for about $2300.00. ATC said they could see it fine. Don't know what the R22 voltage is but mine is 12 V DC. I recall there was some talk of financial assistance for ADSB fitment for GA from Airservices a few years ago but I don't think any aircraft owner seriously believed that would happen.