Mode S Consultation
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Robin
Surely not hitting another aircraft in flight is a big advantage, ADS-B will atleast keep the bigger and faster aircraft away from you.
Most of you have a GPS ADS-B works by broardcasting your position (from your GPS) via the Mode S transponder. An aircraft equiped with the full system will get commands to avoid your aircraft in much the same way as with TCAS.
As the cost of the system comes down I see a larger number of aircraft fitted with the system, after all in 1980 who would have predicted that in twenty years most light aircraft would have a global area navigation system.
But we need to push Eurocontrol and the CAA in the right direction and that is why I support ( with money) the efforts of the PFA & AOPA (IO-540 I would support the PPL/IR lot but I can't because I don't have a PPL)
Most of you have a GPS ADS-B works by broardcasting your position (from your GPS) via the Mode S transponder. An aircraft equiped with the full system will get commands to avoid your aircraft in much the same way as with TCAS.
As the cost of the system comes down I see a larger number of aircraft fitted with the system, after all in 1980 who would have predicted that in twenty years most light aircraft would have a global area navigation system.
But we need to push Eurocontrol and the CAA in the right direction and that is why I support ( with money) the efforts of the PFA & AOPA (IO-540 I would support the PPL/IR lot but I can't because I don't have a PPL)
Originally Posted by A and C
Surely not hitting another aircraft in flight is a big advantage, ADS-B will atleast keep the bigger and faster aircraft away from you.
How many people with aircraft valued at less than £5000 will accept paying thousands more just to keep flying? After the high costs of mandatory insurance, I would expect to see yet more leave the budget end of the sport.
What right does the CAA have to introduce legislation that will, at a stroke, place such an unnacceptably high cost burden on the budget end of recreational aviation?
We are not all in the comfortable position of being able to afford this much expenditure in one go, for many of us it represents several years maintenance costs.
VP
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Originally Posted by A and C
Surely not hitting another aircraft in flight is a big advantage, ADS-B will atleast keep the bigger and faster aircraft away from you.
Most of you have a GPS ADS-B works by broardcasting your position (from your GPS) via the Mode S transponder. An aircraft equiped with the full system will get commands to avoid your aircraft in much the same way as with TCAS.
Most of you have a GPS ADS-B works by broardcasting your position (from your GPS) via the Mode S transponder. An aircraft equiped with the full system will get commands to avoid your aircraft in much the same way as with TCAS.
..especially as the near approxes I have had have been with low-flying military stuff, and aren't they an exemption?
However, when you read the new requirement for the carriage of an ELT, the justification is the cost-benefit analysis of scrambling a Sea King to get you. Against that the £1500 cost is seen as very reasonable and hence now mandated.
Strange, isn't it, that a Mode S product that doesn't yet exist has the estimated price of £1500! Is this the CAA's view of a reasonable cost?
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As I said in one of my first posts on this subject there will always be aircraft that CAN'T fit mode S for technical reasons. these aircraft are the ones that only fly in good VFR and so I don't see a problem with the exemption of these aircraft, this is what I shall say to the CAA.
I don't think that the this is an unreasonable position to hold but rather than jumping up and down and stamping my feet in rage about mode S I try to see the advantages of the system and use the best reasoning to get the most out of the CAA/Eurocontrol in fact ADS-B (that is in use in the USA and Sweden) is in a lot of ways a better system than TCAS and yet costs a fraction of the price.
I don't think that the this is an unreasonable position to hold but rather than jumping up and down and stamping my feet in rage about mode S I try to see the advantages of the system and use the best reasoning to get the most out of the CAA/Eurocontrol in fact ADS-B (that is in use in the USA and Sweden) is in a lot of ways a better system than TCAS and yet costs a fraction of the price.
A&C,
I agree with your view, but the RIA makes it very clear that they don't wish to consider exemptions for other than a small subset of aircraft (hang gliders, specifically).
There are now many thousands of cheap and simple microlights and foot launched powered aircraft flying in the UK (the total number of microlights and foot launched powered aircraft flying in the UK is between 6000 and 8000). There are likely to be many more when the deregulation of single seat microlights gets into the ANO in the very near future (within the next 12 months, in all probability). For these aircraft to carry a transponder of any description is going to be a very real challenge, on cost, power consumption and radiological safety grounds.
My beef is with the broad-brush mandating of Mode S to ALL powered aircraft, irrespective of cost, safety or normal airspace usage, not the wisdom of fitting it for those who have the money to spare. To be completely honest, if I had the cash and an aircraft with an electrical system I would seriously consider fitting one, but there are many more pressing things I need to buy to keep myself and my aircraft safe.
What needs to be fought against, in my view, is the mandatory fitment to all powered aircraft and gliders, not the very existence of the system.
VP
I agree with your view, but the RIA makes it very clear that they don't wish to consider exemptions for other than a small subset of aircraft (hang gliders, specifically).
There are now many thousands of cheap and simple microlights and foot launched powered aircraft flying in the UK (the total number of microlights and foot launched powered aircraft flying in the UK is between 6000 and 8000). There are likely to be many more when the deregulation of single seat microlights gets into the ANO in the very near future (within the next 12 months, in all probability). For these aircraft to carry a transponder of any description is going to be a very real challenge, on cost, power consumption and radiological safety grounds.
My beef is with the broad-brush mandating of Mode S to ALL powered aircraft, irrespective of cost, safety or normal airspace usage, not the wisdom of fitting it for those who have the money to spare. To be completely honest, if I had the cash and an aircraft with an electrical system I would seriously consider fitting one, but there are many more pressing things I need to buy to keep myself and my aircraft safe.
What needs to be fought against, in my view, is the mandatory fitment to all powered aircraft and gliders, not the very existence of the system.
VP
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robin
the best thing for GA is to speak with a single voice. Dividing us up into small interest groups means that we can be picked off and ignored by the authorities.
Very true, but UK GA has never had a single voice and this isn't about to happen. There are too many different kinds of groups around scraping out the bottoms of too many different barrels.
I know some of 'top-end' GA who have already had to fit Mode S don't have a lot of sympathy with low-enders 'barging around the sky invisibly.
If you mean me, I would agree but you perhaps still fail to see what I don't like about it. I don't like getting a RIS with many of the reported contacts being something like "traffic at 12 o'clock, reciprocal track, altitude unknown". Totally f*****g useless. Especially when I know that a lot of the time (having caught a glimpse of him afterwards) he either does have a transponder and has deliberately turned it off, or the sort of plane it is (a new one) cannot possibly not have one.
As mentioned earlier, the £1500+ or £5000+ for Mode S has to give the owner something back worth that sort of spend - and it doesn't for microlighters, glider pilots or PFA pilots.
That's right, the benefit is "only" to all the other people in the sky. This illustrates why UK GA has no single voice
Actually I don't think it will be forced onto unpowered microlighters and gliders, anyway.
A&C
I would support the PPL/IR lot but I can't because I don't have a PPL
Perhaps you mean you don't have an IR? The group is open to IMCR pilots too, and anybody else can support it anyway. A lot of the members don't have an IR.
the best thing for GA is to speak with a single voice. Dividing us up into small interest groups means that we can be picked off and ignored by the authorities.
Very true, but UK GA has never had a single voice and this isn't about to happen. There are too many different kinds of groups around scraping out the bottoms of too many different barrels.
I know some of 'top-end' GA who have already had to fit Mode S don't have a lot of sympathy with low-enders 'barging around the sky invisibly.
If you mean me, I would agree but you perhaps still fail to see what I don't like about it. I don't like getting a RIS with many of the reported contacts being something like "traffic at 12 o'clock, reciprocal track, altitude unknown". Totally f*****g useless. Especially when I know that a lot of the time (having caught a glimpse of him afterwards) he either does have a transponder and has deliberately turned it off, or the sort of plane it is (a new one) cannot possibly not have one.
As mentioned earlier, the £1500+ or £5000+ for Mode S has to give the owner something back worth that sort of spend - and it doesn't for microlighters, glider pilots or PFA pilots.
That's right, the benefit is "only" to all the other people in the sky. This illustrates why UK GA has no single voice
Actually I don't think it will be forced onto unpowered microlighters and gliders, anyway.
A&C
I would support the PPL/IR lot but I can't because I don't have a PPL
Perhaps you mean you don't have an IR? The group is open to IMCR pilots too, and anybody else can support it anyway. A lot of the members don't have an IR.
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Seems to me they keep quoting benefits as "access to airspace". Well if they are hell bent on mandating transponders, why are they not considering the option of mandating mode C the minimum outside, class A (or D at worst), then its up to individuals whether they see the benefit of airspace access as worth the upgrade to mode S. TCAS on the airlines and fast jets (assuming the RAF put them on) will still prevent those collisions with Mode C.
Also they say:
"The introduction of SSR Mode S technology to replace existing SSR Mode 3A/C transponders would be an essential step in improving the efficiency of the SSR 1090 MHz ‘Reply’ frequency, and hence safety. Implementation of SSR Mode S would be the only way to permit the UK to increase the carriage of SSR transponders on aeroplanes and helicopters above current levels and meet the ICAO Annex 6 pressure-altitude reporting requirements. The withdrawal of SSR Mode 3A/C technology would also ensure that the full benefits of the recent investment made by operators in collision avoidance systems, SSR Mode S radars and the future ATC ground environment can be realised."
But don't back this up with any evidence. What is the evidence behind this, especially the bold bits?
I think they have built the case for this like a stack of cards, but with key cards missing.
Also they say:
"The introduction of SSR Mode S technology to replace existing SSR Mode 3A/C transponders would be an essential step in improving the efficiency of the SSR 1090 MHz ‘Reply’ frequency, and hence safety. Implementation of SSR Mode S would be the only way to permit the UK to increase the carriage of SSR transponders on aeroplanes and helicopters above current levels and meet the ICAO Annex 6 pressure-altitude reporting requirements. The withdrawal of SSR Mode 3A/C technology would also ensure that the full benefits of the recent investment made by operators in collision avoidance systems, SSR Mode S radars and the future ATC ground environment can be realised."
But don't back this up with any evidence. What is the evidence behind this, especially the bold bits?
I think they have built the case for this like a stack of cards, but with key cards missing.
IO540,
I hope you are right about this cost not being forced onto microlights, powered hang gliders, paramotors etc, but suspect that unless the views of this large group of recreational aviators are aired to the powers-that-be we WILL be lumbered with such an imposition.
Let's not forget that conventional light aircraft GA is heading towards becoming a minority in the recreational aviation market in the UK. If conventional light aircraft aren't already outnumbered by microlights, powered hang gliders and paramotors, I suspect that they will be before too long.
I may be wrong, as I don't have the statistics to hand, but a quick scan though the new registrations page in any of the magazines shows where the market growth is. It's also worth remembering that unregistered paramotors and powered hang gliders now outnumber microlights. They don't show in any published statistics, yet make up a sizeable proportion of the recreational aircraft sector and are impacted by this proposed legislation.
We must not let conventional GA thinking, by a few well-heeled souls who couldn't care less about spending another few thousand on their hobby, spoil the pitch for those of us not in such a privileged position.
VP
I hope you are right about this cost not being forced onto microlights, powered hang gliders, paramotors etc, but suspect that unless the views of this large group of recreational aviators are aired to the powers-that-be we WILL be lumbered with such an imposition.
Let's not forget that conventional light aircraft GA is heading towards becoming a minority in the recreational aviation market in the UK. If conventional light aircraft aren't already outnumbered by microlights, powered hang gliders and paramotors, I suspect that they will be before too long.
I may be wrong, as I don't have the statistics to hand, but a quick scan though the new registrations page in any of the magazines shows where the market growth is. It's also worth remembering that unregistered paramotors and powered hang gliders now outnumber microlights. They don't show in any published statistics, yet make up a sizeable proportion of the recreational aircraft sector and are impacted by this proposed legislation.
We must not let conventional GA thinking, by a few well-heeled souls who couldn't care less about spending another few thousand on their hobby, spoil the pitch for those of us not in such a privileged position.
VP
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Can anyone please tell me why military aircraft should be exempt? I can see the reasons in time of conflict etc but what about normal operations? They should be mandated to use at the very least current mode c.
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Maybe this should be done with PMs A&C 
but it looks like you have a CPL or ATPL then.
A lot of FAA IR private pilots do in fact have a CPL and not a PPL. This is because the FAA CPL is, like the FAA IR, much more practically based than the Euro version. I am doing mine too, have done the written already.
Also, a big chunk of the now ageing CAA IR crowd are in fact ex commercial pilots who have ATPLs, and not all of them have PPLs.
but it looks like you have a CPL or ATPL then.A lot of FAA IR private pilots do in fact have a CPL and not a PPL. This is because the FAA CPL is, like the FAA IR, much more practically based than the Euro version. I am doing mine too, have done the written already.
Also, a big chunk of the now ageing CAA IR crowd are in fact ex commercial pilots who have ATPLs, and not all of them have PPLs.
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So we don't like this- well do something !
I am slowly getting together my responce to this mode S thing and the most apparent error in the CAA document is the cost to industry.
Having just skimmed table 5.3.1.1 I see that the CAA thinks that a "lightwieght aviation SSR transponder" (LAST) costs £500-£1000.
A quick look at page 6 of popular flying shows the first of these units on sale for £1500 so clearly I will have to go and look more deeply into the costs as it would seem that section 5.3 of the document is somewhat wide of the mark !
Once I have digested the costs part of the document I will let you know the results but if the cost estimate for all the sections of 5.2 are as far adrift as the LAST estimate then it will be time to write to the minister of transport to let him know that the CAA document is misleading.
Having just skimmed table 5.3.1.1 I see that the CAA thinks that a "lightwieght aviation SSR transponder" (LAST) costs £500-£1000.
A quick look at page 6 of popular flying shows the first of these units on sale for £1500 so clearly I will have to go and look more deeply into the costs as it would seem that section 5.3 of the document is somewhat wide of the mark !
Once I have digested the costs part of the document I will let you know the results but if the cost estimate for all the sections of 5.2 are as far adrift as the LAST estimate then it will be time to write to the minister of transport to let him know that the CAA document is misleading.
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The quotes that i am getting for a panel mounted Mode S are between £2800 (Garmin) and £3100 (King)+ £170 for the Alt encoder + VAT, I suspect that you could dirve the price down by about £200 with one other type of transponder but that is all that is on the market for panel mounted units.
This is a far cry from the CAA estimate of £1700 - £1800 for a panel mounted LAST unit but this is all that is on the market at the moment.
For you interest take a look at
www.casa.gov.au/pilots/download/ADS-B.pdf
This is what we should be getting if we have to go down the mode S road.
This is a far cry from the CAA estimate of £1700 - £1800 for a panel mounted LAST unit but this is all that is on the market at the moment.
For you interest take a look at
www.casa.gov.au/pilots/download/ADS-B.pdf
This is what we should be getting if we have to go down the mode S road.
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I am finding the document a fascinating read, full with hopes and expectations, just like all government IT briefs.
It is clear the CAA are concerned that the 'cheap-skates' will find it hard to afford this additional cost and looking for the magical piece of kit that can be brought down in price by generous manufacturers
I love the bit (6.2), where they give an example of a flying school with 8 aircraft required to find £24k to equip their fleet, probably resulting in the sale of one aircraft. They then state that they expect businesses to get a 15% discount (built into the figures) when bulk-purchasing the kit, but in 5.2.4, this is an anticipated discount for purchases of 10 units - not a lot of good for the 8 aircraft club, then.
This doesn't even get close to the situation of the user groups with one or two aircraft that need to be re-equipped. They can't even set the cost off against tax - as mentioned in 4.3 and 4.4, where it is acknowledged that the main burden will be picked up by private aircraft operators - not business.
Add to that the massive hike in the numbers of annual checks (up to 13,200) new aircraft requiring licencing and annual checks), and we start to see the scale of the issue.
It is clear the CAA are concerned that the 'cheap-skates' will find it hard to afford this additional cost and looking for the magical piece of kit that can be brought down in price by generous manufacturers
I love the bit (6.2), where they give an example of a flying school with 8 aircraft required to find £24k to equip their fleet, probably resulting in the sale of one aircraft. They then state that they expect businesses to get a 15% discount (built into the figures) when bulk-purchasing the kit, but in 5.2.4, this is an anticipated discount for purchases of 10 units - not a lot of good for the 8 aircraft club, then.
This doesn't even get close to the situation of the user groups with one or two aircraft that need to be re-equipped. They can't even set the cost off against tax - as mentioned in 4.3 and 4.4, where it is acknowledged that the main burden will be picked up by private aircraft operators - not business.
Add to that the massive hike in the numbers of annual checks (up to 13,200) new aircraft requiring licencing and annual checks), and we start to see the scale of the issue.
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£2500-£2800 plus VAT is about right for a Garmin GTX330. The unit lists at about £2000, and the cheapest installation (assuming a readily available prewired bay in which a transponder used to live) is about £300.
This is for either a G-reg or an N-reg but on a N-reg it costs more because an IA has to sign it off; alternatively you can go to a firm which has an in-house IA but they will charge you more to start with If you need a DER signoff that's another £500 at least.
This is for either a G-reg or an N-reg but on a N-reg it costs more because an IA has to sign it off; alternatively you can go to a firm which has an in-house IA but they will charge you more to start with
If you need a DER signoff that's another £500 at least.
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"The real problem is that the CAA have not had to deal with any effective opposition to there policys in the past. At long last GA is getting it's act together with AOPA, PFA and others moving into political lobbying and putting pressure on them."
Really
I see no evidence of this being the case.
GA has no united representation in Europe. For this reason the lobbying that does take place is ineffective.
I fitted mode S when it was first mooted it would be mandatory for controlled air space operations - cost about £4,500. There does not seem to have been any significant fall in the price of Garmin units since.
Care should be taken about underestimating the cost of installation. Often it is not a simple replacement of the existing unit.
Whilst I believe it is not mandatory - try and find someone who can test the mode S aspect. In theory it should be possible to do so on the ground - but how many work shops have the equipment? You will have even less luck in the air.
Any regulatory authority has a moral if not legal responsibility to conduct a regulatory impact assessment AND to ensure in this case the suppliers can meet demand, supply the units at the cited cost and the workshops can fit and test the equipment. I am not sure those assurances can be given on any of these counts at the moment.
Should we all fit mode S? My original inclination was we should not be compelled to do so. However, I am a great supporter of GPS. In my opinion GPS used properly has made navigation far more reliable and the risk of CAS infringements less. The cost of the units has fallen, in part doubtless due to increased demand. There is a danger with any new technology that we are resistant because it is "new". My own opinion is that IF the units can be produced as cheaply as the CAA say, and the workshops can fit and test the equipment, and the advantages others have outlined are part and parcel of the deal, there will be benefits for many users. Those who see no benefit for themselves should also recognise that unless fitment is universal, the benefits of traffic avoidance are negated for all.
In particular I agree with the carriage of mode S for IMC (not IFR) operations regardless of the airspace. The reality is that for IMC operators the cost of the kit whilst never inconsequential is part of the high cost of maintaining an aircraft fit for this purpose. In spite of the big sky theory I like a RIS or RAS inside and outside controlled airspace in IMC but the reality is in open FIR it is seldom available.
Finally cases of “near misses” in controlled airspace have been cited as part of the rational. It occurs to me however that if a pilot is going to infringe CAS there is also a good chance he is not talking to anyone on the radio anyway so mode S will only help if he cannot be identified on primary radar. Of course if he has “forgotten” to turn on the radio presumably he might well have “forgotten” to turn on mode S and mode S Alt.
Maybe AT should be able to discretely activate an rev limiter in these circumstances - that would of course get the pilots attention!!
Really
I see no evidence of this being the case.
GA has no united representation in Europe. For this reason the lobbying that does take place is ineffective.
I fitted mode S when it was first mooted it would be mandatory for controlled air space operations - cost about £4,500. There does not seem to have been any significant fall in the price of Garmin units since.
Care should be taken about underestimating the cost of installation. Often it is not a simple replacement of the existing unit.
Whilst I believe it is not mandatory - try and find someone who can test the mode S aspect. In theory it should be possible to do so on the ground - but how many work shops have the equipment? You will have even less luck in the air.
Any regulatory authority has a moral if not legal responsibility to conduct a regulatory impact assessment AND to ensure in this case the suppliers can meet demand, supply the units at the cited cost and the workshops can fit and test the equipment. I am not sure those assurances can be given on any of these counts at the moment.
Should we all fit mode S? My original inclination was we should not be compelled to do so. However, I am a great supporter of GPS. In my opinion GPS used properly has made navigation far more reliable and the risk of CAS infringements less. The cost of the units has fallen, in part doubtless due to increased demand. There is a danger with any new technology that we are resistant because it is "new". My own opinion is that IF the units can be produced as cheaply as the CAA say, and the workshops can fit and test the equipment, and the advantages others have outlined are part and parcel of the deal, there will be benefits for many users. Those who see no benefit for themselves should also recognise that unless fitment is universal, the benefits of traffic avoidance are negated for all.
In particular I agree with the carriage of mode S for IMC (not IFR) operations regardless of the airspace. The reality is that for IMC operators the cost of the kit whilst never inconsequential is part of the high cost of maintaining an aircraft fit for this purpose. In spite of the big sky theory I like a RIS or RAS inside and outside controlled airspace in IMC but the reality is in open FIR it is seldom available.
Finally cases of “near misses” in controlled airspace have been cited as part of the rational. It occurs to me however that if a pilot is going to infringe CAS there is also a good chance he is not talking to anyone on the radio anyway so mode S will only help if he cannot be identified on primary radar. Of course if he has “forgotten” to turn on the radio presumably he might well have “forgotten” to turn on mode S and mode S Alt.
Maybe AT should be able to discretely activate an rev limiter in these circumstances - that would of course get the pilots attention!!
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I just had a Mode S fitted to my Hawk XP. Cost me £1800 plus VAT all in. Linked to the GNS 430 so it goes in and out of flight mode automatically and has been enabled to recieve traffic data should it ever appear in Europe. I llok forward to taking it to the USA next spring and seeing the traffic stuff actualy work for real!
