Mode S Consultation

[robin]

Dear all

The RIA for Mode S has just been published. Please look through the documentation and respond to the CAA. This is likely to prove expensive for low-end pilots - they quote a figure for a LAST of between £500-£1000, but the cheapest so far is over £1500

http://www.caa.co.uk/default.aspx?ca...90&pageid=6476

[VP959]

The above link has been a little edited somewhere along the line, I think. The link direct to the Mode S page seems to be:

http://www.caa.co.uk/default.aspx?ca...90&pageid=6476

There is an online questionaire for those so inclined to respond, but it helps if you read an inwardly digest the RIA document before attempting it.

The RIA document itself seems a little flawed and makes a number of errroneous assumptions. It's well worth a read if you are interested in the future costs of recreational aviation, even if it is a bit hard going.

VP

[Maxflyer]

I read through the document and believe that it is pretty much decided. Mode S will be a part of our life soon enough. The suggestion seems to be that if it is not accepted fully we will lose swathes of class G to controlled airspace. The document notes how there will be detrimental effect on small FTOs and cites a business case where one operator will have to sell one aircraft in his fleet to fund the outfitting ofr his other aircraft with mode S kit. It says that the costs will be passed on by increases in student training rates and that there will be a fall off in the number of trainee PPLs taking up flying.

Apparently we (GA) are responsible for a phenomenal rate of near misses each year and this is the only way to stop it! I'm inclined to believe that it is more to do with an opportunity to tax us for our time in the air. Whilst that particular method of revenue grabbing is not alluded to in the document I just get the nagging feeling that GA is looked upon as an unwanted user of the sky above CAA land. The document notes the year on year increase of CAT and I guess the government and large operators have to be seen to be doing something about reducing emissions. Well, get rid of GA and I'm sure that would help meet our Kyoto commitments!

I realise reading my words that I sound a bit like a conspiracy theorist, but stranger things have happened.

I also know who killed Kennedy and can tell you the real truth about Roswell

[QDMQDMQDM]

I suspect one of the drivers behind Mode S is so that we can share our uncontrolled airspace with UAVs. They don't say it, but I bet that is a reason.

The whole thing makes me want to vomit. I shall not switch it on most of the time. As I have said before, what are they going to do? Send the police to the rough area where my non-mode S transponding aircraft disappeared from the screen and try and arrest me?

Add in number plate reading cameras and face recognition cameras all over our motorway system (now and in process), aggregation of all medical records to a cetnral spine (in process), road charging by GPS transmitter (trials planned), guarding of all mobile phone calls and location information for 5 years (now) and, boy, do we have a surveillance state.

QDM

[IO540]

QDM

I do wonder what is going to be done about all those planes that don't have a proper electrical system, but IMHO you are going a little over the top when it comes to Mode S and "big brother".

This topic has been done to death here but basically there isn't enough radar coverage to usefully track planes with Mode S as they bimble around the UK countryside at 2000ft and they sure as hell aren't going to install it for tracking GA traffic.

I happen to think that if the UK had adopted, many years ago, the US-style mandatory Mode C veils around major airspaces, we would not be facing this issue now. The schools would have done their bit of moaning but by now it would be over and done with. The TCAS triggering issue would not be an issue, and that would deal with most of what I believe to be the true reason behind the current push for mandatory transponders. But no, UK GA will safeguard its human rights right up to the point where the only bit of it still left flying will be farm strip operators.

[A and C]

What's in it for us?

At the moment the take up for mode S in the UK is very low even in the light of it becoming mandatory. This is because the fitting of mode S is of no improvment to the way we fly.

In the USA the GA community is fitting mode S but it is NOT mandatory............. why ?

It is because with the mode S you can get weather radar data link, traffic imformation and soon ADS-B (it's on the east coast now).

If the CAA want us to spend about £5000 per aircraft to help them out then we must have something in return and ADS-B would be a good start.

I do however wish them to note that some aircraft will never have the electrical systems to support any form of mode S, these aircraft are the types that only fly on good VFR days so ADS-B would not be too much of an issue.

[robin]

Great - £5000 + fitting (not counting annual checks and licences) for us is our engine fund, at present.

Add to that the second consultation about rolling out EASA regs to the operations of airfields across Europe, and we're in for some 'fun'!

In some respects, it is good that we are such an aged bunch, with fewer young people coming into the sport. It means that in 10 years time, sport aviation might be only the distant memory of a few old people sitting in their nursing homes.

[A and C]

over reaction

It should be about £5000 fitted and if you have GPS ADS-B traffic avoidance.

Any how you won't get much engine for £5000 !

[VP959]

I note that in the RIA the CAA quote the total UK financial impact as below £20M, hence this does not require to be presented to the Prime Ministers office for approval.

Mind you, they are also quoting a transponder installed cost of £500 and have made no mention of the installation cost or annual inspection/maintenance charges.

A quick sum shows that at the present cost of £1500 per unit, the cost to recreational aviation alone will be over £10M, excluding fitting and certification costs.

VP

[IO540]

It means that in 10 years time, sport aviation might be only the distant memory of a few old people sitting in their nursing homes.

I am afraid that is a lot closer to the truth than many would admit, but equally the same will happen to the old farts inside the CAA The only difference is that they will have a much better pension than you...

I think Mode C should have been made mandatory, in many/most places, years ago. The problem with GA is that everything is made into a massive fight, often backed up by highlyemotive and false arguments (like the big brother radar surveillance stuff - never technically feasible). Every time this bogus stuff gets used, the people in power just take the p1ss.

Mode S is not the end of the world; many people operating 30 year old Cesspits spend twice the GTX330 installation cost on every Annual. If your plane has no way to carry a Mode S XP then by all means fight it but for everybody else it is now a lost battle.

[robin]

Originally Posted by A and C

It should be about £5000 fitted and if you have GPS ADS-B traffic avoidance.
Any how you won't get much engine for £5000 !

No - but it is what we have saved for the replacement over a considerable period. To burn it on a piece of kit I don't need, is a bit of a gut-wrencher. There are more necessary items I'd prefer to spend the money on

[VP959]

Just remember that a great many of us fly aircraft with a value of less than £5000 and do so on an annual flying budget of a few hundred pounds.

The cost of a transponder, radio, installation etc is several years maintenance costs for some of us, so we will forgo something else, probably more safety relevant, if forced to buy this useless item.

I have yet to see a single pertinent argument as to why a slow, highly visible, low flying, microlight, paramotor or powered hang glider, that only flies in the open FIR during daylight and good weather, should be forced into this expenditure.

Not only that, but there is no suitable equipment available for carriage on many of these very light aircraft and fitting one of the existing Mode S units may present an unnacceptably high radiological exposure risk on something like a paramotor.

Let's not forget that there are more than 10,000 of us that fly cheap and slow aircraft, VFR only and not in controlled airspace. There are, I believe, more than 3,000 paramotor aviators alone, plus another 4,000 microlights, a couple of thousand PFA types and probably a couple of thousand gliders, all of whom have been included in the daft bit of blanket legislation as it is currently worded.

We need to take a balanced view, based on the total number of individuals impacted by this, not just the impact on the relatively small number of GA aircraft.

VP

[IO540]

Well I am sure the people inside the CAA are not stupid and if there is no way to do it then they won't enforce it, for those types.

The "farm strip" flying scene in the UK is pretty safe, probably safer in the very long term than anything else. All of UK's GA airfields (everything below say the level of Southend or Cardiff) could close and probably will but farm strip flying will always carry on. It's a very basic sporting activity.

Just remember that

that only flies in the open FIR during daylight and good weather

not in controlled airspace

is in fact not true for the hundreds of these pilots that infringe CAS every year.

Last year I had an unrelated reason to phone up ATC at a major airport in the south and they said they got a dozen or two infringements the previous day or two, mostly microlights going to/from some microlight convention, with a whole swarm of them going through a bit of the Class A.

It's all very well arguing for training simplicity for these relatively simpler planes (and I have no reason to doubt that the WW2 attitudes to GPS prevalent in GA are any different there) but you've only got to fly on the wrong heading for an extra 5 minutes (because you forgot to wind up your stopwatch, or any of a dozen other reasons) and all of a sudden you find yourself above this big airport with two big runways, with a load of 747s on the ground, a load more holding above, departures stopped, and everybody in the tower tearing their hair out and many of them wishing GA was totally banned.

[robin]

IO540

>>>Well I am sure the people inside the CAA are not stupid and if there is no way to do it then they won't enforce it, for those types. <<<

I'd never call the types at the Belgrano stupid. What I would accuse them of is not defending the rights of non-commercial traffic. The Transport Select Committe has already seen that the CAA has little representation by GA.

Unfortunately between them, EASA and the CAA will do whatever is easier for them, and they are firm believers in the power of regulation. After all, there can be no accidents if 'the little guy' is regulated out of existence - but in the name of safety, of course

I'd really like to be proved wrong, but precedence goes against it.

[A and C]

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.

My plee is that ALL pilots in the GA sector join one of the oganisations that is working to get the results for GA that we want, the trouble is that a lot of pilots will spend £120 to fly for a cup of tea on a Sunday but won't spend £48 on a years membership of the PFA.

[IO540]

The most effective thing currently is probably membership of the PPL/IR group (www.pplir.org). Admittedly perhaps not for the PFA types but at least they don't go around like a bull in a china shop. GA IFR privileges are the most threatened in the long term; VFR will always carry on in some form, with by far the biggest enemy being property developers.

[robin]

No - 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.

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. But surely we all need to take the view that all new regulations have to be reviewed properly and none should be imposed at disproportional cost.

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.

[eyeinthesky]

QUOTE
I have yet to see a single pertinent argument as to why a slow, highly visible, low flying, microlight, paramotor or powered hang glider, that only flies in the open FIR during daylight and good weather, should be forced into this expenditure
UNQUOTE

How about this:

2 of the most serious safety incidents to affect civil commercial aircraft so far this year have been:

1) A paramotor in controlled airspace in the middle of the climbout lane of a regional airport which was only just missed by a DH8 departing. The DH8 had no time to take avoiding action.

1) A motor glider at FL80 in controlled airspace overhead another regional airport which was just missed by a regional jet.

Both of these were in 'daylight and good weather'; they had just missed out the 'open FIR' bit. Neither of them were visible on radar or TCAS and would have been unable to manoeuvre quick enough to avoid a collision.

I'm afraid that the crass stupidity or dogmatic attitude or even "The whole thing makes me want to vomit. I shall not switch it on most of the time. As I have said before, what are they going to do? Send the police to the rough area where my non-mode S transponding aircraft disappeared from the screen and try and arrest me?" approach is doing us no favours. If EVERYONE kept in the bits they should do there would be no risk, but they don't.

You may object to spending £5k on a bit of equipment, but if that ultimately helps another aircraft see you and avoid you (using ATC radar support or TCAS), then how does that cost compare to the cost of your life or those of unsuspecting fare-paying passengers (we are all those at some time) who have a right to expect to get from A to B without the risk of being wiped out by some unseen aircraft who is where he shouldn't be?!

[VP959]

The simple fact is that this is massive overkill for a relatively small problem.

BTW, £5k is more than my aircraft is worth, by far, plus it's more than most paramotors cost new.

The bottom line with this legislation is that it's a sledgehammer to crack a nut, it's poorly thought through and furthermore the RIA misrepresents the true costs and risks.

I agree wholeheartedly at the need to try and reduce airprox incidents, but cannot realistically see how fitting transponders to all and sundry would achieve this.

As a further point, foot launched powered aircraft are exempted from regulation under the ANO and I understand that single seat microlights are soon to be granted the same, or a similar, exemption. This is hardly going to make enforcement straightforward. If introduced as it stands I suspect safety might be further compromised, as those outside of the regulated environment might just be further alienated by increasingly daft rules and regulations, and hence pose a greater danger to CAT etc by ignoring much of what comes out of the Belgrano.

As with most things, education works better than regulation, and that is what will stop people behaving dangerously, not a little box that costs them a fortune and tells them nothing.

VP

[tmmorris]

Originally Posted by IO540

GA IFR privileges are the most threatened in the long term

Couldn't agree more. We are being pushed towards light sport/microlight/PFA day VFR types, NPPL (no IFR or night ratings available), and the PPL and IR become ever more geared towards commercial training. With the British weather this is foolish and dangerous.

Tim