Proposed amendment of the ANO: Mode S

[robin]

Counsel of perfection, I'm afraid

I think we are all just too cynical about what we will get from Mode S expenditure when the infrastructure is just not there and the ATCOs themselves are getting nervous about the way their screens will work in future with everyone transponding

Flying a PFA machine I have no option but to plan my routes so I don't overfly congested areas and rarely get any service from the Mon-Fri only LARS service

At weekends I talk to the air-ground operators at (say) Compton Abbas, Old Sarum, Popham or Wycombe and give traffic information. They are just not equipped (or permitted) to give meaningful information, except to watch out for local traffic. Mode S just won't make any difference

[gpn01]

Another agenda ?

I find it strange that the rest of Europe isn't mandating a change to Mode-S.

If there's a demonstrable benefit (e.g. cost saving or improvement in safety) then why isn't Europe driving this 'initiative' ? The drive is not by EASA (= European Aviation SAFETYAgency) but by the CAA who probably see their existing role diminishing as EASA takes on more responsiblities.

Could Mode-S, and its regiulation, provide the CAA with a purpose to exist post-European harmonisation ?

[NorthSouth]

Originally Posted by gpn01

I find it strange that the rest of Europe isn't mandating a change to Mode-S.

It is. There's an ECAC mandate for Mode S, leading ultimately to ADS-B. In addition there's an ICAO Standard that all aeroplanes and helicopters should carry a transponder. The UK's filed a difference from that for years but the CAA has now committed itself to following ICAO SARPs wherever possible.
NS

[gpn01]

Originally Posted by NorthSouth

It is. There's an ECAC mandate for Mode S, leading ultimately to ADS-B. In addition there's an ICAO Standard that all aeroplanes and helicopters should carry a transponder. NS

The existing ECAC mandate is for aircraft above 5700kg/19 pax though isn't it ? (http://www.eurocontrol.int/msa/galle....0.11SEP03.pdf) .

I couldn't find details online about an ICAO transponder standard (although I did find http://www.airservicesaustralia.com/...S-B%20Aus..pdf which is an ICAO report on the immaturity of ADS-B). In any case, I thought that the ICAO standard was for aeroplanes (which isn't necessarily the same as aircraft).

[NorthSouth]

Originally Posted by gpn01

The existing ECAC mandate is for aircraft above 5700kg/19 pax though isn't it ?

Yes you're probably right - what are other ECAC states doing about extending the Mode S requirement to all aircraft/all airspace?

Originally Posted by gpn01

I couldn't find details online about an ICAO transponder standard...In any case, I thought that the ICAO standard was for aeroplanes (which isn't necessarily the same as aircraft).

The Danish SLV has helpfully put all ICAO annexes on their website at http://dcaa.slv.dk:8000/icaodocs/
The generic transponder requirement is in all three parts of Annex 6, so applies to air transport and GA aeroplanes and to helicopters - "All aeroplanes/helicopters shall be equipped with a pressure-altitude reporting transponder". UK has filed a difference to this, stating that they'll apply it when Mode S comes in. My only question is, since ICAO Annex 6 only applies to International Commercial Air Transport - Aeroplanes, International General Aviation - Aeroplanes and International Operations - Helicopters, does this mean ICAO SARPs don't apply to any aircraft which is not flown internationally?
NS

[bookworm]

Originally Posted by NorthSouth

My only question is, since ICAO Annex 6 only applies to International Commercial Air Transport - Aeroplanes, International General Aviation - Aeroplanes and International Operations - Helicopters, does this mean ICAO SARPs don't apply to any aircraft which is not flown internationally?

ICAO SARPs only apply as adopted by local law. The deal is that if you're equipped according to the ICAO SARPs, you should be permitted to fly internationally without having to jump through hoops related to every state you want to fly over. But the local law can exempt anything from ICAO rules for flight within its sovereign airspace as it sees fit.

[gpn01]

Am confused

Originally Posted by bookworm

Iif you're equipped according to the ICAO SARPs, you should be permitted to fly internationally without having to jump through hoops related to every state you want to fly over. But the local law can exempt anything from ICAO rules for flight within its sovereign airspace as it sees fit.

So, if the future scenario is that the whole of UK aviation (that's EVERY glider, light aircraft, microlight, balloon, hang glider, UAV, helicopter and ultralight) is entirely controlled, as the CAA would like it, by Mode-S equipped facilities then a German Cessna 172 decides that he wants to fly to the UK will he/she need a Mode-S tranponder fitting ?

[IO540]

Yes, he will upon entering UK CAA airspace, unless a temporary visitation exemption is available.

This is already the case for loads of other equipment, especially for IFR. Take the old ADF thingy. The CAA requires it for IFR in CAS, but few other countries require it. Germany requires an ADF for some night flight IIRC.

ELT is another. Some countries need it, some don't. All N-reg planes have to carry it, worldwide.

The equipment carriage rules across Europe are an absolute nightmare, and are "obviously" widely flouted without anybody (the pilot in particular) realising.

To date, anybody flying IFR will have been generally aware of the need to carry various bits of variously expensive kit if they want to fly around Europe. Now, with Mode S, attention of VFR pilots is being drawn to it.

One would have thought that JAA would have unified the rules but they haven't. The nature of politics is that local exemptions have to be allowed in order to get anything agreed. EASA, taking over from JAA, is likely to simply force a lot of stuff through.

N-reg owners tend to be more aware of this than most, not least because the rules are more clearly stated.

[bookworm]

Originally Posted by gpn01

So, if the future scenario is that the whole of UK aviation (that's EVERY glider, light aircraft, microlight, balloon, hang glider, UAV, helicopter and ultralight) is entirely controlled, as the CAA would like it, by Mode-S equipped facilities then a German Cessna 172 decides that he wants to fly to the UK will he/she need a Mode-S tranponder fitting ?

I think it extremely unlikely that he/she would need one "fitting" as I would be very surprised if German requirements were less onerous than our own.

Note that according to ICAO SARPs, as NS suggested, altitude-reporting transponders have been required for all flying machines for at least 5 years.

By the time the Mode S requirement comes in, I imagine this will all be within EASA's remit.

[Sedbergh]

From reading the PFA and BGA responses to the Mode S proposal it appears that the French and the Germans are NOT proposing to make transponders compulsory in open airspace, but only in CONTROLLED airspace (which makes sense because all concerned will be in touch with ATC anyway)

The CAA seem to be alone in the folly of wanting everything that flies to have transponders in uncontrolled airspace.

I wonder what would happen if every light a/c, glider, microlight, VLA etc had a transponder and then asked for RIS in open airspace. How long before the system collapsed? 5 minutes??

[robin]

Originally Posted by Sedbergh

.
I wonder what would happen if every light a/c, glider, microlight, VLA etc had a transponder and then asked for RIS in open airspace. How long before the system collapsed? 5 minutes??

It is becoming clear that we are not to get any additional service or access to CAS just through carrying Mode S. ATC will 'dial us out' unless we get close to bothering them.

Even ATCOs are saying that they are going to have real trouble with this one, and don't want it, except in the areas that concern them ie close to their airfields or commercial traffic

[Parapunter]

I agree that this is important Mr Sedbergh. I'm a member of the hang & paragliding communities, just one of around eight thousand in the UK & half a million or so Europe wide. This proposal from the CAA could very well represent the end of competitive cross country flying in the UK for us since the kit represents a severe weight & cost penalty for our ultra light aircraft.

Whilst we only fly for leisure, it's estimated that 2,000 jobs will be at risk from this proposal & the end of a thirty year sporting heritage could be made reality. Naturally, we seek exemption from the proposal & the associated costs of implementing it. Thus far, we have seen price proposals of 1000-1500 GBP per unit with a 3-400 GBP annual oncost for servicing of the transponder units. To put it in context, that represents over 50% of the purchase price of our gliders!

Instead, we would prefer to illustrate our discipline in the light of our well established controlling body, the BHPA & our strict & thorough pilot rating scheme which gives those pilots flying beyond our soaring ridges the skills & awareness to mix safely with our powered brethren.


Say no to mode s Transponders!


Edited to add: I should point out that I speak only for myself & represent no part of our sport other than my own bimbling around the sky.

[robin]

Just seen Max Seaman's response in Loop. I have great respect for him in my dealings with him.

However, here is what he says about the price of kit:

"You state that a transponder is going to cost £2000, but make no mention of the Low Powered SSR Transponder (LPST) that the CAA would like to see marketed at £500-£1000"

Well, where is it? and what are the CAA doing to ensure that the price is at the lower end of the spectrum?

It seems the only people the CAA wish to exempt from carriage of Mode S are parachutists

[jabberwok]

I could point you to one such device but forum rules probably don't allow it.

Try an oogle search for "Lightweight Mode A/C/S Level 2 Transponder with ADS-B". That should take you straight to the page.

[Choxolate]

One of the things that worries me is the format of the "consultation" document.

Basically it is divided into sections with a series of questions and multiple choice answers, e.g. one question is "Need to improve collison avoidance measures" - Strongly Agree to Strongly Disagree with this as an aim.

Is there anybody who thinks we should not try to improve collision avoidance?

So a tick in the agree box.

Now all the boxes will be added up and the CAA will say that over xx% agree that Mode-S will improve collision avoidance - OH NO THEY DIDN'T - they agreed it should be improved but not HOW.

This method of consultation applies through the whole document and will give the answer they want.

Yes there is space to write comments but I am sure these will not be used for any quantitative analysis.

[robin]

Originally Posted by jabberwok

I could point you to one such device but forum rules probably don't allow it.
Try an oogle search for "Lightweight Mode A/C/S Level 2 Transponder with ADS-B". That should take you straight to the page.

If you are talking about the first entry - they would find it hard to get below £1500

[VP959]

Indeed, the one referred to is £1500 plus VAT, which makes it closer to £1800, rather than the "£500 to £1000" referred to by the CAA in the RIA. As it looks like being the only one on the market, why should they reduce the price? It certainly wouldn't make economic sense when they have a captive market that absolutely have to buy the things under a provision of the law. In fact, my inclination if I were this company would be to put the price up, as people will still have to buy them if they wan't to keep flying................

VP

[IO540]

The "confidential" end user list price of a GTX330 is about £2000+VAT. Installation is on top and will range from £300 to replace some existing transponder, to a lot more for a complete brand new setup.

A cheap transponder won't help with the installation cost.

The only way to make this whole business "cheap" is to have a portable transponder, which can be strapped somewhere or installed by the pilot.

The moment an avionics shop is involved, nothing much happens under a grand if it involves drilling holes, fitting aerials, and running wires.

I still can't believe they are going to mandate Mode S for everything that flies. Quite bizzare.

[Lucy Lastic]

Originally Posted by IO540

The "confidential" end user list price of a GTX330 is about £2000+VAT. Installation is on top and will range from £300 to replace some existing transponder, to a lot more for a complete brand new setup.

A cheap transponder won't help with the installation cost.

The only way to make this whole business "cheap" is to have a portable transponder, which can be strapped somewhere or installed by the pilot.

I've been told that the LPST mentioned needs a chip installed in the aircraft circuitry to uniquely identify the aircraft (for charging purposes??). Although the LPST is portable, the chip isn't, and will need installation, maintenance and calibration - all at a price.

On the RIA is says that if all aircraft (gliders, microlights and fixed wing) get Mode S, 13000 aircraft will need to be fitted, have annual checks, and get fixed when it goes wrong.

Do we actually have enough avionics engineers willing to do this?

[VP959]

My previous price was wrong, it's £1500 including VAT, not plus VAT.

The number of aircraft affected is a lot more than 13,000. According to the CAA's own GA review figures there are more than 27,000 affected aircraft in the UK fleet. 26% of these are un-registered, deregulated types (hang gliders, paragliders, powered hang gliders and paramotors), 21% are SEPs, 15% are microlights, 10% are gliders, 7% are balloons/airships, 6% are PFA types, 6% are helicopters and gyroplanes, 4% are commercial air transport, 2% are private multi engined, 2% are vintage or historic and 1% are private turbine.

The recreational aircraft sector is about 75% of the UK fleet, perhaps a little more, and is composed mainly of very light aircraft with little or no capability to carry a transponder.

With an assumed unit cost of £1500 (as this is what the only unit available is priced at), then the cost of fitting all 27,000 aircraft will be over £40M, excluding installation, inspection, approval and licencing costs. Even allowing for perhaps 10% of the fleet that already have Mode S, the cost still greatly exceeds the £20M figure beyond which regulatory impact statements have to be submitted to the Prime Ministers Office.

The CAA are pulling a fast one here, as they seem to have deliberately set the assumed unit price of a transponder, plus the affected aircraft fleet size, at figures that come in below the magic £20M.................

VP