Proposed amendment of the ANO: Mode S
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Case doesn't stack up
Right, I've read the RIA and a few other documents to boot and come to these conclusions.
The total number of airproxes in an 18 month period (Jan 04 to Jun 05) was 299. Let's round that to 300 and take two-thirds to give us 200 per annum. Of those, only 150 or so would have benefited from Mode S/TCAS. Compare that to the CAA's own traffic statistics of total air movements of 3.8 million in 2005. Doing the sums, this means that less than .007% of movements involved a reported Airprox. This number is so small as to be negligible and certainly doesn't justify a capital investment programme of this magnitude.
The CAA have not quantified their targets for Mode S safety improvments. There is no estimate of benefit. Will Mode S reduce the 299 down to 200? 150? 0? If they can't put a number to it, it means they really don't know.
The CAA's airprox statistics do not differentiate where GA was involved. Of the 299, how many involved the GA fleet where Mode S would have been a factor? They're basing their case on a very small number which they have not completely explained. This becomes an issue when looking at the projected growth of aviation in the next 20 years. If the current problem is not with GA, then the future problem is unlikely to be with GA.
Overall, the CAA have not made a case for Mode S either substantiating the need or quantifying the benefit. This is going to be the basis of my response to them.
Pitts2112
The total number of airproxes in an 18 month period (Jan 04 to Jun 05) was 299. Let's round that to 300 and take two-thirds to give us 200 per annum. Of those, only 150 or so would have benefited from Mode S/TCAS. Compare that to the CAA's own traffic statistics of total air movements of 3.8 million in 2005. Doing the sums, this means that less than .007% of movements involved a reported Airprox. This number is so small as to be negligible and certainly doesn't justify a capital investment programme of this magnitude.
The CAA have not quantified their targets for Mode S safety improvments. There is no estimate of benefit. Will Mode S reduce the 299 down to 200? 150? 0? If they can't put a number to it, it means they really don't know.
The CAA's airprox statistics do not differentiate where GA was involved. Of the 299, how many involved the GA fleet where Mode S would have been a factor? They're basing their case on a very small number which they have not completely explained. This becomes an issue when looking at the projected growth of aviation in the next 20 years. If the current problem is not with GA, then the future problem is unlikely to be with GA.
Overall, the CAA have not made a case for Mode S either substantiating the need or quantifying the benefit. This is going to be the basis of my response to them.
Pitts2112
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Doing the sums, this means that less than .007% of movements involved a reported Airprox
The problem with that line of argument is that it is like saying that 0.007% of children left alone with an adult get sexually molested, so paedophiles do no harm.
Or, since there has never been a GAT/CAT midair, one should be able to dismantle all controlled airspace. Clearly, the evidence does not support the need for CAS at all.
One needs to approach it differently. How many MPs and Lords are involved in this sport? That is the key to everything in the UK - or anywhere else for that matter. Write to them. Write to your MP. No use complaining to the CAA.
The proposal for paragliders to carry transponders (I haven't read it myself so taking the above poster's word for it) is comparable in barmy-ness to the one from the DfT (which uses the CAA as its consultant on just about everything) to kick out foreign-reg planes out of the UK after a parking period of 90 days.
The problem with that line of argument is that it is like saying that 0.007% of children left alone with an adult get sexually molested, so paedophiles do no harm.
Or, since there has never been a GAT/CAT midair, one should be able to dismantle all controlled airspace. Clearly, the evidence does not support the need for CAS at all.
One needs to approach it differently. How many MPs and Lords are involved in this sport? That is the key to everything in the UK - or anywhere else for that matter. Write to them. Write to your MP. No use complaining to the CAA.
The proposal for paragliders to carry transponders (I haven't read it myself so taking the above poster's word for it) is comparable in barmy-ness to the one from the DfT (which uses the CAA as its consultant on just about everything) to kick out foreign-reg planes out of the UK after a parking period of 90 days.
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Originally Posted by IO540
[I]One needs to approach it differently. How many MPs and Lords are involved in this sport? That is the key to everything in the UK - or anywhere else for that matter. Write to them. Write to your MP. No use complaining to the CAA.
.
.
Unfortunately, though, there are signs that the Committee has swallowed the CAA's line that they are better placed to regulate than EASA and so are holding on to some of their old territory
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Originally Posted by IO540
Doing the sums, this means that less than .007% of movements involved a reported Airprox
The problem with that line of argument is that it is like saying that 0.007%
One needs to approach it differently. How many MPs and Lords are involved in this sport? That is the key to everything in the UK - or anywhere else for that matter. Write to them. Write to your MP. No use complaining to the CAA.
The problem with that line of argument is that it is like saying that 0.007%
One needs to approach it differently. How many MPs and Lords are involved in this sport? That is the key to everything in the UK - or anywhere else for that matter. Write to them. Write to your MP. No use complaining to the CAA.
The CAA need to come to the realisation that, while 0 Airproxes (even reduced) is a good goal, this proposal is not going to achieve it.
On the MP issue, that's a particularly good one. Does anyone know what stance Lembit Opik has taken? I've had no luck getting on to his website or anyone to answer the phone.
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Someone in our flying club has emailed Lembit Opik & he has undertaken to ask parliamentary questions.
For those who don't know, Mr Opik is a lapsed PG pilot. I believe he lapsed after flying consderably closer to the edge of the sky than is recommended, but it appears he retains an interest in gliding matters.
For those who don't know, Mr Opik is a lapsed PG pilot. I believe he lapsed after flying consderably closer to the edge of the sky than is recommended, but it appears he retains an interest in gliding matters.
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That document looks like it was once used to justify Mode S for airline use. Fair enough. What they appear to have done is decided it's time to force it on the rest of the world, and added a load of stuff about Airproxes (used over 60 times but not defined once).
Take out all the legitimate stuff for airlines and Mode S and there is nothing left of substance except the possible need for GA to have mode C near busy airports. They said you only needed Mode C too, not Mode S
Take out all the legitimate stuff for airlines and Mode S and there is nothing left of substance except the possible need for GA to have mode C near busy airports. They said you only needed Mode C too, not Mode S
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Originally Posted by slim_slag
That document looks like it was once used to justify Mode S for airline use. Fair enough. What they appear to have done is decided it's time to force it on the rest of the world, and added a load of stuff about Airproxes (used over 60 times but not defined once).
Take out all the legitimate stuff for airlines and Mode S and there is nothing left of substance except the possible need for GA to have mode C near busy airports. They said you only needed Mode C too, not Mode S
Take out all the legitimate stuff for airlines and Mode S and there is nothing left of substance except the possible need for GA to have mode C near busy airports. They said you only needed Mode C too, not Mode S
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The CAA have already come to their conclusions.
Section 2.2.2 gives the alternatives.
These alternatives need to be described in greater detail and people given the ability to comment on them. The restrict traffic growth is obviously directed at the airlines, and they already have to use Mode S, so it's a stupid thing to say in this document.
What restrictive airspace measures would be required? That sounds like a threat to me, do this or else. They need to describe those changes as most GA people might not give a damn. People in the SE could install Mode C as the document suggests, the quid pro quo being a massive reduction in controlled airspace as there is no need for the ridiculous buffer zones around places like LHR and STN. Decreasing the amount of 'positively controlled' airspace would remove VFR choke points so satisfying their own objectives stated in para 1, which is to reduce airproxes.
Section 2.2.2 gives the alternatives.
If this technical interoperability is not put in place, the alternatives are to either segregate non-compatible users through restrictive airspace measures or to restrict traffic growth.
What restrictive airspace measures would be required? That sounds like a threat to me, do this or else. They need to describe those changes as most GA people might not give a damn. People in the SE could install Mode C as the document suggests, the quid pro quo being a massive reduction in controlled airspace as there is no need for the ridiculous buffer zones around places like LHR and STN. Decreasing the amount of 'positively controlled' airspace would remove VFR choke points so satisfying their own objectives stated in para 1, which is to reduce airproxes.
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Originally Posted by slim_slag
What restrictive airspace measures would be required? That sounds like a threat to me, do this or else. .
People in the SE could install Mode C as the document suggests, the quid pro quo being a massive reduction in controlled airspace as there is no need for the ridiculous buffer zones around places like LHR and STN. Decreasing the amount of 'positively controlled' airspace would remove VFR choke points so satisfying their own objectives stated in para 1, which is to reduce airproxes.
Pitts2112
Last edited by Pitts2112; 16th Aug 2006 at 16:22.
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You need to remove the forward slash from the first quote tag. Will read the document again, but the more I think about it the more I think it's a piece of well structured BS.
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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.
Annoyance coming from the Prime Ministers Office will get far more attention in the CAA offices, than annoyance coming from a load of GA pilots.
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I don't see a problem with mandating Mode C/S in normal spamcans etc (much as this will annoy lots of people, but I've already given my reasons for this) but this business of mandating it much wider, to the "flying machines" that can barely install it or power it, suggests that the person who wrote this is the same clueless person who wrote the "Kick out N-reg" proposal.
I sometimes wonder if these people are hand picked to do a "hatchet job".
I sometimes wonder if these people are hand picked to do a "hatchet job".
Precisely the point I made in my response to them a month or so ago, Dublin Pilot.
They can't argue with the 27,212 fleet size figure, as it's their own data, taken from the most recent GA review. They can't argue about the £1500 unit cost figure either, as that is the advertised price, including VAT, of the only available portable transponder, fixed units are slightly more expensive.
A quick, and extremely conservative, estimate of the absolute minimum real cost to the UK very light recreational fleet is:
Transponder purchase costs for the light recreational aircraft fleet that doesn't currently have a Mode S transponder fitted (about 60% of the total UK aircraft fleet, and includes most of the PFA fleet, all of the BMAA fleet, all foot launched aircraft, 90% of the balloon fleet and 80% of the glider fleet) = 16,260 x £1500 = £24.39M
Modification design and approval costs for approx 6,500 Permit to Fly aircraft and gliders (assuming about half the PFA fleet already have transponders of some sort fitted, around 500 gliders have them fitted and none of the BMAA fleet have them fitted) = 6,500 x £100 (a very conservative figure) = £0.65M
Initial installation, inspection and licence cost for 4,500 Permit to fly aircraft and gliders, at approximately £200 per aircraft (again, a conservative estimate) = £1.3M
Inspection and licensing costs for the 26% of the UK fleet that is deregulated, (around 7,000 aircraft, including hang gliders, paragliders, powered hang gliders and paramotors) = 7,000 x £200 = £1.4M
This gives a lowest possible cost, excluding the fitting of new wiring looms or antennas to affected aircraft, of £27.74M, just for the very light recreational fleet, excluding all the flying club SEPs, all the light twins, all rotorcraft and the historic and vintage fleet. Assuming that half of these aircraft need to have new transponders fitted will add another £7.8M to this, which increases the grand total to £35.5M.
Someone at the CAA has been unbelievably creative with the accounting on this, which either indicate incompetence on their part, or a deliberate attempt to circumvent the due process of government. If it's the latter, then, as a agency of the DfT they are in breach of their terms of reference, I suspect.
VP
They can't argue with the 27,212 fleet size figure, as it's their own data, taken from the most recent GA review. They can't argue about the £1500 unit cost figure either, as that is the advertised price, including VAT, of the only available portable transponder, fixed units are slightly more expensive.
A quick, and extremely conservative, estimate of the absolute minimum real cost to the UK very light recreational fleet is:
Transponder purchase costs for the light recreational aircraft fleet that doesn't currently have a Mode S transponder fitted (about 60% of the total UK aircraft fleet, and includes most of the PFA fleet, all of the BMAA fleet, all foot launched aircraft, 90% of the balloon fleet and 80% of the glider fleet) = 16,260 x £1500 = £24.39M
Modification design and approval costs for approx 6,500 Permit to Fly aircraft and gliders (assuming about half the PFA fleet already have transponders of some sort fitted, around 500 gliders have them fitted and none of the BMAA fleet have them fitted) = 6,500 x £100 (a very conservative figure) = £0.65M
Initial installation, inspection and licence cost for 4,500 Permit to fly aircraft and gliders, at approximately £200 per aircraft (again, a conservative estimate) = £1.3M
Inspection and licensing costs for the 26% of the UK fleet that is deregulated, (around 7,000 aircraft, including hang gliders, paragliders, powered hang gliders and paramotors) = 7,000 x £200 = £1.4M
This gives a lowest possible cost, excluding the fitting of new wiring looms or antennas to affected aircraft, of £27.74M, just for the very light recreational fleet, excluding all the flying club SEPs, all the light twins, all rotorcraft and the historic and vintage fleet. Assuming that half of these aircraft need to have new transponders fitted will add another £7.8M to this, which increases the grand total to £35.5M.
Someone at the CAA has been unbelievably creative with the accounting on this, which either indicate incompetence on their part, or a deliberate attempt to circumvent the due process of government. If it's the latter, then, as a agency of the DfT they are in breach of their terms of reference, I suspect.
VP
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I think they are building into their calculations discounted prices, based on the fact that many owners will choose to go for the low cost version, when available
They are quite adamant that they are loking for a low cost product of between £500 and £1000, although there is no sign there is a manufacturer willing and able to do it for that sort of price
I've written to my MP on this and the chair of the Transport Select Committee, as I feel this is open to review. They already acknowledge uncertainty in costs, but still want to implement, and are bodging the figures to suit
They are quite adamant that they are loking for a low cost product of between £500 and £1000, although there is no sign there is a manufacturer willing and able to do it for that sort of price
I've written to my MP on this and the chair of the Transport Select Committee, as I feel this is open to review. They already acknowledge uncertainty in costs, but still want to implement, and are bodging the figures to suit
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Folks,
Another though occurred to me today. Reading the RIA, the underlying message has nothing to do with Mode S, per se. The underlying problem is how to effectively provide safe separation of all the different types of users in the complex airspace of the UK, especially in the context of the projected growth in Commerical Air Transport demand (2-3x by 2030).
Mode S is a classic case of presentation of someone's solution rather than discussion of the problem. Anyone who's ever managed a project or tried to spec an IT system for a client will recognise the symptoms.
I think an effective alternative to Mode S for private aviation would be an open discussion with the representative bodies to address the real separation problem as a wider community so each can express their concerns and put their own ideas on the table, sort of a self-regulation approach, under the control of the DfT or CAA. It would have to be genuine debate and produce results, but my experience in doing this is you get a much stronger solution than by one organisation thinking it knows best for all. You also get much more creative solutions that the one organisation probably couldn't have achieved on their own.
I'm thinking that this proposal to MPs, the CAA, and the DfT, in concert with a robust response to the RIA, may have some mileage. Details need to be fleshed out of course, but this is my thinking so far.
Your thoughts?
Pitts2112
Another though occurred to me today. Reading the RIA, the underlying message has nothing to do with Mode S, per se. The underlying problem is how to effectively provide safe separation of all the different types of users in the complex airspace of the UK, especially in the context of the projected growth in Commerical Air Transport demand (2-3x by 2030).
Mode S is a classic case of presentation of someone's solution rather than discussion of the problem. Anyone who's ever managed a project or tried to spec an IT system for a client will recognise the symptoms.
I think an effective alternative to Mode S for private aviation would be an open discussion with the representative bodies to address the real separation problem as a wider community so each can express their concerns and put their own ideas on the table, sort of a self-regulation approach, under the control of the DfT or CAA. It would have to be genuine debate and produce results, but my experience in doing this is you get a much stronger solution than by one organisation thinking it knows best for all. You also get much more creative solutions that the one organisation probably couldn't have achieved on their own.
I'm thinking that this proposal to MPs, the CAA, and the DfT, in concert with a robust response to the RIA, may have some mileage. Details need to be fleshed out of course, but this is my thinking so far.
Your thoughts?
Pitts2112
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... grrrrrrrrrrrrrrrrr
IO540 wrote .....
Well IO540, as much as I agree with you on many issues, on this I bloody disagree. Do you have a vested interest in fitting or selling avionics ? 
By any chance is your flying, generally IFR long transits, at the 'expensive' end of single engine GA ? Are you always in and out of controlled airspace ?
IMHO
It WILL NOT improve safety, in fact, speaking as an ATCO, I am convinced it will clutter many many radar screens and potentially max out a lot of sectors.
It will NOT create a known traffic environment as it is not mandated for the military.
In areas with hills, valleys and poor radar cover (eg Scotland and Wales, which makes up 50% of the UK landmass) please explain which radar will see my mode S return. In fact please explain which RT transmitter will enable me to speak to anyone below 3000.
Do you have any idea how many aircraft operate outside controlled airspace at the moment without transponders ? It is sad, but I think many many ATCOs are really quite ignorant of how much flying actually goes on outside controlled airspace. And I speak from experience. I have detected a growing feeling (particularly since ATC privatisation) that anything other than 737s are just not important, and are only 'spamcans' or people with limited RT having 'fun', and therefore not worthy of attention. A bad bad bad attitude that ATC units do little to counter.
I use the example again of last months Strathallan flyin. 78 aircraft departed in 30 minutes. Most just went on their way. Now, if we all have to fit Mode S (for someone elses perceived commercial benefit) don't we then have a right to demand and expect a service for having been forced to comply .... ?
I guarantee that any radar unit would be unable to cope with 78 aircraft calling in that timescale. You couldn't even do simple RT let alone pass traffic info, and if you can't pass traffic info .. then what is the ####ing point of Mode S in the first place ? Unless it is purely to benefit the locos that want to cut corners outside controlled airspace and operate into small regional airports..... but these are often through areas of intense mil activity ... where the mil errr..... dont have to fit Mode S.
Doesn't seem logical to me.
Fitting Mode S is effectively a tax, and a bloody ineffective and expensive one too.
No tax without representation.... no there's a catchy slogan ....
I don't see a problem with mandating Mode C/S in normal spamcans etc (much as this will annoy lots of people, but I've already given my reasons for this)
By any chance is your flying, generally IFR long transits, at the 'expensive' end of single engine GA ? Are you always in and out of controlled airspace ?
IMHO
It WILL NOT improve safety, in fact, speaking as an ATCO, I am convinced it will clutter many many radar screens and potentially max out a lot of sectors.
It will NOT create a known traffic environment as it is not mandated for the military.
In areas with hills, valleys and poor radar cover (eg Scotland and Wales, which makes up 50% of the UK landmass) please explain which radar will see my mode S return. In fact please explain which RT transmitter will enable me to speak to anyone below 3000.
Do you have any idea how many aircraft operate outside controlled airspace at the moment without transponders ? It is sad, but I think many many ATCOs are really quite ignorant of how much flying actually goes on outside controlled airspace. And I speak from experience. I have detected a growing feeling (particularly since ATC privatisation) that anything other than 737s are just not important, and are only 'spamcans' or people with limited RT having 'fun', and therefore not worthy of attention. A bad bad bad attitude that ATC units do little to counter.
I use the example again of last months Strathallan flyin. 78 aircraft departed in 30 minutes. Most just went on their way. Now, if we all have to fit Mode S (for someone elses perceived commercial benefit) don't we then have a right to demand and expect a service for having been forced to comply .... ?
I guarantee that any radar unit would be unable to cope with 78 aircraft calling in that timescale. You couldn't even do simple RT let alone pass traffic info, and if you can't pass traffic info .. then what is the ####ing point of Mode S in the first place ? Unless it is purely to benefit the locos that want to cut corners outside controlled airspace and operate into small regional airports..... but these are often through areas of intense mil activity ... where the mil errr..... dont have to fit Mode S.
Doesn't seem logical to me.
Fitting Mode S is effectively a tax, and a bloody ineffective and expensive one too.
No tax without representation.... no there's a catchy slogan ....
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Originally Posted by Aunt Rimmer
IO540 wrote .....
No tax without representation.... no there's a catchy slogan ....
No tax without representation.... no there's a catchy slogan ....
Pitts2112
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Pitts,
My thoughts fwiw are that you've hit on the ideal course of action - I can report that our lot are lobbying for exactly that, exemption underpinned by dialogue & debate, as we have done with each and every previous issue that has threatened our continued existence - ultimately, we have a strong track record of self governance & we hope that that will prevail in our case. Nothing's guaranteed though & I'm heartened by many of the opinions I've read on here.
My thoughts fwiw are that you've hit on the ideal course of action - I can report that our lot are lobbying for exactly that, exemption underpinned by dialogue & debate, as we have done with each and every previous issue that has threatened our continued existence - ultimately, we have a strong track record of self governance & we hope that that will prevail in our case. Nothing's guaranteed though & I'm heartened by many of the opinions I've read on here.
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Well IO540, as much as I agree with you on many issues, on this I bloody disagree. Do you have a vested interest in fitting or selling avionics ?
By any chance is your flying, generally IFR long transits, at the 'expensive' end of single engine GA ? Are you always in and out of controlled airspace ?
No vested interest other than flying with an RIS (when I can get it) and I would like fewer "level unknown" traffic reports. I would imagine that you as an ATCO would also prefer to know the height of the return(s) when providing a radar service. You will know perfectly well that providing a pilot at FL50 with an RIS, and telling him - as the rules require you to - about every "level unknown" return doing about 70kt is probably a waste of his time and your time. It is highly likely that the return is much lower down.... but not certain. If everybody had Mode C/S then the most of the RIS radio traffic would go. To be fair, this won't happen because Mode S is unlikely to be mandated for many very slow or lightweight machines (simply because it's impractical) so these will still be around but I am sure your workload will still go way down.
Don't forget that a lot of people do have transponders and don't use them deliberately.
I do fly IFR across Europe too but that is generally under radar control and most of it is in CAS, where the problem doesn't arise, and anyway very few non transponding planes will be at FL100+. In fact there is close to zero GA at those levels.
I don't see a connection between having a working transponder, and working an ATC unit on the radio. It's immediately obvious that if everybody called up e.g. London Info, doing exactly what they were taught in their PPL, the service would collapse. A radar service with too many targets should not collapse; with Mode S you can turn off those that are at low level and nowhere near CAS. Those (much fewer, one hopes) that are busting CAS, or look like they are about to, you will want to turn back on
By any chance is your flying, generally IFR long transits, at the 'expensive' end of single engine GA ? Are you always in and out of controlled airspace ?
No vested interest other than flying with an RIS (when I can get it) and I would like fewer "level unknown" traffic reports. I would imagine that you as an ATCO would also prefer to know the height of the return(s) when providing a radar service. You will know perfectly well that providing a pilot at FL50 with an RIS, and telling him - as the rules require you to - about every "level unknown" return doing about 70kt is probably a waste of his time and your time. It is highly likely that the return is much lower down.... but not certain. If everybody had Mode C/S then the most of the RIS radio traffic would go. To be fair, this won't happen because Mode S is unlikely to be mandated for many very slow or lightweight machines (simply because it's impractical) so these will still be around but I am sure your workload will still go way down.
Don't forget that a lot of people do have transponders and don't use them deliberately.
I do fly IFR across Europe too but that is generally under radar control and most of it is in CAS, where the problem doesn't arise, and anyway very few non transponding planes will be at FL100+. In fact there is close to zero GA at those levels.
I don't see a connection between having a working transponder, and working an ATC unit on the radio. It's immediately obvious that if everybody called up e.g. London Info, doing exactly what they were taught in their PPL, the service would collapse. A radar service with too many targets should not collapse; with Mode S you can turn off those that are at low level and nowhere near CAS. Those (much fewer, one hopes) that are busting CAS, or look like they are about to, you will want to turn back on
Last edited by IO540; 17th Aug 2006 at 09:18.
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Well, there is so much BS in their draft document it's hard to know where to start. They are playing the safety card in their objectives, and obviously hoping nobody will notice that only a small part of the following 65 pages is relevant to this objective. Aimed at our elected representatives, and not people who might know a bit about the subject. On reading the document it is easy to lose the will to live, and I am sure they are relying on that too.
First, it's a Partial RIA, how can anybody comment on an incomplete document? so what are they hiding for the final edition? I still think the document was initially written to justify the use of Mode S for airlines, they have now stuck a bit on the front to force it onto GA under the guise of 'safety'.
SO the objective is stated in 2.1.1
and the issues they have identified are in 2.2.5 to 2.2.12 inclusive.
Issue 2 (2.2.6) is the only issue that appears to be relevant to GA. Force the airlines to carry mode S (already done) and the other important issues are solved. The other minor issues are fluff. For issue two, they are hanging their hat on reported Airprox figures. These are incredibly subjective, the vast majority are found on investigation to be no risk to fligt. We could manipulate the figures by putting a request on PPrune to either report anything or nothing for six months.
(a) Putting Mode S in spamcans will do nothing to alter GA on GA collision risk. You need some TCAS device to do this, and that is not mandated and I doubt it ever will be as the goal is simply to force all users to carry mode s. If this is forced through it will only be for the benefit of airlines who decide to enter class G so they save money, so those gaining the benefit (the airlines) should pay.
(b) Airspace infringements. Yep, worth discussing and everybody would like to see these reduced. I'd say most airspace infringements are due to complex and excessive airspace, the design of airspace in the SE is a complete mess.
They appear to accept my argument. 4.7.3
So a corresponding reduction in this controlled airspace should reduce the number of infringements. How to do this?
I go back to my Mode C veil. LHR is the only significantly large airport in the UK and a mode C veil would pretty much cover this and the satellite airports like LGW and LTN. Give LHR a 30 nm mode c veil, reduce surface area as aircraft would now be squaking altitude so ATC would indeed have decent knowledge of position and intentions. LGW, LTN, STN to have 5nm radius surface areas and there is a huge amount of airspace freed up for everybody. Choke points removed so airproxes down. Objective one satisfied. Draw a 30nm veil on the southern england chart and it doesn't really get in the way, people without transponders will have to fly around it, but that is a price one pays. The airlines/ATC/CAA will benefit most from reduction in infringements, so using the principle of the person who gains the most pays the most, they should pay.
It will never happen
(c) Regional airports. The figures tell the story, these are not very busy at all. 5 mile radius surface areas should be plenty. Works in the US with smaller surface areas. The recent airspace grab at Bristol shows the CAA have no intention of using mode S to reduce controlled airspace. They want Mode S and increased airspace, if mode S was going to introduce efficiencies they would not have done what they did at BRS.
(d) Gliders. Just another airspace user, to include them is BS fluff.
(e) TCAS in GA. Well, if we want it, let us pay for it. NO need to mandate - er it isn't, so why bring it up?
(f) MOD. Well, they aren't being made to do anything and probably wont, so why bring it up? BS.
Rest of the document is full of 'may', 'possibly', 'could'. All BS assumptions, better left out of a serious document which will cost GA tens of millions, but on speed reading it looks good and I guess that is what they are hoping will happen.
The cost part of the equation has been covered by others. Sounds like the CAA are BS there too, wouldn't surprise me reading the rest of the document.
They need to detail the alternatives they have rejected out of hand. ALso need to detail the alternatives threatened in 2.2.2
Haven't time to proof read this, just random thoughts and rantings. The CAA want to do it so they can see where we are, and not for safety reasons. The airlines may have a safety interest, but they really want to see us so they can cut corners and save money (or later charge us for using 'their' airspace), so if it goes through they should pay.
First, it's a Partial RIA, how can anybody comment on an incomplete document? so what are they hiding for the final edition? I still think the document was initially written to justify the use of Mode S for airlines, they have now stuck a bit on the front to force it onto GA under the guise of 'safety'.
SO the objective is stated in 2.1.1
The objective of this proposal is to make a significant contribution towards ensuring that the number of mid-air collisions and serious risk-bearing ‘near-miss’ incidents in UK airspace does not increase and, preferably, decreases as the level of air traffic grows
Issue 2 (2.2.6) is the only issue that appears to be relevant to GA. Force the airlines to carry mode S (already done) and the other important issues are solved. The other minor issues are fluff. For issue two, they are hanging their hat on reported Airprox figures. These are incredibly subjective, the vast majority are found on investigation to be no risk to fligt. We could manipulate the figures by putting a request on PPrune to either report anything or nothing for six months.
(a) Putting Mode S in spamcans will do nothing to alter GA on GA collision risk. You need some TCAS device to do this, and that is not mandated and I doubt it ever will be as the goal is simply to force all users to carry mode s. If this is forced through it will only be for the benefit of airlines who decide to enter class G so they save money, so those gaining the benefit (the airlines) should pay.
(b) Airspace infringements. Yep, worth discussing and everybody would like to see these reduced. I'd say most airspace infringements are due to complex and excessive airspace, the design of airspace in the SE is a complete mess.
They appear to accept my argument. 4.7.3
it is highly likely that the number of airspace infringements would increase above current levels if more UK airspace was converted into controlled or restricted access airspace.
I go back to my Mode C veil. LHR is the only significantly large airport in the UK and a mode C veil would pretty much cover this and the satellite airports like LGW and LTN. Give LHR a 30 nm mode c veil, reduce surface area as aircraft would now be squaking altitude so ATC would indeed have decent knowledge of position and intentions. LGW, LTN, STN to have 5nm radius surface areas and there is a huge amount of airspace freed up for everybody. Choke points removed so airproxes down. Objective one satisfied. Draw a 30nm veil on the southern england chart and it doesn't really get in the way, people without transponders will have to fly around it, but that is a price one pays. The airlines/ATC/CAA will benefit most from reduction in infringements, so using the principle of the person who gains the most pays the most, they should pay.
It will never happen
(c) Regional airports. The figures tell the story, these are not very busy at all. 5 mile radius surface areas should be plenty. Works in the US with smaller surface areas. The recent airspace grab at Bristol shows the CAA have no intention of using mode S to reduce controlled airspace. They want Mode S and increased airspace, if mode S was going to introduce efficiencies they would not have done what they did at BRS.
(d) Gliders. Just another airspace user, to include them is BS fluff.
(e) TCAS in GA. Well, if we want it, let us pay for it. NO need to mandate - er it isn't, so why bring it up?
(f) MOD. Well, they aren't being made to do anything and probably wont, so why bring it up? BS.
Rest of the document is full of 'may', 'possibly', 'could'. All BS assumptions, better left out of a serious document which will cost GA tens of millions, but on speed reading it looks good and I guess that is what they are hoping will happen.
The cost part of the equation has been covered by others. Sounds like the CAA are BS there too, wouldn't surprise me reading the rest of the document.
They need to detail the alternatives they have rejected out of hand. ALso need to detail the alternatives threatened in 2.2.2
Haven't time to proof read this, just random thoughts and rantings. The CAA want to do it so they can see where we are, and not for safety reasons. The airlines may have a safety interest, but they really want to see us so they can cut corners and save money (or later charge us for using 'their' airspace), so if it goes through they should pay.