Proposed amendment of the ANO: Mode S

[tmmorris]

Yes, that seems a good compromise, though I was happy with the status quo ante...

Good luck.

Tim

---

[per pretiosissima ad astra, these days]

[Aunt Rimmer]

... VFR in Class D - I beg to disagree ...

Well, I still don't see why VFR in Class D should require Mode A, S or C.
At the moment Mode A/C is not mandated unless you are above FL100 and in Class A+B ( I think).
I operate out of a Class D airport, generally on VFR standard entry/exit lanes .... wait for it ..... WITHOUT A TRANSPONDER. The aircraft is placarded as VFR only anyway as it only has a Class 2 VOR.
Now, I know most of the ATCOs, I even trained some of them in a past life , and despite the banter (ooh the banter ), I don't think my transponderlessness (copyright that one I think ) has caused any problems whatsoever.
I still need ATC clearance, but sounding (and acting) like a sensible chap and having a good relationship with my friendly ATC provider, they know I ain't going to them about.
Why should I have to have Mode S when for eg. French Eurostars or RAF Tornadoes apparently don't have to? The only difference in ops is that I'm a bit faster and carry 4 pob.
Where is the logic ? Likewise, how is anyone going to know if the height readout is actually correct ? At the moment I have to verify the mode C of EVERY aircraft that I ident. How will anyone know if I have switched it off, or if it is u/s ? Particularly if I am operating out of a field outside CAS when I won't be speaking to anyone. Or even ... flying amongst the hills below radar and radio cover. Who will even see me ? or hear me ?
Once again it would seem that the over-crowded situation in the London area leads to faceless bureaucrats dictating kneejerk measures that are inappropriate outside the flatlands of the SouthEast.
I could go on .... and I will .....but the FM Immune farce was another case. Somebody elses commercial gain (radio stations), paid for by GA having to shelve out £2000 per radio for an upgrade. Same really as GA being squeezed out of regional airports for precious runway slots. Someone elses (RYR, EZY, FlyBe, BAW) commercial gain, GA gets the heave ho.
I thought part of the CAA Pension Funds remit was to support GA, not continually it over with extra costs and diktats. Oh silly me.
Anyway, Beagle, I respectfully amend your suggestion to <edit> also exempt VFR traffic operating in Class D from carrying Mode S, especially if they have a nice paintjob <end.edit>.

PS Anyone planning on going to Barton next week for the CAA 'Open Consultation' ?

[BEagle]

You mean you don't want to fly under VFR in Class D? That seems a bit daft to me.

We need to give something, otherwise Mode S will be mandatory even under VFR in Class G.

Hence my suggestion.

I agree about the FM immunity nonsense - it cost us £17500 to sort out 4 x PA28s.... Yet in the USA with squillions of FM broadcasting stations, there is no such requirement.

[Aunt Rimmer]

PS

Now, I am wading my way through the RIA document, with all it's shpeel about safety safety safety .....

Couple of things spring to mind. ....

CAA continually bang on about increased safety and wanting to reduce regulated airspace ..

So here's a couple of scenarios ....

Scenario 1
OK, I fit Mode S.

Johnny Tornado is exempt and doesn't have to - Johnny Tornado hammers around low-level, then zoom climbs through an advisory route from low level (pops up from below radar cover) causing men, women and children to be flung about in the back of an EZY737 (mode S and ACAS equipped) dropping into Inversneckie. Johnny Tornado (oblivious to the mayhem) then descends low level hammers round a couple of valleys and smacks into me (below radio and radar cover) just as I take off from Loch Tay.

Did Mode S make my flight safer ?
Did it make the 737s flight safer ?
Did it make the Tornadoes flight safer ?
Am I pissed off ?

Scenario 2
OK, I fit mode S. Johnny Tornado fits mode S and ACAS.
Same sortie - perhaps Johnny Tornado is now aware of the EZY737 ?
Perhaps JT is now aware of me coming round the corner ?
Perhaps we don't die, and save the £6m cost of loss of planes and life.
Then I can begin to see a benefit.

Scenario 3
Regional Airport near Glasgow with a large Class D Zone extending from surface all the way up to FL245. But IFR traffic into said airport cannit be descended under radar below 3000' unless within the final approach area. So, why not release that huge chunk of airspace below say 2500' outside of the final approach to VFR aircraft with Mode S ?

Scenario 4
The Highlands Restricted Area. Some of the most stunning landscape, (comprising about 50% of the area of the highlands), prohibited to light aircraft from 3pm, 4 days a week, because of military low flying (despite the fact that more low-flying actually goes on outside the HRA). This holds back any development of aircraft touring round Scotland.

But, if all military were to carry ACAS and Mode S, and if I was to too .... then why not open it up and allow free access .... ?

If I genuinely believed that this was not just some one way process to over control and over regulate for the sake of it, I would say yes.

But if the benefits are what the CAA say, then they should be willing to fund this for those benefits alone. The cost of a mid-air might be saved instantly.

[Flying Lawyer]

Report on a meeting held by the CAA on 15 August concerning the
“Proposal to amend the Air Navigation Order 2005 for the purpose of improving the technical interoperability of all aircraft in UK airspace”.

By Peter Saundby, Vice President, Royal Aero Club.
With advice from Tom Hardie, Peter Hearne and Ian Strachan.

This meeting was held in the Civil Aviation Authority, Kingsway, London, on Tuesday 15 August 2006. It was attended by some 28 persons, all the major Associations and AOPA being represented.

Tom Hardie who is tasked with the GA Alliance response was present together with Peter Hearne and Ian Strachan representing the BGA but equally concerned with other recreational aviation interests.

The meeting was chaired by Andy Knill, the CAA Manager for ‘Surveillance and Spectrum Management’ he has had a distinguished career in the development of secondary radar. He was supported by Andy Greenwood and Sqn Ldr Max Seaman, both of whom have professional backgrounds as fighter controllers in the RAF. The initial presentation was given by Gp Cpt Wragg RAF, but he then excused himself and left the meeting. His professional background is in air traffic control.
Therefore a problem was that none of this CAA ‘expert’ team has had any serious flying experience and, as I have written elsewhere, the sky looks different when seen from a cockpit rather than the radar room of a control centre.

From the BHPA and BGA points of view, it became apparent that the CAA team knew little about soaring operations. There is a need for the CAA to accept data that will be needed for the relevant modelling that yet has to take place.

An outstanding feature of the day was the repeated exposure of internal contradictions. On the CAA web site the meeting was described as “a workshop in support of the proposal to amend the ANO”. It was certainly not a workshop because nothing was produced and not one of the visiting attendees ever spoke in support of the proposal.

We opened with a presentation by Gp Cpt Wragg, in which he stated that this proposal was the culmination of fourteen years work, that the objective was flight safety and that the intention was to listen. It was a proposal and open to consultation. However the ‘experts’ had considered and rejected other options and this became only too clear later in the meeting. He also assured the meeting that there was no intention of using the information on traffic for other purposes, presumably referring to past suspicions of charges for airspace use. He was keen for responses although time will tell whether his team will actually take any notice of these.

Andy Greenwood then showed some initial responses to the consultation document, there had been 850 individual responses, 28 small businesses and 1 large business. 80% supported voluntary equipage and 77% did not believe that there would be any safety benefit. Of the replies from small businesses, 75% expected losses and 25% would cease trading. His argument was that the case for universal transponders was a safety case and even implied that those who opposed were against safety!
From the audience it was repeatedly put that the safety case was for electronic visibility and not mode ‘S’ transponders, these being merely one potential solution and also not the one being progressed by the Federal Aviation Administration in the USA.

Most of the CAA presentation was in support of the concept of electronic visibility, that this would reduce the risk of collisions, facilitate traffic management, enable traffic growth and replace current obsolete systems. All this is uncontroversial and agreed by those present. However the only technical solution ordained by the CAA is the carriage of mode ‘S’ transponders. Therefore the real debate as to whether this is the optimum or the only technical solution never took place, indeed the Chairman ruled discussion out of order saying “that it would take three days of meetings to address this issue”.

It is apparent, and was even admitted by the CAA team, that ADS-B [broadcasting of position by the aircraft] will become the system for the future and therefore the CAA advocates the purchase of transponders with extended squitter. Consequently the purchase of any other transponder can only be an interim measure. There appears to be a determination by the CAA to avoid any expenditure involved in the immediate modification of infrastructure to accept ADS-B information while appearing to discount expenditure imposed upon others.

In what discussion did take place, it was pointed out that TCAS suffers limitations when used for pilot controlled collision avoidance because there is no vector information and this had been the subject of a warning by Eurocontrol. A transponder needs to be illuminated by radar before responding and this may not always be the case at low level. The possibility that a very large increase in airborne mode ‘S’ transponders might result in spurious TCAS warnings was discounted by the CAA team. However it was pointed out that in the development of military systems it had been found unwise to rely solely on modelling and that flight test verification is essential before final decisions are taken.

Discussion of international issues exposed further contradictions. It was stated that ICAO had mandated transponders although this is not true for those un-powered aircraft included in the CAA proposal. At one moment we were being told that ICAO was mandatory, the second that the CAA were encouraging the development of low output transponders that did not meet the ICAO specification. Accounts of developments in France and Germany did not match with information from elsewhere. This CAA proposal runs counter to the declared aims of the EASA Board to encourage technical innovation and the development of light aviation in Europe.

A reference to UAVs was equally inconclusive. The CAA envisages widespread civil and military use and the electronic visibility of all other airspace users could enable an avoidance system. However the same arguments exist as to how that visibility could be created. An important point made was that questions power supply and weight are as equally critical for UAVs as for recreational aviation. The question of radiological protection was only raised at the end. This is related to output power, but thermal considerations alone were considered. Interference with cardiac pacemakers and non-approved aircraft electronic equipment has not been explored. Indeed a delusion exists in the CAA that with EASA airworthiness approval, all instrumentation in gliders will become certified.

Much faith is being put by the CAA in the development of low powered low cost transponders, LAST and LPST. Prices were cited as low as under £1000. However these items, despite past efforts, have not yet been developed and we now have a chicken and egg situation. A representative from the company implied that they could not justify ‘bringing to market’ costs unless that market was assured. That leads to the position that future legislation may ‘require’ the fitting of equipment that does not yet exist. The Chairman ignored strong pleas from those representing organisations that no specification should be issued without consultation with those who would be compelled to use the equipment in the air.

There was limited discussion on possible hybrid systems, squitter transmissions passing information on aircraft position and vector based on internal GPS navigational systems. This was rejected by the Chairman who clearly did not believe the integrity and accuracy of current commercial [off the shelf] GPS systems despite evidence being offered to the contrary.

The BHPA protested that the CAA had not consulted on actual air space usage and that must be taken into account by the CAA. This case was supported by the BGA because the same point has been made at earlier GACC meetings. The CAA team agreed that they would now be prepared to examine such material. The BGA made the further point that the proposed change in the regulations would involve a prohibition on the ability of gliders to fly IMC in unregulated airspace. This change would be resisted because it had no sensible connection with transponder carriage and was entirely contrary to the concept of electronic visibility.

Individual exemptions from the ANO will be permitted on various grounds, and blanket exemptions will be permitted for certain in-service military aircraft. However these exemptions must detract from the concept of universal visibility and may prove difficult for the CAA to administer.

In summary this was most unsatisfactory meeting, although that was not unexpected. It is not obvious what motives are driving our CAA. The overt reasons do not appear adequate to explain what will become a major political and perhaps legal battle. Maybe the adverse financial and economic implications for general aviation are not appreciated. Certainly the meeting exposed a lack of knowledge by these CAA ‘experts’ of how recreational aviation operates and this ignorance cannot be dispelled by a few visits to Clubs, but needs honest and open cooperation between the CAA and the relevant associations.

They must understand our operations and we need to know the pressures driving their policies. The major reason cited was flight safety and the collision risk, yet few fatalities arise from this cause and the same expenditure on other measures would save far more lives. Even the majority of respondents have not accepted this particular flight safety case. Is our CAA concerned that that their responsibility for airspace management entails legal liabilities? It was stated that the increase of controlled air traffic drove their proposal, but this increase is in controlled air space while the proposal relates to unregulated airspace.
Another reason given was that the CAA has already spent fourteen years and it was time to move on, but the logic of this is not obvious. International considerations were treated selectively and only those that supported the CAA case were cited. Despite statements to the contrary, the decision to amend ANO has apparently been made and will be driven through. Actions speak louder than words.

While all agree that electronic visibility is desirable, there are obvious alternative and much better technical solutions to those advocated by the CAA. The FAA is leading with ADS-B and in aviation the Americans force the pace. At best the CAA proposals can only be an expensive interim solution. Adoption of ADS-B could solve the CAA problems of costs, radio spectrum congestion and windmills. The statement by the Chairman that there would always be civil radar for air traffic control was without supporting evidence. As was demonstrated at the meeting, ADS-B can be small light and low powered. A complete navigational pack for para-gliders weighing only 180 gms was exhibited and this could feed a low power transmitter.

The reason for this impasse between general aviation and the CAA is difficult to discern. Their attachment to obsolescent systems is inexplicable because the CAA employs well qualified individuals who must be aware of modern developments. However a point not addressed at this meeting is that there are pressures on the CAA for the use of small regional airfields by commercial air traffic. As reported by GASCO, the Guild of Air Traffic Control Officers recently expressed their concern that the expansion of traffic has outstripped the capability of the Air Traffic Services. They have proposed a change from the VFR ‘see and avoid’ to a ‘sense and avoid’ based on TCAS. Can this be a clue to a covert reason for the present activity by the CAA?

"It was certainly not a workshop because nothing was produced."

I like that one.

[Aunt Rimmer]

Beware Flames .......

both of whom have professional backgrounds as fighter controllers in the RAF

Well that IMHO says volumes.

It appears to me that the CAA is not being staffed by people with a working knowledge, sympathy or understanding of GA and small aeroplanes. Plenty of senior posts are now being occupied by ex-RAF FC's and ATC'rs who do not have the broad experience or civil licences associated with the areas they are now being asked to regulate. Nice cushy number - leave at 38/16 point with RAF pension straight into a nice desk job with lots of paperwork and a nice pension to boot ..... the difference is, in the RAF they might not be used to having their decisions challenged or scrutinised from below - however out in civvy street ... it is another matter .... I hope !! So get challenging !!

Professionally speaking, I have found FCs to have a stunning lack of understanding about civil ATC ops (never mind GA) - living in a darkened distorted world where everyone is a 'target' would lend itself nicely to the philosophy of overcontrol and over-surveillance that this RIA represents.

I'm sorry but I have no faith that their RAF experience is of any relevance to civil aviation and GA in particular. In fact the gung-ho 'they're all nobbers' attitude displayed by many ex-RAF CAA staffers to GA and PPLs is frankly depressing and a bloody disgrace - especially as it is these 'nobbers' who pay both their ing pensions.

I know there are a few exceptions, and yes I am generalising, but there are few dedicated flyers pissing into the CAA wind.

Ironically, FCs have been involved in two of my most recent airmisses. Ha ha ha. So here's a thought, why not make THEM fit a Mode S transponder ? I have applied for an EASA STC to show where they could be inserted .....

Their (the CAA) attachment to obsolescent systems is inexplicable ...

Perhaps it is just a product of a cold war mindset ?


I stand back and await the tirade ....................

[IO540]

Aunt Rimmer

they know I ain't going to them about.

Again taking the charitable position regarding the CAA's intentions (whether justified or not), the problem is that a large chunk of the product of the PPL training establishment do not fall in the same category...

Tudor Owen's post is pretty amazing but not suprising. A lot of people have been saying for years that the CAA is run by retired RAF navigators, who joined the CAA to preserve their pension rights, and back in the RAF they had no option other than a desk job (or no job) anyway. You only have to watch a certain CAA safety evening presenter to see the patronising attitude.

[slim_slag]

Well, FL, interesting post. They don't seem to know what the CAA are up to either.

When one reads some of the threads on here, then looks at AAIB reports, then looks back at threads on here, it seems that the airlines are doing what they want to and the CAA are a rubber stamp agency. I hate to be a conspiracy theorist, bu the only thing that really fits is the airlines deciding GA must use Mode S for their purposes, and the CAA are rubber stamping that decision too.

So if the people at that meeting are correct and this is going through no matter, is the only solution then a judicial review? Expensive stuff I would think. And I am sure judges doing these reviews are hyper-intelligent beings, I am sure they can be swayed by the regulator playing the safety card, and I bet that would be their gambit there too.

[IO540]

The cost of a JR is five figures and up.

The basis for it would be the failure to follow the statutory procedure, e.g. doing a proper consultation. Probably easy enough to show in this case.

[B Fraser]

A fascinating post FL, I was surprised to see that the Balloon fraternity were not represented by the BBAC.

Your average hot air machine is around 100,000 cubic feet of brightly coloured ripstop nylon above a highly visible "beacon" powered by LPG. All flights take place in reasonable to perfect visibility. Just how would a mode S transponder make a collision with a balloon less likely Perhaps the CAA think balloons are difficult to spot ?



The CAA - "We're not happy until you're not happy"

[Pitts2112]

Who holds the CAA accountable?

The more I'm thinking about this whole thing the more I'm becoming convinced that the CAA are going to do what they want to do, that they have already made their minds up and that this consultation is really no more than a sham. So to who are the CAA reportable that will ensure they follow a genuine consultation and take the views of those about to be regulated into account? I know that's not a real strength of this government anyway, but it seems that involvement by the government is about the only way to hold the CAA accountable.

It seems to me that MP involvement is the next stage. I've already mentioned this issue in an e-mail to my local MP and will be following up with a phone call next week. I'm not sure what he can do directly, but if he can point me in another direction, or ask a few key questions within the DfT, then maybe a little MP attention on the matter may help the CAA see there is another way to handle this.

The thing that's really frustrating is that, as a community, we're not unwilling to be regulated. We just seem to have very little say in how it happens. Having said that, the PFA, BGA, BMAA have quite a lot of devolved authority, so the idea is not completely foreign to them. Maybe that's something we can build on. At any rate, if a few MPs ask the questions, then it becomes an issue the CAA and DfT can't just sweep under the carpet.

Just my further .02 worth.

Pitts2112

[robin]

Originally Posted by slim_slag

Well, FL, interesting post. They don't seem to know what the CAA are up to either.
When one reads some of the threads on here, then looks at AAIB reports, then looks back at threads on here, it seems that the airlines are doing what they want to and the CAA are a rubber stamp agency. I hate to be a conspiracy theorist, bu the only thing that really fits is the airlines deciding GA must use Mode S for their purposes, and the CAA are rubber stamping that decision too.
So if the people at that meeting are correct and this is going through no matter, is the only solution then a judicial review? Expensive stuff I would think. And I am sure judges doing these reviews are hyper-intelligent beings, I am sure they can be swayed by the regulator playing the safety card, and I bet that would be their gambit there too.

Just back from FFF at Kemble, where I had the joy of talking to a member of the CAA who worked on the TCAS proposals.

When I mentioned the example of the collision quoted in the RIA as justifiying the mandating of Mode S he was horrified, as he has not seen an example of an incident reported through AAIB yet where Mode S would have made any difference. He promised to read through the document and look at the proposals where TCAS is quoted.

So if the CAA don't even talk to each other.....!!!!

[QDMQDMQDM]

A lot of people have been saying for years that the CAA is run by retired RAF navigators, who joined the CAA to preserve their pension rights, and back in the RAF they had no option other than a desk job (or no job) anyway. You only have to watch a certain CAA safety evening presenter to see the patronising attitude.

I couldn't believe it when I went to one. I am guessing it is the same bloke. He came to Devon to talk to a bunch of rag and tube aviators and he had absolutely no idea whatsoever about the world we operate in and, even worse, he didn't appear to give a toss about that fact either.

The Mode S thing is preposterous -- unelected officials gone berserk. Ask a bureaucrat and the answer is always more asinine regulation, whatever the question is.

Regulate first, think later, if at all.

QDM

[IO540]

Same man probably. The name escapes me.

I went to one of these a while ago. I asked him something about IFR, somebody in the audience hissed "you don't need IFR, you can go everywhere VFR" and he seemed happy with that. Then somebody (don't think it was me, but it could have been) mentioned the 3-letter dirty word ("G" "P" "S") and the audience started turning around and shaking their heads in disapproval... Much of the audience are a bunch of "groupies" who go there to get their logbooks stamped. I suppose, to be charitable, these things are aimed at very low hour pilots, which make up much of the UK PPL scene and probably much of the incident data.

So what we have here is one little bit of the CAA which is astonishingly backward, stuck in the goode olde world of WW2.

But we also have a very modern CAA, with intelligent people (e.g. some IR examiners) who know what GPS is, can even program a route into a GNS530, to whom for example BRNAV (which - triple INS equipped transport jets aside - is impractical outside the IFR approved GPS context) is everyday stuff, and who cannot possibly have these backward attitudes.

Then there is the bulk of the CAA which looks after jet transports and they are obviously pretty smart.

My own experience of dealing with the CAA is that the organisation contains a lot of very able individuals.

What amazes me is how these "factions" can co-exist in the same building, never mind generate any sort of coherent policy.

[Flying Lawyer]

B Fraser

The BBAC was represented through the Royal Aero Club, the national co-ordinating body for recreational flying in the UK. The national associations of all the principal air sports in the UK and are represented on the RAeC Council and Committees, including -
British Aerobatic Association
British Balloon & Airship Club
British Gliding Association
British Hang Gliding & Paragliding Association
British Microlight Aircraft Association
British Model Flying Association
British Parachute Association
British Precision Pilots Association
Formula Air Racing Association
Helicopter Club of Great Britain
Popular Flying Association
RAeC Records Racing & Rally Association
Historic Aircraft Association
PPL/IR Europe
Tiger Club

The RAeC is also the UK representative on Europe Air Sports, the body which co-ordinates responses to legislation and regulation affecting recreational flying within the EU and more widely throughout Europe.
The President of EAS, Sir John Allison, is a former RAF officer but (thankfully) he certainly isn’t the sort of RAF type described in some posts above.
He was a fighter pilot who retired as Air Chief Marshal of the Royal Air Force and Commander-in-Chief of Strike Command, but he’s no desk-pilot - he's one of us. Although best known for displaying Duxford warbirds and as a Shuttleworth pilot, he's always been and still is an active light aircraft owner/pilot.
An extract from a speech illustrates the marked difference between his approach and some others mentioned:

The recreational and sport pilots in powered aircraft, glider and hang glider pilots, the microlighters, the home-builders, the balloonists, the parachutists and the aero-modellers …………. are all too easily overlooked when the legislator reaches for his pen.
It is for all these sporting and recreational pilots and aviators that I take the opportunity to speak.

………. Too often it is forgotten that at the receiving end of all legislative changes are the hapless citizens real people leading real lives who have little interest in politics. They will accept reasonable, proportionate and necessary change, but otherwise they just want to get on and enjoy their recreation without undue interference. I am one of those.

Having regard to the large numbers of these ordinary citizens affected by changes to the aviation environment in Europe, I would caution legislators and politicians concerning the social and political health of the evolving European Union. Until recently, the citizens of Europe had experience only of the impact of national law on their pursuit of flying for sport and leisure. On the whole that experience was satisfactory. Nobody was unreasonably excluded by reason of disproportionate cost, excessive rules or by denial of access to airspace. However, almost all the changes, either already implemented or now in the pipeline, are adverse for the recreational pilot.

If new rules introduced by the institutions of the Union change the lives of its citizens for the worse, it can be no surprise if resistance to the entire European project is the outcome. I believe that is what is happening in my own country.

It is not persuasive to deploy the mantra of free movement across Europe as the primary justification. Many - especially the huge numbers who have no interest in flying far from their home airfield - would consider the price they are being invited to pay either in monetary terms or in reduction of freedoms is too high.

………. It is difficult to understand why, for recreational aircraft, we cannot just accept the existing airworthiness, maintenance and licensing regimes of all member states. These systems are already delivering an excellent level of third party safety so why move away from them?

I declare a bias because he's been a friend for many years, but IMHO he's just the sort of man we need fighting our corner of aviation.

[slim_slag]

So blame the Europeans, eh? Easy to do and popular with the masses. Problem with that is the RIA doesn't say Europe is behind this, in fact it says European regulations are nothing to do with this at all. Section 2.2.7 (c) talks about the Single European Skies initiative. sorry to quote it all, my bolding.

Under the SES initiative, mandates are being issued to EUROCONTROL by the European Commission to develop interoperability implementing rules on SSR Mode S Interrogator Code Allocation for radars and on Surveillance Performance requirements. However, these will not legislate for the carriage and operation of SSR transponders on aircraft, and appropriate mandates in this regard are not currently being muted. The SES initiative is still somewhat embryonic and the work programme has to be prioritised within available resources. Indeed, the initial SES rules are likely to just support existing programmes and projects. The UK policy proposal contained within this Regulatory Impact Assessment (RIA) is, therefore, complementary to foreseen future SES requirements for SSR transponder carriage. In any case, mandating the carriage and operation of SSR Mode S in UK airspace from 31 March 2008, ahead of any potential European legislation, is essential because of national concerns. These concerns are elaborated throughout this RIA but centre on the need to introduce measures that sustain or improve levels of safety in a joint and integrated UK airspace, while managing the increasing complexity of this airspace and the increasing density of air traffic using it.

Was going through this, and really should have bolded the whole lot. According to the CAA document, the "Europeans" have nothing to do with mandating the carriage of Mode S whatsoever. Sorry, but it appears the driving force behind this is coming from elsewhere.

[Lucy Lastic]

It sure is.

Looks to me as though the CAA hoped to have slipped this one in under everyone's radar, so to speak.

Unfortunately for them, like a 4 year-old caught fiddling, they are denying everything ("it wasn't me, mummy") and are trying to put the blame everywhere, except where it belongs.

And again, like a 4 year-old, it has no plans to change its mind on what it originally planned to do. Given that around 80% of respondents what voluntary equipage, that a significant proportion of businesses expect difficulty in funding the change and that even if Mode S were to be fitted to all GA, we'd still have collision risk from FJ traffic, there should be grounds for optimism

However, given the CAA's notorious lack of good faith, I'd not be surprised to see them steam-roller this one through - agfter all, this is only a consultation and not a negotiation

Consultation= ask your stakeholders because you have to do so, by law. Then make a few minor tweaks and carry on with what you intended

Negotiation= sit in a smoke-filled room for months with your stake-holders work hard, 'engage' with all sides and come up with a compromise solution broadly acceptable to all (or not)

[Flying Lawyer]

s_s

I wasn't blaming the Europeans for this.
I quoted the extract only to illustrate that some former RAF officers are on our side and fighting for us.
The speech refers to Europe because that's EAS area of responsibility. It was given at EuroControl headquarters in Brussels.

[Single Spey]

Folks

I think we are all missing something fundamental here. The RIA is 'to improve the technical interoperability of ALL aircraft in UK airspace.' Has the CAA actually proven the case for ALL aircraft to have technical interoperability?

If there is a requirement to improve safety, particularly for ops outside regulated airspace, then where is the consultation and evidence to show that improved technical interoperatbility for ALL aircraft is the solution? What other options were considered?

I could suggest that one option would be to legislate that commercial flights above 5700kg (or whatever) may only take place into airports that have a radar approach service. In principle this is no different to legislating that these airports must have the required fire cover and be licenced. It could be made a condition of licencing. In this way there would be improved safety for commercial ops into airports in unregulated airspace without affecting the status quo for other airspace users in the vicinity. The commercial operator would pay for this through the airport fees, passed on to the customer who after all is the main beneficiary of the improved safety, and would find it hard to refuse if the argument is safety based.

OK, so what about microlights and gliders that might not show up on the primary radar and are not equipped with SSR? Well, two top of the head solutions: mandate that the radar equipment must have a performance capable of detecting low radar cross section targets, or encourage owners of low radar cross section aircraft have to be fitted with a radar reflector that increases the probability of detection.

The CAA appears to have leapt straight into trying to justify a technical solution, mainly on the basis that i) they need to clean up the RF spectrum thus conventional transponders are out and ii) commercial operators want to make more use of TCAS in unregulated airspace.
So let's see the evidence that supports 'technical interoperability for ALL'
and if it hasn't been produced let's push to postpone the current RIA and get the CAA to undertake the proper study to address the problem.

As an aside, earlier posts referred to the past military career of two individuals involved in the RIA process. I assume that everyone knows Andy Knill's previos military background?

[slim_slag]

Well FL, the speech you quoted speaks for itself. It is riddled with references to regulation from Europe being bad, regulation from the member state being good. However all the evidence shows this idea is coming from the CAA or somebody using the CAA, and not Europe. So if your mate wants to be effective he should look into that and find out what is really driving this, and work out something that suits everybody.