Proposed amendment of the ANO: Mode S
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Presumably, replacing the LTMA with Class C airspace with Mode C type veils etc would mean a redesign of the SIDs and STARs. The LTMA shape, AIUI, is based around the present procedures.
This, I think, is why the ATC profession is dead against major airspace changes like that. They would have to change just about everything.
This, I think, is why the ATC profession is dead against major airspace changes like that. They would have to change just about everything.
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Slim_slag
A fine response.
At a recent meeting BGA representatives highlighted the lack of any mention in the Partial RIA to H & S risk from a Mode S transponder in a rag and tube aircraft or when held on the person.
It now seems that the CAA are producing a separate analysis of the radiological issues, but this will be published in late Sept or Oct ie after the consultation has closed and therefore we will be unable to comment on the analysis
As you rightly mention the paper is shot full of holes, and has been cobbled together using questionable statistics. Even the response form is loaded so that the 'tick boxes' will support the CAA view
Note that if you tick the 'Do Nothing' option on Response 5, this does not mean that you support the idea of 'Do nothing' but that you support the view of the CAA in that 'Do Nothing' is unworkable.
They obviously know little about low-end aviation, and care less. Here is a classic quote from the RIA Section 5.2.5.1:
"For example, only those private pilots that use ATC would have their recreational flying directly helped by any economic benefits from more efficient ATS. However, they would benefit from ATC efficiency as members of the public when undertaking flights with commercial operators for business or pleasure."
In other words, for the financial outlay, we won't see any benefit unless we fly Chavair to Ibiza - nice one!!!
A fine response.
At a recent meeting BGA representatives highlighted the lack of any mention in the Partial RIA to H & S risk from a Mode S transponder in a rag and tube aircraft or when held on the person.
It now seems that the CAA are producing a separate analysis of the radiological issues, but this will be published in late Sept or Oct ie after the consultation has closed and therefore we will be unable to comment on the analysis
As you rightly mention the paper is shot full of holes, and has been cobbled together using questionable statistics. Even the response form is loaded so that the 'tick boxes' will support the CAA view
Note that if you tick the 'Do Nothing' option on Response 5, this does not mean that you support the idea of 'Do nothing' but that you support the view of the CAA in that 'Do Nothing' is unworkable.
They obviously know little about low-end aviation, and care less. Here is a classic quote from the RIA Section 5.2.5.1:
"For example, only those private pilots that use ATC would have their recreational flying directly helped by any economic benefits from more efficient ATS. However, they would benefit from ATC efficiency as members of the public when undertaking flights with commercial operators for business or pleasure."
In other words, for the financial outlay, we won't see any benefit unless we fly Chavair to Ibiza - nice one!!!
One thing that's clear on this thread, as elsewhere, is that a small minority of aircraft users are calling the shots.
Just for interest, here is the current % make up of the UK aircraft fleet, using the CAAs own data. Remember ALL are currently included in the Mode S proposal, unless it gets amended. I've listed them below in decreasing fleet size order:
Foot launched aircraft, powered and non-powered = 26%
Light single engine piston = 21%
Microlights = 15%
Gliders and SLMGs = 10%
Balloons and airships = 7%
Amateur built fixed wing = 6%
Helicopters and gyros = 6%
Commercial Air Transport = 4%
Light twin engine piston and larger singles = 2%
Vintage and historic = 2%
Turbine light aircraft = 1%
What is clear from this list is that a very large number of these aircraft are not using radio, are not using air traffic control facilities, are not flying anywhere except in class G airspace and are restricted to VFR flight only, yet these are the ones bearing the brunt of the financial impact of the mode S proposal.
VP
Just for interest, here is the current % make up of the UK aircraft fleet, using the CAAs own data. Remember ALL are currently included in the Mode S proposal, unless it gets amended. I've listed them below in decreasing fleet size order:
Foot launched aircraft, powered and non-powered = 26%
Light single engine piston = 21%
Microlights = 15%
Gliders and SLMGs = 10%
Balloons and airships = 7%
Amateur built fixed wing = 6%
Helicopters and gyros = 6%
Commercial Air Transport = 4%
Light twin engine piston and larger singles = 2%
Vintage and historic = 2%
Turbine light aircraft = 1%
What is clear from this list is that a very large number of these aircraft are not using radio, are not using air traffic control facilities, are not flying anywhere except in class G airspace and are restricted to VFR flight only, yet these are the ones bearing the brunt of the financial impact of the mode S proposal.
VP
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That's an excellent point robin. The CAA is also supposed to adhere to the 'user pays principle'. By their own admission, it's only the airlines who will be using the "new efficient" ATS who benefit, so the airline should pay. If the cost to equip the GA fleet is as little as the CAA claim, it shouldn't be too much of a problem for the airlines to pay for it. And they can look at it as a deductible investment towards future money saving efficiencies.
Of course why mention ATS efficiencies when the stated objectives are only safety based? It's a BS way to sneak through a financial burden on GA using a BS safety argument, the financial benefit of which accrues to the airlines. We can see who regulates the CAA.
Of course why mention ATS efficiencies when the stated objectives are only safety based? It's a BS way to sneak through a financial burden on GA using a BS safety argument, the financial benefit of which accrues to the airlines. We can see who regulates the CAA.
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This is an interesting thread. SLim_slag when you talk about no TCAS for GA you seem to have forgotten SKYWATCH equipment that is in the SR22 etc. That is a traffic avoidance system that anyone lucky enough to be in a SR22 can use and that is based on SSR (mode s or c) I personally think that when ssr has been around for over 60 years in one form or another, perhaps we should be looking at it as away of enhancing safety. After all you wouldn't fly without using a seat belt, why would you want to fly with out something that could stop you being swallowed by a turbine engine or chopped by someones prop?
Stands back and watch the flames
Stands back and watch the flames
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Fair point; however the system you refer to costs about £10,000 to install, so few UK GA pilots will go for it.
Also there are very few GA-GA mid-airs, zero in IMC I believe (in the UK, so far), so the case for this is not strong. The traditional viewpoint in traditional UK GA is that you are supposed to keep a lookout (what the traditionalists call the "Mk 1 eyeball") in VMC, and those who are concerned about a mid-air in IMC can fly around in the knowledge that they are far more likely to hit a hill, so actually they would be better off spending similar money on GPWS.
Debating this, one just goes round and round. One could make a case for mandatory Mode C in the vicinity of busy controlled airspace (as they have in the USA), for reasons of traffic separation, i.e. to get a better grip on the numerous and rising CAS infringements. But at the same time PPLs are taught the same old dead reckoning navigation techniques and absolutely nobody (who is in a position to change anything) wants to do anything about that, so infringements will continue, regardless of what transponder equipment planes are carrying. If I was in charge of reducing infringements, I would first tear all my hair out, and then make Mode C mandatory around CAS, US-style.
Unfortunately the last thing Europe is going to do is what America does, on the principle that Europe always does it better....
Also there are very few GA-GA mid-airs, zero in IMC I believe (in the UK, so far), so the case for this is not strong. The traditional viewpoint in traditional UK GA is that you are supposed to keep a lookout (what the traditionalists call the "Mk 1 eyeball") in VMC, and those who are concerned about a mid-air in IMC can fly around in the knowledge that they are far more likely to hit a hill, so actually they would be better off spending similar money on GPWS.
Debating this, one just goes round and round. One could make a case for mandatory Mode C in the vicinity of busy controlled airspace (as they have in the USA), for reasons of traffic separation, i.e. to get a better grip on the numerous and rising CAS infringements. But at the same time PPLs are taught the same old dead reckoning navigation techniques and absolutely nobody (who is in a position to change anything) wants to do anything about that, so infringements will continue, regardless of what transponder equipment planes are carrying. If I was in charge of reducing infringements, I would first tear all my hair out, and then make Mode C mandatory around CAS, US-style.
Unfortunately the last thing Europe is going to do is what America does, on the principle that Europe always does it better....
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Originally Posted by dublinpilot
If this is true, then perhaps someone should explain to the Transport Minister, and to the Prime Ministers Office that the CAA are 'massaging the figures' (rather than a more confrontational term) to circumvent 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.
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.
Tabs please !
Originally Posted by Parapunter
Say no to mode s Transponders!
Perhaps I should call up the local ATC for Radar information next time I go ridge soaring at 50 feet AGL with my buddies and stop looking over my shoulder.
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zkdli, hope you don't think telling you "I never actually said that" is a flame 
I am sure the number of reported airproxes would drop if all GA craft had some sort of optional TCAS connected to their mandated mode S transponder, but it would not drop to zero as Table 13 shows.
When the US was mandating Mode S for commercial operations, it looked at mandating mode S in GA flights, but decided not to do it. One of the concerns was 'saturation' of the 1090MHz frequency and swarms of GA planes filling all the displays on the ground and in the air. Any possible frequency saturation must be made considerably worse if GA planes are actively transmitting, which is what happens when you have TCAS on board.
Anyway, this issue is brought up in the Partial RIA, section 3.2.3 (e)
How has the CAA responded to what sounds like a genuine concern?
2012? As far as 2012? WTF. That's four years after this is all due to start! What happens in 2013? Are they saying they don't know whether the system will be overloaded in 2013? Looks like it to me. What happens then? They say "Further modelling will be conducted", so publish the model and the results and let us comment on that too BEFORE they implement what appears to be an expensive experiment which if it works will only benefit the airlines and ATC.
This partial RIA is a joke, but seems like their mind is made up.
I am sure the number of reported airproxes would drop if all GA craft had some sort of optional TCAS connected to their mandated mode S transponder, but it would not drop to zero as Table 13 shows.
When the US was mandating Mode S for commercial operations, it looked at mandating mode S in GA flights, but decided not to do it. One of the concerns was 'saturation' of the 1090MHz frequency and swarms of GA planes filling all the displays on the ground and in the air. Any possible frequency saturation must be made considerably worse if GA planes are actively transmitting, which is what happens when you have TCAS on board.
Anyway, this issue is brought up in the Partial RIA, section 3.2.3 (e)
The GA community has raised concerns that widespread equipage of SSR transponders on aircraft that routinely operate in large ‘clusters’ could saturate radars, ATC systems and ACAS.
The CAA has investigated this issue and conducted modelling for the period up to 2012, which indicates that there should be no significant problems in this regard
This partial RIA is a joke, but seems like their mind is made up.
Well, I think we should have a rethink about all the factors involved - and also take the opportunity to harmonise/simplify things generally. We'll have to give way to some extent, but Mode S transponders on paramotors would be just plan madness.
What about:
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under IFR and < 2000 kg, Mode A compulsory if under VFR and < 2000 kg.
Class E to G - Mode C compulsory under IFR. No transponder required under VFR.
And how about a 6000ft UK-wide TA whilst we're at it?
Tin hat on.....
What about:
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under IFR and < 2000 kg, Mode A compulsory if under VFR and < 2000 kg.
Class E to G - Mode C compulsory under IFR. No transponder required under VFR.
And how about a 6000ft UK-wide TA whilst we're at it?
Tin hat on.....
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I thought Mode S was already mandatory for all IFR.
Or it is just IFR in CAS?
People also forget that this is a Euro-wide thing. All very well to get an exemption in the UK but what is going to happen to popping over to France?
Or it is just IFR in CAS?
People also forget that this is a Euro-wide thing. All very well to get an exemption in the UK but what is going to happen to popping over to France?
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IO540 is quite right about the Europe wide bit, 8000 French micros are already except and the home built sector are pushing hard for the same treatment. Agreements allow all the French aircraft into UK airspace for a certain number of days (60?) a year.
If you force non radio Aircraft to fit mode S how are you going to know if it is accurate in the air? My only airprox in many years and 800 hours was in IMC. I was tracking via a VOR on a RIS in the open FIR. I was warned of unknown traffic indicating 2000 feet. I was 1000 feet above so carried on. I was in and out of cloud but above a solid layer, I came out of one bank just in time to see an aircraft flash under me left to right very close indeed. RIS indicated it was the unknown traffic so his encoder must have been out by at least 800ft. In this case both aircraft had mode C, but only one was talking to the local LARS. My examiner (it was an IMC renewal) did not report the incident. Mode S would not have helped in this case, which is also the case in all the fatal mid air collisions that have happened in recent years.
Rod1
If you force non radio Aircraft to fit mode S how are you going to know if it is accurate in the air? My only airprox in many years and 800 hours was in IMC. I was tracking via a VOR on a RIS in the open FIR. I was warned of unknown traffic indicating 2000 feet. I was 1000 feet above so carried on. I was in and out of cloud but above a solid layer, I came out of one bank just in time to see an aircraft flash under me left to right very close indeed. RIS indicated it was the unknown traffic so his encoder must have been out by at least 800ft. In this case both aircraft had mode C, but only one was talking to the local LARS. My examiner (it was an IMC renewal) did not report the incident. Mode S would not have helped in this case, which is also the case in all the fatal mid air collisions that have happened in recent years.
Rod1
Don't forget that much of Europe doesn't permit flight under IFR outside CAS in the first place!
We Brits do have some traditional rules which we must fight to hold on to in the face of mounting Eurocracy!
We Brits do have some traditional rules which we must fight to hold on to in the face of mounting Eurocracy!
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Don't forget that much of Europe doesn't permit flight under IFR outside CAS in the first place
The essential thing here is that by allowing IFR OCAS the UK acknowledges what is a fait accompli anyway i.e. nobody knows whether you are VMC or IMC when en-route, so no enforcement of any of the VFR rules (clear of cloud, a specified distance from cloud, a specified visibility, in sight of the surface, etc) is possible anyway.
Look at the huge growth of the high-end ultralight and permit categories. A lot of them very well equipped for what is obviously IFR operations. But of course none of these people ever go into a cloud
Not being able to fly IFR OCAS simply means that one cannot request an instrument approach without drawing attention to oneself, in the "not having the JAA IR" department. And one gets stuck at towered airports if the cloudbase is below the VFR departure minima. Other than that, I am sure there is just as much "IFR OCAS" in the rest of Europe as here.
The UK rules go hand in hand with the IMC Rating, which as far as I can tell is close to unique in Europe. Also fairly unique is the anally retentive manner with which Class D is dealt with, being treated as Class B or C, so I think the present situation is just handy for the CAA which really doesn't want to change the airspace management.
The essential thing here is that by allowing IFR OCAS the UK acknowledges what is a fait accompli anyway i.e. nobody knows whether you are VMC or IMC when en-route, so no enforcement of any of the VFR rules (clear of cloud, a specified distance from cloud, a specified visibility, in sight of the surface, etc) is possible anyway.
Look at the huge growth of the high-end ultralight and permit categories. A lot of them very well equipped for what is obviously IFR operations. But of course none of these people ever go into a cloud
Not being able to fly IFR OCAS simply means that one cannot request an instrument approach without drawing attention to oneself, in the "not having the JAA IR" department. And one gets stuck at towered airports if the cloudbase is below the VFR departure minima. Other than that, I am sure there is just as much "IFR OCAS" in the rest of Europe as here.
The UK rules go hand in hand with the IMC Rating, which as far as I can tell is close to unique in Europe. Also fairly unique is the anally retentive manner with which Class D is dealt with, being treated as Class B or C, so I think the present situation is just handy for the CAA which really doesn't want to change the airspace management.
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Beags,
Seems eminently sensible, but I anticipate that ATCOs will want mode C in classes E-G where it underlies classes A-C (which is basically everywhere), to avoid having to call traffic (and spurious TCAS activations) on low-level VFR. Of course, one solution would be to mandate mode C for IFR and prohibit mode A only squawks for VFR - mode C or nothing...
Tim
Seems eminently sensible, but I anticipate that ATCOs will want mode C in classes E-G where it underlies classes A-C (which is basically everywhere), to avoid having to call traffic (and spurious TCAS activations) on low-level VFR. Of course, one solution would be to mandate mode C for IFR and prohibit mode A only squawks for VFR - mode C or nothing...
Tim
So that would be:
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under VFR or under IFR if < 2000 kg.
Class E to G - Mode C compulsory under IFR. No transponder required under VFR.
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under VFR or under IFR if < 2000 kg.
Class E to G - Mode C compulsory under IFR. No transponder required under VFR.
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Yes, but it would be undermined if lots of VFR traffic squawked mode A only underneath CAS - would cause TCAS warnings (as far as I understand, TCAS being rather outside my experience...!)
Tim
Tim
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Mode A is pretty useless. Especially if one takes the charitable view that the driver behind all this is CAS busts; Mode A doesn't help with busts from underneath.
In fact, if there was the slightest possibility of Mode C being acceptable (rather than S) upgrading a Mode A installation to Mode C is relatively cheap. One can pick up a Mode C on U.S. Ebay (or from various secondhand avionics shops) for a few hundred quid, and currently there are plenty around due to IFR pilots having to put in Mode S.
In fact, if there was the slightest possibility of Mode C being acceptable (rather than S) upgrading a Mode A installation to Mode C is relatively cheap. One can pick up a Mode C on U.S. Ebay (or from various secondhand avionics shops) for a few hundred quid, and currently there are plenty around due to IFR pilots having to put in Mode S.
OK then:
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under VFR or under IFR if < 2000 kg.
Class E to G - Mode C compulsory under IFR. Mode C optional under VFR, Mode A not permitted.
Would that be OK? - I'm meeting the CAA next week.
Class A to C airspace - Mode S compulsory.
Class D - Mode S compulsory under IFR if > 2000kg. Mode C compulsory under VFR or under IFR if < 2000 kg.
Class E to G - Mode C compulsory under IFR. Mode C optional under VFR, Mode A not permitted.
Would that be OK? - I'm meeting the CAA next week.
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Originally Posted by IO540
I thought Mode S was already mandatory for all IFR.
Or it is just IFR in CAS?
People also forget that this is a Euro-wide thing. All very well to get an exemption in the UK but what is going to happen to popping over to France?
Or it is just IFR in CAS?
People also forget that this is a Euro-wide thing. All very well to get an exemption in the UK but what is going to happen to popping over to France?
Just tell them you are a Eurostar. The DGAC have exempted all 8500 French microlights.