Letter to MP on Mode S
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From: Surrey, UK.
Originally Posted by Pitts2112
Originally Posted by rustle
Possibly the worst "explanation" of anything in the history of the world.
Well done.
Well done.Pitts2112
1. Minister person (with advice) can shoot it down in flames as incorrect
2. CAA can do likewise and will use that as an example of the dis-information that is being spread about
If telling lies about technology is the only way forward for the anti-mode-S mob I guess we'll see you in the avionics shop soon
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From: EuroGA.org
One should keep threads on here informative at all times. So let me have a go, editing the previous version:
To briefly explain what a Mode S transponder is:
It is a piece of equipment, installed in the aircraft at a cost varying between £2000 and perhaps £4000 (depending on various factors including whether a transponder was installed previously) which the CAA is proposing to make mandatory. [include a photograph of say a Garmin GTX330]
The reason being given is to improve safety. However, the CAA has thoroughly failed to make their case for this, as the attached proposal and the commentary demonstrates [attach CAA proposal and one or more of the informed comments on it from the various GA bodies; some of these are actually OK]
There are many aircraft types on which the transponder installation is impractical; for example due to not having an electrical supply.
Transponders are mandatory in certain classes of airspace but they should not be made mandatory for all light aircraft.
Understandably, other European countries have exempted their general aviation aircraft from this requirement, but the UK CAA is determined to drive it through.
The UK general aviation scene is already suffering from excessive regulation and this will make matters worse.
Or something like that....
However, I think Mode S is a lost cause, for all planes other than those on which installation is technically infeasible.
To briefly explain what a Mode S transponder is:
It is a piece of equipment, installed in the aircraft at a cost varying between £2000 and perhaps £4000 (depending on various factors including whether a transponder was installed previously) which the CAA is proposing to make mandatory. [include a photograph of say a Garmin GTX330]
The reason being given is to improve safety. However, the CAA has thoroughly failed to make their case for this, as the attached proposal and the commentary demonstrates [attach CAA proposal and one or more of the informed comments on it from the various GA bodies; some of these are actually OK]
There are many aircraft types on which the transponder installation is impractical; for example due to not having an electrical supply.
Transponders are mandatory in certain classes of airspace but they should not be made mandatory for all light aircraft.
Understandably, other European countries have exempted their general aviation aircraft from this requirement, but the UK CAA is determined to drive it through.
The UK general aviation scene is already suffering from excessive regulation and this will make matters worse.
Or something like that....
However, I think Mode S is a lost cause, for all planes other than those on which installation is technically infeasible.
Joined: Aug 2000
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From: uk
I have now received two replies from my MP re. Mode S.
The first encloses a response from Sir Roy McNulty, Chairman of the CAA, and was probably written by Humphrey Appleby. I haven't finished decoding it yet but it doesn't seem to say too much that is helpful.
The second is from Gillian Merron MP, PUS for Transport. She says that -
"The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft, including microlights, balloons and paramotors, unless the activity is unusual and likely to cause interaction with other types of airspace user (e.g. an endurance flight)............. Until a Mode S Low-power SSR Transponder (LPST) is available commercially for use within UK airspace, all classes of light aircraft will operate under a blanket exemption."
That sounds like good news.
The first encloses a response from Sir Roy McNulty, Chairman of the CAA, and was probably written by Humphrey Appleby. I haven't finished decoding it yet but it doesn't seem to say too much that is helpful.
The second is from Gillian Merron MP, PUS for Transport. She says that -
"The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft, including microlights, balloons and paramotors, unless the activity is unusual and likely to cause interaction with other types of airspace user (e.g. an endurance flight)............. Until a Mode S Low-power SSR Transponder (LPST) is available commercially for use within UK airspace, all classes of light aircraft will operate under a blanket exemption."
That sounds like good news.
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From: up North
Until a Mode S Low-power SSR Transponder (LPST) is available commercially for use within UK airspace, all classes of light aircraft will operate under a blanket exemption.
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From: East Anglia
I have just returned to this thread as my MP has sent me a copy of a letter he received form the CAA.
I see there is some criticism of my letter. Not sure which bit was being objected to but let me make some points
Cost... £4700 + VAT was what was charged by Extra for fitting a Mode S on a new Extra. Maybe it will reduce but that's an actual number at present. I used it.
The other point was that I could not see any point is having a mode S transponder in a PFA type unless the aircraft has radio and is talking to someone. If I'm buzzing around in uncontrolled airspace in East Anglia with radio off and Mode S on what are the ground stations going to do? Probably use the software to remove my trace from the screen unless I get near controlled airspace? This is what I meant by filtering my signal out.
Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.
I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms. We need this so that MPs can make a judgement between the words from the CAA and opposing words from the PFA etc.
At present I think they see a lot of jargon they don't understand and their response is to ask the experts (the CAA!). The CAA point to their consultation exercise and say how fair it all is and then cloak it in the statement "well you want to make UK aviation safer don't you?".
MPs can only challenge this if they have clarity. Either about how the working of Mode S is being misrepresented or evidence that the CAA have not consulted GA properly.
The reply from the CAA (Sir Roy McNulty, Chairman of the CAA) says they have performed a proper consultation of GA bodies.
I wonder why the PFA felt it necessary to write a 38 page letter starting with the comment that they had not been consulted properly.
I intend to write back to my MP regarding the lack of proper consultation. If Russle would like to create a paragraph or two that uses no jargon to explain why Mode S is not a solution to the problem then I would be delighted to include it.
Lets remember what we are trying to achieve.
I see there is some criticism of my letter. Not sure which bit was being objected to but let me make some points
Cost... £4700 + VAT was what was charged by Extra for fitting a Mode S on a new Extra. Maybe it will reduce but that's an actual number at present. I used it.
The other point was that I could not see any point is having a mode S transponder in a PFA type unless the aircraft has radio and is talking to someone. If I'm buzzing around in uncontrolled airspace in East Anglia with radio off and Mode S on what are the ground stations going to do? Probably use the software to remove my trace from the screen unless I get near controlled airspace? This is what I meant by filtering my signal out.
Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.
I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms. We need this so that MPs can make a judgement between the words from the CAA and opposing words from the PFA etc.
At present I think they see a lot of jargon they don't understand and their response is to ask the experts (the CAA!). The CAA point to their consultation exercise and say how fair it all is and then cloak it in the statement "well you want to make UK aviation safer don't you?".
MPs can only challenge this if they have clarity. Either about how the working of Mode S is being misrepresented or evidence that the CAA have not consulted GA properly.
The reply from the CAA (Sir Roy McNulty, Chairman of the CAA) says they have performed a proper consultation of GA bodies.
I wonder why the PFA felt it necessary to write a 38 page letter starting with the comment that they had not been consulted properly.
I intend to write back to my MP regarding the lack of proper consultation. If Russle would like to create a paragraph or two that uses no jargon to explain why Mode S is not a solution to the problem then I would be delighted to include it.
Lets remember what we are trying to achieve.
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From: South Norfolk, England
The second is from Gillian Merron MP, PUS for Transport. She says that -
SS
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From: SE England
I just don't trust the CAA on this.
They want this to happen, but the technical and economic arguments are against them. Even worse, the logic of expecting non-radio aircraft or aircraft with no electrical systems to carry Mode S - they still haven't had the radiological report yet - is unarguable, and they know it.
However, never doubt it. They will try to get this through and are working on a damage-limitation exercise to overcome the objections without giving up on the key principle
They want this to happen, but the technical and economic arguments are against them. Even worse, the logic of expecting non-radio aircraft or aircraft with no electrical systems to carry Mode S - they still haven't had the radiological report yet - is unarguable, and they know it.
However, never doubt it. They will try to get this through and are working on a damage-limitation exercise to overcome the objections without giving up on the key principle
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From: EuroGA.org
Zulu Alpha
Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.
I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms.
The answer is that most people don't get the reason why Mode S is being pushed forward into GA - even the stuff flying outside controlled airspace.
It is to ensure that if the aircraft strays into CAS (which happens hundreds of times a year in the UK, whether anybody likes it or not) its transponder will trigger TCAS systems on transport jets, enabling them to take avoiding action.
There is another argument which is that a certain amount of transport traffic flies through bits of Class G, where it could encounter GA traffic that is currently flying non-radio and non-transponder, and legally so. In this respect, one can regard transponder carriage+use as a reasonable quid pro quo for GA not having to lose chunks of Class G.
It's nothing to do with safety for GA. The statistics for GA/GA mid-airs are much too thin to justify any real expenditure in this area, and in any case the State has very little business in dictating individual risk management.
The slight problem with the above is that Mode C would do this job just as well as Mode S. Mode S does have advantages for IFR within CAS (basically, facilitating some slick ATC software functions) but for OCAS I don't see why they don't just settle on Mode C, as the USA has done many years ago. I suppose the reason is that most GA planes are in fact legally capable of IFR.
Anyway, it looks that large chunks will be exempt, just as I thought all along, which is sensible.
Perhaps someone can tell me how a mode S transponder will then make me any safer? They cannot contact me to warn of another aircraft civil or military.
I would welcome a simple explanation suitable for a non technical MP who knows little about GA or aviation in general. So far nothing I have seen explains things in simple terms.
The answer is that most people don't get the reason why Mode S is being pushed forward into GA - even the stuff flying outside controlled airspace.
It is to ensure that if the aircraft strays into CAS (which happens hundreds of times a year in the UK, whether anybody likes it or not) its transponder will trigger TCAS systems on transport jets, enabling them to take avoiding action.
There is another argument which is that a certain amount of transport traffic flies through bits of Class G, where it could encounter GA traffic that is currently flying non-radio and non-transponder, and legally so. In this respect, one can regard transponder carriage+use as a reasonable quid pro quo for GA not having to lose chunks of Class G.
It's nothing to do with safety for GA. The statistics for GA/GA mid-airs are much too thin to justify any real expenditure in this area, and in any case the State has very little business in dictating individual risk management.
The slight problem with the above is that Mode C would do this job just as well as Mode S. Mode S does have advantages for IFR within CAS (basically, facilitating some slick ATC software functions) but for OCAS I don't see why they don't just settle on Mode C, as the USA has done many years ago. I suppose the reason is that most GA planes are in fact legally capable of IFR.
Anyway, it looks that large chunks will be exempt, just as I thought all along, which is sensible.
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From: SE England
There is another argument which is that a certain amount of transport traffic flies through bits of Class G, where it could encounter GA traffic that is currently flying non-radio and non-transponder, and legally so. In this respect, one can regard transponder carriage+use as a reasonable quid pro quo for GA not having to lose chunks of Class G.
They treat Class G as their airspace and as they start to use it more and more, 'negotiating' short cuts, they still want the protection of controlled airspace.
My point - if they need this service, they should be the ones paying for it. But, of course, they won't.
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From: UK
If that's the only reason (I don't know!) then there's a simple solution, though - legally require Mode S for IFR flight in CAS. (c.f. change to require FM Immune kit for Instrument approaches in CAS back in the late 90s.)
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From: Euroland
I agree with the CAA. Mode S should be required and ADS-B should be widespread. The fault is with society in general, aviation tends to be developed by "pilots", not business people - hence the eejits that setup 90% of new airlines and lose a fortune. The problem is nobody has had the ability or desire to develop and cerify cheap avionics. I.e. Mode S for £200.
If someone could do for avionics what MOL did for Ryanair - it won't be such an issue.
Computers, airline travel, cars (relatively speaking), phones, etc all came down in price. Avionics are "special", they only go up!
VT
If someone could do for avionics what MOL did for Ryanair - it won't be such an issue.
Computers, airline travel, cars (relatively speaking), phones, etc all came down in price. Avionics are "special", they only go up!
VT
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From: EuroGA.org
Dave
I suppose the answer to that one must be the occassional transport traffic in Class G.
You can fly IFR OCAS, nonradio and non-xp. And we all know that "IFR" v. "VFR" in Class G is no more than in the pilot's mind.
So, do you want to carry an transponder, or do you want lots of bits of Class D around all the new "London XXXXXX International" airports? This isn't a loaded question. Different people would see it different ways. The typical cost of putting a GTX330 into a GA spamcan is about £3000 inc VAT, and less if you had something in the hole previously. This price will fall if the market is created through legislation, through new products. Is this cost worth the G airspace preservation, or the occassional extra access into D? For some it might be, for others probably not, but let's say you have a syndicate around a PA28; you can forget any members who have gone the extra mile to get an IMCR for example.
Lucy Lastic
ATC has to right to order you about in G, under an FIS (it can under an RIS). You can simply turn off your radio to start with or, more sensibly, run a listening watch on London Info.
I suppose the answer to that one must be the occassional transport traffic in Class G.
You can fly IFR OCAS, nonradio and non-xp. And we all know that "IFR" v. "VFR" in Class G is no more than in the pilot's mind.
So, do you want to carry an transponder, or do you want lots of bits of Class D around all the new "London XXXXXX International" airports? This isn't a loaded question. Different people would see it different ways. The typical cost of putting a GTX330 into a GA spamcan is about £3000 inc VAT, and less if you had something in the hole previously. This price will fall if the market is created through legislation, through new products. Is this cost worth the G airspace preservation, or the occassional extra access into D? For some it might be, for others probably not, but let's say you have a syndicate around a PA28; you can forget any members who have gone the extra mile to get an IMCR for example.
Lucy Lastic
ATC has to right to order you about in G, under an FIS (it can under an RIS). You can simply turn off your radio to start with or, more sensibly, run a listening watch on London Info.
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From: SE England
Agreed. What I was saying was that I was listening to the pilot of the ChavAir bullying the ATCO, which I felt was inappropriate. If they choose to route through Class G then they can't expect the same service as in CAS.
But in any case I would almost never listen out on London Information. That is next to useless for most of my flying. It is next to impossible to find space to get to speak to them and most of those being worked by them seem to be in a completely different part of the world.
Oh, and they aren't much help with Mode S are they, as they are not radar equipped.
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From: West Wiltshire, UK
It's worth remembering that there are more recreational pilots flying paragliders, hang gliders (powered or otherwise), paramotors, microlights, PFA types, balloons and gliders than there are flying in club type light aircraft, by a fair margin.
This transponder stuff may be trivial to the small minority of private flyers who fly the expensive kit, but for the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand it's a really big deal.
Remember that the majority of recreational flyers rarely even use radio at the moment..............
VP
This transponder stuff may be trivial to the small minority of private flyers who fly the expensive kit, but for the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand it's a really big deal.
Remember that the majority of recreational flyers rarely even use radio at the moment..............
VP
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From: EuroGA.org
But in any case I would almost never listen out on London Information. That is next to useless for most of my flying
Agreed; I said "listening watch" because it's a good idea to always be on a known working frequency in case of a mayday call. There is little point, in general, in talking to anybody unless they can offer a radar service.
And yes I meant "NO". That ATP had no right to demand anything whatsoever in G. But.... if enough of this goes on then we will get more Class D, because the airlines rule the world, so to speak.
The European angle is another thing... airspace access issues are everywhere.
the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand
Aren't they going to be exempted?
Agreed; I said "listening watch" because it's a good idea to always be on a known working frequency in case of a mayday call. There is little point, in general, in talking to anybody unless they can offer a radar service.
And yes I meant "NO". That ATP had no right to demand anything whatsoever in G. But.... if enough of this goes on then we will get more Class D, because the airlines rule the world, so to speak.
The European angle is another thing... airspace access issues are everywhere.
the many thousands who float around in aircraft costing between a couple of thousand and perhaps ten thousand
Aren't they going to be exempted?
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From: Cirencester UK
Letter to MP on Mode S
Just catching up on this thread, having been at EASA and Eurocontrol meetings in capacity of UK 'expert' (!) from the S&RA / GA community on working groups etc last few days.
Two points:
1. Mode S requirement does not emanate from EASA (an element of the text of a letter to a MP). It is an ICAO requirement going back some years and as such was specified for aeroplanes (not aircraft). For those who do not know the difference, look it up !
2. CAA core reason for the proposal for all aircraft in all UK airspace to carry Mode S is because of CAT now using (currently) Class G to fly into / out of regional airports, and future growth trends. It's the LoCos. The alternative might be a large expansion of Class D (min) airspace. That is a very real issue.
Simple really. Pity the CAA solution is too.
DGR
Europe Air Sports / RAeC etc etc
Two points:
1. Mode S requirement does not emanate from EASA (an element of the text of a letter to a MP). It is an ICAO requirement going back some years and as such was specified for aeroplanes (not aircraft). For those who do not know the difference, look it up !
2. CAA core reason for the proposal for all aircraft in all UK airspace to carry Mode S is because of CAT now using (currently) Class G to fly into / out of regional airports, and future growth trends. It's the LoCos. The alternative might be a large expansion of Class D (min) airspace. That is a very real issue.
Simple really. Pity the CAA solution is too.
DGR
Europe Air Sports / RAeC etc etc
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From: uk
Now that I have had more time to study the letters from Sir Roy McNulty and Gillian Merrin I have written again to my MP.
Merrin said: "The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft". She ignores the fact that they already have.
She also said: " Until a LPST is available commercially, all classes of light aircraft will operate under a blanket exemption." Why do we need an exemption if there is no proposal to fit them?
McNulty's letter treats the whole of UK airspace as the same. I have explained to my MP the simple difference beween controlled and uncontrolled airspace and what limited value a transponder is in the latter.
Preparing the letter I came to look at CAP722 which is the CAA guidance on UAV's. One of the key requirements for the operation of a UAV operating in anything other than defined exclusion zones is the ability to "sense and avoid". (Didn't it use to be see and avoid?).
I have therefore explained to my MP that the only beneficiaries of a global Mode S system would be the Low Cost airlines and the UAV industry which, it seems to me, will soon be a huge growth industry.
Merrin said: "The CAA is unlikely to propose the fitment of Mode S transponders to light aircraft". She ignores the fact that they already have.
She also said: " Until a LPST is available commercially, all classes of light aircraft will operate under a blanket exemption." Why do we need an exemption if there is no proposal to fit them?
McNulty's letter treats the whole of UK airspace as the same. I have explained to my MP the simple difference beween controlled and uncontrolled airspace and what limited value a transponder is in the latter.
Preparing the letter I came to look at CAP722 which is the CAA guidance on UAV's. One of the key requirements for the operation of a UAV operating in anything other than defined exclusion zones is the ability to "sense and avoid". (Didn't it use to be see and avoid?).
I have therefore explained to my MP that the only beneficiaries of a global Mode S system would be the Low Cost airlines and the UAV industry which, it seems to me, will soon be a huge growth industry.
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From: Strathaven Airfield
Why do we have to have Mode S?
Am I paranoid to think that it is linked to two recent news stories?
One is that a quarter of all the CCTV cameras in the world are in the UK.
The other is that Unmanned Aerial Vehicles are being proposed for traffic patrols, pylon inspections etc.
So, imagine the news if a spotty teenager wipes out a mum and dad off for a flight in a microlight or Cessna while he sits in his air-conditioned office "flying" the UAV!
Now if the UAV can detect Mode S transmissions.......
Am I paranoid to think that it is linked to two recent news stories?
One is that a quarter of all the CCTV cameras in the world are in the UK.
The other is that Unmanned Aerial Vehicles are being proposed for traffic patrols, pylon inspections etc.
So, imagine the news if a spotty teenager wipes out a mum and dad off for a flight in a microlight or Cessna while he sits in his air-conditioned office "flying" the UAV!
Now if the UAV can detect Mode S transmissions.......