Letter to MP on Mode S
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Letter to MP on Mode S
To pick up on Mode S again, I visited my MP a week ago to ask his support with the issue. I explained the sham consultation the CAA were holding, the lack of accountability with the DfT, and the desire of the GA community to be part of the solution.
The upshot of the meeting was he asked me to write a formal letter to him (text below) and he would forward it on to Douglas Alexander, SoS for Transport, which he confirmed today he has done. In my letter, I asked for his help in overseeing a proper consultation process. I proposed that the CAA abandon the current Mode S proposal and open up a working group with the GA representative bodies to find a solution to the problem of safe use of the complex airspace in the UK as commercial transport continues to grow over the next 20 years.
I've never seen another issue unite the GA world like this one has. If enough MPs get direct contact from us about it, then they'll have to do something. If you haven't written to your MP, I hope it's not too late to do so and have an impact on this process.
Please feel free to use any or all of the letter below to send to your own MP!
I'll let you know if I get any further word from him. Let's hope the CAA sit up and take notice.
Text of my letter to Jeremy Hunt, Conservative MP:
15 October 2006
Ref: Civil Aviation Authority Consultation on Mode S
Dear Jeremy,
I am writing to ask for your assistance in overseeing the consultation the Civil Aviation Authority is conducting on the issue of Mode S transponders in all aircraft. I am concerned that the CAA are acting unilaterally and are not conducting a fair and open consultation with the General Aviation (GA) community. Time is of the essence as the CAA are expected to issue a final ruling by the end of the year.
The CAA is deciding on a proposed rule to require all aircraft of any type to carry a new piece of equipment known as a Mode S transponder. They have issued a public consultation document (the response period closed on 29 Aug), as required by law, but the wording and tone of the document leaves a strong impression that they have decided on the issue, are not open to genuine input and alternative proposals, and are conducting a sham consultation with the general aviation community.
To briefly explain Mode S, it is a new piece of equipment, replacing an older system, which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless using certain types of airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken this one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors).
The concern the general aviation community has is that Mode S does not actually effect the problem the CAA are trying to resolve. Their own consultation document fails to support their proposal. The problem the CAA are trying to address is the safe use of complex and congested airspace in the UK, by a wide range of users and aircraft types, as commercial traffic continues to grow, and it is a genuine issue.
The concern the general aviaition community has is that the CAA are not acting in our best interest or the best interest of aviation as a whole. The CAA has lost the confidence of the very constituents they are meant to look out for and this issue has undone years of good work in building relationships between GA pilots and the CAA. Mode S is merely one alternative, not the only solution. But it is the only solution the CAA have thought of and they are clearly intent on carrying it through, much to the detriment of the GA industry. The Department for Transport have, in the past, made it clear that they are unwilling to question the CAA on their policies and procedures, implicitly making the CAA an uncontrolled regulatory authority with no accountability or oversight of due process. This is not how a regulatory body should be controlled in a free and democratic society.
I propose, and would like your support in enacting, that the CAA abandon this consultation and the Mode S proposal as it is fundamentally flawed in conception and damaging to the relationships between the GA community and the CAA. To instill a new sense of trust and goodwill, this consultation would be replaced by a working group, overseen by an independent third party arbiter, and including the representative bodies of the aviation community such as the Popular Flying Association, the British Gliding Association, and others. There is enough technical and operational experience in those organisations and the GA community that, given an opportunity to be part of the solution, they may come up with a more creative, more effective, and more democratic answer than the CAA have done by themselves.
Thank you very much for your time and attention on this matter. I look forward to hearing from you soon.
The upshot of the meeting was he asked me to write a formal letter to him (text below) and he would forward it on to Douglas Alexander, SoS for Transport, which he confirmed today he has done. In my letter, I asked for his help in overseeing a proper consultation process. I proposed that the CAA abandon the current Mode S proposal and open up a working group with the GA representative bodies to find a solution to the problem of safe use of the complex airspace in the UK as commercial transport continues to grow over the next 20 years.
I've never seen another issue unite the GA world like this one has. If enough MPs get direct contact from us about it, then they'll have to do something. If you haven't written to your MP, I hope it's not too late to do so and have an impact on this process.
Please feel free to use any or all of the letter below to send to your own MP!
I'll let you know if I get any further word from him. Let's hope the CAA sit up and take notice.
Text of my letter to Jeremy Hunt, Conservative MP:
15 October 2006
Ref: Civil Aviation Authority Consultation on Mode S
Dear Jeremy,
I am writing to ask for your assistance in overseeing the consultation the Civil Aviation Authority is conducting on the issue of Mode S transponders in all aircraft. I am concerned that the CAA are acting unilaterally and are not conducting a fair and open consultation with the General Aviation (GA) community. Time is of the essence as the CAA are expected to issue a final ruling by the end of the year.
The CAA is deciding on a proposed rule to require all aircraft of any type to carry a new piece of equipment known as a Mode S transponder. They have issued a public consultation document (the response period closed on 29 Aug), as required by law, but the wording and tone of the document leaves a strong impression that they have decided on the issue, are not open to genuine input and alternative proposals, and are conducting a sham consultation with the general aviation community.
To briefly explain Mode S, it is a new piece of equipment, replacing an older system, which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless using certain types of airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken this one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors).
The concern the general aviation community has is that Mode S does not actually effect the problem the CAA are trying to resolve. Their own consultation document fails to support their proposal. The problem the CAA are trying to address is the safe use of complex and congested airspace in the UK, by a wide range of users and aircraft types, as commercial traffic continues to grow, and it is a genuine issue.
The concern the general aviaition community has is that the CAA are not acting in our best interest or the best interest of aviation as a whole. The CAA has lost the confidence of the very constituents they are meant to look out for and this issue has undone years of good work in building relationships between GA pilots and the CAA. Mode S is merely one alternative, not the only solution. But it is the only solution the CAA have thought of and they are clearly intent on carrying it through, much to the detriment of the GA industry. The Department for Transport have, in the past, made it clear that they are unwilling to question the CAA on their policies and procedures, implicitly making the CAA an uncontrolled regulatory authority with no accountability or oversight of due process. This is not how a regulatory body should be controlled in a free and democratic society.
I propose, and would like your support in enacting, that the CAA abandon this consultation and the Mode S proposal as it is fundamentally flawed in conception and damaging to the relationships between the GA community and the CAA. To instill a new sense of trust and goodwill, this consultation would be replaced by a working group, overseen by an independent third party arbiter, and including the representative bodies of the aviation community such as the Popular Flying Association, the British Gliding Association, and others. There is enough technical and operational experience in those organisations and the GA community that, given an opportunity to be part of the solution, they may come up with a more creative, more effective, and more democratic answer than the CAA have done by themselves.
Thank you very much for your time and attention on this matter. I look forward to hearing from you soon.
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Well done Pitts,
Copied (I couldn't word it better) and sent to Andrew Tyrie, MP for my area (Chichester West Sussex).
It might help ... you never know?
SS
Copied (I couldn't word it better) and sent to Andrew Tyrie, MP for my area (Chichester West Sussex).
It might help ... you never know?
SS
Well done chaps. Funnily enough, I was lying in bed this morning thinking that all PPL's should write to their MP's about Mode S.
Letter going off this w/end to Bob Walter MP. I think it is also worth making the point that the cost to the industry is way higher than that forecast by the CAA. The only way their costs can be right is if the GA community is decimated, which it may well be if this goes ahead.
Letter going off this w/end to Bob Walter MP. I think it is also worth making the point that the cost to the industry is way higher than that forecast by the CAA. The only way their costs can be right is if the GA community is decimated, which it may well be if this goes ahead.
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A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
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1. I didn't want the argument to become about money or funding. The issue for me is the CAA's blind insistence that this is the only solution and their bullying tactics to get what they want. If we make the argument about money, it makes us sound like rich toss-pots whinging about having to spend more of our money on our expensive hobby. It also is an argument that be easily discounted or worked around.
2. I didn't expect my MP to become embroiled in the Mode S issue per se, but I did expect him to be interested in a Government controlled organisation not conducting a democratic process in good faith.
The other thing about costs is that there is still no device suitable for all aircraft so talking about cost is pure speculation and fiction. Not a good place to start an argument in Parliament.
Keep going, folks. Put the ideas in your own words and send it off the your MP!
Pitts2112
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A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
Hadn't heard that and there's nothing on the PFA site to that effect, so I would guess the CAA haven't gone public with the info if that's the case. However, I would argue the letters are still worth sending because if our MPs or the DfT like the idea of a working group, then they might still push for it's establishment regardless of the deadline moving back. If we can get a working group set up now, then it has the full time and attention till 2010 to reach a better solution.
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A PFA inspector mentioned to me yesterday that it's all been postponed to 2010. If I should have known this already, I'm sorry. There have been so many things to get enraged about...
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
Does anyone know if it's just postponed or postponed-pending-proper-consultations? I'd like my letter to reflect the current situation. It's ready to go, otherwise..
Thanks
CC
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I wish I'd got chapter and verse from him, but was otherwise occupied and it didn't register fully at the time.
I agree that it certainly won't hurt to keep pushing and get the democratic representatives (if not the processes) active.....
CC
Done!
I agree that it certainly won't hurt to keep pushing and get the democratic representatives (if not the processes) active.....
CC
Done!
Last edited by ChampChump; 21st Oct 2006 at 13:03. Reason: Update!
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I specifically didn't do that for two reasons (though Jeremy did ask me in our meeting).
1. I didn't want the argument to become about money or funding. The issue for me is the CAA's blind insistence that this is the only solution and their bullying tactics to get what they want. If we make the argument about money, it makes us sound like rich toss-pots whinging about having to spend more of our money on our expensive hobby. It also is an argument that be easily discounted or worked around.
2. I didn't expect my MP to become embroiled in the Mode S issue per se, but I did expect him to be interested in a Government controlled organisation not conducting a democratic process in good faith.
The other thing about costs is that there is still no device suitable for all aircraft so talking about cost is pure speculation and fiction. Not a good place to start an argument in Parliament.
Keep going, folks. Put the ideas in your own words and send it off the your MP!
Pitts2112
1. I didn't want the argument to become about money or funding. The issue for me is the CAA's blind insistence that this is the only solution and their bullying tactics to get what they want. If we make the argument about money, it makes us sound like rich toss-pots whinging about having to spend more of our money on our expensive hobby. It also is an argument that be easily discounted or worked around.
2. I didn't expect my MP to become embroiled in the Mode S issue per se, but I did expect him to be interested in a Government controlled organisation not conducting a democratic process in good faith.
The other thing about costs is that there is still no device suitable for all aircraft so talking about cost is pure speculation and fiction. Not a good place to start an argument in Parliament.
Keep going, folks. Put the ideas in your own words and send it off the your MP!
Pitts2112
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My MP has just written back to me ask for 'more clarification as to the purposes of this instrument'. Fair enough. Not yet being a PPL and not having covered transponders thoroughly yet, what should I tell him?
Kev.
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This what I wrote to my MP
Good luck!
To briefly explain Mode S, it is a new, fairly expensive (~£5,500 inc fitting) piece of equipment which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless they wish to enter certain types of restricted airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken the European Aviation Safety Agency requirements one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors), even if operating outside controlled airspace. No other country is extending the requirement to all aircraft. The CAA proposal is that tens of thousands of Mode S transponders will have to be fitted and switched on.
Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal
Good luck!
To briefly explain Mode S, it is a new, fairly expensive (~£5,500 inc fitting) piece of equipment which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless they wish to enter certain types of restricted airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken the European Aviation Safety Agency requirements one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors), even if operating outside controlled airspace. No other country is extending the requirement to all aircraft. The CAA proposal is that tens of thousands of Mode S transponders will have to be fitted and switched on.
Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal
My MP has replied to say that he has forwarded my letter to Sir Roy McNulty, head of the CAA, and has asked Douglas Alexander to comment on the accountability of the CAA. Will keep you informed of the outcome.
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Originally Posted by Zulu Alpha
To briefly explain Mode S, it is a new, fairly expensive (~£5,500 inc fitting) piece of equipment which the European Aviation Safety Agency has required for all commercial air transport aircraft (passenger and cargo airlines) to enhance safety in controlled airspace. UK airlines are in the process of complying with this regulation but there has never been a requirement for any other aircraft to carry a transponder unless they wish to enter certain types of restricted airspace. In fact, most light aircraft in the world do not carry a transponder of any type. The UK CAA, however, has taken the European Aviation Safety Agency requirements one step further and are requiring it for all aircraft (including light aircraft, microlights, gliders, balloons, and paramotors), even if operating outside controlled airspace. No other country is extending the requirement to all aircraft. The CAA proposal is that tens of thousands of Mode S transponders will have to be fitted and switched on.
Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal
Simply having this equipment in every light aircraft will not enhance safety, as these aircraft are not generally in radio contact with any radar equipped air traffic control as there is no requirement for them to do so. In fact there is not sufficient capacity in our current air traffic control system for every aircraft outside controlled airspace to be in radio contact with radar equipped ATC. Each of these thousands of aircraft with their new mode S transponders will be illuminated on radar screens and this clutter will have to be filtered out so that commercial traffic can be identified.
The radar and ATC systems will then filter out the signals from them so that only important commercial traffic can be seen. In addition ATC will have no way of contacting the aircraft containing these tens of thousands of transponders. This makes the requirement to fit them an expensive and pointless exercise. Mode S does not actually affect the problem the CAA are trying to resolve. Even their own consultation document fails to support their proposal
Well done.
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Folks, generally speaking, I think these last few posts are excellent. MPs seem to be taking some interest and asking the right kinds of questions (accountability of the CAA, for one). Keep up the effort and the good work!
Pitts2112