Mode 'S' mandatory for gliders.
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Problem with mode C is that when there are too many hits, the system gets confused (see FRUIT). Mode S has more complexity which combats these issues..
There is a capacity limit... Mode S has higher capacity.. if everyone was forced onto Mode C then system will likely fall apart (as far as I understand it)
There is a capacity limit... Mode S has higher capacity.. if everyone was forced onto Mode C then system will likely fall apart (as far as I understand it)
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Pbrooks, no they don't, but they recieve generally Radar Services particularly above FL100....so with a Transponder fitted you are visible and therefore safer.
Bigchopper, said
Read the whole thread and you'll understand what "they" are doing there. If "they" are there it's for a good reason, i.e there's no other choice, not all airports are under airways or TMA's. In the case of some of the East Coast stuff it's simply much more economical (and environmentally friendly 
) to go Newcastle direct Aberdeen rather than going...TILNI TALLA PERTH ADN. It's going to happen more and they do pay to have the required equipment fitted.
Ultimately we all operate in the same sky, why should Gliders (which is what this thread is about) have any special right NOT to pay for it?
It's a minority sport after all.
Bigchopper, said
What are they doing there in the first place?
) to go Newcastle direct Aberdeen rather than going...TILNI TALLA PERTH ADN. It's going to happen more and they do pay to have the required equipment fitted.Ultimately we all operate in the same sky, why should Gliders (which is what this thread is about) have any special right NOT to pay for it?
It's a minority sport after all.
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A friend of mine owns land with a public footpath across it. I am going to suggest that he charges walkers for the privilege of enjoying HIS countryside. After all, walkers are a minority, so why shouldn't they pay for the upkeep of the fences and gates that make their journey safe!
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It's a minority sport after all.
The sky belongs to everyone, yes. So why do we have to pay for it when WE don't need it?
Lets put it another way.. Do you believe that, because this is for the benefit of CAT (and it IS, lets face it!), that the airliners should be subsidising this? If so it would be an easier pill to swallow, but it still doesn't help the folk who do not and cannot have a suitable power supply.
Just coming on here and ranting about the 'Safety Benefits' is not good enough...it is just a very good political reason/excuse to exercise some corporate muscle....
...any special right NOT to pay for it?
Last edited by Mr_Bigchopper; 8th May 2008 at 21:42.
minority sport?
It's a minority sport after all.
8,000 glider pilots in the UK, how many airline pilots that are not glider pilots? Around 3,000 gliders. How many aeroplanes?
UK is the world no 1 ranked country for competition gliding, one of the very few sports Britain is good at.
UK junior gliding team recently scored 1st,2nd and 3rd in junior world gliding champs, how many other sports field such a strong junior team? In recent years the UK has scooped around 50% of the medals at world and European level.The BGA is very proud of its youth training, will the transponder bill force them to cut this ? I guess kids of this generation dont need to grow up being air minded and experiencing the beauty and wonder of exploring the sky. They could always just getting drunk and do drugs like the other kids.
In terms of airsport, gliding is far from a minority!
b b
Last edited by bad bear; 9th May 2008 at 07:16.
on a lighter note
In the case of some of the East Coast stuff it's simply much more economical (and environmentally friendly ) to go Newcastle direct Aberdeen rather than going...TILNI TALLA PERTH ADN. It's going to happen more and they do pay to have the required equipment fitted.
Now the military have transponders and radar and last time I looked at airprox reports they were still getting close to you environmentally friendly risk takers on the east coast, so how will gliders fitting transponders lessen that risk? Gliders are not in that mix but very fast military types most certainly are and it can be quite difficult to keep out of their way with or without transponders and ACAS. There is a good reason why P18 is not H24 and is nothing to do with gliding.
ComJam, if you read the airprox reports on that route you might reconsider your choice. Like many others you seem to ignore real risk when it suites you and blow up perceived risk beyond all reasonable proportions. Do you really think you could reliably out manoeuvre a military jet if you were to encounter one and is that what you should really be doing in this super safe modern world ?
b b
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Thankyou, the NCL to ADN route was being used as an example of how it can be much more economical to route "off airways". But, then, I think you knew that really...
Oh but gliders ARE in that mix, over Northumberland, an extremely busy bit of airspace, with Gliders, Light Aircraft, Military fast-jets and the ocassional "off route" medium commercial aircraft. Only one of these types does not have a transdonder fitted (generally, i know not ALL light aircraft have).
With fast military aircraft it is not "difficult to keep out of their way...with ACAS" it gives ample warning, even a simple TCAD system is sufficient IF the threat is squwaking.
If by "real risk" you mean operating outside CAS, it's not because it suits me, it's because it's my job. Not all "commercial" aircraft are involved in ferrying punters from A to B. Some of us have tasks to fly that require us to be outside CAS. How else am I going Flight Check the SAB VOR or the Inverness ILS or the Doncaster anything?
Far from "blowing up a perceived risk" i'm acknowledging a known risk. I've had late sightings of gliders while on task and I've had TCAD / TCAS alerts on Military fast movers....the latter is far less concerning because the alerting systems make you aware of the threat nice and early. There is then no need to "out-manoeuvre" it as you are fully aware of where it is and becoming visual with it is much easier.
so how will gliders fitting transponders lessen that risk? Gliders are not in that mix but very fast military types most certainly are and it can be quite difficult to keep out of their way with or without transponders and ACAS
With fast military aircraft it is not "difficult to keep out of their way...with ACAS" it gives ample warning, even a simple TCAD system is sufficient IF the threat is squwaking.
Like many others you seem to ignore real risk when it suites you and blow up perceived risk beyond all reasonable proportions.
Far from "blowing up a perceived risk" i'm acknowledging a known risk. I've had late sightings of gliders while on task and I've had TCAD / TCAS alerts on Military fast movers....the latter is far less concerning because the alerting systems make you aware of the threat nice and early. There is then no need to "out-manoeuvre" it as you are fully aware of where it is and becoming visual with it is much easier.
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On 7 May, ComJam wrote
‘The point is: GLIDERS WITHOUT ANY TYPE OF TRANSPONDER ARE MORE OF A DANGER THAN GLIDERS WITH ONE......you cannot possibly disagree with that, therefore they should all have them...it's a total "no brainer"’
But not even the CAA is proposing that ‘they should all have them’.
Option 3 is to include gliders in all SSR transponder carriage regulations. Leaving aside any locally-negotiated exceptions, when taken with option 1 the effect would be to require gliders to operate a Mode S transponder when in any controlled airspace, or when above FL100, or when in any Transponder Mandatory Zones (TMZ), but not otherwise.
So it looks as if the CAA disagrees with ComJam.
‘The point is: GLIDERS WITHOUT ANY TYPE OF TRANSPONDER ARE MORE OF A DANGER THAN GLIDERS WITH ONE......you cannot possibly disagree with that, therefore they should all have them...it's a total "no brainer"’
But not even the CAA is proposing that ‘they should all have them’.
Option 3 is to include gliders in all SSR transponder carriage regulations. Leaving aside any locally-negotiated exceptions, when taken with option 1 the effect would be to require gliders to operate a Mode S transponder when in any controlled airspace, or when above FL100, or when in any Transponder Mandatory Zones (TMZ), but not otherwise.
So it looks as if the CAA disagrees with ComJam.
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Well I would disagree, Mr Radar.
I know of someone who has successfully completed a return trip to the south of France from Scotland "sans transpondeur" - VFR all the way, but helpful controllers in CTRs and a bit of prior notice and a lunch emergency .... and it was perfectly feasible.
No reason why you can't have VFR routes in Class D airspace - such as the entry/exit lanes at Glasgow. Or in SVFR routes in Jersey/Guernsey CTAs.
Mandatory is overkill.
I know of someone who has successfully completed a return trip to the south of France from Scotland "sans transpondeur" - VFR all the way, but helpful controllers in CTRs and a bit of prior notice and a lunch emergency .... and it was perfectly feasible.
No reason why you can't have VFR routes in Class D airspace - such as the entry/exit lanes at Glasgow. Or in SVFR routes in Jersey/Guernsey CTAs.
Mandatory is overkill.
Mandatory carraige in Controlled Airspace or above FL100 but with agreed exemptions, be that through the use of Letters of Agreement and RA(T)s, published VFR routes and conditions attached, or Prior Permission Required from the ATC unit involved if not either of those. Some of that will help gliders, some won't.
I am not sure that the Emergency Lunch exemption will catch on in the UK. The food at UK airfields is too bad
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I am not sure that the Emergency Lunch exemption will catch on in the UK. The food at UK airfields is too bad
I won't be able to guarantee your survival.
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Mode s from a non expert
I'm just getting up to speed on this mode s stuff because i'm just about ready for my first cross country. so this post will be devoid of techie talk since I don't know any
The problems as I see it (keeping my ears tuned around the (gliding) club are
1) cost
2) power consumption
3) time scales
4) perception of the future
Cost/power/timescales - well someone said in an earlier post "I'm sure someone will come up with a reasonably priced piece of kit eventually" OK - but the problem is there's a deadline to all of this and "eventually" might be too late to stop me (and many others) having to pay more than my 30 yr old glider is worth. I understand the safety concerns- being part of the explosives industry we are awash with health and safety regs to the point where a show previously costed at £1500 now costs around £7,500 to avoid a possible accident where the risk is estimated at around 8 million to 1, not quite as bad as trying to win the lottery but getting close. Has anyone actually done a cost versus risk analysis. How many prox's, how many hits involving gliders. If the current status quo was maintained, what would be the risk to those 200 passsengers mentioned in an earlier post
But the main worry in all I hear is more to do with the future and what might happen. We hear rumours that the budget airline community would dearly love to be able to fly in straight lines between regionals. So the big question is - is this the thin end of the wedge? is our sport about to be "control Airspaced" out of existence? Can anyone give assurances that gliding as a sport will still be around in 20 yrs time
BTW - We have been told that those who are to gain commercially from these new measures will be footing the bill for implementation, so can anyone tell me who I send my invoice to for my shiny new transponder
The problems as I see it (keeping my ears tuned around the (gliding) club are
1) cost
2) power consumption
3) time scales
4) perception of the future
Cost/power/timescales - well someone said in an earlier post "I'm sure someone will come up with a reasonably priced piece of kit eventually" OK - but the problem is there's a deadline to all of this and "eventually" might be too late to stop me (and many others) having to pay more than my 30 yr old glider is worth. I understand the safety concerns- being part of the explosives industry we are awash with health and safety regs to the point where a show previously costed at £1500 now costs around £7,500 to avoid a possible accident where the risk is estimated at around 8 million to 1, not quite as bad as trying to win the lottery but getting close. Has anyone actually done a cost versus risk analysis. How many prox's, how many hits involving gliders. If the current status quo was maintained, what would be the risk to those 200 passsengers mentioned in an earlier post
But the main worry in all I hear is more to do with the future and what might happen. We hear rumours that the budget airline community would dearly love to be able to fly in straight lines between regionals. So the big question is - is this the thin end of the wedge? is our sport about to be "control Airspaced" out of existence? Can anyone give assurances that gliding as a sport will still be around in 20 yrs time
BTW - We have been told that those who are to gain commercially from these new measures will be footing the bill for implementation, so can anyone tell me who I send my invoice to for my shiny new transponder
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A bike is a hazard
Well some would argue, some idiot driving a fast car on a country lane is the hazard!!
country lanes are for horses and cyclists urban roads and motoways are for fast cars
airways are for your commercial fast jets ...........and .......
country lanes are for horses and cyclists urban roads and motoways are for fast cars
airways are for your commercial fast jets ...........and .......
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Only Civil Servants would want to crowd air traffic into narrow airways when nowadays [with seriously accurate navigation systems available] aircraft could file their intended routes as they were taking off and a computer could calculate in advance any potential conflicts. That plus inbuilt proximity warning systems should help safety. 100% safety is frankly impossible, only the present PC biased expect that.
That is for the big boys however. For the minnows [who mainly fly VFR for fun only] Mode 'S' is a real pain in the ar*e, literally, as our gonads are rarely more than a few feet away from the transmitter aerial [200 + watts]. Sophisticated sailplanes will have to carry less water and more battery power if they want to cross airways IMHO.
The thought of bimbling PowerChute pilots at 1000 feet sitting on Mode 'S' gear seems utter stupidity.
BTW Not only Sailplanes win World Championships - UK Microlights do too!
a sample http://www.czechinfo.aero/wmc.aspx?lokID=2
That is for the big boys however. For the minnows [who mainly fly VFR for fun only] Mode 'S' is a real pain in the ar*e, literally, as our gonads are rarely more than a few feet away from the transmitter aerial [200 + watts]. Sophisticated sailplanes will have to carry less water and more battery power if they want to cross airways IMHO.
The thought of bimbling PowerChute pilots at 1000 feet sitting on Mode 'S' gear seems utter stupidity.
BTW Not only Sailplanes win World Championships - UK Microlights do too!
a sample http://www.czechinfo.aero/wmc.aspx?lokID=2
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Caa Unanswered Questions
The following e mail, that is now posted on a number of web sites, was sent to the CAA two weeks ago and appears to remain unanswered.
Did the CAA fully consider all the issues raised in the questions before formulating their four proposals and the consultation document?
Will they reply in time for consultees to consider their answers?
Dear Mode S Team
The consultation documents & meetings have so far not produced answers or updates on your web site that address the questions below. Would you please provide answers in good time for carefully considered responses to the consultation?
AIRSPACE INFRINGEMENTS
The CAA states that “One of the most significant current safety risks to UK aviation is the inadvertent or unauthorised penetration of controlled and reserved airspace, and it is a major issue currently being considered by the Airspace and Safety Initiative.”(ASI)
The CAA subsequently states “The infringement of Red Arrows airspace in 2005 & 2006, and the subsequent cancellation of certain displays, left many paying spectators particularly disgruntled.”
The following statistics for Infringements resulting in Mandatory Occurrence Reports (MOR’s) for the years 2002 to 2007 is not in included in the Consultation document nor indeed is any explanation of the dramatic reduction in MOR’s of a severity to require investigation.
By complete contrast NATS reports over 600 Infringements for 2007.
Some of these are said to result in “reduced separation”. This would appear to confirm that the safety layer provided by current radar separation standards is very effective.
Q1 A Bearing in mind the recent year on year reductions in Airspace Infringement MOR’s of a severity to warrant investigation, what evidence of specific risk is the CAA using to opine that – “One of the most significant current safety risks to UK aviation is the inadvertent or unauthorised penetration of controlled and reserved airspace ”
B How many unauthorised, as opposed to inadvertent, penetrations of controlled and reserved airspace by aircraft operating transponders are represented in the above figures?
Q2 As the Red Arrowsinfringements are included in this consultation document they are presumably considered very relevant to transponder carriage. What evidence does the CAA have that the quoted infringements of Red Arrows airspace –
(i) could have been prevented by transponder carriage
OR
(ii) cancellation of the shows avoided by transponders
Q3 Which of the four proposed Options does the CAA believe could have avoided the Red Arrows infringements and/or ensured the shows could commence?
Q4 What vertical, horizontal and risk parameters does NATS apply in recording an airspace infringement?
Q5 What evidence and explanation does the CAA have to account for the 3-year trend of significant annual reductions in Infringement MORs requiring Investigation?
Q6 There are no recommendations from the ASI included in the Consultation document. What formal recommendations have the ASI made to DAP regarding transponders?
Q7 Please supply a copy of the relevant ASI reports & recommendations.
Q8. If there are no relevant reports & quantified recommendations from the ASI, what is the justification for the CAA to pre empt these with proposals for extended transponder carriage as a necessary solution to Airspace Infringements?
Q9 What recent evidence, does the CAA have, of glider Airspace Infringements resulting in Mid Air Collisions, MOR’s or Airprox reports that would justify, in terms of proportionality, gliders being included in the mandating of transponders in TMZs created to address Airspace Infringement risks?
MODE S Consultation Document – Annex E lists “Relevant AAIB & UKAB Reports & Recommendations.”
Annex E Item 1.Lists 16 “examples of UKAB Airprox reports ”
Two of these relate to the uninvented Low Power transponder for gliders and are also represented in Item 2. This leaves 14 examples of which none of the discussion & comment resulted in a formal “Safety Recommendation” relating to transponders. (To put this in context - In the last 10 years there have been over 1500 Airprox reports & the UKAB has issued 84 formal Safety Recommendations)
Airprox no. 175/05 is one of the “relevant” examples cited by the CAA.
The only reference to transponders in this report is a comment by the PA28 pilot involved in the Airprox – “ He opined that it would probably help considerably if gliders were any other colour but white or had radios and transponders so they could participate in ATC.”
The report subsequently states - “It was the unanimous view of the Board that this incident provided another example of the urgent requirement for the development of electronic collision warning systems and their fitment to light aircraft and gliders”.
The CAA has repeatedly quoted Airprox reports and recommendations to justify its proposals. In particular it states in 12.5 “The CAA must consider and, where appropriate, act upon relevant reports and recommendations from such bodies as the Air Accident Investigation Branch (AAIB) and the UK Airprox Board (UKAB).”
Q10 As both the glider and the aircraft were visible on Radar and Transponders do not provide electronic collision warning between gliders and light aircraft; why specifically does the CAA cite this report to be relevant to its Transponder policies and options?
Q11 What “urgent” action did the CAA take to promote the development of collision warning systems suitable for fitment to light aircraft and gliders as a result of this “relevant” Airprox recommendation?
Annex E Item 3. says - “The AAIB has made a recommendation to the CAA concerning the use of SSR transponders with altitude information (AAIB Recommendation 99-34)”
This recommendation dates from 1999. In fact it reads – “The CAA should include in its safety programme the following advice (6 items are listed) to GA operators who plan to use the low level airspace:
d. The routine use of the radar transponder, including height information.” (The other five suggestions do not relate to transponders.)
This is “advice” in relation to a nine-year-old safety presentation not a recommendation to “mandate” any of the CAA’s transponder proposals.
Not mentioned at all are AAIB Recommendations 2005-06 & 2005-08 (both six years later) in relation to glider, helicopter and microlight collision fatalities–
2005-06 “It is recommended that the CAA should initiate further studies into ways of improving the conspicuity of gliders and light aircraft, to include visual & electronic surveillance means, and require the adoption of measures that are likely to be cost effective in improving conspicuity.”
2005-08 “It is recommended that the CAA should promote international co-operation and action to improve the conspicuity of gliders and light aircraft through visual and electronic methods.”
The CAA repeatedly rejected these recommendations stating - “………particularly in the light of impending wider transponder carriage.”
Q12 How would the CAA’s “wider transponder carriage” proposals have provided the necessary electronic conspicuity to minimise the risk of these collisions and future similar collisions?
Q13 Is the CAA now prepared to take concerted action on these AAIB recommendations and the recommendation in Airprox report 175/05?
Annex E Item 2. Says “The UKAB has issued a safety recommendation concerning the carriage and operation of transponders in gliders (UKAB safety recommendation 186/05-02)” –
186/05-02 (3 years ago) reads - “The CAA should continue to promote and with renewed urgency the production of a lightweight transponder and, when available, consider mandating its carriage and use in gliders.”
In the December 2007 update of Airprox 186/05-02 published by the UKAB, the CAA states – “Work on LPST development by several companies continues.”
In Para 3.5 of “The Full RIA for a proposal for Phase 1” published shortly before the Phase 2 Consultation, the CAA states “The LPST is undoubtedly a significant element of the proposals and the CAA has been working with industry for several years to encourage the development of a transponder suitable for these types of aircraft.”
All my attempts to pre-order a low power transponder for my glider have been unsuccessful and AFE Oxford (Transponder retailers) advise that there are no Companies developing such equipment.
Q14 Who are the companies the CAA refers to its December 2007 update?
Q15 What evidence is there of the current stage of development of Low Power transponders?
Q16 Does the CAA now have any evidence of any trials relating to Low Power transponders that are not mentioned in the consultation document?
Q17 If the “significant element” of the CAA’s phased proposals (i.e. LPST) is not being developed, then phases towards a widespread safety layer depending on ACAS in Class G Airspace is severely flawed. What justification is there to implement the Phase 2 Options now, and impose significant costs on GA, at a time that the full potential of other collision warning systems, i.e. available and developing GPS based collision warning & data link systems, usable by aircraft for which there is no transponder, have not been thoroughly re-considered and evaluated?
MODE S Consultation Document Para 12.5
“Moreover, the UKAB has previously advised the CAA that it fully supports the proposals to mandate the equipage of Mode s transponders on all aircraft operating in the UK FIR to the maximum extent possible as permitted by available technology.”
The Airprox Board has never published this as a safety recommendation.
Neither the CAA nor the Airprox Board has published the document containing this advice.
Q18 Please supply a copy of the full document containing this recommendation from the Airprox Board in order that it can be considered in context.
The CAA’s Objectivity in relation to transponders.
Consultation document Page vi – “However, the CAA has four other key priority areas in the use of SSR transponders that it considers should be adopted in the next phase of any expansion in the use of Mode – S.”
In considering the objectivity & credence of the CAA’s proposed Phase 2 Transponder priorities and timescale it is pertinent to consider whether the CAA is prone to overstate the necessity of its transponder proposals.
In the 2006 transponder consultation document the CAA states -
“As safety is the highest priority in aviation any safety improvements will, therefore need to be put in place before air traffic levels can be allowed to increase.”
Q19 What measures did the CAA or DfT implement to prevent Air traffic levels increasing?
Q20 How many CAT operators has the CAA or DfT prevented from flying in Class G Airspace due to the lack of safety improvements?
Q21 How many CAT operators have notified the CAA or DfT that they will not commence operations or increase operations through class g airspace until there are further safety improvements?
OPTION 1
The Phase 1 mandate of Mode-s transponders has ensured that radar spectrum capacity will not be exceeded and the use of Mode a/c transponders will not increase but instead decrease.
The CAA says that Mode-s is backwards and forwards compatible with Mode A/C.
Mandating Class D airspace, which already provides an ATC “known environment”, will burden owners of Mode A/C equipped aircraft to change to mode-s and effectively exclude numerous recreational aircraft for which there are no mode s transponder.
Q22 What key safety benefits would mode-s provide over Mode A/C in the already known environment of Class D airspace?
Q23 What measures could the CAA implement to ensure that aircraft unable to carry Mode S would not be unnecessarily denied access to Class D Airspace?
Thank you
Martin Breen
Did the CAA fully consider all the issues raised in the questions before formulating their four proposals and the consultation document?
Will they reply in time for consultees to consider their answers?
Dear Mode S Team
The consultation documents & meetings have so far not produced answers or updates on your web site that address the questions below. Would you please provide answers in good time for carefully considered responses to the consultation?
AIRSPACE INFRINGEMENTS
The CAA states that “One of the most significant current safety risks to UK aviation is the inadvertent or unauthorised penetration of controlled and reserved airspace, and it is a major issue currently being considered by the Airspace and Safety Initiative.”(ASI)
The CAA subsequently states “The infringement of Red Arrows airspace in 2005 & 2006, and the subsequent cancellation of certain displays, left many paying spectators particularly disgruntled.”
The following statistics for Infringements resulting in Mandatory Occurrence Reports (MOR’s) for the years 2002 to 2007 is not in included in the Consultation document nor indeed is any explanation of the dramatic reduction in MOR’s of a severity to require investigation.
year (note 1)
infringements (note 2)
ARE investigations (note 3, note 4)
as % of MOR infringements (note 5)
Formal Caution (note 4, note 6, note 7)
Prosecutions (note 7, note 8)
2000
344
9
2.62%
0
5
2001
314
13
4.14%
0
9
2002
326
44
13.50%
4
17
2003
376
51
13.56%
15
10
2004
341
45
13.20%
15
8
2005
517
52
10.06%
22
5
2006
630
40
6.35%
19
5
2007
267
3
1.12%
4
1
By complete contrast NATS reports over 600 Infringements for 2007.
Some of these are said to result in “reduced separation”. This would appear to confirm that the safety layer provided by current radar separation standards is very effective.
Q1 A Bearing in mind the recent year on year reductions in Airspace Infringement MOR’s of a severity to warrant investigation, what evidence of specific risk is the CAA using to opine that – “One of the most significant current safety risks to UK aviation is the inadvertent or unauthorised penetration of controlled and reserved airspace ”
B How many unauthorised, as opposed to inadvertent, penetrations of controlled and reserved airspace by aircraft operating transponders are represented in the above figures?
Q2 As the Red Arrowsinfringements are included in this consultation document they are presumably considered very relevant to transponder carriage. What evidence does the CAA have that the quoted infringements of Red Arrows airspace –
(i) could have been prevented by transponder carriage
OR
(ii) cancellation of the shows avoided by transponders
Q3 Which of the four proposed Options does the CAA believe could have avoided the Red Arrows infringements and/or ensured the shows could commence?
Q4 What vertical, horizontal and risk parameters does NATS apply in recording an airspace infringement?
Q5 What evidence and explanation does the CAA have to account for the 3-year trend of significant annual reductions in Infringement MORs requiring Investigation?
Q6 There are no recommendations from the ASI included in the Consultation document. What formal recommendations have the ASI made to DAP regarding transponders?
Q7 Please supply a copy of the relevant ASI reports & recommendations.
Q8. If there are no relevant reports & quantified recommendations from the ASI, what is the justification for the CAA to pre empt these with proposals for extended transponder carriage as a necessary solution to Airspace Infringements?
Q9 What recent evidence, does the CAA have, of glider Airspace Infringements resulting in Mid Air Collisions, MOR’s or Airprox reports that would justify, in terms of proportionality, gliders being included in the mandating of transponders in TMZs created to address Airspace Infringement risks?
MODE S Consultation Document – Annex E lists “Relevant AAIB & UKAB Reports & Recommendations.”
Annex E Item 1.Lists 16 “examples of UKAB Airprox reports ”
Two of these relate to the uninvented Low Power transponder for gliders and are also represented in Item 2. This leaves 14 examples of which none of the discussion & comment resulted in a formal “Safety Recommendation” relating to transponders. (To put this in context - In the last 10 years there have been over 1500 Airprox reports & the UKAB has issued 84 formal Safety Recommendations)
Airprox no. 175/05 is one of the “relevant” examples cited by the CAA.
The only reference to transponders in this report is a comment by the PA28 pilot involved in the Airprox – “ He opined that it would probably help considerably if gliders were any other colour but white or had radios and transponders so they could participate in ATC.”
The report subsequently states - “It was the unanimous view of the Board that this incident provided another example of the urgent requirement for the development of electronic collision warning systems and their fitment to light aircraft and gliders”.
The CAA has repeatedly quoted Airprox reports and recommendations to justify its proposals. In particular it states in 12.5 “The CAA must consider and, where appropriate, act upon relevant reports and recommendations from such bodies as the Air Accident Investigation Branch (AAIB) and the UK Airprox Board (UKAB).”
Q10 As both the glider and the aircraft were visible on Radar and Transponders do not provide electronic collision warning between gliders and light aircraft; why specifically does the CAA cite this report to be relevant to its Transponder policies and options?
Q11 What “urgent” action did the CAA take to promote the development of collision warning systems suitable for fitment to light aircraft and gliders as a result of this “relevant” Airprox recommendation?
Annex E Item 3. says - “The AAIB has made a recommendation to the CAA concerning the use of SSR transponders with altitude information (AAIB Recommendation 99-34)”
This recommendation dates from 1999. In fact it reads – “The CAA should include in its safety programme the following advice (6 items are listed) to GA operators who plan to use the low level airspace:
d. The routine use of the radar transponder, including height information.” (The other five suggestions do not relate to transponders.)
This is “advice” in relation to a nine-year-old safety presentation not a recommendation to “mandate” any of the CAA’s transponder proposals.
Not mentioned at all are AAIB Recommendations 2005-06 & 2005-08 (both six years later) in relation to glider, helicopter and microlight collision fatalities–
2005-06 “It is recommended that the CAA should initiate further studies into ways of improving the conspicuity of gliders and light aircraft, to include visual & electronic surveillance means, and require the adoption of measures that are likely to be cost effective in improving conspicuity.”
2005-08 “It is recommended that the CAA should promote international co-operation and action to improve the conspicuity of gliders and light aircraft through visual and electronic methods.”
The CAA repeatedly rejected these recommendations stating - “………particularly in the light of impending wider transponder carriage.”
Q12 How would the CAA’s “wider transponder carriage” proposals have provided the necessary electronic conspicuity to minimise the risk of these collisions and future similar collisions?
Q13 Is the CAA now prepared to take concerted action on these AAIB recommendations and the recommendation in Airprox report 175/05?
Annex E Item 2. Says “The UKAB has issued a safety recommendation concerning the carriage and operation of transponders in gliders (UKAB safety recommendation 186/05-02)” –
186/05-02 (3 years ago) reads - “The CAA should continue to promote and with renewed urgency the production of a lightweight transponder and, when available, consider mandating its carriage and use in gliders.”
In the December 2007 update of Airprox 186/05-02 published by the UKAB, the CAA states – “Work on LPST development by several companies continues.”
In Para 3.5 of “The Full RIA for a proposal for Phase 1” published shortly before the Phase 2 Consultation, the CAA states “The LPST is undoubtedly a significant element of the proposals and the CAA has been working with industry for several years to encourage the development of a transponder suitable for these types of aircraft.”
All my attempts to pre-order a low power transponder for my glider have been unsuccessful and AFE Oxford (Transponder retailers) advise that there are no Companies developing such equipment.
Q14 Who are the companies the CAA refers to its December 2007 update?
Q15 What evidence is there of the current stage of development of Low Power transponders?
Q16 Does the CAA now have any evidence of any trials relating to Low Power transponders that are not mentioned in the consultation document?
Q17 If the “significant element” of the CAA’s phased proposals (i.e. LPST) is not being developed, then phases towards a widespread safety layer depending on ACAS in Class G Airspace is severely flawed. What justification is there to implement the Phase 2 Options now, and impose significant costs on GA, at a time that the full potential of other collision warning systems, i.e. available and developing GPS based collision warning & data link systems, usable by aircraft for which there is no transponder, have not been thoroughly re-considered and evaluated?
MODE S Consultation Document Para 12.5
“Moreover, the UKAB has previously advised the CAA that it fully supports the proposals to mandate the equipage of Mode s transponders on all aircraft operating in the UK FIR to the maximum extent possible as permitted by available technology.”
The Airprox Board has never published this as a safety recommendation.
Neither the CAA nor the Airprox Board has published the document containing this advice.
Q18 Please supply a copy of the full document containing this recommendation from the Airprox Board in order that it can be considered in context.
The CAA’s Objectivity in relation to transponders.
Consultation document Page vi – “However, the CAA has four other key priority areas in the use of SSR transponders that it considers should be adopted in the next phase of any expansion in the use of Mode – S.”
In considering the objectivity & credence of the CAA’s proposed Phase 2 Transponder priorities and timescale it is pertinent to consider whether the CAA is prone to overstate the necessity of its transponder proposals.
In the 2006 transponder consultation document the CAA states -
“As safety is the highest priority in aviation any safety improvements will, therefore need to be put in place before air traffic levels can be allowed to increase.”
Q19 What measures did the CAA or DfT implement to prevent Air traffic levels increasing?
Q20 How many CAT operators has the CAA or DfT prevented from flying in Class G Airspace due to the lack of safety improvements?
Q21 How many CAT operators have notified the CAA or DfT that they will not commence operations or increase operations through class g airspace until there are further safety improvements?
OPTION 1
The Phase 1 mandate of Mode-s transponders has ensured that radar spectrum capacity will not be exceeded and the use of Mode a/c transponders will not increase but instead decrease.
The CAA says that Mode-s is backwards and forwards compatible with Mode A/C.
Mandating Class D airspace, which already provides an ATC “known environment”, will burden owners of Mode A/C equipped aircraft to change to mode-s and effectively exclude numerous recreational aircraft for which there are no mode s transponder.
Q22 What key safety benefits would mode-s provide over Mode A/C in the already known environment of Class D airspace?
Q23 What measures could the CAA implement to ensure that aircraft unable to carry Mode S would not be unnecessarily denied access to Class D Airspace?
Thank you
Martin Breen
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Why won't the CAA answer the very simple questions?
Herewith below the CAA response but no answers.
Why won't it be possible for the CAA to answer the very simple questions they have been asked?
They repeatedly give their "opinion" in the Consultation document and all they are being asked for is the basis upon which, and evidence on which they have based their statements in various documents and their stated opinion.
How can a consultee respond to the consultation in a valid way if the CAA have not provided relevant evidence in the consultation document and decline to answer simple questions.
Why can't they name the Companies that they claim are devoloping Low power Transponders that they claim are a "significant part" of their proposals?
Why can't they clearly state whether they have evidence of any relevant trials of low power transpnders?
Why is the CAA proposing Transponder legislation to address "Airspace Infringements" when they have not yet had any formal recommendations from the ASI that was set up to review & make recommendations to addess Airspace Infringements?
Why can't they explain the relevance of the Red Arrows references in the consultaion document.
Why can't they provide the MOR figures they are using and account for the trends in them?
Why can't they give the vertical, horizontal and risk parameters used by NATS to log an airspace infringement?
Why can't they provide the document from the Airprox Board that they refer to?
Why can't they just answer all the very simple questions that they have been asked (and presumably have seriously considered in detail before producing proposals for legislation?)- to clarify the basis of their opinions and recommendations.
Will they answer the questions in detail in their proposed response document or will it be necessary for a Judicial Review?
Is this more evasion and obfuscation by the CAA?
Spin Buster
----Original Message----
From: [email protected]
Date: 19/05/2008 15:44
To: <[email protected]>
Subj: RE: Mode S Consultation Queries
It will not be possible to provide a detailed response to all the
issues
raised in your e-mail before the end of the consultation period.
Consequently, we intend to treat your correspondence as a formal
response to the Mode S consultation. Having reviewed all the
responses
to the proposals, we propose to publish a 'Response To Consultees'
document on the CAA web pages. This will provide a synopsis of the
various issues raised alongside a CAA response, which will detail any
resulting future investigation deemed necessary by the Authority.
Should you decide to make a further response to the public
consultation,
you may wish to take note of the following general comments:
1. The 2007 figures quoted on the flyontrack website are not for a
full year.
2. A sample of 200 MORs involving airspace infringement revealed
that approximately 15% of infringing aircraft were not carrying and
operating a transponder.
3. No specific ASI recommendations have been received by the CAA
Mode S team.
4. There are a number of transponders on the market which produce a
peak pulse power of 70W and appear to be suitable for use in many
types
of glider.
5. Studies indicate that the key safety benefits of Mode S over
Mode A/C are reduced radio spectrum interference and improved
detection
of aircraft.
Regards
Mode S Team
Surveillance and Spectrum Management
Directorate of Airspace Policy
UK Civil Aviation Authority
Why won't it be possible for the CAA to answer the very simple questions they have been asked?
They repeatedly give their "opinion" in the Consultation document and all they are being asked for is the basis upon which, and evidence on which they have based their statements in various documents and their stated opinion.
How can a consultee respond to the consultation in a valid way if the CAA have not provided relevant evidence in the consultation document and decline to answer simple questions.
Why can't they name the Companies that they claim are devoloping Low power Transponders that they claim are a "significant part" of their proposals?
Why can't they clearly state whether they have evidence of any relevant trials of low power transpnders?
Why is the CAA proposing Transponder legislation to address "Airspace Infringements" when they have not yet had any formal recommendations from the ASI that was set up to review & make recommendations to addess Airspace Infringements?
Why can't they explain the relevance of the Red Arrows references in the consultaion document.
Why can't they provide the MOR figures they are using and account for the trends in them?
Why can't they give the vertical, horizontal and risk parameters used by NATS to log an airspace infringement?
Why can't they provide the document from the Airprox Board that they refer to?
Why can't they just answer all the very simple questions that they have been asked (and presumably have seriously considered in detail before producing proposals for legislation?)- to clarify the basis of their opinions and recommendations.
Will they answer the questions in detail in their proposed response document or will it be necessary for a Judicial Review?
Is this more evasion and obfuscation by the CAA?
Spin Buster
----Original Message----
From: [email protected]
Date: 19/05/2008 15:44
To: <[email protected]>
Subj: RE: Mode S Consultation Queries
It will not be possible to provide a detailed response to all the
issues
raised in your e-mail before the end of the consultation period.
Consequently, we intend to treat your correspondence as a formal
response to the Mode S consultation. Having reviewed all the
responses
to the proposals, we propose to publish a 'Response To Consultees'
document on the CAA web pages. This will provide a synopsis of the
various issues raised alongside a CAA response, which will detail any
resulting future investigation deemed necessary by the Authority.
Should you decide to make a further response to the public
consultation,
you may wish to take note of the following general comments:
1. The 2007 figures quoted on the flyontrack website are not for a
full year.
2. A sample of 200 MORs involving airspace infringement revealed
that approximately 15% of infringing aircraft were not carrying and
operating a transponder.
3. No specific ASI recommendations have been received by the CAA
Mode S team.
4. There are a number of transponders on the market which produce a
peak pulse power of 70W and appear to be suitable for use in many
types
of glider.
5. Studies indicate that the key safety benefits of Mode S over
Mode A/C are reduced radio spectrum interference and improved
detection
of aircraft.
Regards
Mode S Team
Surveillance and Spectrum Management
Directorate of Airspace Policy
UK Civil Aviation Authority
Join Date: May 2008
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Martins reply to the CAA
To: <[email protected]>
Subj: RE: Mode S Consultation Queries
Dear Mode S Team
Thank you for your brief response to my questions. I note that –
1. You say that the 2007 figures quoted on the flyontrack website are
not for a
full year but you have not provided any alternative figures or
analysis. Please do so.
2. You say that approximately 15% of infringing aircraft were not
carrying and
operating a transponder, which indicates that 85% were doing so, and
never the less infringed Airspace!
3. Your proposals are not based on any recommendations from the
Airspace & Safety Initiative and have pre-empted any recommendations
they might make.
4. The 70w transponder that that you have referred to is unsuitable
for my glider. The additional weight of the transponder and extra
battery reduce the, already very limiting, maximum cockpit load to an
unacceptable figure which is why I asked questions about the Low
Power
Transponder – not the 70w one.
It is not acceptable to me that you should treat my correspondence as
my formal response to the Consultation instead of providing detailed
answers to my questions.
I therefore formally request you to answer my correspondence in
detail
and am copying the correspondence to my MP with a request that he
obtains answers from you in the event that you again choose not to
provide them.
If your current Consultation end date does not allow time for you to
provide the answers in good time for me and other Consultees to
consider them in our formal response then you could extend the
consultation period by the necessary time.
Is it more important to you to close the Consultation on an arbitrary
date rather than allow an extra few days to enable fully considered
responses in the interests of Aviation Safety?
Regardless of any decision that you make in relation to the end date
of the Consultation period I do require my correspondence answered in
detail.
Please confirm that you will provide detailed answers to my
correspondence and state your decision in relation to the end date of
the consultation period.
Regards
Martin Breen,
Subj: RE: Mode S Consultation Queries
Dear Mode S Team
Thank you for your brief response to my questions. I note that –
1. You say that the 2007 figures quoted on the flyontrack website are
not for a
full year but you have not provided any alternative figures or
analysis. Please do so.
2. You say that approximately 15% of infringing aircraft were not
carrying and
operating a transponder, which indicates that 85% were doing so, and
never the less infringed Airspace!
3. Your proposals are not based on any recommendations from the
Airspace & Safety Initiative and have pre-empted any recommendations
they might make.
4. The 70w transponder that that you have referred to is unsuitable
for my glider. The additional weight of the transponder and extra
battery reduce the, already very limiting, maximum cockpit load to an
unacceptable figure which is why I asked questions about the Low
Power
Transponder – not the 70w one.
It is not acceptable to me that you should treat my correspondence as
my formal response to the Consultation instead of providing detailed
answers to my questions.
I therefore formally request you to answer my correspondence in
detail
and am copying the correspondence to my MP with a request that he
obtains answers from you in the event that you again choose not to
provide them.
If your current Consultation end date does not allow time for you to
provide the answers in good time for me and other Consultees to
consider them in our formal response then you could extend the
consultation period by the necessary time.
Is it more important to you to close the Consultation on an arbitrary
date rather than allow an extra few days to enable fully considered
responses in the interests of Aviation Safety?
Regardless of any decision that you make in relation to the end date
of the Consultation period I do require my correspondence answered in
detail.
Please confirm that you will provide detailed answers to my
correspondence and state your decision in relation to the end date of
the consultation period.
Regards
Martin Breen,
Join Date: Jul 2002
Location: united kingdom
Age: 63
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Not sure what you mean by the vertical, horizontal and risk parameters used by NATS...
But if an aircraft is seen in CAS that does not have a clearance, then it is reported. As for risk, the required separation from unknown aircraft and the actions required of controllers are in the public domain - published in the UK MATS PT1 available on the CAA website.
Regards
ZKDLI
But if an aircraft is seen in CAS that does not have a clearance, then it is reported. As for risk, the required separation from unknown aircraft and the actions required of controllers are in the public domain - published in the UK MATS PT1 available on the CAA website.
Regards
ZKDLI
Join Date: May 2008
Location: Belfast
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CAA Unanswered Questions
In post #79, Spin Buster wrote-
‘Why can't they name the Companies that they claim are devoloping Low power Transponders that they claim are a "significant part" of their proposals?
Why can't they clearly state whether they have evidence of any relevant trials of low power transpnders?’
So far, the only low power (30 W or under) transponder that I’ve seen anything about is the Kinetic Avionic Products Limited L.A.S.T (Light Aviation SSR Transponder). Are there any others?
As of May 2005, a Eurocontrol commissioned study reported that ‘Becker, Dittel, Garmin, Unitel and Filser were contacted and only one company, Filser, had plans to develop and license one. This suggests that there is little momentum towards obtaining a solution for light aircraft in the near future.’
The same Study stated that the ‘UK CAA is optimistic that a low power (20W) LAST could be available on the market by 2008’. But the current CAA consultation does not give any information about such a LAST.
Is there a European or international standard for LASTs or LPSTs?
‘Why can't they name the Companies that they claim are devoloping Low power Transponders that they claim are a "significant part" of their proposals?
Why can't they clearly state whether they have evidence of any relevant trials of low power transpnders?’
So far, the only low power (30 W or under) transponder that I’ve seen anything about is the Kinetic Avionic Products Limited L.A.S.T (Light Aviation SSR Transponder). Are there any others?
As of May 2005, a Eurocontrol commissioned study reported that ‘Becker, Dittel, Garmin, Unitel and Filser were contacted and only one company, Filser, had plans to develop and license one. This suggests that there is little momentum towards obtaining a solution for light aircraft in the near future.’
The same Study stated that the ‘UK CAA is optimistic that a low power (20W) LAST could be available on the market by 2008’. But the current CAA consultation does not give any information about such a LAST.
Is there a European or international standard for LASTs or LPSTs?
Last edited by Expedient; 25th May 2008 at 19:42.