Mode 'S' mandatory for gliders.

[Spin Buster]

Latest CAA Reply to Martin Breen

Martin prefaced his questions with - "please provide answers in good time for carefully considered
responses to the consultation"

Andy knill has replied that Martins questions "could be interpreted as being your response to the consultation." Andy has again evaded answering the questions - WHY????????

Exactly which part of the phrase "please provide answers in good time for carefully considered responses to the consultation" can be interpreted as being the response to the consultation???

They don't want to answer Martins questions!!!! All the more reason that they should.

Spin Buster




----Original Message----
From: [email protected]
Date: 28/05/2008 11:12
To: <[email protected]>
Subj: FW: Mode S Consultation Queries

Dear Mr Breen

Thank you for your e-mail. First of all, in any consultation there
will
be queries which arise as part of a formal response and these are
dealt
with through the Summary of Responses (SoR) and CAA comments process.
A
consultation is there to elicit answers and information as,
notwithstanding the considerable time spent with user groups prior to
publication, it is recognised that not every facet of a proposal will
be
covered in the document. Indeed, the Better Regulation process is
designed to ensure that individuals and organisations can raise
queries
and provide information during the process. This is then dealt with as
part of the full process so that a submission to Government can cover
these aspects before any decision is taken.

The consultation commenced on 31 January and is due to end on 31 May
08.
The questions, which you submitted on 6 May, could be interpreted as
being your response to the consultation, in which case they would be
dealt with, in conjunction with many others as appropriate, in the SoR
document. However, if this is not your formal response, please submit
the challenges to the consultation document as part of your formal
submission. Your questions will then be dealt with accordingly.

In terms of the length of the consultation, the period given is in
excess of that required and every effort has been made to further
inform
the debate through briefing sessions and media material. Given that
you
raised your queries with less than 4 weeks to run, I do not consider
your demands to be reasonable, particularly as there is an accepted
process for dealing with questions raised through the consultation
process.

I look forward to receiving your formal response.

Regards


Andy Knill

[Spin Buster]

Vertical Horizontal & risk parameters used by NATS

ZKDLI
Airways were established 10 miles wide to allow for navigation errors using NDB's etc. Likewise other Airspace boundaries allow for deviations from the ideal track and provide safety margins.

Radar separation standards also provide significant margins.

These margins are provided to allow for minor errors that reduce the margins without incurring undue risks.

Controlled Airspace boundaries are not drawn to align with ground features that can be used accurately by pilots relying on visual navigation. They are invisible except on moving maps or radar.
It is inevitable that pilots navigating visually will infringe airspace by small amounts whilst using their best endevours to avoid doing so.

Does NATS record an Airspace infringement of 1 foot vertically or horizontally over the line? If not 1 foot then what vertical and horizontal parameters are used?
Is the recording of minor infringements a numbers game ploy to justify more airspace, more air traffic controllers, better pay or is genuine risk a parameter?

Regards
Spin Buster

[mm_flynn]

NATS has recently (last couple of years) changed to recording every infringement they are aware of. They then classify the results of these infringements depending on the impact on traffic in CAS. You can see a summary of this on the flyontrack web site. The classification are broadly
Minor - separation was maintained - 93%
A concern - standard separation was lost - 5%
Serious - The aircraft were quite close - 2%

NATS and the CAA acknowledge clearly that the trend in minor infringements is driven more by reporting than any change in activity.

non-transponder/Mode A only aircraft can only be detected infringing control zones (not areas) unless they full into the A Concern or Serious categories and hence they figure to a much higher proportion in the later two categories than the first one.

With regard to the comment

It is inevitable that pilots navigating visually will infringe airspace by small amounts

that shouldn't be true in general. However, for airports partially embedded in CAS or transiting some of the narrow gaps, the VFR flyer has to be able to navigate to the same precision as a two crew aircraft with PRNAV, and this clearly does result in minor infringements (which is why you see clusters around the London area GA airports).

[Spin Buster]

Airspace Infringements

Thank you mm flynn for pointing me at the FLYONTRACK web site.

It appears that around 98% of NATS reported Airspace infringements are not "serious".
Is reporting them a good use of ATC time?

There is no detailed analysis of the "serious" ones.
Are they all GA pilots? Are they without transponders?
What common factors are there to these "serious" infringement?
Does anyone know where the detailed analysis can be found please?

Flyontrack makes a big thing of the cost of 747's having to go around as a result of Infringements but there are no statistics given for 747 go arounds in these circumstances.
Anyone know how many of these there are per year and how the cost compares with ATC holding delays on the ground and in the air?
I can see one of the LHR holds from my garden and it is in regular use. I can't see the go arounds so cannot comment.
Regards
Spinbuster

[mm_flynn]

Originally Posted by Spin Buster

Thank you mm flynn for pointing me at the FLYONTRACK web site.

It appears that around 98% of NATS reported Airspace infringements are not "serious".
Is reporting them a good use of ATC time?

There is no detailed analysis of the "serious" ones.
Are they all GA pilots? Are they without transponders?
What common factors are there to these "serious" infringement?
Does anyone know where the detailed analysis can be found please?

Flyontrack makes a big thing of the cost of 747's having to go around as a result of Infringements but there are no statistics given for 747 go arounds in these circumstances.
Anyone know how many of these there are per year and how the cost compares with ATC holding delays on the ground and in the air?
I can see one of the LHR holds from my garden and it is in regular use. I can't see the go arounds so cannot comment.
Regards
Spinbuster

I did an analysis of a years worth of serious ones (SSE1 and SSE2) and the results are what you probably would expect.

• Mostly GA and a bit of MIL are the perpetrators.
• 1/3 mode C/S, 1/3 Mode A, 1/3 non-transponding.
• The Mode A only/Non-transponder were either lost, thought they knew were they were but were wrong, or just chose to fly through the airspace (a para- glider in Southampton comes to mind)
• The mode C ones where generally more complex. A couple of 'emergencies' and some foreign pilots (ie. not based in the UK) not understanding the UK system.

The mode C/S ones give good notice of the impending screwup so while they might disrupt flights they generally can be vectored around. It is only if they suddenly do something unexpected that you get an SSE1/2 (i.e. a close shave).

To some of your other questions. Yes it is a good use of time to record all infringements, it is a standard safety management approach to look at the minor events to track if your action plan is reducing the risks of a rare major event.

The scale of time wasted and fuel burned from infringements is going to be small relative to that driven by weather and inadequate runway capacity. But that still doesn't mean it isn't a relevant way of thinking of the impact.

And finally, to put it into proportion, infringements caused about 1/3 of the total serious losses of separation incidents. Level busts was I believe the single biggest issue. Which is why the CAT guys get a constant stream of 'must do better' around compliance with clearances and why the downlink of altitude preselect information on Mode S Enhanced was the first bit to be implemented by NATS.

PS - the 5% that were 'of concern' really are of concern. If a controller allowed to aircraft he was controlling to get that close there would be much paper and probably some retraining at a minimum. The fact this happens with one aircraft that is operating pretty much at random makes it a much more worrying issue for everyone. On top of this the 2% or of close shaves really are very worrying events.

[Spin Buster]

Facinating analysis - thank you once more mm flynn.

If I have understood it-

Over 90% of UK registered aircraft are GA, and they only account for one third of serious losses of separation.
Two thirds are down to professional pilots using ATC in Controlled Airspace.
I am not criticising - mea culpa, having had a FL100/FL110 clearance confusion & level bust - just musing about proportionality.

Of the one third of losses of separation, about two thirds are down to navigational errors.

Moving maps with Airspace warnings are relatively so cheap, low power and readily available for most recreational aircraft that there is scope for dramatically reducing GA Infringements, ATC workload, risks and disruption costs. Prevention being better than cure?
I have two in my glider.
GASCO are encouraging moving maps.

If Notams were provided graphically on an official web site, infringements of temporary airspace, might also be dramatically reduced. An official version of "Notam Map" or similar would help a lot. Even better if the airspace was downloadable into the moving map.

Are TMZ's and extended mode s mandates the best and most proportional answer?

regards
Spin Buster

[cats_five]

Spin Buster, wish you had posted that before I sent my response in! The proportions and comments on moving maps would have been very useful.

[mm_flynn]

Originally Posted by Spin Buster

Facinating analysis - thank you once more mm flynn.

If I have understood it-

Over 90% of UK registered aircraft are GA, and they only account for one third of serious losses of separation.
Two thirds are down to professional pilots using ATC in Controlled Airspace...

That is a reasonably accurate, but potentially misleading summary. The loss of separation incidents are almost exclusively associated with controlled airspace and the amount of GA activity in this airspace will be small relative to the overall population. In addition, exposure (i.e. flight hours) is much more relevant than the number of aircraft registered (a registered but non-flying aircraft is hardly likely to figure in an infringement!).

NATS and the professional pilots are doing a lot of work on training, awareness, expensive new equipment, etc. to help them address the issues in their control. It is not entirely unexpected, given the money they are putting in to address their issues, that there is pressure for GA to invest in technology to help on the issues for which they are responsible.

[PPRuNe Radar]

Over 90% of UK registered aircraft are GA, and they only account for one third of serious losses of separation. Two thirds are down to professional pilots using ATC in Controlled Airspace.

That statistic you make about UK GA also takes no account of the many aircraft which transit the UK each day, or are based here under a different State of Registry. Do UK GA aircraft represent 90% of all the UK movements ?? I doubt it. The GA in the statistics will be for all GA which are involved in a serious loss of separation, regardless of where they are registered.

You can't say either for certain that all the rest are caused by professional pilots. ATC make errors too, authorities make errors, operating agencies make errors. The list is endless.

All you can say is that statistics can tell you whatever you want to hear.

The real fact of the matter is that an infringement of CAS has the potential to result in a mid air collision. Fact. It will only take one, and should that ever occur (God forbid), then you can expect GA in the UK to be severely restricted and penalised in a classic case of bolting the stable door after the horse has bolted. One collision may have been seen as unlucky, but two will place the authorities in the realms of negligence if they have not taken measures such as mandatory surveillance equipment and other technologies to prevent it reoccurring. So they will use a very large sledgehammer to crack the nut ... and GA.

[Dr_Tre]

Minor thread creep................


not in range of any books at the mo, can anyone answer this v.quick question with certainty - at the mo', is a transponder mandatory for class D airspace transit?

just a yes or no will suffice


thanks in advance

[mm_flynn]

Originally Posted by PPRuNe Radar

The real fact of the matter is that an infringement of CAS has the potential to result in a mid air collision. .... One collision may have been seen as unlucky, but two will place the authorities in the realms of negligence if they have not taken measures such as mandatory surveillance equipment and other technologies to prevent it reoccurring. So they will use a very large sledgehammer to crack the nut ... and GA.

While not disagreeing that a mid-air would precipitate action, it is useful to note that, where mid-airs with CAT have occurred (and over the decades there are a number), the authorities have generally reacted in a reasonably sensible and proportionate way (IMHO). Specifically Mode C veils were introduced decades ago in the US following the collision above Cerritos. HOWEVER, unlike the current CAA proposals, there was recognition of what could and could not be achieved at reasonable cost. Hence, the ability for gliders and non-electric aircraft to get exemptions.

The CAA proposal (back to the start of the thread) is to fit a very expensive and, to-date technically unproven (unless someone can post the CAA approval for 'portable' battery powered Mode-S for gliders and microlights), solutions. In addition, the proposed solutions do nothing much for the roughly annual GA/GA or GA/MIL mid-air in the UK. It feels like another case of a disproportionate effort to address one rather remote (but very bad) risk while ignoring the rather more common but less bad risk.

not in range of any books at the mo, can anyone answer this v.quick question with certainty - at the mo', is a transponder mandatory for class D airspace transit?

No - But if you are technically capable of carrying one go and get one with altitude encoding, it makes everyone else's life easier and makes the case less robust for forcing those people who can't down a blind alley - and possibly it will save your life as more people carry ACAS and NATS does actually start to help like providing a much expanded EGLF LARS)

[Dr_Tre]

Thanks for the reply mm_flynn.

You're preaching to the converted here, I'm all for mode C - i was only asking to help settle a 'disagreement'.

[Spin Buster]

PPRUNERadar said -
"You can't say either for certain that all the rest are caused by professional pilots."

Absolutely right and I didn't. Sorry that it was open to interpretation that way.
My intention was to highlight that despite all the regulation associated with CAT operations, only one third of serious infringements would be prevented if all GA aircraft were grounded. Proportionality!

Spin Buster

[PPRuNe Radar]

No doubt about that

[astir 8]

One of the principal arguments put forward by the CAA for increased transponder carriage by GA was a 50% increase in air traffic movements by 2020 which was projected in a Government White Paper published in 2003. That was an increase in commercial traffic, not GA/Gliding.

The newsletter of the Association of European Airlines dated 3rd June rather knocks a hole in that "increased traffic" extrapolation. Stagnation, reduced passenger loads and gloom seems the real current picture. See

http://files.aea.be/news/pr/pr08-019.pdf


I suppose because it appeared after the expiry of the CAA consultation period on 31st May, it won't be counted in the argument

[cats_five]

I'm sure I'm not the only person that has suggested in my response that the projections from 2003 are probably invalid now, given the recent changes in the price of oil. I had no problem finding half-a-dozen CAT bad luck stories to back up my statement.

Of course it will probably cut no ice, but at least I tried.

[rocketmandlgc]

Mode S - A different argument

All, Most of the posts on this topic have been on broadly similar themes. Well here is a different one for everyone's consideration. It actually formed part of my response to the consultation. If anyone wants to come back to me I'm more than happy to engage in the debate, although I only get online every couple of days, so don't expect immediate rfeplies.

Here goes:

My response to the consultation is that – whilst I have some sympathy for, and am in broad agreement in principal for Mode S for everyone, some parts of the aviation community – and gliding in particular - should remain exempt from any phase 2 recommendations, and that these exempt categories be made the subject of a phase 3 implementation.

Here are my reasons:

Economic:

Gliding in particular has been a “first introduction” to aviation for many of our current commercial pilots and the number of commercial pilots required in the future will increase if the government’s white paper on the future of aviation is to be implemented..

Gliding (as opposed to hang or para gliding) will – I believe - continue to be of economic benefit to commercial aviation by providing recruitable material , trained to a very high standard of basic flying skills and aerodynamic knowledge, providing that the gliding community remains as a low cost entry point for potential pilots some of whom would not normally be considered as suitable material for other forms of entry into aviation (RAF for example).

Many gliding clubs are non or low profit making, some turning in annual profits of as little as £10,000. My own club xxxx operates a fleet of 3 x 2-seater training aircraft and 3 single seaters for early solo pilots. To equip these at current prices with currently available equipment would cost (CAA figures) between £18K – 30K – or put another way, 3 years of profit, a 3 year postponement of facilities improvements, building renovation and fleet expansion.

Given that our current letters of agreement with xxxxx work extremely well and there have been no recorded incidents EVER – this seems a very high price to pay for something of (immediate) dubious benefit.
Social

In my last section I stated “…..as a low cost entry point for potential pilots some of whom would not normally be considered as suitable material for other forms of entry into aviation (RAF for example).”

My club (and most other clubs i suspect) is proud to boast amongst its membership, a Postman and a High Court Judge. The effects of your current proposals would be to turn my club into a club of high court judges. The Postman would not be able to afford to continue flying – or at least would have his cross country ambitions curtailed so much that the sport would inevitably lose it’s attraction.

I myself was brought up in an inner city area and, like many concerned citizens, I despair at the lack of facilities available to many young people in our society today. The speed at which we appear to be sinking into an abyss of alcoholism and violence is frightening. A former Archbishop, William Temple once said “What is considered to be exceptional behaviour in one generation has a habit of becoming the “norm” in the next”

It is therefore imperative that minority sports such as Gliding – a sport which encourages the best in both team discipline AND individual endeavour, not only be allowed to continue but encouraged to flourish and grow. This encouragement may be in the form of grants for innovative marketing to the youth culture, and (this is where the CAA might come in) funding of new technology implementations to enable gliding to co-exist with other air traffic with no or little impact on the cost of gliding to the majority of its participants.

One way that can be achieved would be for the Civil Aviation Authority to use it’s influence over government to persuade government to fully fund the research and development of a low power pressure altitude transponder of a suitable size for use in gliders.

By funding the R&D costs, this would enable equipment manufacturers to sell at a reasonable price without having to worry about clawing back the R&D element in what is after all a small limited market. Target price excluding installation would be < £1000 (£995 will do)

Another way would be additionally for the commercial sector to fund the equipping of all club registered 2-seater training aircraft and some single seaters where it could be demonstrated that such single seaters were used for early cross country training.

Conclusion

1) There is time – time to pause, time for a phase three

AS I have stated, OUR Letters of agreement with xxxxx are working well. I suspect other clubs will tell you the same, as I also suspect your own incident stats will tell you. There is no need to rush. Despite increases in commercial traffic since 2003, incident reports are down.

2) As the governing body, the CIVIL Aviation Authority should use its powers to encourage Government to protect Gliding, for the economic and social reasons stated above, by the funding and provision of Mode s equipment for the sport., so that the sport can co-exist with the planned increase in air traffic to 2025

Let’s all pause for reflection, so we can get it right for everyone.

Sincerely,