Unbelievable!!!!
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Unbelievable!!!!
Applying spectrum pricing to the Aeronautical sector - a second consultation | Ofcom
This is Christmas and not April 1st, but Ofcom don't seem to think so
This is Christmas and not April 1st, but Ofcom don't seem to think so
Remember the last time they produced a similar pile of Crap they were put back in their box. Read it, comment seriously on it; that's not difficult as its written by an ignoramus and a delight to tear apart, then get it in by the deadline.
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Yep, that's true
But they have the gall to ignore everything that was said the last time. With politicos looking for additional income we have to make sure we all respond on this.
But what a time to send out the consultation......
But they have the gall to ignore everything that was said the last time. With politicos looking for additional income we have to make sure we all respond on this.
But what a time to send out the consultation......
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So far I've only read the summary, but initially I can see a question which I don't think is likely to be answered in the main text: "What administrative system is the AIP replacing?"
It would be surprising if no-one paid any form of annual fee for control of a frequency, but how much is being paid now compared to the prices outlined in Year 5 following the AIP?
It would be surprising if no-one paid any form of annual fee for control of a frequency, but how much is being paid now compared to the prices outlined in Year 5 following the AIP?
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At least they seem committed not to charge per aircraft, that's a good thing.
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Just a random thought, but what about introducing a civilianised version of TOCNET for A/G stations? I don't pretend to understand the detailed complexities of the subject, but generally it works like a radio (PTT switches, only one can talk at one time, etc) but it uses VOIP and wireless technology.
I've seen TOCNET work in military applications, so I presume it can be adapted to General Aviation as well.
I've seen TOCNET work in military applications, so I presume it can be adapted to General Aviation as well.
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Again, true
But this would be a cost that gains us nothing. A pound raised that goes to make an airfield more profitable is fine.
A pound raised to go to the dead hand of central government is another thing. Odds are it will go to pay bonuses to the heads of Ofcom
But this would be a cost that gains us nothing. A pound raised that goes to make an airfield more profitable is fine.
A pound raised to go to the dead hand of central government is another thing. Odds are it will go to pay bonuses to the heads of Ofcom
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How many small Airfields will chuck the Ground Station in the bin and go non-radio?
That, to me is the important safety issue. Less radio use at local Airfields in class G airspace can't help either.
That, to me is the important safety issue. Less radio use at local Airfields in class G airspace can't help either.
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This outside my area of expertise, and I'm on the side of the Atlantic which is not affected, but...
I am aware that Canadian aviation regulation or fee change proposals, include an element of the effect on aviation safety, which could result form the change being implemented. Looks to me that making the use of radio for air traffic awareness and separation less viable, creates a definate safety shortcoming, compared to the present situation. Wave that flag at the money grubbers...
What is the cost of an accident (mid air) comapred to not taking that money in fees, which created a disincentive to use the radio?
Just a thought...
Pilot DAR
I am aware that Canadian aviation regulation or fee change proposals, include an element of the effect on aviation safety, which could result form the change being implemented. Looks to me that making the use of radio for air traffic awareness and separation less viable, creates a definate safety shortcoming, compared to the present situation. Wave that flag at the money grubbers...
What is the cost of an accident (mid air) comapred to not taking that money in fees, which created a disincentive to use the radio?
Just a thought...
Pilot DAR
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Couple of thoughts:
- Apart from emergency frequencies, which are free, the height of the fees only seem to be based on the Designated Operational Coverage. That's why a Tower frequency has the same fee as an AFIS or A/G frequency despite the vast difference in type and amount of traffic handled by these services. And anything that's got a DOC that's bigger than that, including things like ATIS and Volmet, get a ridiculously high charge. Doesn't seem fair, does it? This argument obviously works both ways: if you draw things to a logical conclusion then any small A/G station should be able to make a bid for the Heathrow Tower frequency.
- Ofcom seems to think that aviation makes money from these aero frequencies, just like cellphone providers make money from their frequencies. Based on this thinking, they try to apply basic economic principles of scarcity, supply and demand to the spectrum. But this premise is flawed: we don't make money from chatting to each other, we make money by moving stuff and people from one place to another. There are several points in the consultation that can easily be torn apart because of this alone.
- There is no mention whatsoever of "operator frequencies", while these are perhaps the only frequencies with a DOC that's big enough to matter, and where the economic principles of scarcity, supply and demand would work. Not to mention that within the context of a single operator, it would definitely be possible to give up the operator VHF frequency and replace it with a completely different technology (like UHF, cellphone, satphone, ACARS, ADS-B or whatever).
- Apart from emergency frequencies, which are free, the height of the fees only seem to be based on the Designated Operational Coverage. That's why a Tower frequency has the same fee as an AFIS or A/G frequency despite the vast difference in type and amount of traffic handled by these services. And anything that's got a DOC that's bigger than that, including things like ATIS and Volmet, get a ridiculously high charge. Doesn't seem fair, does it? This argument obviously works both ways: if you draw things to a logical conclusion then any small A/G station should be able to make a bid for the Heathrow Tower frequency.
- Ofcom seems to think that aviation makes money from these aero frequencies, just like cellphone providers make money from their frequencies. Based on this thinking, they try to apply basic economic principles of scarcity, supply and demand to the spectrum. But this premise is flawed: we don't make money from chatting to each other, we make money by moving stuff and people from one place to another. There are several points in the consultation that can easily be torn apart because of this alone.
- There is no mention whatsoever of "operator frequencies", while these are perhaps the only frequencies with a DOC that's big enough to matter, and where the economic principles of scarcity, supply and demand would work. Not to mention that within the context of a single operator, it would definitely be possible to give up the operator VHF frequency and replace it with a completely different technology (like UHF, cellphone, satphone, ACARS, ADS-B or whatever).
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This proposal runs totally counter to flight safety. This will encourage, or force, many operators to dump ATIS frequencies or split Twr/App setups in order to ensure financial survival in a sector which is economically precarious at the best of times. Aviation safety is an area which really should be completely isolated from 'market forces'.
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I would guess this would be a point to be raised by the CAA and our representative bodies.
The history of Ofcom's consultations shows they pay lip service to the idea of safety.
The maritime one looks at exempting (or giving a discounted rate) to charitable and life-saving organisations, such as the RNLI.
What they don't see is the need for even small airfields to have a frequency (often shared between a number of airfields anyway) so that we can get the information we need about traffic and weather.
That part of the case I would guess will be very lightweight against the very real financial benefits of selling off the spectrum.
The history of Ofcom's consultations shows they pay lip service to the idea of safety.
The maritime one looks at exempting (or giving a discounted rate) to charitable and life-saving organisations, such as the RNLI.
What they don't see is the need for even small airfields to have a frequency (often shared between a number of airfields anyway) so that we can get the information we need about traffic and weather.
That part of the case I would guess will be very lightweight against the very real financial benefits of selling off the spectrum.
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Personally I think that charging for ATIS and VOLMET is criminal and is a definite risk to safety. Another tax raising/money grabbing attempt thinly disguised as 'market demands and competition'. Pathetic bean-counting ... albeit very big beans .... and we know what big beans generate .....
How many times have you tuned ahead to get ATIS and VOLMET info on a cross-country ? If that has to be charged for .. who pays ? Or will we just call-up FIR sectors and overload them with hundreds of requests for weather info. Or just get out the mobile orbit a phone mast and download the latest METARs ?
Pretty much every user group in the UK, drivers, farmers, sailors, holidaymakers gets relatively accurate realtime weather for free.
Aviation is a damn sight more critical and 'realtime' especially when you are in the air. But it is difficult to access by conventional means when in the air (TV, radio, internet, phone).
So the most safety critical user is the one that ends up paying. That seems rather ironic.
How many times have you tuned ahead to get ATIS and VOLMET info on a cross-country ? If that has to be charged for .. who pays ? Or will we just call-up FIR sectors and overload them with hundreds of requests for weather info. Or just get out the mobile orbit a phone mast and download the latest METARs ?
Pretty much every user group in the UK, drivers, farmers, sailors, holidaymakers gets relatively accurate realtime weather for free.
Aviation is a damn sight more critical and 'realtime' especially when you are in the air. But it is difficult to access by conventional means when in the air (TV, radio, internet, phone).
So the most safety critical user is the one that ends up paying. That seems rather ironic.
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You could make a 'market' analysis of the cost, but you'd have to factor the likelihood of a mid-air with a notional cash value per life lost. That sort of calculation is performed, of course, but it's distasteful to most of us.
Who will pay for the Safetycom frequency?
Tim
Who will pay for the Safetycom frequency?
Tim
In a speech in London to the Reform think-tank, Mr Cameron promised: "With a Conservative Government, Ofcom as we know it will cease to exist.
"Its remit will be restricted to its narrow technical and enforcement roles. It will no longer play a role in making policy."
"Its remit will be restricted to its narrow technical and enforcement roles. It will no longer play a role in making policy."
Notwitshtanding the LAA's request, a large number of individual responses will always carry more weight than a 'co-ordinated response'.
Incidentally, the Ofcon artists are hosting the following meeting in January 2010:
Forthcoming Events
Ofcom will be holding the following events in England in the near future.
Draft Annual Plan 2010/11
Ofcoms England draft Annual Plan 2010/11 event is being held on 18th January 2010 at 3pm until 4pm at Ofcom, Riverside House, 2a Southwark Bridge Road, London, SE1 9HA.
To register your attendance please email [email protected]
Ofcom will be holding the following events in England in the near future.
Draft Annual Plan 2010/11
Ofcoms England draft Annual Plan 2010/11 event is being held on 18th January 2010 at 3pm until 4pm at Ofcom, Riverside House, 2a Southwark Bridge Road, London, SE1 9HA.
To register your attendance please email [email protected]
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In the details of the report (Appendix 7, Annex 8, Figure 4.5) their own figures suggest that at small, "low movement" airfields (they use Dunsfold as an example) the fee will equate to almost £5 per movement.
Can small airfields afford to swallow such a cost? Can they afford to put up their landing fees by a fiver or go non-radio (both putting pilots off visiting and hurting them again)?
They don't seem to think so: "This does not in itself imply that the landing charges under AIP would be unaffordable, just that there would be a discernable impact."
Ali
Can small airfields afford to swallow such a cost? Can they afford to put up their landing fees by a fiver or go non-radio (both putting pilots off visiting and hurting them again)?
They don't seem to think so: "This does not in itself imply that the landing charges under AIP would be unaffordable, just that there would be a discernable impact."
Ali