Is there a low power transponder for flying >15,000 ft?
 

In post #79, Spin Buster quotes the CAA as replying to one of Martin Breen’s questions (about whether a low power transponder is available) as follows-

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.

But do they give an adequate signal above 15,000 ft? Gliders can easily exceed that height in wave at a number of UK sites.

The manual for the Funkwerk Avionics (formerly Filser) TRT800 (150W maximum output transponder; 18.5 dBW (71 watts) peak power at the antenna) gives its maximum flight level as ‘15000 ft.’

Check the manual for the TRT800H.

The Light Aircraft Association's response
 

This has been posted on gliderpilot.net (which had been out of action for some weeks due to a hacker). It's a very thorough and well reasoned response and well worth reading in full.

www.lightaircraftassociation.co.uk/Consultation/ModeS%20Sub%20Docs/LAA%20Draft%20Mode%20S%20Consultation%20Response.pdf

It is a thorough and well reasoned response, but it does contain some misconceptions:

...you discuss the need to operate the UK ground environment in “mixed mode”, that is to say, all radars interrogate in both Mode S and Mode A/C because of safety issues. So all Mode S transponders reply in both modes and we understand this is likely to continue for some years, certainly until 2012 and beyond if equipment programmes are not delivered by then.
Until the day that Mode A/C interrogation is turned off, all Mode S transponders will also respond in Mode A/C. This has not been a problem so far as virtually all aircraft that have fitted Mode S, previously had Mode A/C so the number of units has remained broadly constant.
If all 15,000 aircraft that are now proposed for Mode S fit were to do so by March 2009, they too would respond to Mode A/C interrogation and UK ATC systems would be overwhelmed.

Mixed mode operations are considerably more sophisticated than the author assumes. "All-call" periods, during which Mode A/C interogations are sent, occupy only a small part of the overall cycle. The rest is "roll call", during which the interrogation is selective. Additionally, Mode A/C interrogations sent during that all-call period can be modified (a "short P4") in such a way that a Mode S transponder does not respond.

Thus having 15,000 Mode S transpoder equipped aircraft poses no problem to mixed mode operations -- having 15,000 Mode A/C only transponder equipped aircraft certainly would be more of an issue.

70W transponder, valid for use above 15,000ft?
 

In post 84, cats_five suggested that I should ‘Check the manual for the TRT800H’, but did not give its output.

I had referred (in post #83) to the CAA’s suggestion that a number of transponders on the market produced ‘a peak pulse power of 70W and appear to be suitable for use in many types of glider’. I asked if those transponders gave an adequate signal above 15,000 ft.

I had in fact checked the TRT800H before posting. It is indeed good up to 35,000 ft. But its output is 250 W (125 W at antenna), which is a fair bit above 70W. Gliders really need a LPST.

So I’m still looking for a 70W transponder, good for use above 15,000 ft.

Glider pilots need to wake up and smell the coffee.

About 10 years ago, following the Dunblane shooting, Britain's recreational taget shooting community lost the right to own certain categories of gun.

If glider pilots do not adopt a more cooperative attitude, they could find themselves in the same boat and frankly few people in the community at large would shed many tears for them, since most people are more interested in their sun flights than protecting minority rights.

Like it or not that is the reality.

It would be a real shame if this happened.

The power required to meet regulatory requirements is determined by ceiling and max speed. Lower power is permitted only on aircraft not capable of operating above 15,000 ft and with a maximum crusing speed of 175 kt or less. If you exceed either restriction, the transponder doesn't stop working, it just ceases to meet regulatory requirements.

bookworm wrote-

Indeed. I didn’t suggest otherwise.

But the CAA replied to Martin Breen-
So what are these 70W transponders for high-flying gliders? Who makes them?

Are they even technically feasible?

Incidentally, the only study of the potential radiological effects of Mode S transponders cited by the CAA related to ‘an 80 Watt transponder with typical antenna’ (para. 10.3 of the consultation). And it only used a ‘generic computer model’.

So no one really knows what the radiological effects of, say, a 125W transponder in a glider will be.

There is a certain arrogance coming across on this discussion that seems to be "put up or shut up!" which is not very helpful. The whole idea of a consultation is to get the views from all parties and to reach a position where most parties are in agreement.

For that to be achieved, the pros and cons need to be considered (not disregarded) and an appropriate response developed.

Enforcing something onto someone who may or may not benefit from it without consideration is worthy of a communist state, not a free country, which I believe the UK is!

:=

The question on feasibility is meaningless. The regulatory requirement makes them unsuitable for aircraft flying above 15,000 ft. The CAA's response is correct in that "many types of glider" do not exceed 15,000 ft.

What you need to argue for is a regulatory change to permit the use of 70W equipment above 15,000 ft by gliders. Good luck.

I hardly thibnk this is an appropriate response. Unless of course some jetliner pilot is going to deliberately set out to sideswipe lots of other aircraft out of the sky.

It seem to me as if we have a situation whereby a governing body has already decided how they want to proceed, and have formulated their "options" accordingly. As the light aircraft people have stated, this consultation is badly flawed, does NOT meet government guidelines, is ill conceived and badly thought through with litle or no evidence to support its options and has not given anyone an opportunity to comment on a "do nothing" option.

All the evidence suggests that safety is improving all the time. Proxes are significantly down, I won't re-print the figures - read other posts. The CAA's own figures state that 15% of airspace infrigements involve aircraft without transponders. I would respectfully point out that in reality that means 85% of infringements are by aircraft WITH transponders. So the answer is simple, take out all the transponders and reduce the infringements (I'm kidding of course but I hope you can see the point- the figures just do not make the CAA's case that light aircraft (including gliders) represenrt any kind of threat to other air users,

The only conclusion many of us can come to is that the CAA has recently changed it's name to "Commercial Aviation Authority" and no longer has the best interests of the rest of civil aviation at heart

Oh dear. Just about any type of glider can exceed 15,000 ft if it is flying in decent wave. The CAA should have said that "many glider flights do not exceed 15,00 ft".

However, anyone who wants a Diamond height will have to do so and people have been doing Diamond heights for some considerable time, in all sorts of gliders, not just nice white modern GRP ones.

And quite a few flat-landers (who otherwise might well not need Mode S, depending on what the final outcome is) visit Scotland (or other wave sites) in search of that elusive Diamond height. But not, I suspect, if they have to spend some £4k on getting a transponder fitted.

rocketmandlgc wrote-

The consultation contravenes various provisions of the Government’s Code of Practice on Consultation (September 2005)-

no list of consultees is included (see para. 2.6 of that Code);

there is no glossary, despite the many technical terms (see para. 3.1);

it doesn’t ‘Invite respondents to comment on the extent to which the criteria have been adhered to and to suggest ways of further improving the consultation process’ (see para. 3.9).;

The consultation document should state the … the web address where, the summary of responses will be published (see para. 4.3).

In addition, some parts of the consultation do not satisfy the Principles of Good Regulation (see para. 6.6 of that code), in that they are not proportional or transparent (does any one really know what Option 2 means?).

The code binds UK agencies, such as the CAA, unless Ministers allow departures in exceptional circumstances.

The Code of Practice on Consultation can be found at-
http://www.berr.gov.uk/bre/consultat...page44459.html

the address given at para. 3 in Annex L to the consultation is wrong.

Why does the CAA think that it does not need to bother to comply with the Code?

More to the point, could transponders have prevented any of the non-transponder equiped proxes or infringements? I suspect not - Mode S (if the transponder is turned on) will help find the culprit, but it won't stop them infringing. I read some of the airprox reports and found that the infringements often seemed to involve a pilot who was 'temporarily unsure of his postition' e.g. lost.

The sort of software on a PDA linked to a GPS that most XC glider pilots use might do more to prevent infringements than a transponder, and it can be implemented for less than £100. (free software, 2nd hand GPS & PDA from Ebay) It's also fairly easy to reload the airspace when that changes - downloads are easy to find on the Internet, and are also easy to check against a chart.

It is important to understand why transponders a relevant to 'reducing infringements'. The transponder doesn't change the fact the infringement has happened, but it does help everyone else deal with the fact safely. Also, a non-transponding aircraft can realistically only be detected infringing a Zone (not an area or airway) unless it is also an airprox - because no one can see it happen unless they nearly hit the infringing aircraft! In terms of infringements that were in the 'but for the Grace of God...' camp, they are split about 1/3 no-transponder, 1/3 transponder with no Altitude, and 1/3 Mode C/S. When I looked at it, all of the Mode C/S 'close call' infringements had some complicating factor that resulted in ATC having little time to react.
While people may use this kind of roped together system, I have also seen plenty of issues where people get muddled up with the technology and would have been better off with much more traditional nav approaches. All the various threads around loss of GPS reception, GPS showed wrong position, map stopped working, etc. seem to involve these roped together solutions. Panel mount GPS is an ultra reliable system. Used PDAs with internal GPS antenna, limited battery life/power codes and cables trailing around the cockpit, running free software is not a great solution to certainty of position or maintaining a good external lookout. (IMHO)

Would they have to be switched off - the truth?
 

Can any of the ATCO’s please advise what is the truth behind suggestions that (a) Mode S would be required to be on at all times and (b) people who say that ATC will tell people to switch them off when the screens become too cluttered and/or TCAS’s trigger too many false alarms.

Two things prompt my enquiry. 1st – a visit to a UK Tower ATC last week – the ATCO said if he saw too many glider responses on the screen, they would suppress the labels because they would garble (I think that is the correct phrase). 2nd: A posting on u.r.a.s. (a UK gliding web site) today includes:

Author : Gavin Short [snip]

I am concerned at ATC overload. My experience is of flying in NE Belgium/Netherlands; Last summer a TMZ was introduced on the southern edge of the Eindhoven CTR which cut off the route east into Germany for clearer airspace and better soaring weather.

The first day of decent soaring weather caused a rush of those gliders who were transponder equiped into the TMZ to head east. Perhaps in excess of 10 gliders which promptly triggered a call from the ATC for 'all gliders in the Eindhoven TMZ to switch of their transponders because ATC could not cope with the multiple contacts' - an interesting legal point - who can authorise aircraft in a TMZ to switch off their transponders?

[snip]

Chris N.

There are two separate issues here

1) Garbling. This happens if multiple transponders respond to the same interrogation, e.g., with same slant range but different ground range, or when transponder replies overlap. This is an increasing issue because of

- more and more interrogators flying (TCAS)
- many ATC radars in Europe with overlapping ranges.
- more data being transmitted in the transponder reply (enhanced Mode S, ADS-B etc.)

S stands for "selective" - a standard Mode A/C transponder will reply to any interrogation for that mode, a Mode S transponder only to one that is directed at that individual transponder, using the 24-bit, which avoids garbling. A Mode S radar does infrequent "all calls" to find out who is around and then interrogates each transponder individually.

Or, put more simply, Mode S is a fix required to accomodate a much larger number of transponding aircraft. That is why universal Mode A/C is not sufficient and the authorities want mode S even for those aircraft that in effect will only ever transmit a 12-bit squawk and pressure altitude, and not only for the heavy/fast guys that transmit a lot more.


2) Screen clutter

That is up to the radar display software, can't comment here.


I am afraid the real debate is whether everyone should squawk or not. If the answer is yes, Mode S is necessary to avoid the ancient A/C technology breaking down in some locations. And while there are better technologies that could do the trick, Mode S is the de-facto incumbent in the airline world.

Maybe the debate is more usefully directed at how to minimise the impact. Do we have to pay silly mod fees for paperwork for safety related equipment?

Cobalt, I was pointing also to what seems to me at least a third issue – that if all the things (not only gliders) below, say, a TMA, have transponders, then descending CAT gets TCAS triggers all the time – because TCAS does not know that the CAT will level out before reaching the below-TMA level – so lots of false alerts. So ATC tell the below-TMA people to switch off.

Presumable the same could happen as a result of ATC’s collision alert system.

So would ATC tell people to switch off – as they reportedly are doing in Holland – or not?
-----------------
And another post on u.r.a.s. said:

“With Mode S, an ATC unit can instruct any S-transponder not to respond to signals from that unit.

“It will still respond to TCAS. However TCAS does not, at present, cope with multiple threats, so guess how much use your mode S will be if you fly in gaggles. FLARM would be a better bet!
[snip]

Chris N.

"who can authorise aircraft in a TMZ to switch off their transponders? "...and how ? Would this mean that everybody would need to have a radio tuned in to a designated frequency ? Cue frenzied feedback about "my glider/parascender doesn't have a radio/no space/already at max weight, etc etc". Suppose it'd resolve the issue of garbling when you have 20+ gliders all circling within a 50 metre radius of each other and all using Mode-S.

Does beg an interesting question though....if you're TCAS equipped, operating in a TMZ, and all the GA in the sector has been told to switch their transmitters off....Who tells the TCAS enabled pilots that they'd better start watching out ?

Seperate point made earlier provides an interesting scenario too whereby you have intensive Mode-S transponding GA below controlled airspace but climbing, at the same time as you have controlled, TCAS equipped aircraftdescending towards the bottom of their operating zone. Would this mean that TMZ buffer zones would be needed around the TMZ's ? That'd then constrict much of GA into an even smaller area. There's likely to be a few nasty crunches under that scenario.

Closing date is 31st May
 

Whatever your standpoint on the Mode S proposals, the closing date for sending your response to the CAA looms.

The consultation closes on the 31st May, which is this coming Saturday. It's not clear to me if snail mail replies have to arrive by then (I'm sure they don't work on a Saturday!) or be postmarked 31st May or earlier.

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

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

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 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).

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

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.

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

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.

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.

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.

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

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.


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)

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'. :ok:

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

No doubt about that :ok:

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

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.

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,