Mode S responses

Essential reading

• Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet • Regulatory Impact Assessment Summaries - especially for Policy Option 3

http://www.caa.co.uk/default.aspx?catid=1698&paget ype=90&pageid=9307

• BGA article in S & G April/May issue • Advice on BGA website

http://www.gliding.co.uk/bgainfo/airspace/modes2008 .htm

Response Document

• On CAA website • Shorter than last consultation • 9 questions of real significance to glider pilots + 3 relevant to power pilots • Clubs

and

individuals need to respond • Make sure it’s your own views as much as possible • Closing date 31 May

Response Document Questions

What would be the impact of maintaining the current status quo on your main activity?

• • • •

Points to consider: Review pros and cons sections of RIAs No cost changes Gliding would continue to operate freely in uncontrolled airspace Gliders would have some access to controlled airspace on current terms e.g. LoA

Option 3: Include gliders in the SSR transponder carriage regulations

i.e. • Mandatory carriage of Mode S in controlled airspace – e.g. Riles zone; Birmingham control zone; Brize zone • Mandatory carriage of Mode S above FL100 • Mandatory carriage of Mode S in TMZs

Option 3: Include gliders in the SSR transponder carriage regulations Questions

• What other advantages and disadvantages could arise if gliders were brought within the SSR transponder carriage regulations ?

• • • •

Points to consider: Review pros and cons sections of RIAs Gliders unable to fly above FL100 No access to Class D on current terms MAYBE – access to Class D with Mode S

Option 3: Include gliders in the SSR transponder carriage regulations Questions

• Has the cost impact of Option 3 been accurately estimated?

RIA estimated costs may be understated – what impact would these have on your operations? What about ongoing costs?

• What would be the impact of Option 3 on small businesses?

e.g. cost – training – aircraft out of service – Part M – proportion of annual costs - member retention – inability to use wave above FL100 - would your club survive?

Option 1: Mandate the carriage and operation of Mode S transponders on all aircraft operating within controlled airspace of classification A to E

• What other advantages and disadvantages could there be under Option 1 if all aircraft operating within controlled airspace used SSR ?

•

Points to consider: Similar to Option 3 plus this will affect tugs & motorgliders anyway

Option 1: Mandate the carriage and operation of Mode S transponders on all aircraft operating within controlled airspace of classification A to E

• Has the cost impact of Option 1 been accurately estimated?

RIA estimated costs may be understated What about ongoing costs?

– what impact would these have on your operations?

• What would be the impact of Option 1 on small businesses?

e.g cost – training – aircraft out of service – Part M – proportion of annual costs - member retention - would your club survive?

Option 2: Implement a formal process to support applications for ‘Transponder Mandatory Zones’ (TMZ) outside of controlled airspace.

• What other issues should be taken into account within a mechanism to process and consider applications for TMZs?

Is the consultation adequate? What is the justification? Do we have any idea what the process would be? Is it sufficiently transparent and accountable? Who might a TMZ affect other than local operators?

Option 2: Implement a formal process to support applications for ‘Transponder Mandatory Zones’ (TMZ) outside of controlled airspace.

• What could be the cost to businesses and GA representative associations of participating in a process for considering the establishment of a TMZ?

What is involved in responding to a consultation? What are the costs (monetary and volunteer time)? What income earning opportunities are lost in the meantime?

Option 4

:

Mandate the carriage and operation of Mode S transponders on all powered aircraft conducting international flights.

Would the cost impact of Option 4 fall within the estimates for Option 1? Has the number of UK aircraft affected by Option 4 been accurately estimated?

What other issues should be taken into account by the CAA when considering whether or not to continue to notify a ‘Difference’ with the ICAO Annex 6 international obligations?

Other comments

An opportunity to say what you really think  Don’t be trapped by the CAA’s Consultation agenda    Ask questions Challenge the assumptions Don’t accept at face value what is written in the Consultation  Refute unjustified or unsupported statements

Comments – Suggestions and ideas

• Safety case (what is the level of risk?) • Statistical evidence • Airprox evidence • Lack of joined-up-thinking by government – DCMS wanting sport to thrive but other Departments damaging airsports • Is continued CAT growth environmentally acceptable?

• Technical problems for gliders

And finally

Watch BGA website for BGA guidance Clubs

and

individuals need to respond Respond before 31 May

Your replies count!

Thank you for coming