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Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’...

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Mode S responses
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Page 1: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

Mode S responses

Page 2: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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&pagetype=90&pageid=9307

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

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

Page 3: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 4: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

Response Document Questions

Page 5: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 6: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 7: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 8: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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?

Page 9: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 10: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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 impact would these have on your operations? What about ongoing costs?

• 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?

Page 11: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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?

Page 12: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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?

Page 13: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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?

Page 14: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 15: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 16: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.
Page 17: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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

Page 18: Mode S responses. Essential reading Consultation document ‘Executive Summary’ or ‘In Focus’ leaflet Regulatory Impact Assessment Summaries - especially.

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