Report on a meeting held by the CAA concerning the "Proposal to amend the Air Navigation Order 2005 for the purpose of improving the technical interoperability of all aircraft in UK airspace".



By Peter Saundby, Vice President, Royal Aero Club; with advice from Tom Hardie, Peter Hearne and Ian Strachan.



This meeting was held in the Civil Aviation Authority, Kingsway, London, on 
Tuesday 15 August 2006. It was attended by some 28 persons, all the major 
Associations and AOPA being represented. The arrangements for the meeting 
were good and the best part was the buffet lunch.

Tom Hardie who is tasked with the GA Alliance response was present together 
with Peter Hearne and Ian Strachan representing the BGA but equally 
concerned with other recreational aviation interests. The meeting was 
chaired by Andy Knill, the CAA Manager for 'Surveillance and Spectrum 
Management' he has had a distinguished career in the development of 
secondary radar. He was supported by Andy Greenwood and Sqn Ldr Max Seaman, 
both of whom have professional backgrounds as fighter controllers in the 
RAF. The initial presentation was given by Gp Cpt Wragg RAF, but he then 
excused himself and left the meeting. His professional background is in air 
traffic control. Therefore a problem was that none of this CAA 'expert' team 
has had any serious flying experience and as I have written elsewhere, the 
sky looks different when seen from a cockpit rather than the radar room of a 
control centre. From the BHPA and BGA points of view, it became apparent 
that the CAA team knew little about soaring operations. There is a need for 
the CAA to accept data that will be needed for the relevant modelling that 
yet has to take place.



An outstanding feature of the day was the repeated exposure of internal 
contradictions. On the CAA web site the meeting was described as "a workshop 
in support of the proposal to amend the ANO". It was certainly not a 
workshop because nothing was produced and not one of the visiting attendees 
ever spoke in support of the proposal. We opened with a presentation by Gp 
Cpt Wragg, in this he stated that this proposal was the culmination of 
fourteen years work, that the objective was flight safety and that the 
intention was to listen. It was a proposal and open to consultation. However 
the 'experts' had considered and rejected other options and this became only 
too clear later in the meeting. He also assured the meeting that there was 
no intention of using the information on traffic for other purposes, 
presumably referring to past suspicions of charges for airspace use. He was 
keen for responses although time will tell whether his team will actually 
take any notice of these.



Andy Greenwood then showed some initial responses to the consultation 
document, there had been 850 individual responses, 28 small businesses and 1 
large business. 80% supported voluntary equipage and 77% did not believe 
that there would be any safety benefit. Of the replies from small 
businesses, 75% expected losses and 25% would cease trading. His argument 
was that the case for universal transponders was a safety case and even 
implied that those who opposed were against safety! From the audience it was 
repeatedly put that the safety case was for electronic visibility and not 
mode 'S' transponders, these being merely one potential solution and also 
not the one being progressed by the Federal Aviation Administration in the 
USA.



Most of the CAA presentation was in support of the concept of electronic 
visibility, that this would reduce the risk of collisions, facilitate 
traffic management, enable traffic growth and replace current obsolete 
systems. All this is uncontroversial and agreed by those present. However 
the only technical solution ordained by the CAA is the carriage of mode 'S' 
transponders. Therefore the real debate as to whether this is the optimum or 
the only technical solution never took place, indeed the Chairman ruled 
discussion out of order saying "that it would take three days of meetings to 
address this issue". It is apparent, and was even admitted by the CAA team, 
that ADS-B [broadcasting of position by the aircraft] will become the system 
for the future and therefore the CAA advocates the purchase of transponders 
with extended squitter. Consequently the purchase of any other transponder 
can only be an interim measure. There appears to be a determination by the 
CAA to avoid any expenditure involved in the immediate modification of 
infrastructure to accept ADS-B information while appearing to discount 
expenditure imposed upon others.



In what discussion did take place, it was pointed out that TCAS suffers 
limitations when used for pilot controlled collision avoidance because there 
is no vector information and this had been the subject of a warning by 
Eurocontrol. A transponder needs to be illuminated by radar before 
responding and this may not always be the case at low level. The possibility 
that a very large increase in airborne mode 'S' transponders might result in 
spurious TCAS warnings was discounted by the CAA team. However it was 
pointed out that in the development of military systems it had been found 
unwise to rely solely on modelling and that flight test verification is 
essential before final decisions are taken.



Discussion of international issues exposed further contradictions. It was 
stated that ICAO had mandated transponders although this is not true for 
those un-powered aircraft included in the CAA proposal. At one moment we 
were being told that ICAO was mandatory, the second that the CAA were 
encouraging the development of low output transponders that did not meet the 
ICAO specification. Accounts of developments in France and Germany did not 
match with information from elsewhere. This CAA proposal runs counter to the 
declared aims of the EASA Board to encourage technical innovation and the 
development of light aviation in Europe.



A reference to UAVs was equally inconclusive. The CAA envisages widespread 
civil and military use and the electronic visibility of all other airspace 
users could enable an avoidance system. However the same arguments exist as 
to how that visibility could be created. An important point made was that 
questions power supply and weight are as equally critical for UAVs as for 
recreational aviation. The question of radiological protection was only 
raised at the end. This is related to output power, but thermal 
considerations alone were considered. Interference with cardiac pacemakers 
and non-approved aircraft electronic equipment has not been explored. Indeed 
a delusion exists in the CAA that with EASA airworthiness approval, all 
instrumentation in gliders will become certified.



Much faith is being put by the CAA in the development of low powered low 
cost transponders, LAST and LPST. Prices were cited as low as under £1000. 
However these items, despite past efforts, have not yet been developed and 
we now have a chicken and egg situation. A representative from the company 
implied that they could not justify 'bringing to market' costs unless that 
market was assured. That leads to the position that future legislation may 
'require' the fitting of equipment that does not yet exist. The Chairman 
ignored strong pleas from those representing organisations that no 
specification should be issued without consultation with those who would be 
compelled to use the equipment in the air.



There was limited discussion on possible hybrid systems, squitter 
transmissions passing information on aircraft position and vector based on 
internal GPS navigational systems. This was rejected by the Chairman who 
clearly did not believe the integrity and accuracy of current commercial 
[off the shelf] GPS systems despite evidence being offered to the contrary.



The BHPA protested that the CAA had not consulted on actual air space usage 
and that must be taken into account by the CAA. This case was supported by 
the BGA because the same point has been made at earlier GACC meetings. The 
CAA team agreed that they would now be prepared to examine such material. 
The BGA made the further point that the proposed change in the regulations 
would involve a prohibition on the ability of gliders to fly IMC in 
unregulated airspace. This change would be resisted because it had no 
sensible connection with transponder carriage and was entirely contrary to 
the concept of electronic visibility.



Individual exemptions from the ANO will be permitted on various grounds, and 
blanket exemptions will be permitted for certain in-service military 
aircraft. However these exemptions must detract from the concept of 
universal visibility and may prove difficult for the CAA to administer.



In summary this was most unsatisfactory meeting, although that was not 
unexpected. It is not obvious what motives are driving our CAA. The overt 
reasons do not appear adequate to explain what will become a major political 
and perhaps legal battle. Maybe the adverse financial and economic 
implications for general aviation are not appreciated. Certainly the meeting 
exposed a lack of knowledge by these CAA 'experts' of how recreational 
aviation operates and this ignorance cannot be dispelled by a few visits to 
Clubs, but needs honest and open cooperation between the CAA and the 
relevant associations. They must understand our operations and we need to 
know the pressures driving their policies. The major reason cited was flight 
safety and the collision risk, yet few fatalities arise from this cause and 
the same expenditure on other measures would save far more lives. Even the 
majority of respondents have not accepted this particular flight safety 
case. Is our CAA concerned that that their responsibility for airspace 
management entails legal liabilities? It was stated that the increase of 
controlled air traffic drove their proposal, but this increase is in 
controlled air space while the proposal relates to unregulated airspace. 
Another reason given was that the CAA has already spent fourteen years and 
it was time to move on, but the logic of this is not obvious. International 
considerations were treated selectively and only those that supported the 
CAA case were cited. Despite statements to the contrary, the decision to 
amend ANO has apparently been made and will be driven through. Actions speak 
louder than words.



While all agree that electronic visibility is desirable, there are obvious 
alternative and much better technical solutions to those advocated by the 
CAA. The FAA is leading with ADS-B and in aviation the Americans force the 
pace. At best the CAA proposals can only be an expensive interim solution. 
Adoption of ADS-B could solve the CAA problems of costs, radio spectrum 
congestion and windmills. The statement by the Chairman that there would 
always be civil radar for air traffic control was without supporting 
evidence. As was demonstrated at the meeting, ADS-B can be small light and 
low powered. A complete navigational pack for para-gliders weighing only 180 
gms was exhibited and this could feed a low power transmitter.



The reason for this impasse between general aviation and the CAA is 
difficult to discern. Their attachment to obsolescent systems is 
inexplicable because the CAA employs well qualified individuals who must be 
aware of modern developments. However a point not addressed at this meeting 
is that there are pressures on the CAA for the use of small regional 
airfields by commercial air traffic. As reported by GASCO, the Guild of Air 
Traffic Control Officers recently expressed their concern that the expansion 
of traffic has outstripped the capability of the Air Traffic Services. They 
have proposed a change from the VFR 'see and avoid' to a 'sense and avoid' 
based on TCAS. Can this be a clue to a covert reason for the present 
activity by the CAA?



18 August 2006