CAA Call for Evidence – Electronic Conspicuity
Update 22 May 2019
Responding to the CAA call for evidence re Electronic Conspicuity
The UK governments Aviation Strategy 2050 identifies a need for electronic identification of all aircraft. There is no timescale attached to this specific strategic view. The UK CAA is keen to establish mandated electronic conspicuity (EC) by all aircraft in all airspace and has made a ‘call for evidence’ regarding EC that closes on the 25th May.
Most of the CAA’s airspace related policies are developed by former air traffic controllers and are primarily influenced by Air Navigation Service Providers (‘ANSPs’, such as NATS) and commercial air transport, who fund much of the CAA’s activity. This often results in a narrow view that does not address the safety and operational needs of the significant number of airspace stakeholders that are categorised as General Aviation (GA), which includes gliding.
The BGA position on Electronic Conspicuity (EC) is to encourage voluntary installation and that pilots should make their own decision on technology based on its ability to do the job and compatibility with other systems.
Glider pilots will be aware that there is already very widespread adoption of EC driven by the benefits to their own operations. Many aeroplane pilots have also voluntarily adopted EC solutions that work for their particular circumstances. And those who routinely fly under air traffic control use transponders as another form of EC. These are based on WWII technology and require air traffic involvement to realise most of the benefits. In recent years, technology has emerged and been developed into affordable and available products that allow all of these EC solutions, including FLARM and Mode S, to work together through rebroadcasting. However, the CAA is very keen to promote their own preferred EC solution that is based on transponder technology on 1090MHz. We believe there are a number of known technical, safety and financial implications which have yet to be properly considered, yet alone resolved.
The BGA will be submitting a comprehensive response. However, we believe that inputs to the CAA’s call for evidence from a significant number of operators and pilots will help the CAA understand that a future EC environment has to meet the needs of and maintain the freedoms of all airspace users rather than diving headlong into an approach that benefits ANSPs and the airlines while failing to deliver a safety benefit to the GA user who collectively will be parting with £’s millions to pay for it.
- The CAA’s call for evidence – CAP 1777 – is available here http://publicapps.caa.co.uk/modalapplication.aspx?catid=1&pagetype=65&appid=11&mode=detail&id=9046
- The CAA has also produced a summary which is available here https://publicapps.caa.co.uk/docs/33/CAP1776_EC_In_Focus.pdf
Please read the documents and respond with your own views. You may wish to note in your own words that whilst Electronic Conspicuity is currently supporting effective lookout and will undoubtedly in future play a leading role in aviation safety and future airspace design;
- There is no justification for a national EC mandate.
- The CAA’s call for evidence does not explain the meaning of ‘interoperable’ in an EC context but nevertheless asks for views on whether or not “interoperability” is the right way forward.
- Mid-air collision represents around 10% of the risk to GA. In other words, whilst important, mid-air collision risk is not the greatest risk to GA. It appears as if the CAA is at risk of applying disproportionate effort in rolling out a general EC mandate. This leads to an assumption that they are doing so to meet the needs of ANSPs and commercial operators whilst dressing it up as a safety benefit to GA.
- Requiring use of 1090MHz for all aircraft is questioned by EC subject matter experts and other regulators, including EASA.
- A solution must work for each sector of GA: not all sectors routinely fly in close proximity to each other and the technology must accommodate this.
- Maintaining the safety benefits associated with existing voluntary adopted EC is critically important. Rebroadcasting facilitates interoperability between EC technologies.
- Any ‘local’ EC mandate that affects access to airspace must be evidence based, risk based, proportionate and subject to full and formal airspace change consultation.
- The call for evidence is a poorly designed consultation that discourages stakeholders from submitting their own views.
It is very important that you use your own words. The Govt and CAA ignore ‘campaign’ responses, ie those that are clearly cut and paste rather than an individual responder’s view.
Please submit your comments to the CAA by 25th May 2019 using their response form https://consultations.caa.co.uk/corporate-communications/e-conspicuity-solutions/consultation/intro/ . The call for evidence includes opportunity to add free text and to attach documents.