This document contains a transcript of the Mode S meeting between representatives of the CAA and a group of pilots, largely members of Lasham Gliding Society, at LGS on Friday the 4th of April 2008. Meeting notes were taken by myself and an audio recording was made. What follows is an accurate record of what was said. No attempt has been made to correct any grammar, in case doing so would have subtly changed the meaning the speakers intended.
Please read it carefully and remember it is a record of spoken questions and answers. I have added punctuation as accurately as I have been able. Some paragraphs are in the style of James Joyce, but these reflect the words as they were spoken.
The recording was not of the highest quality and a couple of speakers regularly caused clipping. This was not obvious during the meeting and is merely present on the recording. I have added notes in italics where I have not been able to make a 100% accurate transcription and my notes do not help.
Many thanks go to my sister, Freddie Sterritt, who made the initial transcription. I have spent many hours trying to make out exactly what was said and subsequently correcting some quite amusing sentences – she has no aviation background.
Responsibility for the remaining errors rests entirely with me.
Chris Sterritt.
Present:
Patrick Naegli (PN) BGA Chairman
From the CAA - John Clark (JC), Phil Roberts (PR), Andy Knill (AK) and Andy Greenwood (AG)
Approximately 300 LGS members and other pilots
Minutes:
Chris Sterritt (CS)
Asking questions:
Hugh Browning (HB)
Peter Hearne (PH)
Chris Garton (CG)
Ian Strachan (IS)
Gordon MacDonald (GMcD)
John Brady (JB)
Good evening, thank you all very much for coming. Just one quick notice is the fire escapes, the main fire escape is obviously at the back of the room there and on the side here, 2 other doors will also lead to the outside. Ok I will introduce you now to Patrick Naegli.
Evening all - in August 2006 I was standing in a room not dissimilar to this one here with a crowd not dissimilar to this one here for a meeting not entirely dissimilar to this one here. At the end of the evening somebody came up to me and then presented to challenge me for 15 minutes on my knowledge of gliding. His finger got closer and closer to my chest. After a while when I explained I was the Chairman of the BGA. He said, “well why didn’t you tell me” and I said, “well I couldn’t get a word in edgeways”. He said, “I thought you were from the CAA”. I said, “why?” and he said, “because you have a tie on. I thought I ought to clear up this confusion at the beginning of the evening rather than at the end of the evening this time round.
Well first off, welcome and thank you very much for coming along to this evenings’ meeting. Whilst this is a gliding site and I know that a good number of people in the room are gliding pilots, we also have many people from other air sport associations/air sport disciplines in the room here this evening and I think that everybody is welcome to such an important topic. I would also like to say thank you to the Lasham Gliding Society for putting the meeting on this evening. I’d like to say thank you to the CAA team for making their time to come along this evening. This is one of a number of meetings that is being held, I suspect maybe not to quite the same degree with numbers of people, but nevertheless one of a number of meetings to be held to discuss the subject of inter-operability and the later set of proposals and I’d like to thank you all for coming along. There haven’t been too many subjects in recent years that have stimulated the level of interest, discussion, debate and indeed concern and anxiety as this one. The objectives of this evening are very, very clear and let me explain by first off telling you what they are and then making it equally clear what they are not. The first of which is, this is an opportunity for the CAA to listen to you. Its not the only opportunity, it’s one of a number and indeed between now and the end of May you have the opportunity for them to hear you again through your own individual submissions to the consultation process which is going on and I will explain at the end of the evening what that is going to look like. Secondly, it is really for you to listen to them… invite your friends in. It is not a negotiation. Neither are the CAA team here empowered to negotiate and we’re in the middle of a consultation process so please do not expect negotiated outcomes from this evening. One of my roles is to try and keep us broadly in order through this whole process and so as a consequence before we start the evenings proceedings, which will be with Phil introducing the CAA team, making some opening remarks from the CAA’s point of view. They are then going to present, in order to make sure that everyone has a base line understanding of what the consultation process is about and what the options are – a summary, and that’s going to be done by way of a DVD and hence the reason why the screen is on now. Quite clearly, the way in which they are going to listen to you is through the questions they are going to be asked.
You can imagine that over the last 3 weeks we have had literally hundreds of questions submitted for this evening. We are going to follow exactly the same process as we did 2 years ago, it seemed to work well at the time, no reason to believe it’s going to work any differently this evening. We’ve had a team processing their way through all those questions over the last week or so. The questions have been organised into 9 different areas, covering such things as the general questions about the consultation process, and the ultimate aims and objectives of the CAA through it – through to the safety case that underpins it, the research that has been used in part to substantiate some of the background to the proposals, each of the 3, or indeed I correct myself, each of the 4 options, each of the 4 options, and then a set of general questions towards the end. What I have done is I have asked a number of people to be prepared to answer the summary list of prepared questions on our behalves, and so during the course of the evening I will be asking them to stand up, ask those questions, allow the CAA to respond, and then depending upon how much time we have got and at what rate we are running, I will open up each area to questions from the floor. Free for all. You didn’t have to pay to come here this evening, but that is as far as the free for all goes. My role is not only to make sure that we remain true to the objectives, to the process of getting between here and 9:30 in an orderly manner, but I’m also here to moderate if need be – I know from August 2006 that that really wasn’t necessary, and so I’m sure it won’t be necessary again this evening.
You will have far more questions than we have got time to deal with this evening. If you aren’t picked to ask questions, then don’t let it rest there, send your questions in afterwards or more importantly, or just as importantly, make those questions known to the CAA through the consultation process. Please don’t feel disappointed if I am not able to actually select you to ask your questions from the floor, and in the interests of time, I will be managing very, very carefully how much time we can give to individual questions. I will be using Chris Starkey’s eyelids to tell me whether in fact I am getting close to the time that I should move on. So without any further delay, I’m going to hand over the microphone to Phil Roberts who will introduce the CAA team and kick this evenings’ proceedings off formally. One thing I should mention just before I hand across, 2 ½ hours is a long time, particularly for those people that are standing. Indeed there are still some people standing outside – it’s very much like August 2006. 2 ½ hours is a long time, so at about quarter past 8, I’m going to break the evening for 15 minutes to give you a chance to stretch your legs, fight over vacant chairs, fight in the bar, indeed do anything other than fight in here, and then come back at about half past 8 and we will carry on with the last hour of the evening. Is that all clear? Good, thank you very much. Phil.
Ladies and Gentlemen, good evening. Patrick, thank you very much indeed for that welcome and for setting out the process that we intend to follow. Now I actually feel like I am in the interrogator’s chair because I’ve got this very bright light in my eyes. However, someone kindly put a note up here that says “no jargon please”, would I please speak CAA terminology and of course someone in the past suggested that we are the ‘Campaign Against Aviation’. I understand that we have just about stopped all gliding here this evening. Well can I make it very clear that it was not us, that it is you who voluntarily stopped gliding to come and hear what we have to say and I’m very pleased you have. If only we could get this level of response for quite a lot of other consultations we have done actually we would be delighted, because on many things we don’t get any response and actually at times that’s really quite challenging. So we are pleased to be here, it does feel a bit like coming into the lion’s den but frankly that’s what we need to do. It’s our job in this arena, some of whom are here tonight to actually make policy on some of these matters, and particularly in the directorate and airspace policy where we work we have responsibility for spectrum use and for airspace use. So whether we like it or not that duty is one that is placed upon us in a statutory way through what’s been laid down in parliament and it’s our job to determine that policy, but clearly seek not to do that in some ivory tower in isolation. We need to be informed, we need to consult, we need to understand what the issues are and that’s really the purpose of this evening as Patrick has set out.
Can I just start then by introducing the team: I am Phil Roberts, Assistant Director of Airspace Policy, have been with DAP for about 10 years and my responsibility is anything to do with controlled airspace. We have a huge amount to do with Europe on a whole waft of things and I’m happy to talk about any of those later, but I’m sure you want to spend this evening talking about inter-operability and Mode S, and environment. There’s 1 or 2 other things and I’ll touch on that in due course. We’re also the met authority and anything to do with met issues and they also produce the VFR charts, and that all sits on my side of the house. On the other side of the house is the other Assistant Director of Airspace Policy, John Clarke and John’s issues include spectrum, they also include the open airspace, the glass G airspace that you utilise in what you do and his side also looks after the airspace utilisation section and the environmental research team. Andy Knill on my left is the Head of Spectrum and Surveillance so it’s his area that is responsible specifically for these proposals. Then we have Andy Greenwood on Andy ‘s left, we’ve got 2 Andys it’s quite easy, is a contractor embedded with us to assist us in dealing with this work, its intensive, requires a lot of people to support that activity.
So phase one of the proposals actually became implemented on last Monday, so having consulted on the first round and having made the decision about what was going to be implemented in that first round it actually came into effect on the 31st March. However we are actually here this evening to talk about the second phase of proposals and the second round of consultation, and hopefully once you have seen the video and I have been able to answer some of your questions, you will understand exactly what is in that second phase of proposals which is fundamentaly different from what was in the first. So getting that message across is a very important part of why we are here this evening. As Patrick pointed out this is one in a series of presentations the team have been to Turweston, they were at Portmoak last week talking to your gliding colleagues north of the boarder and there’s another couple to come after this. Now let’s be very clear, we recognise that this is an emotive topic. We knew that and we are delighted to see you here this evening so that you can understand exactly what those issues are. It also comes at a time when a whole raft of other issues that come from Europe, EASA, which also have an impact on what you, what we do, so please don’t think we don’t understand – we do. To an extent, in some ways we’re not always going to see eye to eye. Our responsibilities require us to take into account all airspace users just like the big noisy thing that’s arrived outside the windows right now. (737 lands) In that context that means there are times when things of interest to one community is not necessarily of equal interest to another and quite often the views are different, and in our responsibility we have to think of commercial, we have to think of GA in all its guises not just gliding, we have to think of military and we have to think of the public because actually they do a lot of flying too – normally they are at the back of a commercial aeroplane. We also have to think, whether we like it or not, about a lot on environmental issues which is part of our responsibility and that’s quite a challenge. So Patrick has actually quite nicely set out what we think we’re here for this evening. It’s 2 aspects: the first is definitely to try and inform this process and we’re here to make sure that you have got the right information, we want to know you understand the proposals and that’s a very important part of the process.
In the first phase we don’t think we achieved that in time, because the consultation, the dialogue was not as good as it could have been and we put our hand up as it takes two to tango when you are communicating, and if you’re not getting the message across then we’re not doing our bit either. Equally we know there are quite a lot of people who never actually read the consultation material. We spent quite a lot of time preparing it, so really would like people to read the material and understand it. We had our first response on the website within 27 minutes of the material being published. You have to be a speed reader to go through 68 pages of quite technical stuff, so that’s one tangible example. I have another one from my flying: there was a GA pilot and I was sitting in the flying club and listening to some of the debate from people who had been flying for years, who you’d expect to have a better understanding but who didn’t. So again please can I urge you to read the material, understand it and if you don’t come back and ask questions and then respond in an informed way. P ????? doesn’t always have it right, as I am sure you will all agree. I think I said in some ways we wouldn’t always see eye to eye, and that inevitable, but I think in a number of other ways, equally we do have some common interests. Firstly, we are actually all passionate about aviation. The Campaign Against Aviation theme I assure you is wrong. An awful lot of people inside the CAA and DAP who enjoy the same sort of activities as you do – so please don’t think of us as being the alien on the other side of the trench – we’re not. We have lots of people who fly in various guises, we do understand the issues, but the purpose of consulting is to make sure that we do truly understand the full cross section of things. The second interest we have in common, whether we like it or not is that we all have to make the most efficient use of a limited resource and in this particular contract that’s both spectrum and airspace. There’s a finite capacity and actually there are a number of competing demands for that capacity and part of our job, again whether you like it or not, is to manage that and balance those interests.
So we are here to inform, we’re here to listen, I give you an undertaking that in answering your questions we will do our very best to be very clear. We will try and answer them as openly, honestly and as frankly as we can. If we don’t know the answer, we will say we don’t know the answer, then we’ll get one and feed it back in through Patrick and through Lasham. We need to understand the technical, the operational, the financial and in some ways the environmental impacts of any policy we change and that’s why consultation is so important to us. So we are delighted you are all here this evening, we hope that we can had a constructive debate and can I also urge you all again, it’s something that Patrick’s said, please respond to the consultation. This is not your response to the consultation, it is part of the process, but we would like you to respond to the material that’s out there because that’s actually important as well. We would like you to respond individually. We are not running a vote here, we are running a consultation, we want to hear what people have to say and I assure you we will take that view into account when reaching a policy decision. 3,000 responses that say the same thing do carry some weight, but we are not counting votes. What we want to do is we really want to understand the issues and that’s why your response is very important. Thank you very much indeed. Without further ado, if I may, I’ll hand over to Andy who can run the video. Thank you.
For those of you who were fortunate enough to gain a seat this evening, you’d have found on your chair a CD. What we’re going to do in the next 25 minutes is play the presentation, which has an automatic narration, to give you an overview of the proposals so that you understand exactly what is being proposed. When you load the CD on you laptop, it should auto-run to this screen. If it’s a MAC you’ll have to click on the icon that says ‘Mode S’. If it’s a PC that doesn’t auto-run, same applies click on the icon. You’ll see this screen has 2 options which highlight when you run the mouse over it. On the ‘Supported Documents’ side, it will give you access to the Consultation Document and the Annexes to the Consultation Document, which is also available to download off the CAA website if you want but it’s also on the CD. There is a Powerpoint presentation on the CD as well which looks at airspace infringements as part of the Airspace And Safety Initiative. It doesn’t have a narration, it’s just a Powerpoint presentation. So some of you if you haven’t got Powerpoint viewer as a minimum, you won’t be able to read that one. There’s also a final document at the bottom there which is an information leaflet on TCAS. In particular it’s focused with how TCAS behaves against VFR aircraft. It was produced by Eurocontrol and it’s also available for download from the Eurocontrol web site. I’ll now run the presentation, it’s 25 minutes long. When you run the presentation yourselves, there are going to be 2 icons which appear on the bottom of the screen for Pause and Play. They allow you not to have to sit through it for 25 minutes without stopping. You’ll be able to pause it and re-start at any time. What you will not be able to do, unfortunately, is rewind it. Without further ado, we’ll run the presentation.
Video – presentation of overview of
the proposal
I have some more CDs at the front, I realise that not everybody has one. Also the BGA were given 500 copies and I believe the BHPA have given a mailing list to clubs so that the BHPA representatives should find that the clubs will have CDs. I just want to very, very quickly summarise those 4 options. They are 4 options for consultation, they are not 4 options that are going forward to the Government at the moment. They are designed to elicit feedback. The first option looks purely at controlled airspace and transponder carriage within controlled airspace. If option 1 went forward in isolation, and none of the other options went forward, it would not affect gliding. Option 3 needs to be enacted as well for gliders to also come under transponder carriage rules in controlled airspace. The 2nd option is a consultation on the process that you would like to see adopted by the CAA to handle applications for TMZs. It is not a consultation on any specific TMZs – it’s what do you really want to see in that process that applicants have to go through. The CAA view at the moment is that it should be the Airspace Change Process. Option 3 would bring gliders within the same transponder carriage rules as everbody else. 45:50
I mentioned that the team had been working its way through hundreds of questions – we’ve manage to pull all those down to a short list of about 40, but we will ask them promptly and I know that the CAA will answer them concisely. I’m actually going to start out by asking 2 questions. I’m going to read them to make sure I don’t miss anything specific in them, I don’t usually use any notes for any of these things, and then I’m going to ask Hugh Browning to stand up and ask those questions that are particularly pertinent to the safety case that the CAA have used. Alistair is going to provide us with a radio mic. Do we have a radio mic? Hugh’s got it already, so if anybody can’t hear clearly, just shout and we’ll repeat the question.
There are 27,000 aircraft on the UK register of which 96% are general aviation. How does the CAA justify the proportionality of their proposals given that it is CAT (Commercial Air Transport) the 4% that are likely to be the primary if not sole beneficiaries of the proposals?
Very valid question. Proportionality is of course very important to us and it is something we have to take into account in bringing forward any proposals as part of the test of reasonableness. It’s not just the account of numbers of flying aircraft, it’s the account of the amount of flying that’s done, the hours and the interaction between all those operators and part of the proposals that we have looked at over the last 12 months in constructing this set of proposals for consultation has been how do we actually address some of those issues. We are hoping that by taking the phased approach we have with these 4 individual categories we can actually break that down. Proportionality, of course it’s all very well quoting numbers, but many of those operators are already equipped and the proportionality issue comes into which ones aren’t equipped and which ones will have to be equipped as part of this regulatory change, compared with those who are already fitting it voluntarily. In terms of how we look as far as we use the airspace for the future, of course there can be a vast number of the proportion of those who are not equipped who could continue to operate in the class G airspace where there is no proposed change within this consultation process.
Thank you Andy. We are capturing, by the way, the answers to the questions this evening. Chris Sterritt is taking notes of the meeting.
The second question: The general concern with environmental issues, including the impact of air travel is being taken far more seriously by governments, including our own, and we are being subject to various costs and other interventions to reduce our impact on the environment. How is the CAA taking into account the significant potential impact of this major shift in reviewing and/or adjusting its estimates of traffic growth?
I think I understand your question.
I can repeat the question if you would like.
It would be helpful, I think, as there’s two aspects to that I think and I just want to make sure I hit both of them.
The general concern with environmental issues, including the impact of air travel is being taken far more seriously by governments, including our own, and we are being subject to various costs and other interventions to reduce our impact on the environment. How is the CAA taking into account the significant potential impact of this major shift in reviewing and/or adjusting its estimates of traffic growth?
And that’s Commercial air transport traffic growth.
Thank you. Having now had the opportunity to hear it twice, I now think I understand the question far better. As far as we are concerned, we are hugely impacted by environmental issues, all of us, and actually dealing with how that impacts on airspace today in a definite day to day business environment is hugely difficult. That doesn’t answer Patrick’s question. In terms of what growth figures are we taking into account, we are currently using the figures in the air transport White Paper which are the only published figures there are available. We also take into account what we know from the actual growth in traffic. If you go back a few years we are looking at 7% and 8% type figures for traffic growth on the commercial front, at the moment the actual figures are something like 3% and 4%. There is still a growth, we still have to accommodate it and its peaky because it isn’t consistent across everything, so we are seeing far greater growth interestingly at regional airports - the Ryanairs of this world, the low cost operators, because we as members of the public want to fly from those places, than we are actually seeing that some of the bigger more established airports. So somehow or other we have still got to deal with the issues that occur in Class G airspace around some of those airports where the traffic has increased dramatically and at the moment doesn’t show too much sigh of tailing off, but despite some of the environmental pressures and despite whatever is happening in the economy at the moment.
Hugh would you like to ask the questions related to the safety case please?
I’ll just check if it works…yes? Thank you.
The phrase ‘the CAA considers’ is used 9 times in the proposal in support of the contention that Mode S is necessary for safety, but in no instance is any supporting evidence provided. So where please can we find the documentary evidence that the CAA used to reach their conclusions and indeed why should we be convinced by assertions without the associated evidence?
I’ll just talk about the consultation document to start off with and then ask Andy to take the rest of the question.
In Section 12 of the consultation document it’s called ‘The Assessment of Risks’ and it explains the thought process that CAA has gone through in terms of assessing risks of mid air collision and the system of TCAS the short term conflict alert. There is also another section of the document which looks at the studies that have been done and summaries such as the collision avoidance systems studies that are available on Eurocontrol website so that the document will hopefully answer some questions. It will hopefully provide you to links to other documents that you can read such as studies by Professor Peter Brooker from Cranfield University and what’s available on the Eurocontrol website.
Ok just taking that a little bit further in terms of the safety case I think there are still some views that the safety issues that were raised in the original consultation still directly are being translated into what we are proposing here. Now of course what we are actually talking about here is the introduction of transponder requirements into controlled airspace where they employ safety limits to protect the traffics within there. That’s a direct relationship, as far as we are concerned, to protect the particular activities within that airspace and to try and make life easy for everybody that operates within that airspace, to be able to contribute to that safety level. Now – interruption from the floor – Can I finish the question, please? Interruption continues.
I’m sorry. As a matter of common courtesy, we’re going to allow the gentleman to finish the question and I explained the procedure at the beginning of the evening. If you’re not willing to follow it, will you please leave the room and surrender your seat to someone who is.
Thank you. Now the 2nd issue is when we were looking at increasing the transponder carriage requirements in this case irrespective of class G airspace, as we just said we are talking about TMZs being introduced via a process. We are not introducing specific TMZs as part of this consultation. We already have the right to introduce a TMZ where the CAA (PN suggests this relates to a question in a later section) I want to explain it in relation to the safety issue because it is important here. We are not trying to justify now every individual TMZ application which may be received in the future. Each one will have to be established on a case by case basis which is identifying a specific issue and reason for that application being made in the first place. And that’s an important aspect I think in relation to the safety stats we have. The other point I would make is in relation to the glider activity we are talking about the interaction, above all, about gliders having SSRs within an environment where transponder carriage is already a key element of the delivery of the target levels of safety. Now when we say we consider, as well, the final point briefly, is the CAA has to be a proactive regulator. We have to respond to the changeing environment and the demands which are placed upon us. We cannot sit back and just wait for something to happen, and that’s why for us the use of ??? 56:30 ???? and the information we have is invaluable within the consultation document.
The word ‘safety’ is used many, many times in the document, but in no case is there any specification of the currently achieved levels of safety or the target levels of safety – why not? Surely quantified estimates are essential to identify and reduce the larger risks; to avoid disproportionate regulation where the risk is low.
In terms of the issues for the airspace we are talking about, we’re talking about the target levels of safety that have to be achieved within that airspace. That’s based on ICAO figures and it’s based and related to the amount of activity that actually goes on within that airspace. The consultation document as Andy has already explained does cross reference the reports related to the delivery of target levels of safety. From our prospective they are known and quantifiable against the traffic levels that go on within the airspace that we are talking about for the proposals we are consulting on for this particular exercise.
What proportion of the total collision risk to CAT aircraft does the CAA estimate to be attributable to gliders and where is please the evidence to support that estimate?
The current target level of safety that we have to achieve does not differentiate between the different aircraft involved. We’re talking about all the movements in there and all the activity that goes on within a piece of airspace. Now if you are flying within that piece of airspace, and you are contributing towards the achievement of that target level of safety, and it is the safety nets and how they are employed that works towards that.
The document claims that Mode S is required to protect CAT in the face of traffic growth. Airprox Board Report Number 17 tells us that the number of Risk A or Risk B airproxes involving CAT has declined from 29 in 1997 to 6 in 2006, while traffic has grown by 35%. So in the face of this evidence why does the CAA claim that traffic growth necessarily means less safety?
We get back to this point we only have a finite amount of airspace. It’s a single volume which in a lot of cases we have to share and in sharing it, in part of that environment the traffic is growing. The figures show it, but I don’t think anyone is disputing that. But what we are saying is notwithstanding what’s happened with some of the figures from the airprox statistics, but actually TCAS has played a fairly important part in driving those figures down. There are a significant number of aircraft that are equipped even if they are not Mode S equipped, they do actually co-operate in the environment and I think that’s actually the key to what we are talking about here.
(comment from the rear of the room)
What we are actually talking about is a co-operative environment because when we get to the issue of sharing this airspace, our activity whether it’s you in a glider or me in a spam can, actually we’ve got to impact on other users. We can’t hide that fact. It’s how we actually get that interaction in the most efficient way, is what we are trying to achieve. So I think the specific answer to the question is we think TCAS has played a very significant part in actually helping to reduce those figures. But equally at the end of the day, airprox reports are in some ways one of the few measures we’ve actually got of finding out what’s happening in this environment. We know that all of the incidents that occur don’t result in an airprox report that goes on and on through the airprox system. So understanding, we are trying to work on the basis of what we’ve got as facts, these of some of the factual bits of information we have
Last one in this segment. Still in that Airprox Board Report Number 17: it comments that 6 was the lowest in their data set, 6 in a year, 6 Risk B. It comments and I quote, “in looking at these 6 events, there is nothing to suggest a common thread and such wide variability does not point to the need for concerted action in a particular area of operations.”
So the Airprox Board are saying that the collision risk for CAT is reducing and there is no need for concerted action. That must mean I think, among other things, that there is no requirement for gliders to carry Mode S. So why please has that kind of observation not resulted in a withdrawal of any proposal for gliders to carry Mode S, whether it be in controlled airspace, in transponder mandatory zones or above Flight Level 100?
That is one airprox report and of course that doesn’t form the basis of the issues that we need to address. We are looking at the whole consideration of the interoperation between various users across a wide range of airspace types. We are not just talking about risk of collision; we are talking about infringements and reactions of safety nets to infringements. We’re talking about how you can manage the airspace more effectively and how you can manage activity for the future. In terms of how we looked at airpox reports, the quoted airprox issues are contained within the consultation document, which we have looked at where they have been appropriate to the proposals we are making. The trade is obviously good, it’s policy and it’s a very positive view, but its only one aspect within other issues that we have to consider and take into account. And when we’re looking at the operation of safety nets between a wide range of users and in airspace where transponder carriage is a key element of that safety net system, the evaluer also has to look at what is the safety case for those who do not carry that and operate along side those people in that same airspace; which is why we have to address the issue.
In a moment we are going to move on to some questions that are related to some of the research that has been used to support the CAA analysis and/or proposals. Are there any further questions that anybody would like to ask from the floor; this is the appropriate point to do so on the CAA safety case.
It’s really a point of order of the whole meeting. When questions are asked, is there going to be an indicator as to whether they have been answered satisfactorily? For example, I think in the last grouping of questions, at least 3 of them weren’t answered at all. I mean they didn’t address the focus of the questions. So what’s going to happen, are we going to leave these issues or are you going to take some action from the Chair to ensure that they are answered properly?
There is a wide range of questions we need to ask this evening. As I mentioned at the start, the purpose is primarily to listen. You will make your own minds up on the quality of information that the CAA have given you. If you are dissatisfied and that there are any further questions open, as I mentioned to you earlier on by all means make them known to me at the BGA, to the CAA direct and through your consultations. If you do not believe that the answers that have been given adequately explain, or indeed answer the questions, then make that point clear. We are not going to be able to pursue any particular question through to a satisfactory conclusion this evening without running the risk of not asking all the questions that many people would have liked to have asked.
If Option 3 is implemented and CAT can use Class G airspace, do the risks decline if gliders carry Mode S?
(CS: not sure if this was exactly the question)
Bob let’s be clear. One of the things that’s about to come in from ICAO is a requirement for a safety management approach, a safety case for commercial air transport as an ICAO annex requirement. That comes in effectively from 2009. So at the moment where you could argue that a commercial air transport aeroplane could go from A to B through Class G and just go willy nilly, ignoring everything, in future the ICAO requirement will say they have to conduct a proper safety case and an assessment of using that airspace. So that’s the first part. The second part is, we already have in place a number of procedures, principals about how commercial air transport routes outside the controlled airspace system. Part of the airspace and safety initiative the ASI badge you’ve seen on this thing, is about how do we make better use of that airspace? In terms of the direct answer to your numerical statistical question, I can’t tell you because we would have to go away and model it and find out the answer. But what I can say is if we have a co-operative environment, I’m sorry I’m going to be boring because I’ll keep coming back to that, actually we think that the likelihood of the risk increasing would be reduced because there are some safety nets in there which will help. But in terms of the statistical analysis then I would say nothing else, of course I wouldn’t, other than we would have go away and model it and understand what the implications were. The challenge we have in all of that, is understanding fully what goes on in Class G airspace all of the time. We can only work on the basis of the information we’ve got available. (faint comment from the floor) No its not all speculative. We will work on the basis of the facts we’ve got. What we don’t have is data from everybody about what is going on in every bit of Class G at every time of the day. And coming back to the question of TLS in Class G, there is only one TLS, it’s an ICAO TLS and actually how you apportion that within that volume of airspace is something that is extremely difficult to do. Sorry, Target Level of Safety. I apologise. On the grounds that ‘TLS’ a
Was used in the question, I thought that ‘TLS’ was Ok in the reply.
You’ll see if you read the CAA document, they refer to French tests on some TB20s simulating gliders in a conflict with an ATR42 carrying a TCAS. Thanks to the good offices of the CAA, I managed to get hold of the actual basic French document on which the comments the CAA made was based, although in between there was a much blander French government document issued to ICAO which says everything was fine. Amazingly, the top level French government report didn’t really accurately reflect what was in the basic trials, and I’d just like to read whilst I ask my question, what the French report says: Exact translation: Paragraph 5.3 page 32, “The visualisation ie the display of the traffic environment suffers from certain deficiencies which prevent a good appreciation of the traffic position in a head-on encounter. TCAS has been designed as a safety net for air-to-air collision avoidance between individual aircraft and not as a See-And-Avoid system.” And shortly afterwards, a further comment Paragraph 5.3, same paragraph, the exact translation states, “because of the overall advantage in terms of safety brought about by the installation of Mode S in mixed traffic zones” (which is what we’d have in CAS) “the STA recommends the installation of Mode S in gliders as a Ground Surveillance Aid. Complimentary investigations will be carried out in the future to determine if other technologies can further improve the results particularly those that relate to aspects of visualisation to the pilots.” I don’t think we want to get into that one today as it isn’t part of our present case. I’d like to ask 2 questions.
The first question is: In view of the French reservations, and they’re very definite ones when you read this report in detail, what plans the CAA have to evaluate TCAS encounters with Mode S equipped glider clusters. I draw your attention to the fact – I’m sure you know as some of you have been involved in it – we had TCAS 1, we had then a lengthy time of the development of TCAS 2 before the protocol was accepted for international use, some several years of experimental flying. We cannot expect that a TCAS system which is designed for single aircraft encounters with commercial aircraft flying at comparable speeds can have any, can just be assumed to be suitable to for encounters with clusters of gliders circling slowly. I think it’s something which you really have to, we really need to have some additional flight tests in this country to examine that case and other cases which the French didn’t consider which is the particualar case of TCAS interaction with gliders near the base of controlled airspace when you have an aircraft in controlled airspace just above or descending through it towards gliders circling just under the bottom of it. We believe that’s going to cause quite considerable problems.
So my second question is; just follows on from that: Will the CAA please give us the assurance that they will not implement the mandatory carriage of Mode S in the cases they’ve mentioned until they’ve satisfactorily resolved these technical issues, which I think are quite serious ones, as otherwise I think you may find your technical ambitions for the use of the system are not satisfied. Thank you.
The points that Peter’s raised there are ones that we’ve discussed and addressed in the past and are a valid issue. TCAS does have operational limitations, that’s always been recognised and that’s always been understood. In terms of the proposals though, let’s put those back into context because we’re not talking here just about the TCAS issue. We’re talking about the safety nets that are operated within controlled airspace. For example which, as Peter correctly pointed out, the French identified is also the ground segment is a significant and key issue within that. In terms of the performance against TCAS and the potential issues that could be caused by a large stack of gliders what we, part of the consultation and part of the discussions with the BGA are to identify where they are likely to occur and how they can be taken into account. Well, you may all laugh, part of this process as well ..(AK speaks very loudly and the recording is clipped)…As to how you look at the zones of the airspace and where some of those issues are discussed with the BGA for the future which is coming in a consultation document That’s a fact that we all need to look at. And in terms of actually looking at where activity is related to a competition for example, as well, then Airspace Notification …(clipped)…are some ways we do now with how to manage those activities to help you. In terms of further usage, yes we are always looking at the model of the environment and making sure that we understand as fully as possible all the potential issues associated with any proposal we subsequently make to government. While various documents that are made, there are various proposals which come in of relevant countries and we have to take those into account. We have to try and fill in any gaps ourselves. As a …(clipped)… I would also just add that the FAA are looking at similar proposals for gliders and we’re trying to have an open debate with them to look at their issues as well to see how we move that forward. As far as the second point is concerned, Peter, no I wouldn’t give you an assurance at this stage because we await the results of the consultation and we’ll look at all the responses and then we’ll determine how we’ll proceed
Peter, those were your 2 questions? Yes? I said that we’d take a break at about a quarter past eight. Let me just take the mood of the room. We have the option of continuing straight through, albeit for another hour and a quarter. If you’d like to take a break for 15 minutes, stretch your legs, possibly steal a chair, can I have a show of hands please?
Ok, well, hardy individuals – I’m sorry gentlemen. There’s no out at this stage. Could I just ask those people at the back of the room if at all possible to shuffle to your left, my right, because there are people still standing outside I think. There’s actually one chair here – we’re going to auction it off. Three! There all equally valuable.
Ok, we’ll just give 60 seconds for the room to quieten down and then we’ll move on.
You talk a lot about how you have done computer modelling of various things and you are going to do all this other computer modelling, but you also state that you don’t actually know what goes on in Class G airspace a lot of the time. I was just wondering how you would like to consolidate those 2 issues because computer modelling is notoriously inaccurate at the best of times, and it gets significantly worse the less you know about it?
Right I declare my hand as not being a computer nerd, and I do not - well in fact I agree with you entirely – rubbish in, rubbish out. We can only go on the basis of the best information we’ve got, and that is what we have tried to do. Now, if there is more information you can provide us with and in responding to the consultation if you think that the information about how gliders perform, what they do, where they go, what sort of numbers, we’ve got it wrong, please tell us. But I’ll tell you what we’ll come back to you with, we’d like some information, some firm information to back it up with, because otherwise we would be equally accused of basing our consultation outcomes on flawed information. So, whatever you can give us in terms of hard facts, and in fact we have worked with the BGA to find out some information about flight level bands, what are the most used, what are the most used areas. But in the round, we’ve done I think maybe twice over the last 25 years that I’m aware of, a couple of sort of snapshots of what goes on in Class G. Some of you may have been involved in the past where we actually sent out census forms, we got the air traffic units to try and produce some information. One of the things we may need to do, is to do that again. Because actually if we constantly go around this thing and keep running up against this problem of what’s actually going on?, do we actually know the full information?, where do we get it from?, it’s a problem. So out of this whole process we may well be coming back to you. If we do, could we please have your help, because in answer to your direct question we can only go with the information we’ve got, we will try and use the best information we’ve got and if we haven’t got it we may need to come and get it.
I just want to pick you up on one point. You mentioned flawed information. Of course an analysis based on flawed information is flawed, but actually analysis based on partial information can be equally valid. There are various modelling techniques that allow that to happen.
Ok, any other questions about the safety case? Excuse me, gentlemen, There’s one gentleman right at the very back. Could you just stand up please and announce your name as you ask the question.
Can you not use the BGA ladder as a source of flight information. Can you please make NOTAMS more understandable – graphical systems are easy to produce now – the old system is unclear and dated. Safety would be improved by glider pilots being able to use the radio.
Thank you, could I say I agree entirely with what you have just said. But unfortunately when we speak to some people we get a very different response and the response is, we don’t want a licence, we don’t want any form of training and in most cases, we don’t want to use a radio. Again going back to my co-operative theme, I agree with you entirely. I’m an air trafficker, when I fly, quite often I don’t speak to air traffic. I’m very happy to be on a radio frequency listening to what’s going on, I’m very happy to be able to react to that and if I need to say, “hello this is me I’m here,” that’s fine. In fact I think some of those listening out squawk trials that we have been doing and hopefully that will become more widespread, is the way to go. But we need people to co-operate, and I agree with you that if we had the ability in lots of cases to have more people using the RT properly, so its short, we get essential messages across not your entire life history, then actually that’s a benefit. On the AIS website, we don’t run the AIS website let’s be clear, NATS run the AIS website, but we regulate them and one of the things we have been very keen to do is exactly what you describe. We want a better interface, we would like it to be more user friendly and we would like it to have some graphics. NATS are relocating their AIS facility this year and we hope that, while they can’t do it right now at the first, within current system, that system is about to be replaced and we’ve made a requirement that a graphic interface is one of the elements of that new system.
Hansard reports that you’ve curtailed all infringement event research. Why, if as you claim, safety is important?
You can’t hold me responsible for what’s in Hansard. I chair the CAA Airspace Infringement Working Group. We met last 2 months ago, we have another meeting in a month’s time, that work has never stopped. In fact actually the work has expanded because as we touched on earlier, the number of airspace infringements is going up. So while we may have stopped any formal research in a research budget type of aspect, I assure you that the work is going on. It’s going on actually quite effectively through a number of fora, including this Airspace And Safety Initiative working with NATS, MOD, other air traffic service providers and a number of representatives of your community. So I would be very interested to see what Hansard actually says. The RNB bit I assume is possible because of course we face funding issues too and have to trim back on things because people don’t want to pay some of the charges we may have put in place in the past – but in terms of airspace infringements I assure you that work is going on and I am personally involved in it.
What is the basis of that work?
Well the work is going on, on the basis of the infringement reports that we get so we are actually working, looking at trends, where these incidents occur both geographically and for what reasons. Eurocontrol have also picked up on that and there is now a very large infringements thread running through GuA (CS: unsure of the last abbreviation) control which we are contributing to as well, so we are actually getting some research work, if you like, done through the Eurocontrol budget. As far as we are concerned we monitor very closely, actually there are cases we get some very good reports. For example for the London area last year there were 369 infringements of controlled airspace in some way shape or form. That figure is actually up very slightly on the previous year. That’s the London TMA only.
We are now going to move on to the set of questions related to Option 1. Remember we’ve got 4 options to work our way through so we need to move on to stick to time. Chris Garton is going to ask the questions from the pre prepared, sorry from those that were submitted.
Non-transponder equipped VFR aircraft have been able to gain access to Class G airspace for many years perfectly safely when the traffic situation permits on the basis of an RT clearance. In consequence they have created a known traffic environment that the CAA requires. What is the actual change that justifies the CAA requiring mandatory transponder carriage and operations in controlled airspace even for VFR flights?
The access is as always has been on the basis as authorised by ATC. In terms of the proposals under Option 1, as you will read in the consultation document, we have said that ATC can still allow access for non equipped in certain cases. The issue here is again is maintaining the TLS, looking at the integrity of the safety nets that are employed in there and making sure that as the changes and demands on that controlled airspace continue to increase, in the light of the current arrangements and the current forecasts, that that TLS can continue to be delivered. There is an argument as well that says in terms of gaining that access, the air traffic controller should be in a better position to be able to manage that access. Now I know some of you will say, well we have some examples where we’ve actually been denied access even though we’ve been transponder equipped etc. This has all been an issue that’s been raised in the past and discussed within various bodies within DAP within our consultation process concerning GA access. DAP has always taken the view that GA access to airspace is always a stipulation he puts on any airspace change on the proviso that he puts on the air traffic service provider. We have in the past conducted exercises to try and find out the reasons for denial in …(clipped)… and will continue to do so, to press for that, but it is a basic issue that we would see the access with the carriage being more efficient because the air trafficker can actually monitor in 3D what you are doing as you progress across the airspace. And …(clipped)… your interaction with the safety nets helps protects the operation and any potential disruption to it. But its maintaining a case for the future not …(clipped)… future demand.
Thank you, that has actually pre-empted one of the next questions and the question was. The proposal, both the written proposal and the DVD use the term ‘the proposal will contribute towards improved access to controlled airspace to all users’. The question then goes on to say that these are the experiences of many airsport pilots, that even with transponders, access is denied and not always for obvious reasons. Indeed one major air traffic unit has explicitly stated it would never under any circumstances allow gliders access to their airspace. So the question is: How is the CAA going to ensure that transponder equipped aircraft will be given equitably access and indeed improved access to controlled airspace in future.
A very reasonable question. There is a mechanism that exists today that you the BGA actually have to enable you to report where you can’t get access to controlled airspace. Carl (CS: can’t hear surname) and I have discussed it many times over, I think in the time I’ve been in DAP I’ve seen 4 reports reported through that system. We are very happy to go and engage with the air traffic service provider, whoever it is, wether it’s the MOD, whether it’s NATS, or any other airport and say, “this airspace is not your airspace, it’s airspace that has been allocated to you for you to manage. We set the rules and actually the rules say that in Class D airspace aircraft should be allowed to access under certain rules, certain conditions.” Now that doesn’t mean that you are going to get into that airspace every single time you ask for on the track that you ask for on your glider approach into somewhere or whatever. We will monitor very closely whether access is being permitted and I think if some of you remember, some time ago, Birmingham issued a Notam saying if you are a light aeroplane don’t bother calling because you ain’t gonna get in. Well we went back to Birmingham as soon as that Notam was issued and said, “change it,” because that’s not the way the Class D rules are designed to operate. Now for the future what we would be very happy to have in place is a mechanism that is available to everybody not just the BGA system to get those reports of where access to airspace is not being granted. I’m not saying we will investigate every single incident, but certainly where we start to see trends, we will be very happy to go to that unit and say, “what’s going on?” Now some of that is around how the request is made, some of that goes back to the RT point at the back of the room and if you don’t actually get your message across succinctly and accurately, you’re probably not going to get what you want straight away. But at the end of the day the rules should permit it and we would be very happy to have an enhanced mechanism for understanding where people aren’t getting access to airspace and we are prepared to do something about it.
Actually I’ll just ask 1 or 2 more questions, Chris, if that’s Ok.
You mentioned in the presentation that letters of agreement are proven to be highly effective, sorry not your words, mine. They are highly effective, safe and practical means to allow GA pilots, not just glider pilots, to operate in close proximity to CAT. Why is it not more appropriate therefore to exploit the practical success of LOAs instead of introducing a new, and as Peter mentioned, in some cases unproven significantly expensive technology instead?
Well the nearest thing is, Patrick, our experience is that in some places they work very well and in other places they don’t. I could cite probably Dunstable, London Gliding Club as having an extremely effective arrangement with Luton and when you consider how close the site of Dunstable Downs is to the Luton final approach, actually if it didn’t work very well we would have a problem. However that is not repeated everywhere and it requires, in all of these cases, 2 to tango, as it quite frequently does in most things. So it actually requires people to comply with the letter of agreement, well first of all there doesn’t require there to be a letter of agreement, it requires there to be written and very clear and operable and it requires people to comply with the rules and unfortunately not everybody, unlike everybody in this room, is as good as complying with those rules. So actually what we are trying to do is make the use of the safety nets, which are there, to enhance the situation and cater for when things don’t go quite as planned in the first place. There is no doubt about it, in some cases they work very well, our experience is that in other places, they don’t.
I would like to just add one small point to that and that’s the problem with an LOA of course is you need to have an organisation to be able to make it with, or a group of people to be able to police it effectively in many cases and for a lot of the issues we are talking about here, there are various operators that will fall outside an arrangement that could be covered by an LOA in every case and that’s part of the issue as well.
Although we’re primarily concerned with those organisations that are well used to operating with LOA’s and therefore would like them to continue.
One other question: Your own forecast for commercial air traffic density growth, or rather the forecast that you have used, clearly show that forecast growth is not uniform across the country and there are many parts of the country that are unlikely to see much change at all in CAT patterns. Why then is it necessary to force this option on all areas of controlled airspace in the UK?
The issue on this one is difficult in terms of making sure that the arrangements actually satisfy the requirements within the airspace. The one thing I’d like to point out is that by making the arrangement associated with the controlled airspace structure, of course all of that is appropriate to the airspace change process, and all airspace has to be reviewed for its requirements. I think if there was a case made that there was a particular exception as we have outlined within some of the arrangements detailed within the proposals, they would have to be considered. But where we are looking at achieving target levels of safety throughout the structure and the safety nets concerned within the controlled airspace structure, where these requirements we believe to exist, we feel it appropriate to keep the rules simple and straight forward as appropriate. But as I say, airspace change requests, airspace change process, is something that can be enacted and reviewed on request by any party within that arrangement.
Sorry could I just add, we touched on this slightly earlier on, the growth is not consistent everywhere quite definitely not and we’ve got some very peaky growth in some of the areas that are serviced by, again some of the low cost operators. Doncaster is a classic case in point, Humberside. These are areas actually away from the major conurbations and actually these are the same areas that you or some of your colleagues do actually want access to as well.
Are there any questions from Option 1 from the floor now?
(CS: can’t hear question, roughly) Do you do anything about LOAs that don’t work well?
Yes, I personally have been to Aston Down where at one stage the relationship between Kemble and Aston Down was not good. I’d like to think it is actually slightly better now than it was then, so yes, if we are aware…, we have a role in quite a lot of these places to act as an independent broker between different airspace users, and we quite frequently do. But we don’t actually have any formal role that says we have to authorise, approve, oversee, govern, regulate LOA’s. Frankly I don’t think we particularly want that because actually what you want is the 2 parties in the LOA or the 3 parties to actually co-operate, back to that same word again, in terms of your activity as an impact on mine and mine as an impact on yours, how can we actually make the best use of this same bit of airspace. And at the end of the day invariably it comes down to compromise and a balance. And it was very interesting in the Aston Down case, I went there one very wet winters Sunday morning and actually one of the parties had brought some lawyers in. Now if there are any lawyers in the room I apologise now. We almost got into a legal argument and it didn’t help because, at the end of the day, what we needed was a pragmatic solution to the problem and eventually I think that’s what they’ve actually come up with. So the answer to your question is yes, if we are aware of it.
Any more questions on Option 1 before we move on to Option 2 – ok. Ian Strachan is going to ask the questions that came in on Option 2. Ian.
Transponder mandatory zones - I think to avoid repeating that all the time I will refer to them as TMZs if that’s ok. We notice in your in your consultation paper Option 2, the emphasis is on supporting TMZs not considering TMZs. And I have a first comment I suppose on strategy, policy if you like. It is to all intents and purposes a new category of airspace, certainly to us in Southern England. You have gone straight to the issue of process rather than the broader aspects of the TMZ and the impacts on all different types of aircraft. Would you like to comment on that?
Yes, first of all, of course, TMZs do not introduce a new class of airspace TMZs have already been around for a long time and we have been using them. Already we use transponder carriage, which is mandatory in Class G airspace. Granted above flight level 100 but it does exist. In terms of how do we see them for the future and the strategy, the TMZ is another tool in your toolbox to address airspace requirements. It’s an option that may be considered along side for example, while a request may have been made for increased controlled airspace. What the issue will resolve more effectively by using a TMZ and more appropriately, rather than just extending a controlled airspace. Now the issue within this consultation is we’ve always said, is for us to make sure that that we can put in place a clear, accountable, transparent process for such cases to be considered. Because that brings everybody, including all the groups that are involved in tonight, in to that process on a more formal basis. For us it’s an option we already have, we have already used it, but this makes it a process and part of the formal airspace change process, so the reasonableness of it, the appropriateness can be formally addressed and that any consultation issues around that can then be demonstrated by the applicant.
Ok, a very simple one: how widespread do you think the TMZs are going to be?
It is the (CS: can’t hear) intention behind this proposal to see what the (CS: can’t hear) TMZ’s across the whole of remaining Class G airspace in the UK. First of all let’s make that quite clear. These are going to have to be looked at on a case by case basis to address a specific issue, because every time we introduce a TMZ somebody is going to be effected by it. Not just somebody who may benefit by it and that needs to be looked at. At this stage the incidence of it may not be very high at all, we can’t prejudge that at this stage. We can say, yes there are potential scenarios where a TMZ may need to be considered, but they are in the process of considering what is the best solution to that particular problem and what’s the best airspace arrangement that we put in place.
Can I just add to that, on the DVD that you’ve got there is actually a slide that, (it’ll probably take too long to get this thing warmed up – we’ve actually got it on the screen there at the moment) which is a slide which shows infringements in the London area. Now, further to Andy’s point, we want these to be targeted, focussed and specific. It’s not a case of just blanketing them everywhere, because actually managing them then becomes more of a problem, particularly when you start talking about potential exemptions or how you deal with a particular site, whatever. So focussed for a specific need and you will see on the slide there are some really difficult clusters of infringements in the London area on the periphery of some of the CTRs. For example, those might be the sort of area where we would target this as an alternative to increasing the size of controlled airspace, because that’s the other option. So we see this as beneficial.
Phil Roberts mentioned infringements. In the consultation document there are various reasons for the potential establishment of a TMZ. Infringement history is one, collision avoidance, efficiency of air traffic and high traffic volume. Are there any other likely reasons and have you any idea at this stage which of those reasons will predominate when TMZs are set up?
I’m afraid a simple answer to you last question is, no we don’t, but other uses, well we’ve had transponder mandatory zones as Andy has described in other parts of the country for other things. To cover outages of primary radar where there has been a problem because an antenna is being replaced, we’ve tried to maintain the sort of level of safety. A number of those have been off the coast so in your terms that probably hasn’t bothered you too much. We’ve got a couple of options in our back pocket at the moment on the grounds that wind farms are a problem and they’re probably a problem to you in your final glide in too as well. But this particular one is about radar interference and one of the ways of dealing with radar interference in wind farms is to put a TMZ around that particular area – so that’s one of the potential applications inside controlled airspace. The proliferation of wind farms is another issue we all have to deal with.
Thank you. Recent comments we have heard from CAA officials have suggested that you would like to have TMZs as soon as possible in certain critical areas. Where are these areas and what do you consider critical?
Well, it goes back to Andy’s point of earlier – we are not going to sit on our hands and do nothing and wait for something to happen. I don’t think you would actually expect us to do that, so if we think we’ve got a weight of evidence that shows us we have a problem, then we are going to explore all the possible options for how we deal with it. Now you will see on that slide when you go on the DVD that there are some very specific clusters very close to the final approaches of some of the big airports in the South East. A number of those incidents have resulted in airproxes, some more serious than others, and while we have got some additional measures, NATS for example have now got a tool called CAIT (controlled airspace infringement tool) which allows a warning effectively if a track is likely to infringe on a piece of airspace. That’s again something we would like to try and see more widespread use of, but it requires co-operation, it requires somebody to be transponding for that bit of kit to say look out for this one, this is a potential infringer – either laterally or vertically. So targeted and focussed where you think there is a problem that can’t be resolved by something else. Equally if we’ve got a couple of years worth of data, and I’ve got 2 slides like that one, they’re not both on the disc but actually they are not hugely dissimilar for 2006 and 2007, so that’s the sort of area we are looking at in the short term.
Thank you. Your handout which we will have has a sketch map on the back which suggests that TMZs will be used to provide what I might call ‘buffers’ around TMAs. Now, is this a broad intent or is it artist’s licence?
That’s only an illustration as a possible concept; we’ve already said everything will have to be on a case by case basis. We are not saying here is a potential set of circumstances, our policy is in the future, every time that set of circumstances occurs we’re going to put a TMZ in it. That is not the case. Every TMZ would have to be fully justified on a case by case basis.
I’m sorry, I’ll have to quote some figures here. In the last 10 years we understand there have been 26 occurrence reports MORs on airspace infringements by gliders. I’m sorry to the non gliding people we’re always hammering gliders, but at least hopefully we are sort of in the same boat. Now 11 of those 26 were at a known club very close to a major airport and we believe that that situation has been solved and there haven’t been any incidents since 2003. That leaves 15 over 10 years which is 1.5 per year. Now we look at the GA infringements in that time and of which there were 300, therefore gliders make up only 0.5% of the infringements. Furthermore there have been none since 2005 and you may be aware that the majority of competition and cross country gliders now carry moving map displays – my own glider has 2. This may well be a factor, would you care to comment on that situation?
Entirely that in terms of those who have that type of equipment probably have a very good track record of not infringing airspace. There was a very interesting article though that appeared in one of the GA magazines the other week about somebody up at Glasgow and this was related actually to the use of GPS, where I’ve got GPS, I know where I am so I flew down the line. Now that’s great on the one hand if you know exactly where you are and if you continue to know exactly where you are. But of course once you are one the line technically you are in, it’s a bit like a goal in football and in another way, one of the things we’ve found through the On Track project which many of you may have contributed to some time back, the independent team not from this area who went round and gathered information on infringements, that the use of those types of systems GPS in particular actually encourages people to go right up to the line. Then what happens is, there is a momentary distraction, we’ve all been there, I have, and because you are right on the line actually it doesn’t take very much to be across the line. So in terms of the glider data, I accept what you say, I say I’ve had this conversation with Colin many times over and I’ve seen some of your print outs. One of the problems we do have and we know we have it on the fixed wing side as well as the powered side is an under reporting. We’ve seen an increase in the infringement figures go up over the last couple of years because of a better reporting regime. We are actually very happy to have that because we’ve known for a long time that we don’t have the true picture. We’ve known we’ve had a percentage of it but we don’t know that we’ve had the totality of it. And of course the difficulty with gliders in many cases is that you don’t paint on radar anyway, so people don’t actually know you are there.
Given that data clearly shows, and I’m following on from Ian’s question, and indeed your own colleagues in the CAA have been known to state that the use of moving maps in gliders is an effective tool in reducing the risk of airspace infringement and in Ian’s statistics show in fact to all intents and purposes is down to zero, at this present moment in time, given that the data clearly shows the infringement risk associated with gliders is extremely low, then why is it necessary to mandate transponder carriage by gliders in TMZs that have been established to reduce infringement risk?
It’s a case by case basis. We are not doing that just to get at gliders or anything. Every one would have to be looked at and justified. Every TMZ to restrict infringements would have to look at that particular activity and in relation to looking at that case by case the impact on any associated gliding activity would have to be considered as well.
Can I just ask the question again? I’m not being flippant, because this is a very important point because we have evidence and you said evidence, and I underlined it 3 times, is important. So, given that the evidence clearly shows that the infringement risk associated with gliders is extremely low and indeed zero in the last 3 years, why is it necessary to mandate the transponder carriage by gliders in TMZs that have been established to reduce infringement risk?
Because we are not creating TMZs specifically for gliders, we are creating TMZs as a tool to help resolve an issue. Now one of the things we have said, is actually Dunstable is a fantastic example in this case in point, we will probably need some mechanism, LOA, MAU whatever, that says in that particular area we are quite satisfied that we can create some form of safe operating mechanism, that will ensure that not only all those of you who do carry kit that will allow you to know exactly where you are, and even those people who occasionally make mistakes, will reduce the likelihood of something going wrong. But let’s be clear, the TMZ thing is not specifically a glider issue, we’re talking about TMZs in the round.
The question specifically related to the proportionality by reducing the zero risk is quite different, therefore why do you state the mechanism to reduce it is for all airspace users where the risk is very, very low, if not zero. That’s the question.
Well let’s be clear, we don’t have a figure that says it’s zero risk. I accept that you have some quite good information, I accept that actually that’s helpful because we touched earlier about having good information, but we don’t know and I don’t think you do either, that’s its zero risk. So this is just a component part of this whole approach.
If I can continue on to policy matters to take the heat off both the glider area and specific incidents. I believe you have said that a proposal to establish a TMZ is a proposal for an airspace change – is that right?
What we have said is that we believe the airspace change process, which is introdu- perhaps we modify to allow proportionality and scalability as to what we are actually talking about because we may be talking about a very small airspace change and to make it appropriate to what’s being proposed; is the appropriate process to use. We already have an established airspace change process which ensures that it’s open and transparent and accountable and in our view at the moment is that we build the TMZ Policy application for a TMZ on the back of that process to give exactly those things. To ensure the right people have to justify the case in the first place, that the right people are consulted and the right evidence is presented to support the original application, so that a decision could be made against that application.
So as I understand it Andy, we have looked at the documents
particularly CAP 724 and 725, sorry about the gobbledygook guys, those
procedures will apply?
No, that wasn’t what I said. I said we would use a modification of those procedures because we felt the airspace change process gave the right sort of infrastructure to make it open and transparent and accountable. Now what we actually haven’t said in the document is exactly yet how we are going to modify those, because one of the things we need to look at through your responses to the consultation is what do you want to see covered in that application process.
Possibly the answer is 725. Can I quote some words which are in your document? TMZ establishment process, you mentioned it just now Andy, would need to be scaleable to ensure the burden on applicants is not disproportionate. This is in the document, yes? How could you ensure that in an abbreviated process, the shortcut process, doesn’t favour the applicant over the local users of that airspace?
Let’s be clear, the airspace change process as it currently stands covers everything from changing the Class A around Heathrow, putting in a new airway over the north sea, modifying a bit of the Galsgow CTR or anything else. So it’s scalability is everything from a tiny filet of controlled airspace to the west end project done a couple of years ago which was about a third of the land area of the UK. So, we need a process that ensures consultation and ensures that we have the ability, as we do for all other airspace changes, to ensure that what has been done through that process has been done properly. And in this particular context it’s likely to be around airspace user issues more than, on some of the other airspace changes we’re currently working with, environmental issues because of how the public is affected on the ground. So it’s tailoring it to the right audience and in this particular context the audience that we would be seeking to engage with or the proposer to engage with. It wouldn’t be us, we would take the proposers’ consultation, look at it, consider how it is being done, does it meet the process and then make a decision based on that. So, let’s be clear, the 724, 725 is what’s there today, it would need some adaptation to fit it for this purpose to make sure it worked.
If I can just continue the last point, I guess really. At the moment as I understand it - we understand it, you the CAA are obliged to follow 724 which is virtually your constitution and the 725 procedures. Now we realise there is a fast track which is built in for special, what you might call, force majure cases of particular accident safety cases and security. I noticed terrorism and so forth, and this is fine, it is not in any way in those publications to reduce the burden on routine applications. So therefore the question is, where in these documents, which you must follow because they are your constitution, is this abbreviated process allowed?
Well actually it says on safety matters we have the ability to make a change. Now I think when we consulted on the airspace change process, crumbs we’re going back 8 or 9 years ago, this was one of the issues that came up where we could impose a requirement on other airspace users. We said at the time in response to that consultation, that we only saw this being used in extremis and actually, other than security incidents around 9/11 where we basically imposed a restriction because the government told us to do so, I don’t think there is a single example of where we have imposed that requirement outside Humber (CS: not certain if this is the right zone) Class D because they had lost all their primary and a number of areas over the north sea, which were done to protect oil rigs. We said we wouldn’t, we haven’t and as I say, we would need to modify the process to make sure that that wasn’t something that could just routinely happen week in week out – because that’s not what we are intending.
Thank you my final word is a comment I guess. Surely it’s more important to consider the permanent burden on local airspace users if a TMZ was established without the usual checks and balances compared to deliberately allowing an exception from what appear to be your SOPs for what you might call administrative reasons.
Are there any questions from the floor on Option 2? We’ll
start with this gentleman here. There’s a radio mic beside you.
If you took an imaginary piece of controlled airspace and put a transponder mandatory zone around it to protect it from incursions, an aircraft without a transponder could well be able to fly in the controlled airspace if it’s Class D, but it won’t actually be able to get there because it won’t be able to get through the TMZ. Do you anticipate any mechanism for allowing aircraft without transponders to penetrate TMZ’s under some form of control or by LOA?
Well let’s be clear John, we are not talking about creating
rings of steel round every bit of controlled airspace, we could never do that,
we might as well change the controlled airspace. I think in terms of creating
corridors for access I think that’s one of the things we’ve touched on it’s on
the video. In some cases you might have to create a corridor, an option a line
or something that allows those who are not RT equipped or transponder equipped
to access that airspace. But again when you start to consider these on a case
by case basis, if you had 1001 reasons why you have to do that, you’ve then
watered down the reason for having one in the first place. So you have to go
back and assess what’s this particular piece of airspace, what’s its
characteristics, who uses it, how often is it used and again, if we are talking
about Dunstable Downs London Gliding Club on the northern edge of the Luton CTR
control zone, actually that would be completely fatuous. We are trying to be
realistic about these proposals and we are trying to use them to deal with what
we think is a real issue. This isn’t a case of blanketing the whole of the
South East of England, I assure you.
If TMZs prove to be effective, can we expect to see a reduction and downgrading of airspace?
What a lovely idea, why not? Let’s be serious, why not? If you’ve built the co-operative environment, if you know who’s there and either through RT or through the use of SSR you can manage that airspace efficiently, why not? Which is why I come back to the point that was made earlier about the airspace change process and TMZs. We’re actually trying to make this process better, we’re trying to make sure that you as the airspace user have the opportunity to make sure that your voice is heard in this debate. So I’m a little taken aback by the sort of line of questioning about the airspace change process. We are actually going to change it, because it isn’t actually quite suitable for that purpose in its entirety now, to make it better for this and that would be a consequent follow on option if we ended up changing it in line with what’s being proposed here.
I think the specific point about the airspace change process was that it mentions that it’s scaleable in the interests of the applicant. What we were talking about is, is it re-scaleable in the interests of other stakeholders? That was the point I think.
Right, we’re now going to have to move on to option 3. We have 25 minutes left before we have to close the meeting. Gordon MacDonald is going to ask the questions that have been collected on Option 3. Where’s Gordon? He’s about 3 miles away from the radio mic.
Found the switch! Right, in formulating Option 3 what specific data has the CAA used to establish the levels of collision risk that actually exist, or are predicted to exist, above flight level 100?
We are looking again at the delivery of a target level of
safety identified by ICAO. We have an operation in there where currently,
transponders are required by everybody else who operates within that airspace.
We have safety net systems which are employed within that airspace. And the
issue we are addressing is whether or not the operations that go on within
there for non transponder carriage equipped people, by continuing to allow that
as a matter of course, does that degrade the overall safety within that
environment. And our perception is at the moment, that if you have people in
there operating, have a low RCS (Sorry - radar cross section) and are therefore
non-identified by primary radar and are not consistent with the other safety
nets i.e. SSR on the ground or the employment of collision avoidance systems in
the other operators that are working in that airspace, how do we manage their
airspace? And it’s similar to the issue that led to the establishments, the
TRAGs above flight level 195, it’s a case of how do we manage that potential
risk. And in our view we have to say what is also the case that says that could
continue in the face of continuing demand, and that’s why we are asking the question
through this consultation. We have looked at it and in our opinion, and I
stress that, it is our view that we are not helping the safety management of
that airspace. So we have to ask the question is it right that that continues
or given the interoperable requirements or technologies that are used within
that airspace, do we allow that to continue or do we change the rules so that
we can manage it more effectively for the future? And that’s why it is included
entirely as a separate element concerning the gliders within the consultation
process.
Thank you for that. Do you believe the risk profile might
actually vary across the UK however, now and in the future?
Yes, I mean it will do, it’s bound to because of the change we’re dealing with – I mean, it’s back to the original problem, the CAA can’t just sit back and see what happens, we have to try and predict based on the information we have. But against that same criteria we have to be prepared to review and monitor for the future as well. We know the risk profile across the UK will vary, we know it changes and that’s why within the consultation as well we’ve said, we want to be able to work – let’s take the gliders - we’re talking about option 3 here so talking specifically about the glider option above flight level 100 for example, how could we work with BGA to try and identify some transponder free zones which could help address that issue where the airspace and environment was appropriate? And how can we address that within the safety management of the overall airspace structure – so yes I would agree with you.
Thank you. Right, moving on. I was very glad to hear Phil earlier, say that airprox is a very key indicator of safety. Airprox Board Reports 11-18 cover the 4 years from mid 2003 to mid 2007. In these 4 year there are 31 risk A and B airproxes involving commercial air traffic aircraft. 18 of these 31 airproxes were outside controlled airspace. Of these 18 airproxes, not a single one involved a glider. So why does the proposal call for gliders to carry Mode S above flight level 100 outside controlled airspace when there doesn’t appear to be any problems whatsoever?
I think what I actually said was the airprox data is one of the few things we’ve actually got. It is, well it relies a bit like infringements reports, on reports actually being initiated in the first place, because unless you’ve actually got that MOR that goes into the system it doesn’t filter its way all the way through to the airprox board and make it into their statistics. In terms of the operation above flight level 100, what we are now staring to, let’s be very clear, we’re now starting to narrow down the size of the community that’s affected. Equally, the nature of the other things that go on in that airspace are largely commercial air transport and military activity. There are not a lot of GAA activities other than gliding in some specific areas that take place above flight level 100, on the basis of what the knowledge that’s available to us. We have started to look at how do we manage that risk? In the case of commercial air transport we have a set of principles, procedures, agreements and as I mentioned earlier the ICAO requirement to get the operator to actually do a hazard analysis and a safety case about their operation in that environment outside controlled airspace will become a requirement from next year. We are actually working with most of the UK operators, the ones that we can, to get them to do that as best practice now. Somehow or other we’ve got to try and create that environment, bearing in mind that they are the predominant users, and make it as safe as we believe we can.
If I could just follow up on that as well, I think when I get my previous answer as well, when we were looking about the variance of activity across UK airspace and the implications, we’re looking again at highlighting the areas where, in terms of probability and potential impact, are these considered to be an issue in those areas where it might not be, that’s where we want to work with the BGA and try and establish these transponder free zones. So I think that the issue you are raising there, we’re actually looking at taking into account and addressing through the process of the consultation and where we move forward from that in the future.
We think it would be reasonable to conclude that gliders should not be required to have transponders in any airspace from flight level 100 to flight level 195. Yet the document poses a blanket requirement for that Mode S above flight level 100. With only limited access to portions of that airspace by gliders and transponders. So given the facts why does the CAA consider option 3 given the obvious disproportionate affect it would have on gliding compared to other airspace users?
I put the question back to you – is it disproportionate when (interruption) …hang on let’s be clear. Who is the principle user in that airspace environment? Is it gliding? No it isn’t, let’s be really honest about this. The amount of gliding that goes on above flight level 100 based on the information that you’ve provided to us from the BGA, indicates that we are actually talking about a relatively small proportion. Now, we also know, based on information that you’ve provided to us, that actually most of that goes on in some quite specific areas. So some how or other for the other users the proportional impact from their point of view is that what they would like to have is clearly a co-operative environment where they can see other things that are operating in that airspace. So here we come back to the balance argument again. How do we deal with managing this in the most balanced way to try and accommodate the needs of all airspace users? And as Andy said, we are very happy we’re in conversations with you now, your senior management in BGA, to try and identify what those areas are. And again through the consultation if you would like to tell us, please do, because at the end of the day this is what we are trying to come to terms with is understanding. We’ve got some information, we won’t say it’s perfect but we are trying to react on the basis of the best information we have and if the consultation improves that information then we’d be very grateful.
Could I just add one extra point as well on that and that is one of the issues we’ve always been faced with is how to we look at what is going on around the world as well and in other airspace. For example the Dutch are just introducing the requirement for transponder carriage zone above 1200 feet across all their airspace and we consider that that’s no appropriate for us and that’s what we’ve looked at. And what we are trying to do is to adopt our proposals to address the same sort of concerns that have been expressed throughout European airspace, but to allow something that is much more manageable for all the airspace users in the UK. But it has an impact, we recognise that.
Moving on. This CAA diagram on our chairs shows areas where
gliders might be exempt from carrying transponders above flight level 100. These areas are directly connected to
existing TRA for gliders from level 195 and up. Is it a specific CAA working area or idea or another example of
just the artistry?
It’s just an example as we said to you, these are areas to try and - diagrams to try and depict to give you something to be able to look at to at least try and grasp what the options may or may not be. They are not specific proposals because those specific proposals would have to be constructed in conjunction with the BGA and the other user groups involved to make sure that what ever was proposed was the best compromise that we could come up with as well. So please don’t read anything into those, they are for illustrative purposes.
I’m just very keen to allow 1 or 2 questions now from the floor on this one and I’m conscious of the fact that we’re actually moving on in time. You have a question?
Re above flight level 1000: someone on the ground is needed to achieve the TLS. Who will this be?
The answer is nobody. It’s intraoprability with the safety nets that are employed by those organisations and those operators in that airsapce, we’re not saying that by doing this you’re talking about provision of service within that. We are improving your identify and your visibility to the safety net systems employed within that airspace. And that’s what we are talking about trying to resolve through this proposal.
There seems to be some confusion between TLS and reducing risk. If the risk of a CAT/glider collision is roughly 1 in 1,000,000, surely this is acceptable? This is approximately the same risk as for a double engine failure.
Actually that’s a very interesting point because what actually happens today we know, and I think there are one or two airline operators in the room who fly for a living might support this, is that to go through that volume of airspace at the moment, they don’t actually analyse the risk. Now come 2009 the ICAO requirement will force them to analyse the risk and through this Airspace And Safety Initiative we’ve already taken action through our flight ops department to encourage that as best practice for UK operators, which is about all we can do until the ICAO requirement comes in. So I guess what we are trying to do is to make it as good as possible without actually imposing what we consider to be a massive burden on any user of the airspace. Particularly, we get to this proportionality debate again, the number of people who use the airspace above flight level 100 is a relatively small proportion from what we are told by the BGA of the totality of all gliders. We are trying to apply it elsewhere but the problem is, this isn’t a straightforward X verses Y there are a whole waft of other considerations that at the end of the day we are obliged to take into account. This is one piece of the jigsaw, please don’t think this is all about gliders and Mode S, this is actually a much larger issue in the round, of which the gliding issue is one part.
The CAA have made reference to material that the BGA have provided them on flight level, on flight above flight level 100 or those parts of the country where it does take place and how many areas of the country it takes place the significant commercial air transport activity. We will make that report available on the BGA website so that everybody is aware of the full set of observations that were shared with the CAA, because I’m not sure it’s easy enough to state them in just one sentence.
I’m conscious of time. Excuse me
sir, I’m conscious of time. We still have one other option we need to ask a
couple of questions on and then I’m going to ask a couple of questions on the
cost related issue at the end. So can I ask John Brady who’s got the questions
on option 4 to stand up please.
(CS: first part of the question was not heard: no mic) … a French aircraft could fly in the UK FIR but it won’t be able to get here because if won’t be able to cross the FIR boundary. Now I recognise that the UK wants to comply with the ICAO standards, but there actually another 603 differences on the CAA book and I’m sure you’re not addressing all of those. There are areas of the world where actually this is very important like the Eastern Mediterranean where if you don’t have a transponder because the air traffic organisations don’t speak to each other, the Turks don’t speak to the Cypriots and so on, if you haven’t got this then you are going to have a collision. But just crossing the FIR boundary between the UK and France doesn’t strike me as a particularly important or safety related issue, but it will be very important because lots of interesting aeroplanes on the continent won’t come here and lots of interesting aeroplanes from the UK won’t be able to go to the continent.
Very well put John, and it’s an issue as you know we have
discussed in the past. It is an ICAO requirement that in proof the efficacy of
collision avoidance systems, pressure altitude reporting transponders are
required by all powered aircraft. We filed a difference about that a long time
ago when the rule first came out, we are obliged to review the finding of that
difference and as we are coming up for an ICAO audit it is also a part of the
appropriateness at this stage. We are not hard over on implementing this if our
adjoining states do not also implement it because it would be a silly exercise,
a pointless exercise. So let me make that quite clear. What we want to be able
to do is to be able to cover it through the consultation, we can hopefully take
on board all the views you have put in and then we can reassess how we move
forward in the light of how our adjacent states are also moving forward on this
one, because they have to consider the same issue. Yes, you are quite right,
there would be no way of us doing and the French not for example.
No second question, John? No? Ok, I’d just like to cover a couple of questions on costs. I’m conscious of time, and there are a couple of people who’d like to ask questions as they’ve signalled an intent to do so before the meeting started.
Costs:
The CAA has provided a range of cost assumptions for the initial installation, ongoing costs of the fitment of Mode S transponders. These are presented in terms of high, medium and low estimates. The low end estimates of the cost of Mode S fitment could easily amount to 20% to 100% of the value of some GA aircraft and many typical gliders. The costs of transponder installation – I’m sorry, I’m reading it again. This will force some gliding clubs potentially to close and indeed many aircraft to restrict their flying to areas where they don’t require transponders. How can anyone justify a financial burden of this magnitude in light of your responsibilities for equitably and proportionate treatment of all airspace users?
The costs that we have put in are the costs that we have obtained through industry. The first point, I want to make sure is that if you disagree with any of those costs, please cover them in your consultation response, that is the important fact and if you can provide evidence that’s helpful. Secondly, in terms of the cost’s proportionality and the reasonableness, the point you have made is quite right and that is something that we have to assess in our submission to government. We recognise that there are severe implications for some users and that the proportionality in relation to the percentage of the original capital buy of the airframe is a significant area. So yes, you are quite right we are aware of that issue but we have to consider that as part of the consultation process and as to how we move forward.
Can I just say, it is not our intention to close any gliding club down or to prevent legitimate access to airspace. It isn’t, that’s not what we are about, but actually what we want to try and do is to create a co-operative environment where other airspace users can interact with what you do, what I do and with what other people do. What we are trying to do is find a mechanism that allows that to happen, so if you have got some ideas, as Andy says, please let’s have them in your response to the consultation. We would like too know, but bear in mind that that’s what we are about, we are trying to understand how we can make the arrangements generally better and more co-operative and at the moment in some areas, they’re not.
The next question on costs, and I appreciate there are many questions we could ask on costs.
Given the disparity between Mode S costs and the benefits, in many cases no benefit, for the majority of glider and indeed many generally aviation pilots t