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Notes
The response document does not provide a means to respond to the most important part of the document – Paragraph 2.1 so you will need to put this in Response 10. It is really quite important.
The objective is at odds with what is actually proposed in the paper. The stated aim is to “… improve the interoperability (of all aircraft) in all classes of airspace” This breaks down into 2 sub-objectives involving improvements to all aircraft and all classes of airspace:
Recreational and sport aircraft (the majority group) are the principle class of aircraft that will be required to carry the proposed equipment; the proposal will not change their interoperability with each other. Neither will it improve their interoperability with exempt air vehicles or military fast jets which are not fitted with ACAS. Therefore the risk borne by these aircraft is essentially unchanged by the proposed solution. Many air vehicles will not be able to carry the proposed equipment and will be exempt; their risk and interoperability with all other users will be unchanged. Thus the objective of improving the interoperability of all aircraft is not satisfied by this proposal. It does not even improve interoperability for the majority of aircraft. Moreover, a large number of air vehicles will not be fitted with the equipment so the degree of safety afforded to CAT is as yet unknown as it is to be set by the exemptions policy which is to be decided later. This is a fundamental matter which actively prevents the application of risk analysis tools to the issue.
As transponder carriage in controlled airspace is already mandated, this proposal will only affect aircraft in Class G airspace. The vast majority of aircraft operating in Class G airspace are those described above whose interoperability will not change. Therefore the proposal will not change interoperability in Class A, B, C or D airspace and may only affect the very small minority of SSR-fitted aircraft that come into conflict with ACAS carrying aircraft in Class G airspace. Thus, the objective of dealing with “all airspace” is not satisfied.
The proposal would allow the interoperability currently enjoyed by CAT in controlled airspace, to be partially extended into class G airspace. Therefore what could actually be achieved by the specific proposal set out in Para 2.1 is to partially improve interoperability for CAT were its operations extended substantially into Class G airspace. This is a quite different issue and you will now be able to see why we have such difficulty in developing a proper response to the RIA.
Although this deals only with the first part of the objective of the RIA, it exposes a fundamental issue that causes the paper to fail to properly identify the problem and hence to fail to develop an appropriate solution. UK aviation deserves an adequate business case to justify its investment and the travelling public deserve a proper analysis of the risk factors that will affect them.
The issue on which this RIA is based is a forecast doubling of air traffic by 2022, drawn from a Eurocontrol assumption related to Eurocontrol airspace. This does not appear to be consistent with other strands of Government policy on sustainable aviation in the UK but it is the basis of the proposal. It cannot go forward on this basis. A major equipment investment, mandated by the regulator, must be underpinned by clear and agreed UK government policy.
The RIA also proposes that this will be just one of many measures necessary to improve air safety in the future. If this is the case, an overarching strategy is needed to set out the issues and to evaluate the risks and determine the range of options available to control them.
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