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Comments on the Potential Benefits of the Proposed Policy Options
Note that here you are agreeing or otherwise with the benefits listed in Para 5.2. This will need some narrative comments to be clear.
1 Do Nothing
2 SSR Mode S on all Aeroplanes and Helicopters
2(a) SSR Mode S and 1090ES (ADS-B 'Out') Capability on all Aeroplanes and
Helicopters
3 SSR Mode S on all Aircraft
3(a) SSR Mode S and 1090ES (ADS-B 'Out') Capability on all Aircraft
Please indicate whether or not you believe that, in principle, the carriage and operation of SSR Mode S transponders by aircraft throughout UK airspace would improve overall safety levels
Although the obvious answer to this is yes, the answer may actually be no.
The proposal will not improve the interoperability of GA aircraft with each other so their safety will not be changed; they will continue to rely on see and be seen for separation. 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. Commercial Air Transport aircraft currently fly mainly in controlled airspace with positive separation and TCAS for use as a last resort anti-collision aid. In the new Mode S environment, CAT aircraft will be encouraged to fly outside controlled airspace but with no separation, limited opportunity to look out and with only TCAS for protection. Their risk of collision will be greater than in the current environment. Therefore, the overall safety level will reduce.
Please provide any supplementary information that you may have on benefits of the policy proposals, or expand on your selected responses.
The RIA does not consider if the low powered transponders and the handheld equipments proposed will actually work. For example, only the main NATS radar sites will have mode S interrogators and it appears that the range of a low powered transponder may only be about 20 nm. So for example, when flying near Birmingham which uses the Clee Hill mode S feed, it is quite possible that no Mode S signal will be detected. For more information see this PFA paper on power levels.
If a portable transponder is carried, it is likely to be screened from some aspects by the pilot and parts of the aircraft. But CAT aircraft will be relying on the signal for collision avoidance.
None of these things have been tested. A trial carried out for the CAA seems to indicate that these concerns may be valid.
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