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CAA Call for evidence: Electronic Conspicuity Solutions - AOPA UK Response

This is the AOPA UK response to the CAA's call for evidence in respect of Electronic Conspicuity solutions which was closed for submissions on 25 May 2019:

AOPA has communicated with its members through our magazine, Enews and working groups the development of this subject. Our membership is mostly made up of owners / pilots that operate certified aircraft and as far as we can see around 60%-70% currently have transponders. We can also see tangible benefits from traffic information systems being displayed on moving maps and through project EVA a lot of work was done to further develop this.

For several years the CAA has been considering the safety benefits that improved Electronic Conspicuity (EC) devices may deliver. AOPA has, since the mid 1990’s, supported the evolution of single step, low cost, light weight portable (electronic) solutions for GA. AOPA still believes that, with widespread (voluntary) deployment of electronic conspicuity devices and, with improved situational awareness, we can reduce the level of collision risk amongst participating aircraft.

As the airspace becomes busier (drones plus increased commercial air transport operations), technology will be needed to enable airspace access, making flights safer and more efficient (environmental benefits).

The current range of technology being considered includes 1090 MHz and UAT (987). The USA has already established an ADSB requirement for its airspace by 2020. In Europe ADS-B does not apply to aircraft with a MTOM less than 5700kgs, so as far as GA is concerned there is no mandate to become ADS-B equipped in Europe.

The principle of encouraging GA to equip with a form of EC is supported by AOPA. All solutions available must be interoperable. From the various discussions and reports AOPA is aware that 1090 will run out of capacity sometime after 2025. This is based on studies carried out by EASA and Eurocontrol, based on the Commercial fleet, and not taking into account General Aviation or Drones. Therefore, 1090 capacity could be made worse if GA is also mandated to use 1090.

NATS have been investigating how satellite derived position data could be used as an ADS-B solution, but this may only offer solutions for transatlantic flights.

The development of 5G technology is likely to be the solution favoured by UAS (Unmanned Aircraft Systems) and the main building block of the future UTM (Unmanned Traffic Management). AOPA thinks that as UTM develops it will be important to integrate GA and Drone operations in the lower airspace, building on the widespread use of 5G. AOPA further believes that with digital technology other benefits such as SWIM (System Wide Information Management) could be enabled. Therefore, we think that GA should be encouraged to equip with EC devices but recognise that 1090 will become capacity constrained at some future point.

Whilst the CAA has reserved 987 UAT we are not aware of any plans for this system to be used for surveillance (unlike the USA). Instead the UK will use 987 for weather in flight. Again we think that this will be of limited value and if payment for the service is required we would not expect a large up take for VFR flight.

With the technology being deployed in Golf airspace, we understand from CAP 1391 that currently it cannot be used in airspace that requires the use of Mode S. The CAA must resolve this if at a later stage there is a plan to mandate the carriage and use of EC devices. We do not support mandates unless there are clearly defined segmented cost verses benefits reports that show why the mandate is needed.

The CAA and Government, under the airspace modernisation strategy, must to develop a technology road map and at the same time be ‘technology’ agnostic. Instead focusing on system deliverables.

Clearly, as with ADS-B the more airspace users that participate, the better the safety and performance of the airspace.

If the CAA decides that a mandate is necessary and where there is a cost to GA, with little benefit, then the CAA and DFT should look at funding opportunities, financial incentives and other initiatives such as tax relief on essential safety equipment. 8.33kHz is a good example of how funding can be used.

In summary –

(1) AOPA supports electronic conspicuity on the basis that low cost, light weight portable solutions be available.
(2) Interoperability / integration is a key system benefit and therefore the CAA should adopt an ‘agnostic’ approach to technology and focus more on systemwide benefits.
(3) In return for investing in EC devices GA should have greater access to airspace.
(4) EC devices may not be required in all airspace but in areas where the traffic density is high then encouraging the adoption of the technology would be a reasonable approach. Where the airspace toolbox has RMZ / TMZ they should also enable flights that carry and use EC devices.
(5) Overall the benefits of using such devices properly must be explained to the GA community and therefore we recommend that the CAA considers a short education campaign.
(6) For mandates consider the use of financial tools / incentives.

Martin Robinson
CEO AOPA UK

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