APPG criticises CAA approach to electronic conspicuity
The comments were revealed in the APPG-GA's response to CAP 1777, the CAA's call for evidence to inform its new strategy on electronic conspicuity devices.
The CAA proposals involve a two stage roll out, starting with mandating conspicuity in selected blocks of airspace before a more general national roll out of the technology nationwide.
Lord Kirkhope of Harrogate, Chair of the APPG-GA's dedicated Airspace Working Group said: "It is clear that the CAA's objective is to get to a point where electronic conspicuity is made mandatory for every airborne vehicle in the UK.
"Yet in our opinion the CAA's one-size-fits-all approach will not work for the vast majority of aviation users."
The APPG-GA's response highlights that different classes of aviation have vastly different requirements of electronic conspicuity devices.
Light aircraft operating in open airspace are unpredictable and often fly within a close manoeuvring environment around airfields.
By contrast, commercial air transport operates in segregated corridors and only face mid-air collision risk when separation mechanisms built into air traffic control procedures fail. The two sectors very rarely operate close to each other.
Lord Kirkhope said: "The danger in regulating a single common functionality standard is that the solution will not suit everyone. The tendency will be on the part of the CAA to mandate the highest possible performance standard to suit commercial airliners, which would bring unnecessary bulk and complication to those operating small aircraft."
The APPG-GA argues that a better solution would be to allow mixed technologies, tied together by a ground based relay network. This is already the case in the USA, where commercial air transport uses Automatic Dependent Surviellence -Broadcast (ADS-B) and General Aviation uses Universal Access Tranceiver (UAT).
Commenting on CAP 1777, Grant Shapps MP, Chair of the APPG-GA said: "The CAA is basing this entire programme on a set of assumed drivers and projected increases to traffic, which we believe more evidence is required to justify.
"Most infringement incidents are minor and cause no safety risk to commercial travel. It therefore seems that these moves are designed to benefit the commercial efficiency of Air Navigation Service Providers whilst light aviation shoulders the burden. This is especially true as many infringements could be avoided by changing bad airspace designs".
On the proposals for limited areas of mandatory conspicuity, Mr Shapps said: "This policy seems like airspace restriction by stealth, especially in an environment where electronic conspicuity is not mandatory.
"All changes must be put through the formal airspace change process and be subject to a robust public consultation. Otherwise I fear the CAA would breach its Section 70 responsibilities under the Transport Act 2000."
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