Dave W wrote:How are pilots "informed"?
They are not - this is not part of the training syllabus (not even close), and for pilots that rent or who otherwise have no direct engagement with aircraft ownership they will have no prompt to a directed means of receiving such knowledge.
In that manner they are no more informed than their passengers, and are in practice "the general public".
No; U cannot see that there is any logic at all to this implicit assumption that pilots are automatically better able to assess any risk than their passengers - and for OFCOM to believe they are, and set policy based on that then that is blinkered bum-covering bureaucracy at its worst.
Note that I am not suggesting that there is in fact any practical risk! I am railing against OFCOM's lack of logic and blind adherence to their process.
The regulations and the documents I’ve quoted are not specifically written for pilots or in fact our corner of aviation. I would bet that OfCOM have little knowledge about aircraft, pilots etc and would normally get that from consultation with the aviation sector. That appears at first sight to have been lacking until this point of sending out letters of intent and asking for feedback.
If pilots/Operators have little training or knowledge then they are in fact “innocents” and it’s reasonable that they be subject to the same levels of exposure as the general public.
The issue I believe is that as a community we have insufficient information to make an informed declaration on the subject which is what is been asked. Hence its plausible to turn to the regulators of the equipment we have fitted and, for transponders, mandated to turn on if fitted and working, for guidance on how to comply.
I’m not sure that berating them for any lack of sympathy for our situation is going to help unless we are prepared to educate surely. That means feedback, directly and through the bodies who represent this sector of aviation.