Primarily for general aviation discussion, but other aviation topics are also welcome.
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By johnm
FLYER Club Member  FLYER Club Member
#1846148
The regulator is faced with an interesting challenge. See and avoid is simply impossible from a light aircraft to the bulk of BVLOS drones, they are far too small but they will be MUCH worse than a bird strike if you hit one.

EC is simply too much of a dog's breakfast to satisfy the requirement.

The only answer is to compel drones to implement TCAS and that's also a challenge.
#1846153
@johnm - for small UAS/RPAS that is almost impossible. TCAS uses way too much power as it it requires interrogation on 1030Mhz and reception on 1090Mhz. Further, even if it were possible then the random interrogations would swamp the 1090Mhz frequency with a crazy number of transponder responses. So TCAS is definitely off the table.

Now 1090Mhz very low power ADS-B on UAS/RPAS, say <1W, would work but the detection ranges would be low - say 2-3 miles at best. But at <1W then it wouldn’t be a significant drain on the UAS/RPAS battery. Here is an article about very low power ADS-B: https://uavionix.com/the-case-for-low-power-ads-b/
#1846157
@Dave W taking your comment about having a working mode s transponder. Are you not assuming that there is adequate conventional radar cover that is effective. There are aérodromes I can sneak round, outside of controlled airspace I might add, and I will be outside of radar cover. These are areas where BVLOS may be active so if integration is to be achieved then something other than a conventional transponder will be required. The North Sea is another example where conventional radar coverage is a challenge as well as the the drone activity in the channel looking for small boats. You might like to see what radars are covering the east coast at our GA levels.

Somewhere in the many threads was comment that ads-B is a solution looking for a problem to solve. I would put it that there are opportunities for integration of things like BVLOS into a shrinking volume of open airspace.

I agree with @Cub I cannot see a blanket mandate, unless GA is going to benefit from an improved service level that we want/need, and even then not everyone will want that service but I think we need to address the onward march of Drone activity and how we cater for it and that’s what may drive a mandate.
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By Cub
FLYER Club Member  FLYER Club Member
#1846161
Dave W wrote:Which <kicks record player> would need to actually happen, based on a proportionate formal assessment, rather than be asserted by somebody without an underlying case.

"Leaping to conclusions" is a phrase that comes to mind.


I am afraid I don’t understand your point.

The Regulator, in assessing the Airspace Change Proposal, would hopefully ensure that a proportionate formal assessment had been conducted by the applicant. The process for conducting this is detailed in CAP 1616.

I, you or anyone else can ‘assert’ how we feel this particular challenge may end up being addressed and I don’t believe I need to detail a specific underlying case to make that assertion. We are discussing the ‘art of the possible’ on an Internet forum but you seem to be getting increasingly perturbed that somebody else's assertion may transfer into reality without checks, balance and careful consideration underpinned by a published procedure?
By johnm
FLYER Club Member  FLYER Club Member
#1846165
All of this is just a bit of tinkering the technology is basically useless for its purpose because as @gaznav rightly points out it won’t scale.

The expected value of drones will have to fund a radically new approach and that will in turn drive a new approach to airspace design.

Using the steam age analogy I referred to before we are currently in the late 18th century
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By Dave W
FLYER Club Member  FLYER Club Member
#1846169
Cub wrote:I am afraid I don’t understand your point.

In that case, either my OP wasn't sufficiently clear, or you haven't assimilated it properly.

Let's go with the former, since it is incumbent on the communicator to communicate clearly.

Had I done so, it would have been evident that I was not talking zbout individual ACPs (not mentioned in any way in the OP) and that "hopefully" has no place in a policy (not individual ACP) position that could affect equippage rather than airspace changes.

And, having re-read it, I think I did do so.
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By Cub
FLYER Club Member  FLYER Club Member
#1846177
Dave W wrote:
Cub wrote:I am afraid I don’t understand your point.

In that case, either my OP wasn't sufficiently clear, or you haven't assimilated it properly.

Let's go with the former, since it is incumbent on the communicator to communicate clearly.

Had I done so, it would have been evident that I was not talking zbout individual ACPs (not mentioned in any way in the OP) and that "hopefully" has no place in a policy (not individual ACP) position that could affect equippage rather than airspace changes.

And, having re-read it, I think I did do so.


State-wide mandate or ACP for a smaller volume of airspace, the process will be very similar. When I say hopefully, I am referring to my personal hope that the CAA continue to apply the scrutiny and audit prescribed in CAP 1616 which appears to have been reassuringly robust in several recent, high-profile cases.

Equally the challenge from external parties to the consultations has been well crafted and constructive, which to me, offers some reassurance that the process to deliver change is working effectively.

PS Just a thought, but you do appreciate that any equipage mandate will almost certainly be achieved via the airspace change process? If you hadn't appreciated that, it may explain why we appear to talk at cross purposes.
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By Dave W
FLYER Club Member  FLYER Club Member
#1846181
Cub wrote:PS Just a thought, but you do appreciate that any equipage mandate will almost certainly be achieved via the airspace change process? If you hadn't appreciated that, it may explain why we appear to talk at cross purposes.

I did not appreciate that. Why would I, or anybody, unless intimately involved in the minutiae of a complex process? It is not immediately obvious since we are not obviously talking about a change to airspace : The airspace classification might well remain the same if the mandate is a change to equipment not a change to airspace itself.

"Almost certainly"? What are the options and where is that determination laid down?


Why would that have been evident to anybody not fully versed in these matters?

In any event, the vehicle for change is surely a detail - the issue in the OP is what (if any) justification might there be for any such mandate, regardless of how it may eventually be implemented.

In none of these 6 pages has any attempt at objective justification been made. That's why I am irritated - all I am seeing (outside the inevitable thread creep) is obfuscation and an unwillingness to address the question.

And just one more time, for the avoidance of doubt: If there is a true justification, equitably balanced, then I likely won't object even if unhappy at the required spend. I will object if it is imposed without explanation or true objective consultation.
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#1846185
@Dave W if you are looking for a single silver bullet for EC, as in the see and be seen concept, for everyone then I don’t think there is one. After all there is currently no current mandate for a Transponder so why EC. Does it add a positive safety benefit, in my view yes but, that is no reason to make it mandatory in the open FIR for everyone.

Even when there are radar services, LARS for example, available not everyone wants to avail themselves and that is a personal choice even though there may be a benefit with a suitable service of course. There is not sufficient MAC statistics for someone to turn round and say enough is enough everyone has to have something. So again in my view a net safety benefit but a choice people make not a mandate.

You mention in your original question, yes I have read it and re-read it also, that there is attraction form other areas for what EC can do in reducing cost of surveillance radar and the integration of drones - and that is true and possible in my view where a mandate will come from if at all. That case is yet to be made but work is in hand to see how for example it might aid other things to happen and out of that will come the cost benefit analysis that you say needs to demonstrate that money needs to spent. I’m not speculating at this stage where the money might be extracted but also there may be a case that to share airspace it becomes a requirement of some description .

So in short no current mandate justification at this time from a legislation perspective but only at this time people’s peace of mind which is a variable.

IMHO

PS, if there is ever a MAC resulting from an infringement then it’s game over, no question.
ls8pilot liked this
#1846186
I also do not think there is, currently, any clear justification for mandatory fitment. Each individual can make their own judgement on the benefits, advantages and disadvantages vs the costs. I would hope that as equipment and technology matures it becomes more attractive, but not mandatory.

In 5-10 years time the situation may be different, but I don't think MAC risk (between manned aircraft) will be the driving force.
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#1846189
I believe that if you do buy something then the signal standards of that device should be mandated for the type. By mandating the standard to be fitted, but not mandating fitment, then we wouldn’t be in such a pickle. I’ve always said, that the standard that is mandated must be interoperable with all other devices in transmit and receive - that way everyone is herded onto one system.

To be honest, I thought the CAA were weak applying this:

The UK Civil Aviation Authority (CAA) today confirmed that ADS-B ‘in/out’ using 1090 MHz is its preferred national system to improve electronic conspicuity for general aviation, ideally used through transponders.


Also, to be honest again, if they had picked FLARM or PAW, I wouldn’t have minded either. But the ‘elephant in the room’ with both of these would be that a UK or even EASA mandated preference for these would not have seen interoperability with aircraft visiting from other countries around the world. FLARM even uses different frequencies in different countries!
#1846193
2025 imagined....

The new joint civilian and military U.K. Aerospace Authority is delighted to announce the successful establishment of Aerospace Enterprise Zones across much of U.K. airspace. The Aerospace Minister hailed this new collaborative airspace which allows commercial aircraft, drones and recreational pilots to safely share lower airspace using mandatory adoption of modern conspicuity technologies. The Minister added that recreational pilots who were unable to fit the new equipment would still have access to plenty of airspace in parts of the U.K. to continue their hobby and there were future plans to develop an online portal for submitting flight plan requests for non fitted aircraft to fly specific routes through the zones.
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By johnm
FLYER Club Member  FLYER Club Member
#1846198
@MattL Your scenario is plausible but not the timescale and @Cub if you think the airspace management and change process in the UK is robust and effective, then I'd like some of what you've been taking :roll: :D
#1846200
gaznav wrote:I believe that if you do buy something then the signal standards of that device should be mandated for the type. By mandating the standard to be fitted, but not mandating fitment, then we wouldn’t be in such a pickle. I’ve always said, that the standard that is mandated must be interoperable with all other devices in transmit and receive - that way everyone is herded onto one system.

To be honest, I thought the CAA were weak applying this:

The UK Civil Aviation Authority (CAA) today confirmed that ADS-B ‘in/out’ using 1090 MHz is its preferred national system to improve electronic conspicuity for general aviation, ideally used through transponders.


Also, to be honest again, if they had picked FLARM or PAW, I wouldn’t have minded either. But the ‘elephant in the room’ with both of these would be that a UK or even EASA mandated preference for these would not have seen interoperability with aircraft visiting from other countries around the world. FLARM even uses different frequencies in different countries!


Whichever protocol is chosen it must be an open protocol allowing multiple manufacturers to supply the hardware. Both FLARM and PAW are closed commercially controlled protocols so should be excluded.
gaznav liked this
#1846206
It’s not clear to me that any current and widely available technology will yet allow for the safe sharing of airspace between GA aircraft and UAVs.

Both the technology and the regulatory environment requires significant innovation and transformation before any such safety case could possibly be approved. The way forward in the short to medium term clearly lies in airspace segregation. Just as we already see.

In the meantime mandating any current iteration of EC (whichever system you choose) is little more than a matter of opinion. For me, the case is not persuasive.

It reminds me of the old saying, when computers were in their infancy and developing rapidly: “When’s a good time to buy a computer?” ... “Yesterday or tomorrow, but definitely not today!”
NigelC liked this
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