Wed May 05, 2021 3:46 pm
#1845104
(TL;DR: If you think there is a case for insisting under force of law that GA owners and operators must spend money on EC at the expense of other safety-related items, then please make it - logically, objectively and in suitable detail, here. I suggest that to justify any mandate, it is only fair that such a case is made to the GA community in advance.)
Yes, yes - another (yet another) EC thread.
But this one is intended specifically to break out and consider the pros and cons of mandating EC.
There are lots of other threads for the technical details and comparing one solution with another etc - that's not what I hope for us to discuss here.
All over social media, including these forums, I see people frequently calling for the CAA to mandate electronic conspicuity.
But I’m not (yet?) convinced that that an objective case for mandation has been made, and I’ll tell you why.
But first, let’s get some basics of my own position out of the way:
So hang on… If I think that, then why am I not convinced of a case for mandation?
Well:
To consider those items in a little more detail:
JUSTIFICATION
If something is to be mandated (that is, people are forced to pay and/or lose existing capability, then to my mind in a democracy there needs to be a firm and objective justification for it, based on logic and not emotion.
There needs IMV to be an underpinning clear cost:benefit analysis that shows that the expense and any associated reduction in entitlements that may arise are worthwhile when considered in the round.
Which brings me to…
OPPORTUNITY COSTS
All of us have a limited flying budget (even you, Richard Branson). Spending money on one thing always means we can’t spend those funds on something else. Requiring people to spend money on EC addresses the mid-air collision (MAC) hazard, sure - but at the potential expense of other threats to GA safety.
The top 10 causes of light aircraft fatalities has been consistent for a few decades, and mid-air collision is quite a way down the list at number 8, typically representing 2-3% of all fatal accidents.
Money spent on EC is money NOT spent on AVGAS, training, upskilling etc. Given that the top two killers are Controlled Flight Into Terrain (CFIT) and Loss of Control In-Flight (LOC-I), there is – I suggest – quite a strong argument that experience, currency and recency are more cost-effective things to spend money on than a piece of electronic wizardry however good it may be in its niche.
And an installation may not be THAT good, which brings me to…
EFFECTIVE IMPLEMENTATION
There has been a lot of useful data and discussion recently on the effectiveness of the various options – including from the most helpful PilotAware VECTOR analysis tool and the limited FLYER qualitative assessment (in which I took part), later reported in the Dec 2020 magazine and a YouTube Video.
There is quite a lot to discuss from those data and analyses (see multiple other threads), but there are a couple of things that are evident: Carry-on equipment does suffer from obscuration (both transmit and receive); that the most effective installations have external antennas; an alert is only useful if it seen/heard.
In short, not all EC solutions are equal, and even identical equipment can perform quite differently depending on how it is installed.
The other very clear point is that simply having detection of others’ EC is not sufficient for an effective mid-air collision avoidance solution: You must also have a commanding ALERTING element to the installation, and that demands audio and sightline considerations to be taken into account.
Unless your installation provides you with a timely warning that you are able to assimilate then some implementations arguably may as well not be carried. (Is a tablet on your knee, with a late warning due to an internally obscured antenna and no means of immediately attracting your attention truly going to protect you?
So the above prompts the question: What, exactly, do those who call for it expect to be mandated?
An SE2 suckered to a side window, or a system with external antenna, eyeline display and plumbed into the intercom, or something in-between?
If something in-between, then what exactly?
What, if any, are the liabilities to ourselves - and the mandating authority, of course - associated with a less than perfect implementation?
My point being: This argument is not as simple as ‘Do you agree with the statement “The CAA must mandate carriage of EC?”’ – the devil as ever will be in the detail, and the detail is almost certainly going to push costs up, not down.
LIKELY ACTUAL COST
Who knows, until the issues above have been thrashed out? But are we really sure what is being asked for, or is the assumption simply “£300-£500 for a Rosetta or SkyEcho2, and jobzaguddun”?
I strongly suspect that a considered mandate will end up with rather greater costs than that. And perhaps it should - if something is to be mandated, then maybe mandate the installation as well as the baseline kit.
If I’m right (that costs will be higher than the few hundred sometimes assumed), does that change anybody’s opinion, especially given the more prevalent risks that don’t get mitigated by EC as discussed earlier?
AN ASIDE:
It seems that the conversation for most GA pilots – and also in the first part of this post - is currently based around air-to-air traffic awareness.
However, there is an undercurrent I detect from some areas that “it” (whatever it means – see above) is attractive to air traffic providers too.
And I can see the sense in that attraction – it’s likely to be much cheaper for them to move to an ADS-B reception network than it is for the current costly legacy infrastructure of primary and secondary radars to be maintained into the medium/long term. It may even be that moving away from legacy infrastructure allows the potential for more widespread use of other functions only available from ADS-B and UAT.
It is also likely to be the case that mandated EC supports the introduction of UAS (“drones”) into Class G.
Well, that’s great - both of those things: But if those are to be part of any case for mandation, then let’s be honest about it up front.
After all, what the ANSPs and UAS companies are effectively doing is moving their own costs onto the aircraft operators – so let’s have a conversation about whether everybody agree that the shift is equitable. We might agree that it is – given the potential for greater operating freedoms and functionality - but lets have an open and honest conversation about it, please.
That conversation should include how that potential will be actualised for all users, including GA – and should include what - if any – antenna performance limits are required (i.e. what, if any, obscuration is acceptable).
CONCLUSION
So, that’s my thinking. Please do disagree.
If you do, then here’s a challenge: If you believe there is a UK relevant basis for mandating EC that is detailed and convincing then please make it here.
I am willing to be convinced by a strong argument: I just haven't heard it yet.
I believe that if it is to be mandated, then it is only reasonable that a strong argument is publicly made first.
If you have an ANSP or Regulatory background, and are able to do so under your employers’ media policies, then it would be valuable to share thinking here too. But I’d be grateful if any hint of “I could tell you but I’m not allowed but trust me, there are good reasons” can be avoided – the whole point of this OP is that I want us to be able to hear and assess those reasons.
(Please note: Again, the question is explicitly about MANDATING it, not "Is EC a good idea” – I suspect we can all agree on that one. The question is about demanding people pay for it, rather than leaving it to them to make a choice.)
AFTERWORD
At some point somebody will inevitably make a comment along the lines of“Pilots being unwilling to spend £250 on EC – that’s only an hour or so’s flying”.
Let’s deal with that now: It’s a strawman fallacy. Firstly, many of us manage to fly for £30-£40 an hour variable cost. If you have to use cherry-picked data to make your case, then your case is unlikely to be strong; Secondly, it won’t be £250 since that assumes the soon-to-expire CAA subsidy and likely disregards some of the performance issues potentially required to be addressed in a mandated solution.
Also, I fully expect someone to comment along the lines of "If it saves one life, it's worth it". That's a great soundbite and I do sympathise with it having lost people I know to MAC. But I have also lost them to LOC-I and CFIT over the years. My view is that if we must choose (and realistically/unfortunately we must: Opportunity Costs) then I will tend to recommend mitigating the more prevalent hazards first.
Yes, yes - another (yet another) EC thread.
But this one is intended specifically to break out and consider the pros and cons of mandating EC.
There are lots of other threads for the technical details and comparing one solution with another etc - that's not what I hope for us to discuss here.
All over social media, including these forums, I see people frequently calling for the CAA to mandate electronic conspicuity.
But I’m not (yet?) convinced that that an objective case for mandation has been made, and I’ll tell you why.
But first, let’s get some basics of my own position out of the way:
- By “electronic conspicuity”, I don’t mean just Mode C/S transponders – even though that is also EC of course; here I am using the term as most others appear to mean it when they talk about "mandating EC": That is, EC = ADS-B/Mode S-ES/FLARM/PilotAware etc.
- I am a fan of EC; I own both PilotAware and SkyEcho2 (and a Mode S transponder).
- I think it is a Very Good Thing that the take up of EC is increasing and is as significant as it is.
- The technology potentially delivers extras such as live in-flight weather and other useful data in the cockpit. That’s evidently also A Good Thing.
So hang on… If I think that, then why am I not convinced of a case for mandation?
Well:
- Because “Mandated” also inevitably means in practice “Being forced to carry and maintain under penalty of law" and also perhaps “Being constrained from what can currently be done”.
- Because there does not appear to be any (openly provided) justification made for it other than “Mid-air collisions: Scary” and “That seems like a good idea”
- Because there is no published cost:benefit analysis on the need for mandating EC.
- Because an effective implementation is likely not as straightforward as some appear to think.
- Because it inevitably won’t be “just £250” to comply.
To consider those items in a little more detail:
JUSTIFICATION
If something is to be mandated (that is, people are forced to pay and/or lose existing capability, then to my mind in a democracy there needs to be a firm and objective justification for it, based on logic and not emotion.
There needs IMV to be an underpinning clear cost:benefit analysis that shows that the expense and any associated reduction in entitlements that may arise are worthwhile when considered in the round.
Which brings me to…
OPPORTUNITY COSTS
All of us have a limited flying budget (even you, Richard Branson). Spending money on one thing always means we can’t spend those funds on something else. Requiring people to spend money on EC addresses the mid-air collision (MAC) hazard, sure - but at the potential expense of other threats to GA safety.
The top 10 causes of light aircraft fatalities has been consistent for a few decades, and mid-air collision is quite a way down the list at number 8, typically representing 2-3% of all fatal accidents.
Money spent on EC is money NOT spent on AVGAS, training, upskilling etc. Given that the top two killers are Controlled Flight Into Terrain (CFIT) and Loss of Control In-Flight (LOC-I), there is – I suggest – quite a strong argument that experience, currency and recency are more cost-effective things to spend money on than a piece of electronic wizardry however good it may be in its niche.
And an installation may not be THAT good, which brings me to…
EFFECTIVE IMPLEMENTATION
There has been a lot of useful data and discussion recently on the effectiveness of the various options – including from the most helpful PilotAware VECTOR analysis tool and the limited FLYER qualitative assessment (in which I took part), later reported in the Dec 2020 magazine and a YouTube Video.
There is quite a lot to discuss from those data and analyses (see multiple other threads), but there are a couple of things that are evident: Carry-on equipment does suffer from obscuration (both transmit and receive); that the most effective installations have external antennas; an alert is only useful if it seen/heard.
In short, not all EC solutions are equal, and even identical equipment can perform quite differently depending on how it is installed.
The other very clear point is that simply having detection of others’ EC is not sufficient for an effective mid-air collision avoidance solution: You must also have a commanding ALERTING element to the installation, and that demands audio and sightline considerations to be taken into account.
Unless your installation provides you with a timely warning that you are able to assimilate then some implementations arguably may as well not be carried. (Is a tablet on your knee, with a late warning due to an internally obscured antenna and no means of immediately attracting your attention truly going to protect you?
So the above prompts the question: What, exactly, do those who call for it expect to be mandated?
An SE2 suckered to a side window, or a system with external antenna, eyeline display and plumbed into the intercom, or something in-between?
If something in-between, then what exactly?
What, if any, are the liabilities to ourselves - and the mandating authority, of course - associated with a less than perfect implementation?
My point being: This argument is not as simple as ‘Do you agree with the statement “The CAA must mandate carriage of EC?”’ – the devil as ever will be in the detail, and the detail is almost certainly going to push costs up, not down.
LIKELY ACTUAL COST
Who knows, until the issues above have been thrashed out? But are we really sure what is being asked for, or is the assumption simply “£300-£500 for a Rosetta or SkyEcho2, and jobzaguddun”?
I strongly suspect that a considered mandate will end up with rather greater costs than that. And perhaps it should - if something is to be mandated, then maybe mandate the installation as well as the baseline kit.
If I’m right (that costs will be higher than the few hundred sometimes assumed), does that change anybody’s opinion, especially given the more prevalent risks that don’t get mitigated by EC as discussed earlier?
AN ASIDE:
It seems that the conversation for most GA pilots – and also in the first part of this post - is currently based around air-to-air traffic awareness.
However, there is an undercurrent I detect from some areas that “it” (whatever it means – see above) is attractive to air traffic providers too.
And I can see the sense in that attraction – it’s likely to be much cheaper for them to move to an ADS-B reception network than it is for the current costly legacy infrastructure of primary and secondary radars to be maintained into the medium/long term. It may even be that moving away from legacy infrastructure allows the potential for more widespread use of other functions only available from ADS-B and UAT.
It is also likely to be the case that mandated EC supports the introduction of UAS (“drones”) into Class G.
Well, that’s great - both of those things: But if those are to be part of any case for mandation, then let’s be honest about it up front.
After all, what the ANSPs and UAS companies are effectively doing is moving their own costs onto the aircraft operators – so let’s have a conversation about whether everybody agree that the shift is equitable. We might agree that it is – given the potential for greater operating freedoms and functionality - but lets have an open and honest conversation about it, please.
That conversation should include how that potential will be actualised for all users, including GA – and should include what - if any – antenna performance limits are required (i.e. what, if any, obscuration is acceptable).
CONCLUSION
So, that’s my thinking. Please do disagree.
If you do, then here’s a challenge: If you believe there is a UK relevant basis for mandating EC that is detailed and convincing then please make it here.
I am willing to be convinced by a strong argument: I just haven't heard it yet.
I believe that if it is to be mandated, then it is only reasonable that a strong argument is publicly made first.
If you have an ANSP or Regulatory background, and are able to do so under your employers’ media policies, then it would be valuable to share thinking here too. But I’d be grateful if any hint of “I could tell you but I’m not allowed but trust me, there are good reasons” can be avoided – the whole point of this OP is that I want us to be able to hear and assess those reasons.
(Please note: Again, the question is explicitly about MANDATING it, not "Is EC a good idea” – I suspect we can all agree on that one. The question is about demanding people pay for it, rather than leaving it to them to make a choice.)
AFTERWORD
At some point somebody will inevitably make a comment along the lines of“Pilots being unwilling to spend £250 on EC – that’s only an hour or so’s flying”.
Let’s deal with that now: It’s a strawman fallacy. Firstly, many of us manage to fly for £30-£40 an hour variable cost. If you have to use cherry-picked data to make your case, then your case is unlikely to be strong; Secondly, it won’t be £250 since that assumes the soon-to-expire CAA subsidy and likely disregards some of the performance issues potentially required to be addressed in a mandated solution.
Also, I fully expect someone to comment along the lines of "If it saves one life, it's worth it". That's a great soundbite and I do sympathise with it having lost people I know to MAC. But I have also lost them to LOC-I and CFIT over the years. My view is that if we must choose (and realistically/unfortunately we must: Opportunity Costs) then I will tend to recommend mitigating the more prevalent hazards first.