I agree, from a GA perspective, this has been very
poorly launched by the CAA - https://www.caa.co.uk/General-aviation/ ... ncy-Trial/
They even link to the RAF Safety Centre’s leaflet, that is less than helpful, as it is written for Military Aviators to understand and not for the average GA Pilot. That is another issue perceived by many on this Forum; the apparent lack of GA SQEP in the GA Unit right now. Then there is that God-awful Safety Sense Leaflet No 13 that they link too - it’s so old that it was written “when Pontius was a Pilot”: http://publicapps.caa.co.uk/docs/33/20130121SSL13.pdf
Then just look at the CAA’s advice (which is also demonstrable of their lack of GA SQEP):
When and How to use the VHF Low Level Common Frequency
When not in receipt of a Lower Airspace Radar Service (LARS) or other Air Traffic Service, Pilots should make Blind Calls on the Low Level Common Frequency as shown below. To prevent clutter on the air the frequency must not be used as a chat frequency and transmissions should be accurate, clear and concise.
When safe and suitable to do so
When entering/exiting the Low Flying System
At turning points or significant heading changes
Approaching well-known and recognisable physical features
Any time it is considered beneficial to the safety of the aircraft
Blind Call Content:
Aircraft type (and number, in the case of formations)
Position in relation to reference points immediately identifiable to other pilots (using cardinal or inter-cardinal directions)
Next significant reference point
As has already been shown on here, the average GA Pilot knows not of the Low Flying Areas (LFAs), nor the fact that the definition of Low Flying System depends on the type of aircraft. As you well know it is <500 ft AGL for military rotary wing and light fixed wing aircraft or <2,000ft AGL for all other military fixed wing aircraft. Again, the fact they have used ‘height’ rather than ‘altitude’ when the majority of GA flies cross country on QNH also shows how badly this has been thought through.
You mention that your own EC appears ineffective against pop-up traffic like HEMS, NPAS and pipeline/electricity inspection. Is that because it is TCAS/ACAS? As such it relies on a round trip 1030/1090MHz interrogation and receive to be effective. Obviously, some transponders have ‘squat switches’ too and so will not reply when on the ground too. So someone lifting from a field could well be a late spot. TCAS often only interrogates once every 5 seconds, so that could also generate a late spot if they are terrain masked and then appear in line-of-sight. A GPS-stamped EC signal like ADS-B is transmitted once or twice a second, so detection is more likely in this scenario of someone conducting a lift during field ops. Again, I would offer that a technical solution like ADS-B is far more fool-proof than a UK-wide common VHF frequency.
The CAA’s guidance also talks about common features, but the military and civil VFR charts mark and name distinctly different features! That is classic Reason’s Swiss Cheese stuff - They called Leominster on their chart, but it isn’t marked on mine!
Also, the guidance is to stay on a LARS or other Air Traffic Service as a priority. That is, at least, good advice. Good airmanship dictates that a call to even an Air Ground Radio Operator within 10nm and 2,000ft of their airfield is wise. So the chances of the conflicting traffic being on the same VHF frequency at the same time, to assimilate the proposed VHF Low Level Freq transmission, is pretty low.
In my opinion, the CAA and MAA would be better off pushing:
1. Getting everyone behind a single non-cooperative EC system that works between all aircraft types (including those visiting from other countries).
2. Building a culture of civil and military Aircrew calling Air Traffic frequencies when at least within 10nm and at <2,000ft of any airfield equipped with a radio frequency. (There was a recent AIRPROX with a Phenom and a Vans RV, that saw the Phenom pass within 2nm at 500ft of a busy GA airfield without making a courtesy call).
3. Have a VFR common chart between the military and civilian Aircrew that shows the same features and names.
4. Have more common frequencies for defined areas (that need to appear on the military and
civil charts) that reflect the expected traffic densities and manage the risk accordingly. The military have had LOTA/OTA frequencies that was learned the hard way from several mid-air collisions between themselves. Defining an area and
a frequency is the only way this will ever properly work.
5. Report Altitude and not Height.
6. Sort out ATSOCAS. As others have mentioned - Basic Service is next to useless and really not much more than a listening watch. The chances of getting a Traffic Service in VFR during the average GA flying day is very low too. A Deconfliction Service? Forget it! A new approach is needed to ATSOCAS, or bring back FIS, RIS and RAS - at least they described what they give!
Then we might have something like a worthwhile and workable system, and not this half-baked plan that appears to have more issues than advantages.
If the CAA are reading this, then pop my consultancy fee in the post...