Any commercial organisation undertaking this sort of review would analyse the safety issues against the required level of safety as part of the business case to ensure it was spending its money effectively. But the CAA is not spending its own money, it is spending yours. Between £19M and £44.2M to be precise, that is about £8M a year for the next four years.
You might expect there to be a significant analysis of risk and safety for each of the options before and after. Indeed, the CAA is required by the consultation guidelines to consider the “do nothing” option and this should clearly show the comparative risk in each case but it does not. It talks about maintaining the “target level of safety” but does not disclose what that is or give us quantitative safety figures for each option. The overall “do nothing” consideration says absolutely nothing about risk save for a completely false statement that “ATC would be unable to safely support future airport capacity”.
When we talk about safety here we are talking about the risk of collisions between CAT and GA aircraft and gliders so we need to take advice from the UK Airprox Board which is the expert group in that area. In his 17th report the Chairman notes that in 2006 there were only 6 risk bearing airproxes involving CAT aircraft, three involving civilian non-CAT aircraft, two military and one CAT. He finishes: the conclusion is that such wide variability does not point to a common theme with the need for concerted action in a particular area of operations. So yes, safety would be improved in some areas by Mode S, but actually safety is already judged satisfactory and this is not a particular area of concern. Safety does not make a business case.
We should point out a statement in the document, (para 12.5) that “the UK Airprox Board supports proposals to mandate mode S transponders to the maximum extent possible”. We have asked the UKAB to clarify their position on this but we have not yet had a reply.
Links:
What the LAA Thinks of the Consultation
Why Mode S Transponders and Not A or A/C
The Safety Case
Transition and Exemption Arrangements
Deadline 31st May 2008
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