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Transponders - 2006 |
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The 2006 CAA Consultation is now closed. The following information is therefore "historical", and simply provided as background to the 2008 CAA Mode S Transponder Phase 2 Consultation. Read the full text of the letter sent by Martin Heywood BHPA Chairman to Andrew D. Price, Consultation Co-ordinator, Department for Transport which is the BHPA‘s response to: CAA partial ria - proposal to amend the air navigation order 2005 for the purpose of improving the technical interoperability of all aircraft in uk airspace. Post Partial RIA consultation update 30 August The consultation period for the CAA‘s Partial Regulatory Impact Assessment on the mandatory carriage of Mode S transponders has now closed. Many thanks to all members who responded to the CAA alongside our own formal submission. It will be very evident to those analysing the responses that there is not only considerable criticism of the proposal but also of the consultation process itself. Many BHPA members provided valuable feedback to the Airspace Panel on pertinent issues for which we are grateful. These have been considered by the airspace panel and our official BHPA response amended accordingly. Please be aware that the BHPA were sent notice of the Partial RIA on 2 June but in common with other air sport governing bodies we were unaware that there would be no public consultation for the subsequent Full RIA document to be presented to the Department for Transport. Hence our plea for member assistance some way into the 12 week Partial RIA consultation.
Official BHPA response The official BHPA response was submitted by the airspace panel on 29 August. Our narrative response to Section 10 "Additional Comments and Feedback" stretched to 15 pages. BHPA narrative response to section 10 Concerns It is obvious, in common with members of other sporting aviation groups, that BHPA pilots found the RIA documentation difficult to understand. Members were concerned that they didn‘t have sufficient knowledge to give an informed answer to (mis)leading questions or the implications of a selected answer. The airspace panel shares these concerns and has raised them in our formal return to the CAA. We will also be raising these and a number of issues concerning the nature of the consultation with the Department for Transport who commissioned the partial RIA. They are obliged under the Cabinet Office Code Of Conduct for Consultations to allow a feedback channel for complaints and concerns over a Consultation Process. The Partial RIA fails numerous recommendations in the Code for Consultation and a link to our letter to the DfT can be found at the top of this page. The Code for Consultations is on-line. Some BHPA members have already copied us their own letters written to the DfT, should you wish to do so the contact details are on page 2 of the Partial RIA.
What happens now? Section 4.3 of the Code For Consultation states that the consultation document should state the date when, and the web address where, the summary of responses will be published. As far as possible this should be within three months of the closing date of the consultation. Those without web access should be able to request a paper copy of this summary. It is unclear at the time of writing whether this refers to the Partial RIA (which makes no mention of time-scale for processing responses), or the Full RIA which the CAA are now preparing for the DfT. The consultant employed by the CAA who prepared the Partial RIA document and response form has already commented that the unprecedented level of response has meant that analysis of responses is likely to continue into the Spring of 2007. This in itself makes the implementation of the proposal in 2008 unlikely. There is no planned public consultation for the Full RIA (contrary to what we were originally told by the CAA) but as a result of the unprecedented public concerns all air sport governing bodies hope and expect to be further consulted during analysis of the partial RIA responses and the drafting of the full RIA. In common with other air sport associations should we not be further engaged in consultation and the Full RIA recommendations be against obvious public opinion then the possibility of a Judicial Review will be explored.
Partial RIA For those members wishing to review please see the Partial RIA. BHPA Airspace Panel 30 August 2006
The CAA Mode S Transponder story so far..... |
