An open letter to the leadership of the LAA

[PiersShedden]

Gentlemen,

The time has come for the UK to take more positive action on aviation mid-air collisions. Last week’s collision in Buckinghamshire involved two certified aircraft, both with instructors on board, both aircraft with occupants with hundreds if not thousands of hours of flying experience between them. In these days of driverless cars why are our our GA aircraft still reliant solely on the busy eyes of their pilots for collision avoidance? There are technical solutions available to us now such as Pilotaware that cost a few hundred pounds, less than the cost of 2 hours flying, that could protect everyone involved in UK aviation from these types of disaster.

The LAA and BMAA together represent permit aircraft pilots in the UK and I appeal to each of you to take the initiative to work with the BMAA and make our skies a safer place by imposing a requirement for these solutions to be fitted to LAA and BMAA aircraft. You can lead for permit GA, hopefully with the support of the CAA in certified GA. When such low cost solutions already exist it is morally right for our governing bodies to impose such a requirement upon their members. Inaction now or reliance on haphazard individual uptake is to miss a golden opportunity to save lives and prevent such terrible accidents in our skies.

Yours sincerely,

Piers Shedden

[dmcnicholl]

A contentious post, Piers. You don't use the 'M' word but you're talking about mandating the fitment of electronic conspicuity. I have no difficulty with the encouragement of EC but I most certainly do have difficulty with a mandate.

I have no knowledge of the circumstances which led to the recent fatal midair, but perhaps neither do you, so don't know if EC would have prevented the event. Absent that certainty your call for mandated EC is at best premature.

[PiersShedden]

No, I have no greater knowledge than you as to the causes of the crash, but it is safe to say that there were four pairs of eyes in those aircraft with many, many hours of flying experience behind them and it was not sufficient to prevent an horrific accident. Yes, we can hope that the full investigation will identify the causes in full in due course, but given the low uptake of collision avoidance equipment in the UK GA fleet it is fair to say that the vast majority of UK GA pilots are relying almost solely on their eyes for collision avoidance, sometimes assisted by a ground-based service of variable quality (in my experience pilots regularly fail to use basic services even when available).

Yes, I am suggesting mandating collision avoidance equipment (not just conspicuity, it has to be reception of traffic information not just broadcast) and I make no apology for doing so. It's almost unbelievable that when technology such as PilotAware is now well proven and so cheaply available it is not already mandatory. We're talking a few hundred pounds here, not the thousands needed for 8.33 or Mode S. Whether flying visual or on instruments, if either or both of those aircraft were fitted with PilotAware or similar then either or both crews could have been made aware of the impending collision. That has to be worth a few hundred pounds for each of us. If you can afford to fly you can afford this.
Even if the equipment were not mandated then I would argue that those insisting on not using traffic avoidance should pay very significantly more for their insurance. Disproportionately and discouragingly more.

I am equally unsympathetic to objections based not on cost but on such a mandate being a violation of some unwritten 'freedom to roam the skies unimpeded' without having to install more equipment in our aircraft or to make oneself fully conspicuous: this equipment is neither heavy nor particularly complex and conspicuity is morally right - everyone would agree that driving at night on the public road without lights is unacceptable behaviour for exactly the same reason.

Cities around the world are working to introduce air taxi services using multirotor autonomous aircraft, so it's fair to say that we are on the eve of 'smart aircraft'. The era when it was acceptable to travel our skies without even basic traffic avoidance equipment is passing and I for one will be delighted when it is gone.

[RichardMaxted]

Seems to me that mandating anything like this merely panders to the "Aviation is Dangerous" tendency that would love to close down many of our airfields. By all means fit equipment that you feel will make you feel safer but don't extrapolate from a single incident that hasn't even yet been fully investigated to a need for all of us to follow your particular as yet uninformed view of the causes of the tragic events.

[RichardMaxted]

There is also the small matter of the idea being promoted quite hard in some quarters that these systems somehow prevent collisions. They do not. They can only tell the pilot about aircraft in the vicinity. They do not know the intentions of the pilots of oncoming or passing traffic. They cannot control the aircraft ( unlike the misplaced driver-less car analogy). They cannot instruct the pilot what to do to avoid a collision. In fact they are little different from enhanced eyes and as such suffer all the drawbacks of eyes Mk1 in that they are attached to a brain that may or may not be concentrating, taking action or still working out where the traffic is that the device has identified.

I have lost count of the number of occasions when an air traffic controller has given me a pretty good steer where an aircraft is relative to me and when I look out of the window I still have to work quite hard to see it. These devices (until they are connected to the controls ) are only, at best, an enhanced air traffic controller. Once identified there will still be that moment when the eyes need to talk to the brain and the brain to the hands before action can be taken. God forbid that anyone turns in VFR flight without looking out first.

They have been brilliantly marketed but completely over-sold in terms of their use. In the end it is always the pilot has to do something or not do something to avoid a collision.

[PiersShedden]

Quite Richard, it is still the pilot that must take action.

But you make an excellent point, these devices do provide an enhanced air traffic controller service. Our GA airfields are struggling to stay open, let alone provide full ATC. Given the serious pressures on air traffic controllers and the cutbacks that we've seen to various local traffic control services in recent times (my local airfield Cranfield and Booker being two recent/current examples), this is another excellent reason to make this technology a GA standard. Whilst traffic avoidance devices wont replace ATZ services they can provide more complete coverage of our skies away from ATZs than basic services alone.

Anyone who has been to the LAA Rally in the past two years will have seen the intense interest at the PilotAware stand from the attendees. There is groundswell member interest in this based upon the horror of ongoing collisions that date back to the first days of flying, not one event. Sometimes we need a 'Weinstein' moment to jolt us from acceptance of the day to day and make us realise that the time has come when something is no longer acceptable.

[coxargus]

Collision avoidance equipment - TCAS - has been around for years but Is just not practical, in my opinion, for our use due to cost amongst other things. It is designed for for use by IFR traffic. Also any thing which encourages us to 'Keep our heads in the office' staring at all the gizmos available today is not good for old fashioned airmanship which includes lookout - although they help. situation awareness should be built in to our brains from the basic training stage so when screens go black - no panic! - we revert to basic principles - listen out and look out and get the chart out on which we have plotted our planned route.

https://www.flyingmag.com/how-it-works-tcas-ii

The laws of statistics dictate that in-flight collisions will happen - however remotely.

Frank Cox

[B Davies]

Piers,

You are calling for an LAA mandate to fit one particular EC system. Whilst I admire your passion and encourage your call for discussion on this subject I think there are some hard facts that must be taken into account.

A Mandate is a regulation by another name. The LAA is not a regulator- we implement regulations on behalf of the UK CAA and in some cases EASA. We will support ideas that benefit our members and we will lobby strongly when necessary. In the case of EC we have done a great deal of work and paid a key role in enabling the connection of uncertified GPS sources to suitably equipped transponders in order to improve EC. We sit on working groups and are currently supporting and in some cases developing a number of trials to improve the use of lower cost EC systems.

The bald fact is that a sustainable EC solution has to be ubiquitous and compatible across all aircraft. The CAA, our regulator, has decided that this system will be ADSB.

It is not the LAA's role to encourage or mandate one particular product when there are currently multiple solutions. We do, however support the concept of a low cost solution to EC.

Best regards

Brian Davies, chairman

[PiersShedden]

Thank you for your excellent response Brian. One point of clarification, though I gave PilotAware as one example of a low cost solution, my call was for such solutions in general.

I do appreciate both the LAA's limitations of authority as well as its work in enabling uncertified GPS sources to be used, a very pragmatic and worthwhile effort as is characteristic of the association.

I entirely accept that the EC and CAA solution of ADSB is the correct solution to collision avoidance. Indeed my call is fundamentally not questioning that but calling for faster adoption of it, as almost all collision avoidance receivers now available (including PilotAware) use ADSB In as one of their primary, inbuilt input sources. These devices would therefore fulfill half of a GA ADSB traffic avoidance solution* making them entirely future proof. My call is fully aligned with EC and CAA policy, what I'm asking for is for the LAA to push this harder as an initiative now that the solutions are so affordable. The CAA trusts the LAA to handle matters related to permit GA so that it can concentrate on bigger commercial matters, so this is an opportunity for our association to pick up an important issue and lobby hard for a really big step forward. Even if you dont want to try to do it through regulation, there are other powerful drivers in GA, insurance premiums being a good example and one where again the LAA has the clout to be listened to.

At current rates of adoption for both ADSB In and Out solutions we are probably looking at widespread GA adoption in 20-30 years which I consider unacceptable and that is what motivates my creating this debate. I categorically do not accept the view that mid-air collisions are 'statistically unavoidable' and that we should therefore accept them as part of the risk of flying. Collisions are thankfully almost unheard of in commercial passenger flying so if we can do it there we can do it in GA.

Best regards
Piers Shedden

*For those not familiar with these systems, ADSB as a GA collision avoidance solution requires two parts, a Mode S transponder with 'ADSB Out' enabled through connection to a GPS source, as well as an 'ADSB In' receiver in the cockpit of the aircraft to highlight any proximity events to the pilot. PilotAware and other collision avoidance devices incorporate an 'ADSB In' receiver so they are fully compatible with ADSB development, however they also simultaneously receive as well as broadcast in other cheaper anti-collision systems such as P3i, Flarm, etc. so adoption now would bring immediate benefits even before ADSB Out becomes widespread. These devices can also provide the GPS signal (thanks to the work of the LAA) to a suitable Mode S transponder to enable ADSB Out.

http://www.pilotaware.com/pilotawareintroduction/

[DaveWhite]

Hmmm. What else should we mandate whilst we are at it?

After all, sadly many more people are killed due to CFIT or loss of control in flight than in midairs.

Should we mandate terrain radars and autopilots?

Or perhaps allow people to fly more with their limited budgets, thereby maintaining the skills and currency that mitigate the hazards leading to CFIT and loss of control in flight? And midairs, to a degree.

I reckon that a properly undertaken cost-benefit analysis would likely show the latter idea to be the most effective one.

PS A couple of hundred pounds is around 6+ hours flying for me, and no doubt other LAA members do better.

PPS I own a PAW. Actually, I have two. Doesn't change my views on the downside of mandation without proper consideration of the bigger picture.

[PiersShedden]

Thanks Dave.
I think sometimes there's too much reluctance to mandate in GA. Look at the automotive world and safety mandates are accepted as part of the ongoing development of how we get from A to B on our roads.
As I've said, there's many a way to skin a cat, be it mandate or cost incentive through lower insurance, etc.
Good to hear that you're already an early adopter.
Best regards

[Paul Catanach]

General aviation is already struggling to attract and/or retain pilots. Telling them they need to shell out for more equipment might be the last nail, even if it is 'just' a tin-tack, in the coffin for some.

GA is a broad church from the well off to those who struggle to meet their minimum flying hours. I'm not saying it's an acceptable trade to keep pilots in the air if we 'only' have a few accidents but as Dave has said that money invested in a couple of extra hours in the aircraft might pay higher dividends. More flying leads to better look out, improved handling, R/T practice (heaven knows it would be nice not to witness some of what goes out on the airwaves), better landings etc, etc, etc so it's not just A versus B.

As with most things there is no black and white here. The cost of a new gadget will not ground everyone. Said gadget will not have everyone flying about with their head down all the time, nor will it prevent all collisions. Knee-jerk responses, particularly before the facts are known, are not the answer. Aviation does come with risks, we need to be careful how we go about identifying and minimising them.

If anyone has any hard information as to the cause of this accident I'd appreciate a steer toward it. In the meantime I'll reserve judgement on whether EC devices might have made a difference.

[PiersShedden]

Thanks Paul, as you say, there's a range of scenarios and factors involved in making GA safer, some more effective than others, some more, some less affordable. And for some would be pilots the lack of widespread anti-collision equipment in GA may also be one of the things holding them back from learning to fly.

However we have no need to await the outcome of the investigation into this particular crash - whatever the findings it is only one mid-air in many in the UK over the years. If we want to know if these devices might make the difference in mid-air collisions in general then we have only to go over the AAIB reports past examples and see if they would have done so in each case. That will give a far better statistical answer than this one tragic event on its own.

Likewise my appeal and indeed any action to accelerate adoption of EC has little to do specifically with this one tragic event.

[DaveWhite]

And for some would be pilots the lack of widespread anti-collision equipment in GA may also be one of the things holding them back from learning to fly.

Is there any evidence at all for this? (I don't mean anecdote, although I don't know any of that either).

Piers, I think you're missing the points made and just re-iterating your opinion. What is the justification for forcing people to spend money on electronic conspicuity at the expense of mitigations for other (and more hazardous) safety-related issues? There needs to be an answer to that question, because funding isn't infinite. People have to choose, whether they are the Regulator or an individual GA pilot. What is the most effective choice for a particular pot of money?

Also, I do disagree that there is too LITTLE mandation in aviation. It is one of the most heavily regulated industries on the planet.

[mikehallam]

Piers,

Taking a "good idea" into forced execution is currently under discussion on the (free) BMAA forum in their case the biennial one hour flight. They say there's no evidence it's improved the accident statistics, so is basically theory versus theory.

Now your knee-jerk proposal has much the same defects.

Perhaps a genuine safety improvement would be to stop all private flying, then the only accidents would be those to the 'controlled' performers ?
Or being even more fundamental and saving hundreds of lives, why not stop all private car driving because we'd soon learn to bicycle, walk or get stuff delivered and social chat via Skype.
Naturally it would also stop so many a/c accidents too, as only the fit or farmers with strips would fly. Safer for them as a spin off because fewer a/c in the air ------ and so on ad infinitum.
Or you could re-locate to a benign Dictatorship ?

I suspect your over enthusiastic "must make sense" demand will fortunately fall by the wayside.

Regards,

mike hallam.