CAA and the Compulsory Fitment of Transponders in All Aircraft
ICAO issued Document 003 in terms of the "AFI CNS ATM Implementation Plan" This document is dated October 2003 - Rev 5.1. The Implementation Plan forms part of a global ICAO initiative, but focuses on the Southern African region.
The document contains certain advisory provisions relating to Terminal areas (TMAs). For example Paragraph 2.2.2.2.1 and paragraph 2.2.2.2.2 read as follows:
"Secondary Surveillance Radar (SSR) should be used to provide surveillance within busy TMAs meeting criteria to be defined by APIRG; SSR Mode S will gradually be introduced in selected busy TMAs to be confirmed by APIRG." and "Where available and when necessary in the interest of safety, existing primary radars may continue to be used in those TMA environments where there still exists a mix of transponder-equipped and non transponder-equipped aircraft until there is sufficient equipage in pressure altitude reporting transponders."
It concludes with the following: "Note: The intent of this paragraph is to discourage the installation of new primary radar. Equipage in pressure altitude reporting transponders should be promoted by States in accordance with ICAO provisions in Annex 6, Part I on international air transport, and Part II on general aviation."
The Aero Club of South Africa has at various forums expressed its dissatisfaction to the notion of mandatory fitment of transponders to all aircraft flying within the "environment" of a TMA. This would make the fitment of transponders compulsory in airspace where a radio was not even required.
CAA published AIC 44.2. The intention of this AIC is to warn pilots that transponders will become compulsory under, over and within 5 miles of the CTAs and TMAs of Cape Town, PE, EL, Jhb, Lanseria, Bloemfontein, Durban and Pietermaritzburg.
CAA regard the AIC44.2 to be their "final consultation prior to implementation".
Both SAPFA and MISASA urged their members to send faxes to CAA objecting to this AIC.
The Aero Club of South Africa has also issued a strong letter of objection to the contents of this AIC as it is contrary to the negotiations it was having with ATNS. The Letter to ATNS(pdf file 13kb) expresses the position of Aero Club in this matter.
The Commissioner of Civil Aviation called a meeting of interested parties which included CAA, Aero Club, AASA and ATNS. The latter two parties proposed that the fitment of transponders be made compulsory with the GA representatives objecting based on a number of issues. GA was tasked to make proposals for a different solution that the one proposed bt ATNS and the airlines.
Aero Club of SA has issued a press release in this regard:
- Aero Club Notice(pdf 17kb)
The Commissioner addressed a letter to all the interested parties giving his view of the situation. He has indicated that the bone of contention is economics, not safety.He indicated that the airspace incursions will not be prevented by either PSR or SSR. He believes education and training be a possible solution.
At that stage it appeared as if the issue of the compulsory fitment of transponders had been shelved. ATNS has however raised the issue again in a letter to the Commissioner for Civil Aviation as they believe that there is a real risk of airspace incursions and have has decided to conduct a functional hazard assessment (FHA) and a collision risk assessment (CRA) with the view of identifying "hazards and risks".
- ATNS Letter to the SACAA(pdf 29kb)
A document has been issued by ATNS. It appears as if the hazards identified in the document are not real. Aero Club is andling the issue.
Contact AWSA at awsa@awsa.co.za if you would like any of these documents faxed to you or supplied in another format.