Thanks. I have added:
Mode S secondary surveillance radar dates from 1975 (ICAO Annex 10 Amendment 66), and ADS-B in its modern form from the early 1990s. By the time any UK mandate could realistically be fully implemented — ten years, on the evidence below — Mode S/ADS-B will be a 40- to 50-year-old surveillance technology. It is incongruous, at a time of exponential development in AI, sensors and robotics, for a government agency to be mandating as the foundation of 21st-century drone integration a radio surveillance technology conceived in the era of the Morris Marina and the Austin Allegro. The CAA should be looking to what AI-driven visual detect-and-avoid can already do, not to what SSR could do half a century ago.
@Jacko well reasoned – one more argument which can’t be stressed enough: The power requirements for a continuously running transponder cannot be met by gliders without undue hassle.
I’m in the process of adding an Akkubox and I know of another Stemme that has one of these behind each seat. But this trouble is on us, it’s for wave flying where we politely ask to enter controlled airspace and it’s not an option for every glider.
Paragliders and hang gliders have it even worse.
As stated previously, this whole thing is almost wholly to do with drones. If the CAA is to license drone ops, they need to cover their ar*se by making EC compulsory…
Same with other countries.
Whether any other technology will emerge any time soon, I doubt; see optical detection in which there is a near-total lack of interest 
The budget to develop and implement an effective new traffic detection system that works for ATC and everybody in the air is large enough that neither the UK nor any other small country is going to do it. Nor does the EU seem to be motivated, even though their time and money would be better spent on this infrastructure project than a lot of the nonsense they do pursue. Organizational competence and understanding is also an issue with any regulator in Europe. I think the choice is either to adopt what is already working or do nothing. A key issue would be to adopt the airspace design that goes along with the technology.
Gliders and other aircraft without an engine driven electrical system are exempted in FAA regs, with the only restriction being that they can’t fly in the very highest levels of controlled airspace, which are geographically small.
This is for GA and drones only. Airlines fly almost entirely in CAS and anyway emit ADSB already.
So no taxpayer money will be spent on it because in Europe almost nothing gets done to support GA.
Airspace changes are politically impossible due to national sovereignty issues. EASA tried it many years ago. Eric Sivel told me it is impossible.
One thing to keep in mind is that drones are coming whether we like it or not. CAT operates largely inside CAS and is equipped with TCAS, transponders etc. If a drone falls out of the sky after hitting an aircraft the drone operator is still alive and well. So the drones are our problem. And MACs are also not as rare as you’d think, AAIB found there were 39 MACs in ~23mln GA hours so about 0.34 per 100k hours. That’s not so negligible when you think that fatal accident rate is about ~1 per 100k hours. Our MAC numbers are also 4x the US numbers (airspace design probably plays a role here).
For the reply to the consultation, one comment I would have is that optical detection working on roads is very different than it working in the air for drones. My guess is that a lot of what is behind this is the intended expansion of drone activity into other parts of the uncontrolled airspace than they are currently allowed this so I would probably ask for that to be curtailed (stronger controls over where drones are able to be).
The point about 1090 MHz saturation is a good one and is something the CAA have themselves said actually. They think 1090 MHz will be saturated sometime around 2040 so that gives us less than 15 years till that happens and we need something new. Maybe it’s time to think about this new thing now rather than have us pay the price twice?
Also the cost is significantly overstated because many aircraft already either have certified ADS-B or an uncertified EC source. Under 140 kts the cost is only buying an EC device.
Overall this doesn’t sound so bad to me. Even in a hypothetical world without drones, I find that aircraft are very difficult to spot with eyesight alone.
Local copy of the above CAP3139 CAA doc cap3139_ec_ws6_consolidated_report_pdf
I haven’t got time to read it right now but I do not believe the saturation theory. GA is declining, not growing, and in some countries it has almost disappeared. In most of Europe, there is virtually no GA. Airline growth is limited by airport slots, ATC capacity, you name it. The system is only just hanging together at present. The UK has had a collapse only yesterday…
But no consultant will get paid for producing a report recommending no action
Hence we get the regulatory ratchet (well there is empire building etc).
I responded somewhere in the lines of “disagree! don’t make the GA pay the bill for UAVs”.
If the CAA were to say something in the lines of “from year 203x any new transponder installs must be ADS-B”, then I would have thought about replying differently.
With regard to the GA MAC data quoted by the CAA in support of an EC mandate, one might argue that they have deliberately(?) distorted the figures by:
(a) aggregating incidents from a 20 year period during which there has been a significant decrease in the number of collisions per year and
(b) including a majority of airshow/competition, glider-on-glider and glider-on-tug/tow rope collisions (which glider pilots recognise as a known risk to be mitigated by routinely wearing parachutes).
Instead of looking all the way back to 2003 the CAA could have noted that there was only one fatal non-glider mid-air collision in the decade to 2023 – but they must have feared that quoting such recent/current data would weaken their case for a blanket criminal EC mandate.
Jacko wrote:
(b) including a majority of airshow/competition, glider-on-glider and glider-on-tug/tow rope collisions (which glider pilots recognise as a known risk to be mitigated by routinely wearing parachutes).And/or FLARM. Literally everone uses it, voluntarily. It works with rather low energy consumption, it doesn’t generate constant alarms when gliders circle in a gaggle, not for the pilots nor for the traffic controllers. It would be much easier if the drones could simply receive FLARM and FANET+