Official CASA response to use of SkyEcho 2 in Class E
I asked a CASA rep if they could get a clarification of CASA's position re use of SkyEcho2 in Class E, as a substitute for a transponder.
Here is the email trail, my questions (in italics), and CASA's response in green. It has been anonymized.
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OFFICIAL
Good morning xxxxx,
I have received a reply, (in green), from the Senior Standards Officer, Air Traffic Management systems, of the Flight Standards Branch for you.
From my reading of the manufacturers website, https://www.uavionix.com.au/skyecho2. This is a portable ADS-B In and Out , and has been accepted by CASA as an approved Electronic Conspicuity (EC) Device as an enhancement to "See and Be Seen" from 16th July, 2020. It is NOT a transponder.
“Correct, with more information about electronic conspicuity and ADS-B is available on the CASA website (https://www.casa.gov.au/airspace/electronic-conspicuity-devices ) as well as in this Advisory Circular: https://www.casa.gov.au/files/advisory-circular-91-23-ads-b-enhancing-situational-awarenesspdf .”
....... I am assuming that CASA intended these devices to be used in Class E in lieu of transponders, to improve visibility under 10,000 ft to VFR aircraft.
“While a SkyEcho 2 improves visibility and situation awareness in Class E airspace, it would have to be used in this airspace in conjunction with a transponder. It cannot be used in lieu of a transponder. The main reason CASA does not allow the SkyEcho 2 to be used by itself in Class E airspace is because it does not respond to TCAS interrogations.”
These SkyEchos are very popular and have also been approved for use in the United Kingdom (where their CASA equivalent is subsidising the purchase of these units.
“This is precisely why EC devices like the SkyEcho 2 were adopted for use in Australia. Unfortunately, CASA is not funded to subsidise their purchase.”
I would like to strongly press for a change to allow carriage of a suitably configured Sky Echo to meet the equipment requirements for Class E up to 10,000ft. The current proposal is a safety disaster in the making.
“The main reason the SkyEcho 2 is not suitable is that it does not respond to TCAS interrogations. TCAS is an important last-ditch safety mitigator for any larger passenger aircraft that may be operating in Class E airspace. Another problem is that the SkyEcho 2, as a portable windshield-mounted device with internal antenna, can suffer from shielding from an aircraft’s superstructure. This means its transmissions are not as reliable dependable as a transponder or other ADS-B device (fixed or otherwise) that has a proper external antenna.”
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Anyone got a cheap transponder I can buy?