RAA Questions FAA ADS-B Out Benefit Projections

Saying fleet equipage for ADS-B Out would likely exceed the $4.73-million benefit use of the system offers, the Regional Airline Association joined the Air Transport Association (ATA) in objecting to the proposed rule requiring ADS-B Out on all aircraft by 2020. Related Story  It also requested the...

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Saying fleet equipage for ADS-B Out would likely exceed the $4.73-million benefit use of the system offers, the Regional Airline Association joined the Air Transport Association (ATA) in objecting to the proposed rule requiring ADS-B Out on all aircraft by 2020. Related Story  It also requested the Federal Aviation Administration re-write its benefits analysis. Other organizations complained that the proposed ADS-B equipment is too robust for current needs and FAA should be looking at evolutionary introduction of airborne equipment rather than the revolutionary equipment proposed as part of its October 2007 Notice of Proposed Rulemaking.
RAA said the largest beneficiary of the proposed rule would be FAA itself as it goes to satellite-based system and shifts the cost of installation and maintenance from FAA ground-based equipment to aircraft operators. The NPRM indicated the FAA would save $3 billion.
RAA also wants to know how the benefits of the NPRM, which calls for equal access to major hub airports, squares with the DOT/FAA restrictions into such airports. It wants the FAA to analyze how the congestion pricing rule will impact future traffic projections and revise its benefits analysis. “The projected benefit assumes that regional operators will have ‘equal access’ to the major hub airports in the coming years,” said RAA in its comments on the NRPM. “[This] could significantly reduce or eliminate regional operations at such hub airports; if this policy is adopted, then we could see the premise for adopting the ADS-B proposal, namely that U.S. air traffic is expected to double by 2025, may simply not occur or may occur only at the less utilized airports and airspace regions. The ability of regional air carriers to have equal access into the major hub airports is the backbone of the regional airline business model. This model is critical to the participation of small- and medium-size communities within the air transportation system. Many of the stated benefits of this proposal are based upon the doubling of capacity at our major hub airports. If this cannot occur as a result of conflicting DOT/FAA policy, then we must seriously view the benefits of enhanced capacity using ADS-B Out for our members as indeed, greatly overstated.”

RAA Estimate of Costs
“FAA estimates the benefits from ‘surface flow application for pilots’ and ‘terminal and en route flow applications of the proposed rule’ at $11.82M (by 2007M$),” said RAA. “If we project that regional operations will consist of approximately 50 percent of all scheduled commercial flights by 2020 (i.e., no change from current operations), that all scheduled flight comprise 80 percent of the total and that all flights will equally benefit from ADS-B Out, then the FAA benefit estimates for regional operators are projected to be $4.73M (by 2007M$). In actuality because the FAA has not committed to a measurable reduction in aircraft-to-aircraft separation standards, the benefits are likely to be local (e.g. Juneau, Alaska) or regional (e.g. Gulf of Mexico) and therefore very difficult to define as benefits for our members.”
The organization noted the current regional fleet consists of nearly 3,000 aircraft and projected regional aircraft to number 4,000 by 2020. “If the projected costs of retrofit/forward fit for ADS-B Out are greater than $118,250 per airplane for the regional fleet, then the FAA’s benefit analysis becomes negative for regional operators,” said RAA. “We think that for only ADS-B Out retrofit/forward fit, the average airplane costs will be around $118,250 per aircraft but are the benefits described in the FAA’s benefit analysis realistic and be accomplished only by the ADS-B Out retrofit/forward fit? Also do they consider the cost incurred by operators at airports without backup radar systems? We think not.”
RAA noted that FAA analysis does not compare the cost/benefits to alternatives and includes the benefits of ADS-B In which is not covered in the rulemaking. Citing the 2003 mandate reducing vertical separation minima (RVSM), the association said the FAA needs help in estimating benefits. “We mention this rule because the benefits used to justify the rule were not primarily safety driven but rather based on capacity enhancement and potential fuel savings by the operators in that RVSM was to provide to the operators, greater opportunities to operate on more fuel efficient routes,” said RAA. “The FAA economists have considerable experience in justifying rules that enhance safety but their experience to realistically cost justify rules that are based upon capacity enhancement and fuel saving may be relatively new and unproven.”
It noted that FAA claims that ADS-B Out would provide more efficient spacing on approach in visual meteorological conditions (VMC) as well as continuous descent approaches. However, it said that this remains unproven as UPS has just equipped part of its fleet with ADS-B to test whether or not it is true and questioned whether such benefits, if proven, can be duplicated at congested airports.
“If ADS-B is indeed the solution for enhancing capacity, it must provide relief at the currently congested hub airports,” said RAA. “The FAA has also implemented a comprehensive instrument approach procedure production plan that enables industry to take advantage of new aircraft and space-based navigation technology, especially as it relates to RNAV/RNP procedures. The benefit analysis should quantify the benefits that ADS-B alone would provide over current recognized procedures that enable current operations for conducting continuous descent approaches.”

ATA Objects to ADS-B Plan
The ADS-B plan issued by the Federal Aviation Administration increases costs because the equipment is too expensive and does not achieve stakeholder benefits, said the ATA as it submitted its comments to the plan yesterday.
“The FAA proposal calls for a Porsche when a Chevy can do the job,” said ATA President and CEO James C. May. “The industry needs a test vehicle, not a race-ready one and the current proposal adds unnecessary cost and complexity. The ATA approach, at almost half the cost of the FAA proposal, would accelerate stakeholder benefits through demonstration projects and [providing incentives for] early equipage.”
While ATA supports ADS-B, the NPRM, as written, does not increase system capacity, efficiency or environmental performance. The NPRM commits the industry to significant investments in equipage, yet fails to return any real benefits to stakeholders.
The organization proposed an alternative providing a two-phased approach that would accelerate the public benefits of ADS-B technology, advance the development of ADS-B applications and reduce the risks of future equipage that may be required.