Industry Questions NPRM on ADS-B Out

Business aviation interests joined airline industry associations in questioning the FAA’s NPRM on requiring ADS-B Out saying the equipment is too expensive and the FAA provides little or no incentives for voluntary equipage. Industry also questioned the agency’s cost/benefit analysis, saying it...

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Business aviation interests joined airline industry associations in questioning the FAA’s NPRM on requiring ADS-B Out saying the equipment is too expensive and the FAA provides little or no incentives for voluntary equipage. Industry also questioned the agency’s cost/benefit analysis, saying it was seriously flawed in its economic assumptions and needed to be revised. The NPRM was issued last October. Related Story The Aircraft Owners and Pilots Association (AOPA) summed it up when it said simply it is not acceptable in its current form.
“It is a high-cost plan that offers little or no new benefits for general aviation, while forcing aircraft owners to retain their existing transponders and spend at least $6,000-8,000 simply to maintain access in the airspace where they already fly,” said the association, urging the FAA to work with industry through the Aviation Rulemaking Committee process to analyze comments and research the more technical issues. AOPA contends the current proposed rule needs such significant modifications that will alter its scope and policy as to warrant the additional step of producing a Supplemental Notice of Proposed Rulemaking rather than continuing with plans to publish a final rule.”
The National Air Transportation Association (NATA) proposed FAA develop a joint (FAA-Industry) ADS-B Transition Plan directed towards on-demand operators, with emphasis on those that provide services to smaller community airports. “A clear presentation of the path to be followed by both the FAA and industry is required to achieve the benefits of ADS-B,” said the association, echoing others that the NPRM does not provide the industry accurate and complete definition of technical requirements/specifications for design/manufacture, certification and installation of both ADS-B Out and IN equipment. “Prior to the issuance of a final rule, NATA believes it is necessary that the FAA aggressively develop and publish, as part of the final regulations, a phased plan of equipage, financial incentives and operational benefits for operators and equipment owners in all affected sectors of the industry.”
As a participant in FAA’s ADS-B Aviation Rulemaking Committee (ARC), the National Business Aircraft Association recommended the agency follow the 12 ARC recommendations on the subject that provide a road map for voluntary equipage. It echoed others saying insufficient data exists to have confidence in the costs stated in the NPRM. It also noted that FAA requirement appear to be more stringent than those in Australia and Canada, raising the question of global harmonization and interoperability.
The bottom line for the industry, however, is the fact that the NPRM is far from addressing their concerns and FAA has much more work to do before an final rule would be acceptable.
The proposed rule either contradicts or ignores the majority of the principals outlined in a 2006 presentation of AOPA research to the FAA. Those principals include:
•ADS-B will result in cost savings by ultimately replacing radar and Traffic Alert and Collision Avoidance System (TCAS);
•ADS-B should eliminate the requirement for a Mode C transponder;
•ADS-B implementation should not be a “Mode S implementation in disguise”
(meaning the only benefit to installing the costly new equipment is continued access to the airspace);
•ADS-B avionics must be affordable majority of general aviation aircraft owners to voluntarily equip or be supportive of ADS-B);
•Cost and complexity should not be an encumbrance to aircraft owners having the equipment installed in their aircraft;
•The datalink for general aviation must be Universal Access Transceiver (UAT);
•The FAA must make a commitment to not change ADS-B avionics standards for at least a decade once these are established;
•All Flight Information Service (FIS) data should be free (along with traffic information FIS serves as an incentive for equipage); and
•The FAA must provide high quality weather and robust traffic information services at least eight to 10 years prior to mandating ADS-B for general aviation.
“The planned ADS-B Out requirement emulates today’s radar coverage, resulting in little more than a warmed over version of the Mode S transponder proposal from the 1980’s,” said AOPA. “This approach to implementing ADS-B raises serious questions about the scope and magnitude of the mandate.” It expressed frustration that despite intense work with FAA on what would induce industry to equip voluntarily as happened with the Global Positioning System (GPS), the FAA’s NPRM fell far short. “FAA’s plan for ADS-B Out, plus the $6,000 to $8,000 per aircraft investment cost needed to comply with the rule fails to motivate aircraft owners to voluntarily install ADS-B avionics. Assuming the cost of avionics were similar to the cost of today’s transponder ($2,500), and the need for a Mode C transponder is eliminated, ADS-B Out must provide at a minimum, the following safety enhancements and operational improvements to make it even remotely appealing for general aviation aircraft owners.
•Air traffic control flight following and radar services in the en route phase of flight, at altitudes most commonly used by general aviation aircraft, usually considered to be below today’s radar coverage.
•Terminal air traffic control services at thousands of general aviation airports including radar vectoring and flight following. These services increase operational capacity and safety at general aviation airports by eliminating the one-in/one-out Instrument Flight Rule (IFR) access limitation.
•Automatic closing of instrument flight plans by air traffic control after landing.
•Using ADS-B position reports to re-trace the flight progress of missing aircraft, accelerating rescue.
•Increasing the availability of low-altitude, direct-to navigation during instrument operations.
•Enabling a Flight Service Station (FSS) interface for improved weather and flight planning services, including tailored information based on accurate knowledge of the aircraft’s position and altitude.
AOPA said even the FAA’s recently awarded contract to ITT for the service, provides little benefit for GA. The NRPM also requires GA to not only re-equip but maintain Mode C transponder at $1.8 million, equal to that for FAA to replicate radar. “The 800 ground stations are not sufficient to provide low-altitude coverage to even a fraction of the 5,400 public-use general aviation airports nationwide,” it said. “With no expansion of important safety services, we are left with serious questions about the value of the ITT contract.”
It also questioned the use of two datalinks. “The proposed rule mandates the use of a 1090 Extended Squitter (1090 ES) ADS-B system for an aircraft that operates above Flight Level 240,” it said in opposing the use of 1090ES because of its performance and limitations identified by FAA and industry research. “Otherwise, aircraft owners have the choice between that datalink and the Universal Access Transceiver (UAT). The UAT ADS-B datalink was designed in the late 1990’s specifically to address the needs expressed by general aviation pilots. In addition to traffic data, the UAT datalink can support the transmission of graphical weather and airspace information into the cockpit, giving pilots who equip with this technology a significant advantage over those using
1090ES. The UAT datalink can also provide greater traffic density and is likely to have a lower cost, making it the likely choice of general aviation aircraft that do not plan to fly above FL240 or outside of North America. In addition, the use of two datalinks presents important issues including safety, operator privacy, and international compatibility.”
The FAA cited the fact existing TCAS systems are not now compatible with ADS-B; and its desire to use it as secondary surveillance radar at large airports in the event of a GPS outage but AOPA countered that FAA has not fully evaluated the feasibility of upgrading TCAS to use ADS-B transmissions in lieu of transponder replies.
It echoed all other organizations saying that incentives, such as federal tax credits, early equipage incentives, a government-issued NextGen equipment voucher, and a competition among manufacturers to develop a low-cost ADS-B were not part of the proposal and recommended such incentives be developed to encourage voluntary equipage.