Please Provide Feedback on ADS-B Proposal

Folks,

Another reminder that the FAA is moving rapidly toward putting much of the cost of the ATC system onto the users via their current proposal on ADS-B.

To summarize, this rulemaking, if it goes into effect without modification, will require anyone who needs to enter Class B, Class C airspace, the mode C veils for those airspaces, AND anyone who wants to fly above 10,000 feet msl (PAY Attention, westerners) will be required after implementation of the proposal, to equip their aircraft with ADS-B.

ADS-B, for those of you living off the net for the last few years, is a device that lives in the back of your aircraft, and continuously transmits (hence the A=Automatic) a signal with your position, derived from GPS (hence the D=Dependant on a GPS) to anyone who's listening out there (hence the S=Surveillance). Oh, yeah, the B stands for Broadcast.

Right now, this equipment costs somewhere between $9,000 and $17,000 per unit, plus installation. It also weighs a good bit for those concerned about the weight of your airplanes.

Frankly, I'm not sure that something like ADS-B isn't a great idea around huge terminal areas. Is Anchorage one of those? It will be, if this thing goes through unmodified.

Westerners, you'll need one of these things to fly above 10,000 feet msl. That means you'll either be in violation or down in the canyons all the time.

Oh, by the way, a couple of points that most folks seem to be missing on this proposal:

1) The system the FAA is proposing is NOT a space based system. To communicate with ATC, you will have to be in line of sight with a GBT (ground based transmitter). Think about that in mountainous areas of the west.

2) The system required by this proposal also will NOT provide the user with free weather, etc, as is the case with the Capstone project in Alaska.

3) I've been flying an airplane equipped with a large flat panel display and ADS-B. It is really tough to see other traffic, and evaluate the threat on a huge flat panel display. I can't imagine trying to use one of these things on any screen that'll fit in the cockpit of a Cub or similar aircraft.

In other words, near as I can tell, all the benefit will be to the FAA, and very little to the user, who will have to purchase and install a lot of very expensive equipment.

Please consider commenting on this proposal NOW, folks. The comment date has been extended to March 3.

Here's the docket: http://edocket.access.gpo.gov/2007/pdf/E7-22544.pdf

And, I'm not suggesting this program is a VERY bad idea, but I really think this proposal needs to be modified.

MTV

Mike I must plead ignorance here.Is this system for collision avoidance ,detection by other aircraft or atc or both?How is this any better for atc if we already use a transponder.I am based just inside Boston's veil.We already have to have Mode C.
Bill

Willy,

Simple answer: All of the above. The ADS- B system is designed to REPLACE ATC radar. As a consequence, your mode C transponder will become useless.

If you're under the veil, be prepared to spend a LOT of money.

The FAA has said from the beginning of Capstone that prices will come down. So far, they haven't, and frankly, if you look at prices of some of the most basic avionics, it's hard to imagine that prices for this kind of equipment will ever come down significantly in price.

This single proposal could have a severe negative impact on little airplanes.

AOPA seems to be getting into jets in a big way lately. I'm not sure they are thinking that much in terms of the little guy on this one.

Please send in some comments.

And, above all READ the dang proposal.

MTV

Thanks for posting Mike. I think all of us HAVE TO respond on all of these rules during the comment periods, whether they will directly impact us or not. If we don't we can't complain when little by little through a rule here and a rule there, we loose most of our freedoms to fly, either through burdensome regulations or government imposed costs to comply with these regulations. It is happening, and unless everyone gets on the boat and makes yourself heard, it will happen faster than any of us think. All in the guise of making us "safer". I have seen the enemy and he is us (not the oil companies or attorney's) and our attitude that it will never happen in our "free" country.

Superchamp,

Correct. Also, this is just the camel's nose under the tent flap, I'd bet. They'll propose ADS-B for Class B and C and above 10 now, then after a few more years, they'll propose the requirement for Class D, and above 1200, etc.

It only takes a few minutes to send a note to FAA and AOPA to let these folks know that one size may not fit all.

There is no doubt that ADS-B is coming, the question is: How much impact will it have on people with simple airplanes.

MTV

ATC

Ever get the idea that someone is trying to shut us down? Or am I just getting paranoid? Seems to me the pay to play concept is getting out of hand.

This is a great example of how government works as it gets older and bigger. Each new guy in positions of even a little power feels he/she has to expand/build on/surpass the accomplishments of his/her predecessor in order to succeed or excel. The easiest way to do this is to create something new. In Congress, that means new laws, each more restrictive, more narrow or more encompassing than the previous. Ever notice that each generation of elected officials is quick to burden us with new laws but almost never repeal old ones? Same goes for the upwardly mobile in other government agencies like the FAA. To continue to do well in their jobs, they have to perpetuate the illusion of moving the organization forward. This often is done without regard to consequences, side effects, collateral damage or anything else. This is what ADS-B is -- somebody's baby, their ticket to the top. While ADS-B is certainly do-able and arguably a quantum leap over today's radar based system, it was most likely intended from the beginning for the airlines, but we -- the rest of us who fly -- got caught up in the requirement by default. It never occurred to the geek in the lab coat or his policy-maker boss that all airplanes are not created equal, nor does he much care. Both want to make their mark. And that mark will be left on us, the little guys. I'm betting that ADS-B is here to stay and, like the AOPA says, will eventually devolve into something we can afford and that we will convince ourselves we need -- another cool gadget in the cockpit. Afterall, how long was it before Mode C sprouted in nearly every cockpit? In the beginning, peer pressure and the need to keep up with the Joneses put them there. I had one in my Skylane and it came in handy because that was a traveling machine. My 12 came with Mode C installed, but why? It is a fun machine that only rarely travels far and never carries me into Class B or C airspace. If I need it, my transponder likely will fill my needs for as long as I have the airplane. I will continue to fly with my elbow out the window from one uncontrolled strip to another as often as I can for as long as I can; that is my choice. Those of you who fly for a living or in weather might as well bend over and spread 'em, because I'm betting ADS-B is coming -- the schedule says within 10 years -- whether you want it or think you can afford it or not and no amount of calling and letter writing will stop it. In ten years, if you can still afford a tank of avgas and are still flying, you will find a way to wedge another scope in your panel and get on with life. That's the American way.

Mike,

As we've been told in ATC the ADS-B will augment and if found to be a viable option replace ground based radar. It is satellite based. There is a ground based component acting as a relay to link the satellite information to ATC facilities. The TCAS like information given to pilots also uses this ground based link. Radio communication will remain exactly as it does today. There is the option to link radios to the satellite but I think until technology catches up it won't happen.

What this means is for once we can actually see you in all areas. Pilots can be given ATC services in areas they once couldn't. In Minneapolis I can't see an aircraft NW of the GEP VOR below 5000'. When I was at RNO we couldn't see anything low outside of the Washoe Valley. The system is seamless. If we would've had the system when Steve Fossett went missing we could've replayed the data and went to his last known position within .1 of a mile. Every aircraft is assigned a aircraft specific Mode S code. You already have one assigned to you. If somebody steals your 170 the radar data can be replayed and we know where your plane went.

As an added benifet pilots can now recieve traffic information on other aircraft. This should not be confused with TCAS, which provides conflict resolution solutions. Traffic position only. Yes you will be able to recieve weather on the system. I think it will be much like what you get today over XM. The government isn't getting into the weather prediction business. To much liability.

The radar's we use today are almost 50 years old. It cost the taxpayers tens of thousands a month just for the electricity to power one. Add to that the associated cost of maintenance. Multiply that by the hundreds of radars out there, and you can get an idea of where your money goes. Most pilots know where they are better than me. I get an update every 5 seconds. At the centers the updates are every 12 seconds. ADS-B update is once per second. As communities grow into cities radar coverage becomes more and more degraded. ADS-B doesn't care if there's buildings or mountains. This new system will have the reliability of the GPS we all use today.

I'm sure there will be constructive comments. Unfortunately I will be gone until Tuesday. I look forward to reading them when I return.

Steve

I've been a big fan of ADS-B in theory, but is it really a good idea to be identifying ourselves? http://www.airsport-corp.com/adsb2.htm at least, without encryption? :-?

Oldbaldguy, I'm afraid you are correct in saying like it or not, expensive or not, bend over. In my experience with the government once they get to the comment phase, they are only going to here what confirms their predetermined conclusions. I commented in the fuel cost thread that I believe the time is not too far distant when we will need to get permission from a high government authority each and every time BEFORE we leave the ground. I stand by this prediction. ADS-B will be one more foot step down this path. Cabinflyer, while I won't argue that the system offer's great potential to track all aircraft, at what cost? Are you going to jam a $17,000 bill down the throat of an owner of a $17,000 Tcraft and tell him its for his own good? Chances are, he will say screw it and not fly. At what cost do we need to protect us from ourselves? Last I checked, there hasn't been many planes running into each other, or disappearing never to be found. Sure it happens, and it makes all the news. But maybe if the safety of everyone everywhere and all times is the job of our Big Brother government, we should require the same GPS tracking devices be installed in all cars and all people. Then we will always no where everyone is at all times, just in case the government needs to "rescue" them. I have seen the enemy and he is us. And I'll bet 99% of the people on this site won't take the time to comment on this proposal. But when it happens it 2 or 5 or 10 years they will wonder how it came to be.

Guys,

Don't get me wrong here. I think that ADS-B as an eventual replacement for ATC radar is probably a great idea, and could actually work.

That said, Cabinflyer, tell us just how well the ATC radar group grope has gone, with billions spent, and the system still not fully functional? I'd suggest that ADS-B will cost orders of magnitude more time and $$ to develop, once the bureaucrats start "tweaking" it, as they did with the radars and with the AFSS computer system, which also took forever and many $$$$ to get up and running.

My concern is that the little guy in the little airplane could get shut out of a lot of airspace. Consider that with the current proposal, you could not fly legally above peak level in much of the western mountains.

So, what I'm suggesting is not telling em to shove it, but rather to IMPROVE the proposal so as not to impact little airplanes too much at least at the start.

Also, mode C veils will cut us off from a lot of airspace, for probably no good reason, as long as we stay out of the primary airspace.

I have a bit of experience with ADS-B, and as far as traffic avoidance, it is TERRIBLE, simply because it requires the pilot to be staring at an MFD, when in fact they should be looking out the window. In busy airspace around here, the display will show 20 or so airplanes, and it's up to the pilot to figure out if any are a threat.

The system communicates with other aircraft directly, and with ATC via GBT's. At least for the moment, the only space based component is the onboard GPS. I'm not sure what the "final" configuration will be, though.

I have also found conflicting information regarding weather information with the proposed system.

In any case, for the moment, Garmin has shot this system in the foot pretty good with the weather info from the 396/496.

We'll see, all I'm asking is that people read the NPRM and comment.

MTV

I agree with Mike. In theory, we live in a participatory democracy. If we don't tell the gov what we think today, then we have no right to bitch later. Just because I'm an OBG and may not be flying real airplanes anymore by the time ADS-B kicks in everywhere doesn't mean I'm not gonna squawk to the powers that be about their lack of prior planning or understanding of the bigger aviation picture in this country. Like the man says, one size does not fit all not matter how hard you try to cram it in. From what I can tell, AOPA is on board in support of ADS-B as are all the various airline and commercial oriented lobby groups. The only other guys in our corner, the EAA, have become so limp-wristed and terrified to make waves that they won't be of any help. That leaves it to us, the people. Comment we should to any and all who will listen -- it's always better to be the shepherd than the sheep.

Is the present proposal still dependent upon the mode S transponder? That's the biggest cost component right now.($5,000)...it could be done a lot cheaper if we got rid of that bottleneck....

George Mandes posted the following on another forum. I think its worth reading:

by ANN Guest Contributor Max Trescott
There’s always a marriage of sorts between pilots and Air Traffic Control, and final vows are about to be exchanged for the FAA’s NextGen Notice of Proposed Rulemaking (NPRM). The proposal mandates ADS-B equipment in all aircraft by 2020, but the deadline for comments is just two weeks away, so now is the time for you to carefully read this prenuptial agreement.



In the past, the FAA has embarked on other multi-billion dollar modernization programs that ballooned in size and failed to deliver as promised. This program could be more successful than those, but it may need changes to optimize it to deliver the right benefits at the lowest cost. Whether you own or rent, your money is at stake and you have until March 3, 2008 to submit comments to the FAA.

To date, the industry has been relatively quiet on the proposal. That’s surprising since, by FAA estimates, GA aircraft owners can expect to pay from $4,000 to $17,000 to bring each aircraft into compliance by 2020. However, if owners think that complying with the mandate will bring free traffic and weather information into the cockpit, they haven’t been paying attention, because it won’t. The full text of the NPRM, which runs 25 pages, can be downloaded as a pfd file.

The underlying premise is that demand for air travel will double over the next 20 years, but that the present US Air Traffic Control system (ATC) is not designed to handle this growth. One constraint is the use of radar technology. Radar is sufficiently inaccurate at longer distances that ATC must keep the moving dots separated by five miles in order to assure that the real airplanes—which may not be exactly where the dots indicate they are—don’t collide with each other. Radar is also expensive to maintain, since it requires large, rotating antennas sited on leased land.

The goals of NextGen include improving safety and efficiency by taking advantage of emerging technologies, namely ADS-B. ADS-B uses GPS receivers on board each aircraft to identify aircraft position more precisely than is possible using radar. It broadcasts this position information so that other ADS-B equipped aircraft, surface vehicles and ground stations are aware of the aircraft’s position. ADS-B has been successfully demonstrated for several years in Alaska as part of the Capstone project. Accidents decreased by 45%, though much of this decline may be attributable to "ADS-B In" capability, not the "ADS-B Out" capability mandated in this NPRM. Here’s the difference.

ADS-B stands for Automatic Dependent Surveillance-Broadcast. It is Automatic because unlike a transponder, it broadcasts continuously, not just when interrogated by radar or a TCAS system. It is Dependent, since it relies on GPS information. It provides the same Surveillance function as radar, but does so by Broadcasting its position.

There are two ADS-B capabilities. "ADS-B Out," which is the only one mandated in the NPRM, refers to an aircraft broadcasting its position and other information. "ADS-B In," which is not being mandated, allows an aircraft to receive traffic information from other ADS-B equipped aircraft, surface vehicles, and FAA ground stations. Weather and other information can be delivered to aircraft additionally equipped with Flight Information Services-Broadcast or FIS-B.

If you’re thinking "wait a minute, I’m spending big bucks for ADS-B Out, but I won’t get any additional information displayed in my aircraft," you’re absolutely right, though the option to receive information is available to you at additional cost. In a sense, ADS-B is a transponder replacement, except that you won’t be allowed to eliminate the transponder, which is needed as a back-up to ADS-B—more on that in a moment. First, let’s talk about benefits.

Proposed NextGen Benefits
A major proposed benefit is that the more accurate data from ADS-B will allow the five mile en route separation between aircraft to be reduced, allowing more aircraft to fit into the NAS. Yet as one commenter to the proposal stated, "reducing enroute and/or terminal separation standards WILL NOT address the congestion problem. Traffic congestion is caused by lack of runway, taxiway, and ramp/gate capacity due to airline ‘hub & spoke’ scheduling practices." You can view this and all comments to the NPRM online.



Another proposed benefit is that the FAA can save money by eliminating some radar installations. However, some of this potential savings is negated by the need to have a backup plan in case the ADS-B system fails. This would be needed if, for example, there were a wide spread outage of GPS service. The proposed backup plan is to retain all primary radar, which is still needed for national defense to identify non-participating aircraft, and to retain approximately half of the secondary radar installations near the nation’s largest airports. Hence, the mode C transponder requirement remains in place so that aircraft will be visible to secondary radar, when needed for backup.

Clearly, the costs and benefits are asymmetrical. The FAA may save money by eliminating some radar installations, but that’s offset by the requirement for pilots to spend thousands of dollars to equip each aircraft with ADS-B. Recognizing this, the NPRM does solicit comments on how to subsidize the costs to pilots and some state legislatures are considering this. On the benefits side, the FAA may succeed in squeezing more aircraft into the en route structure, but pilots who opt for the minimum required ADS-B Out requirement derive little benefit, except for continued access to the NAS.

ADS-B Regulatory Requirements
ADS-B wouldn’t be required everywhere; the requirements are similar to that of mode C transponders. To review, mode C transponders are required when operating above 10,000 feet MSL, within 30 miles of some, mostly Class B airports, and when flying under, above or through Class B and C airspace. There is an exclusion related to flying within 30 miles of Class B airports for "any aircraft which was not originally certificated with an engine-driven electrical system" and the ADS-B proposal includes the same exclusion. Mode C transponders are not required above 10,000 feet if one remains within 2,500 feet of the ground, however the ADS-B proposal does not include that exclusion.

The ADS-B proposal further mandates that aircraft operating in Class E airspace over the Gulf of Mexico, from the coastline out to 12 NM and above 3,000 feet MSL, would require ADS-B Out. This area, which contains hundreds of helicopters servicing thousands of offshore oil wells, doesn’t have radar coverage, so ADS-B would enhance surveillance in this area.

A seemingly odd requirement is that aircraft flying above FL240 will use a different ADS-B system, known as 1090ES, than many lower flying aircraft. Presumably, this is to rationalize the U.S. ADS-B proposal with that of existing 1090ES standards in some other countries. Thus, high flying aircraft traveling between continents could have the same standard ADS-B system, regardless of where they fly.



The rub is that this equipment has a lower bandwidth and cannot accommodate FIS-B capabilities, such as the display of weather in the cockpit. Thus, another ADS-B unit, called a Universal Access Transceiver (UAT) and operated on a different frequency, is proposed as an alternate way for lower flying aircraft, that are presumably more interested in these services, to comply with the ADS-B mandate. This complicates implementation of the proposal, as aircraft using these two different types of ADS-B equipment won’t be able to directly communicate and "see" each other. Hence, the proposal includes many ADS-R translators, which are sets of crosslinked, ground-based transceivers that re-broadcast all ADS-B signals on both frequencies. This should allow all ADS-B equipped aircraft, regardless of the standard they use, to see each other—except when they are not within line of sight of a ground-based ADS-R site.

Proposal Comments
Reading through the comments, many of them well thought out, is enlightening. Here are a few. The NTSB wonders why the proposal doesn’t mandate ADS-B In, which could provide additional safety information to pilots that would prevent incidents such as runway incursions. An individual points out that in many cases, the cost to install ADS-B represents one tenth to one third of the total value of older aircraft. A few people commented on security issues, including the lack of data encryption that might allow ADS-B to be used as a tool for terrorists to target aircraft.

Several comments focused on the requirement for ADS-R to handle the two different ADS-B standards. One said "The added risk of faults, failures, and ‘aged data’ (latency) in the additional computer hardware and software to accommodate two separate links (not to mention the additional infrastructure cost) makes the proposed implementation ludicrous."



Another individual, commenting on the illusory benefits of equipping with just the minimum required ADS-B Out, said "It's totally unclear what benefits, if any, will accrue to users if they equip with only the proposed ADS-B Out option."

Get Involved: Send Your Comments Today
While ADS-B holds tremendous promise, the current proposal represents a compromise that could be improved upon. Clearly the FAA has chosen to reduce pilot cost by not mandating ADS-B In, even though there’s little benefit to pilots of equipping with just ADS-B Out. Many of the services, such as weather, that would make ADS-B In valuable require equipment that differs from the ADS-B standard, used in some other countries. Thus two different standards were proposed, which increase the cost of the ground infrastructure and decrease overall system performance. However, since the time when ADS-B was first developed, some of these services, such as weather, have become available separately from third party providers. Meanwhile, the ADS-B freight train is hurtling down the tracks, as the contract has already been let for installing the ground infrastructure.



Any time billions are being spent—both of taxpayer money and of aircraft owners’ money—it pays to take a close look. Final comments on the proposal are due March 3, 2008, so read the proposal carefully. Then send your comments to AOPA. Just as in a wedding ceremony, you need to "Speak now or forever hold your peace."

Max Trescott (shown above) is an experienced CFI, author, and aviation educator.



MTV