Applications and Petitions: None Answers and Replies: ADSB Out Performance Requirements - Comments of European Business Aviation Association Orders and Notices: None Rules and Regulations: None Grant of Petitions: None

	ADSB Out Performance Requirements to Support ATC FAA-2007-29305 February 28, 2008 Comments of European Business Aviation Association EBAA would like to express its full support for the proposal. The requirements in term of accuracy and integrity of the aircraft position will allow future developments of ADS-B applications as ASAS. The recommendation to use WAAS, keeping the door open for future technology improvements (GPS III, Galileo) is appreciated. This is a low cost solution which will have the advantage of promoting the development and use of SBAS approaches such as LPV and "steep & curved". Safety will be improved (elimination of NPA) and it will be positive for the environment too (procedures to mitigate noise nuisance). The recommendation to implement the UAT is an excellent proposal. Due to the traffic increase there will be more and more commercial and Business Aviation activities in the TMAs of regional and local airports. UAT will permit General Aviation to equip their aircraft with a system which will combine ADS-B in and out, will provide TIS-B FIS-B and which may allow tomorrow for data link. Such a development will drastically improve the safety of all airspace users. We believe 1090ES is not a solution adapted to GA. Transmission of an "indication of the emitter category" to quantify the wake vortex signal is also an important feature for wake vortex prediction and so to determine Wake vortex separational minima. Nevertheless EBAA suggests that to improve the value of "indication”, this indicator should reflect less the class of weight but rather the class of energy of the vortex. Such a measure related to 'aircraft induced drag", can be computed based on aircraft type, weight, flaps setting and indicated airspeed. By: EBAA, 32-2-766-00-70 Index