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FAA-2007-29305 - ADSB Out Performance Requirements to Support ATC
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ADSB Out Performance Requirements to Support ATC
Optimizing the Benefits of Automatic Dependent Surveillance-Broadcast - Report from the ADS-B Aviation Rulemaking Committee - October 3, 2007
Surveillance/Positioning Backup Strategy Alternative Analysis - Final Report - January 8, 2007 - 172 Pages By: FAA
ADS-B Benefits Enabled from Improved En Route Conflict Probe Performance - August 27, 2007
Next Generation Air Transportation System Integrated Plan - December 12, 2004
A Predictive Model of User Equipage Costs for Future Air Traffic Services and Capabilities: An ADS-B Example - Mitre Technical Report - May 2006
ATO En Route Services - Surveillance and Broadcast Services Benefits Basis of Estimate - August 2007
October 19, 2007 Request to Extend Public Comment Period A key component of NextGen, ADS-B technology is an important step to updating the national airspace system. We appreciate FAA’s effort to embrace technology that will further safety, capacity, efficiency and environmental benefits. As noted in the proposal, the FAA needs additional information in several areas to complete a regulatory evaluation. Coordination and retrieval of this information will be extensive and time consuming. For example, our organizations and our members will have to coordinate with airplane manufacturers to determine when and how manufacturers could provide equipment and services to comply with a potential final rule. The bases for several of the FAA fundamental cost assumptions outlined in the Draft Regulatory Impact Analysis are not clear. For instance, it is not clear on what basis FAA or industry should assume airplane manufacturers would: (1) invest in equipping newly delivered aircraft after a federal commitment of two appropriation-funding cycles, or; (2) start equipping ADS-B Out avionics on new aircraft deliveries in 2012, because it would be cheaper to purchase new aircraft with the avionics installed than to retrofit in 2020. Substantiation of these assumptions will take extensive coordination with various air carriers and airplane manufacturers. By: Air Transport Association of America, Air Carrier Association of America, Aerospace Industries Association, Regional Airline Association and National Air Carrier Association
On File at Federal Register November 16, 2007 Extension of Comment Period | As Published in Federal Register November 19, 2007 This action extends the comment period for an NPRM that was published on October 2007. In that documentt the FAA proposed performance requirements for certain avionics equipment on aircraft operating in specified classes of airspace within the United States National Airspace System. This extension is a result of requests from the: Air Transport Association of Americal Inc., Air Carrier Association of Americat Civil Aviation Aerospace Industries Associationt National Air Carrier Associationl and Regional Airline Association; Aircraft Owners and Pilots Association; and Cargo Airline Association to extend the comment period to the proposal. The comment period for the NPRM published on October 2007, scheduled to close on January 31 2008, is extended until March 2008. By: Airspace and AIM Office, Edie Parish
December 19, 2007 Under Order 1110.147, effective July 15, 2007, the FAA established the ADS-B Aviation Rulemaking Committee pursuant to the Administrator’s authority under Title 49 of the United States Code section 106(p)(5). The ADS-B ARC provides a forum for the U.S. aviation community to discuss and review the ADS-B NPRM after its publication, formulate recommendations on an ADS-B mandate, and consider additional actions that may be necessary to implement those recommendations. The ARC submitted questions to the FAA to clarify the NPRM. The questions and the FAA responses were discussed at an ARC teleconference on December 19, 2007 and are being submitted to the docket so the public will have an opportunity to see the any clarifying information the FAA provided to the ARC. By: Office of Rulemaking, Cindy Nordlie
Published in Federal Register December 21, 2007 This notice announces the availability of a revised Initial Regulatory Flexibility Analysis associated with the notice of proposed rulemaking entitled, ‘‘Automatic Dependent Surveillance-Broadcast Out performance requirements to support Air Traffic Control service.’’ The comment period for the Notice of Proposed Rulemaking published on October 5, 2007, as extended on November 19, 2007, closes March 3, 2008. By: Pamela Hamilton-Powell
January 28, 2008 Re: Comments of Rockwell-Collins The FAA should develop a two-stage ADS-B mandate. The first stage is a forward-fit mandate of 2013 with somewhat relaxed performance requirements [i.e., NACp ≥ 7, NIC ≥ 6] from the final 2020 mandate requirements. Re-assess plan to decommission TIS-B. There is a need for ASA applications to gap-fill missing traffic that is known about by other means of surveillance. By: Rockwell-Collins, 319-295-3971, cwmcderm@rockwellcollins.com
February 22, 2008 Comments of Alaskan Region Technical Standards Branch The second issue is the need to have enough adequately trained maintenance personnel available to perform these functions. This is an ongoing issue for aircraft operating in remote locations such as Alaska that do not have the luxury of having a certified 145 repair station available to do the system checks associated with the functionality of the ADS-B or Transponder checks each 24 months. This mostly affects the part 91 and small Part 135 operators that operate several hundred miles from the closest part 145 facility rated to perform this function. We recommend 14 CFR 91.411 (b) (2) be revised to allow a certificated mechanic with an airframe rating who is properly trained and with the required equipment to perform the integrated system checks associated with the functionality of the ADS-B equipment. By: ARTSB
February 26, 2008 In the context of the needs of the on-demand air transport industry, DayJet supports the mandate. Further, DayJet proposes that the FAA develop a joint (FAA-Industry) ADS-B Transition Plan expanded to encompass the on-demand flight service operators. These operators provide services at the small community airports and are willing to install the equipment necessary to meet the requirements of the JPDO NextGen vision for transformation of the U.S. air transportation system. DayJet is willing to participate with the FAA in a NextGen operational implementation that culminates in final operational services. We believe that the resulting data and operational experience will show significant benefits for today’s NAS challenges, including provision of validated data and information. By: DayJet
February 27, 2008 Comments of ERA Radar Corporation We need to improve the capabilities of smaller reliever airports. The larger OEP size airports are reaching their capacity and in many cases have reached their capacity at peak hours. Improvements to their infrastructures with ADS-B and other NextGen capabilities will provide temporal relief for these airports, but ultimately they have a finite capacity and delays will return. Longer term congestion relief needs to begin now. NextGen concepts call for better utilization for small reliever airports to help provide this relief. Many of the newer VLJs and 'seat on demand' airlines are providing services to these smaller airports vs. increasing the congestion at the larger hub airports. This approach needs to be encouraged and accelerated. Working with these on demand airlines and secondary airports will increase the utility of many of these airports, making them a more viable alternate for aircraft to fly into. Building reliever airport infrastructure will provide alternatives to the over crowded hub airports. In some cases these operators are willing to deploy ahead of the FAA plan. In those cases, FAA should encourage this action and develop plans and processes for integration of these capabilities into the NAS. By: ERA, David Ford, 703-402-7344
February 29, 2008 Comments of the Aerospace Inudstries Association | Word The proposed rule defines one level of system performance (accuracy, integrity, etc.) for all ADS-B airspace. This is a very high level of performance, presumably established to accommodate the most stringent operational applications anticipated for ADS-B use (e.g., super-density terminal operations). Recognizing that performance-based operations are a foundational element of the future operational concept, ADS-B performance requirements should be based on realistic operational applications. ADS-B compliance in RNP-4 airspace, for example, should require lower accuracy and integrity than for operations on closely-spaced parallel approaches in low visibility. By: AIA, Susan Mertes
February 29, 2008 Comments of Air Line Pilots Association ALPA is concerned that the lack of a planned mandate or timeline for ADS-B In is not addressed in the NPRM. The FAA states that “NextGen will be an aircraft-centric system” and that NextGen will “vastly improve situational awareness”. Further, ALPA agrees that ADS-B In will enable “… applications such as aircraft merging and spacing, and self-separation. These applications are enabled by having aircraft identify each other on the same data link without the need to employ ADS-R, which would increase the latency of the transmission”. However, ALPA believes that the full realization of increased capacity and enhanced safety can not be realized until “ADS-B In” (i.e. information received by the aircraft on other aircraft positions) equipage is also mandated for operations at designated locations, routes, and altitudes. Therefore, it is imperative that the FAA include a requirement for ADS-B In and a timeline for implementation as a part of this ADS-B rule. By: ALPA, Brian Townsend
February 29, 2008 Air Line Pilots Association, International ALPA is concerned that the lack of a planned mandate or timeline for ADS-B In is not addressed in the NPRM. The FAA states that “NextGen will be an aircraft-centric system” and that NextGen will “vastly improve situational awareness”. Further, ALPA agrees that ADS-B In will enable “… applications such as aircraft merging and spacing, and self-separation. These applications are enabled by having aircraft identify each other on the same data link without the need to employ ADS-R, which would increase the latency of the transmission”. However, ALPA believes that the full realization of increased capacity and enhanced safety can not be realized until “ADS-B In” (i.e. information received by the aircraft on other aircraft positions) equipage is also mandated for operations at designated locations, routes, and altitudes. Therefore, it is imperative that the FAA include a requirement for ADS-B In and a timeline for implementation as a part of this ADS-B rule. By: ALPA, Brian Townsend
February , 2008 Comments of The Air Transport Association of America Commercial transport operators certainly are interested in technology that could improve the capacity and efficiency of the NAS. ADS-B technology is the most promising foundation for NextGen and its goals of improving NAS performance while accommodating a three-fold growth in traffic. Our recommended program and actions can accelerate the implementation of ADS-B Out and instill confidence in an FAA-industry development program while avoiding premature and overly-optimistic commitments and investments. By: Basil Barimo, 202-626-4000
February , 2008 Comments of Airports Council International - North America We wish to express a general concern that the ADS-B/Out performance requirements of this NPRM fail to identify any specific operational advantage. The vague references to benefits that will be realized at some future, unspecified time resulting from a future voluntary installation ofADS-B/In will not provide sufficient fmancial and operational justification to motivate aircraft operators to equip. There is a very real risk that the much needed capacity improvements cited in the NPRM will not be accomplished unless specific improvements in operational capabilities will result from this proposed rule. In our view, that will require the integrated treatment of both ADS-B/Out and ADS-B/In, along with identification ofthe associated revised air traffic procedures that will accomplish the needed capacity improvement. It is our view that adoption ofthis rule at this time is premature. Rather than proceed with an incomplete and hastily developed rulemaking proposal, we urge you to address the many comments filed in the docket and re-issue a supplemental notice ofproposed rulemaking addressing these important concerns. By: Gregory Principato
February 29, 2008 Comments of the Association of European Airlines/International Air Transport Association IATA/AEA are opposed to WAAS as it is not a global solution and does not provide suitable operational benefit to justify its use by International Air Transport. Airlines have invested and are continuing to invest in aircraft augmentation systems that are global and offer comparable benefits at a reduced cost. IATA / AEA strongly recommend the internationally accepted Mode S 1090 MHz ES for all traffic at all levels, in line with our ADS-B out policy, and oppose to a double ADS-B data communication link standard. By: AEA/IATA
February 29, 2008 Comments of Aviation Communication & Surveillance Systems | Word The NPRM states that “Terminal area and surface applications such as Final Approach and Runway Occupancy Awareness would not be enabled unless all aircraft in the surface environment report their position accurately on runways and taxiways (NACp equal to or greater than 9).” This wording suggests that if there were 100 aircraft around a given airport and one of those aircraft was not reporting an accurate position then functions like FAROA would be turned off on all 100 aircraft. This does not seem like the best alternative. In this example, it would be better if the 99 aircraft with sufficiently good position accuracy continued to provide the FAROA function, with FAROA showing the position of the other 98 aircraft which were reporting good positional accuracy. It would only be necessary to turn off FAROA on the one aircraft that did not have accurate position information. This would be analogous to present day TCAS systems which continue to operate even though there may be an aircraft in the vicinity with a failed transponder. The TCAS on all the aircraft with functioning transponders continue to work; TCAS is only failed on the aircraft with the failed transponder. By: ACSS
February , 2008 The emphasis of the NPRM and also the NextGen future concept seems to be on specifying enhanced technology and performance capabilities for the future aircraft fleet. It is doubtful that simply replacing Comm/ Nav/ Surveillance capabilities aboard aircraft and in corresponding ATC systems with enhanced performance will accomplish the ambitious goals for increased traffic capacity, efficiency, and system growth without substantial improvements in ground system automation. The NPRM only addresses traditional surveillance applications for ADS-B Out and associated performance requirements. Expanding NAS system capacity is likely to require major changes in ATM system automation functionality and to requirements for air-ground data communication which are scarcely addressed in this NPRM. In addition, the position performance requirements for ADS-B surveillance specified in this NPRM are different from the performance requirements for navigation within the NAS. Position performance requirements for ADS-B are being developed without recognition of existing navigation capabilities. Requirements for navigation and surveillance need to be derived in a coordinated, not isolated, process that will not unnecessarily drive up cost. By: Daniel Mooney
February 25, 2008 DAL supports preferential, not exclusionary airspace, for aircraft equipped with ADS-B. Even though operators may want to equip, there could be delay in parts availability due to the high demand, forcing airlines to operate non-ADS-B capable. Airlines should not be performance penalized for this. Conversely, if an operator has equipped, they should be able to take part in a benefit, if available. By: Delta
February 29, 2008 Comments of the Department of Defense Multilateration is less costly than equipping for ADS-B since it requires no addition or modification to the aircraft and much less costly than a traditional radar. Several international civil aviation authorities are already replacing secondary radar with multilateration in both wide and terminal serveillance areas. DoD would like to see justification for statements used to support this analysis. By: Gerald Pease
March 2, 2008 FedEx requests that the FAA reconsider the ADS-B Out mandate until ADS-B Out is evaluated with the ADS-B Out ground infrastructure scheduled for 2013. FedEx requests that the FAA provide financial incentives for the airline industry to accelerate the equipage of a number of aircraft with ADS-B Out and evaluate the system soon after 2013. A fully integrated evaluation will help the industry identify the benefits of ADS-B Out and evaluate the latency of equipment available for ADS-B Out. By: FedEx Express
September 4, 2007 Comments of the International Air Transport Association Where justified by operational and business cases, air traffic control using ground radar surveillance should migrate towards ADS-B (OUT). In airspace where ADS-B OUT is declared operational, associated radar installations should be decommissioned as soon as operationally feasible and the resulting maintenance and operational savings passed on to airspace users. By: IATA
February , 2008 Comments of National Air Carrier Association We are concerned that the agency’s 2020 timeframe for implementation of ADS-B Out technology may be too aggressive. While we share the concerns about moving expeditiously to address the growing capacity and efficiency needs of the NAS, we are concerned that this timeframe must take into account the overall economic condition in which our carriers are operating. At a minimum, the agency believes that the total costs for complying with this rule are $1.27 billion, and the industry will begin incurring these costs as early as 2012. This is a significant sum for an industry that is struggling to obtain some level of profitability as fuel costs continue to rise to record levels. For a number of our carriers, there will be a need to analyze the costs for retrofitting their current fleet of aircraft with the proposed ADS-B Out technology, or await the acquisition of newer aircraft and equip those aircraft with the proposed technology. Our carriers’ timeframes for fleet modernization are largely affected by the timelines of the airframe manufacturers. For instance, if the delivery date of a new aircraft is greatly delayed, this, in turn, affects our carriers’ abilities to modernize. This will significantly affect the decision-making process in moving forward with ADS-B Out deployment. We would respectfully urge the FAA to consider more flexibility for carriers in making the transition to ADS-B Out beyond the proposed 2020 timeframe. Counsel: Edward Faberman, 202-719-7420, epfaberman@acaa1.com for ACAA and Thomas Zoeller, 703-358-8065, tzoeller@naca.cc for NACA
March 3, 2008 Comments of the National Business Aviation Association NBAA believes the FAA should develop a tool for operators to assess the benefits of both early equipage and when full equipage is required by the mandate. This tool would allow an operator to evaluate early equipage in the context of existing equipage. Assuming operators have a long lead time to equip their aircraft, they would be able to examine various equipage strategies. This approach could be tailored to an operator’s specific environment and needs, taking local constraints into account. Typically, in a mandate situation, the only additional cost for early equipage is the cost of money. The decision tool would be similar in form and function to the European Model for Strategic ATM Investment Analysis. The EMOSIA is generic to cover any change in the air traffic management environment. The ADS–B tool would be specific to ADS–B equipage, but should still provide targeted input to an array of stakeholders and use a full scope of possible cost and benefits to arrive at a net present value of different levels of ADS–B equipage. By: Ed Bolen
February 29, 2008 Comments of United Air Lines | Word The compliance date for this NPRM for operations above FL240 should be moved up to 2015. The net present value of costs and benefits to operators would increase by over $215 Million with a 2015 compliance date. This NPRM should include a Part 25 requirement for new aircraft to be compliant with ADS-B Out, meeting the requirements of TSO-C166A by 2011. The performance requirements specified in this NPRM should be adjusted. The highest required NACp should be 8. The rule should be amended at a later date if a business case can be established for applications requiring a NACp of 9. If a valid requirement is established for a NACp of 9, the rule should not implement the requirement for a NACp of 9 until the Department of Defense can provide the FAA a commitment that the minimum number of GPS satellites will be 27 plus adequate spares. We prefer a commitment of 30 plus spares. By: United, Joe Burns, 303-780-5178, joe.burns@united.com
March 3, 2008 Comments of the Aircraft Electronics Association Because the FAA has established this revolutionary change in basic ADS-B performance requirements, there isn’t any equipment that currently meets the Minimum Performance Standard for light general aviation aircraft. The FAA’s timeline of January 1, 2020, is a mere 12 years away. Assuming five years to ramp up full production of ADS-B equipment, that leaves only seven years to equip the entire general aviation fleet. This is not realistic. A better estimate of completion would be 2025. By: AEA, Richard Peri
March 3, 2008 Comments of Aircraft Owners and Pilots Association The ADS-B proposal is a good starting point for deliberation on the implementation of this cornerstone for NextGen. However, the proposal is not acceptable in its current form. The FAA must commit to working with the aviation community to analyze the comments, concerns and recommendations submitted and, where appropriate, conduct technical research and develop a supplemental notice of proposed rulemaking. By: AOPA, Andrew Cebula
February 27, 2008 Comments of Defense Concept Associates ADS-B is the key element of Free Flight as well as that of the proposed NextGen ATC system. With the ground environment in place, it can replace the transponder on domestic aircraft. With slight modification and the addition of a battery and a G-switch, it can also replace the ELT. A UAT in "crash mode" could transmit position for a month rather than hours with the same size battery, immediately alerting any UAT receiver and MFD within range. Most aircraft would be equipped with dual antennas, giving a higher probability of reception. These capabilities have been widely recognized and promoted by both G/A and FAA personnel without response from FAA management. There is no mention of either of these functions in the NPRM discussion. Failure to proceed with those applications is mystifying and has no logical defense. The decision to adopt two ADS-B links, 1090ES and UAT, was a serious error. Given that other nations, such as Australia, have seen fit to standardize on 1090ES, the US nevertheless has a unique aviation system with needs that should always be considered first by our government. When the decision was made to develop ADS-B, some wise heads in the FAA told Mitre Corp. to take a clean sheet of paper and come up with a system that would serve all segments of aviation. This became the UAT. The radar lobby responded with their usual, " But I can do everything with Mode S." However, it is not difficult to look behind the closed doors at FAA in those early days and see a realization that, if G/A continues to grow, and the forecast traffic is achieved or even exceeded, 1090 MHz will not cut it. The frequency already has occasional interference problems with ATCRBS Modes A, C and S, TCAS, and all of the military modes including IFF using it. When Capstone needed a system ASAP, UAT was the logical choice. RTCA SC-186/WG-3 was still arguing over how they were going to cram all of that precision data into 128 bits. (They never did.) UPS AT, Inc. (now Garmin AT) made a producible and practical product out of Mitre's thoughtfiil design and Capstone has been an unqualified success. By: Tom Teetor
March 3, 2008 Comments of Experimental Aircraft Association EAA does not feel that this NPRM, which proposes wholesale mandatory ADS-B Out equipage of the recreational and general aviation aircraft fleet, accomplishes any of the safety or operational benefits that might otherwise be derived. EAA maintains that this proposal, as written, contains all of the cost and complexity penalties of ADS-B with none of the potential benefits that could be offered to the recreational and general aviation operators. EAA encourages the FAA to examine more thoroughly the concept of developing differing MOPS for VFR operations outside of Class A and B airspace so that aircraft operating outside of these high density areas in VFR conditions could carry ADS-B equipment of a lower transmitting power and cost while ensuring adequate levels of surveillance and separation. By: EAA, Douglas Macnair
March 3, 2008 Comments of Helicopter Association International HAI’s actions clearly indicate that we support the concept of ADS-B as the cornerstone of the NextGen. We are convinced that it offers new and exciting capabilities that will increase operational efficiency and enhance safety in the helicopter industry and throughout aviation. However, at the same time, we encourage the FAA to continue working closely with, and listening to industry as we learn more from the first phases of the system roll-out in the Gulf, Alaska, and other locations. It must be remembered that this proposed rulemaking is not a final step but rather one of many “first steps” in what will be a long and complex implementation process. By: HAI, Matthew Zuccaro
March 3, 2008 We agree wholeheanedly with tlie comments submitted by Dayjet as being in the best interests of advancement of the specifications for the future of the Next Generation System, in particular, ADS-B. By: Andrew Locke
March 4, 2008 Comments of the National Air Transportation Association A clear presentation of the path to be followed by both the FAA and industry is required to achieve the benefits of ADS-B. 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. The impact to small businesses, whether they are in the equipment manufacturing, installation/maintenance or operational sectors of the industry, must be accurately addressed by the FAA. The vast majority of those impacted by the proposed implementation of ADS-B technologies will be small business entities and individual general aviation operators. By: NATA, Eric Byer
March 3, 2008 Comments of the Regional Airline Association The chief beneficiary of simply the ADS-B Out proposal, is the FAA. The Regulatory Evaluation states that the FAA will benefit from a savings of approximately 3 billion dollars since it no longer has to equip the ground infrastructure with secondary RADAR and secondary navigation systems (the primary ILS will become the backup or secondary system to ADS-B Out). In order to convert to a satellite based navigation system from the present day ground based navigation system, the primary cost of equipment installation and maintenance shifts from the FAA ground based equipment to the aircraft operators. One of the goals of this proposal was to “incentivize” certain segments of industry to encourage retrofit in advance of the proposed compliance date of 2020. Considering the cost of compliance however this will not occur until individual operators have a realistic cost benefit analysis to justify retrofit/forward fit expenditures. The regional airline operators in particular need a more realistic cost benefit analysis if we intend to seek financial incentives from other government entities, particularly if DOT/FAA policy regarding airport rates and charges is amended and regional aircraft are forced out of the airports where ADS-B would provide the greatest benefit. By: RAA, David Lotterer
March 4, 2008 Based on our operating history we believe the implementation of ADS-B IN is as important as ADS-OUT and also need RNP to move traffic away from the congested Class B/C airspace that the current proposal addresses. We believe the demonstration to those non OEP 35 airports will carry greater significance to a larger number of users and speed adaptation. There is overlapping, duplicative, and potentially conflicting regulation related to the current 20-25 year implementation of Mode S as all SATSair airplanes have that capability. A clear program to emphasize the benefits to the larger number of small airplanes will help with the network implementation in our opinion. By: Steve Hanvey, 864-232-9566, steve.hanvey@satsair.com
March 3, 2008 Comments of the General Aviation Manufacturers Association GAMA remains concerned about the practicality of meeting not only the rulemaking schedule, but also the overall program schedule. It is critical that the FAA avoid letting the rulemaking schedule take priority over publishing a fully vetted rule that meets both the needs of the FAA and the aviation community. It is also critical that the FAA ensure that the ADS-B program progress quickly to address key decisions related to future ADS-B applications. The final rule should recognize ADS-B In – with a robust definition – as a means through which the FAA will encourage voluntary equipage. By: GAMA, Jens Hennig
March 3, 2008 The scope of the document is unclear. The title, the summary (paragraph III page 56951) and the considerations on the Paperwork Reduction Act (paragraph IX page 56963) imply that the scope is limited to ADS-B Out equipage requirement. However the NPRM contains multiple references to future ADS-B In applications deemed to be the real NextGen project requisite, without setting a clear and phased implementation schedule for each possible application. No aircraft has been certified to the proposed standards. There is a need identified for a unique concurrent program of system demonstrations, in-service evaluations and compliance, and R&D to develop advanced standards and build confidence and benefits for further development. It is important to recognize this need for demonstration projects, and take advantage now of the time available to carry out those projects in a collaborative government-industry effort. If the projects are not planned and initiated soon, this time will be lost. FAA should collaborate with industry to determine by 2010 which non-ADS-B avionics can be replaced by ADS-B equipage. By: Airbus, Philippe de Gouttes, 33-05-61-93-27-91, philippe.de-gouttes@airbus.com
March 3, 2008 Comments of the United States Parachute Association While there are obvious overall benefits to an ATC system that utilizes ADS-B, not all operators will derive the same benefit. A jump operator flying above 10,000 feet msl (as most do) with ADS-B would not see the enroute efficiency gains touted by the NPRM. However, the cockpit display of nearby traffic would seem to be an enhancement in safety. Obviously, the requirement to be equipped with ADS-B would impose a negative economic impact on all jump operators. The proposal estimates that the average “GA” aircraft (presumably piston) could incur an equipage cost ranging from $6,578 to $22,283. A turboprop aircraft would incur a cost ranging from $12,906 to over $486,000. The lower end of each range imposes a tremendous burden on the operator; the upper end puts the operator out of business. It seems that the FAA ADS-B proposal will move the infrastructure cost from the ground to the cockpit. By: USPA, Randy Ottinger, 540-604-9740
March 21, 2008 Re: DOT Memo Showing Comments of Boeing Boeing contends that ADS–B can be implemented sooner (before 2020) by using a two-phased approach that makes use of existing equipment early. Specifically, Boeing states that the first phase should be limited to ADS–B Out and the performance requirements should be reduced to those required for ADS–B Out. Once this is accomplished, the FAA can focus on the development of ADS–B In applications and their performance requirements. The second phase would include an ADS–B In mandate when the standards are complete. Boeing and the FAA discussed WAAS in relation to ADS–B. In response to a discussion, the FAA clarified that the NPRM does not specify WAAS; it specifies performance requirements. By: DOT |
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