FAA ADS-B NPRM needs to be drastically changed

If you thought that the user fee issue was important, this proposal is far more onerous to the GA community.

You can access the 100 page NPRM from this AOPA website:

http://www.avweb.com/avwebflash/news/ADSB_PilotRequirements_2020_196268-1.html

This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I can determine from available information will be costly (as high as ~$18,000 per aircraft) just to transmit position info.

This does NOT get you free weather, free traffic info or other data transmitted by the ADS system.

It will require ADS-B Out equipage to fly above 10,000 feet MSL, into Class C airspace, by all aircraft at airports within current Class B Mode C rings (30 NM), etc.

My analysis shows ZERO to INSIGNIFICANT benefit to most GA users but potentially onerously high costs. My current draft response to this NPRM is at the link below. It is a Word document and is still very draft. I will be updating it as I more fully develop it.

http://tinyurl.com/2wem8j

This NPRM needs massive and overwhelming GA pilot community input to fight it. Details are in the NPRM and we must also ensure that AOPA, EAA , etc are on board.

Previous AOPA statements that 75% of GA pilots are in favor of ADS-B if they get free weather fail to prperly cover the costs to the pilot for avionics. Once you read the NPRM and my review, an objectively worded poll would probably show less than 5% of GA pilots willing to equip with all the ADS-B avionics needed to get free weather.

More to follow soon.

Ron Lee

Cost predictions?

Ron Lee said:

This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I can determine from available information will be costly (as high as ~$18,000 per aircraft) just to transmit position info.

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How can you accurately predict the cost of a piece of avionics gear in the year 2020?

Doubtful it will cost 18K

I think that all we have to do is update our transponder:

Garmin Embraces ADS-B With New Capabilities for Transponders

OSHKOSH, Wis./July 24, 2007 ? Garmin International Inc., a unit of Garmin Ltd. (Nasdaq: GRMN), is continuing to advance Automatic Dependent Surveillance-Broadcast (ADS-B) avionics in the general aviation market segment by enabling the popular GTX 330 and GTX 33 transponders with 1090 MHz Extended Squitter (ES) transmission capabilities. The 1090 MHz ES will be available as an optional upgrade for GTX 330 and GTX 33 transponders.

?Providing a 1090 MHz ES to the general aviation market will increase situational awareness and safety of flight once the ADS-B system is fully implemented,? said Gary Kelley, Garmin?s vice president of marketing. ?ADS-B technology is a critical step toward realizing the FAA?s vision of NextGen, and our leading-edge ADS-B products are a building block for the future.?

The addition of 1090 MHz ES to Garmin?s Mode S transponders will allow general aviation aircraft to automatically transmit position, velocity and heading information. This frequent and highly accurate aircraft state information will provide superior surveillance capability for air traffic control, which is presently dependent upon aircraft position information derived from ground radar interrogation that has a slower update rate. The 1090 MHz ES builds upon the existing system by transmitting pertinent aircraft information independent of being interrogated.

The 1090 MHz ES upgrade preserves all of the existing GTX 330 and GTX 33 features. This includes Mode S TIS datalink reception and traffic, which are displayed in vivid color on the GNS 430W, GNS 530W and GMX 200 displays.

The 1090 MHz ES capability is expected to be available in the fourth quarter of 2007. Further details, product specifications and pricing will be forthcoming.

Won't it need GPS data?

The Garmin upgrade would need GPS data. You cannot transmit what you don't know. I can't imagine FAA letting us use our 496's to supply the GPS data, so add the cost of whatever the then-equivalent of a TSO'd 430 would be.

Ron Lee said:

...
This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I can determine from available information will be costly (as high as ~$18,000 per aircraft) just to transmit position info.

This does NOT get you free weather, free traffic info or other data transmitted by the ADS system.

It will require ADS-B Out equipage to fly above 10,000 feet MSL, into Class C airspace, by all aircraft at airports within current Class B Mode C rings (30 NM), etc.

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Whoa there chicken little...

$18,000? How did you arrive at this number? Starting from scratch maybe if you ware talking about a NORDO aircraft with no electrical system. I'm guessing that you would have also been against the transponder in class C and above airspace back in the '70s also? By 2020 I predict the cost to to equip for ADSB-Out will be the same as the cost of a today's Mode C transponder. Not that I'm in full agreement with the FAA's plans, but I think more information is required before we go screaming that the sky is falling.

William, have you read the NPRM?

I have and that is a figure that they used (upper end of range). Before you folks start chopping holes at my point, realize that I have read the NPRM. I am always open for corrections but as of yet no one has provided any.

Ok, let's assume that the unit is only $9000 or $7000. The point remains that it offers ZERO improvement over a Mode C transponder for anything that I need to do. And probably most people on this forum.

You are free to ignore this issue, but if it passes and you have to shell out thousands for a box that offers nada, just remember that I am providing adequate warning and...in MNSHO... objective and factual analysis.

Adding a GPS to a transponder doesn't need to be nearly as expensive as a 430/480/530. I think all ADS-B needs is position, direction, and maybe speed. Parts for that are less than $50.

I fly out of Renton, WA (KRNT). There is no radar coverage in the vicinity of the runway. There's a hill between us and the Sea-Tac approach radar. On top of that, we have an adjacent seaplane base and Boeing Field is just over the hill. Lots of traffic and not much radar coverage. ADS-B could possibly have prevented the mid-air here a while back. I'd call that a benefit.

Instead of putting effort into stalling ADS-B, I'd rather the AOPA and EAA put effort into bringing down the cost of the equipment and encouraging the FAA to provide wx info as a carrot. Weather data is free, and the equipment doesn't need to cost any more than GTX-327 transponder.

Davepar said:

Adding a GPS to a transponder doesn't need to be nearly as expensive as a 430/480/530. I think all ADS-B needs is position, direction, and maybe speed. Parts for that are less than $50......the equipment doesn't need to cost any more than GTX-327 transponder.

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Well, I'd agree with you that it doesn't need to cost any more than that, but will it? I'd bet that that all XPDRs are going to TSOed, and that means it will cost a lot more than what it costs to make. ADS-B type technology has been around a LONG time (e.g., APRS) and the parts necessary to make it work are not expensive. However, consider what TSOed autopilots cost versus the TruTrak and Trio units - about a factor of 3x to 5x.

Questions to be answered (although I admit I have not read the ANPRM):
* Will Mode C be required once you have ADS-B installed? Can you remove Mode C?
* How will the feds deal with WX data over ADS-B? Recently the feds have tried to limit free redistribution of data gathered by the feds (e.g., NOAA data).
* Will the FAA harmonize requirements with other countries so that you don't have to carry ADS-B and Mode C when flying outside the US?

TODR

the_other_dougreeves said:

Well, I'd agree with you that it doesn't need to cost any more than that, but will it? I'd bet that that all XPDRs are going to TSOed, and that means it will cost a lot more than what it costs to make. ADS-B type technology has been around a LONG time (e.g., APRS) and the parts necessary to make it work are not expensive. However, consider what TSOed autopilots cost versus the TruTrak and Trio units - about a factor of 3x to 5x.

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I always compare the cost of an non-certified/non-TSO'd device with that of the certified equivalent. I have to say, that comparison is not always economically favorable to the experimental product.

In 2004 I had an S-Tec 30 autopilot installed in my Cardinal for about $9,000. The equivalent Tru-Trak would have been about $4000 before installed. Not quite 3x as much.

the_other_dougreeves said:

Questions to be answered (although I admit I have not read the ANPRM):
* Will Mode C be required once you have ADS-B installed? Can you remove Mode C?

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I think it unlikely you will see an ADS-B out transponder, that is not Mode C (and possibly S) capable.

the_other_dougreeves said:

* How will the feds deal with WX data over ADS-B? Recently the feds have tried to limit free redistribution of data gathered by the feds (e.g., NOAA data).

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I don't think this was the FAA. This was the misguided attempt by ex Senator Rick Santorum (R-PA) who was in bed with Accuweather and WSI to protect their vested interest.

the_other_dougreeves said:

* Will the FAA harmonize requirements with other countries so that you don't have to carry ADS-B and Mode C when flying outside the US?

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Same as answer to question 1. While some countries may have ADS-B, I think Mode C will be the default building block for all and will continue to be a requirement outside of ADS-B areas. I don't think removing Mode C (or S) from an ADS-B transponder will save an appreciable amount on it's cost.

Important point to understand

This NPRM only covers ADS-B Out (the transmission of your position and velocity information plus ID...maybe other items). It does not get you free weather, traffic info, METARS, TAFS, NOTAMS, TFRs. So you still need the capability to receive TIS-B and FIS-B info and display it if you want it.

hevansrv7a said:

The Garmin upgrade would need GPS data. You cannot transmit what you don't know. I can't imagine FAA letting us use our 496's to supply the GPS data, so add the cost of whatever the then-equivalent of a TSO'd 430 would be.

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The NPRM sidesteps the issue of whether you'll be required to use a certified GPS, it simply says that WAAS would be required to meet ADS-B Out accuracy and integrity requirements.

However, who would believe that the FAA will accept the outputs of a non-TSOd WAAS GPS as good enough to separate airplanes from one another? So tack on cost of certified WAAS-enabled version of your favorite GPS.

the_other_dougreeves said:

Will Mode C be required once you have ADS-B installed? Can you remove Mode C?

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Check into the NPRM section that deals with backup surveillance. The FAA plans to keep enough secondary (i.e., Mode C/S) radars in place to cover the busiest airports and airspace above 18,000' MSL. If you're going to operate in those Class A/B/C areas and choose to equip with UAT to get all those great FIS-B products, you'll still have to carry a Mode C transponder to operate if GPS is denied, disrupted or otherwise unavailable.

Dave

I am gonna have a big red switch marked "stealth mode" that shuts all that stuff off!



Seriously, I doubt that the value added benefits extended to the GA community will be worth the cost outlay. Just my skepticism in action. I am a true "wait and see" Yankee.

Dave, I like the avatar!

CJ

Captain_John said:

Seriously, I doubt that the value added benefits extended to the GA community will be worth the cost outlay. Just my skepticism in action. I am a true "wait and see" Yankee.

Dave, I like the avatar!

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Thanks John!

I worked on the ADS-B program for a few years. Believe it or not, in times past the FAA really did seem interested in providing that 'carrot' that Dave P mentioned, and in working with industry to bring avionics costs down. But the current FAA leadership seems to be focused on cost-benefit analyses and the financial bottom line - which probably means that private GA gets the fuzzy end of the lollipop.

And since this is the same group that brought us the privatized FSS system, I'm afraid we're in for a lot of pain

Dave

Suggestion to become educated on ADS-B

Read the tinyurl link I listed in the first post. Although I have more work to do to finish it, it is probably the best current summary of problems as they relate to GA. Once I get the cost-benefit document I will likely show that it is flawed. I have already shown that there is zero to insignificant benefit to the GA community.

Then you should read the NPRM. Read any other websites you wish on ADS-B.

I am open to being shown where my analysis is wrong. No one has done that yet. I suspect that many don't care or don't want to make the effort to get educated. But this will cost you dearly if the FAA gets their way.

The FAA is the only clear winner in this scheme.

I will prefix this, by saying that I have not read the NPRM. But I will say, as a future air traffic controller, we need something better than mode C transponders. In densely populated areas, having ADS-b on board all aircraft with the ability for them to talk to each other and display traffic in an TCAS-like setup (Not just mode S) is a phenominal improvement in safety. I have no idea how many close calls i've had, but I know it's been way more than I've noticed...

Geez folks, read the NPRM

Read my response. This NPRM does not get you traffic info onboard. It gets the GA pilot NOTHING. No weather. No TFRs. No NOTAMs. No TAFS. No traffic.

Nothing.

And nothing suggests that it is any better than Mode C in the real world.

Here is the link to the Federal Register version of the NPRM and comment submittal:

http://tinyurl.com/2raefd

osxuser said:

I will prefix this, by saying that I have not read the NPRM. But I will say, as a future air traffic controller, we need something better than mode C transponders. In densely populated areas, having ADS-b on board all aircraft with the ability for them to talk to each other and display traffic in an TCAS-like setup (Not just mode S) is a phenominal improvement in safety. I have no idea how many close calls i've had, but I know it's been way more than I've noticed...

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Stephen,

I'll say it again...
These things still do not cover all the aircraft out there w/o electrical systems. Is the FAA proposing grounding all those J-3's, T-Crafts, Champs, etc?

Heck, I know of one local Sonix builder who didn't install a transponder because he lives outside of the Mode-C veil and doesn't plan on flying any where near it.

What do all these wiz bang things do for them? Nothing, just like Ron states they will do (or not do) for the rest of us.

Let's turn this thread around...

What is the best technology/process/solution that we in GA can come up with to solve the FAA's problem?

N941WR said:

Stephen,

I'll say it again...
These things still do not cover all the aircraft out there w/o electrical systems. Is the FAA proposing grounding all those J-3's, T-Crafts, Champs, etc?

Heck, I know of one local Sonix builder who didn't install a transponder because he lives outside of the Mode-C veil and doesn't plan on flying any where near it.

What do all these wiz bang things do for them? Nothing, just like Ron states they will do (or not do) for the rest of us.

Let's turn this thread around...

What is the best technology/process/solution that we in GA can come up with to solve the FAA's problem?

Click to expand...

I am perhaps naive enough to consider that the exceptions mentioned in the NPRM (Which is read the highlights of now) probably apply in the same way they currently apply to the J3's that fly in controlled airspace and in the mode C veil.... contact the controlling agency first!

Also, although ADS-B in is all that is REQUIRED by the FAA, in the same way that Mode-S just happens to provide TIS, so will the ADS-b solutions available to us from the avionics manufacturers... the reason? Because we as CONSUMERS will demand it. Heck you can hook your GTX330 to a cheap 396 GPS and get traffic. Have a little faith in Garmin and the others...

Of course I'm in Socal, so to me this looks like the same requirements as Mode C right now, but I have to read further in the NPRM to figure out where ADS-b out is actually required...