EAA Critical of FAA's ADS-B Proposal
March 6, 2008 — EAA submitted its comments this week to a Notice of Proposed Rulemaking (NPRM) for the FAA's plan to implement Automatic Dependent Surveillance-Broadcast (ADS-B) as the central component of the Next Generation air traffic control system. While EAA has long supported efforts to modernize the way air traffic is monitored and controlled, it was highly critical of the FAA's plan as it was unveiled in the NPRM.
"Most of the benefits cited in this NPRM either do not apply to general aviation at all or are derived from technologies already being embraced and fielded by general aviation pilots and aircraft owners on their own, such as GPS and moving map technologies," wrote Doug Macnair, EAA vice president of government relations. "FAA did not consult with the general aviation industry in developing this implementation proposal, and it shows."
According to the NPRM, all aircraft operating in Class A, B, and C airspace, plus all airspace above 10,000 feet msl, would be required to install ADS-B datalink equipment, or ADSB Out, by 2020. This expensive equipment would transmit aircraft identification information as well as position, altitude, and speed.
A major benefit of NextGen cited by FAA would be to reduce airline delays and capacity constraints that are the norm today, especially at the 35 busiest airports known as Operational Evolution Partnership (OEP) airports. EAA suggests that ADS-B should therefore be tested on a limited basis with the air carriers to see if it works before requiring wholesale installation on GA aircraft.
EAA further contends that the equipment, as now priced, would be beyond the means of thousands of small aircraft owners and hinder GA. Similar equipment requirements over the past 30 years each had the same flaw: They kept many airplanes and pilots from flying because of time and expense involved.
"By failing to get GA's input and simply mandating wholesale installation of ADS-B Out for nearly 80 percent of the GA fleet, the FAA has unnecessarily turned the recreational and general aviation community against what could well be a very useful and helpful technology if properly and appropriately implemented," Macnair said. "Under this proposal the agency is dramatically shifting the costs of the NAS from FAA ownership and operation of ground-based ATC surveillance technologies to the individual aircraft owner to the tune of many billions of dollars.
"EAA is urging FAA to meet with the general aviation community before finalizing this rule."
EAA will continue to work to protect its members from unnecessary costly equipment requirements and ensure that as the NextGen system evolves that there are real benefits for general aviation and not just for the FAA air carriers.
Summarizing EAA's comments:
- EAA continues to maintain that a combination of ADS-B In and Out can provide significant benefits to certain segments of the general aviation community. However:
- 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 strongly urges the FAA to ensure that the limited exceptions to existing transponder and encoder requirements for aircraft that do not have electrical systems sufficiently robust to power such equipment be continued under any ADS-B or other future ATC surveillance scheme.
- EAA encourages the FAA to examine more thoroughly the concept of developing differing Minimum Operational Performance Standards (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.
- EAA encourages the FAA to better understand VFR operations in the western U.S., where VFR aircraft transition on a daily basis through mountain passes, many of which are at or above 10,000 feet msl. This simple act of safe flying would be their only exposure to the proposed mandated ADS-B equipment requirements. Passage of the 10,000-foot msl requirement could have a significant safety impact on those VFR only operations.