ok, I tried to hold off on posting this as it is probably not of general interest but this issue has me concerned. ADSB is a good idea but I fear bad management is hurting it and may significantly delay it.
July 13, 2014
Michael P. Huerta
Administrator
Federal Aviation Administration
800 Independence Avenue, S. W.
Washington, DC 20591
Administrator Huerta,
I am writing today to share my observations on ADS-B, arguably the single most transformative task you and your successors have undertaken. My vantage point is that of a GA pilot who routinely flies both certified and experimental aircraft and one that values safety.
One of the experimental aircraft I fly is equipped with ADS-B In and Out. The out function is accomplished using a TSO’d Mode S-ES transponder coupled with a non-certified GPS and pressure altitude source. Of course, this pressure altitude source is tested per FAR requirements every twenty four months. The increase in situational awareness that comes from a complete and accurate traffic picture is phenomenal and the FAA should be commended for conceiving of and implementing the ADS-B concept. If I were to guess, I would think a survey of the average GA pilot would show that over 50% of the traffic targets available on a three mile ring are never seen. In short, the availability of traffic in GA aircraft is a transformative lifesaving concept; if it is implemented.
I’ve just recently purchased a certified motor glider and have begun to examine my options for ADS-B In and Out. I am no expert on the technology and even less so on the minutia of the regulations surrounding the 2020 mandate or its implementation. Given this, I’ll speak in generalized terms and may, in some instances, completely miss on my facts. Even with this, I think the overall reason for this note will be clear.
As I understand my options today, I can install ADS-B out equipment if there is a STC for the installation or, per the October 10, 2012 guidance prepared by Alejandro Rodreguez and Chris Parfitt, I can seek field approval for TSO’d equipment which has an STC for another application provided I follow the exact wiring, functional testing and documentation processes depicted in that STC. In my case, I am working with a Motor Glider where there are no STC or STCs for similar aircraft.
The interesting part about the STC requirement for an ADS-B Out system is that I can install a TSO’d Mode S transponder and a TSO’d GPS position source based solely on a 337 (or a generalized STC like those provided by Garmin for their radio/gps nav/com units) provided all the manufacturer’s requirements are adhered to. It seems only when I connect the certified position information from the GPS source up to the transponder that an STC is required. I understand that these systems are new and need to be held to a higher standard but I believe there will be some unintended consequences of these decisions and that these consequences could be avoided without sacrificing ADSB integrity or functional verification.
Someone mentioned to me that, even if we start today and every GA owner was willing to pay the price, there are not enough avionic shop hours between now and 2020 to bring the fleet into compliance by 2020. I’m not sure if that is accurate but it does point to a fundamental flaw in the mandate concept. The current structure and implementation costs/complexity surrounding the mandate will, at a minimum, delay its implementation and possibly kill the mandate altogether. Once the whole GA fleet starts to feel the pain, you will see a ground swell revolt against a government mandate that will cost most GA owners $5,000 in hardware and likely several thousand dollars in installation costs. These owners will contact their representatives and all momentum will be lost.
It is 2014 and what I have described above is foreseeable and preventable. I believe it is in the public’s interest that all aircraft be equipped with ADS-B Out and that cost effective system options are available for the GA community to access ADS-B In in certified aircraft. It is absolutely silly that experimental aircraft are allowed to trump certified aircraft in this vital area of safety. Accomplishing GA moving to ADSB will require significant work on both equipment and regulatory compliance costs. This work will take strong leadership as I would think the entrenched interests are very strong. I can not imagine delegating this responsibility will do anything but provide a way to duck the issue and leave it for someone else’s watch.
Costs for, and impediments to, implementation in GA can be traced to two general areas, equipment and administrative. I’ve lumped installation in with administrative as compliance requirements drive a majority of the installation costs.
TSO’d transponder costs are well known. They are higher than non-TSO’d units of the exact same construction because of the compliance costs of producing TSO’d hardware and the associated liability for equipment installed in certified aircraft. The same can easily be said for TSO’d GPS sources. There is little difference between a $50 12 channel WAAS receiver puck off Amazon and a certified GPS source from a manufacturing cost standpoint and yet the TSO’d unit costs $2,500 plus the cost of a TSO’d antenna. These added costs do improve quality, reliability and traceability but at a price that will likely fuel the postponement or demise of implementing ADSB in GA.
From a hardware standpoint, I would think it would be in the best interest of the GA community and the general population if the FAA were to generate a class of equipment that had streamlined approval and a measure of liability protection (and any other steps that would reasonably reduce cost). This device class would be an integrated Mode S-ES transponder, pressure altitude encoder, acceptable GPS source and ADS-B In receiver. This device could easily be a sub $2,000 device provided the FAA worked in partnership with manufacturers to qualify the equipment. In this instance, I would even suggest a no cost certification facility staffed and funded by the FAA.
On the administrative side, these devices need to be installed under a 337. The need for an STC and, in most cases, a field approval will literally stop the implementation dead in its tracks. The FAA alone can not handle the burden of reviewing and issuing field approvals for all the necessary aircraft let alone STCs for every type certificate currently operating in the US. Further, the cost of compliance on the hardware manufacturer’s and installer’s sides are equally damming. If done correctly, there is absolutely no reason why the above described equipment installation could not be handled as simply as a currently replacing a Mode C transponder with a Mode S transponder.
Accomplishing ADSB implementation is going to require significant leadership. Relying on a mandate alone without addressing the fundamental methodology and costs by which GA can comply will fail. Regretfully, it is getting progressively harder to truly manage such projects and prevail over entrenched interests and yet that is exactly the type of leadership this project requires. That task falls on your shoulders thus the reason for this note.
Good Luck,
Bill Hart
