ADS-B. RA-Aus Official Response

RECREATIONAL AVIATION AUSTRALIA

RESPONSE to the

Joint Consultation Paper

Transition to Satellite Technology for Navigation and Surveillance.

October 2007.

Executive Summary.

Recreational Aviation Australia (RA-Aus) believes that the Joint Consultation Paper (JCP) proposal has been formulated to justify extended surveillance of aircraft without verifiable and quantifiable safety related evidence and that the proposal is based solely on the economic benefits to Air Services Australia (ASA) and Regular Public Transport (RPT) Operators. Veiled threats of withdrawal of inducements and cross industry funding if a sector delays or does not accept the JCP recommendation does not engender a sense of consultation, but rather one of bribery and coercion.

The JCP justification that the economic benefits for ASA and claimed increases in RPT efficiency are justification enough to allow adverse economic impact, as well as adverse safety outcomes, for all other private airspace users is not supported. We also contend that the Cost Benefit Analysis provided is not rigorous or based on accurate current data, nor are the assumptions made accurate, in respect to the majority of the private aircraft fleet, and in particular the Recreational Aircraft fleet.

RA-Aus has a long standing board policy to oppose any mandatory introduction of ADS-B for aircraft operating in CTAF ( R ), class G or E airspace in line with accepted practice in the US NAS airspace, unless there is a clear-cut unequivocal safety case that concludes that the US and ICAO in their collective wisdom have it wrong. The JCP falls short of providing a compelling safety case to justify the introduction of ADS-B (LAP).

RA-Aus is unable to accept the proposal in its current form nor the suggested timing of the mandatory introduction of ADS-B (LAP).

RA-Aus Response to JCP Key Change Proposals

Proposed timing of transition to satellite technology for navigation and surveillance.

Not acceptable under any circumstance.

Requirements for carriage and use of ADS-B avionics from mid 2012

Not acceptable under any circumstance.

Requirements for carriage and use of ADS-B avionic from mid 2014

Not acceptable under any circumstance.

Use of funds that would otherwise be spent on navaids and enroute radars to provide cross industry funding for fitment of ADS-B and GNSS avionics in aircraft less than 5,700kg

Not acceptable under any circumstance.

RA-Aus Position

The JCP and supporting documentation Cost Benefit Analysis (CBA) have been examined by RA-Aus in preparation for our response. The CBA paints a rather rosy picture of the benefits for ASA while disregarding the true negative economic impacts on Australian Aviation if ADS-B were to be mandated for the whole of the Australian private fleet. We are deeply concerned at the attempt to oversell the benefits of navigation with the added impost of surveillance and thereby justifying both under the CBA by stealth. Statements such as: “Improved operational efficiency for RPT operations….greater availability of optimal flight levels…. due to accurate aircraft position information for ATC and pilots” benefits that are currently available from Ground Based Radars (GBR) and transponders. It appears that ASA chooses not to invest in their business and wish to shift the investment burden on to all airspace users. RA-Aus have no objection to the implementation of ADS-B (UAP) in class A airspace where the majority of the so called benefits of optimal Flight Levels accrue.

The CBA draws comparisons from non-comparable ATM systems to Australia’s primarily Class G nature and we also note that both the JCP and the CBA consistently refer to the benefits of safety by combining ADS-B (Out and In) in every context when ADS-B (Out) is only being subsidised which offers no protection to the majority of lower airspace users such as Recreational/GA pilot unless fitted with ADS-B (In). Therefore any claims of a safety based case arguments for the GA/Recreational fleet in the JCP/CBA are disingenuous at best.

If implemented, the JCP proposals would force higher cost impost on a sector of the industry that can least afford it. Unilateral mandating of ADS-B could have the effect of encouraging a new and adverse underground culture. Higher entry and operating costs (new aircraft fitment and ongoing maintenance) will have an adverse effect on the growth of recreational/GA operations. ADS-B will effectively create a controlled Class ‘G ‘contrary to a previous Ministerial Airspace Policy Statement stipulating ‘G’ as the default airspace.

The JCP canvassed option of cost free ADS-B fitment, without allowing for costs involved in ongoing maintenance support, will not encourage new aircraft ownership and will stifle growth rates in all sectors of aviation. Contradictory comments on the life of ADS-B units ranging from 15 to 25 years do little to engender confidence in the data presented.

No guarantees have been given that once ADS-B is mandated in class G airspace it will not be used as a vehicle to expand ASA airways charges or unnecessarily restrict operations.

The JCP data and assumptions are not based on facts. Current data out of the US (Aviation Week & Space Technology, 8^th Oct 2007 Pg 40) claims that costs for GA aircraft could be as high as US$17,000.00 and cites avionics capacity constraints as one of the major limiting factors. It is a well known fact that the Australia suffers a major shortage of avionics LAMES. Indicative costing presented in the JCP are far of the mark and would increase dramatically due to supply and demand pressures if mandatory fitment were to be introduced. In any case, the FAA is only proposing fitment to commercial aircraft and not until 2020.

For most Recreational and GA pilots, ADS-B (Out) only, offers no foreseeable safety benefit in the mandatory fitment to a radio equipped aircraft. Even if ADS-B (In) is provided it could lead to an over reliance on this new technology and has the potential to generate a culture of ‘video screen VFR’ which will in turn create the very same accident that it was installed to prevent.

We note with interest that the military have withdrawn from being compliant within the proposed ASA time frame and have set their target for 2020 in line with the US. It would be farcical to insist that the civilian fleet have mandated fitment without including the military fleet.

Apparently ASA have already reached the foregone conclusion that they will introduce ADS-B regardless of the wishes of the majority of aircraft owners in Australia. ASA’s blatant disregard for ministerial directive “Air Services Act 1995 Section 16 Direction No.4 of 2004” would seem to be the motivating factor for attempting to force ADS-B on the private aviation sector in Australia, when in the US ADS-B will only be mandated for Commercial aircraft, operating in upper airspaces. Statements in the JCP alluding to the fact that ADS-B training and education packages are already being prepared makes a mockery of the consultation process.

JCP/CBA Shortcomings

What little safety justification is presented in the JCP/CBA draws a very long bow. It assumes that VFR CFIT accidents will be reduced. Any seasoned pilot would agree that the way of reducing VFR CFIT accidents would not be by focussing attention inside the cockpit at the expense of external visual cues.

Claims of efficient preservation of life through using ADS-B for accident location overlooks an already introduced mandate for the introduction of 406MHz GPS locator beacon by Feb 2009, and already deployed by a growing number of Recreational and GA pilots, at far lower cost than ADS-B. Many such leaps of deductive reasoning are evident in the paper and applied to excess; including that VFR flights into IFR conditions will be mitigated by ADS-B. In fact this technology may well encourage scud running and inadvertent entry into non VFR conditions.

Mid air collisions research demonstrates that risk increases with proximity to an airfield. ADS-B OUT does not mitigate this risk, only “see and avoid” is the most efficient method as even TCAS is unreliable in close proximity to circuit traffic. In the case of CTAFs the heightened sense of false confidence in technology, both radio and ADS-B is, in itself posing more risk than it does a mitigator. A non-radio equipped aircraft is virtually invisible in this sense, to others not practised in “see and avoid” principles.

The JCP claim that ADS-B will reduce Violations of Controlled Airspace (VCA) is also a rather large deductive leap as most VCA’s occur from penetration from Class G where there is no requirement below 5000’ to carry a radio or ADS-B (Out).

RA-Aus formally reject the figures quoted in the CBA with respect to non-VH registered aircraft in Table 4-6: Entire fleet numbers. Not only are these figures incomplete by not including the Hang Gliding Federation of Australia’s currently registered aircraft, but also age of the data is of great concern. Whilst it is true that most of the ‘traditional’ Australian registered aircraft numbers remain fairly constant, the same can not be said for the Non-VH registered area. This demonstrates the questionable integrity of the JCP/CBA data presented. Actual RA-Aus data since 2002 has documented an actual growth rate in excess of 10% per year to date, in the number of RA-Aus registered aircraft. RA-Aus Aircraft registrations, have recorded a 16% increase in CY 2006. For these reasons alone, we believe that the CBA analysis and integrity of the document is flawed, assuming only an arbitrary growth rate of 4% a year.

RA-Aus current projections using a conservative figure of 13% growth rate in aircraft registrations (not taking into consideration the current exponential swing) has projected aircraft numbers at 4706 for CY 2012 and the CY 2014 aircraft registrations are projected at 6009. The CBA cost analysis has been formulated on incorrect data and has also failed to correctly assess projected growth rates. Nor do the CBA figures take into account Hang Gliding Federation current and projected figures, further skewing the analysis towards the wrong side of the balance sheet.

Security and Boarder Protection

Linking ADS-B to National security has no real value unless tracking compliant aircraft. Only primary radar will identify a non-compliant or hostile aircraft. In the US the Department of Transportation's Inspector General Calvin L. Scovel III told Congress “that ADS-B had Potential Security Vulnerabilities, because ADS-B makes the position of aircraft in flight generally available, some are concerned about the possibility of introducing false targets into the system”. He also went on to say “A security assessment is needed to determine ADS-B risks and appropriate countermeasures. The FAA needs to continue to work with the intelligence community and the Departments of Defense and Homeland Security to ensure that concerns about ADS-B security are adequately addressed”. Therefore any claim that ADS-B has benefits for National security is premature. In fact, ADS-B has some potentially damaging vulnerabilities and shortcomings that could work against National Security.

Conclusion

The JCP has made a compelling case for the introduction of ADS-B based solely on the economic benefit of introduction for Air Services Australia (ASA). Introduction of ADS-B would relieve the economic burden for ASA of replacing existing ground based radars and shift the burden on an aviation sector already reeling from high costs and least equipped to absorb further cost imposts. The JCP has failed to make a clear cut safety based case for the introduction of ADS-B (LAP).

In the USA, the FAA is proposing fitment of ADS-B to commercial aircraft only, and in any case will not be mandatory until 2020. The FAA acknowledges that there are still major risks that will have a direct bearing on the cost, schedule, and expected benefits of ADS-B and has called for further consultation and studies.

The timelines and scope of the ADS-B (LAP) introduction in Australia as proposed in the JCP are patently not required for any other reason than to relieve ASA from a Ministerial directive they have failed to implement. The proposals and timelines outlined in the JCP are unrealistic, unachievable and an unnecessary economic burden on private aircraft owners with no apparent safety benefit.