More on ADSB

I took my first trip to Oshkosh this year, absolutely amazing, but that is another story.

While there I went to a presentation by the FAA on ADSB. First I was surprised by the poor attendance at the presentation and I can offer no explanation why this would be so. Perhaps Americans are apathetic, perhaps they think 2020 is a long way away, or perhaps they don't understand the term "The devil is in the detail"

The FAA and other authorities are well into the roll out with contracts for ground stations signed and work progressing. The FAA asked for industry and pilot submissions and feedback and received over a 90 % NEGATIVE response. But as the roll out was so far advanced I personally got the distinct impression that this "consultation process" was purely only lip service so they could claim "We consulted with pilots and the industry" After the presentation I personally went up to the FAA presenter and talked to him privately. I asked him were there concerns about the extremely negative response. He told me "NO". He said there were 1271 negative and 101 positive submissions. He said they expected much more. Perhaps the American GA pilot fraternity may regret not responding more aggressively on this in the future. It could also be that, say an organization like the EAA with tens of thousands of members responded in the negative, and the FAA classed this as one negative response.

Now to the technical side of things. There are good and bad here. The "good" is this will not become compulsory until 2020 and like in Australia only the uplink (out) will become compulsory. It will only become compulsory above 10,000 ft and it will only apply to "high usage" airports listed in their document 41 CFR part 91

Now the bad. The compulsory (out) must be TSO'd (certified) and maintained by certificated technitions. It must be hard wired (with seal?) and must not be able to be turned off by the pilot. The current cost of available units by approved manufactures (Garmin being one) is US$10,000 PLUS instillation. Instillation alone is many thousands of dollars.

ADSB is to be considered a "primary" and it will also be compulsory to keep and maintain a "secondary" mode C transponder. New aircraft, or those wanting to fly in the ADSB airspace must fit and maintain both ADSB out and Mode C.

Also the current control "steps" will go and a wall will drop down from 10,000 feet to the surface with a radius of 30 miles. Here is some of that "devil in the detail" Those pilots who think they will be able to fly around the US at 1,000 to 5,000 ft and stay out of ADSB airspace by flying under the steps are in for a big shock. If you look at a US aviation chart and put a 30 mile radius around their "RPT" type airports you don't get much "free" airspace left, except in the desert, and the military have a big chunk of that.

Now for the "conspiracy people." Currently there is a big push in the US for "user fees" The Government wants to charge a $25 per flight user fee. This is being strongly resisted by the GA people and is currently held up in Congress and the Senate, but not defeated. President Bush has threatened a veto if some form of user fee on GA is not passed. With ADSB that can't be turned off their Airservices people will be able to not only charge a per flight fee but also a charge per mile fee. As the safety factor for pilots is the "IN" component, the conspiracy people may have a point here in that this is all about tax revenue and surveillance.

Everyone I spoke to including the FAA people privately acknowledge that the primary reason for ADSB is surveillance and income generation, and cost saving on new Radars.

The "conspiracy people" also believe (and this is something I never considered myself before) that it will allow the different US Government agencies to make extensive use of UAV's to fly all all over the US. For what purpose I am not sure.

I also saw ADSB "IN" working. You can currently buy ADSB IN and OUT for $20,000 However the manufactures said that the "IN" component will get very cheap due to competition and the fact that it doesn't have to be certified. It seems to me that if it has to be certified it becomes a license for the manufactures to print money. The massive extra amount they charge for a certified product seems to me, way out of proportion to the extra work of compliance.

We must be very vigilant here in Australia and be prepared to be very political. Once the Government installs a tax income stream it is very hard, if not impossible, to remove. If you don't believe this consider how hard it would be to get the State Governments to remove speed cameras where they are shown to have no safety benefit.

John McKeown

OPS. MANUAL UPDATE

Hi All,

All RA-Aus members will soon be getting a CD copy of the new Ops. and Technical Manual with the July Magazine. Included will be a "Bonus Section" of John Brandon's excellent Tutorials, an electronic version of AC43.13 "Aircraft Inspection, Repairs and Alterations" and AC90-89A "Amateur Built Aircraft and Ultralight Flight Testing Handbook, and a copy of CASA Visual Flight Rules.

The new Ops. Manual will become effective on August 1, 2008.

PLEASE, don't ring the office about questions straight away. Even if only 10 % of members ring in that is nearly 1000 inquiries and will totally overwhelm the office staff.

We, the board and office staff copped a lot of flack by a very small minority of members by going electronic here, but we have saved your organization tens of thousands of dollars that can be better spent elsewhere, and have given you a bonus section that would be cost prohibitive to send out in printed form. If you are a special case and don't have access to a computer you can request a printed copy of the manuals only. You won't get the bonus section in print form.

A special thanks needs to go to board member Lynn Jarvis from SA who voluntary did a lot of work on the bonus section.

John McK

Cold Morning Starts

We all know someone, particularly Jab drivers, who complain about their cold morning start problems. Well after coming across a book by F. Potts " A Guide to Bush Flying" he has a chapter about cold starts in Alaska.

We really have it so, so easy. In fact we have it so easy, we don't even have a problem.

Extracts from "A Guide to Bush Flying"

Section I: Equipment and Environment

Part IV, Chapter 12: Preheating Equipment and Methods

Engine Compartment

“Aviation fuel is distilled with a much lower vapor pressure than automobile fuel so that during the climb to altitude engine failure will not be experienced due to vapor lock. What this means from an operational point of view is that once temperatures get down to -9 degrees C, the engine will require preheating so the fuel can properly vaporize for ignition.” (Aircraft using mogas will experience vapor lock at a much higher temperature) Take note here guys. JM

Compounding the problem, at about -21 degrees C most oils (the exceptions being synthetics like the discontinued Mobil AV-1) become too thick to lubricate the cylinders and bearings properly, and if you could manage to start your engine at this temperature (by heavy priming, or a bit of mild preheating), the wear that would take place until the oil began to flow would probably be equivalent to more than 50 hours of normal operation.

(Mike Busch, the Cessna Pilots Association's engine specialist, claims that one cold start at the lower temperature extremes can cause as much wear as 500 hours of normal cruise operation)

There are no convenient ways around these problems, and, like the FAA and taxes, they are a fact of aviation life

The best bush preheating rig is one that uses a simple old-fashioned gasoline blowtorch that can be operated on avgas taken directly from the airplane's fuel sumps

Blowtorch and stovepipe method. The equipment list for this system consists of a small fire extinguisher, one or two gasoline blowtorches, three lengths of 3" stovepipe, an insulated engine cover, and a two- or five-gallon metal gasoline can. Here is how the system works:

1. After the last flight of the day, the oil is drained from the engine into the gasoline can. Quick-drains should be installed on all airplanes in the fleet to facilitate this daily chore.

2. The can of oil is taken inside your office or home, where it is placed near the stove so it can be kept warm until needed again.

3. When the airplane is to be called into service, the can of oil, with the lid removed, is placed on top of the stove and heated to about 122 degrees F/50 degrees C.

4. While the oil is warming, take the three lengths of 3" stovepipe and fasten them together. Place one end inside the engine compartment and temporarily rest the other end on the ground. The best place for the pipe to go into the Super Cub's engine compartment is on the right side by the brace to the exhaust stack. With the Cessna 180/185, it is best to drop the right cowl-flap and place the pipe there (see illustrations 28 and 31).

5. Carefully light the blowtorch away from the airplane, and when it is operating properly place the nozzle into the lower end of the stovepipe.

With the Cessna 180/185 and 206 you should use two blowtorches, and these must be placed in the same pipe (see illustration 31). Never use two pipes, one going to the right side cowl-flap and the other going to the left side cowl-flap, because of the danger that one of the blowtorches might go out, while still spraying fuel into the stovepipe. The second torch could then ignite the fuel inside the engine compartment. With both torches in the same stovepipe this danger is averted.

6. Adjust the insulated engine cover over the top and sides of the engine compartment so the right cooling air-inlet, behind the prop, is covered and the left air-inlet is open (see illustration 28). This is done to allow the heated air to pass over the engine and out the far side, taking the cold with it. Remember, heat-circulation is the name of the game. When using combustion heaters, if both air-inlets are blocked, it will take longer for the engine to reach starting temperatures.

7. When the engine is warm enough that the prop moves freely and the carburetor or fuel-injector is able to vaporize fuel correctly (about 45 minutes at -4 degrees F/-20 degrees C; 1+20 at -40 degrees F/-40 degrees C), the blowtorch(es) can be turned off and set aside to cool. At this point the hot oil is poured into the engine, three or four shots of priming are given, and the engine is turned over four to six times by hand. It is now ready to go, and should start on the first turn of the prop.

Battery

Cold also affects the battery; at seriously low temperatures it will not have enough power to start the engine. In the bush you must either remove the battery and take it inside for the night so it can be kept warm, or you must handprop the airplane for the first flight of the following day."

And we think we have it bad on cold mornings.

Amberley Airshow 4/5 October 2008

The RAAF are putting on an Airshow on the 4th and 5th of October. There will be a civilian component where the RA-Aus will have a presence.

Nick Sigley and I will be the organizers for the RA-Aus component, and I in particular would like anyone who has some special ideas on how we can make our group really stand out to pass them on to me on. (0438728311) or send me an email.

John McKeown

Don't Forget Heck Field this Weekend

Gold Coast Sports Flying Club

---

The Gold Coast Sports Flying Club, Heck Field, Jacob's Well, we would like to invite you and those around you that may be interested, to a CASA presentation that is being held on Saturday the 31st of May. Safety topics to be covered are operations at non-towered aerodromes and situational awareness, areas that we all need to be familiar with. The seminar will start at 11:30 am and will be presented by a number of aviation safety advisors including Charles Galea. Mike Poole, the Recreational Aviation Australia Operations Manager is also planning to attend subject to the vagaries of his position.

For those who are driving, the venue is located at 1638 Jacob's Well Road and for flyers, Heck Field is situated just south of the Jacob's Well (JCW) VOR and is displayed on both the Brisbane and Gold Coast VTCs. Runways directions are 10/28 and 18/36. On the Sunday there will also be a get together and BBQ commencing at 9:30 am. If you are thinking of coming (on either day) or for further details, please contact the club president, Peter Johnstone on 0430 466 288 or kityhawk@iprimus.com.au . The clubs website, containing some aerodrome information is www.gcsfc.org.au . While I realise that many may not be able to make the journey due to distance or other commitments please pass the message on those who can.

Our Operations Manager Mick Poole will also be in attendance.

Ops. Manual Update

Hi All,

The new Ops. manual is now at CD proof read stage, and all going well CD's will be burned and sent out with the July Magazine.

Mick Poole has declared August 1st as the implementation date baring unforeseen problems.

There will be a realistic "Grandfather" period for people who have been training under the old Ops. manual. (eg the new cross country increase from 5 to 10 hours.)

John McK

By The Numbers

I thought members may be interested in some numbers and ratios.

The Government body CASA look after approx 11,000 pilots in Australia. These include ATPL, CPL, and PPL. pilots. To do this they have a staff of approx. 600 people. This is a ratio of 18:1. Pilots as to admin.

The RA-Aus look after approx 9,000 recreational pilots, and do this with a staff of 10. This is a ratio of 900:1

Interesting numbers aren't they?

I truly believe our day to day administration is is far more efficient than any other, but if you have some issue that is not the norm, please look at these ratios and consider cutting the people in Canberra and your elected members a little slack. There are some things in the past we could have done better, but we are trying to do things better month by month, and every year we become a little more professional than the past year.

Rotax Flickering Oil Pressure

There is a problem appearing in Rotax 912 engines with flickering oil pressure. Three aircraft at my home airfield at Boonah had the problem.

Rotax Australia has appeared, from statements to me by owners, to be somewhat unhelpful in this regard telling the owners the only problem is at Boonah when in fact there have been other reports around Australia of the same problem. Owners have been told all sorts of very expensive fixes including "buy and install a new oil pump"

There are two very experienced engine guys on the field at Boonah and to them the problem is not unique, and easily fixed. The problem is just a weak relief spring (probably a bad batch of outsourced springs), and is easily fixed with some shims. The Rotax factory actually have a shim kit to fix this problem, but people locally have been told to spend bulk dollars on a new oil pump.

One of our members (with air force hydraulic training and experience) and in consultation with one of our very experienced mechanics, fixed his problem by going to the local hardware store and buying a pack of small stainless steel washers to use as shims. Two little washers fixed his problem.

( I will ask M. and B. if they will write a technical explanation to post here)

RA-Aus Official Response to CTAF (R) Establishment

18/3/08

Mr Peter Cromarty
General Manager
Office of Airspace Regulation
Civil Aviation Safety Authority

Dear Peter,

RE: Establishment of CTAF (R)
In the past RA-Aus has been a firm supporter of the consultative process undertaken by Airservices Australia and the AERU team with regard to changes of airspace and indeed changes to CTAF(R)s.

RA-Aus also supported the formation of the OAR as we believed that the service provider should not be the regulator as well. However recent events with regard to the OAR’s ‘Blanket’ creation of CTAF(R)s at all Passenger Transport Operation(PTO) Aerodromes have directly shaken our confidence in the consultation process demonstrated by the OAR.

RA-Aus believes that this unilateral move by OAR will destroy years of successful industry consultation. RA-Aus and Industry incur substantial costs to attend a variety of consultative forums of which OAR is only one. If OAR is to disregard the inputs provided by industry during the consultative process than RA-Aus would be better served to take the political route in getting our viewpoint across to Government. The current move to create ‘blanket’ CTAF(R)s is in direct opposition to CASA Directive 1/2007 and also the Australian Airspace Policy Statement (AAPS) for which no cost benefit or risk management process has been undertaken.

The process used by AERU successfully in the past have been essentially Option 3 and it is the only option under the present Discussion Paper(DP) that conforms to the AAPS.

We are also keenly aware of the implications of enmasse CTAF(R)s and their direct correlation to the introduction of ADS-B in the future. RA-Aus understands the desire of the airlines to mandate radio at all PTO aerodromes, however we believe that normalising deviation from the ideals of NAS (US) is creating another unique Australian Airspace System problem that NAS was introduced to alleviate.

Phone: (02) 6280 4700 Fax: (02) 6280 4775 E-mail: admin@raa.asn.au

VISIT US AT WWW.RAA.ASN.AU


RA-Aus believes that the perceived safety benefit increase of mandating radio at a wide number of PTO aerodromes is unreliable at best and unless OAR is responsible in their duty of care and follow the required government protocols as per the AAPS and address this subject with a risk based/cost benefit analysis method, the impact will severely affect not only current operations but also future confidence in CASA’s ability to consult with industry.

RA-Aus strongly supports Dr. Bob Hall’s letter of the 22nd of February 2008 to you on the introduction of the new CTAF(R) aerodromes and further more RA-Aus will vigorously oppose any such endeavour to mandate restrictions on current freedoms where no safety case is first demonstrated.

RA-Aus remains committed to the consultation process however finds it difficult to justify expending considerable time and money on consultation with government bodies that wish to repeal strategic directions put in place by their predecessors in order to effect outcomes different to those already agreed in principle during the consultation process.

RA-Aus does not believe that OAR is fulfilling it’s obligation as the airspace regulator if it bypasses government protocols such as the AAPS in favour of more powerful vested interests at the expense of equitable airspace access for all users.

Regards


Lee Ungermann
CEO Recreational Aviation Australia Inc.


Bruce Byron, CASA
Bob Hall, ASAC
Tim Blatch, AOPA

NATFLY 2008 - 25 Years

Hi All,

Our national fly in is on again over Easter at Narromine (20 - 23 March.) This event is of special significance this year as it marks our 25 th year of existence. If you can attend, please do so.

If you are flying in please remember to read the AIP supplement about our event H12/08.

I have also had reports that the "Cat Head Burrs" are particularly bad this year. Please take precautions.

Safe Flying,

John

RA-Aus Board Meeting, February 2008

The following items may be of interest.

1. RA-Aus Forum. It was decided that we would develop our own web forum. In this way we can better inform our members of developments in an appropriate and timely manner.

2. Our new Operations Manual is finalised and will be burned to a CD and sent out with the April edition of our magazine, and become effective at our Ops. Manager’s discretion. Probably on the first of May. For those who want a hard copy, this will be available from the office on a cost recovery basis. By sending the manual out on a CD with the magazine your association stands to save approx. $150,000. One significant change is increasing the cross country time from 5 to 10 hours. Those doing their cross country endorsement would be advised to hasten.

3. BFR’s There has been some confusion regarding BFR’s. I went through this with our Ops. Manager to clarify things.

1. A BFR is NOT a pass /fail test. It is a review.

2. A BFR is NOT a training flight. Hence it can be done in any aircraft.

3. The pilot being tested is regarded as the PIC, not the instructor.

4. The instructor does not need to be endorsed on the aircraft used.

5. The review should aim to be in the most flown aircraft, but advisory only.

4. CTAF-R. Air-services is aggressively pushing to make ALL licensed aerodromes a CTAF-R. We need to watch and fight this one.

5. 10,000 th. Member. We are getting very close to getting our 10,000 th. Member. As a comparison, I understand AOPA have about 3500 members, SAAA about 1500 members, and HGFA about 2500 members, mostly hang glider pilots.

6. Student Scholarship Program. We have started a student scholarship program. With the official launching next month.

7. Mobile Training School. Due to the serious problems caused by the trial Mobile Training School. No further mobile schools will be approved. However Satellite Schools will be approved on application and the meeting of set conditions.

8. Video of Forums. An attempt will be made to video instructor forums and technical forums at this years Natfly. These will be for sale after the event.

9. Club Insurance. It may not be wildly known but affiliated clubs are covered under the RA-Aus insurance policy for many club events. But not air shows.

John McKeown

Possible Glitch with LSA Aircraft

Note from our Technical Manager.

If you are going to transfer from VH to LSA you must provide a copy of the revised Special Certificate of Airworthiness. The SCoA has to be re-issued by an Approved Person with 24-XXXX. An additional transfer cost to the owner.

Also please note that under the current CASA regulations, LSA aircraft cannot be used for Hire and Reward. A SCoA for aircraft being used for Hire will not be issued. The basis of the regulation wording states LSA aircraft can only be used for Private Ops, Flying Training and Glider Towing.

Chris Kiehn has emailed Bernie Hole from CASA for his understanding of this. This could be a serious blow for anyone wishing to make money with LSA aircraft..!

******* ********* ********

Update. Chris has received a response from Bernie.


"The information you require is contained in CAR 262 APA. The requirements are that production LSA aircraft can be used for Private operations Flying training Glider towing.

The aircraft can be hired out for any of these operations. In other words, if you owned an aircraft you could hire it out to a person for private operations etc.

Hope this helps

Regards

Bernie
"

Fire Safety and Composite Aircraft

There has been a lot of press coverage lately about fire and composite aircraft. This has been about the new generation of passenger aircraft, but there are now a lot of composite recreational aircraft on our register, so this should be of interest to us.

The following is a link to an article by the ATSB on this matter, written in April 2006. (mouse click on ATSB)

John McK

Presidents Memo to RA-Aus members

ADS-B: A Panacea and Gravy Train for Air Services Australia.

A Poison Pill for RA-Aus and all private aircraft owners.

Last week I attended the Safe Skies conference in Canberra. During one of the presentations by the CEO of Air Services Australia (ASA), I was absolutely shocked to see the following slide as part of his presentation which depicted RA-Aus aircraft as a current safety threat.

ADS-B: A Panacea and Gravy Train for Air Services Australia.

A Poison Pill for RA-Aus and all private aircraft owners.

Last week I attended the Safe Skies conference in Canberra. During one of the presentations by the CEO of Air Services Australia (ASA), I was absolutely shocked to see the following slide as part of his presentation which depicted RA-Aus aircraft as a current safety threat.

( Mouse click on the above image to enlarge the photo)

ASA’s insinuations that Drifters (and by implication, RA-Aus aircraft) are unsafe is inflammatory and patently untrue. There have been no studies, no evidence produced to support the CEO’s suggestion. Air Services Australia is the same organisation that steadfastly refuses to implement the Transport Minister's “Ministerial Directive” that requires provision of radar in areas which Air Services claims to require Class C airspace, but have no radar - such as Coffs Harbour. ASA are content to ignore real SAFETY threats and endanger the lives of “fare paying passengers” by operating Control Zones without radar, and in the process disobeying a Ministerial directive; while fabricating non existent SAFETY problems of Drifters operating OUTSIDE control airspace in “G” or general use airspace, where they have been operating SAFELY for over 25 years.

I believe that the Minister should be taking ASA to task and insisting that ASA implement his directive. Where is accountability when a Ministerial directive can be ignored for over 3 years, endangering the lives of fare paying passengers? ASA is the same organisation that is now trying to ram ADS-B down the throats of private aircraft owners to cure a problem that doesn’t exist. What Air Services Australia is trying to do is shift the cost of new and replacement radars away from Air Services and on to all owners of aircraft under the guise of SAFETY in an effort to lessen their own financial responsibilities.

In the United States ADS-B is still in its infancy and the FAA has announced that due to technical and other reasons ADS-B will not be a requirement until 2020; and then for commercial aircraft only. For Australia to mandate a technical solution years before the US is inviting obsolescence and interoperability problems as well as additional future costs. Aircraft in the US will still be required to carry a transponder as the primary means of collision avoidance. Aircraft using only G or E airspace in the US will not be required to carry ADS-B. The US has significantly higher air traffic density and the fact that they are not contemplating ADS-B for class G or E airspace makes a mockery of ASA purported safety claim for the much lower density of traffic in Australian G and E airspace.

The fact is that forcing every aircraft in Australia to carry ADS-B would be a quick and easy solution for ASA requirements to replace their current ground-based radars. RA-Aus has no problem with ASA implementing ADS-B in higher level airspaces where it will be of most benefit to the airlines. Mandating ADS-B for use in both upper and lower airspace cannot be supported on either a safety or a cost benefit basis.

Air Services Australia is a government corporation providing ATC and Air Navigation services. It is expected to make a profit and pay a dividend to the Government. RA-Aus find it somewhat inappropriate that ASA is a member of the Aviation Policy Group (APG) a peak body formulating strategic aviation policy. Policy and profit motive do not make good bedfellows nor are they conducive in formulating impartial strategic policy that affects all Australian airspace users. Having ASA represented on the APG is a bit like having the fox in the henhouse. I believe that the Minister should review the makeup of the APG with a view to excluding ASA or alternatively having airspace users represented on the APG if ASA’s commercial interests are represented.

In last months magazine Lee gave an overview of what ADS-B was all about and the fact that there was a Joint Consultation Paper (JCP) put out by the APG on ADS-B. RA-Aus have submitted a response rejecting the paper and its proposals. A copy of our response is on our website.

It appears that ASA is ready to manufacture a bogus safety case on why G airspace should be reduced or why all RA-Aus aircraft should be fitted with an ADS-B. I ask that all members remain vigilant and be ready to lobby their local members of Parliament and write to the Minister asking that he curtail ASA’s arrogance and conceit. I’m sure our 8,200 flying members and some 4,000 aircraft owners would make an impact if they all wrote letters to the media and decision makers. In the meantime please do your own research into the issue so that you can respond to any nonsense claims of SAFETY issues surrounding ADS-B, airspace and CTAF( R) being made by ASA when trying to justify their own flawed agenda.

I would much rather be talking about fun things like the Evans Head Great Eastern Fly- In over the Christmas / New Year period. It promises to be a great time with many events planned over the four days. More details elsewhere in this magazine.

Christmas and the season of goodwill is almost with us. The office will be closed over the Christmas-New Year period so if you have any business that will need to be conducted over that period, plan on getting it done earlier.

On behalf of all the members I would like to pass on a vote of thanks to all our office staff who have all worked hard and efficiently in providing us with the services we need to keep us flying with a minimum of fuss. We wish them a Merry Christmas and a Happy New Year full of rewarding challenges.

To all our faithful members, your Board extends the compliments of the season with the fervent desire that you all have a Merry Christmas and a SAFE New Year.

John Gardon

RA-Aus President

ADS-B - Technical Article

I have had a few people ask me more information on the technical side of ADS-B.

For those interested there is a very good Technical Article on ADS-B written some time ago by John Brandon. It is on the on the RA-Aus web site. Mouse click on "Technical Article" above to go straight to the site.

John McK

ADS-B, Presidents Memo to the Minister

10 November 2007

Dear Minister,

I attended the Safeskies conference in Canberra last week. It was a very beneficial conference with the Safety Systems theme well received. The organisers and sponsors should be congratulated for an excellent event. We were all disappointed that you were unable to open the conference but understood the time pressures you are currently under.

During one of the presentations I was very disturbed at the direction that Air Services Australia were taking on the introduction of ADS-B, as well as the implied suggestion that private operations in class G airspace were a safety risk. With the establishment of the Office of Airspace Regulation (OAR) within CASA, I would have thought that Air Services comment was inappropriate and pre-emptive.

Attached is an article that will shortly be published in the RA-Aus magazine with a print run of some 13,000 copies for both members and newsstand distribution. I would appreciate it if you could read it and respond to the following specific issues raised:

1. Is the Minister happy with the current situation of Air Services ignoring a Ministerial Directive for over three years?

2. Is it appropriate for Air Services to be represented on the Aviation Policy Group, when their profit driven motives may not coalesce with the broader strategic needs of all aviation sectors?

3. Can you assure us that issues such as the implementation of ADS-B, reduction and regulation of G Airspace and increase in numbers of CTAF ( R ) will be subject to an aviation industry wide true consultation process?

4. Can you assure us that your Airspace Policy statements, and in particular, that class “G” airspace is be considered the default airspace and that the eventual aim is to adopt the unaltered US and ICAO NAS airspace model, are still the guidance for the OAR?

5. Can the Minister assure us that, if after full industry wide consultation, it is determined that fitment of ADS-B is to be mandated for class “E” and “G” airspace that:

(i) both ADS-B (in) and ADS-B (out) equipment will be provided free of charge and maintained by ASA for all private aircraft operators.

(ii) No charges will be ever be levied by ASA for private operations in “E” and “G” airspace as is currently the case.

We plan on releasing the article to all other aviation journals and magazines as well as the Australian newspaper in the near future. We would obviously like to convey factual material in those articles.

RA-Aus has prided itself on working with the regulator in a co-operative and consultative manner in forums such as CASA’s SCC process. As a result you have heard very little from us other than occasional courtesy visits. In this instance we believe that ASA is bypassing and rushing the normal consultative process. That they are doing this in an effort to achieve an outcome that would solve ASA’s financial predicament, by shifting cost burdens onto private aircraft owners. Therefore we feel that we had no other option but to approach you for clarification given the circumstances.

Thank you for taking the time from your busy schedule to respond.

Regards,

John Gardon

Two Gyro Pilots Badly Burnt

Two Gyroplane pilots, an instructor and a student pilot were badly burnt in a landing accident at Echuca late yesterday afternoon. The Gyro burst into flames on landing heavily. One of the pilots died of his burns to-day.

Although this is not under RA-Aus jurisdiction, it reminds me of a badly burnt pilot I wrote about in an earlier post. See Accident Lessons, Sep. 18. (just click here)

When you go flying please consider wearing non flammable or low flammable clothing, and have a way of getting out of your seat belts quickly.

ADS-B. - Know Your Enemy

This is a slide put up by Greg Russell at the recent Safe Skies conference. November 1-2, 2007 in Canberra. (Mouse click on photo to enlarge image)

He cites this Drifter, most probably legally flying in class G airspace, as an example of the type of aircraft that poses a real danger to aviation, and the reason for ADS-B

Greg Russell is the CEO of Air Services Australia. He is pushing this ADS-B business real hard. Why I wonder? Particularly in light of the conclusions the FAA in the US have come to, which are opposite to ASA views.

Greg Russell and ASA are pushing very hard to sell ADS-B as the be all and end all panacea for aviation safety, completely disregarding the US experience and intent. When the arguments they put up for safety make no sense you have to ask WHY. The Latin term 'Que Bono" comes to my mind. Que Bono - Who benefits? Certainly not the vast majority of recreation aviators in Australia.


His safety arguments are nonsense. Read the RA-Aus submission below.

I personally have no issue with ADS-B in controlled airspace or above 10,000 feet where commercial and RPT operate.

I also believe there are some regulations you may not like, and some, perhaps, are not worth fighting. In these cases you grin and bear it.

However this is a very serious battle we MUST win. Not just for us now, but for all our future members.

Our Association is very fortunate at this time, as we have a President and CEO who are willing to go out and fight for what they believe is in the best interest of our members. They are against the ADS-B proposal in its current form and are prepared to do something about it, while some others in our association are content to sit on their hands, and even be appeasers.

Others in our association may have different views to me on this matter, and that is good. It is very healthy to have different views and opinions. It is not healthy to have fence sitters and appeasers. If you feel strongly about this matter, one way or the other, do something about it. Don't just sit on the fence. Ask your local board member what his or her views and actions are. If you don't like the answer, tell them so, and consider how you vote at the next RA-Aus Board election. (This goes for me too. If you think I am too unyielding on this matter, vote me off)

John McK

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.

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