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.

Rotax Engines

This is an interesting site about Rotax Engines. If you want to read the articles just click on the subject title below.

Reading Pistons

Reading Spark Plugs

Bing Carburettors

Choosing Two Stroke Oils

Human Factors Training

Human Factors Training

Our new Operations Manual has been with CASA for some time, (well before I was elected to the board) and was promised to be approved before this Christmas. However I see this as a remote possibility due to the election. (Update 30/10/07 - I may have been somewhat premature with the last statement. Watch this space )

Probability the biggest impact on current licensed members will be the need for everyone of us to undertake a course in Human Factors. At this stage it appears we will be given two years to undertake this course and there is a possibility that it can be done by "self study". I haven't seen the course but I don't think it will be much of a burden to us, and may be a big help to our decision making.

RA-Aus Magazine

I have been getting a number of complaints about our magazine. The main issues are Lateness, and that some members see the magazine in the newsagent before they get their posted copy.

Most members would not be aware that we no longer edit our magazine. The RA-Aus has contracted out the magazine to Zebra Publishing. We pay them a fee to edit print and publish our magazine.

I have brought the complaints I have received to the attention of the other Board Members and the Executive. My personal view is our members MUST receive their mailed copy before the general public can purchase a copy in a newsagent. Even if this means delaying the distribution to the newsagents. I have presented this view to the full Board and Executive.

I have also presented the view that we need to find out why the magazine is so often late, and take steps to fix the problem.

Recreational Flying Forum

On the side bar you will see a link to an aviation forum called Recreational Flying Forum. This is a private forum run by a gentleman named Ian Baker. It has no formal association with the governing body of recreational flying, the RA-Aus.

I have not met Ian however I personally find this an excellent forum for all recreational pilots. I am a member of this site (JohnMcK) and I support this site from a personal perspective and a board member perspective. The site is well moderated and friendly. You just have a look at some of the other aviation forums to see the viscous nature and tone of some anonymous posters to see what can happen without good moderation.

There has been an issue earlier this year where the RA-Aus suddenly refused to accept Ian's advertisements in our magazine. This was before my election to the board, and I have not been able to fully find out why. But times have changed and this is no longer an issue.

Ian also runs an online shop where recreational aviators have access to a range of aviation goods at competitive prices. I personally haven't bought anything there yet so I can't comment on the service, but if Ian runs the shop as he runs the forum, I don't think there will be any issues.

Apart from club meetings and flyins, forums such as this are a great way for recreational aviators to communicate. However for the newer pilots, don't just read the one post on a topic. I have seen examples of wrong information being given, and advice given "as gospel" that later turns out to be given by a student pilot. However the big advantage of a forum such as this, is it generally doesn't take long for someone to post the correct information.

More on ADSB

This is a copy of a post I made on the Recreational Flying Forum.

Hi Ian,

I personally have no issue, and my understanding is, neither does the RA-Aus for ASDB to be fitted for entry into controlled airspace. My main concern is for the grass roots members of the RA-Aus. The ultralight people. We have become a major growth association, (while most others are shrinking) by looking after our members, and having a policy of "affordable flying". "Safety with responsibility". Just look at what has happened to GA in the past few years. Now ask yourself why?

If we agree to this being compulsory outside CTA we are selling out not only the vast majority of our current members but also the vast majority of our future members. How are all our "Rag and Tube" members going to cope with this?. How are all the HGFA trike pilots going to cope with this, or all the roatacraft people? I will tell you how. They will be back in open paddocks like the early years. (and there are those who would prefer this to happen)

There is an old Latin saying "Cue Bono" It means "who benefits". We should all ask ourselves Who benefits from all this business. First, only the out link will be compulsory, who will benefit from this? Certainly not any recreation aviator. Where is the safety benefit in this if none of us has a down or in link? There isn't any. If there was a real concern about safety outside CTR the Government, instead of giving a $10,000 one off voucher for the up link only they could subsidize ALL aircraft in Australia (RPT included) with something like the current "Flarm" unit fitted to gliders. This is a very small box, draws next to no current, and costs about $600. This unit has in and out link, audio and visual collision avoidance, data logging, and output plotting for those with LCD screens. You can also have obstacle (power lines) and terrain (high ground) database alarms added. All this is available NOW for $600. (perhaps much cheaper if mass produced)

No I think we need to look further. Lets look at this from a "cue bono" aspect. - Who does really benefit. I have a few personal ideas. Perhaps some of you do also.

John McK

PS. In the interests of full disclosure. I have a Flarm unit fitted in my Drifter as I fly from a mixed ultralight and glider airfield. I have absolutely no connection with the manufacturer or sale of these units.

ADSB

ADS-B

Automatic Dependent Surveillance – Broadcast

Airservices/CASA are pushing ahead with ADS-B (a type of upmarket version of Flarm used by gliders and some ultralights at mixed airfields) This, in its current form, I believe, will be VERY BAD news for us. By 2012 all aircraft entering CTA will be required to have ADS-B fitted, and by 2014 all aircraft in CTAF(R) will require ADS-B. View link

CASA policy is to make all aerodromes that have a visit from one or more 10 seat aircraft per month a CTAF(R). So starting 2014 if you want to go into or through a CTAF(R) you must have ADS-B, and by then most of the airfields we currently fly at or near or through will be CTAF(R)

The “estimated” cost of these units is $10,000 to $15,000 plus instillation?. They can only be repaired by a CASA approved Radio Tec. They will also need to be serviced every two years by an approved Tec. Most of us can’t fly our aircraft into Brisbane or some other major center for a service, So if you can’t put your plane on a trailer, think of what the call out fee might be.

There are suggestions that the government may cover the costs for the initial instillation for currently registered aircraft but not for any new aircraft in the future. But even if we get a “free” unit, the upkeep could "bankrupt" many of us. We will also sell out all our future members of RA-Aus, or if you belong to AOPA, SAAA etc, your future members, if we accept this in its current form. Also no one seems to know how big or how heavy these aviation units are or what their power consumption will be. There will be exemptions for aircraft with low battery capacity or no alternator etc, plus other undefined aviation uses. You could have airspace full of, say, gliders, hang gliders, paragliders etc but banned to ultralights. If so what is the point of having them compulsory outside of CTR.

Also, as I read the new regulations, If you don't have ADSB you won't be able to fly above 5,000 ft (QNH) regardless of the terrain.

My personal view is we need to lobby to at least stop them from being compulsory in CTAF(R), and below 10,000 ft.

In the marine field this system is called AIS (no height requirement) and has been in operation for some time, and I guess is where the Aviation idea came from. This is now mandated for commercial shipping but you can buy pleasure craft versions of AIS for under $1000 which use is voluntary. Also non AIS equipped pleasure craft are not excluded from shipping lanes where AIS is compulsory for commercial shipping. Eg The narrow shipping lane up Cape York Peninsular.

Also if any of you people out there have a "thing" about your personal privacy in sporting or pleasure pursuits, be advised that every single move you make in your aircraft fitted with ADSB, from key on to key off, will be tracked and logged by the government agencies. (track, height, time, bearing, landings etc). If your IQ is greater than 10 you can work out future possible ramifications of this.

The military have rejected their compulsory instillation for now. My personal view is we should do the same under the current proposals.


How to respond

Please forward your response to DOTARS by 31 October 2007 by one of the following means:

• Fax Attn: ADS-B Proposal (02) 6274 7804
• Post ADS-B Proposal, Office of Airspace Management,
  Department of Transport and Regional Services
  GPO Box 594
  Canberra ACT 2601
• Email ADSB@dotars.gov.au

We, as Recreational Aviators must be very proactive on this matter. RESPOND NOW.


John McK (wearing my personal and RA-Rus Board hat on this one)

CASA Requests our Views and Issues for the Future

Our CEO has received a memo from the head of CASA asking us to put forward our ideas for the future of aviation (all aviation) in Australia. He also asked us to list any problems or issues that we foresee in Recreational Aviation in Australia in the medium to long term future.

I have some of my own views relating to Recreational Aviation but I need your input to get your views. You people out there are our association and it is your views that need to be heard.

I need to send in a reply to our CEO in two weeks. So please give me your thoughts and ideas before the 19 th October 2007. "Email me johnmck@gil.com.au" or mob. 0438728311

Thank you

John McK

BFR's

This past weekend my local flying club held a Fly-in breakfast, and knowing I was their new board member hit me up with a number of issues (as they should) One real problem area that I personally didn’t realise was such an issue is our BFR’s

I will bring this up at Board Level but I need to get more feedback on the issues you face. Please email me (johnmck@gil.com.au) with your concerns. The more feedback you give me the more I can argue on your behalf.

First to the BFR itself. By definition, a BFR is just what it says. A Biennial Flight Review. It is a review of our flying. It is not a pass-fail test. Its purpose it to identify and correct any bad habits or problems in our flying.

Now come the issues. These are as I see them at present, and it is here I need your feedback.

1. Single Seaters. The regulations state the test should be in the aircraft you fly the most. Several people stated they only fly single seaters and Instructors won’t review their flying from the ground.

When this is the case these pilots are told they must do their BFR in the school’s aircraft. These pilots say they feel very uncomfortable doing a “test” in an unfamiliar plane. I need more of your views on this.

2. Instructor Skills. Some pilots with “different” 2 seat aircraft claim any BFR to them is worthless as the local Instructor has never flown their type of aircraft and would have no idea of what is going on. This applies to a Rag and Tube pilot asking an instructor who has only flown hi performance aircraft to do a BFR in the back of his Drifter to a Rag and Tube Instructor doing a BFR for a Sting pilot. I agree with them on this and some solution needs to be found.

3. Insurance Issues. Some pilots want a BFR in their type of aircraft, but not in their aircraft as they carry no crew insurance and don’t know the consequences of an accident. They also ask what are the consequences of an Instructor “taking over”. I don’t know this myself but will ask.

4. Under CASA GA rules a type endorsement also rates as a BFR. This needs to be clarified under our rules. Eg. Does a tail-wheel endorsement or a check flight (endorsement) on say a Tecnam rate as a BFR?

5. Dual certificates. For our GA and RA-Aus pilots does a GA BFR also rate as a RA-Aus BFR.? If not why not. The argument here is it is a flight review of a higher level so should flow down. There has been no suggestion to me (yet) that a BFR should flow up the other way.

As I said in the beginning I was unaware of the depth of feeling on this matter, but being a rag and tube pilot myself, I can see I would be very uneasy if I had to travel to another airport to do a BFR in a plane I had never even sat in before with an instructor I didn’t know. Please give me feedback and I will bring it up with the Board.

John McKeown