FAA ADS-B Out NPRM needs to be drastically changed

[Ron Lee[_2_]]

If you thought that the user fee issue was important, this proposal is
far more onerous to the GA community.

You can access the 100 page NPRM from this AOPA website:

http://www.avweb.com/avwebflash/news/ADSB_PilotRequirements_2020_196268-1.html

This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I
can determine from available information will be costly (as high as
~$18,000 per aircraft) just to transmit position info.

This does NOT get you free weather, free traffic info or other data
transmitted by the ADS system.

It will require ADS-B Out equipage to fly above 10,000 feet MSL, into
Class C airspace, by all aircraft at airports within current Class B
Mode C rings (30 NM), etc.

My analysis shows ZERO to INSIGNIFICANT benefit to most GA users but
potentially onerously high costs. My current draft response to this
NPRM is at the link below. It is a Word document and is still very
draft. I will be updating it as I more fully develop it.

http://tinyurl.com/2wem8j

This NPRM needs massive and overwhelming GA pilot community input to
fight it. Details are in the NPRM and we must also ensure that AOPA,
EAA , etc are on board.

Previous AOPA statements that 75% of GA pilots are in favor of ADS-B
if they get free weather fail to prperly cover the costs to the pilot
for avionics. Once you read the NPRM and my review, an objectively
worded poll would probably show less than 5% of GA pilots willing to
equip with all the ADS-B avionics needed to get free weather.

More to follow soon.

Ron Lee

[Lee McGee]

If ADS-B technology costs $18,000 today, that will be $1800 or even $180 in
2020.

I work in the high tech computer industry. 5 terabytes of disk storage cost
nearly $1,000,000 in the year 2000. Today, in summer 2007, we just bought 7
terabytes for $11,000. This is not a typo. The technology is similar.

Lee McGee (yet another Lee)


"Ron Lee" > wrote in message
...
> If you thought that the user fee issue was important, this proposal is
> far more onerous to the GA community.
>
> You can access the 100 page NPRM from this AOPA website:
>
> http://www.avweb.com/avwebflash/news/ADSB_PilotRequirements_2020_196268-1.html
>
> This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I
> can determine from available information will be costly (as high as
> ~$18,000 per aircraft) just to transmit position info.
>
> This does NOT get you free weather, free traffic info or other data
> transmitted by the ADS system.
>
> It will require ADS-B Out equipage to fly above 10,000 feet MSL, into
> Class C airspace, by all aircraft at airports within current Class B
> Mode C rings (30 NM), etc.
>
> My analysis shows ZERO to INSIGNIFICANT benefit to most GA users but
> potentially onerously high costs. My current draft response to this
> NPRM is at the link below. It is a Word document and is still very
> draft. I will be updating it as I more fully develop it.
>
> http://tinyurl.com/2wem8j
>
> This NPRM needs massive and overwhelming GA pilot community input to
> fight it. Details are in the NPRM and we must also ensure that AOPA,
> EAA , etc are on board.
>
> Previous AOPA statements that 75% of GA pilots are in favor of ADS-B
> if they get free weather fail to prperly cover the costs to the pilot
> for avionics. Once you read the NPRM and my review, an objectively
> worded poll would probably show less than 5% of GA pilots willing to
> equip with all the ADS-B avionics needed to get free weather.
>
> More to follow soon.
>
> Ron Lee
>
>
>

[Gig 601XL Builder]

Lee McGee wrote:
> If ADS-B technology costs $18,000 today, that will be $1800 or even
> $180 in 2020.
>
> I work in the high tech computer industry. 5 terabytes of disk
> storage cost nearly $1,000,000 in the year 2000. Today, in summer
> 2007, we just bought 7 terabytes for $11,000. This is not a typo. The
> technology is similar.
> Lee McGee (yet another Lee)


Very unfortunately the prices for certified aviation electronics hasn't done
the same and there is no reason to think it will in the future.

[Bob Noel]

In article >,
"Lee McGee" > wrote:

> If ADS-B technology costs $18,000 today, that will be $1800 or even $180 in
> 2020.

How much did a KX-155 cost in 1987?

How much did it cost in 2006?

Did the installation cost for <insert avionics box> go up or down in the past
20 years?



>
> I work in the high tech computer industry. 5 terabytes of disk storage cost
> nearly $1,000,000 in the year 2000. Today, in summer 2007, we just bought 7
> terabytes for $11,000. This is not a typo. The technology is similar.

high tech computer industry is not the same animal as avionics.

--
Bob Noel
(goodness, please trim replies!!!)

[Morgans[_2_]]

"Lee McGee" > wrote

> I work in the high tech computer industry. 5 terabytes of disk storage
> cost nearly $1,000,000 in the year 2000. Today, in summer 2007, we just
> bought 7 terabytes for $11,000. This is not a typo. The technology is
> similar.

I just saw a terabyte external drive for under 300 bucks. Wow!
--
Jim in NC

[Jim Stewart]

Gig 601XL Builder wrote:
> Lee McGee wrote:
>> If ADS-B technology costs $18,000 today, that will be $1800 or even
>> $180 in 2020.
>>
>> I work in the high tech computer industry. 5 terabytes of disk
>> storage cost nearly $1,000,000 in the year 2000. Today, in summer
>> 2007, we just bought 7 terabytes for $11,000. This is not a typo. The
>> technology is similar.
>> Lee McGee (yet another Lee)
>
>
> Very unfortunately the prices for certified aviation electronics hasn't done
> the same and there is no reason to think it will in the future.

From what I can tell, ADS-B requires a
mode-s transponder, a high performance GPS,
a 1030 Mhz receiver which may or may not
be part of the transponder, a fast computer
and a display.

There's no way to predict what that would
cost in 2020 except that it will be more
than $180.

[[email protected]]

Lee McGee > wrote:
> If ADS-B technology costs $18,000 today, that will be $1800 or even $180 in
> 2020.

> I work in the high tech computer industry. 5 terabytes of disk storage cost
> nearly $1,000,000 in the year 2000. Today, in summer 2007, we just bought 7
> terabytes for $11,000. This is not a typo. The technology is similar.

> Lee McGee (yet another Lee)

The avionics market place has neither the size nor the freedom of the
consumer market place.

The price of cutting edge avionics will come down over time, but not
hardly at the same rate as consumer stuff.



--
Jim Pennino

Remove .spam.sux to reply.

[Ron Lee[_2_]]

>> Very unfortunately the prices for certified aviation electronics hasn't done
>> the same and there is no reason to think it will in the future.
>
> From what I can tell, ADS-B requires a
>mode-s transponder, a high performance GPS,
>a 1030 Mhz receiver which may or may not
>be part of the transponder, a fast computer
>and a display.
>
>There's no way to predict what that would
>cost in 2020 except that it will be more
>than $180.
>
>
I believe that UAT is 978 MHz but the frequency is trivial.

Ron Lee

[Morgans[_2_]]

"Jim Stewart" <> wrote

> From what I can tell, ADS-B requires a
> mode-s transponder, a high performance GPS,
> a 1030 Mhz receiver which may or may not
> be part of the transponder, a fast computer
> and a display.
>
> There's no way to predict what that would
> cost in 2020 except that it will be more
> than $180.

The word "aviation" in the title of the device automatically multiplies the
price by 100!

I thought everyone knew that principle of pricing aviation equipment, of any
kind.
--
Jim in NC

[Larry Dighera]

On Mon, 08 Oct 2007 18:56:04 GMT, (Ron Lee)
wrote in >:

....
>Previous AOPA statements that 75% of GA pilots are in favor of ADS-B
>if they get free weather fail to prperly cover the costs to the pilot
>for avionics. Once you read the NPRM and my review, an objectively
>worded poll would probably show less than 5% of GA pilots willing to
>equip with all the ADS-B avionics needed to get free weather.


AOPA FINDS ADS-B PROPOSAL NEEDS WORK
(http://www.avweb.com/eletter/archives/avflash/974-full.html#196330)
AOPA has taken a first look at the FAA's complex new ADS-B
proposal
(http://www.aopa.org/advocacy/articles/2007/071003ads-b.html)

(http://www.avweb.com/avwebflash/news/ADSB_PilotRequirements_2020_196268-1.html),
and found plenty of technical and cost issues that will affect
general aviation pilots. Randy Kenagy, AOPA senior director of
strategic planning, said an initial review of the 100-page Notice
of Proposed Rulemaking showed that "much more work needs to be
done before the FAA publishes its final rule." The proposal would
require all aircraft operators to install ADS-B equipment by 2020
if they want to fly in controlled airspace. The new avionics would
provide cockpit weather and traffic information to pilots,
replacing services such as flight following or en route vectoring.
AOPA President Phil Boyer tied the FAA proposal to the current
fight over user fees. "If they [the FAA] want GA pilots to spend
thousands of dollars on new avionics, we need to make sure that
the expenditures are considered as we assess what GA should pay in
fuel taxes in the future FAA budget," he said.

It would appear that AOPA is revising it's stance on the mandatory
ADS-B issue, but given the fact that AOPA feels it would only cost
each aircraft owner "thousands of dollars," not tens of thousands of
dollars, it is doubtful they yet fully appreciate the ramifications of
the issue. While mandatory ADS-B equipment might be a step forward
for GA pilot operations, it would seem to me, that it is FAA (and
avionics manufacturers) who stand to receive the most benefit from
this proposal.

And if mandatory ADS-B installation were to result in the
decommissioning of ATC radar installations, that would be a step
backward, because there would be no backup system in the event of an
outage in ADS-B operation. But more importantly, the validity of
aircraft positional information, upon which ATC currently relies,
would switch from an empirical to reported. That coupled with the
change from terrestrial based communications to satellite based
communications would seem to provide reduced system integrity, IMO.

[Ron Lee[_2_]]

>It would appear that AOPA is revising it's stance on the mandatory
>ADS-B issue, but given the fact that AOPA feels it would only cost
>each aircraft owner "thousands of dollars," not tens of thousands of
>dollars, it is doubtful they yet fully appreciate the ramifications of
>the issue. While mandatory ADS-B equipment might be a step forward
>for GA pilot operations, it would seem to me, that it is FAA (and
>avionics manufacturers) who stand to receive the most benefit from
>this proposal.

Excellent point. The NPRM also only covers ADS-B Out which does not
get the GA pilot free weather or traffic info. I will have to correct
AOPA on that but since it took forever to correct them on the fuel
increase percentage during the user fee debate...it may be hard.

>And if mandatory ADS-B installation were to result in the
>decommissioning of ATC radar installations, that would be a step
>backward, because there would be no backup system in the event of an
>outage in ADS-B operation. But more importantly, the validity of
>aircraft positional information, upon which ATC currently relies,
>would switch from an empirical to reported. That coupled with the
>change from terrestrial based communications to satellite based
>communications would seem to provide reduced system integrity, IMO.

Concur. The backup strategy is to use SSR with transponders. I am
still unclear if all aircarft must keep curremt Mode C/S transponers
if they get ADS-B Out or if ADS-B Out units incorporate Mode C/S
functionality.

This NPRM is really flawed, makes unsupported conclusions and should
really be withdrawn entirely while they go back to the drawing board
and get some people with common sense helping them.

Ron Lee

[john hawkins]

Based on historical FAA performance on modernization, what makes anyone
think that ADS-B will be ready to be implemented by 2020 or even 2050? I'm
glad the AOPA is keeping us aware of whats going on. I really think we need
to provide a voice to the FAA other than ATA and major contractors, but I'm
not worried that we will actually have to have ADS-B equipment anywhere the
planned date.


"Ron Lee" > wrote in message
...
> If you thought that the user fee issue was important, this proposal is
> far more onerous to the GA community.
>
> You can access the 100 page NPRM from this AOPA website:
>
> http://www.avweb.com/avwebflash/news/ADSB_PilotRequirements_2020_196268-1.html
>
> This NPRM to mandate ADS-B Out avionics on aircraft by 2020 as best I
> can determine from available information will be costly (as high as
> ~$18,000 per aircraft) just to transmit position info.
snip

[Larry Dighera]

On Tue, 09 Oct 2007 14:33:06 GMT, (Ron Lee)
wrote in >:

>The backup strategy is to use SSR with transponders.

So, primary radar will be decommissioned, and the ability to paint
anything, like rain and primary targets, will be lost also. Is that a
step forward?

[Larry Dighera]

On Tue, 09 Oct 2007 14:52:35 GMT, "john hawkins"
> wrote in
>:

>Based on historical FAA performance on modernization, what makes anyone
>think that ADS-B will be ready to be implemented by 2020 or even 2050?

The contract recently signed with ITT to implement ADS-B nationally
presumably contains a performance clause and penalty for failure to
meet milestone dates.

[Ron Lee[_2_]]

Larry Dighera > wrote:

>On Tue, 09 Oct 2007 14:52:35 GMT, "john hawkins"
> wrote in
>:
>
>>Based on historical FAA performance on modernization, what makes anyone
>>think that ADS-B will be ready to be implemented by 2020 or even 2050?
>
>The contract recently signed with ITT to implement ADS-B nationally
>presumably contains a performance clause and penalty for failure to
>meet milestone dates.
>
Plus the ITT contract would have much of the system (ground stuff) in
place circa 2013...plenty of time for inevitable delays.

Ron Lee