Why are people ignoring the ADS-B Out NPRM?

[Ron Lee[_2_]]

Official link: http://tinyurl.com/2raefd

My analysis: http://tinyurl.com/2wem8j

This NPRM will mandate aircraft avionics that in my opinion offers
little to no benefit to the GA pilot, no safety improvement, may help
the airlines (not proven) and may only help the FAA save money.

And for all this each GA aircraft will incur a huge cost (impossible
to accurately quanitify but possibly in the $9000 - $17000 range).

Read my analysis then the NPRM and submit your comments.

Ron Lee

[Steven P. McNicoll]

"Ron Lee" > wrote in message
...
>
> Official link: http://tinyurl.com/2raefd
>
> My analysis: http://tinyurl.com/2wem8j
>
> This NPRM will mandate aircraft avionics that in my opinion offers
> little to no benefit to the GA pilot, no safety improvement, may help
> the airlines (not proven) and may only help the FAA save money.
>
> And for all this each GA aircraft will incur a huge cost (impossible
> to accurately quanitify but possibly in the $9000 - $17000 range).
>
> Read my analysis then the NPRM and submit your comments.
>

How do you know people are ignoring it?

[Larry Dighera]

On Tue, 11 Dec 2007 09:39:42 -0600, "Steven P. McNicoll"
> wrote:

>
>"Ron Lee" > wrote in message
...
>>
>> Official link: http://tinyurl.com/2raefd
>>
>> My analysis: http://tinyurl.com/2wem8j
>>
>> This NPRM will mandate aircraft avionics that in my opinion offers
>> little to no benefit to the GA pilot, no safety improvement, may help
>> the airlines (not proven) and may only help the FAA save money.
>>
>> And for all this each GA aircraft will incur a huge cost (impossible
>> to accurately quanitify but possibly in the $9000 - $17000 range).
>>
>> Read my analysis then the NPRM and submit your comments.
>>
>
>How do you know people are ignoring it?
>


Presumably due to the dearth of comments that have been submitted.
Have you visited the docket comment web site?

[Steven P. McNicoll]

"Larry Dighera" > wrote in message
...
>
> Presumably due to the dearth of comments that have been submitted.
>

Why do you presume to speak for others?


>
> Have you visited the docket comment web site?
>

No.

[Ron Lee[_2_]]

>> Presumably due to the dearth of comments that have been submitted.
>>
>Why do you presume to speak for others?

>> Have you visited the docket comment web site?
>>
>No.


Larry got it. Visit the comments section and it is distressingly void
of comments compared to the rule about electronic filing of info
before re-entering the USA.

Ron Lee

[Gig 601XL Builder]

Ron Lee wrote:
>>> Presumably due to the dearth of comments that have been submitted.
>>>
>> Why do you presume to speak for others?
>
>>> Have you visited the docket comment web site?
>>>
>> No.
>
>
> Larry got it. Visit the comments section and it is distressingly void
> of comments compared to the rule about electronic filing of info
> before re-entering the USA.
>
> Ron Lee

Which is kind of strange because the ADS-B requirements are going to effect
a lot pilots than the trans-national reporting requirements.

[Bob Noel]

In article >,
Newps > wrote:

> > And for all this each GA aircraft will incur a huge cost (impossible
> > to accurately quanitify but possibly in the $9000 - $17000 range).
>
> More likely a much smaller cost.

wanna bet?

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

[Newps]

Ron Lee wrote:
> Official link: http://tinyurl.com/2raefd
>
> My analysis: http://tinyurl.com/2wem8j
>
> This NPRM will mandate aircraft avionics that in my opinion offers
> little to no benefit to the GA pilot, no safety improvement, may help
> the airlines (not proven) and may only help the FAA save money.

Perhaps people disagree with you.


>
> And for all this each GA aircraft will incur a huge cost (impossible
> to accurately quanitify but possibly in the $9000 - $17000 range).

More likely a much smaller cost.

[Robert M. Gary]

On Dec 11, 9:59 am, "Gig 601XL Builder" <wrDOTgiaconaATsuddenlink.net>
wrote:

> Which is kind of strange because the ADS-B requirements are going to effect
> a lot pilots than the trans-national reporting requirements.

But the ADS-B requirement is achievable, it is possible to put this
type of equipment on your aircraft (I would even look forward to it),
but the border crossing requirements aren't possible to meet (unless
Mexico all of the sudden becomes a 1st world nation with telephone
systems).

-Robert

[Ron Lee[_2_]]

>> This NPRM will mandate aircraft avionics that in my opinion offers
>> little to no benefit to the GA pilot, no safety improvement, may help
>> the airlines (not proven) and may only help the FAA save money.
>
>Perhaps people disagree with you.

More likely people don't want to read the NPRM and are unaware of the
onerous cost for no benefit.

>>
>> And for all this each GA aircraft will incur a huge cost (impossible
>> to accurately quantify but possibly in the $9000 - $17000 range).
>
>More likely a much smaller cost.

The current Garmin unit is in the $8000-9000 range installed and may
or may not meet the requirements of the NPRM. The FAA projected cost
is around $17,000.

Personally I have no desire to pay even $1000 for something that
offers no benefit to me and for an operational concept that is flawed
and should assume Mode C transponders for GA aircraft.

Ron Lee

[Gig 601XL Builder]

Robert M. Gary wrote:
> On Dec 11, 9:59 am, "Gig 601XL Builder" <wrDOTgiaconaATsuddenlink.net>
> wrote:
>
>> Which is kind of strange because the ADS-B requirements are going to
>> effect a lot pilots than the trans-national reporting requirements.
>
> But the ADS-B requirement is achievable, it is possible to put this
> type of equipment on your aircraft (I would even look forward to it),
> but the border crossing requirements aren't possible to meet (unless
> Mexico all of the sudden becomes a 1st world nation with telephone
> systems).
>
> -Robert


Achievable? You think? Hell it would be cheaper for US pilots to pay for
satellite internet links at all the small and medium size airports near the
US/Mex border than to add the equipment required for ADS-B in every US
aircraft.

[Larry Dighera]

On Tue, 11 Dec 2007 11:27:17 -0700, Newps > wrote:

>
>More likely a much smaller cost.

That's the second time you suggested that ADS-B equipage will be less
than stated, but failed to provide any credible argument to support
your polyandrist prediction.

WHY do you think it will be cheaper? Is there anything tangible that
leads you to that conclusion, or are you prescient, or what?

[Larry Dighera]

On Tue, 11 Dec 2007 10:59:56 -0800 (PST), "Robert M. Gary"
> wrote:

>But the ADS-B requirement is achievable,

Complete (In and OUT) implementation of ADS-B is achievable too, and
it would be significantly more useful than what is currently proposed.
But, that isn't the issue. It's a matter of cost verses performance.
What significant benefits does the current FAA proposal provide to
light GA operations that might conceivably justify such a significant
investment. Consider it might cost as much as 50% of the value to
equip a C-150 with ADS-B, and significantly impact it's already
marginal useful load number.

>it is possible to put this
>type of equipment on your aircraft (I would even look forward to it),

I would look forward to it also if it were the full ADS-B
implementation. Then the pilot would received useful information.
There's even a chance that the position of military training flights
might even be depicted then. But the FAA's proposal is for solely
your aircraft to transmit its GPS coordinates and transponder S code
to ATC at a cost to ALL aircraft owners of around $10,000.00. There
is no data up-link to the cockpit, no WX, nor traffic depiction at
all.

[Larry Dighera]

On Tue, 11 Dec 2007 11:04:33 -0600, in rec.aviation.piloting you
wrote:

>
>"Larry Dighera" > wrote in message
...
>>
>> Presumably due to the dearth of comments that have been submitted.
>>
>
>Why do you presume to speak for others?
>

Because, I have visited the comment web site, and found a total of 58
comments submitted in response to this NPRM. It's just a guess.

>
>>
>> Have you visited the docket comment web site?
>>
>
>No.
>

Oh well...

[[email protected]]

Guys-
I think you might want to check out www.aveoengineering.com
They are releasing this as a standard feature in a DFD Skyway and
TrafficCom/TransCom units, and the cost of these units is very low
compared to Garmin. They don't have to pay for all of Garmin's
marketing... they sell through word of mouth in the aviation
community.

The reason your previous estimates were around $10k was that you were
looking at a Garmin solution. Garmin isn't the only game in town.
Actually, sometimes other companies can come in with a new technology
that is leaps over the competition. I believe that might be the case
here with their Digital Flight Deck (DFD). It has XM Weather, XM
Radio, Traffic depiction, WAAS GPS, etc. etc. Plus, the Aveo menus
are simple to operate... not a click here, twist this, then this, then
click here, then confirm, etc. like on the Garmins.

Give them a look. I think you'll be pleasantly surprised at how low
cost and highly functional they are. And remember, they build
military grade solutions at Aveo! If it can work in a jet fighter...
it can work in a C150 :-)

Cheers,
MrBizi

On Dec 11, 7:10 pm, Larry Dighera > wrote:
> On Tue, 11 Dec 2007 10:59:56 -0800 (PST), "Robert M. Gary"
>
> > wrote:
> >But the ADS-B requirement is achievable,
>
> Complete (In and OUT) implementation of ADS-B is achievable too, and
> it would be significantly more useful than what is currently proposed.
> But, that isn't the issue. It's a matter of cost verses performance.
> What significant benefits does the current FAA proposal provide to
> light GA operations that might conceivably justify such a significant
> investment. Consider it might cost as much as 50% of the value to
> equip a C-150 with ADS-B, and significantly impact it's already
> marginal useful load number.
>
> >it is possible to put this
> >type of equipment on your aircraft (I would even look forward to it),
>
> I would look forward to it also if it were the full ADS-B
> implementation. Then the pilot would received useful information.
> There's even a chance that the position of military training flights
> might even be depicted then. But the FAA's proposal is for solely
> your aircraft to transmit its GPS coordinates and transponder S code
> to ATC at a cost to ALL aircraft owners of around $10,000.00. There
> is no data up-link to the cockpit, no WX, nor traffic depiction at
> all.

[Gig 601XL Builder]

wrote:
> Guys-
> I think you might want to check out www.aveoengineering.com

I did and a search of the phrase "ADS-B" on their website gets the reply
below. So what does this have to do with the topic?
Sorry, no matches were found.
Please try again using different search words.

[Ron Lee[_2_]]

wrote:

>Guys-
>I think you might want to check out www.aveoengineering.com

Show me where they have ADS-B Out functionality to meet the
requirements of the appropriate TSO.

I don't see it.

You have not shown a lower cost solution and bear in mind that I have
no desire to pay even $1000 for a piece of equipment that offers
NOTHING to improve safety or anything else that matters to me.

It may help the airlines and the FAA but does nothing for me.

The aircraft owners better wake up and read this stuff or they will be
socked with an expensive mandate very soon.

Ron Lee

[nobody[_2_]]

"Ron Lee" > wrote in message
...
>
> The aircraft owners better wake up and read this stuff or they will be
> socked with an expensive mandate very soon.
>

I expect to be priced out of flying long before this happens.

Airport closings
Fuel Tax
Sales Tax
Excise Tax
Landing Fees
Fuel Transfer Fees
Parking Fees
Security Fees
Passenger Fees

Skyrocketing insurance
Unobtainable parts (carb floats)

Did I miss anything?

[Jose]

>>How do you know people are ignoring it?
> Presumably due to the dearth of comments that have been submitted.
> Have you visited the docket comment web site?

Maybe people just don't believe protesting will make any difference.
What ever happened to the thing on the DC FRZ and ADIZ? Last I saw
we're still saddled with it (albeit in a cosmetically altered form)
despite thousands of comments.

Jose
--
You can choose whom to befriend, but you cannot choose whom to love.
for Email, make the obvious change in the address.

[Newps]

Ron Lee wrote:

>
> The current Garmin unit is in the $8000-9000 range installed and may
> or may not meet the requirements of the NPRM. The FAA projected cost
> is around $17,000.


When transponders were first mandated the ones then on the market were
over $10,000, which is like $25-30K today.

[Newps]

It's a chicken and egg argument today. The system isn't up and running
yet except for the east coast. Now that the contract is let and the
specs are known or mostly known the various manufacturers will be
getting to work. How many times do you have to see this happen before
you believe it? Starting with about OSH 09 all this stuff will be all
the rage.

Larry Dighera wrote:

> On Tue, 11 Dec 2007 11:27:17 -0700, Newps > wrote:
>
>
>>More likely a much smaller cost.
>
>
> That's the second time you suggested that ADS-B equipage will be less
> than stated, but failed to provide any credible argument to support
> your polyandrist prediction.
>
> WHY do you think it will be cheaper? Is there anything tangible that
> leads you to that conclusion, or are you prescient, or what?
>
>

[Jon]

On Dec 12, 11:38 am, Newps > wrote:
> It's a chicken and egg argument today. The system isn't up and running
> yet except for the east coast.

<http://www.faa.gov/about/office_org/headquarters_offices/ato/
service_units/enroute/surveillance_broadcast/coverage/>

[Gig 601XL Builder]

Newps wrote:
> Ron Lee wrote:
>
>>
>> The current Garmin unit is in the $8000-9000 range installed and may
>> or may not meet the requirements of the NPRM. The FAA projected cost
>> is around $17,000.
>
>
> When transponders were first mandated the ones then on the market were
> over $10,000, which is like $25-30K today.

But how much were they when they were required in what is now A, B and C
airsapce?

[Jim Logajan]

"nobody" > wrote:
> I expect to be priced out of flying long before this happens.
>
> Airport closings
> Fuel Tax
> Sales Tax
> Excise Tax
> Landing Fees
> Fuel Transfer Fees
> Parking Fees
> Security Fees
> Passenger Fees
>
> Skyrocketing insurance
> Unobtainable parts (carb floats)
>
> Did I miss anything?

Use Tax
Rising maintenance costs
Hangar/tie-down costs
Increases in various FAA fees:
Registering an aircraft
Replacing an aircraft registration
Airman certificate
Replacement airman certificate
Issuance of airman medical certificate (in addition to examiner's fee)

I'm sure I missed some stuff too.

[Larry Dighera]

>Larry Dighera wrote:
>
>> On Tue, 11 Dec 2007 11:27:17 -0700, Newps > wrote:
>>
>>
>>>More likely a much smaller cost.
>>
>>
>> That's the second time you suggested that ADS-B equipage will be less
>> than stated, but failed to provide any credible argument to support
>> your polyandrist prediction.
>>
>> WHY do you think it will be cheaper? Is there anything tangible that
>> leads you to that conclusion, or are you prescient, or what?
>>
>>
On Wed, 12 Dec 2007 09:38:37 -0700, Newps > wrote:

>It's a chicken and egg argument today. The system isn't up and running
>yet except for the east coast. Now that the contract is let and the
>specs are known or mostly known the various manufacturers will be
>getting to work. How many times do you have to see this happen before
>you believe it? Starting with about OSH 09 all this stuff will be all
>the rage.
>

So you're implying that once the initial purchasers of the hardware
have paid for the engineering development costs, marketplace
competition and economy of scale will result in falling equipment
prices?

Even if that were to occur, it won'd do anything to reduce the cost of
the labor to install the mandatory equipment.

Have you any idea of the period of time (from the issuance of the
regulation to the commencement of issuance of administrative action
violations) that will be allotted for mandatory compliance with the
regulation promulgated by the NPRM?

If that time period is not too long, why wouldn't it behove
manufacturers to maintain inflated equipment prices, secure in the
knowledge that buyers have no choice but to purchase and install
before the deadline?

[Andrew Gideon]

On Wed, 12 Dec 2007 01:10:14 +0000, Larry Dighera wrote:

> Then the pilot would received useful information.

Perhaps I'm missing something, but there's nothing in the NPRM that
prevents ADS-B-in, right? So an owner can choose to pay more than the
minimum, get -in, and receive that benefit.

But the mandate of -out is required to achieve the full benefit of the -
in. And that's something of an economic annoyance: Anyone doing the
minimum investment is paying that investment for the benefit of others.

On the other hand, would we want to mandate that higher cost for both -in
and -out?

- Andrew

[Andrew Gideon]

On Wed, 12 Dec 2007 18:41:53 +0000, Larry Dighera wrote:

> If that time period is not too long, why wouldn't it behove
> manufacturers to maintain inflated equipment prices, secure in the
> knowledge that buyers have no choice but to purchase and install before
> the deadline?

That requires either monopoly or collusion. Otherwise, the vendors will
each undercut each other until the prices can't move any further.

Of course, that's in the ideal world. We do live there, right?

- Andrew

[[email protected]]

On Dec 12, 1:59 pm, Andrew Gideon > wrote:
> On Wed, 12 Dec 2007 18:41:53 +0000, Larry Dighera wrote:
> > If that time period is not too long, why wouldn't it behove
> > manufacturers to maintain inflated equipment prices, secure in the
> > knowledge that buyers have no choice but to purchase and install before
> > the deadline?
>
> That requires either monopoly or collusion. Otherwise, the vendors will
> each undercut each other until the prices can't move any further.
>
> Of course, that's in the ideal world. We do live there, right?

Actually the ideal world would be for the FAA to allow the equipment
makers to self-certify that their equipment meets the TSO specs if it
passed a simple standardized pass/fail operational test to be allowed
to be installed as a minor alteration to any general aviation aircraft
flown under Part 91 and participate in the ADS-B network. Then
equipment makers like Dynon, TruTrak, Blue Mountain and a host of
others who today only make computerized avionics for experimentals
could make low-cost ADS-B equipment for the whole GA fleet.

[Larry Dighera]

On Wed, 12 Dec 2007 19:56:17 +0000 (UTC), Andrew Gideon
> wrote:

>On Wed, 12 Dec 2007 01:10:14 +0000, Larry Dighera wrote:
>
>> Then the pilot would received useful information.
>
>Perhaps I'm missing something, but there's nothing in the NPRM that
>prevents ADS-B-in, right?

I can't confirm nor deny that.

>So an owner can choose to pay more than the
>minimum, get -in, and receive that benefit.

I understand what you're getting at, but your conclusion rests on the
necessity of the FAA implementing ADS-B IN. I haven't seen any
authoritative information that indicates that is actually going to
occur, have you?

>But the mandate of -out is required to achieve the full benefit of the -
>in.

Agreed. But the FULL BENEFIT of IN won't occur until the military is
included in the ADS-B picture. And it's completely unclear how the
NPRM will afford light GA operators any benefit at all for their
multi-thousand dollar mandatory investment and reduction in useful
load. That doesn't seem very equitable and balanced to me.

> And that's something of an economic annoyance: Anyone doing the
>minimum investment is paying that investment for the benefit of others.

Then perhaps it would be more equitable if the "others" funded it.

>On the other hand, would we want to mandate that higher cost for both -in
>and -out?

Until I become aware that the FAA intends to fund implementation of
ADS-B IN in the reasonably near future, I'd say that question is moot.

[Larry Dighera]

On Wed, 12 Dec 2007 19:59:27 +0000 (UTC), Andrew Gideon
> wrote:

>On Wed, 12 Dec 2007 18:41:53 +0000, Larry Dighera wrote:
>
>> If that time period is not too long, why wouldn't it behove
>> manufacturers to maintain inflated equipment prices, secure in the
>> knowledge that buyers have no choice but to purchase and install before
>> the deadline?
>
>That requires either monopoly or collusion.

You say that like it's an unreasonable possibility. :-(

>Otherwise, the vendors will
>each undercut each other until the prices can't move any further.

If the market is hot, and ADS-B equipment manufacturers are unable to
meet order demands, there won't be any reduction in pricing, IMO.
Given the aircraft operators' limited temporal window for compliance,
I can see prices remaining high until the deadline date passes.

[Dylan Smith]

On 2007-12-12, Larry Dighera > wrote:
> Because, I have visited the comment web site, and found a total of 58
> comments submitted in response to this NPRM. It's just a guess.

Especially considering in Britain we got well over 3,000 comments to the
CAA trying to force us all to have Mode-S in *all* airspace (including
Class G, which is the majority of our airspace - usually going up to
18000 ft.)

--
From the sunny Isle of Man.
Yes, the Reply-To email address is valid.