Two weeks to comment...or lose $17,000 USD

[Ron Lee[_2_]]

Comment against the ADS-B Out NPRM or you will have to waste up to
$17,000 on a useless piece of avionics

http://stopads-b.org/ADS.htm

Ron Lee

[Larry Dighera]

On Sat, 16 Feb 2008 16:12:11 GMT, (Ron Lee)
wrote in >:

>Comment against the ADS-B Out NPRM or you will have to waste up to
>$17,000 on a useless piece of avionics
>
>http://stopads-b.org/ADS.htm
>
>Ron Lee

It would seem that there is about a 12 hour deficit in our comment
period:

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[BakedandFried]

"Ron Lee" > wrote in message
...
> Comment against the ADS-B Out NPRM or you will have to waste up to
> $17,000 on a useless piece of avionics
>
> http://stopads-b.org/ADS.htm
>
> Ron Lee

Prove it, dickhead.

[Jim Logajan]

"BakedandFried" > wrote:
> "Ron Lee" > wrote:
>> Comment against the ADS-B Out NPRM or you will have to waste up to
>> $17,000 on a useless piece of avionics
>>
>> http://stopads-b.org/ADS.htm
>>
>> Ron Lee
>
> Prove it, dickhead.

He has a link on that web page to a document where attempts to do just
that.

So how's the trolling going?

[[email protected]]

On Feb 16, 6:32 pm, Jim Logajan > wrote:
> "BakedandFried" > wrote:
> > "Ron Lee" > wrote:
> >> Comment against the ADS-B Out NPRM or you will have to waste up to
> >> $17,000 on a useless piece of avionics
>
> >>http://stopads-b.org/ADS.htm
>
> >> Ron Lee
>
> > Prove it, dickhead.
>
> He has a link on that web page to a document where attempts to do just
> that.
>
> So how's the trolling going?

Well...you're one for one so far. But I'm hopeful you'll do better
soon.

Love,
Your Mom.

[Mike Isaksen]

....
"Ron Lee" wrote in message ...
> Comment against the ADS-B Out NPRM or you will have to
> waste up to $17,000 on a useless piece of avionics.
> http://stopads-b.org/ADS.htm

Done! Thanks for the reminder Ron.

We are already over-regulated, and to think that the FAA will further reach
into my pocket in their effort to cost-shift the burden of maintaining their
antiquated radar facilities is unacceptable. If the traffic increase is as
they forecast, I fully expect to hear more and more ATC replies like: "VFR
flight following unavailable" or "unable,... what're your intentions?"

I'll be damned if I pay for boxes that benefit them, and it'll actually
reduce my services.

[Larry Dighera]

On Sat, 16 Feb 2008 16:12:11 GMT, (Ron Lee)
wrote in >:

>Comment against the ADS-B Out NPRM or you will have to waste up to
>$17,000 on a useless piece of avionics
>
>http://stopads-b.org/ADS.htm
>
>Ron Lee


Here's my comment:



Docket ID FAA-2007-29305
Docket Title ADSB Out Performance Requirements to Support ATC
Document ID FAA-2007-29305-0002
Document Title Automatic Dependent Surveillance--Broadcast (ADS-B)
Out Performance Requirements To Support Air Traffic Control (ATC)
Service



Sirs:

This NPRM imposes a severe financial hardship on General Aviation
operators without providing anything close to commensurate benefits.
Many GA aircraft are valued at less than the cost of equipping them
with the equipment that would be required by this NPRM. Because the
equipment proposed in this NPRM only provides for one-way transmission
of flight positional data to ATC, it offers the pilot NONE of the
potential benefits of a full ADS-B system such as weather information,
and conflicting traffic information.


Inequity:
---------
Clearly this NPRM was drafted to benefit the air carriers, who already
have GPS and Mode S transponders installed in their aircraft, and ATC
surface surveillance and control. If this inequitable NPRM should be
enacted, it will price a significant percentage of the GA fleet out of
the skies. There are only about 19,382 US air carrier aircraft, or
about 11% of the 219,780 GA aircraft fleet, so GA will be funding 89%
of this NPRM which largely benefits airline operations at hub
airports.


Military Exempt:
----------------
As there is no plan in this NPRM to implement ADS-B for military
aircraft, so they will remain largely invisible to ATC, the airlines,
and GA. Clearly this NPRM is not only inequitable in the burden it
imposes on GA operators, but it is fundamentally flawed in it failure
to address ALL aircraft operating in the National Airspace System.


Vulnerability:
--------------
Because ADS-B is a satellite-based system, it is vulnerable to solar
activity. It is well known that solar flairs and coronal mass
ejections are capable of rendering satellite based communications
inoperable. Imagine the potential chaos that would ensue if all air
traffic control in the NAS were dependent on ADS-B, and it were
rendered useless by a solar storm, and the existing FAA radars were
decommissioned!

Further, the ADS-B system relies upon the aircraft's onboard GPS
equipment and Mode S transponder for aircraft positional information
that is broadcast to ATC. This is a fundamental difference from the
current system of ground-based radars that relies solely on the laws
of physics for aircraft positional information. This difference
introduces the possibility of rogue aircraft spoofing the system by
broadcasting erroneous ADS-B positional information. This is
considerably more difficult when radar is employed for confirming the
position air traffic.

Further, the current radar based ATC system is decentralized, as the
radars are located in many installations throughout the country. In
the event of an equipment failure, only the area served by the
nonfunctioning radar is impacted. In the case of ADS-B, there is
considerably less system tolerance for equipment failures, and there
are single points of failure that can bring the entire system down.


Trading Proven Technology For Unproven:
--------------------------------------
If the current radars are to be decommissioned in favor of replacement
with ADS-B technology, there will be precious little equipment that
the FAA can employ to verify the true position of aircraft, and in the
event of solar disruption of the ADS-B system, there will be no other
system available for ATC.


Summary:
--------
So, if the current ADS-B OUT NPRM is enacted, GA (89%) will have to
install 219,780 ADS-B units at a projected cost of up to $17,000.00
each, and receive none of the ADS-B IN benefits such as air traffic
depiction and weather information. The sole advantage will be ATC's
positional information of GA aircraft in areas lacking radar coverage,
and on the ground. The NPRM does not address military operation, nor
solar communications disruptions, not the loss of verifiability
provided by existing radars, and it would abandon existing proven
technology. If a private corporation were to attempt to market a
product with such an unfavorable price/performance ratio, it would be
a complete failure.

Best regards,
Larry Dighera

[Ron Lee[_2_]]

Larry, that is an excellent comment. That is why having many people
provide their viewpoints is so imporatnt since I do see all the
problems with this NPRM.

There is only one nit with your summary:

>Summary:

> The sole advantage will be ATC's positional information of GA aircraft
> in areas lacking radar coverage, and on the ground.

My discussions with FAA ADS folks is that the currently planned
coverage for ADS-B ground units is only to meet the same coverage
provided by radars today. Thus there will be no improvement in the
mountain areas and many places in the USA just a thousand or so feet
AGL.

One concern I have is that the NPRM, if changed, may be to force
complete ADS-B (In and Out) functionality. That will make it more
expensive for thinsg that I do not need. I have terrain awareness in
my GNS 430W and may turn it off since it is a nuisance flying in the
mouyntains.

Weather...I can get a 496 if I really need real time weather. I have
done fine without it so far. Either use Flight Service or land and
get updates.

Ron Lee

[Larry Dighera]

On Sat, 23 Feb 2008 18:09:58 GMT, (Ron Lee)
wrote in >:

>
>Larry, that is an excellent comment.

Thank you. One of the readership of this newsgroup was kind enough to
point out a misspelling, and I'm sure there are other issues with my
comment given my limited research into the subject, but thanks for the
kind words.

>That is why having many people provide their viewpoints is so imporatnt
>since I do see all the problems with this NPRM.
>
>There is only one nit with your summary:
>
>>Summary:
>
>> The sole advantage will be ATC's positional information of GA aircraft
>> in areas lacking radar coverage, and on the ground.
>
>My discussions with FAA ADS folks is that the currently planned
>coverage for ADS-B ground units is only to meet the same coverage
>provided by radars today. Thus there will be no improvement in the
>mountain areas and many places in the USA just a thousand or so feet
>AGL.

That is disappointing. I was hoping there might be a chance of ADS-B
assisting in separating high-speed low-level military aircraft
operating on MTRs from GA flights, or other GA aircraft operating
below current radar coverage in remote areas.

My gut feeling is, that this NPRM is an attempt to address the runway
incursion issue, and that ADS-B information would be used to augment
or replace radar information about the location of aircraft on the
airport surface.

>
>One concern I have is that the NPRM, if changed, may be to force
>complete ADS-B (In and Out) functionality. That will make it more
>expensive for thinsg that I do not need.

Can you imagine the FAA proposing a NPRM mandating ADS-B IN and OUT at
a cost that exceeds the value of 50% of the aircraft in the GA fleet?
They are going to have to find a less expensive solution, or face a
revolt, IMO.

[Ron Lee[_2_]]

>My gut feeling is, that this NPRM is an attempt to address the runway
>incursion issue, and that ADS-B information would be used to augment
>or replace radar information about the location of aircraft on the
>airport surface.

I don't know what the plan is. The NTSB comment sounds like it may
agree with your point however I don't see ADS-B Out only solving that
problem. If you are correct, that is just another reason why it may
only help the airlines and the FAA.

Ron Lee