Just two days left to try to stop an expensive and worthless FAA mandate on ADS-B

[Ron Lee[_2_]]

Full details at:

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

Comments due by 3 March 2008. It does not have to be multiple pages.
Read some of the comments on pages 4-7 and a simple paragraph will
suffice.

Ron Lee

[Andrew Gideon]

On Sun, 02 Mar 2008 03:02:20 +0000, Ron Lee wrote:

> Full details at:
>
> http://stopads-b.org/ADS.htm

This document is incorrect in at least one way. It claims that there's
no benefit to GA because there's no mandated IN functionality. But this
proposal makes a benefit available to GA because of the mandated OUT
functionality.

A GA owner can choose to invest in ADS-B-IN. If the owner does so, the
pilot sees all traffic because of the mandated OUT functionality in all
those other aircraft. If there were no mandated OUT functionality, this
benefit would not be available to the GA pilot.

What is true is that this mandates the least possible cost w/o giving up
the aforementioned benefit. Personally, I *like* that. While the OUT
mandate is required for benefit to everyone, the IN benefit accrues only
to the owner/pilot. We should be free to choose that - or not -
ourselves since only we are impacted by this choice.

- Andrew

[Larry Dighera]

On Sun, 2 Mar 2008 18:14:59 +0000 (UTC), Andrew Gideon
> wrote in >:

>
>A GA owner can choose to invest in ADS-B-IN. If the owner does so, the
>pilot sees all traffic because of the mandated OUT functionality in all
>those other aircraft.

Unfortunately that is incorrect. Military aircraft will not be
equipped with ADS-B at all, and I'm not sure what the situation is
with aircraft that lack an electrical system. So while some benefit
may accrue to GA operators who choose to invest in ADS-B IN, it is
unclear if the FAA intends to immediately provide weather and other
services via ADS-B, but rest assured, that ALL aircraft will not be
depicted on ADS-B IN displays.

[Bob Noel]

In article >,
Andrew Gideon > wrote:

> A GA owner can choose to invest in ADS-B-IN. If the owner does so, the
> pilot sees all traffic because of the mandated OUT functionality in all
> those other aircraft. If there were no mandated OUT functionality, this
> benefit would not be available to the GA pilot.

exactly what is the cost of that benefit? Shouldn't the GA pilot
(alledgedly) benefiting from ADS-B Out not fund the equippage of
those aircraft with ADS-B Out?

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

[Andrew Gideon]

On Sun, 02 Mar 2008 21:23:12 -0500, Bob Noel wrote:

> In article >,
> Andrew Gideon > wrote:
>
>> A GA owner can choose to invest in ADS-B-IN. If the owner does so, the
>> pilot sees all traffic because of the mandated OUT functionality in all
>> those other aircraft. If there were no mandated OUT functionality,
>> this benefit would not be available to the GA pilot.
>
> exactly what is the cost of that benefit? Shouldn't the GA pilot
> (alledgedly) benefiting from ADS-B Out not fund the equippage of those
> aircraft with ADS-B Out?

Did you write "out" where you'd meant to write "in"? Otherwise, I'm
afraid that I'm not understanding your question.

GA pilots aren't funding equipment in other aircraft. They are, however,
funding the creation of a network in the air whereby all aircraft
(excluding military? Nasty, that!) are announcing their positions. It's
not all that different from transponders, in the sense that putting a
transponder in an aircraft benefits all aircraft, and not just the
aircraft footing the bill.

Separate from this, the GA owner can choose whether or not to spend the
extra dollars to gain direct benefit from this network.

- Andrew

[[email protected]]

Andrew Gideon > wrote:
> On Sun, 02 Mar 2008 21:23:12 -0500, Bob Noel wrote:

> > In article >,
> > Andrew Gideon > wrote:
> >
> >> A GA owner can choose to invest in ADS-B-IN. If the owner does so, the
> >> pilot sees all traffic because of the mandated OUT functionality in all
> >> those other aircraft. If there were no mandated OUT functionality,
> >> this benefit would not be available to the GA pilot.
> >
> > exactly what is the cost of that benefit? Shouldn't the GA pilot
> > (alledgedly) benefiting from ADS-B Out not fund the equippage of those
> > aircraft with ADS-B Out?

> Did you write "out" where you'd meant to write "in"? Otherwise, I'm
> afraid that I'm not understanding your question.

> GA pilots aren't funding equipment in other aircraft. They are, however,
> funding the creation of a network in the air whereby all aircraft
> (excluding military? Nasty, that!) are announcing their positions. It's
> not all that different from transponders, in the sense that putting a
> transponder in an aircraft benefits all aircraft, and not just the
> aircraft footing the bill.

> Separate from this, the GA owner can choose whether or not to spend the
> extra dollars to gain direct benefit from this network.

The problem with all this is the (currently) insane cost of the equipment.

If the cost of the required equipment were in the ballpark of a new
transponder and the optional equipment in the ballpark of a decent
handheld GPS, I doubt you would see much objection.

While the equipment costs will eventually probably fall to those levels,
the current outlook is about an order of magnitude greater than that,
which makes the cost a very significant fraction of the value of the
existing GA fleet.


--
Jim Pennino

Remove .spam.sux to reply.

[Jim Logajan]

Andrew Gideon > wrote:
> GA pilots aren't funding equipment in other aircraft. They are,
> however, funding the creation of a network in the air whereby all
> aircraft (excluding military? Nasty, that!)

I just did a quick scan of the DoD comments posted today (FAA-2007-29305-
0154.1) and it looks like they are complaining about the cost or
unlikelyhood of retrofitting some of their aircraft to be in compliance.
Hmmm.

> are announcing their
> positions. It's not all that different from transponders, in the
> sense that putting a transponder in an aircraft benefits all aircraft,
> and not just the aircraft footing the bill.

Nit: I'm not clear how transponders in two otherwise NORDO aircraft stops
either from bumping into each other. Or to what extent transponder (or ADS-
B Out) equipped aircraft prevent MACs near or at non-towered airports.

> Separate from this, the GA owner can choose whether or not to spend
> the extra dollars to gain direct benefit from this network.

My understanding is that if they want to fly VFR above 10,000 MSL they will
be required to have ADS-B Out. This is a _new_ cost requirement for using
that portion of the airspace - even to VFR flights. Not only is it a new
cost, it provides the VFR pilot no benefit. I believe that two fully
compliant ADS-B Out aircraft flying VFR in that space can still bump into
each other. Hence the conclusion by some (such as myself) that the mandate
costs and benefits are not equitable nor reasonable. (I also dislike the
technology because it relies on GPS.)

Anyway, finally got around to submitting my comments (hopefully in time).
They weren't terribly coherent or compelling, but what the heck.

[Ron Lee[_2_]]

>Did you write "out" where you'd meant to write "in"? Otherwise, I'm
>afraid that I'm not understanding your question.
>
>GA pilots aren't funding equipment in other aircraft. They are, however,
>funding the creation of a network in the air whereby all aircraft
>(excluding military? Nasty, that!) are announcing their positions. It's
>not all that different from transponders, in the sense that putting a
>transponder in an aircraft benefits all aircraft, and not just the
>aircraft footing the bill.

Incorrect. Without ADS-B In capability...or talking to ATC,
broadcasting ADS-B Out does nothing for you. Mode-C does just as
good.
>
>Separate from this, the GA owner can choose whether or not to spend the
>extra dollars to gain direct benefit from this network.

Do look into it and determine if the high cost is worth it to you. It
is not to me

Ron Lee
>
> - Andrew

[Ron Lee[_2_]]

>Nit: I'm not clear how transponders in two otherwise NORDO aircraft stops
>either from bumping into each other. Or to what extent transponder (or ADS-
>B Out) equipped aircraft prevent MACs near or at non-towered airports.
>
Without ADS-B In and a display...or talking to ATC....there is no
added ability to prevent a mid-air. That assumes ADS-B groujnd
reception of the ADS-B Out broadcast.

>> Separate from this, the GA owner can choose whether or not to spend
>> the extra dollars to gain direct benefit from this network.
>
>My understanding is that if they want to fly VFR above 10,000 MSL they will
>be required to have ADS-B Out. This is a _new_ cost requirement for using
>that portion of the airspace - even to VFR flights. Not only is it a new
>cost, it provides the VFR pilot no benefit. I believe that two fully
>compliant ADS-B Out aircraft flying VFR in that space can still bump into
>each other. Hence the conclusion by some (such as myself) that the mandate
>costs and benefits are not equitable nor reasonable. (I also dislike the
>technology because it relies on GPS.)
>
>Anyway, finally got around to submitting my comments (hopefully in time).
>They weren't terribly coherent or compelling, but what the heck.

Apparently you may need a GPS/WAAS (TSOd) receiver as well. Add in
that cost if you don't have one.

Ron Lee

[Andrew Gideon]

On Mon, 03 Mar 2008 18:31:05 +0000, Jim Logajan wrote:

> I just did a quick scan of the DoD comments posted today
> (FAA-2007-29305- 0154.1) and it looks like they are complaining about
> the cost or unlikelyhood of retrofitting some of their aircraft to be in
> compliance. Hmmm.

And those are real issues. I wish there was some magic wand to wave to
drop the price.

[...]
> Nit: I'm not clear how transponders in two otherwise NORDO aircraft
> stops either from bumping into each other. Or to what extent transponder
> (or ADS- B Out) equipped aircraft prevent MACs near or at non-towered
> airports.

You're right that the benefit is limited to the owner that chooses to do
the minimum. That's the bad side of this. But it's the "cost" of having
owners foot the bill for building this "network", I'm afraid.

One alternative to this would be to mandate -IN as well as -OUT. I'm
glad that that's not being done, in that it gives the owner more choice.
To my mind, the mandate covers the minimum necessary to build the network
that makes the benefits available to anyone taking the next step. W/o
the mandate, that benefit would be far more limited.

>> Separate from this, the GA owner can choose whether or not to spend the
>> extra dollars to gain direct benefit from this network.
>
> My understanding is that if they want to fly VFR above 10,000 MSL they
> will be required to have ADS-B Out. This is a _new_ cost requirement for
> using that portion of the airspace - even to VFR flights. Not only is it
> a new cost, it provides the VFR pilot no benefit.

That is true. But as I've written, this mandate is necessary so that the
benefit of ADS-B-IN be available. That's why I compare this to
transponders: it provides benefit to aircraft participating in
transponder-in (ie. taking to ATC {8^) but an aircraft can choose to not
participate.

- Andrew

[Andrew Gideon]

On Tue, 04 Mar 2008 04:22:52 +0000, Ron Lee wrote:

>>Separate from this, the GA owner can choose whether or not to spend the
>>extra dollars to gain direct benefit from this network.
>
> Do look into it and determine if the high cost is worth it to you. It
> is not to me

We did a survey in our club a while back regarding how the members (each
of whom is an owner, BTW) would like to see money spent on upgrades.
That is, is WX more or less important than traffic, etc.

WX was first (which shouldn't be a surprise). Traffic was #2. This was
a surprise to me given the raw numbers (ie. found in the Nall report).
But we do fly in a congested area, and one of our home airports has a
nontrivial history of nearby MACs.

We didn't weight the survey questions by price; that's probably our next
step. Tossing the price of ADS-B-IN into the mix may very well change
the ordering. But, just from idle chatter, I see that traffic really is
a big concern for us.

On the other hand, I believe that Zaon (?) has said that they'd be
releasing a portable ADS-B-IN based unit at some point. So the cost may
be far lower than what we're seeing today.

- Andrew

[Larry Dighera]

On Tue, 4 Mar 2008 16:11:30 +0000 (UTC), Andrew Gideon
> wrote in >:

>I believe that Zaon (?) has said that they'd be
>releasing a portable ADS-B-IN based unit at some point. So the cost may
>be far lower than what we're seeing today.

Would that portable ADS-B equipment meet the NPRM requirements?

[K l e i n]

On Mar 3, 9:22*pm, (Ron Lee) wrote:
> >Did you write "out" where you'd meant to write "in"? *Otherwise, I'm
> >afraid that I'm not understanding your question.
>
> >GA pilots aren't funding equipment in other aircraft. *They are, however,
> >funding the creation of a network in the air whereby all aircraft
> >(excluding military? *Nasty, that!) are announcing their positions. *It's
> >not all that different from transponders, in the sense that putting a
> >transponder in an aircraft benefits all aircraft, and not just the
> >aircraft footing the bill.
>
> Incorrect. *Without ADS-B In capability...or talking to ATC,
> broadcasting ADS-B Out does nothing for you. *Mode-C does just as
> good.

Seems to me that having ADS-B Out only does at least as much for me as
a Mode-C transponder, only better. A TCAS I or II equipped airplane
can see my mode-C and maybe able to avoid me without my even knowing
he's there. Sounds like a benefit to me. If I have ADS-B Out, the
ADS-B In equipped airplane will likewise be able to see me and avoid
hitting me - still a benefit, I think. He'll do a better job of
avoiding me in the ADS-B case because he won't be relying on
directional antenna technology to obtain my azimuth, but rather will
calculate the azimuth to me based on differencing the GPS positions -
a much more accurate calculation. Even if the other guy doesn't have
ADS-B In, but is IFR and talking to center, center will be able to
give much more accurate traffic information than they can with Mode-
C. Yet another benefit for me, even if I'm VFR and not talking to
ATC.

> >Separate from this, the GA owner can choose whether or not to spend the
> >extra dollars to gain direct benefit from this network. *
>
> Do look into it and determine if the high cost is worth it to you. *It
> is not to me

I think the cost estimates are totally bogus for the GA market. After
all, it's only a GPS and a transmitter.
I'd be surprised if a complete GA market ADS-B Out/In system couldn't
be done for a couple thou.

K l e i n

[Gig 601XL Builder[_2_]]

K l e i n wrote:

> I'd be surprised if a complete GA market ADS-B Out/In system couldn't
> be done for a couple thou.
>
> K l e i n

You must be kidding yourself. What's the lowest priced IFR certified
GPS? Add to that the lowest price transmitter which all so must be
certified. Add to that what ever needs to be certified to receive the IN
side and display it. Finally add in the cost to certify the whole
thing together. Then pay to install it all.

If any one comes out with a certified ADS-B Out/In for $40K I'll be
surprised. Half that for out only if we are lucky.

[K l e i n]

On Mar 4, 2:36*pm, Gig 601XL Builder >
wrote:
> K l e i n wrote:
>
> > I'd be surprised if a complete GA market ADS-B Out/In system couldn't
> > be done for a couple thou.
>
> > K l e i n
>
> You must be kidding yourself. What's the lowest priced IFR certified
> GPS? Add to that the lowest price transmitter which all so must be
> certified. Add to that what ever needs to be certified to receive the IN
> * side and display it. Finally add in the cost to certify the whole
> thing together. Then pay to install it all.

I'm talking mainly about the cost of ADS-B Out. That unit pretty much
has no user interface at all. Could be a lump that installs
anywhere. Who says it has to be a full blown WAAS IFR GPS? I just
bought a gadget called a SPoT that has a GPS receiver and a Globalstar
compatible transmitter. Cost $135. It has essentially all the
functionality needed for a ADS-B Out. It only needs to transmit on a
slightly different frequency at a somewhat higher power. Are saying
it has to be built with 1980's technology??

> If any one comes out with a certified ADS-B Out/In for $40K I'll be
> surprised. Half that for out only if we are lucky.

Do you think this has to cost 10 X as much as a Garmin 496? I don't.
I bet Garmin doesn't think so either. Maybe less than 1X496. An Out
only box could cost far less.

K l e i n

[Ron Lee[_2_]]

Larry Dighera > wrote:

>On Tue, 4 Mar 2008 16:11:30 +0000 (UTC), Andrew Gideon
> wrote in >:
>
>>I believe that Zaon (?) has said that they'd be
>>releasing a portable ADS-B-IN based unit at some point. So the cost may
>>be far lower than what we're seeing today.
>
>Would that portable ADS-B equipment meet the NPRM requirements?

I doubt it since the NPRM only discusses ADS-B Out. To that end, you
apparently need a TSOd GPS/WAAS receiver which will not be portable.

Andrew, if your club folks want weather, buy a 396/496 with XM
weather. Rent it out when people need it. Get a Zaon for traffic.
All that they want is available right now. ADS-B is not the answer.

Ron Lee


>

[Ron Lee[_2_]]

>
>I'm talking mainly about the cost of ADS-B Out. That unit pretty much
>has no user interface at all. Could be a lump that installs
>anywhere. Who says it has to be a full blown WAAS IFR GPS? I just
>bought a gadget called a SPoT that has a GPS receiver and a Globalstar
>compatible transmitter. Cost $135. It has essentially all the
>functionality needed for a ADS-B Out. It only needs to transmit on a
>slightly different frequency at a somewhat higher power. Are saying
>it has to be built with 1980's technology??

The specs mentioned in the NPRM can only be met with a GPS/WAAS unit
and I am assuming TSOd (in the panel unit).


>> If any one comes out with a certified ADS-B Out/In for $40K I'll be
>> surprised. Half that for out only if we are lucky.
>
>Do you think this has to cost 10 X as much as a Garmin 496? I don't.
>I bet Garmin doesn't think so either. Maybe less than 1X496. An Out
>only box could cost far less.

Ok, lets say it is JUST $10,000 US for the GPS/WAAS receiver and ADS-B
Out unit installed (may be much higher). It is not worth it to me
when Mode-C provides adequate surveillance. PLus for YOU to benefit
you have to talk to ATC (if they have coverage). Most people I know
don't talk to ATC.

Ron Lee

[Larry Dighera]

On Tue, 4 Mar 2008 12:34:43 -0800 (PST), K l e i n
> wrote in
>:

>I think the cost estimates are totally bogus for the GA market. After
>all, it's only a GPS and a transmitter.
>I'd be surprised if a complete GA market ADS-B Out/In system couldn't
>be done for a couple thou.

Garmin sells hand-held GPSs for more than a couple of thousand
dollars, and they don't require any installation labor.

[Gig 601XL Builder[_2_]]

K l e i n wrote:
> On Mar 4, 2:36 pm, Gig 601XL Builder >
> wrote:
>> K l e i n wrote:
>>
>>> I'd be surprised if a complete GA market ADS-B Out/In system couldn't
>>> be done for a couple thou.
>>> K l e i n
>> You must be kidding yourself. What's the lowest priced IFR certified
>> GPS? Add to that the lowest price transmitter which all so must be
>> certified. Add to that what ever needs to be certified to receive the IN
>> side and display it. Finally add in the cost to certify the whole
>> thing together. Then pay to install it all.
>
> I'm talking mainly about the cost of ADS-B Out. That unit pretty much
> has no user interface at all. Could be a lump that installs
> anywhere. Who says it has to be a full blown WAAS IFR GPS? I just
> bought a gadget called a SPoT that has a GPS receiver and a Globalstar
> compatible transmitter. Cost $135. It has essentially all the
> functionality needed for a ADS-B Out. It only needs to transmit on a
> slightly different frequency at a somewhat higher power. Are saying
> it has to be built with 1980's technology??
>
>> If any one comes out with a certified ADS-B Out/In for $40K I'll be
>> surprised. Half that for out only if we are lucky.
>
> Do you think this has to cost 10 X as much as a Garmin 496? I don't.
> I bet Garmin doesn't think so either. Maybe less than 1X496. An Out
> only box could cost far less.
>
> K l e i n
>

While that may be what you think you are talking about you specifically
wrote, "I'd be surprised if a complete GA market ADS-B Out/In system
couldn't be done for a couple thou." But that's OK.

Well what makes you think it isn't going to have to be certified to at
least the level of a TSOd GPS? And what do you think the 496 would cost
if it were certified?

[[email protected]]

Ron Lee > wrote:
> Larry Dighera > wrote:

> >On Tue, 4 Mar 2008 16:11:30 +0000 (UTC), Andrew Gideon
> > wrote in >:
> >
> >>I believe that Zaon (?) has said that they'd be
> >>releasing a portable ADS-B-IN based unit at some point. So the cost may
> >>be far lower than what we're seeing today.
> >
> >Would that portable ADS-B equipment meet the NPRM requirements?

> I doubt it since the NPRM only discusses ADS-B Out. To that end, you
> apparently need a TSOd GPS/WAAS receiver which will not be portable.

Which is one of the main reasons the price tag is so high.

A more sensible approach would be to allow equipment classed like
handheld GPS for those that aren't going to be doing approaches into
Class B at minimums, but that isn't the proposal.

--
Jim Pennino

Remove .spam.sux to reply.

[[email protected]]

Larry Dighera > wrote:
> On Tue, 4 Mar 2008 12:34:43 -0800 (PST), K l e i n
> > wrote in
> >:

> >I think the cost estimates are totally bogus for the GA market. After
> >all, it's only a GPS and a transmitter.
> >I'd be surprised if a complete GA market ADS-B Out/In system couldn't
> >be done for a couple thou.

> Garmin sells hand-held GPSs for more than a couple of thousand
> dollars, and they don't require any installation labor.

And a Mr Coffee goes for $9.99 at Walmart, neither of which will meet
the requirements of ADS-B as proposed.

What it SHOULD cost, if the proposal were sensible and allowed for
non-TSO handheld equipment, and what it WILL cost given the current
proposal requirements are two different things.


--
Jim Pennino

Remove .spam.sux to reply.

[K l e i n]

On Mar 4, 4:25*pm, wrote:
> Larry Dighera > wrote:
> > On Tue, 4 Mar 2008 12:34:43 -0800 (PST), K l e i n
> > > wrote in
> > >:
> > >I think the cost estimates are totally bogus for the GA market. *After
> > >all, it's only a GPS and a transmitter.
> > >I'd be surprised if a complete GA market ADS-B Out/In system couldn't
> > >be done for a couple thou.
> > Garmin sells hand-held GPSs for more than a couple of thousand
> > dollars, and they don't require any installation labor.
>
> And a Mr Coffee goes for $9.99 at Walmart, neither of which will meet
> the requirements of ADS-B as proposed.
>
> What it SHOULD cost, if the proposal were sensible and allowed for
> non-TSO handheld equipment, and what it WILL cost given the current
> proposal requirements are two different things.

I read the requirements a little more carefully, and it is true that
ADS-B Out, as currently specified must be WAAS, etc. My bad.
However, eventually the FAA will figure out that it is in everybody's
best interest for low-cost units to become available, especially, for
the sport/antique/glider/etc community that has no way to install a
fully compliant unit. The FLARM being sold into European glider
community does all the "important" functions of ADS-B Out/In for
enabling collision avoidance at the $1000 cost level. Works about the
same too, except for lower power Out transmission. People buying
Cirrus and above aircraft will have no problem with the $10,000 cost
level. Garmin will be happy to serve them. FLARM and ZAON, etc will
be happy to serve the kilobuck market.

K l e i n

[Larry Dighera]

On Tue, 04 Mar 2008 23:25:04 GMT, wrote in
>:

>Larry Dighera > wrote:
>> On Tue, 4 Mar 2008 12:34:43 -0800 (PST), K l e i n
>> > wrote in
>> >:
>
>> >I think the cost estimates are totally bogus for the GA market. After
>> >all, it's only a GPS and a transmitter.
>> >I'd be surprised if a complete GA market ADS-B Out/In system couldn't
>> >be done for a couple thou.
>
>> Garmin sells hand-held GPSs for more than a couple of thousand
>> dollars, and they don't require any installation labor.
>
>And a Mr Coffee goes for $9.99 at Walmart, neither of which will meet
>the requirements of ADS-B as proposed.
>

My point was, that Mr. Klein's assertion was inconsistent with the
pricing of far less capable, non-certified equipment.

>What it SHOULD cost, if the proposal were sensible and allowed for
>non-TSO handheld equipment, and what it WILL cost given the current
>proposal requirements are two different things.

Because the DoD sees this NPRM as a means of surveiling aircraft
operations, and seems to be dictating the wording to FAA, it's unclear
if the equipment you suggest will be considered.

[Bob Noel]

In article >,
Larry Dighera > wrote:

> Because the DoD sees this NPRM as a means of surveiling aircraft
> operations, and seems to be dictating the wording to FAA, ...

eh? That's the first I've heard of that. Why do you think that the
DOD is pushing any aspect of ADS-B? (I hope you have more
than the Alaska demo with ADS-B)

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

[Ron Lee[_2_]]

>
>I read the requirements a little more carefully, and it is true that
>ADS-B Out, as currently specified must be WAAS, etc. My bad.
>However, eventually the FAA will figure out that it is in everybody's
>best interest for low-cost units to become available, especially, for
>the sport/antique/glider/etc community that has no way to install a
>fully compliant unit. The FLARM being sold into European glider
>community does all the "important" functions of ADS-B Out/In for
>enabling collision avoidance at the $1000 cost level. Works about the
>same too, except for lower power Out transmission. People buying
>Cirrus and above aircraft will have no problem with the $10,000 cost
>level. Garmin will be happy to serve them. FLARM and ZAON, etc will
>be happy to serve the kilobuck market.
>
>K l e i n

You have more faith in the FAA than I do. Have you read the NPRM?
You may be right about Cirrus buyers but what if the cost to a Cessna
owner is over $20,000 USD? This NPRM apparently was not vetted with
the stakeholders prior to release.

After learning more about it I am not sure that UAT is even
needed....and the weather and traffic elements from this system may
also be unneeded system drivers.

My current guess is that retaining Mode-C for GA (perhaps expanding
the equipage if a worthwhile mid-air risk reduction can be proven) is
adequate.

Find a way to reduce the cost of XM weather. Ga folks who want
enhanced traffic detection can use flight following/traffic advisory
services from ATC and/or get a system such as offered by Zaon or
Monroy.

If the airlines, air taxi folks, cargo, etc want ADS-B...go for it.
They are assuming capacity improvements when the NPRM does not
guarantee that separation standards will happen.

Ron Lee

[Gig 601XL Builder[_2_]]

K l e i n wrote:

> However, eventually the FAA will figure out that it is in everybody's
> best interest for low-cost units to become available, especially, for
> the sport/antique/glider/etc community that has no way to install a
> fully compliant unit.

Good God! What makes you think that is the case? When has the FAA EVER
reduced the certification requirements of a piece of installed
equipment? I doubt anyone would argue that a pilot with 496 with WX is
in a better position to fly cross country IFR than the same pilot with
nothing other than an old VOR receiver and CDI. But only one of those is
legal for IFR flight.

[Larry Dighera]

On Wed, 05 Mar 2008 04:21:38 -0500, Bob Noel
> wrote in
>:

>Why do you think that the DOD is pushing any aspect of ADS-B?

Because of the tone of their NPRM comment to the FAA. Have you read
it?
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064803e52f6&disposition=attachment&contentType=pdf

[Andrew Gideon]

On Tue, 04 Mar 2008 22:37:12 +0000, Ron Lee wrote:

>>Would that portable ADS-B equipment meet the NPRM requirements?
>
> I doubt it since the NPRM only discusses ADS-B Out.

And the Zaon solution, as I understand, is only -In. So this doesn't
address the mandate. But what it does do is lower the bar for those that
want to get the benefit made available by the mandate.

[...]

> Andrew, if your club folks want weather, buy a 396/496 with XM weather.

That's where we're heading. We actually tried to do this concurrent with
our first WAAS upgrades, but a combination of a busy shop and the first
aircraft being a "problem" (where to put the portable GPS with a full
panel and an emergency gear extension lever on the floor {8^) has pushed
this back a bit.

> Rent it out when people need it.

We did discuss this, but it has a number of logistic issues. First,
we're spread over two airports. Second, we have no "facility" (ie. a
club house) where to store the units. So the consensus right now is to
simply perform semi-permanent installs in the fleet.

Any suggestions for alternatives are very welcome, however.

> Get a Zaon for traffic. All that they
> want is available right now. ADS-B is not the answer.

The problem with current traffic solutions, from my perspective, is the
very limited space in which they can be trusted to operate. One of our
airports, for example, is largely shadowed by local geography from the
nearest RADAR. So too close to the airport - a place where traffic would
be quite nice <grin>! - means no transponder-based traffic.

However, the price of the Zaon units is low enough that we may invest
today even knowing that we'll probably want to replace these with ADS-B
based units at some point in the (not too nearby) future.

- Andrew

[Ron Lee[_2_]]

Andrew Gideon > wrote:

>On Tue, 04 Mar 2008 22:37:12 +0000, Ron Lee wrote:
>
>>>Would that portable ADS-B equipment meet the NPRM requirements?
>>
>> I doubt it since the NPRM only discusses ADS-B Out.
>
>And the Zaon solution, as I understand, is only -In. So this doesn't
>address the mandate. But what it does do is lower the bar for those that
>want to get the benefit made available by the mandate.
>
What it does is allow improved traffic detection based upon what GA
aircraft already have in their aircraft (Mode-C). ADS-B Out adds
nada.
>
>> Get a Zaon for traffic. All that they
>> want is available right now. ADS-B is not the answer.
>
>The problem with current traffic solutions, from my perspective, is the
>very limited space in which they can be trusted to operate. One of our
>airports, for example, is largely shadowed by local geography from the
>nearest RADAR. So too close to the airport - a place where traffic would
>be quite nice <grin>! - means no transponder-based traffic.
>
>However, the price of the Zaon units is low enough that we may invest
>today even knowing that we'll probably want to replace these with ADS-B
>based units at some point in the (not too nearby) future.

A Zaon, or Monroy type system supplements see and avoid should you
elect to get such a system. There is NO evidence that the ADS-B
solution will provide close to 100% coverage at GA pattern altitudes
although I have asked the FAA to provide that information.

Plus...if you read and understand the NPRM and read my comments, ADS-B
Out only has the potential to improve traffic issues IF....big
IF...people equip with ADS-B In or talk to ATC.

I suspect that the high cost of ADS-B equipage will keep its
implementation rate in GA aircraft at well under 10% which is far less
than Mode C (about 85% I think).

Read the NPRM (and comments.) It is bad.

I don't suggest that you not buy ADS-B. Buy whatever you want. But
for most GA pilots it is too costly and provides no benefits as far as
this NPRM goes.

The whole ideal behind GA benefits from ADS-B In appears at this time
to be pointless given Zaon/Monroy systems and XM (or equivalent)
weather.

Ron Lee