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

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