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

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.

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

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