Looking for feedback on proposed Open Letter on the 2020 ADSB-Out Mandate

[lolachampcar]

I've gotten swallowed up by the ADSB-Out Mandate Monster and did a little therapeutic writing to ease the pain.

I'd be curious for feedback from the community. Should I go looking for a "letters to the editor" forum for this?

Thanks,
Bill

Can GA Turn the 2020 ADSB-Out Mandate Around?

I fly both Experimental and Certified aircraft. My experimental aircraft has full ADSB in and out capabilities which leads me to feel that NexGen and ADSB is one of the most important things the FAA has done in forty years. However, my experience with my certified aircraft has me concerned that GA may never see the benefits of NextGen or ADSB.

A friend sent me a quick news clipping on Michael Whitaker’s testimony before the committee headed by Senators Ayotte and Cantwell. I went online to view the testimony as sometimes news outlets can provide a less than accurate account. In short, Mr. Whitaker was brought before the committee to represent the FAA’s view of a an inspector’s general report detailing failings in the implementation of NextGen and the ADSB component of NextGen. Mr. Whitaker’s response was simply that the FAA was doing its part, there were 140,000 N number aircraft subject to the 2020 ADSB-Out mandate and that “industry” needed to step up to the plate and do its’ part and get equipment installed in these aircraft. He went on to say something like 140 aircraft a day need to be done but only 100 per month were having ADSB-Out installed. To paraphrase a line from one of my favorite movies, it was obvious to me that what we have here is a failure to lead. Mr. Whitaker also emphatically stated that the mandate would not slip.

I’m an old operations guy so my take on running a project is that management’s job is to remove the obstacles that prevent people from doing their jobs. It is management’s job to identify obstacles. It seems clear to me that tossing a mandate over the wall to “industry” and expecting them to deal with it will have one of two outcomes. The first and most likely for me is that GA will slowly become aware of the need to spend well over $5K per aircraft to equip them with ADSB-Out to meet the mandate. Someone will start promoting that the only benefit will be to let big brother know exactly where you are along with your tail number. This will lead to a ground swell of complaints to our representatives followed by a push of the mandate or even its demise as currently envisioned. The second less likely alternative is that 2020 comes and a vast majority of GA is grounded. Neither of these options should be acceptable, especially when we have five years to work on the issue.

There is a lot going on with ADSB-Out and a lot of good reasons for all the caution in how the systems are designed and installed. I’ll focus here only on the core goal of fulfilling the ADSB-Out mandate in a sensible way and one that is in the public’s best interest.

If I were responsible for implementing the Mandate, I would recognize that pricing is the single largest barrier to my getting GA to go along with this whole idea. Given that price will stop me dead in my tracks I would make solving that problem my top priority.

ADSB is a good idea for GA, industry, ATC and the population as a whole so this is what I would do to get GA to move (remembering that GA is a vast majority of the aircraft flying around and that, without them, NextGen does not work)-
(1)
Work with industry to generate a general transponder specification that meets all the functional requirements of ADSB-out. This device would include Mode S-ES, GPS position in a separate inclusive antenna/receiver, dual pressure transducers for both pitot/static lines (automated ground/air determination) OR GPS based Ground/Air determination as used by Garmin, UAT receiver for ADSB-In and WiFi server for support of external equipment.
(2)
Work with Congress to provide a liability shield for manufacturers such that their liability for compliant equipment is limited to the cost of the equipment.
(3)
Allocate a portion of the FAA funding to establishing a compliance testing facility staffed by FAA employees whose task is to aid manufacturers in producing compliant product. This would be offered as a no charge service to any manufacturer.
(4)
Produce a working group within the compliance division of the FAA to generate generalized installation guidelines such that any A&P can install this equipment. This group would also produce test procedures for both ATC and the A&P such that installed system performance can be verified and monitored on an ongoing basis for continued airworthiness (akin to the current 24 month transponder test but without the need for a certified avionics shop). Given the automated nature of NextGen, this could likely be done by the A&P or IA logging onto a FAA server to enable a test flight then documenting the results of that test flight in surveilled airspace. If it is easy enough, it could be included in annual and 100 hour inspections effectively halving the current time between transponder checks.

The above would result in sub thousand dollar installs of fully ADSB-in/out compliant equipment with the added benefits that anyone with an IPad or similar device will have access to in cockpit accurate moving map position, weather reports, composite Nexrad radar and, what I find most important, accurate traffic. AOPA and EAA would get behind this in an instant actually helping the FAA meet the Mandate as opposed to what I believe they will eventually end up doing and that is fighting it.

 

[John Collins]

Most of what you propose will not reduce the cost of the equipment.
(1) Has already been done and the transponder route is not the least expensive in comparison to the UAT route.
(2) This won't solve anything as the reason for entrance is not a liability issue, it is the cost of obtaining compliance, much of which is unnecessary. For example, the FAA is forcing all manufacturers other than Garmin to request a piecemeal AML for installation. There is absolutely no rationale for this and simply adds to costs and slows down installation. The fact that these same units may be installed by field approval, as long as the same components are used and wired in the same way, totally undermines the FAA argument that each aircraft make and model has to be individually verified.
(3) This is done now. I am not aware of any FAA charges for processing the STC and performing any tests, most of that is borne by the manufacturer that submits their own test results.
(4) Right now avionics shops are not trained nor do they have the test equipment to verify the installations. Most don't RTFM. The equipment can be installed today by an appropriately rated airframe mechanic and signed off by an IA. They are even less likely as a group to do it correctly. From the FAA section that checks compliance, it is reported that 80% of the installations flying today (just over 4000) are not compliant in one way or another. BYW, an iPad with ForeFlight and a Stratus will display all of the configuration data and indicate compliance. Approved equipment to do the same job is at least a $6000 piece of add on test equipment which most shops don't have.

One thing that would go a long way to reduce the angst regarding ADS-B for aircraft that are not economical to install ADS-B equipment IMHO would be to provide some limited regulatory relief for aircraft operating below a class B shelf or in the 30 NM Class B shield. I would propose eliminating the requirement in this airspace when at or below 2500 AGL. The transponder mode C would remain as it is today, so these aircraft would still show up as TISB to participating aircraft.

 

[petrolero]

One thing that would go a long way to reduce the angst regarding ADS-B for aircraft that are not economical to install ADS-B equipment IMHO would be to provide some limited regulatory relief for aircraft operating below a class B shelf or in the 30 NM Class B shield. I would propose eliminating the requirement in this airspace when at or below 2500 AGL. The transponder mode C would remain as it is today, so these aircraft would still show up as TISB to participating aircraft.

They would show up as long as they are in radar coverage which they likely would be if under a Class B shelf - or if they get pinged by an aircraft with active traffic.

That would mean they are highly likely to be in some form of coverage and thus would show up on TIS-B. This seems like a workable exception.

 

[lolachampcar]

I may not have been clear on (1) and it has not been done.

One consists of defining an ADSB-Out solution that consists of S-ES AND TSO'd GPS puck (ala Dynon Skyview), UAT ADSB-In receiver and Wifi server. The least expensive would be for the spec to allow ground/air via GPS instead of what most of the rest of the world (not Garmin) is having to do using a dual port pressure switch on pitot/static. The goal is a set of devices that will meet the mandate AND provide value to the GA owner.

Item 2 may or may not be an issue. I have not produced TSO'd equipment but the two explanations you routinely hear for why aircraft stuff is an order of magnitude (slight exaggeration) more than it should be is the two non-value cost adders liability and compliance. Item 2 addresses liability removing it as an excuse.

3 is not done now and requires the FAA to fund a compliance lab with all necessary testing equipment and to staff it with FAA employed technicians and engineers. Their charter is to work WITH manufacturers to identify and solve compliance related issues. Test early prototypes and identify changes that need to be made to meet the spec. Participate in the process. The FAA most certainly does not do this now. I'm in the process of getting a field approval for an Out solution and I can assure you I am getting NO help from anyone at the FAA.

I'm not sure where you were heading with item 4 but I too see avionics shops as a gate. If everyone has to do this, then I think we need a system by which the owner can work with an A&P to comply. Validation should be done by airborne servalance verification by test flight and WITHOUT an avionics shop involved. If this is done correctly, it could be part of the annual. Avionics shops only become involved in the process if there is an issue (and after either the GPS or Txp box has been swapped out by the A&P).

Your last point is, by default, where we will likely end up if we do not change path. There will be carve outs for GA.

I would prefer that the technology be made affordable and doable such that all GA owners will be clamoring to get the update. The system will be safest when everyone participates.

I am not saying the above is easy nor is it a fully vetted solution. By the same token, I can buy a 10 Hz WAAS enabled GPS engine for $25 from SparkFun in quantity 1 and I've looked inside the Trig S-ES remote transponder housing. There is hardly $120 worth of effort in that housing at current volumes and significantly less when you consider the volumes necessary to equip GA. Any other money spent on compliance needs to be justified or removed from the equation.

 

[John Collins]

I may not have been clear on (1) and it has not been done.

One consists of defining an ADSB-Out solution that consists of S-ES AND TSO'd GPS puck (ala Dynon Skyview), UAT ADSB-In receiver and Wifi server. The least expensive would be for the spec to allow ground/air via GPS instead of what most of the rest of the world (not Garmin) is having to do using a dual port pressure switch on pitot/static. The goal is a set of devices that will meet the mandate AND provide value to the GA owner.

Item 2 may or may not be an issue. I have not produced TSO'd equipment but the two explanations you routinely hear for why aircraft stuff is an order of magnitude (slight exaggeration) more than it should be is the two non-value cost adders liability and compliance. Item 2 addresses liability removing it as an excuse.

3 is not done now and requires the FAA to fund a compliance lab with all necessary testing equipment and to staff it with FAA employed technicians and engineers. Their charter is to work WITH manufacturers to identify and solve compliance related issues. Test early prototypes and identify changes that need to be made to meet the spec. Participate in the process. The FAA most certainly does not do this now. I'm in the process of getting a field approval for an Out solution and I can assure you I am getting NO help from anyone at the FAA.

I'm not sure where you were heading with item 4 but I too see avionics shops as a gate. If everyone has to do this, then I think we need a system by which the owner can work with an A&P to comply. Validation should be done by airborne servalance verification by test flight and WITHOUT an avionics shop involved. If this is done correctly, it could be part of the annual. Avionics shops only become involved in the process if there is an issue (and after either the GPS or Txp box has been swapped out by the A&P).

Your last point is, by default, where we will likely end up if we do not change path. There will be carve outs for GA.

I would prefer that the technology be made affordable and doable such that all GA owners will be clamoring to get the update. The system will be safest when everyone participates.

I am not saying the above is easy nor is it a fully vetted solution. By the same token, I can buy a 10 Hz WAAS enabled GPS engine for $25 from SparkFun in quantity 1 and I've looked inside the Trig S-ES remote transponder housing. There is hardly $120 worth of effort in that housing at current volumes and significantly less when you consider the volumes necessary to equip GA. Any other money spent on compliance needs to be justified or removed from the equation.

I don't agree that ES is the way to go to get costs down. Where I was going with 4) is that it is already permitted for an IA to do the installation, he just has to RTFM. It is no more complex than any other installation if you follow the install instructions and check it out after it is installed in accordance with them. It is not brain surgery. But if someone is unwilling to read and follow instructions or doesn't have basic skills, I don't think a working group is going to do any good.

No, the last point has to be fought for to make it a reality. Otherwise we will just retire a bunch of aircraft needlessly.

 

[lolachampcar]

I really should not emphasize S-ES over UAT as the idea is an affordable solution that meets the mandate (and UAT meets the mandate for some).

The IA signing off on an installation assumes an STC exists. There are many certified aircraft for which there are way to few to warrant an STC (like mine). In addition, the STC or field approval based on an STC is a non-trivial undertaking. Sure, it meets the requirements to ensure system performance but a bit more work on the part of the FAA could completely remove the need. Further, that work would pale in comparison to the FAA having to respond to all the STC and FA request that would be required for all of GA to meet the mandate.

If a little more work and forward thinking can head off a train wreck, then the only reason to keep heading for the cliff is to protect entrenched commercial interests. This is one of the instances where those entrenched interests would be (are) acting in direct opposition to GA and the public's best interests.

I'm truly surprised there is not more outrage. I'm an owner and I can not fathom being forced to spend in excess of $5K per plane to conform to a mandate when the same goals could be reached for far less with more value provided for the money being spent.