Mr Skidmore backs flawed CASA ADS-B Regulation Impact Statement
Thread Starter
Mr Skidmore backs flawed CASA ADS-B Regulation Impact Statement
In an article this morning in The Australian under the heading “Watchdog backs cost estimates for satellite tracking system” (reproduced in entirety below) CASA Head, Mark Skidmore, has ignored every one of AOPA’s objections to the current requirements for the fitment of ADS-B well ahead of other aviation countries.
Those in the know realise that there is no measurable economic or safety benefit for our unique ADS-B requirements that are coming in in 18 months’ time where every IFR aircraft (yes, even a 172) will have to have ADS-B Out fitted even in non-controlled airspace. No other country in the world has such onerous and expensive requirements.
All of the points in the AOPA letter have been completely ignored by Mr Skidmore as it’s clear that the person who wrote the letter is one of the “iron ring” who came up with the requirements in the first place.
I had an independent person look at the Regulation Impact Statement and he worked out that the negative effect for general aviation was something like $60 million. Can you imagine one of the claims of this huge ADS-B cost is “there will be safety improvements … including increased accuracy of directed traffic information”!
Now how does that save any money for general aviation? The article goes on to talk about “quicker alerting when aircraft vanish from surveillance” but it doesn’t mention that at a typical height a small aircraft flies, there will only be about 10% of Australia covered.
Here is the full article…
Those in the know realise that there is no measurable economic or safety benefit for our unique ADS-B requirements that are coming in in 18 months’ time where every IFR aircraft (yes, even a 172) will have to have ADS-B Out fitted even in non-controlled airspace. No other country in the world has such onerous and expensive requirements.
All of the points in the AOPA letter have been completely ignored by Mr Skidmore as it’s clear that the person who wrote the letter is one of the “iron ring” who came up with the requirements in the first place.
I had an independent person look at the Regulation Impact Statement and he worked out that the negative effect for general aviation was something like $60 million. Can you imagine one of the claims of this huge ADS-B cost is “there will be safety improvements … including increased accuracy of directed traffic information”!
Now how does that save any money for general aviation? The article goes on to talk about “quicker alerting when aircraft vanish from surveillance” but it doesn’t mention that at a typical height a small aircraft flies, there will only be about 10% of Australia covered.
Here is the full article…
A review by the Civil Aviation Safety Authority of cost estimates to introduce satellite-based technology in general aviation aircraft has found its original assumptions were “adequately sound’’.
The Aircraft Owners and Pilots Association wrote to CASA boss Mark Skidmore about concerns that cost estimates in the regulation impact statement for the mandatory introduction of automatic dependent surveillance-broadcast equipment in all instrument flight rules planes by 2017 were incorrect.
Operators have complained the costs can be crippling and AOPA wants the RIS to be re-evaluated.
It also wants CASA to adopt the US Federal Aviation Administration’s approach not to require ADS-B in Class G or E airspace below 10,000ft.
Some operators, including airspace campaigner Dick Smith, have also called for the introduction of ADS-B to be delayed in Australia until after it has been introduced in the US and cheaper equipment becomes available.
In a letter to AOPA, Mr Skidmore listed a series of safety improvements he expected to accrue over time due to the introduction of ADS-B, including increased accuracy of directed traffic information, quicker alerting when aircraft vanish from surveillance, narrower search and rescue areas and a number of advantages from air traffic management automation.
He rejected accusations that Australia was “conducting an R&D exercise for the world’’ and said ADS-B development had been going on for many years and was part of the International Civil Aviation Organisation’s Global Air Navigation Plan.
On the cost issue, he said the RIS had not claimed the introduction of ADS-B would be cost neutral for general aviation and the internal review said it was now common for general aviation installations to use equipment combining multiple avionics functions in one box.
He said the cost of the ADS-B component should be apportioned across the various other functions in the box.
“The internal review considered that, in general, the original RIS assumptions were adequately sound in terms of current ADS-B costs, with the exception of those costs used for the modifications to some integrated avionic systems under aircraft type certificates — these had relatively higher costs than those contained in the RIS,’’ Mr Skidmore said, noting that the US dollar exchange rate had also fallen since the RIS was published.
“The review also noted the view expressed by some, including the Aircraft Electronics Association, that ADS-B equipage costs may well increase as the US and European mandates approach and global demand for equipment stretches supply and installation capacity.’’
Turning to the call to adopt the 10,000ft rule, the CASA boss pointed to differences between US and Australian airspace as well as in the way the two countries were introducing ADS-B.
The FAA would require aircraft to have ADS-B to fly in most airspace requiring a Mode C transponder, including classes A, B or C as well as within 30 nautical miles of a Class C ring around a Class B primary airport to ground level and most Class E airspace above 10,000ft.
“Significantly, the FAA mandate applies to both IFR and VFR operations,’’ he said.
The Aircraft Owners and Pilots Association wrote to CASA boss Mark Skidmore about concerns that cost estimates in the regulation impact statement for the mandatory introduction of automatic dependent surveillance-broadcast equipment in all instrument flight rules planes by 2017 were incorrect.
Operators have complained the costs can be crippling and AOPA wants the RIS to be re-evaluated.
It also wants CASA to adopt the US Federal Aviation Administration’s approach not to require ADS-B in Class G or E airspace below 10,000ft.
Some operators, including airspace campaigner Dick Smith, have also called for the introduction of ADS-B to be delayed in Australia until after it has been introduced in the US and cheaper equipment becomes available.
In a letter to AOPA, Mr Skidmore listed a series of safety improvements he expected to accrue over time due to the introduction of ADS-B, including increased accuracy of directed traffic information, quicker alerting when aircraft vanish from surveillance, narrower search and rescue areas and a number of advantages from air traffic management automation.
He rejected accusations that Australia was “conducting an R&D exercise for the world’’ and said ADS-B development had been going on for many years and was part of the International Civil Aviation Organisation’s Global Air Navigation Plan.
On the cost issue, he said the RIS had not claimed the introduction of ADS-B would be cost neutral for general aviation and the internal review said it was now common for general aviation installations to use equipment combining multiple avionics functions in one box.
He said the cost of the ADS-B component should be apportioned across the various other functions in the box.
“The internal review considered that, in general, the original RIS assumptions were adequately sound in terms of current ADS-B costs, with the exception of those costs used for the modifications to some integrated avionic systems under aircraft type certificates — these had relatively higher costs than those contained in the RIS,’’ Mr Skidmore said, noting that the US dollar exchange rate had also fallen since the RIS was published.
“The review also noted the view expressed by some, including the Aircraft Electronics Association, that ADS-B equipage costs may well increase as the US and European mandates approach and global demand for equipment stretches supply and installation capacity.’’
Turning to the call to adopt the 10,000ft rule, the CASA boss pointed to differences between US and Australian airspace as well as in the way the two countries were introducing ADS-B.
The FAA would require aircraft to have ADS-B to fly in most airspace requiring a Mode C transponder, including classes A, B or C as well as within 30 nautical miles of a Class C ring around a Class B primary airport to ground level and most Class E airspace above 10,000ft.
“Significantly, the FAA mandate applies to both IFR and VFR operations,’’ he said.
Last edited by Dick Smith; 11th Sep 2015 at 02:33.
Join Date: Dec 2003
Location: Australia
Posts: 926
Likes: 0
Received 0 Likes
on
0 Posts
Whilst I support the contention that CASA is appalling and must change in almost all respects, the constant critisism of Skidmore is counterproductive. He needs to be a new broom, but he needs to be given a chance.
I would be much more critical of Minister Truss, and his performance as minister overseeing CASA.
I would be much more critical of Minister Truss, and his performance as minister overseeing CASA.
Last edited by rjtjrt; 11th Sep 2015 at 06:08. Reason: Correction of typing
Join Date: Apr 2001
Location: Adrift upon the tides of fate
Posts: 1,840
Likes: 0
Received 0 Likes
on
0 Posts
So, you are saying the ADS-B requirement fails a cost/benefit analysis, yet you studiously ignore calls to produce a cost/benefit analysis for your airspace proposals?
Hypocrite.
Very. Big. Hypocrite.
Hypocrite.
Very. Big. Hypocrite.
Thread Starter
We all hoped the new Director would stand up for what was ethical and ask for the RIS to be re looked at.
Yet we see the military culture of supporting the system no matter the number of mistakes made.
Mr Skidmore signed the letter. All very sad.
Yet we see the military culture of supporting the system no matter the number of mistakes made.
Mr Skidmore signed the letter. All very sad.
Yet we see the military culture of supporting the system no matter the number of mistakes made.
Join Date: Oct 2011
Location: Australia
Posts: 91
Likes: 0
Received 0 Likes
on
0 Posts
Let's face it, they don't pick people who will rock the boat or go against government directives. Why would they? Probably just a co-incidence they have picked so many military guys.
Dick was never in a position of power in CASA (although he was duchessed into believing he was).
All it takes is 3 minutes to read Part VII of the Civil Aviation Act to see what powers the Chairman of the Board has (and, therefore and more importantly, doesn't have). (The CASA Board is another scam that industry falls for with depressing but now predictable regularity.)
All it takes is 3 minutes to read Part VII of the Civil Aviation Act to see what powers the Chairman of the Board has (and, therefore and more importantly, doesn't have). (The CASA Board is another scam that industry falls for with depressing but now predictable regularity.)
So, you are saying the ADS-B requirement fails a cost/benefit analysis, yet you studiously ignore calls to produce a cost/benefit analysis for your airspace proposals?
Hypocrite.
Very. Big. Hypocrite.
Hypocrite.
Very. Big. Hypocrite.
I rather suspect that you do not know the difference between a Cost/Benefit analysis and a "cost/effectiveness" analysis.
In simplistic terms, in a cost/benefit analysis, the person incurring the costs should get some or all of the benefits.
In the latter case, those incurring the costs do not necessarily get any benefits.
With the "airspace reform", it is very effective for AsA, huge costs are being imposed on industry, to save AsA a small fortune. Despite the political and PR position of airlines, it is very difficult to show a saving, given the real traffic levels over Australia.
Dick is quite correct in calling for a proper cost/benefit analysis of the ADS-B debacle. Re-doing a RIS, which CASA has refused to do, doesn't, help, all a RIS tells you is what it is going to cost, after the decisions have been made.
A proper CBA tells you whether you should do it by whatever means, of which regulation should be the last resort, not the first, whatever "it" is, before the "decisions" are made.
CASA culturally hates the idea of CBA, if it was rigorously applied, a large amount of aviation legislation would never see the light of day.
Part 132 is a good example, two simple regulations being turned into scores of pages of regulations and brand and new MOS, all to address problems that are asserted, but nowhere detailed. Nowhere does Part 132 address any known and illustrated problems, because they don't exist, CAR 262Am and CAR 262AN have operated effectively and "economically" since 1998.
Part 132 creates yet another expensive bureaucratic nightmare that will achieve nothing, other than hamstringing Limiter Cat. operations into yet another regulatory straight-jacket.
As for Parts 121 and 135, plenty of coffin nails there --- all to "address" non-problems, except in the minds of those paid to generate regulations.
Tootle pip!!
Leadshed
To save AsA a small fortune. How so?
AsA is funded by Industry so therefore this "small fortune" is shared/saved by Industry.
With the "airspace reform", it is very effective for AsA, huge costs are being imposed on industry, to save AsA a small fortune.
AsA is funded by Industry so therefore this "small fortune" is shared/saved by Industry.
Join Date: Apr 2001
Location: Adrift upon the tides of fate
Posts: 1,840
Likes: 0
Received 0 Likes
on
0 Posts
I don't care whether you call it a CBA, cost-effectiveness analysis, cost–utility analysis, risk–benefit analysis, economic impact analysis, fiscal impact analysis, or Social return on investment (SROI) analysis. All roads lead to Rome.
i.e. Dick and yourself are saying there should be some sort of measurement of costs attached to reasons, and an analysis thereof, for the ADSB rules/changes. Yet Dick offers no such analysis for his airspace proposals- just a "why don't we try it and see" argument. You don't see the hypocrisy?
BTW- be careful what you wish for. A CASA CBA (as you define it) might very well show NO PROBLEM. An owner's CBA might be the total opposite. Where do you go then? As sunny alludes to, the costs will always reside somewhere. Just where, seems to be the issue, doesn't it?
i.e. Dick and yourself are saying there should be some sort of measurement of costs attached to reasons, and an analysis thereof, for the ADSB rules/changes. Yet Dick offers no such analysis for his airspace proposals- just a "why don't we try it and see" argument. You don't see the hypocrisy?
BTW- be careful what you wish for. A CASA CBA (as you define it) might very well show NO PROBLEM. An owner's CBA might be the total opposite. Where do you go then? As sunny alludes to, the costs will always reside somewhere. Just where, seems to be the issue, doesn't it?
The benefits must include the entertainment value for owners and pilots of VFR aircraft.
(The exceptions almost always put the lie to the benefits.)
(The exceptions almost always put the lie to the benefits.)
somewhere around Dubbo, and from then on Airservices have no idea where I am, same as before? Is it just that it's not working yet or is coverage exactly the same as it was (is) under the old radar system?
Not sure what you mean when you say "Airservices have no idea where I am".
On the assumption your ADS-B unit is working correctly (you've verified that at some stage with ATC, right?) then if you are within the coverage areas of sites you should be being seen.
ADS-B coverage | Airservices
If there is some problem with your ADS-B setup or planning, you might review this:
http://www.airservicesaustralia.com/...ckage_V4.0.pdf
AsA is funded by Industry so therefore this "small fortune" is shared/saved by Industry.
A question or two for you, please:
What was AsA's "profit" last years and the dividend history paid the "shareholders" (ie: the Government) over the years. You know as well as I do that AsA is a profit earning enterprise, and extracting reductions in charges is like pulling teeth.
Why have there been the recent comments (some "informal") from BARA and AATA about the level of AsA charges.
The cost to GA has been recently estimated to be as much as $60M plus in capital costs for nil benefits.
Given Mr. Skidmore's/CASA's recent statements on the RIS, I believe it is a reasonable assumption that he does not understand the difference between a CBA, a CEA and RIS, either.
Ferris,
I strongly recommend that you look up the Australian Government's/OBPR/Productivity Commission guidelines (or Access Economics, for that matter) for the various analysis, they are not my definitions.
I am very familiar with the two so called CBA performed by CASA, in the early days of this saga, I know just how seriously and fundamentally flawed they were.
If (in their internal analysis ) the airlines cannot show real savings from ADS-B and it is acknowledged that there are no benefits to the bulk of GA, pray tell how a properly conducted CBA could be positive.
All it takes is 3 minutes to read Part VII of the Civil Aviation Act to see what powers the Chairman of the Board has (and, therefore and more importantly, doesn't have). (The CASA Board is another scam that industry falls for with depressing but now predictable regularity.)
Tootle pip!!
Last edited by LeadSled; 13th Sep 2015 at 10:26.
