Lead thankyou, understanding positions is critical!
Attached (Appendix A) is an analysis of the decisions facing the industry submitted by Sport Aviation as input to the discussion paper. This analysis is based on the work done by GIT and ABIT. This submission was apparently entirely ignored in the preparation of the current JCP.
.. that’s a worry …. Has there been any indication as to why?
Analysis of the work done by the GIT and ABIT teams shows the following:
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1. GNSS Nav. is clearly justified by the savings achieved.
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2. Replacement of SSR as described in the JCP, is clearly cost beneficial and probably justifies some cross-subsidy of the cost of installation of ADS-B OUT in GA aircraft because the proposal disposes capital investment from the ATM provider to GA. This should be an ongoing subsidy, not a one off subsidy, as the cost savings to the ‘big’ end of town are ongoing.
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3. No systematic attempt has been made in these studies to address the avionics which may mitigate CFIT accidents except that it is clear that mandating ADS-B OUT will have no effect on this significant accident type.
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4. Cost benefit justification of the extension of the ADS-B mandate beyond that required for radar-like services justified by capacity requirements, must stand alone. The benefits included must be limited to those which are a result of the extended mandate (ie depend on the fitment of ADS-B OUT in other aircraft in regions where radar-like services cannot be justified for capacity reasons) – and costs include all those required to achieve those benefits. (See following)
.. apart from point three (which would only happen with GNSS equipment anyhow, which might be considered in relation to point 1.) I agree!
Cost Benefit Justification of Project B – Extension Beyond SSR Replacement
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A detailed analysis, by Sport Aviation, of the shortcomings of the ABIT cost benefit analysis, which was accepted by ABIT and ASTRA but, despite assurances given Sport Aviation, has not been addressed in this updated cost benefit analysis, is attached (Appendix B).
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In summary this shows:
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* GNSS Nav. and avoidance of CFIT accidents are not outcomes of fitment of ADS-B OUT.
… was TAWS/GPWS/EGPWS part of the project scope as far as required outcomes?
* Savings on SSR by replacement with ADS-B similarly do not depend on a mandate extended beyond radar coverage justified by capacity requirements.
… agreed … how would ‘sport’ treat this in the project context when considering the ministerial radar directive in regional D’s (as just one example)? … I agree though that CBA/Risk must identify where mitigation is required (particularly outside existing areas) … but how do you achieve that in advance without accurate means of collecting traffic data (apart from IFR)? I suppose extrapolation of expected traffic densities/complexities and costs could be used, however would that be any more robust that the proposed?
* Search and rescue benefits do not require ADS-B OUT in other aircraft.
… ‘require’ no .. but is there a benefit if it is equipped for other reasons?
Accordingly, none is a benefit of the extended mandate.
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* Collision avoidance depends on ADS-B IN as well as ADS-B OUT
… again agree (OCTA and outside existing surveillance)
Accordingly, if this benefit is to be included, then the costs must include fitment of ADS-B IN as well as ADS-B OUT.
…. Agreed (when considering CBA/Risk OCTA)!
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Have sport compared (if that is possible) the CBA of the Status Quo into the future?
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I take it ‘sport’ expect an RPT CBA including separate risk analysis (presuably for individual volumes) etc to be included in the GA proposal?
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So in dot point, could you give us a brief run down of what 'Sport' would
need to be comfortable with the process and the outcomes?
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The same input from the other sectors would be invaluable!
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Thanks for providing the information! .. a reasonable response from ‘Sport’!