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View Full Version : Never, ever, correct a mistake – CASA policy


Dick Smith
27th May 2016, 06:39
It appears that one of the reasons CASA will not comply with the AOPA request to delay the ADS-B mandate to 2021, for all IFR aircraft, is because they are concerned that people who have already fitted the equipment could sue.

This is ridiculous! As it simply means they can never correct an error. No doubt it also means that they can never correct Part 61 because some people (including myself) have had to pay large amounts of extra money in complying with the more arduous requirements.

Surely those who fitted ADS-B early have done this because they believe there were advantages for them. They had the freedom to delay the fitment as there is no requirement to fit before February 2017.

Also, anyone with any common sense would not bother to sue CASA, because CASA will throw unlimited amounts of industry money at the action.

Come on Mr Skidmore! Use a bit of fairness and common sense and announce that this ridiculous and unique mandate will be delayed until 2021.

Otherwise, I fear you will have the embarrassment of Nick Xenophon and his party making the decision for you. It has happened before with fixed ELTs - where the incoming government changed the law so portable ELBs would be allowed. This saved the industry since then tens of millions a year.

Mr Approach
27th May 2016, 08:39
The mandate was apparently based on Airservices and hence the industry that funds it saving huge amounts of money by not having to replace the radar systems.

The radar systems were replaced so logically there is no reason for the mandate.

A radar system probably has a life of fifteen years, let's say 2030, so a mandate for ADS-B to be on all aircraft by 2028 would make sense.

Have I missed something?

CaptainMidnight
27th May 2016, 08:54
Have I missed something? It seems you have.

The radars Airservices have replaced have largely been in the "J" curve.

ADS-B is providing surveillance across the country, where none was available before.

There is a world outside TMA -

Dick Smith
27th May 2016, 09:38
And there was no safety requirement for this.

Procedural separation is what they use for Hobart approach so why not use it at flight levels over Alice where collision risk is minuscule ?

I know. They wanted Australia to lead the world.

CharlieLimaX-Ray
27th May 2016, 10:55
Bit like when you closed down the Australian DME, and we had to flog around without IFR approved GPS's for a period of time!

Frank Arouet
27th May 2016, 11:06
Oh, my goodness. Australian peculiar DME. Probably better you hadn't brought that up.

fujii
27th May 2016, 11:11
Minimal collision risk over Alice Springs. Again another demonstration of gross ignorance. Everything to and from SEA Asia for ML, SY & AD goes over or close to Alice plus DN overflyers. With scheduling they all get there about the same time. I did procedural enroute from Alice tower in the 80s and 90s and it was bloody hard then and it didn't take long to run out of airspace when working with converging tracks, 20 DME or 2000 ft separation. About three o'clock one morning SY fogged in and I had six overflyers heading that way. Try handling those diversions procedurally.

The number of airlines and traffic to Asia has increased significantly since then and is forecast to grow. Aircraft nearing Alice will have burnt off a fair bit of fuel and possibly looking for higher levels. Add to that RVSM and free flight and procedural control over Alice is still flat out.

ADS-B will ease workload, free up airspace, allow aircraft to fly more efficiently, save fuel and lower costs for the airlines.

Would any ML or BN ENR controllers like to make a comment?

LeadSled
27th May 2016, 11:59
Folks,
Mr. Skidmore has talked about "fairness", and how unfair it would be to those who have already fitted $$$$ ADS-B, if it was further delayed. Also that those who have not fitted ADS-B get an "unfair" financial advantage by not having to fund ADS-B.
I would strongly argue that such "reasons" are beyond CASA power.
Just have a look at the Act, CASA can ONLY make decisions based on safety grounds, CASA CAN NOT make decisions based on "fairness" or commercial grounds.
In short, the reasons CASA have given for NOT doing as was effectively promised in Tamworth, delaying the low level mandate to 2021, are not a lawful exercise of CASA power.
Tootle pip!!

BuzzBox
27th May 2016, 12:47
I guess it could be argued that by not delaying the implementation date, they haven't actually made a decision. Ergo, it's not unlawful!

mgahan
28th May 2016, 02:34
Make a note in your diaries for today: it's probably a one-off of historic proportions. I spring to Dick's defence (sorry Dick, I have to use that offensive word "defence" but it has a lower case so the more intelligent will be able to discern a difference between my action and my one time employer).

During my tenure as ATS System Requirements Manager I conducted a number of meetings with industry reps about the decommissioning of DMEA. Mr Smith attended a couple and was most vocal about the policy to be applied in determining the locations where DMEA would or would not be replaced with DMEI so it is unfair to say the decommissioning was his (Dick's) call. There were very clear technical and economic reasons for the decommissioning.

As I remember, it was at one of those meetings that the late Alan Green made his classic comment about hoping that any brain surgeon about to operate on him was "a professional and not some well meaning amateur."

MJG
Can't have Dick blamed for everything, can we?

mustafagander
28th May 2016, 10:26
What's this stuff about CASA and mistakes???

By definition CASA never makes a mistake so the chance to correct one will never arise.

aroa
29th May 2016, 02:11
You should all know by now that CAsA's 'Mission Statement' is (apart fro destroying GA)..... All Control. NO Liability. No Accountability.

Thus 'mistakes, illegal actions etc do not exist.
They can be described as "unfortunate discrepancies in the wording" or " use of discrepant words"
See, arses all covered. Nil probs for (Non) Aviation House.
Next debacle.

LeadSled
29th May 2016, 03:16
Dick,
The title of the thread does mis-cast the official position as espoused by Mr. Skidmore, is that CASA is never wrong, therefor there is no mistake to correct.

I suggest this, based on his public statements rejecting the widely voiced opinion that CASR Part 61 is just one big mistake --- that is just getting bigger with every new batch of Exemptions --- such exemptions, of course, should not be characterized as correcting mistake, but merely CASA introducing a level of flexibility at the request of "industry".

I guess that means the CASA Chairman's comments about Part 61, and all the "band aids" that the Exemptions, in his view, represent, cannot be taken as the views of the management of CASA.

Tootle pip!!

P51D
29th May 2016, 04:17
Flying with a lady DHC Beaver pilot in Alaska a few days ago and she advised that a ADS-B unit was provided free to her aircraft for testing a few years ago. She asked when was Australia upgrading for GA and when I told her that our Regulator required this to occur in 2017 she was aghast and asked why, as the FAA isn't requiring her and the US industry to do so untll 2021, at which time the costs will have reduced significantly, which would also help us if CASA weren't so pig-headed. Says it all really, our CASA id putting needless costs on a struggling industry and it just beggars belief that they have no business acumen or understanding of the industry, but then our skies are just so much busier than North America aren't they!!

LeadSled
29th May 2016, 11:00
Flying with a lady DHC Beaver pilot in Alaska a few days ago and she advised that a ADS-B unit was provided free to her aircraft for testing a few years agoFolks,
I would point out that the ADS-B supplied ( Project Capstone??) was NOT a 1090ES type, but UAT, a genuine broadband transceiver, with far more capability than 1090ES ADS-B. This was the system used for all early developments in the US, such as the "Tennessee Valley" trial, and the huge amount of development money spent by United Parcel Service, UPS.

The UAT system is deployed throughout the "lower 48", and much of the "price confusion" about really cheap US "ADS-B" is because, all too often, UAT prices are being quoted. Even in US, 1090ES ADS-B is bleeding expensive, compared to UAT, for a fraction of the capability.

The antiquated abortion that is 1090ES ADS-B/C would not have occurred if this outgrowth of a WWII system had not been "granted" a late entry to the ICAO competition for a broadband datalink ( which 1090ES is not), which included ADS-B/C capability.

If ICAO has not succumbed to the lobby to promote the wildly incapable 1090ES ADS-B/C, we would not be having all the problems we are, and everybody from airlines down would NOT HAVE INCURRED the proven to be huge installed costs of 1090ES ADS-B.

It would have been straightforward for Dick Smith to fit UAT to his CJ3, around AUD$20,000 or less, the costs to Qantaslink -8 would have been around AUD$20-40,000, instead of around AUD$300-500,000. In each case quoted, and all similar, it would have been a stand alone system that did not interfere with existing transponders and ACAS/TCAS, and did not have to be integrated with "glass cockpits".

And FAA would not be having the channel saturation problems of 1090ES that Mitre Corp. forecast in the early 1990s.

And the "irony" is that many airlines have had to fit broadband transceivers anyway, doubling up costs, as VDL-2 (for ARINC/SITA) has replaced ACARS due to bandwidth necessity, and many parts of the world mandate non-voice comms. for much routine CNS/ATM -- via ARINC/SITA.

VDL-4 is VDL-2 plus ADS-B OUT, and was the first ADS-B system in daily service, in Scandinavia.( Note: NOT Australia, as Airservices often claim)

Huge amounts of money, for a vastly inferior and limited system, which is 1090ES ADS-B. We will pay and pay and pay for this huge technological step backwards.

Tootle pip!!

Sunfish
29th May 2016, 11:53
The Act does not require CASA to ensure the existence of a civil aviation sector at all. merely to ensure "safety."

thus it is possible for CASA to discharge any and all of its responsibilities under the Act by preventing flying at all.

it follows that the only errors CASA can commit and be held to account for are by permitting aviation to occur.

Therefore CASA Is never in challengeable error if it prevents aviation from occurring.


the rest is history - everything is prohibited except by reference to exemptions.

actus reus
29th May 2016, 12:14
Lead,
True, except that the VDL mode 4 trial in Miami led the FAA to basically abandon VDL-4.
Airlines were buying aircraft back in late 1997 that had 1090 fitted whether the airline wanted it or not.
ICAO dropped the ball because the Air Navigation Commission had not recommended to the Council what the tech standard would be so the aircraft manufacturers went with what they thought was the way to go.
Hence, 1090-ES.
Talk about red tape and crap in ICAO.
CPDLC was the issue and only belatedly did ICAO come out with a tech spec that reflected the equipment that was already fitted, and had been for years, in aircraft that were flying around.
The tech 'guru' at AsA said back in 2012/2013 that for UAT to be viable in Australia given that AsA would have to install re-transmitters to blend the 1090ES data with the UAT data so that 'in-out' would eventually be available data to all aircraft regardless of what equipment they had fitted, meant that the OZ GA fleet 'had to double between now and 2020 and double again between 2020 and 2025' from a cost benefit point of view.
UAT has its main advantage in the USA from the provision of 'real time' weather information to aircraft (deemed a good idea after the unfortunate DC 9 crash/ breakup in weather that was not visible to ATC).
The FAA said it would not provide that weather service over UAT and it is 'third party' providers in the US who do this.
No one, including ARINC, Jeppersen et al, considered the OZ market big enough to warrant the expense of providing that service in OZ. Needless to say, AsA had no interest in stepping into providing that service either.
Unfortunately, the AsA man I spoke of died and the discussion did not progress beyond that point.
At the last Air Navigation Conference in ICAO, there was another 'push' for VDL-4 from Russia. The use of it for determining 'windshear' on approach to land.
Luke warm enthusiasm I believe is the best way to describe the way that has gone regardless of whether it is a good idea or not.
The whole thing is a mess and shows that lack of coordination between ICAO and the OEMs will never produce an acceptable result.

actus reus
29th May 2016, 21:27
Sorry, made a mistake. Russia's use of VDL-4 was to determine what Wake Turbulence Separation was needed between aircraft on approach.

LeadSled
30th May 2016, 08:57
True, except that the VDL mode 4 trial in Miami led the FAA to basically abandon VDL-4.Actus,
The major development thrust by UPS/FAA was with UAT. A few US airports adopted VDL-4 for tracking aircraft/vehicles on the airport, I have never followed that up.The US Marines adopted VDL-4 tracking on some of their practice ranges.

UAT (being CDMA) is clearly the superior broadband datalink, and covers the whole "lower 48". Pick up any US GA magazine, and look at the services available over UAT, that 1090ES can never match.

Airlines were buying aircraft back in late 1997 that had 1090 fitted whether the airline wanted it or not.

Don't know who told you that furphy, simply not true, the major manufacturers only started fitting ADS-B Out to production aircraft in the mid-2000s, and as of now, less than 10% of the US airline fleet is fitted. I flew Boeing aircraft that were brand new deliveries in 2000, 1090ES was not even a customer option.

For any "glass cockpit" aeroplane (almost everything from mid-1980s) it was a huge and expensive job to retrofit. If my memory serves me correctly, the A380 was the first Airbus aircraft to be fitted with 1090ES ADS-B in production, although, obviously, it is now available across the Airbus production range.

Don't confuse the Airservices obfuscation about Mode S transponders, and ADS-B 1090ES capable transponders (Mode S we have had for a very long time) --- at one stage it seems AsA was publishing Mode S fleet figures as if every Mode S was ADS-B capable, which was the propaganda line at the time --- ADS-B was just a wire from a GPS to a Mode S transponder remember the AsA pamphlets and PowerPoint presentations --- I still have one somewhere on an Airservices CD.

The real story is that the major US avionics manufacturers did not own or control any of the patents for the UAT (Qualcomm = CDMA=Generation 3 and on mobile phones) or VDL (Ericsson = TDMA= Generation 2 mobile phones or first generation digital, GSM), the US airlines were in a parlous financial state, and they were sold a line that 1090ES would be a "cheap and cheerful" solution to ADS-B, and the lobbying was furious, hence my statement that the 1090ES was given a late entry into an ICAO competition that dated back to the 1980s.

As I have also previously posted, the airlines still had to fit a broadband data anyway, and last time I looked, VDL-2 was supplanted VHF AM for new generation ACARS, although "traditional" ACARS is alive and well.

Going to 1090ES for ADS-B, under the pressure of lobbying by the ATA and others is one of the dumbest decisions I have seen in a long aviation career, it will cost the whole aviation community many hundreds of millions of $$$, compared to the original plans/intentions of ICAO.

1090ES is a giant step BACKWARDS in technology.

Tootle pip!!

PS: Again, the last time I looked, Airservices is using the same ground stations as FAA, except the Australian ground stations have an empty card file slot, where the UAT transceiver would be in a US installation, beside the 1090ES card.

OZBUSDRIVER
30th May 2016, 10:02
UAT is an orphan of MITRE. A solution looking for a problem to solve...The original idea was a low cost broadband data link for GA to rival the likes of ACARS. UAT only transmits every twelve seconds as opposed to twice a second on 1090ES...UAT doesn't transmit from aircraft to aircraft, UAT still requires transponder fitment where 1090ES IS a transponder. Whilst all the other free goodies like wx and updated restricted areas and NOTAM would be great...somebody has to pay...not to mention the absolute blanket of ground stations here in OZ...all connected back to ML and BN by secure TWO WAY LINK....other than that, yeh UAT would be great:}

Leadie, this was done to death years ago:ugh:

OZBUSDRIVER
30th May 2016, 10:14
Leadie, forget ADS-B! Part61 WILL screw GA out of existence. That and Part42 and Part147 for AME training makes no sense for a whole library full of unnecessary regulation. If there is somewhere the fight is really need...Leadie...it is here. It probably is too late...once 2019 rolls around that's it for learning old school for GA maintenance.

actus reus
30th May 2016, 14:04
Lead,
I do not think a 'brain dump' of information makes a compelling point. OZ says it all.

Having flown in the 777 test programme in 1995, I can assure you that 1090 was a 'live'

concept then.

Plus, when we did the FAA/Boeing 'FANS in the Terminal Area' research in the later 90's (the

hook up of the United Airlines DC 10 sim in Denver, the Boeing 777 sim in Seattle and the

FAA ATC sim in Atlanta) which was aimed at Constant Descent and no voice comms

(including no 'clear to land' by voice), UAT was not going to cut it in any way shape or form

for the reasons (refresh rate) that OZ has articulated.

Find something else to go hard on. Excuse the pun.

LeadSled
31st May 2016, 08:55
ADS-B for Airbus and Boeing etcOz, Actus,
Have a look at the above thread, on Tech Log, re. availability of 1090ES ADS-B on Boeing.

A "live concept" in mid-1990s was not a roll-out, and FANS-1 was/is NOT in any way dependent on ADS-B or, indeed, a transponder --- but I am certain you know, is dependent on a datalink. That trials were held involving "in trail" separation and climbs and descents is a "so what", the first ones, and the whole Tennessee Valley trial used UAT -- as did Capstone. Indeed, one trial just used TCAS II presentations --- it worked, but only when there were only two aircraft in range, as there was no positive identification.

Of course 1090es was being talked about --- a conference I went to, in US, in 1996, was largely devoted to the subject, and all the potential problems, if 1090ES was adopted, instead of the intended (since the 1980s) broadband, either VDL-4 or UAT. As a matter of interest, at that stage, it was VDL-4 that was widely favored,(including IFALPA and IAOPA and most European NAA at ICAO) except by ATA and the US major avionics manufacturer, for reasons already posted.

See if you can get a copy of the article on the latest problems in the 1030/1090 frequencies, in the latest Aviation Week (AWST)--- and the expensive work-rounds proposed, which MIGHT include a retrofit of an entirely new transponder/TCAS (TCAS III??).

All problems, I might point out, created by or exacerbated by 1909ES ADS-B, and yet such a small proportion of the US airline fleet is equipped.

That UAT/VDL-4 is not a transponder has never been disputed, but it is significant that nobody has yet built and sold in large numbers a TCASII that picks up the ADS-B IN functions, because it adds no new functionality to the effectiveness of TCAS II v. 7.x.

FAA simply do not see UAT or 1090ES ADS-B as anything more than a datalink --- as we now have proven (those of us who can add up have always known) keeping the "traditional" transponder, and having ADS-B as a stand alone part of a multi-use broadband transceiver ( as most of GA in US can do) is cheaper by far than mandating 1090ES.

There are some serious attempts to re-write history here --- UAT was developed largely by UPS, who bought an electronics firm that built the original equipment (Apollo Corp.??) , and to suggest that a refresh rate was an inherent limitation is just to laughable for words. VDL-4, the first to go into daily operation for ATC, was unquestionably successful, but lost out in the politics, as did UAT.

That UAT or VDL-4 did NOT impinge on the 1030/1090 frequencies would have been critical to avoiding the problems now (already) occurring, and the fact that they were "stand-alone" systems, compared to producing 1090ES ADS-B OUT (let alone IN) was what made them a fraction of the cost to fit any aircraft.

You do understand, do you, who and what Mitre Corp. is, what it is not is a commercial corporation. It had no commercial interest in the outcomes, but its analysis and forecasts, 20 years later, as blindingly accurate.

As is clear, from the AWST article, the long forecast chickens are coming home to roost, and the cost to the industry is potentially huge.

Funnily enough ( and it is really funny- Ha! Ha!) the cheapest solution to the emerging problems for operations in the US might well turn out to be mandating UAT for all aircraft, and turning 1090ES ADS-B off (back to Mode S only) in US airspace (and western Europe) --- a cheaper solution than developing and deploying a whole new transponder fit, substituting wide area multilateration for SSB, and a few other very expensive tweeks, like a whole new major hardware/software upgrade for the already seriously delayed FAA ATC upgrade.

After all, the ground infrastructure already exists, as does the software --- all FAA ADS-B ground stations are dual 1090ES/UAT.

All so very sad, and bleeding expensive for a not even second rate system.

Tootle pip!!

OZBUSDRIVER
1st Jun 2016, 11:53
In September 1998 there were only a handful of aircraft running gear built by MITRE. In 1999 Capstone started in Alaska...UPS AT were successful with their MX20 and GX60 GPS linked with the UAT datalink. OK...my first error on UAT in a long while...it is the TIS uplink that is delayed. UAT transmits position once a second. History on Leadsled's datalinks (https://www.aea.net/AvionicsNews/ANArchives/DatalinksJuly05.pdf)

EDIT- MITRE Center for Advanced Aviation System Development 1995 first concept of UAT
The Universal Access Transceiver Digital Data Link (http://www.propgov.com/gps_atc/Cache/project_details.cfm.htm)

The Universal Access Transceiver, or UAT, is the two-way digital data link employed in the Capstone system. It is a high-bandwidth, multi-purpose, low cost data link. UAT was initially developed by CAASD. CAASD has worked with data link technology for several years, and its work in related areas of aviation research is part of Capstone's legacy. Developed under internal research and development funds at MITRE beginning in 1995, the UAT was originally conceived as a simple, multifunction broadcast data link alternative for small aircraft. Following the successful flight demonstrations of ADS-B, FIS-B and TIS-B as part of CAASD efforts, United Parcel Services (UPS) Aviation Technologies developed a commercial version of UAT. Subsequently, UAT was included in the winning proposal by UPS Aviation Technologies for Capstone avionics and ground stations. RTCA has begun developing UAT standards, with CAASD again poised to play a key role.


EDIT- Whilst UAT is many things....somebody has to pay for it. The FAA justifies UAT to keep GA off 1090ES and contributing to FRUIT. Also to decom some 70% of the 130 SSR facilities across the nation. Compare this with the cost savings put forward by Dunstone here in the early days of ADS-B for a handful of SSR sites in the J Curve.

Regardless. AirServices 1090ES was part of ICAO mandate for full ATM coverage ABV FL280.

LeadSled
3rd Jun 2016, 01:50
Folks,
An interesting new post on Tech Log suggests that FAA is going to require dual UAT/1090ES ADS-B, with the 1090ES switched back to Mode S (or C ??) below 18,000, the US transition altitude ----- due the mounting problems with 1090ES frequency saturation.
This is a new one on me, I am not really convinced it is correct, but it would be one answer to all the problem outlined in last week's AWST article.
I have asked the poster for references.
Tootle pip!!

OZBUSDRIVER
3rd Jun 2016, 12:14
Interesting...Flightradar24 does use third party receivers. The post proves the need for FDE!

Leadsled can u link that prune thread?

aroa
7th Jun 2016, 23:28
Here's a quote that says it all....

No major institution can expect to preserve a shred of public trust if it manifestly fails to understand such a basic concept of accountability.

Thats our CAsA for ya !!