ADS-B + Subsidy - It's on the table - Submn's close 31 Oct

[Scurvy.D.Dog]

… yes you are probably right Lead!
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... its all just a conspiracy by the major manufacturers like AB and Boeing, and the service providers like AsA, CASA, DoTaRS, the EU (who have a non subsidised mandate coming), the FAA, CAA, Korea, Russia, Italy …. Oh gosh yeh …. ICAO member states!
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Here's a riddle:-
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- VD4 and 1090ES .. which is dearer? .. and
- What do you care about VDL2 Sig as far as GA goes?
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Are you saying the JCP costing/s are wrong? if so spell it out
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Do you know what ADS-B units will be available and what they will cost to GA? … does Hall?
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What do you want? .. an absolute price guarantee? …. an absolute 100% subsidy guarantee? .. no end limit to the subsidy? ... what do you reckon that will do to the price per unit??
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…… it’s a wedge not worth playing IMHO if that’s the game!
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… beyond 2013, maybe? …. OCTA
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… an open ended new aircraft subsidy is as silly as saying the Gov’t should be paying for radio or a mode C since they were invented!

We know (ask for the AsA studies) the collision risk above 5000 is vanishingly small (see AS/NZ4360.2004 for a definition),

Perhaps you might enlighten us to whether Hall prescribes to the sort risk process considerations as articulated by the NTC (comparative doctrine)?
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The NTC is compliant with AS/NZ4360.2004 (note in particular the references at the end of the document):-
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http://www.ntc.gov.au/filemedia/Repo...FAIRPMar07.pdf
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If so (given he has an interest in a particular outcome), how does he quantify consequence/s in his determinations on this subject to arrive at:-

a statistical zero

.. oh were it so
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…. and the consequence/s?

, and an even smaller "statistical zero" above 10,000 (see AsA Class C v. E studies above 10,000). "Mandatory" radio above 5,000 feet is a remnant of pre-AMATS days.

… lots of statistical zero’s there
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Does Hall believe the same to be the case with regard to the carriage of VHF radio and existing A/C TXPDRS?
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….. you know what I am getting at in regard to the Part 103 (RA-Aus etc) draft open for consultation at the moment
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.. in practical terms it states (for G, CTAF and E airspace):-
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If a part 103 aircraft is capable of powering a radio and/or a TXPDR, that if it is serviceable, it MUST be used (with no time limitation for corrective action I might add)!
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… It does not say:-
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If capable of powering a VHF and/or TXPDR it MUST be serviceable and it MUST be used (which applies to other aircraft)!
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Perhaps the ADS-B debate is co-related, perhaps you might ask Hall for us!
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In Australian aviation, we are demonstrably no good at rational risk management, but much prefer what are irrational and emotional arguments about "safety",

…a vanishingly small statement!

all the while ignoring rational analysis of where the "safety" problems actually exist ---

… oh I get it ... bit like AusNAS 2B and 2C .... that’s why we had to change airspace with AusNAS including CTAF procedures then?
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hmmm … vanishingly small!

to find out where that is, look at the ATSB records ---it is not in mid-air collisions.

… noooooooooo ….. but the difference between airprox and mid-air is a tally-ho paper and luck! ... I take that Christmas Eve 2003 was just an aberration not worthy of consideration because a mode C and TCAS saved the day (in the last nanosecond!) ….. a vanishingly small emotive argument no doubt for those without accurate mode C or a TCAS!
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If what is proposed is not to your liking, write and explain to them why, explain what you would like to make it acceptable! ..... to say no under any circumstance would have little credible basis in fact …. IMHO … of course!
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Take all the rose coloured glasses off, and go back and very carefully re-read the posts of Dr. Hall's documents.

... sage advice, given that he is the President of the ASAC ....
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Its been fun .. good luck!

[LeadSled]

Gaunty,
M'oold darlin',
Take up your complaints about AOPA claiming credit with the particular Canberra based V-P who made the statements. I, for one, am big enough to recognise the effective role you played for JACC.

As to the rest, for the benefit of this thread, why don't you quote the prices I asked you to get, the cost of the stuff RFDS is using for "trials", and if the GPS IS C-145 or C-146 certified,(I have claimed it is not, here's an opportunity to publicly prove me wrong) how about details of how long such a new version of an old GPS has been available, or would that puncture an emotional balloon.

You know a group of us were flying a prototype ADS-B collision avoidance system here in the east, 6-7 years ago, the GPS engines were 12 Ch. Rockwell, but only C129A. The project was abandoned when the difficulties with obtaining C145/146, and licenses for certain patents became obvious ----and nothing has changed since that time -----same people making the only receivers, same people hold the patents very tight, you can work the rest out.

-mandatory TCAS in every GA charter aircraft regardless of seat numbers and mandatory transponders-

For the same reason I don't support mandatory ADS-B ---- There is no cost/benefit justified safety case to support such an edict. Having said that, have a look at the ICAO requirements for TCAS/ACAS v. Australia.

an ADSB out would improve the accuracy on the TCAS outa
sight.

See previous posts, theoretically the position would be more accurate, but it is of no practical effect ---- as you would know if you knew anything about TCAS and the coverage volumes, and what triggers a TA and an RA. Hence the few manufacturers of TCAS/ACAS have no plans to avail themselves of the existing RTCA standard --- which is available now.

Love from the East

Tootle pip!!

PS: You should get into the claims that Bankstown is still the busiest Secondary, the real movement rate is not within a bull's roar of Jandakot.

[LeadSled]

Scurvy,
Where do I start ---- so let's stick with facts ---- You're right about VDL-2--- of no interest to GA, but please go back to the history of the ICAO "competition" for a modern broadband datalink, UAT v. VDL-4 ---- and the latecomer --- 1090ES, so now a large number of aircraft are going to need "almost" VDL-4, as well as 1090ES, a very expensive doubling up.

Retrofitting 1090ES to any "glass cockpit" that did not come factory fitted, is measured in $$MM, given the SAS experience of equipping MD80 with VDL-4, the answer is "moderate", in the order of $250,000 per AC. Sorry, I don't have the issue of AWST to give you precise references.

We all owe you a vote of thanks for the National Transport Commission consultation draft, a careful study will help everybody understand the serious shortcomings in the JCP (and its preceding) documents.
Perhaps you should all look at Jones v. Bartlett [2000] HCA 56 and the words of Chief Justice Gleeson at 23, for an HCA definition of safety, somewhat different (and far more recent and supported) than that preferred by Civilair.

From the NTA Consultation draft:

These duties of care do not require safety at any cost. Duties to ‘ensure’ are qualified by the statement ‘so far as is reasonably practicable’ (SFAIRP). The SFAIRP qualification is either included in the formulation of the obligation (the wording of the duty itself), or is indicated in the primary Act as an acceptable defence to a prosecution under the Act.

Irrespective of the means by which the qualification is added, the effect is still the same:the level of safety the duty holder must provide hinges on what is ‘reasonably practicable’ given the situation and context.

SFAIRP is a legislative qualification that is well known to the law and found in a number of statutes both in Australia and overseas. In essence, it requires weighing the risk against the resources needed to eliminate or reduce the risk.
It does not require every possible measure to be implemented to eliminate or reduce risk, but it places the onus on the person holding the duty to demonstrate (or be in a position to demonstrate) that the cost of additional measures to control the risk (over and above those risk controls already in place) would be grossly disproportionate to the benefit of the risk reduction associated with the implementation of the additional risk control.

Note the reference to cost/benefit, having actually established the risk. When there is NO demonstrated risk (no safety case), that is not already covered by existing equipment and procedures, how do you justify the cost.

Asserting a hazard/risk does not make it so.

From the NTC13.

Step 1: Risk Identification This step is the essential starting point for satisfying your duty of care. You need to establish what risks are present
in respect to your proposed railway operations. Many risks are well known and can be immediately tackled by equally well established ways of eliminating or reducing them.
Other risks are not well known and may require some foresight and careful consideration.

This essential VERY FIRST STEP is missing from the totality of the ASTRA docs. through to the JCP re-hash. Asserting a hazard/risk does not make it so.

There is no Safety Case, and no proper Cost/Benefit analysis to justify the "mandate" of ADS-B at any level. At all times it has been and is an attempt to justify a pre-determined outcome, otherwise there would be no need to offer what look awfully close to bribes to GA, to go along with the charade.

You should also plough through the OBPR Handbook.http://www.obpr.gov.au/bestpractice/index.html

In putting up the reference to the NTC paper, you have helped reinforce the case Dr. Hall has made. Sadly, in my opinion, you have made a serious error in attacking Dr. Hall's analysis on the basis he is (amongst other things) the President of ASAC. In my opinion you are challenging his personal and professional integrity.

I choose to describe "vanishingly small" as a "statistical zero", because that is exactly what it is, a risk so small as to be negligible and can be disregarded. In risk management terms a risk can never be a mathematical zero.

The AsA risk analysis of E v.C above 10,000' was a good example of a properly conducted safety case, and the result showed a "vanishingly small" collision risk in this airspace volume, both with C and E.

The NAS 2b windback was at the other end of the scale, go read the report (commissioned by CASA) by Prof. Terry O'Neil, of ANU.

In the case of ADS-B, the safety case and proper CBA are neither good nor bad, they simply don't exist.

IF THE CASE FOR ADS-B MANDATE IS SO STRONG, WHY ARE THE PROPONENTS SO KEEN TO ENSURE THAT IT IS NOT SUBJECT TO THE STANDARD ANALYSIS for regulatory development.

As for cost of equipment, pray tell what is wrong with quoting what is actually available now (which I have done) then it is over to you to explain the logic of why a manufacturer would reduce his prices when there is a captive market, or how an unknown new manufacturer is going to come up with a magic answer.

The ONLY feasible way to have ADS-B at anything like the proposed (subsidy) prices is if only C129A GPS is used, the ATSO precludes that.

Tootle Pip!!
















Tootle Pip!!

[Scurvy.D.Dog]

... spot for ya on hook line and 'Lead' sinker :-)

… like a shark to blood
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…. Did you look for hooks before devouring … more on that later

Scurvy,
Where do I start ---- so let's stick with facts ---- You're right about VDL-2--- of no interest to GA, but please go back to the history of the ICAO "competition" for a modern broadband datalink, UAT v. VDL-4 ---- and the latecomer --- 1090ES, so now a large number of aircraft are going to need "almost" VDL-4, as well as 1090ES, a very expensive doubling up.

…. Which international aircraft are they Lead? because the only aircraft possibly affected are Int’l but they will have 1090ES won’t they …. So no issue … and if (lets assume for argument sake ALL GA Oz aircraft have 1090ES) …. they can operate OS (should the unlikely need arise) just like their commercial kero burning cousins! Irrespective of VDL-4

Retrofitting 1090ES to any "glass cockpit" that did not come factory fitted, is measured in $$MM, given the SAS experience of equipping MD80 with VDL-4, the answer is "moderate", in the order of $250,000 per AC. Sorry, I don't have the issue of AWST to give you precise references.

…. So why don’t Boeing AB et al (through IATA) see it as an issue??? .. that’s because it is not …. I come back to previous comments re Honeywell …. Do you seriously suggest Honeywell have not been in the loop on this as with all the other large manufacturers?

We all owe you a vote of thanks for the National Transport Commission consultation draft, a careful study will help everybody understand the serious shortcomings in the JCP (and its preceding) documents.

.. thanks ol’ mate, happy to assist
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….. shall I balance your enthusiastic, selective quotes with the salient point of posting the NTC paper! …. It is quite simple, I have said it before … ye ready…
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… now that you have read it with gusto, I ask you now to reread the entire document, and post back to us how the proponents of this JCP could undertake a Risk assessment when:-
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1. Quantitative and qualitative data on which to base a risk assessment of OCTA and/or outside current surveillance areas, is not possible as there is no VFR data on which to make a risk assessment! And;
2. The proposal seeks to increase the number and accuracy of the devices used to mitigate collision risk OCTA and/or Surveillance areas i.e. no risk increase! And;
3. The proposal has separated the GA sector from that of RPT and Military airspace users, and therefore any attempt to infer effects on those sectors is irrelevant! And;
4. The costs are intended (based on consultative estimates) to be zero for GA VFR and IFR. In that regard, in the context there is no requirement for a CBA specific to a cost impost on GA V’s a Benefit … in other words it is a mute point (in may well be included in the ATS and RPT CBA Risk assessments) .. one assumes they are separate!
5. If ADS-B ‘in’ is received by some or all of the GA recipients (whether paid for by the voucher or separately), then there is a demonstrable cost AND safety benefit (on this point we agree)
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.. some relevant quotes form the NTC paper regarding the above

9.2 Quantitative Risk Analysis
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Dealing with Uncertainty in QRA
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To be effective, QRA requires a good safety performance measuring system to provide data that will support the process. Without this, QRA can be little more than a series of well intentioned estimates that may add little more than less intensive techniques can offer.
Proxy data from other sources (eg comparable rail authorities) can be used, but only on the basis that differences between the rail authorities can be adjusted for appropriately in the risk estimates. In some cases, differences between rail authorities will make comparative data not usable at all.
The quality of the analysis depends on the accuracy and completeness of the data sources for the numerical values and the validity of the models used.
The uncertainty and variability of both consequences and likelihoods should be
considered in the analysis and recorded.
Since some of the estimates in QRA are imprecise, a sensitivity analysis should be carried out to test the effect of uncertainty on anticipated outcomes.
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9.3 Fault Tree Analysis
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The weaknesses of FTA are:
• they can be very time consuming to construct;
• there may be errors if branches (paths) are missed;
• substantial experience is needed;
• there is an assumption of the binary nature of failures; and
• they are a snapshot in time and need constant updating in dynamic or evolving systems.
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9.4 Event Tree Analysis
The weaknesses of Event Trees are:
• they assume events are independent and conditional only on the precursor event;
• each node within the Event Tree doubles the number of outcomes (binary logic) and increases the complexity of frequency; and
• there is a practical limit to the how many headings that can be presented (usually 8 to 10).

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How can the real risk (particularly OCTA) be quantified without any data that suggests that the risk is tolerable?

10. RISK IMPROVEMENT AND MAINTENANCE PROGRAMS
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10.1 Valuing Improvements in Risk
This section of the Guideline provides guidance with respect to the proposal and assessment of risk reduction projects. It is important in the first instance to gain an understanding of how to convert safety benefits and dis-benefits to monetary terms as a sanity check against project and program costs
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The concept of VFP (Value for Preventing a Fatality)
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When undertaking comparisons between costs and benefits as part of the determination of what is reasonably practicable, it is necessary to convert the safety benefits (the reduction in risk measures in fatalities, injuries or dollars avoided) to a monetary value (dollars).
Generally, this is done using a standard conversion factor. This factor is the “Value for Preventing a Fatality” (VPF).
The VPF is an economic conversion factor which includes more than the direct financial costs avoided. The VPF factor can be applied to equivalent fatalities in order to take injury costs into consideration. Its value is in comparing investment in risk reduction with value obtained in a common currency.
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The above calculation is based on the residual risk of the duty holder as seen in the SMS.
The SMS includes a large number of controls which need to be maintained and (in the case of infrastructure and fleet) replaced periodically to maintain residual risk at existing levels. It is relevant to look at the “inherent risk” seen in the Principal Risk Register to make a judgement on the value of these existing controls from a safety perspective. In the case of the fictitious Metro duty holder referred to above, by not maintaining existing controls, Equivalent Fatalities could rise to 100 annually (much higher figures are seen commonly on third world railways under similar circumstances). The VPF for avoiding
such a decline would exceed $120M annually. This figure is in addition to that invested in improved safety measures.
For most practical duty holders, the cost of maintaining existing controls is much less than that figure. Procedures should be in place to maintain the effectiveness of existing controls on a “no less safe” basis without necessary reference to a cost/benefit analysis.
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Staging options and their implications
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Where a safety improvement opportunity has been identified, a number of staging options generally exist for its implementation. The cost of implementation will often vary greatly depending on the staging option chosen.
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Typical staging options are
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• Require the improvement to be adhered to for all future works as well as implementing a rework project to modify all existing locations (this model was adopted when changes to signal bonding practices at points were introduced). This method is generally highest cost but introduces the change most quickly.
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• Require the improvement to be adhered to for all future works as well as implementing an annual works program to modify all existing locations in priority order over a number of years (this model was adopted when introducing new technology LED signals to replace incandescent types). This method enables most efficient use of annual works funding (since locations are prioritised according to risk), but implementation period is longer.
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• Require the improvement for new projects only. This option is lowest cost. For some types of changes it may be close to cost free. However implementation will be according to the signal renewals program and may be on a cycle of 50 years or more.
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Where the cost/ benefit analysis is strongly positive, one of the first two options should be chosen.

.. now to the other waffle

…. the words of Chief Justice Gleeson at 23, for an HCA definition of safety, somewhat different (and far more recent and supported) than that preferred by Civilair.

…. Errm where does civilair come into this???

In putting up the reference to the NTC paper, you have helped reinforce the case Dr. Hall has made.

… quite the opposite, but you took the lure like a trout

Sadly, in my opinion, you have made a serious error in attacking Dr. Hall's analysis on the basis he is (amongst other things) the President of ASAC.

…. So you are admitting Hall is against this proposal for the reasons you cited earlier ?

In my opinion you are challenging his personal and professional integrity.

… your opinion is erroneous in so far as I mearly point out a reality … regarding the efficacy of a Risk assessment that cannot be undertaken (without data) and therefore cannot be accurate. God help some poor bastard trying to extrapolate an unnecessary RA from data he/she does not have, only to have you lot rip it/them to shreds …. Aren't you suggesting (through Halls quotes) that ASAC is calling for a process that is not possible nor IMHO warranted ….
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… I have been managing aviation risk as part of my occupation for 17 years, you refer to me and others as all sorts of ridiculous things .. am I offended .. no ….. offence is only taken when the barb is delivered by someone with credibility and probity!

In the case of ADS-B, the safety case and proper CBA are neither good nor bad, they simply don't exist.

.. given what we know (JCP), the safety case is irrelevant (no negative), and the CBA is based on consultation with groups that Hall would likely not have discussed the issues/amounts with .. please do not be offended that I would believe the Access Eco CBA over Hall

IF THE CASE FOR ADS-B MANDATE IS SO STRONG, WHY ARE THE PROPONENTS SO KEEN TO ENSURE THAT IT IS NOT SUBJECT TO THE STANDARD ANALYSIS for regulatory development.

…. What were you saying earlier about rose coloured glasses …. Keen no … obvious yes!

As for cost of equipment, pray tell what is wrong with quoting what is actually available now (which I have done)

… no, your old numbers were blown outa the water!

then it is over to you to explain the logic of why a manufacturer would reduce his prices when there is a captive market,

.. its called international competition … you and Dick should know all about that … or is that only when it suits the argument?

or how an unknown new manufacturer is going to come up with a magic answer.

.. I am sure Microair (as just one manufacturer ) would take exception to that!

The ONLY feasible way to have ADS-B at anything like the proposed (subsidy) prices is if only C129A GPS is used, the ATSO precludes that.

….. yawn … yes OK Lead
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Nighty nite then Happy!

[Quokka]

Leadsled, ditch the Civilair conspiracy theory, this is industry driven, not Union driven.

I live on the other side of the planet and I have absolutely nothing to gain financially from supporting the proposed introduction of ADS-B in Australia. But, after two decades of aviation, from both sides of the fence, having seen the limitations of TCAS, see-and-avoid, and old RADAR technology, I am supporting this for one reason alone... it will save lives. Maybe not your life by sheer probability, but it will save other peoples lives. And they will never know it, and neither will you. But I've come to the conclusion that you don't give a about anyone else's life.

Accept this from someone who understands the problem very very well, because I see it every working day of my life. I don't work for Airservices. I don't work for CASA. I don't work for the ATSB. I'm not a member of Civilair.

It is necessary and it will save lives.

[SM4 Pirate]

A little thread drift if I may

Leadsled et al,

This isn't about all about cheaper service that just may be safer (cost outlay now, savings later).

Take the WA area's mine sites; morning and arvo push is just damn dangerous at times; aircraft kept below preferred cruising and pushed below descent profiles, sprayed with traffic OCTA, within an outside the CTAF(R)s. There is no radar coverage outside 160NM Perth down in the weeds and the high level coverage is extremely limited in it's application due to all those nasty procedural standards that must be used before the blip drops off; not after; not to mention the issues with the blips yet to appear on radar inbound.

A trial done in NAS days (about 2 years ago); 'faked' radar coverage over the goldfields. The sectors that normally split into "5 busy consoles" were able to handled on one console with very little effort; the difference between radar and procedural separation and not having to prove all those standards and take all those reports.

If ADS-B fittment can achieve similar "like coverage" without the expense of installing 3 radar heads in outback WA then it will be a win win for all; less controllers needed ipso facto cheaper service; traffic given when it's needed; not because it falls within the "criteria"; combine this with the DS dream of more class E airspace and controller 'protection'.

But, it only takes a small % of aircraft flying around without the gear and the whole system falls apart. Why? Well because for every non ADS-B aircraft that need the 'procedural criteria or separation' then those that do have it need to be effectively kept away (outside the tolerances) of that ones track; the more you have the less practicable that becomes; so you defensive position is treat all as if they don't have the gear to save getting it wrong; these can be career ending type mistakes if made.

When we first tried to introduce RVSM it was canned due to the % of non-capability; it was too difficult to know what to use for when and whom.

Anyway, I concur with Quokka, this will save lives; it will resolve significant workload issues and despite the ADS-B - IN arguments; from a controllers perspective ADS-B out (and in range) will be a massive improvement.

Imagine the morning sequence at ML-SY-BN without radar and then how 'easy' it works with it; if ADS-B works half as well then it will be fantastic; particularly if you manage to get every major RPT destination inside the ADS-B coverage; it's not all about what's in the cockpit; IMHO there will be massive savings and benefits just with ADS-B out.

The improved service at somewhere like Dubbo will be huge; real traffic that you are actually in conflict with; on request 'surveillance services to avoid' i.e. vectors etc; all not thought about in today's environment.

Controllers in such a system may even have enough confidence to use technology and vector IFRs away from VFRs (not that I think that should be the priority) even in class G, like they do in the States cause they have confidence in their gear and system; unlike our current system where every VFR is potentially "blind" to the ATCs.

[CaptainMidnight]

SM4 Pirate Quokka

It provides visibility to ATC and all the benefits (= improved services) that go with that so it has my vote - the sooner the better.

And I'm not sure how widespread Mr Hall's support is within the sport aviation community. Visibility to ATC means potential access to CTA that is curently unavailable, an advantage a few I know recognise.

ADS-B "in" can wait - nice to have one day but not worth holding off and waiting for.

[Creampuff]

So ADSB out will be beneficial even if the position data comes from a C129A GPS?

[SM4 Pirate]

So ADSB out will be beneficial even if the position data comes from a C129A GPS?

Well, yes, is the simple answer; but whether the CASA approved 'radar like' standards will support that integrity is something to consider; but what GPS data has been used during the trial to 'prove' the technology? Everyone seems very happy with the data collected so far; quoting much more accurate than radar etc.

[Scurvy.D.Dog]

... and thus the CTA and OCTA case is made!

[gaunty]

Creamy.

YES.

[Jabawocky]

Creamy, Gaunty Scurvy.....

Seems the obvious is getting through at last....thank you for supporting what is the way of the future.

I feel like saying....Told ya so, but that would be inviting criticism.....hard hat on...off to the bunker! Goodnight

[Creampuff]

Whoa there Jab!

I count those as a ‘maybe’, a ‘therefore’ and an unequivocal ‘yes’.

I’m a simple soul and need explanations in words of one syllable.

Does the ATSO preclude C129A GPS as asserted by Leaddy? If not, what is the precise effect of the ASTO requirements with respect to C145/146 versus C129A?

[GaryGnu]

Document Trail

Creampuff,

I'll have a go (please bear in mind that I have no access to the RTCA Docs).

CAO 20.18 Appendix XI, 1 requires that ADS-B transmitting equipment that meets ATSO-C1004 or C-1005.

CAO 20.18 App XI, 2 requires that position data transmitted by ADS-B equipment is determined by TSO C145/C146 compliant receivers from 28th June 2012.

ATSO C-1005 makes no reference to FAA TSO C129a.

ATSO C-1004 Appendix 1, 4 b. (2) allows incorporation of GPS equipment into the transponder that meet the specifications of class A1 equipment as per TSO 129a. However, the ATSO adds the requirement that the GPS equipment must incorporate Fault Detection and Exclusion (FDE) capability as defined in (the no longer current) FAA Notice 8110.60.

As I understand TSO C129a vs TSO c145/c146, one of the prime differences is that C129a requires only FD algorithms and C145/C146 require FDE algorithms. There may be other differences but that is one.

Based on all of that I have to agree with Leady that a TSO C129a equipment does not comply with ATSO requirements.

I am willing to be corrected at any time on my interpretations of these documents.

I will get back to you on whether a straight TSO C129a receiver meets the requirments of FAA TSO C166 or C166a.

Also,

As far as I can tell CASR Part 172 MOS does not require ADS-B postion data derived from TSO C145a or C146a. It only requires that the ADS-B message have a NUC of 5 or better for application of the 5nm sep standard.

[Creampuff]

Hmmmm

CAO 20.18 subsections 9B.2 and 3 say:

9B.2 ADS-B transmitting equipment carried by an aircraft for operational use in Australia must comply with an approved equipment configuration.

9B.3 If ADS-B transmitting equipment carried by an aircraft does not comply with an approved equipment configuration, it must be deactivated before flight in Australia.

Subsection 9B.1 defines 'approved equipment configuration' to mean:

the requirements:

(a) set out in Appendix XI; or

(b) approved in writing by CASA and published from time to time in an Advisory Circular.

There's a note that says:

Equipment configurations approved by CASA are published in Appendix D of Advisory Circular 21-45.

So, if you want to actually turn on ADSB transmitting equipment in an aircraft in Australia, the equipment must meet the requirements of Appendix XI or the AC.

Appendix D of Advisory Circular 21-45 says:

APPROVED EQUIPMENT

The current list of approved equipment can be found at the following website address: http://casa.gov.au/rules/1998casr/02...45eqptlist.pdf

This is what appears at that address:

Approved Equipment

1. This list is not exhaustive and other equipment combinations will be added from time to time.

2. The transponder combinations have been found acceptable in accordance with the standards and guidelines set out in AC 21.45(0) and proposed amendments to CAO 20.18.

3. ACSS XS-950 transponders are not acceptable unless software modification A is incorporated.

4. GNSS receivers are included as interoperability of transponder and data source are critical to transmission of ADS-B messages fit for purpose. The GNSS receivers listed here have not been assessed by CASA for equivalency to TSO-C145a or TSO-C146a performance.

5. Where the transponder is not connected to the GPS/MMR the combination is "acceptable" but will not provide the data necessary to receive air traffic services based on ADS-B.

6. Alternate part numbers or different software modifications cannot be assumed to be acceptable and will require assessment by CASA.

[then there is a table with 1 Transponder Manufacturer and Model ('ACSS XS-950 (with software mod A)'), 2 part numbers for that transponder ('7517800-10005 and 7517800-11006'), 4 MMR/GPS Receiver Manufacturer and Models ('Rockwell Collins GLU-920' with the corresponding part numbers '822-1152-121' and '822-1152-130', 'Honeywell GR-550' with the part number 'HG2021GC02', 'Rockwell Collins GLU-920' with the part number '822-1152-002' and 'Rockwell Collins GLU-925' with the part number '822-1821-001') ]

A very simple question: What C129A GNSS receivers satisfy the MMR/GPS receiver requirements of CAO 20.18 subsection 9B?

Just the manufacturers/models/part numbers please.

[Scurvy.D.Dog]

.. its a long one .. sorry ... it might explain the state of play though!

THE FOURTH MEETING OF ADS-B STUDY AND IMPLEMENTATION TASK FORCE (ADS-B SITF/4)
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Nadi, Fiji, 26-28 October 2005
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http://www.icao.int/icao/en/ro/apac/...SITF4/ip12.pdf

Is the current ADS-B deployment good enough?
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It has been argued by some that DO260 is not good enough since a new standard DO260A has been approved and that as a matter of principle, the latest standard should be used. In this particular case however, the FAA has allowed both DO260 and DO260A to be certified against TSO C166.
DO260A requires the independent transmission of accuracy and integrity values.
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Airservices Australia (and Airbus) believe that the current avionics meets the minimum requirements. Airservices Australia is already using DO260 avionics for ADS-B separation services in Queensland with approval of the Australian regulator.
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Airservices Australia takes the view that DO260 is good enough because it is as good as “radar”. Airservices Australia has observed ADS-B traffic from Boeing and Airbus aircraft for some time using its ADS-B ground station.
DO260A has been written to serve the needs complex air-air applications which have greater needs compared to the Radar like service application and the use of DO260A in forward fit aircraft is supported.

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AUTOMATIC DEPENDENT SURVEILLANCE – BROADCAST (ADS-B) SEMINAR AND THE SIXTH MEETING OF ADS-B STUDY AND IMPLEMENTATION TASK FORCE (ADS-B SITF/6)
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Seoul, Republic of Korea, 23 – 27 April 2007
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http://www.icao.or.th/meetings/2007/...B_TF6/wp06.pdf

CONSIDERATION OF EXISTING ADS-B AVIONICS
(Presented by Australia)
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2.3 The major difference of note between DO260 and DO260A is that DO260 provides a positional data quality indicator called NUC (Navigational Uncertainty Category), while DO260A provides a positional data integrity value called NIC (Navigational Integrity Category) and a positional data accuracy value called NAC (Navigational Accuracy category). DO260A also has improvements related to ADS-B IN capabilities (i.e. ADS-B reception).
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2.4 RTCA has recently issued changes 1 and 2 to DO260A, and change 1 to DO260.
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2.5 There are no significant changes between DO260 and DO260A regarding the transmission of ADS-B data. Most features are identical. A few message formats have changed but receivers can readily cope with both DO260 and DO260A – in fact DO260A allows the existence of DO260 as DO260A version 0.
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2.6 It must be emphasized that only DO260 is consistent with ICAO Annex 10
Amendment 77. However, the Aeronautical Surveillance Panel (ASP) has developed a new ICAO manual, Doc 9871, titled "Technical Provisions for Mode S Services and Extended Squitter". The manual is expected to be published towards the end of 2007. It updates technical provisions related to Mode S radar and extended squitter ADS-B currently contained in Annex 10 Vol. III. The material on Mode S radar has been revised to reflect the experience of States currently implementing these provisions. An updated set of extended squitter provisions known as Version 1 has been introduced.
Version 1 is compatible with the RTCA DO-260A MOPS. The existing provisions, which have been renamed Version 0, will remain since there are many implementations that comply with these requirements. Annex 10 will be modified to refer to Doc 9871.
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2.7 AEEC standard ARINC 718A defines the behaviour of the avionics and installation from an airline industry viewpoint.
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2.8 RTCA and EUROCAE have just released DO303/ ED126 documents which describe the requirements for use of ADS-B to provide air traffic services in Non Radar Airspace (NRA).
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2.9 These documents have been produced by the joint Eurocontrol / FAA / RTCA / EUROCAE ADS-B Requirements Focus Group (RFG) and detail the operational, safety and performance requirements for non-radar application of ADS-B. They include an “interoperability document” at Annex H which gives details which messages are required. Aircraft already equipped with DO260 equipment meet these requirements, provided that the installation provides positional integrity data to the transponder. The positional integrity value used is called the “Horizontal Protection Limit” (HPL).
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2.10 The RFG plans to issue further documents, in particular to cover the use of ADS-B for air traffic services in Radar Airspace, and for air-to-air applications such as In Trail Procedures.
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3. What is the Perceived Problem with DO260?
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3.1 Background:
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GPS is the only practical source of ADS-B positional data today – although the standards allow equivalent performance systems.
Suitable GPS receivers output HPL which guarantees that the reported position is within the HPL distance, with high certainty (10E-7). The HPL value is calculated based on the ability of the GPS receiver, when presented with the satellite set, of detecting a “bad” ranging signal from a faulty GPS satellite. GPS receivers also output a value called Horizontal Figure of Merit (HFOM), which is the expected accuracy of the positional data assuming that all satellites are working correctly
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3.2 Calculation of transmitted integrity value DO260 as written requires the transmitted NUC value to be based on HPL if HPL is available on the aircraft (this is good from the point of view of data integrity).
However, DO260 allows the transmitted NUC to be based on HFOM if HPL is not available (this is not good – because when using HFOM the user of the data isn’t protected from satellite ranging errors). DO260A (and DO260 change 1) requires NIC to be based on HPL and does not allow this exception. When NUC is based on HPL, then DO260 avionics are essentially the same (with respect to positional integrity) as DO260A avionics, i.e. essentially NUC=NIC when HPL is used to generate NUC.
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The DO303 (and ED126) Annex H interoperability requirements require the DO260 NUC value to be based on HPL by design (para H.1.4.5.2), but recognises that it may switch to HFOM when the GPS receiver is first switched on (initialisation) or when there are not enough GPS satellites to adequately determine the required positional surety. DO303 Annex G demonstrates that the risks of using HFOM in these cases are lower than the base case when HPL is used – because satellite ranging errors are so rare.
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This is further supported in the DO303/ED126 Safety assessment (Annex C): the rare NUC-HFOM encoding case is corresponding fully with the case of “(Undetected) Quality Indicator Corruption” (ED-126 Fault Tree ‘OH4u3’): both from an interoperability and operational effect perspective. ‘OH4u3’ produces a 10-5/fh requirement for the relevant “Airborne Quality Indicator Corruption” failure. Conceptually and in terms of effect, this failure is equivalent to the rare encoding of HPL based on HFOM;
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3.3 Accuracy and integrity must be transmitted separately
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DO260A requires that positional integrity data is transmitted as NIC as discussed above, and that accuracy is transmitted separately as NAC. As seen from para 0, DO260A NIC and DO260 NUC can be seen as equivalent if the avionics use HPL, by design.
It is Airservices Australia’s view that, for ATC surveillance applications, whilst it may be desirable, the accuracy value (NAC) is not strictly required if the integrity limit is known. Eg: If the integrity value guarantees with high certainty that the positional data is within say 0.5 nautical mile –it is of limited value to know what the 95 percentile accuracy value is. In any case a conservative accuracy figure can be determined from the integrity value.
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It is true that some Kalman filter based systems could use a separate accuracy value – but if the data has integrity indicating it is “good enough to use” then knowledge of the accuracy is of minor value. It is recognised that some future applications may require accuracy. Surface surveillance may be one such application.
For air-air applications, whilst not yet confirmed, it is suspected that if the integrity value is known, and is acceptable, accuracy is unlikely to be required – for the same reasons.
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3.4 DO260 is not acceptable for ADS-B IN capable aircraft
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It is well accepted that DO260A receiver systems are desirable for ADS-B IN applications because of the improved receiver processing techniques proposed in DO260A1. However, the receiver system is required to correctly process DO260 based transmissions.
Normally (in current deployed equipment) the ADS-B receiver system is a separate equipment to the ADS-B transmitter. Therefore, current DO260 aircraft may not necessarily need to replace their ADS-B capable transponder when implementing ADS-B IN.
However, DO260 transmissions remain safe and useable for ADS-B IN providing positional integrity data is used (i.e. HPL). As expressed above there are no identified weaknesses of DO260, solved in DO260A, that warrant exclusion of DO260 aircraft from ADS-B IN operations. Of course, as the definition of ADS-B IN applications continue, deficiencies in both DO260 and DO260A are likely to be identified.
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1 It is not mandatory to follow the proposed algorithm. Another algorithm may be proposed, provided the manufacturer demonstrates equivalent performance
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4. What is the position of various agencies ?
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4.1 FAA:
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The FAA has published TSO C166 which allows ADS-B avionics to be certified against either DO260 or DO260A. TSO C166 also requires aircraft to transmit SSR code in the ADS-B messages to allow legacy ATC systems to more easily correlate ADS-B data with radar. However, DO260 does not support transmission of SSR code.
More recently, the FAA published TSO C166A which only allows future compliance with DO260A change 2. RTCA DO260A change 2 clarifies TIS-B requirements and changes ADS-B IN processing.
Previous approvals under TSO C166 may continue to be manufactured. New approvals have to be applied for under TSOC166A.
The FAA envisages an environment by 2020 whereby there is a mandate for carriage and use of DO260A change 2 avionics.
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4.2 Europe:
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The European CASCADE program’s ADS-B Pioneer program will accept either DO260 or DO260A avionics. Europe has prepared a Notice of Proposed Amendment (NPA) based on the ED126 (DO303) requirements and major aircraft manufacturers are looking to certify against this NPA. It is reported that 11 European airlines (more than 250 airframes) will request EASA to certify current (DO260) avionics for use with the CASCADE program in the first half of 2008. CASCADE is considering a second wave of pioneer airlines.
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4.3 Australia:
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Australia will accept DO260 or DO260A avionics; and will be ready when further revision is available.
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5. What is installed on aircraft today?
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5.1 Transponders:
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Almost all aircraft transmitting ADS-B today are equipped with TSO C112 transponders complying with the European Mode S mandate. These transponders comply with an (adequate) subset of DO260. Many thousands of aircraft are already transmitting. The subset of messages being transmitted complies with the requirements of DO303/ED126.
There are almost no DO260A avionics available except for Rockwell Collin’s TDR94D-108 used in regional aircraft, and the integrated A380 avionics from Honeywell. There are almost no ADS-B IN implementations at this time except for a number of UPS freight aircraft. DO260A processing is expected in all ADS-B IN avionics. All transponder vendors for large aircraft use HPL for calculation of NUC. An earlier ACSS transponder did not, and ACSS has issued a service bulletin to correct this. The upgraded ACSS transponder uses HPL only.
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5.2 Positional Data:
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Until the recent publication of the STP MOPS DO302, most ADS-B standard setting has unfortunately concentrated on the transmitter (transponder) and has not concentrated on the requirements of the positional source.
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The following may be helpful:
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• Altitude comes from the same source as transponder Mode C data.
• If positional data comes from the Inertial Navigation System (INS) or Inertial Reference System (IRS), it usually doesn’t have an HPL (or equivalent) and hence the ADS-B message reports NUC=0 (no integrity), i.e. the ADS-B data is effectively unusable.
• When the positional data comes from a GPS source (such as a Multi-Mode Receiver, MMR) then the issues are:
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Does the GPS provide HPL (some don’t)?
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• Does the GPS have Fault Detection & Elimination (FDE) which eliminates data from satellites detected as faulty from the solution, allowing ADS-B data with good NUC to continue to be broadcast? This is an availability issue.
• Does GPS assume Selective Availability (SA) is on? Unfortunately many do, which increases the size of HPL and decreases the percentage of time that an acceptable GPS signal is received? This is also an availability issue.
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• DO-302 STP MOPS provide suitable standards for the positional data source including the use of INS and MMR data for ADS-B purposes. However, here are no avionics available today or in the short term, that will comply with DO-302.
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6. What can be used by ATC today?
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6.1 Australia has deployed, and operationally uses ADS-B for 5 nautical mile separation.
ADS-B ground stations which can receive both DO260 and DO260A have been used. Australia is ready for and already supports DO260A aircraft when they arrive in Australia.
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6.2 However, DO260 is only considered adequate IF the transponder is provided with HPL and the transponder uses HPL to calculate NUC, i.e. Australia requires DO260 with HPL.
6.3 Essentially Australia considers DO260 (as implemented in many aircraft) as equivalent to DO260A if HPL is used.
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6.4 Currently, Airservices and CASA individually check and then authorise each airframe to participate, i.e. check that the above requirements of paragraph 0 are met before changing a filter in the ATC system to allow the aircraft to be seen by ATC.
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6.5 In parallel Australia’s regulator has published a Notice of Proposed Rule Making (NPRM) to require those transmitting ADS-B to transmit data compliant with either DO260A or DO260 with HPL provided. The effective date for this rulemaking is not yet decided. Some time after it becomes effective Australia will cease individually checking airframes.
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6.6 Australia has approved ADS-B operations for over 380 airframes. Avionics checks to date show that the majority of rejections are because:
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• The aircraft are equipped with ACSS transponders that not upgraded with the Service bulletin (hence don’t use HPL), or
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• The aircraft have inadequate GPS due lack of true HPL.
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7. Surface movement applications
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7.1 The use of Ads-B data to support, surface movement surveillance applications of ADS-B appears promising and a number of states are considering this application.
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7.2 DO260 unfortunately encodes the integrity data in a way such that if HPL is >182 metres (0.1 nautical mile), surface squitter sends NUC=6 meaning no integrity.
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7.3 Thus DO260 equipped aircraft are not able to deliver any useful integrity value unless the HPL<182 metres. Data collection in Australia shows that about 40% of Air Transport aircraft reports (DO260) currently report with NUC=6 (no integrity) when on the surface.
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7.4 One implication of this is that the surface movement system will treat identically the following cases because it cannot tell them apart when using DO260.
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�� An aircraft with high accuracy, but HPL integrity value at say 200 metres ,
transmitting NUC=6.
�� An aircraft with no GPS, at the end of a long flight, transmitting INS positional data with a 1 nautical mile error, with NUC=6.
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7.5 Surface movement applications could perhaps utilise accuracy (from DO260A) or other monitoring systems to guarantee adequate safety but there has not yet been adequate study nor determination of appropriate standards for this application.
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7.6 At face value, the use of DO260A, which reports accuracy may solve this problem, assuming that the surface movement application can detect faulty GPS ranging errors by other means.
In many cases, since the surface surveillance is advisory, integrity monitoring may not be required.
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8. What is the Australian & Airbus position?
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8.1 Australia supports DO260A but recognises that DO260 avionics have already been installed in thousands of aircraft. DO260A avionics are not yet readily available. Australia believes that significant safety and efficiency benefits can be realised worldwide using DO260 avionics in the period before DO260A becomes common.
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8.2 CASA and Airservices can see no legitimate rationale for denying safety and efficiency benefits to early equippers of ADS-B in the Australian environment.
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8.3 It is understood that Airbus also have this view. Airbus is currently involved in certification of avionics for the European CASCADE certification activity – against a NPA based on the ED126 interoperability document.
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8.4 The solution is to transition to DO260A as soon as possible for forward fit, but also to recognise that significant benefit can be gained from use of DO260 data in the meantime. There is no strong case for retrofit at this time except for compliance with FAA envisaged mandates and in the case that the international community fail to recognise DO260 benefits.
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9. Recommendations
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9.1 The meeting is invited to note the benefits of accepting DO-260 equipped aircraft for provision of ATC separation services provided that appropriate measures are in place to ensure that HPL is used to generate NUC.
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9.2 The meeting is also invited to note the benefits of using DO260A for forward fit when avionics become available especially in support of surface applications and because of the FAA position.

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My bolding and underlining

[Scurvy.D.Dog]

Re TSO 129a ... and its interations

TSO 129a standard/s including (RAIM or FDE RTCA208 and 229)
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. as best I can tell, the only difference between RTCA208 and 229 is pressure altitude input automation and GPS cross check of alt i.e. WAAS type cert … happy to be corrected though!
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There are various classes of 129a …. A1 seems to be the IFR NPA standard (with RAIM etc) …. There may be classes of 129a that are and are not approved in the ADS-B context?
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http://rgl.faa.gov/Regulatory_and_Gu...FILE/C129a.pdf
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And;
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http://www.airweb.faa.gov/Regulatory...F?OpenDocument
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TSO GNSS Nav integrity treatment
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http://www.comlaw.gov.au/ComLaw/Legi...5?OpenDocument
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Manufactures of 129a that include (FDE)
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http://investor.trimble.com/released...leaseID=191162

The twelve channel TA-12 receiver was designed, tested and documented to enable aircraft host navigation systems to be certified to the standards defined by the FAA TSO-C129a and later the JPO MSO-C129a for military aircraft. Standard features include all-in-view tracking, Fault Detection and Exclusion (FDE) and step detection in accordance with RTCA/DO-229, predictive RAIM to support FAA Notice 8110.60 operations

http://www.avionicsales.com/product/gps.htm
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… note the Nav’s with 129a A1 approval
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One assume that all current TSO GPS systems would comply with 129a A1 at least! And may have the addition of RTCA 229 Alt as well!
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... so if 129a (all) are excluded (if they are) .... the question is why given the technical capabilities of same?

[Creampuff]

Hmmmm

8.1 Australia supports DO260A but recognises that DO260 avionics have already been installed in thousands of aircraft. DO260A avionics are not yet readily available. Australia believes that significant safety and efficiency benefits can be realised worldwide using DO260 avionics in the period before DO260A becomes common.
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8.2 CASA and Airservices can see no legitimate rationale for denying safety and efficiency benefits to early equippers of ADS-B in the Australian environment.

I will try some other simple questions:

When will CASA be putting its legislative money where its task force mouth is? That is, when will CASA be amending CAO 20.18 or AC 21.45 so that DO260 avionics used as part of ASDB transmitting equipment are permitted to be switched on in aircraft in Australia?

What ASDB equipment is in the trial aircraft?

Does the ADSB equipment in the trial aircraft comply with 20.18 or have they been exempted from 20.18?

[Scurvy.D.Dog]

... fair Q's
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.. although, the caveat in the AC for approval on an individual hull basis (I assume) is to cover differences in 129a standards re the RTCA's
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.. none the less it needs clear clarification

[LeadSled]

Folks,

There are almost no ADS-B IN implementations at this time except for a number of UPS freight aircraft.

And that is all UAT, not 1090ES, ie; as used in Capstone and the Ohio Valley trials--- which was UPS.

Scurvey,

Gets complicated, doesn't it ---- is everybody clear when a transponder is being discussed ? or an ADS-B? Can you find me a DO260A or a DO260 + HPL for $$ten grand----fifteen-----thirty. Then add the GPS. Please look up the quotes for a Collins TDR94D-108 (DO260A) TXPD, and let us know, that's better than me doing it, I doubt you would believe me. But just to be helpful, the Collins CTL-94E control head, alone, lists for US$7880 at Southeast Aerospace. Continuing in my helpful mode, the above transponder P/N is 622-9210-108. Don't confuse this version with the other TDR94D that range between US$20-32,000 new.

Starting to make the complete Garmin ADS-B reference unit plus GTX330D at about US$16,000 plus (say) $5000 fitting look a steal.

Gaunty --- how are you going with your mates at RFDS? Got the prices yet for all that Bendix-King gear? Does it meet the ATSO? --- Scurvey has helpfully produced a helpful guide for you all.

And all for an alleged safety problem that is not even on the ATSB "radar", see the latest analysis.

If we want to pour $100-300M into something that will address the top safety issues, how about starting with pilot training --- with a view to saving some of the lives being actually lost.

Tootle pip??

PS: Creamy, I think you mean DO260+HPL.