View Poll Results: Which ADS-B scenario do you support?
Scenario 1 (Status quo)
25
12.69%
Scenario 2 (subsidised-60% VFR fleet fitment)
8
4.06%
Scenario 3 (subsidised-90% VFR fleet fitment)
164
83.25%
Voters: 197. This poll is closed
ADS-B + Subsidy - It's on the table - Submn's close 31 Oct
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How about a bit of research before posting - it's all in the joint consultation paper that can be found at http://www.dotars.gov.au/aviation/ai...Technology.pdf. 
If you don't have the time to read the lot, go to the FAQ's at the end.
Firstly, under the proposal ALL aircraft (except aircraft without an engine powered electrical system and some military aircraft) will be required to be fitted and used in E airspace and above, G above A050 and in CTAF(R)'s. This includes foreign registered aircraft, however only aircraft below 5700kg MTOW receive the subsidy.
Secondly the system will be using the 1090MHz ES which does NOT require a ground station for another aircraft to use the data - ADS-B IN receivers will receive and process the transmission from other aircraft - similar to ACASII. So an aircraft equipped with ADS-B IN will receive ADS-B out data from all aircraft that are within line of sight irrespective of ground station location.
As to cost - according to the paper it is revenue neutral and should cost aircraft below 5700kg nothing - according to the paper each aircraft should receive a TSO'd GPS as part of the package for no cost. According to the paper the airspace charges for the "big end of town" will be reduced which will recoup the cost of the installation for them.
Chimbu chuckles & ForkTailedDrKiller - care to reconsider your comments in light of the above?
As to the argument about not being provided with a verbal warning or instructions on ADS-B in equipment - do we really need it? There can only be one system that does this, and that should be ACAS (TCAS) (ACAS can be improved by including ADS-B data, I believe ICAO are looking at this). We will have to treat ADS-B IN the way we use the mark one eyeball and most of other aircraft instruments - by including it into our scan to increase our situational awareness.
Given the improvements in battery technology and the likely low weight and power consumption of the equipment wouldn't this be the ideal time to include aircraft without an engine driven electrical system as well? If so the subsidy must be sufficient to cover the complete cost of the installation.
I agree with Scurvey.D.Dog that this a great step forward, at effectively no cost to light aircraft, it's a step forward like the introduction of radio, the introduction of radar, and the introduction of mode C transponders.
If you don't have the time to read the lot, go to the FAQ's at the end.Firstly, under the proposal ALL aircraft (except aircraft without an engine powered electrical system and some military aircraft) will be required to be fitted and used in E airspace and above, G above A050 and in CTAF(R)'s. This includes foreign registered aircraft, however only aircraft below 5700kg MTOW receive the subsidy.
Secondly the system will be using the 1090MHz ES which does NOT require a ground station for another aircraft to use the data - ADS-B IN receivers will receive and process the transmission from other aircraft - similar to ACASII. So an aircraft equipped with ADS-B IN will receive ADS-B out data from all aircraft that are within line of sight irrespective of ground station location.
As to cost - according to the paper it is revenue neutral and should cost aircraft below 5700kg nothing - according to the paper each aircraft should receive a TSO'd GPS as part of the package for no cost. According to the paper the airspace charges for the "big end of town" will be reduced which will recoup the cost of the installation for them.
Chimbu chuckles & ForkTailedDrKiller - care to reconsider your comments in light of the above?
As to the argument about not being provided with a verbal warning or instructions on ADS-B in equipment - do we really need it? There can only be one system that does this, and that should be ACAS (TCAS) (ACAS can be improved by including ADS-B data, I believe ICAO are looking at this). We will have to treat ADS-B IN the way we use the mark one eyeball and most of other aircraft instruments - by including it into our scan to increase our situational awareness.
Given the improvements in battery technology and the likely low weight and power consumption of the equipment wouldn't this be the ideal time to include aircraft without an engine driven electrical system as well? If so the subsidy must be sufficient to cover the complete cost of the installation.
I agree with Scurvey.D.Dog that this a great step forward, at effectively no cost to light aircraft, it's a step forward like the introduction of radio, the introduction of radar, and the introduction of mode C transponders.
Last edited by werbil; 19th Aug 2007 at 00:41. Reason: add ftdk
Grandpa Aerotart
I have read the blurb on the AsA website.
ADS-B in is not mandated/subsidised only ADS-B out. A TCAD fit for a typical GA light aircraft is about USD20k++...I have no reason to suspect 'in' will be lot cheaper...even if it is 1/2 TCAD it will still be USD10k.
ADS-B for GA will be purely a surveilance tool.
Don't get me wrong...satellite based ATM is the way of the future...but why the (seeming) undue haste?
I get the feeling the are trying to sell us something quickly so they can decommission some radars in the next cycle of scheduled replacement rather than the one after that. It has a 'NAS2b' feel about it....rushing it in shouting it's benefits from the roof tops and hoping people don't ask too many difficult questions.
After the first 28 stations are commissioned the low level ADS-B coverage will be sparse to say the least.
What is the time frame and how many stations required to extend ADS-B down to levels where the GA aircraft they are mandating fitment operate...<8000'?
What will ADS-B give those few aircraft that wil have 'in' (eventually), High end/regional turboprops and jets, that they dont get now from TCAS?
The requirement for turbine carrying more than x passengers to carry TCAS going to be withdrawn?
Why do I need to know where aircraft that cannot effect my operation, because they are outside the range of my TCAS, are?
If ADS-B is not going to have any effect on capital city terminal airspace capacity, because of noise sharing/runway constraints that ADS-B cannot address, and the enroute airspace in Australia is not crowded as is that in the US/EU why the rush?
One of the drivers, if not THE driver, for the FAA's move to satellite based ATM is they have convinced themselves that their airspace is going to be inundated with many 1000s of VLJs...the way the US economy is going that very much remains to be seen...and who cares anyway it won't effect Australia...we might see 20. The US probably has a real need even without 1000s of VLJs but they are not rushing in mandating everything capable of sustained flight has ADS-B within 5 years...why are we?
Why don't we just wait and see what Australia needs rather than base decisions on what countries with truly busy airspace feel they need?
Australia has such a tiny aviation industry compared to the US/EU/Asia etc...the last thing we need to be doing is behaving like trendsetters in this area.
What imperative does mandatory ADS-B out in GA answer?
ADS-B in is not mandated/subsidised only ADS-B out. A TCAD fit for a typical GA light aircraft is about USD20k++...I have no reason to suspect 'in' will be lot cheaper...even if it is 1/2 TCAD it will still be USD10k.
ADS-B for GA will be purely a surveilance tool.
Don't get me wrong...satellite based ATM is the way of the future...but why the (seeming) undue haste?
I get the feeling the are trying to sell us something quickly so they can decommission some radars in the next cycle of scheduled replacement rather than the one after that. It has a 'NAS2b' feel about it....rushing it in shouting it's benefits from the roof tops and hoping people don't ask too many difficult questions.
After the first 28 stations are commissioned the low level ADS-B coverage will be sparse to say the least.
What is the time frame and how many stations required to extend ADS-B down to levels where the GA aircraft they are mandating fitment operate...<8000'?
What will ADS-B give those few aircraft that wil have 'in' (eventually), High end/regional turboprops and jets, that they dont get now from TCAS?
The requirement for turbine carrying more than x passengers to carry TCAS going to be withdrawn?
Why do I need to know where aircraft that cannot effect my operation, because they are outside the range of my TCAS, are?
If ADS-B is not going to have any effect on capital city terminal airspace capacity, because of noise sharing/runway constraints that ADS-B cannot address, and the enroute airspace in Australia is not crowded as is that in the US/EU why the rush?
One of the drivers, if not THE driver, for the FAA's move to satellite based ATM is they have convinced themselves that their airspace is going to be inundated with many 1000s of VLJs...the way the US economy is going that very much remains to be seen...and who cares anyway it won't effect Australia...we might see 20. The US probably has a real need even without 1000s of VLJs but they are not rushing in mandating everything capable of sustained flight has ADS-B within 5 years...why are we?
Why don't we just wait and see what Australia needs rather than base decisions on what countries with truly busy airspace feel they need?
Australia has such a tiny aviation industry compared to the US/EU/Asia etc...the last thing we need to be doing is behaving like trendsetters in this area.
What imperative does mandatory ADS-B out in GA answer?
Creamie,
M'learned friend, a question for you.
ICAO has no plans to mandate any or all of the three competing ADS-B systems.
In the absence of such an ICAO mandate, can the Commonwealth of Australia ban non-Australian aircraft from Australian airspace, contrary to the provisions of the freedoms established by the Chicago Convention, if they do not carry a form of ADS-B that meets the proposed Australian mandate.
Put another way, does the Australian Constitution give the Australian Government the power to make such a rule that is enforceable on non-Australian aircraft.
Tootle pip!!
M'learned friend, a question for you.
ICAO has no plans to mandate any or all of the three competing ADS-B systems.
In the absence of such an ICAO mandate, can the Commonwealth of Australia ban non-Australian aircraft from Australian airspace, contrary to the provisions of the freedoms established by the Chicago Convention, if they do not carry a form of ADS-B that meets the proposed Australian mandate.
Put another way, does the Australian Constitution give the Australian Government the power to make such a rule that is enforceable on non-Australian aircraft.
Tootle pip!!
I'm in one of those moods
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Chuck .... the time frame for SSR replacement is (as I understand it the driver) .. and the funds available if that does not factor.
.
Interesting the points made, either way, the traffic will still move!
.
... NAS2B like ..... you suprise me Chuck
.
... ASTRA (including industry reps and experts) have been working on this for years ...they have put the cards on the table for comments (hope many have, for or against) explained the funding window and why .... how does that compare with NAS2B?
.
Stick with TCAS and MSSR ... don't bleat when the inevitable happens ... the predictive quote from the oracle is telling!
.
.... lets run a book shall we?
.
- Cost of ADS-B (including 'in') for GA?
- Whether Boeing and AB et al will have 1090ES TCAS 'in' interface within 12months?
- Whether locations like Broome, Alice and other regional Jet locations will have surveillance to ground level in the two senarios i.e. ADS-B or MSSR is the norm into the future?
- Whether 'effective' pilot self separation (IFR and VFR) will occur OCTA?
- Whether aural alerting included in ADS-B 'in' becomes the norm for GA?equipment at affordable levels (given the subsidy)?
.
.... its up to ewe's
.
WX in NRM was good!
.
Werbil
.
Interesting the points made, either way, the traffic will still move!
.
... NAS2B like ..... you suprise me Chuck
.
... ASTRA (including industry reps and experts) have been working on this for years ...they have put the cards on the table for comments (hope many have, for or against) explained the funding window and why .... how does that compare with NAS2B?
.
Stick with TCAS and MSSR ... don't bleat when the inevitable happens ... the predictive quote from the oracle is telling!
.
.... lets run a book shall we?
.
- Cost of ADS-B (including 'in') for GA?
- Whether Boeing and AB et al will have 1090ES TCAS 'in' interface within 12months?
- Whether locations like Broome, Alice and other regional Jet locations will have surveillance to ground level in the two senarios i.e. ADS-B or MSSR is the norm into the future?
- Whether 'effective' pilot self separation (IFR and VFR) will occur OCTA?
- Whether aural alerting included in ADS-B 'in' becomes the norm for GA?equipment at affordable levels (given the subsidy)?
.
.... its up to ewe's
.
WX in NRM was good!
.
Werbil
Grandpa Aerotart
I am not trying to convince anyone of anything...and please guys I feel uncomfortable with "If CC says it is so that is good enough for me". I appreciate the sentiment but I'd be much happier if you look at what I write critically, do your own research that answers the questions I pose or statements I make based on MY understanding of an issue...and then challenge me if you don't agree....that way we all learn something...I love learning new stuff...I have learned lots in the course of this thread.
ADS-B is great in and of itself...the local context is the question.
SSD...answer my questions based on your understanding of the issues.
They are not rhetorical questions designed to put doubt in people minds.
My first vote was for option 3...the more I read and thought about the issues as I experience them in my work and fun flying the more questions I had...I now prefer option 1 within the Oz GA context and in the short to medium term.
Upper level ADS-B makes all the sense in the world within the local regulatory context of providing ATM coverage across a vaste continent to cheaply...how many current generation Boeings/Airbus will be ADS-B capable remains to be seen...I remain to be convinced about the practicle/political realities of low level ADS-B.
With no time line for low level ADS-B you can not logically have a time line for mandating GA fitment.
ADS-B is great in and of itself...the local context is the question.
SSD...answer my questions based on your understanding of the issues.
They are not rhetorical questions designed to put doubt in people minds.
My first vote was for option 3...the more I read and thought about the issues as I experience them in my work and fun flying the more questions I had...I now prefer option 1 within the Oz GA context and in the short to medium term.
Upper level ADS-B makes all the sense in the world within the local regulatory context of providing ATM coverage across a vaste continent to cheaply...how many current generation Boeings/Airbus will be ADS-B capable remains to be seen...I remain to be convinced about the practicle/political realities of low level ADS-B.
With no time line for low level ADS-B you can not logically have a time line for mandating GA fitment.
Last edited by Chimbu chuckles; 19th Aug 2007 at 07:18.
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Q - What does ADS-B Out do for me?
A - Most of OZ is currently not surveilled, this means aircraft must be separated by ridiculously large, inflexible procedural standards. Procedural standards are typically 6 times larger than surveillance standards as well as being much more complex to apply. If ATC can see you we will say no to your requests much less often (about 85% less often)
Air Route design is dictated by the silly procedural standards - this costs you time and money as well as forcing aircraft onto two way routes over existing ground based NAVAIDs which is dangerous and stupid - Surveillance means more direct tracking as well as racetrack patterns. Racetracks make clouds less lumpy.
Procedural traffic information is better than nothing - but not that much better. Which would you prefer? "IFR traffic is ABC passed somewhere sometime ago estimating somewhere else sometime in the future" OR "Traffic in your 11o'clock 4nm crossing right to left"
Extension of control area protection below F180 is very difficult without Surveillance - assuming there is enough traffic to warrant control area protection. If Dick were to get his way, and class E was extended down to 1200ft outside radar coverage, you can expect the system to grind to an immediate shuddering halt. Start clearances anyone?
Apart from keeping our customers from encountering a lumpy cloud, one of the ways we ATC's earn our pay is to assist in some small way if an aircraft gets into trouble. Take it from me there is a hell of a lot more we can do for you if we can actually see you.
Of course I am an ATC - and therefore may be involved in the great government/union/alien ADS-B conspiracy to control the minds of iconic entrepreneurs everywhere - feel free to detune your radio and don tin foil hat.
A - Most of OZ is currently not surveilled, this means aircraft must be separated by ridiculously large, inflexible procedural standards. Procedural standards are typically 6 times larger than surveillance standards as well as being much more complex to apply. If ATC can see you we will say no to your requests much less often (about 85% less often)
Air Route design is dictated by the silly procedural standards - this costs you time and money as well as forcing aircraft onto two way routes over existing ground based NAVAIDs which is dangerous and stupid - Surveillance means more direct tracking as well as racetrack patterns. Racetracks make clouds less lumpy.
Procedural traffic information is better than nothing - but not that much better. Which would you prefer? "IFR traffic is ABC passed somewhere sometime ago estimating somewhere else sometime in the future" OR "Traffic in your 11o'clock 4nm crossing right to left"
Extension of control area protection below F180 is very difficult without Surveillance - assuming there is enough traffic to warrant control area protection. If Dick were to get his way, and class E was extended down to 1200ft outside radar coverage, you can expect the system to grind to an immediate shuddering halt. Start clearances anyone?
Apart from keeping our customers from encountering a lumpy cloud, one of the ways we ATC's earn our pay is to assist in some small way if an aircraft gets into trouble. Take it from me there is a hell of a lot more we can do for you if we can actually see you.
Of course I am an ATC - and therefore may be involved in the great government/union/alien ADS-B conspiracy to control the minds of iconic entrepreneurs everywhere - feel free to detune your radio and don tin foil hat.
I'm in one of those moods
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My opinions only
… if in the process of fitting avionics that includes a GNSS as per the AC and ‘out’ .. does it exclude ‘in’ if it is part of the unit? .. not that I can see!
…. Again, maybe … how will we know unless manufacturers know that a critical mass of units will be purchased? … if the standard is common across the globe …. Are we suggesting that GNSS/OUT/IN/Aural cannot be incorporated into one box? … how do the manufacturers answer that until they know there is a market? …. Is Garmin’s jump just a precursor? … maybe maybe not …. The naysayer’s were bleating about no units just weeks ago! … are Garmin the only ones that are gunna build this stuff …doubt it!
.. partly, ATS DTI/ATC Serv to IFR, IFR CDTI (it will happen), VFR CDTI if enough people bark for it!
.. it's in the doc’s … folks wishing to reduce delays in CTA and reduce third party intervention OCTA and reduce the chance of IFR smacking into VFR, or VFR smacking into VFR ….. sure, dependant on gear in the aircraft …. How many GA aircraft are not seen by TCAS?? … to suggest Mode A, C are even in the same ball park from an accuracy and reliability point of view is fanciful!
… it's no feeling Chuck, it is spelt out they have made that funding justification perfectly clear! …. I ask this, if the radars are replaced, and the funding is then not available …. How long unitl ADS-B is mandated do you think? ... a radar lifetime is 20+ years … and in that time how much are the industry paying in delays and ATS that are not necessary?? … has anyone asked that question? ….
… hang on …. The thing is published, there is a media release, I read the docs’ and immediately put the links etc up here to stimulate awareness and discussion … shouting its benefits from the roof tops? 
… what, cutting and pasting relevant extracts is
…. What difficult questions?
… and where are the ground stations? …. I would suggest most of them are positioned to provide line of sight at regional terminals and high level coverage ….. why would you want big brother watching you cross the Simpson Desert at A085 … would ya?
… depends on where the coverage is deemed necessary … I guess at first grab, RPT regional terminals, Regional D … but then how do you determine yet where to put low level ADS-B surveillance unless you have completed a CBA/risk analysis …. And you cannot do that for ADS-B unless aircraft are gunna be ADS-B equipped … otherwise it would need to be a CBA/Risk Ass based on MSSR …… So which would you put in place first … the chicken or the ADS-B egg’s? …… I mean god forbid making airspace decisions without the correct process right!?
…. Demand would make it more than a few ….. and accuracy, reliability and truth in azimuth
why would you do that? ICAO are working on standards now for ADS-B input to TCAS …. One assumes TCAS in the transition would receive A, C, S and ADS-B displayed/aural traffic …
… you don’t …… do you need to know about the aircraft that can effect your operation? .. of course you do …. So if you have short range .. why would you not want long range for say Oceanic
… well that depends if the industry …. i.e. you want:-
- Surface monitoring with Runway Incursion alarms (the biggest single risk in air traffic management in the world today)
- Accurate surveillance that negates expensive kit like the PRM
- Less spurious TCAS events due TMA proximities
- multiple level target response in ACAS to things like Surface vehicles visible on your CDTI (low vis op’s, runway humps etc)
- Vehicles with a basic display to see you thundering down the tar in the fog!
.
.. just to name a few … no, no rush
… VLJ is but one aspect, I would suggest the existing saturation is more the point but to identify that as the driver would be to admit not having done enough … wouldn’t it?
… because we can afford to fund the relatively smaller fleet …. Probably because we do not have the Primary and ATS infrastructure spending the US has to face because of years of indecision??
…. Yes why not!
…. The trend is already known …
…. Because we cannot afford to fit the fleet and buy radar and put in ADS-B ground stations ….! And smart SMR radars (that are no where near as smart as ADS-B) … and remember those little squat switches for the TXPDR … hmm don’t need them with ADS-B
…. That’s the best I can give you seeing I have just returned home after being on the go since 5am Friday .. but that’s another aviation story!
.. and you have based that on assumptions and the opinions of a couple whose opinions arrive without any corroboration (links, quotes etc) … your call I guess
not really, the manufacturers along with the services providers and regulators have been quoted in the documents that has the Australian Government imprimatur … as cynical as I am, I am inclined to believe IATA, ICAO, ASTRA and their composite representatives across industry (including the manufacturers) over the opinions of a retired 74 pilot with an axe to grind and another without any factual support for their assertions! …. But hey that’s me … ever the doubting Thomas!
…. Fair enough then!
.. and without a timeline for fitment and funding to support that timeline … how do you timeline surveillance decisions before an aerostudy ... duplicate aerostrudies on the Australian airspace volumes? ..... yep thats gunna happen in time to make a smart decsion on buying 20+ multi-million dollar radar heads?
.
NO CHICKEN .. NO EGG .. NO CHICKEN
.
STAUS QUO ….. Bargain!
.
AusNAS 3 here we come!
ADS-B in is not mandated/subsidised only ADS-B out.
A TCAD fit for a typical GA light aircraft is about USD20k++...I have no reason to suspect 'in' will be lot cheaper...even if it is 1/2 TCAD it will still be USD10k.
ADS-B for GA will be purely a surveilance tool.
Don't get me wrong...satellite based ATM is the way of the future...but why the (seeming) undue haste?
I get the feeling the are trying to sell us something quickly so they can decommission some radars in the next cycle of scheduled replacement rather than the one after that.
It has a 'NAS2b' feel about it ....rushing it in shouting it's benefits from the roof tops
… what, cutting and pasting relevant extracts is
hoping people don't ask too many difficult questions.
After the first 28 stations are commissioned the low level ADS-B coverage will be sparse to say the least.
What is the time frame and how many stations required to extend ADS-B down to levels where the GA aircraft they are mandating fitment operate...<8000'?
What will ADS-B give those few aircraft that wil have 'in' (eventually), High end/regional turboprops and jets, that they dont get now from TCAS?
The requirement for turbine carrying more than x passengers to carry TCAS going to be withdrawn?
Why do I need to know where aircraft that cannot effect my operation, because they are outside the range of my TCAS, are?
If ADS-B is not going to have any effect on capital city terminal airspace capacity, because of noise sharing/runway constraints that ADS-B cannot address, and the enroute airspace in Australia is not crowded as is that in the US/EU why the rush?
- Surface monitoring with Runway Incursion alarms (the biggest single risk in air traffic management in the world today)
- Accurate surveillance that negates expensive kit like the PRM
- Less spurious TCAS events due TMA proximities
- multiple level target response in ACAS to things like Surface vehicles visible on your CDTI (low vis op’s, runway humps etc)
- Vehicles with a basic display to see you thundering down the tar in the fog!
.
.. just to name a few … no, no rush
One of the drivers, if not THE driver, for the FAA's move to satellite based ATM is they have convinced themselves that their airspace is going to be inundated with many 1000s of VLJs...the way the US economy is going that very much remains to be seen...and who cares anyway it won't effect Australia...we might see 20.
The US probably has a real need even without 1000s of VLJs but they are not rushing in mandating everything capable of sustained flight has ADS-B within 5 years...why are we?
Why don't we just wait and see what Australia needs rather than base decisions on what countries with truly busy airspace feel they need?
Australia has such a tiny aviation industry compared to the US/EU/Asia etc...the last thing we need to be doing is behaving like trendsetters in this area.
What imperative does mandatory ADS-B out in GA answer?
SSD...answer my questions based on your understanding of the issues.
.
They are not rhetorical questions designed to put doubt in people minds.
.
They are not rhetorical questions designed to put doubt in people minds.
My first vote was for option 3...the more I read and thought about the issues as I experience them in my work and fun flying the more questions I had...I now prefer option 1 within the Oz GA context and in the short to medium term.
Upper level ADS-B makes all the sense in the world within the local regulatory context of providing ATM coverage across a vaste continent to cheaply...how many current generation Boeings/Airbus will be ADS-B capable remains to be seen...
I remain to be convinced about the practicle/political realities of low level ADS-B.
With no time line for low level ADS-B you can not logically have a time line for mandating GA fitment.
.
NO CHICKEN .. NO EGG .. NO CHICKEN
.
STAUS QUO ….. Bargain!
.
AusNAS 3 here we come!
Chimbu,
Looks like you're not on Scurvy's A list any more. Thinking for yourself !!, be careful, it might be catching. You might start a whole new trend.
Strange as it may seem to some, and contrary to Scurvy's assertions, I don't have any axe to grind, except that I have a great aversion to fantasy in the aviation world.
I much prefer to stick to facts. And for anybody who wishes to do a search, you will find I am a long time supporter of the original Freeflight concept, and the enabling technology, including ADS-B. Because of the potential economic and safety benefits - at high level. But Freeflight, not what is going on here. Those papers are to be found in the files of a well know pilot union.
And a great aversion to the idea that the bottom end of aviation, which is already struggling under huge cost and other pressures, being stuck with some very expensive equipment by mandate, that addresses no demonstrated safety problem, and from which no measurable benefit is derived.And certainly nothing to offset the initial and ongoing costs.
And a very great aversion to the fact that the ADS-B IN, which is implicit in the RAAA position, is nowhere to be found in the equipment of airline standard. Is there anybody from Eastern lurking, how are the Dash 8 mods. going? --- where is the ADS-B IN ---- anywhere?? The Bush gets it in the neck, again.
Any of you can get onto the web, and do your search, and have a look at the Garmin/Collins/Freeflight Inc./Allied Signals/etc. prices, just for Mode S ADS-B transponders--- and the tiny Australian market won't make much impact on the price ---- if it is mandatory, why would a rational salesman reduce prices and margins to a captive market. Then go looking for the prices of the matching C145/146.
Folks, even if the "subsidy" eventuates (ADS-B OUT only) look at the indicative prices, and it is not a permanent subsidy, only existing aircraft, so it will really help the international competitiveness of the training organisations on the world market (just one example) --- by increasing the price of a new aircraft, after 2011/2013, by somewhere between $20,000-30,000 ---- again, to solve which safety problem.
Tootle pip!!
Looks like you're not on Scurvy's A list any more. Thinking for yourself !!, be careful, it might be catching. You might start a whole new trend.
Strange as it may seem to some, and contrary to Scurvy's assertions, I don't have any axe to grind, except that I have a great aversion to fantasy in the aviation world.
I much prefer to stick to facts. And for anybody who wishes to do a search, you will find I am a long time supporter of the original Freeflight concept, and the enabling technology, including ADS-B. Because of the potential economic and safety benefits - at high level. But Freeflight, not what is going on here. Those papers are to be found in the files of a well know pilot union.
And a great aversion to the idea that the bottom end of aviation, which is already struggling under huge cost and other pressures, being stuck with some very expensive equipment by mandate, that addresses no demonstrated safety problem, and from which no measurable benefit is derived.And certainly nothing to offset the initial and ongoing costs.
And a very great aversion to the fact that the ADS-B IN, which is implicit in the RAAA position, is nowhere to be found in the equipment of airline standard. Is there anybody from Eastern lurking, how are the Dash 8 mods. going? --- where is the ADS-B IN ---- anywhere?? The Bush gets it in the neck, again.
Any of you can get onto the web, and do your search, and have a look at the Garmin/Collins/Freeflight Inc./Allied Signals/etc. prices, just for Mode S ADS-B transponders--- and the tiny Australian market won't make much impact on the price ---- if it is mandatory, why would a rational salesman reduce prices and margins to a captive market. Then go looking for the prices of the matching C145/146.
Folks, even if the "subsidy" eventuates (ADS-B OUT only) look at the indicative prices, and it is not a permanent subsidy, only existing aircraft, so it will really help the international competitiveness of the training organisations on the world market (just one example) --- by increasing the price of a new aircraft, after 2011/2013, by somewhere between $20,000-30,000 ---- again, to solve which safety problem.
Tootle pip!!
Grandpa Aerotart
I get the feeling I am pissing you off SSD...not my intention...just asking some questions is all...and airing my concerns as someone who uses the entire airspace column from very, very low to FL450
As you have stated this is the biggest deal in any of our careers...as you also stated it has come a little out of the blue...we are being asked to mentally shift gears from the attitudes of the last 15 years or so to some sort of potential airspace nirvana just around the next bend...and all for free when user pays has been the rules of the game for a very long time.
Thank you for your big picture answers.
I was reading through the JPC document again a few hours ago and noticed the final stage would be an additional 11 ground units bringing the total to 39...given that the coverage map showing 28 had only one unit on the east coast at/around BN I can perhaps be forgiven for wondering what was going to happen in the rest of the J curve ADS-B wise?
The final 11 units were characterised as final state 'full coverage' so I guess most of the 11 units will be sat on strategic hill tops in the J curve.
As you say we have several years of electronic developement to go before boxes are actually being removed from their packaging...IF the US GA market takes up the ADS-B 1090 es technology that will spur manufacturers like Garmin to come up with a cleaver box....there is no other way the economies of scale will make it affordable.
I suspect the costs will be a higher and the savings to industry perhaps not as great as depicted...ever known anything like this not to work out that way?...there will be much angst, mutterings and doubt cast about but we may just end up with something pretty reasonable.
And I bet when all is said and done I will be sat up at FL390 about to descend into YSSY with as much vectoring, speed control and holding as we get now...or maybe you will have given me speed control 1500nm earlier...faster or slower it doesn't matter...I will have been throwing fuel out the back at an increased rate over ECON
Actually I just thought of something really funny...ADS-B might benefit GA more than the big end of town...after all the biggest limiting factor for the airlines by far is tarmac...be that runways or parking...as you say ADS-B will make airport movements in bad weather safer...I don't think they will elevate rates much because taxiing in fog is scary enough at 10kts thank you very much...I dont care what gadgets they come up with I won't be taxiing at 25kts like I can on a sunny day.
I really think the upper level enroute savings are a load of hot cock...at best this technology might slow the rate at which things get worse but that is about it. The only real significant savings to be had are in the arrival/departure phases and ADS-B doesn't give you more tarmac or even more terminal airspace.
GA has virtually no such constraints except around places like Sydney.
Do I think ADS-B and a flight plan will get me a clearance through YSSY in my Bonanza where Mode C/Flight plan doesn't now?
Nope.
Do I think AsA will dramatically reduce their charges once they have clawed back the subsidy?
Nope...it will be like your car/house insurance no claim bonus...sorry to sound cynical...there will be plausible sounding reasons why enroute/terminal charges don't reduce....something along the lines of "Hey they aren't as high as they would have been"
GA might actually be the biggest net beneficiary...wouldn't that be funny
to FL450As you have stated this is the biggest deal in any of our careers...as you also stated it has come a little out of the blue...we are being asked to mentally shift gears from the attitudes of the last 15 years or so to some sort of potential airspace nirvana just around the next bend...and all for free when user pays has been the rules of the game for a very long time.
Thank you for your big picture answers.
I was reading through the JPC document again a few hours ago and noticed the final stage would be an additional 11 ground units bringing the total to 39...given that the coverage map showing 28 had only one unit on the east coast at/around BN I can perhaps be forgiven for wondering what was going to happen in the rest of the J curve ADS-B wise?
The final 11 units were characterised as final state 'full coverage' so I guess most of the 11 units will be sat on strategic hill tops in the J curve.
As you say we have several years of electronic developement to go before boxes are actually being removed from their packaging...IF the US GA market takes up the ADS-B 1090 es technology that will spur manufacturers like Garmin to come up with a cleaver box....there is no other way the economies of scale will make it affordable.
I suspect the costs will be a higher and the savings to industry perhaps not as great as depicted...ever known anything like this not to work out that way?...there will be much angst, mutterings and doubt cast about but we may just end up with something pretty reasonable.
And I bet when all is said and done I will be sat up at FL390 about to descend into YSSY with as much vectoring, speed control and holding as we get now...or maybe you will have given me speed control 1500nm earlier...faster or slower it doesn't matter...I will have been throwing fuel out the back at an increased rate over ECON
Actually I just thought of something really funny...ADS-B might benefit GA more than the big end of town...after all the biggest limiting factor for the airlines by far is tarmac...be that runways or parking...as you say ADS-B will make airport movements in bad weather safer...I don't think they will elevate rates much because taxiing in fog is scary enough at 10kts thank you very much...I dont care what gadgets they come up with I won't be taxiing at 25kts like I can on a sunny day.
I really think the upper level enroute savings are a load of hot cock...at best this technology might slow the rate at which things get worse but that is about it. The only real significant savings to be had are in the arrival/departure phases and ADS-B doesn't give you more tarmac or even more terminal airspace.
GA has virtually no such constraints except around places like Sydney.
Do I think ADS-B and a flight plan will get me a clearance through YSSY in my Bonanza where Mode C/Flight plan doesn't now?
Nope.
Do I think AsA will dramatically reduce their charges once they have clawed back the subsidy?
Nope...it will be like your car/house insurance no claim bonus...sorry to sound cynical...there will be plausible sounding reasons why enroute/terminal charges don't reduce....something along the lines of "Hey they aren't as high as they would have been"
GA might actually be the biggest net beneficiary...wouldn't that be funny
I'm in one of those moods
Thread Starter
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Lead ol' chap ... A list ... doubt it, no such animal, just respect for folks who can state their case (with facts or experienced opinions) without the benefit of time standing still ... you know the type, those who cannot get off their arses and research the topic before posting watery absolutes
.
I'm not gunna piss in Chuck's pocket, nor would he appreciate it, nor I suspect would he in anyone elses (knowing our Chuck as we do) .... and as much as I am sure you would like folks to take sides .. there are none ... just words .. good, bad, strong, frilly and just plain unsubstanciated crap!
.
.. such is life as Ned Kelly said .... I'm over it ... are you?
.
It is outa respect for folks like Chuck and his questioning, that I went surfing (with ferkin matchsticks under the lids
) to catch a couple of things I saw the other day that might be of interest
.
http://www.iata.org/NR/ContentConnec...n_of_ADS-B.pdf ... note Para 11 Boeing and AB
.
http://www.eurocontrol.int/eec/publi..._Maturity.html ....note the peer reviews and the sorts of work being undertaken such as in-trail etc ...
.
ICAO South Korea (ADS-B)
.
http://www.icao.or.th/meetings/2007/...B_TF6/ip14.pdf ... note the uses that ADS-B excels at (including some I mentioned earlier)
.
... got another couple of interesting things sent the other day ... thought I had em' on the 'stick' ... alas no .. on the drive at work .... postem Tuesday PM.
.
.. not pissed Chuck, on the contrary, that is the sort of stuff these threads should be about .... I'd be disappointed if you were not blunt
.
As I said before, I am as cynical as most, probably more having worked for the mob for 17years
and as such, I want to know if this proposal is loaded 
.. because if it is, and could be to the detrement of the section of the industry that can least afford to be fecked over ... there is a missile to be launched at Canberra, and we'd better make dam'd sure we know what the **** we are talkin about before we hit the red button eh
.
.... novel concept eh Leadie
.
... now **** off ... I'm goin to bed!
... doubt it, no such animal, just respect for folks who can state their case (with facts or experienced opinions) without the benefit of time standing still ... you know the type, those who cannot get off their arses and research the topic before posting watery absolutes .
I'm not gunna piss in Chuck's pocket, nor would he appreciate it, nor I suspect would he in anyone elses (knowing our Chuck as we do) .... and as much as I am sure you would like folks to take sides .. there are none ... just words .. good, bad, strong, frilly and just plain unsubstanciated crap!
.
.. such is life as Ned Kelly said .... I'm over it ... are you?
.
It is outa respect for folks like Chuck and his questioning, that I went surfing (with ferkin matchsticks under the lids
) to catch a couple of things I saw the other day that might be of interest.
http://www.iata.org/NR/ContentConnec...n_of_ADS-B.pdf ... note Para 11 Boeing and AB
.
http://www.eurocontrol.int/eec/publi..._Maturity.html ....note the peer reviews and the sorts of work being undertaken such as in-trail etc ...
.
ICAO South Korea (ADS-B)
.
http://www.icao.or.th/meetings/2007/...B_TF6/ip14.pdf ... note the uses that ADS-B excels at (including some I mentioned earlier)
.
... got another couple of interesting things sent the other day ... thought I had em' on the 'stick' ... alas no .. on the drive at work .... postem Tuesday PM.
.
.. not pissed Chuck, on the contrary, that is the sort of stuff these threads should be about .... I'd be disappointed if you were not blunt
.
As I said before, I am as cynical as most, probably more having worked for the mob for 17years
and as such, I want to know if this proposal is loaded .. because if it is, and could be to the detrement of the section of the industry that can least afford to be fecked over ... there is a missile to be launched at Canberra, and we'd better make dam'd sure we know what the **** we are talkin about before we hit the red button eh .
.... novel concept eh Leadie
.
... now **** off ... I'm goin to bed!
Biggles in Oz, you state:
That is the main part of the con. That is why the cost benefit case is fraudulent. They cost ADS-B ‘out’ but then bring in the advantages of ADS-B ‘in’ which is not costed and not yet available.
I say again – I totally support ADS-B. There is no doubt it is the way to go for the future. However any cost benefit studies should be done accurately without any spinning or conning.
There is no certified ADS-B ‘in/out’ unit which can be fitted to a small regional airline – the people who appear to desperately want ADS-B ‘in/out’.
By the way, if you want a really good and objective view on the Government’s ADS-B paper, I suggest you look at the submission put out by the Australian Sport Aviation Confederation. I agree with it totally – and before you start accusing me of being involved, I wasn’t in any way, but it is good to see that the matter can be looked at in an objective way.
Why is the proposed subsidy only for ADSB-OUT equipment ?
I say again – I totally support ADS-B. There is no doubt it is the way to go for the future. However any cost benefit studies should be done accurately without any spinning or conning.
There is no certified ADS-B ‘in/out’ unit which can be fitted to a small regional airline – the people who appear to desperately want ADS-B ‘in/out’.
By the way, if you want a really good and objective view on the Government’s ADS-B paper, I suggest you look at the submission put out by the Australian Sport Aviation Confederation. I agree with it totally – and before you start accusing me of being involved, I wasn’t in any way, but it is good to see that the matter can be looked at in an objective way.
I'm in one of those moods
Thread Starter
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... thats crap Dick ... the CBA is 'based' on 'out', the benefits as far as I can see are based on that .... the references to 'in' are separate.
.
If that is not the case, can you point out where!
.
So based on your advice ... are sport for or against the cross industry funding proposal? .... or are they in favour of 'in' being part of the proposal!
.
IF it is the latter ... I wholeheartely agree with them!
.
If that is not the case, can you point out where!
.
So based on your advice ... are sport for or against the cross industry funding proposal? .... or are they in favour of 'in' being part of the proposal!
.
IF it is the latter ... I wholeheartely agree with them!
Folks,
From Dr. R.J.Hall, PhD, President of ASAC.
----------------------------------------------------------------------------
SPORT AVIATION PRELIMINARY RESPONSE TO:
JCP: Transition to Satellite Technology for Navigation and Surveillance
Dr. R J Hall
President ASAC
15/08/07
EXECUTIVE SUMMARY
Sport Aviation understands that satellite technology for navigation and surveillance is the way of the future and accordingly, supports appropriate application of this technology in Australia.
Sport Aviation expects that the implementation of this technology will be subject to risk management and cost benefit justification as required by the AAPS.
Sport Aviation will support those parts of this initiative which can be justified. Sport Aviation believes that extension of the ADS-B mandate beyond that required for replacement of SSR radar required by capacity needs, cannot be justified and is implacably opposed to this extended mandate.
Sport Aviation believes that implementation of some important aspects of this new technology has been stalled by an almost ideological push for this unjustified extended mandate. This objective has been pursued by attempting to combine the separate aspects of this technology into a single decision, using the benefits from other cost beneficial aspects of this technology, to fund a wide mandate for ADS-B OUT.
It is very unfortunate that the JCP seems to be no more than a continuation of this approach.
Sport Aviation notes that the JCP promises that the second stage of the proposal involving an extension of the ADS-B mandate into Class G airspace ‘will be subject to a risk management and cost benefit justification’ but points out that this is not acceptable. The very essence of a risk management approach is that it is not ‘tacked on at the end’ after the decision has been made; but it is an integral part of the decision making approach
A risk management and cost benefit justification is a systematic, rigorous, quantitative means of deciding what actions can be justified. It starts with the problems or hazards to be solved or mitigated, canvasses all possible solution or mitigators and determines which of these can be justified by the outcomes achieved. It is fundamental to the rigour in this approach that the cost benefit study must include only those benefits resulting from the mitigator under consideration and that all costs associated with the implementation of that mitigator must be included.
This approach has never been attempted by the ABIT team apparently responsible for this JCP.
Sport Aviation believes that analysis of the work carried out by the GIT and ABIT teams shows that the implementation of GNSS Navigation and the replacement of SSR with ADS-B to provide radar-like services, where required by capacity needs of the ATM system, has been justified; but that this study has already shown that the extension of the ADS-B mandate beyond that required to achieve these outcomes cannot be justified on a risk management and cost benefit basis and further, that the ABIT team agreed this fact at the last ABIT meeting.
Sport Aviation will agree any requirement which can be justified, but is implacably opposed to any requirement which cannot. Further, Sport Aviation will not agree to an exemption from a costly requirement based on inability to power, when the requirement itself cannot be justified for anyone.
Bob Hall
DETAILED COMMENTS
The Discussion Paper
Much of the discussion paper obfuscates or simply avoids the decisions facing the Industry by proposing that this technology must be implemented as a single decision. This effectively asks the question – ‘Will Australia implement GPS based avionics or not?’ but avoids the real issues, which are – which aspects of this technology, where and by whom?
The paper proposes that the decision is a single issue on the transparently thin argument that there are cost savings if the avionics installation is done simultaneously and that aircraft operators might be more likely to install other GPS based avionics if they are forced to install ADS B OUT.
Even if the installation of GPS avionics in individual aircraft is to be carried out in a single step it is a non sequitur to say the decision as to which capabilities need to be installed in which aircraft must also be a single global decision.
If it is a single global decision then, clearly, Australia must be part of this new technology – but the fallacy is the assumption that it is a single global decision. Accordingly, the primary outcome of this JCP is not a result of this analysis but is actually assumed in the starting assumptions of the analysis.
Risk Management Justification
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.
Clearly, the Industry faces at least four decisions – each of which is, technically and conceptually, an independent issue; each with its own benefits and implementation costs. The only connection being they are, or may be, addressed by GPS based technology. Thus –
1. GNSS Nav. aids or not.
2. Replacement of SSR with ADS-B where capacity requirements justify a radar-like service.
3. Recommendation or mandate of avionics required to avoid CFIT accidents.
4. Extension of the ADS-B mandate beyond radar coverage justified by capacity requirements.
These are the reasons for considering a requirement for GPS based avionics. The analysis must start with these reasons – canvas all possible solution or mitigators and depend on a cost benefit analysis to determine which of the mitigators can be justified.
Points, 1) and 2) are business decisions. R&D by the GIT and ABIT teams have demonstrated that these new technologies are as good or better than the older technology and are more cost effective. Points 3) and 4) are mitigators designed to deal with identified hazards.
Analysis of the work done by the GIT and ABIT teams shows the following:
1. GNSS Nav. is clearly justified by the savings achieved.
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.
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.
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)
Cost Benefit Justification of Project B – Extension Beyond SSR Replacement
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).
In summary this shows:
* GNSS Nav. and avoidance of CFIT accidents are not outcomes of fitment of ADS-B OUT.
* Savings on SSR by replacement with ADS-B similarly do not depend on a mandate extended beyond radar coverage justified by capacity requirements.
* Search and rescue benefits do not require ADS-B OUT in other aircraft.
Accordingly, none is a benefit of the extended mandate.
* Collision avoidance depends on ADS-B IN as well as ADS-B OUT
Accordingly, if this benefit is to be included, then the costs must include fitment of ADS-B IN as well as ADS-B OUT.
On this valid basis, extension of an ADS-B OUT mandate beyond that required for replacement of SSR with ADS-B, falls well short of being cost beneficial and, accordingly, cannot be justified on a risk management basis (See Appendix B for more details). This proposal then cannot be implemented under the AAPS.
This result applies whether or not a means of funding these costs can be found.
A Reasonableness Test
Finally, the outcome does not pass a ‘reasonableness’ test.
The extended mandate is for Class E and for Class G above 5000’ – this exclusively en route airspace where the collision hazard is vanishingly small. This is a return to the dark ages of mandatory radio above 5000’ (with no protection in terminal airspace).
It is claimed that this will remove reliance on unalerted see-and-avoid in terminal airspace. This is a false claim as the proposal mandates ADS-B OUT for aircraft already required to carry and use radio and a transponder. This would add a third mitigator against this hazard.
Finally, it would appear that the is still no intention to mandate ADS-B IN for RPT aircraft in the same airspace. (The ADS-B OUT units may well be bleeping at no one.)
Cost Benefit Calculation Attached
Finally, the cost benefit study attached to the JCP is in fact more misleading than that previously rejected by Sport Aviation and the Board of Airservices and is, again, rejected by Sport Aviation and should be by all of the industry.
The study does not distinguish the clearly separate projects involved. It assumes that savings from one project can be used to justify costs for another.
Put simply, the approach by ABIT has always been that the technology must be implemented because it is technically superior. Any analysis of costs and benefits has been an attempt to work out ‘how we can afford this great technology we have developed’ – not to decide where its implementation can be justified.
If the exercise is to find a way of funding a project which has already been agreed, then this might be considered acceptable. However the AAPS requires a risk management and cost benefit justification for such an airspace change.
If this requirement is to be honoured, then the purpose of the examination of a mitigator as part of a risk management justification, is to determine whether the implementation of this mitigator is justified by the outcomes achieved. Clearly, then the cost must include all the costs required to achieve the outcomes and the value of outcomes must be limited to those actually produced by that mitigator.
The analysis attached the JCP calculates benefits which either do not depend on the fitment of ADS-B OUT in other aircraft (GNSS Nav., CFIT and search and rescue outcomes for example) or depend on the fitment of ADS-B IN in all or most aircraft (collision accidents) but the costs do not include the fitment of ADS-B IN.
If the benefits of the extended mandate are limited to those resulting from this extended mandate and the costs include both ADS-B OUT and ADS-B IN this extended mandate is not justified by the figures presented.
Bob Hall
-------------------------------------------------------------------------
Professor Hall,formerly of U.of NSW, is one of Australia's leading risk management experts. He is also an expert on the various models used in collision risk probability analysis.
Tootle pip.
From Dr. R.J.Hall, PhD, President of ASAC.
----------------------------------------------------------------------------
SPORT AVIATION PRELIMINARY RESPONSE TO:
JCP: Transition to Satellite Technology for Navigation and Surveillance
Dr. R J Hall
President ASAC
15/08/07
EXECUTIVE SUMMARY
Sport Aviation understands that satellite technology for navigation and surveillance is the way of the future and accordingly, supports appropriate application of this technology in Australia.
Sport Aviation expects that the implementation of this technology will be subject to risk management and cost benefit justification as required by the AAPS.
Sport Aviation will support those parts of this initiative which can be justified. Sport Aviation believes that extension of the ADS-B mandate beyond that required for replacement of SSR radar required by capacity needs, cannot be justified and is implacably opposed to this extended mandate.
Sport Aviation believes that implementation of some important aspects of this new technology has been stalled by an almost ideological push for this unjustified extended mandate. This objective has been pursued by attempting to combine the separate aspects of this technology into a single decision, using the benefits from other cost beneficial aspects of this technology, to fund a wide mandate for ADS-B OUT.
It is very unfortunate that the JCP seems to be no more than a continuation of this approach.
Sport Aviation notes that the JCP promises that the second stage of the proposal involving an extension of the ADS-B mandate into Class G airspace ‘will be subject to a risk management and cost benefit justification’ but points out that this is not acceptable. The very essence of a risk management approach is that it is not ‘tacked on at the end’ after the decision has been made; but it is an integral part of the decision making approach
A risk management and cost benefit justification is a systematic, rigorous, quantitative means of deciding what actions can be justified. It starts with the problems or hazards to be solved or mitigated, canvasses all possible solution or mitigators and determines which of these can be justified by the outcomes achieved. It is fundamental to the rigour in this approach that the cost benefit study must include only those benefits resulting from the mitigator under consideration and that all costs associated with the implementation of that mitigator must be included.
This approach has never been attempted by the ABIT team apparently responsible for this JCP.
Sport Aviation believes that analysis of the work carried out by the GIT and ABIT teams shows that the implementation of GNSS Navigation and the replacement of SSR with ADS-B to provide radar-like services, where required by capacity needs of the ATM system, has been justified; but that this study has already shown that the extension of the ADS-B mandate beyond that required to achieve these outcomes cannot be justified on a risk management and cost benefit basis and further, that the ABIT team agreed this fact at the last ABIT meeting.
Sport Aviation will agree any requirement which can be justified, but is implacably opposed to any requirement which cannot. Further, Sport Aviation will not agree to an exemption from a costly requirement based on inability to power, when the requirement itself cannot be justified for anyone.
Bob Hall
DETAILED COMMENTS
The Discussion Paper
Much of the discussion paper obfuscates or simply avoids the decisions facing the Industry by proposing that this technology must be implemented as a single decision. This effectively asks the question – ‘Will Australia implement GPS based avionics or not?’ but avoids the real issues, which are – which aspects of this technology, where and by whom?
The paper proposes that the decision is a single issue on the transparently thin argument that there are cost savings if the avionics installation is done simultaneously and that aircraft operators might be more likely to install other GPS based avionics if they are forced to install ADS B OUT.
Even if the installation of GPS avionics in individual aircraft is to be carried out in a single step it is a non sequitur to say the decision as to which capabilities need to be installed in which aircraft must also be a single global decision.
If it is a single global decision then, clearly, Australia must be part of this new technology – but the fallacy is the assumption that it is a single global decision. Accordingly, the primary outcome of this JCP is not a result of this analysis but is actually assumed in the starting assumptions of the analysis.
Risk Management Justification
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.
Clearly, the Industry faces at least four decisions – each of which is, technically and conceptually, an independent issue; each with its own benefits and implementation costs. The only connection being they are, or may be, addressed by GPS based technology. Thus –
1. GNSS Nav. aids or not.
2. Replacement of SSR with ADS-B where capacity requirements justify a radar-like service.
3. Recommendation or mandate of avionics required to avoid CFIT accidents.
4. Extension of the ADS-B mandate beyond radar coverage justified by capacity requirements.
These are the reasons for considering a requirement for GPS based avionics. The analysis must start with these reasons – canvas all possible solution or mitigators and depend on a cost benefit analysis to determine which of the mitigators can be justified.
Points, 1) and 2) are business decisions. R&D by the GIT and ABIT teams have demonstrated that these new technologies are as good or better than the older technology and are more cost effective. Points 3) and 4) are mitigators designed to deal with identified hazards.
Analysis of the work done by the GIT and ABIT teams shows the following:
1. GNSS Nav. is clearly justified by the savings achieved.
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.
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.
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)
Cost Benefit Justification of Project B – Extension Beyond SSR Replacement
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).
In summary this shows:
* GNSS Nav. and avoidance of CFIT accidents are not outcomes of fitment of ADS-B OUT.
* Savings on SSR by replacement with ADS-B similarly do not depend on a mandate extended beyond radar coverage justified by capacity requirements.
* Search and rescue benefits do not require ADS-B OUT in other aircraft.
Accordingly, none is a benefit of the extended mandate.
* Collision avoidance depends on ADS-B IN as well as ADS-B OUT
Accordingly, if this benefit is to be included, then the costs must include fitment of ADS-B IN as well as ADS-B OUT.
On this valid basis, extension of an ADS-B OUT mandate beyond that required for replacement of SSR with ADS-B, falls well short of being cost beneficial and, accordingly, cannot be justified on a risk management basis (See Appendix B for more details). This proposal then cannot be implemented under the AAPS.
This result applies whether or not a means of funding these costs can be found.
A Reasonableness Test
Finally, the outcome does not pass a ‘reasonableness’ test.
The extended mandate is for Class E and for Class G above 5000’ – this exclusively en route airspace where the collision hazard is vanishingly small. This is a return to the dark ages of mandatory radio above 5000’ (with no protection in terminal airspace).
It is claimed that this will remove reliance on unalerted see-and-avoid in terminal airspace. This is a false claim as the proposal mandates ADS-B OUT for aircraft already required to carry and use radio and a transponder. This would add a third mitigator against this hazard.
Finally, it would appear that the is still no intention to mandate ADS-B IN for RPT aircraft in the same airspace. (The ADS-B OUT units may well be bleeping at no one.)
Cost Benefit Calculation Attached
Finally, the cost benefit study attached to the JCP is in fact more misleading than that previously rejected by Sport Aviation and the Board of Airservices and is, again, rejected by Sport Aviation and should be by all of the industry.
The study does not distinguish the clearly separate projects involved. It assumes that savings from one project can be used to justify costs for another.
Put simply, the approach by ABIT has always been that the technology must be implemented because it is technically superior. Any analysis of costs and benefits has been an attempt to work out ‘how we can afford this great technology we have developed’ – not to decide where its implementation can be justified.
If the exercise is to find a way of funding a project which has already been agreed, then this might be considered acceptable. However the AAPS requires a risk management and cost benefit justification for such an airspace change.
If this requirement is to be honoured, then the purpose of the examination of a mitigator as part of a risk management justification, is to determine whether the implementation of this mitigator is justified by the outcomes achieved. Clearly, then the cost must include all the costs required to achieve the outcomes and the value of outcomes must be limited to those actually produced by that mitigator.
The analysis attached the JCP calculates benefits which either do not depend on the fitment of ADS-B OUT in other aircraft (GNSS Nav., CFIT and search and rescue outcomes for example) or depend on the fitment of ADS-B IN in all or most aircraft (collision accidents) but the costs do not include the fitment of ADS-B IN.
If the benefits of the extended mandate are limited to those resulting from this extended mandate and the costs include both ADS-B OUT and ADS-B IN this extended mandate is not justified by the figures presented.
Bob Hall
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Professor Hall,formerly of U.of NSW, is one of Australia's leading risk management experts. He is also an expert on the various models used in collision risk probability analysis.
Tootle pip.
I'm in one of those moods
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Lead thankyou, understanding positions is critical!
.. that’s a worry …. Has there been any indication as to why?
.. apart from point three (which would only happen with GNSS equipment anyhow, which might be considered in relation to point 1.) I agree!
… was TAWS/GPWS/EGPWS part of the project scope as far as required outcomes?
… 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?
… ‘require’ no .. but is there a benefit if it is equipped for other reasons?
… again agree (OCTA and outside existing surveillance)
…. Agreed (when considering CBA/Risk OCTA)!
.
Have sport compared (if that is possible) the CBA of the Status Quo into the future?
.
I take it ‘sport’ expect an RPT CBA including separate risk analysis (presuably for individual volumes) etc to be included in the GA proposal?
.
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?
.
The same input from the other sectors would be invaluable!
.
Thanks for providing the information! .. a reasonable response from ‘Sport’!
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.
Analysis of the work done by the GIT and ABIT teams shows the following:
.
1. GNSS Nav. is clearly justified by the savings achieved.
.
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.
.
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.
.
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)
.
1. GNSS Nav. is clearly justified by the savings achieved.
.
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.
.
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.
.
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)
Cost Benefit Justification of Project B – Extension Beyond SSR Replacement
.
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).
.
In summary this shows:
.
* GNSS Nav. and avoidance of CFIT accidents are not outcomes of fitment of ADS-B OUT.
.
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).
.
In summary this shows:
.
* GNSS Nav. and avoidance of CFIT accidents are not outcomes of fitment of ADS-B OUT.
* Savings on SSR by replacement with ADS-B similarly do not depend on a mandate extended beyond radar coverage justified by capacity requirements.
* Search and rescue benefits do not require ADS-B OUT in other aircraft.
Accordingly, none is a benefit of the extended mandate.
.
* Collision avoidance depends on ADS-B IN as well as ADS-B OUT
.
* Collision avoidance depends on ADS-B IN as well as ADS-B OUT
Accordingly, if this benefit is to be included, then the costs must include fitment of ADS-B IN as well as ADS-B OUT.
.
Have sport compared (if that is possible) the CBA of the Status Quo into the future?
.
I take it ‘sport’ expect an RPT CBA including separate risk analysis (presuably for individual volumes) etc to be included in the GA proposal?
.
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?
.
The same input from the other sectors would be invaluable!
.
Thanks for providing the information! .. a reasonable response from ‘Sport’!
I'm in one of those moods
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Lead .. Supplementary if I may..
.
.… could you provide the Appendix’s (B is mentioned so I guess there are others)?
.
… and perhaps the workings on which the CBA/risk assumptions are drawn!
.
Cheers
.
Oh .. and one other, the date on your forwarded post is 15/08/07 ….. is that the date you received the information from Prof Hall or the date of creation of the response from Prof Hall?
.
.… could you provide the Appendix’s (B is mentioned so I guess there are others)?
.
… and perhaps the workings on which the CBA/risk assumptions are drawn!
.
Cheers
.
Oh .. and one other, the date on your forwarded post is 15/08/07 ….. is that the date you received the information from Prof Hall or the date of creation of the response from Prof Hall?
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Do not have time for a legthy post now, but I do believe that there is a flly spec'd and will be available for deployment end 2008 if the go ahead is given, solution sub $10k and this is from the horses mouth for a change.
I also wonder if as I think LeadsSled made a point what will it add o new a/c. Well if for GA a/c the cost of a coneventional Mode C + Encoder kit was deducted (you would be buying that anyway) from the ADSB kit...it might ad say $4400 to your new a/c purchase. Or if they said they said you would still get the ADSB "upgrade subsidised" then you would only pay for the cost of mode C now. Ok some RAAA guys do not buy mode C now, but in my opinion they should now anyway, even if its not law.
Geeif we all had Mode C minimum and lots of Radar coverage, and all RPT (even low capacty) had TCAS, maybe none of this would be worth it. But ADSB is way cheaper than the alternative.
Its simple, and many other benefits can be spun off it for not much cost.
Ohh and for those of you who think big brother will be tracing your every Class G flight to invoice you, turn it to "private" mode or whatever it will be called, just like squawking 1200.......nobody will know.
Some of you are scared of ghosts.
J
I also wonder if as I think LeadsSled made a point what will it add o new a/c. Well if for GA a/c the cost of a coneventional Mode C + Encoder kit was deducted (you would be buying that anyway) from the ADSB kit...it might ad say $4400 to your new a/c purchase. Or if they said they said you would still get the ADSB "upgrade subsidised" then you would only pay for the cost of mode C now. Ok some RAAA guys do not buy mode C now, but in my opinion they should now anyway, even if its not law.
Geeif we all had Mode C minimum and lots of Radar coverage, and all RPT (even low capacty) had TCAS, maybe none of this would be worth it. But ADSB is way cheaper than the alternative.
Its simple, and many other benefits can be spun off it for not much cost.
Ohh and for those of you who think big brother will be tracing your every Class G flight to invoice you, turn it to "private" mode or whatever it will be called, just like squawking 1200.......nobody will know.
Some of you are scared of ghosts.
J
Folks,
More from Dr. R.J.Hall, PhD
-----------------------------------------------------------------------------
APPENDIX A
THE PROPOSED DISCUSSION PAPER and RENEWED COST BENEFIT ANALYSIS of ADS-B
COMMENTS by ASAC
Dr. R. J. Hall
President ASAC
2/03/07
SUMMARY
The ASAC organisations expect that any decision on the implementation of GPS based technology – GNSS Nav and ADS-B – will be made on a risk management and cost benefit basis.
The Minister’s policy that all airspace management decisions will be made on a risk management and cost benefit basis is well received by all of industry. It would be very unfortunate if the first and arguably most important decision in airspace management since this policy was announced abrogated that policy.
The implementation of GPS based technology involves a number of separate objectives or outcomes – related only by the fact that they depend on GPS. These separate objectives must be considered, costed and subjected to separate risk management and cost benefit justification leading to a separate implementation decision.
Treating these as separate projects is not only essential to a valid justification of these different but related objectives but is essential if timely and optimal implementation of this important technology is to be achieved.
Having spent considerable amounts of public and industry money on this project it is essential that momentum in this overall initiative not be lost by artificial bundling of these separate objectives into a single project with the associated controversy regarding a wide mandate for ADS-B OUT.
The proposed discussion paper and associated cost benefit analysis of these projects must deal with, and report on, these separate projects as separate projects.
BACKGROUND
The ASAC organisations understand that GPS based technology – including GNSS navigation and ADS B – is important new technology for the provision of ATM services which, if applied appropriately, is capable of significant cost savings and improved services and safety.
Australia has spent significant sums of public and/or industry money developing this technology. Accordingly, the ASAC organisations believe that it is important that appropriate implementation of this technology be expedited so that the expected cost savings can be achieved.
Unfortunately, it appears that appropriate implementation of some aspects of this technology is being delayed by what seems to be an almost ideological push to achieve a very wide ADS-B mandate from the very outset. It appears that this objective is forcing an attempt to implement these changes as a single project making the decision an all or nothing outcome. No other nation is taking this ‘big bang’ approach. It is our view that this ‘big bang’ approach is delaying implementation of clearly cost beneficial aspects of this technology while the controversial aspects of a wide ADS-B mandate is debated.
Further to this and equally importantly, debate on these initiatives remains technology driven rather than outcomes based. That is, proposals for the implementation of this technology are based on the existence and success of this technology, not on the need to achieve an identified and justified business objective.
BASIS of IMPLEMENTATION DECISIONS
Implementation of this technology should be progressive. Individual business objectives need to be clearly identified and pursued as separate projects so that those which are ready and/or urgent can be implemented as soon as appropriate – not delayed by other more controversial objectives – so that the momentum in this project is not lost.
The ASAC organisations note that it is government policy that changes to airspace management – which would include these technologies – will be on a risk management and cost benefit basis. ASAC applauds this policy, recently announced by the Minister, and well received by the whole of industry. The ASAC organisations insist that it is clear that the decisions to implement this technology come under this policy and hence that each separate implementation decision must be on a risk management and cost benefit basis.
PROJECT OBJECTIVES
It seems to sport aviation that the development of this technology to date has identified the following separate objectives which are addressed by these technologies.
1. Cost savings and improved outcomes from GNSS Navigation.
2. Implementation of GPS based technology to assist the avoidance of CFIT accidents.
3. Replacement of existing SSR with ADS-B. (Previously known as Option B.)
4. Extension of the ADS-B mandate beyond current radar coverage for air-to-air conflict warning etc. (Previously known as Option C and D.)
There may be others but there are at least these four.
These objectives are not interdependent and the decision to implement must be considered, costed and justified separately.
Some arguments have been advanced that there are economic reasons for simultaneous implementation of some of these objectives. Despite these arguments, the decision to proceed or not in each case is not interconnected as these are independent objectives connected only by the fact that they depend on GPS.
1. GNSS Navigation
A very strong case and plea was made at the most recent meeting of the GIT and ABIT teams, that the delay in implementation of this technology is costing significant sums of money in refurbishing existing aids which would not be required after implementation of GNSS Nav. It is clear that this project can go ahead and it should not be delayed at cost to the nation and the industry because of controversial aspects of other related but not dependant projects.
2. CFIT accidents
This category of accident has actually cost lives. Implementation of the GPS technology to assist the avoidance of these accidents does not depend on ADS-B technology. Any delay in the implementation of this technology threatens to cost lives and should not be tolerated.
3. Replacement of existing SSR with ADS-B
This project – previously referred to as Option B – is clearly cost beneficial and, so far as ASAC understands, is not controversial. An ADS-B OUT mandate for all in Classes A and C and for IFR only in Class E would allow this project to proceed with very significant savings.
4. Extension of the ADS-B Mandate
This project is clearly not cost beneficial nor can it be justified on a risk management basis – not even for the protection of the travelling public.
It is well established that the collision risk in en route airspace is negligible being a few to several orders of magnitude less than design standards for major structural failure.
Circuit and radio procedures at untowered airfields combine to make radio alerted see-and-avoid very successful for collision avoidance in the terminal airspace. Provision of a further means of alert at very considerable cost to GA in this airspace in Australia is not justified.
SIMULTANEOUS IMPLEMENTATION
The only rational argument proposed is that simultaneous implementation would allow some cost savings and a cross subsidy of installation of ADS-B in GA.
Firstly, the cost savings are much less than the actual marginal cost so simultaneous implementation is not cost beneficial.
Secondly, any savings which accrue from the other aspects of this project can be applied to a subsidy at any time after initial implementation. A staged implementation will allow the possibility of using this money for R&D projects which may reduce the cost of implementation rather than simply applying this money to a subsidy.
IMPLEMENTATION IN SPORT AIRCRAFT
Some classes of aircraft – sports aircraft and some ultralights – have no need of any of the services provided by any of these projects. The cost and power drain of the necessary avionics makes fitment in these aircraft impractical and draconian.
These aircraft hold a general exemption from the carriage of transponders in Class E airspace.
Attached are two documents providing a brief justification for this exemption both for safety and security reasons.
It is important to note that this exemption is not only justified on the basis of cost and inability to power but also on a risk management basis. The nature of operations by this category of aircraft means that these aircraft do not represent a credible hazard.
When it comes to collision risk it is established that even unaltered see-and-avoid from such aircraft is effective. A paper justifying this conclusion has been previously supplied to DOTARS ASTRA and CASA. This paper supplied separately.
Bob Hall
President, ASAC
-----------------------------------------------------------------------------
And one more to come.
More from Dr. R.J.Hall, PhD
-----------------------------------------------------------------------------
APPENDIX A
THE PROPOSED DISCUSSION PAPER and RENEWED COST BENEFIT ANALYSIS of ADS-B
COMMENTS by ASAC
Dr. R. J. Hall
President ASAC
2/03/07
SUMMARY
The ASAC organisations expect that any decision on the implementation of GPS based technology – GNSS Nav and ADS-B – will be made on a risk management and cost benefit basis.
The Minister’s policy that all airspace management decisions will be made on a risk management and cost benefit basis is well received by all of industry. It would be very unfortunate if the first and arguably most important decision in airspace management since this policy was announced abrogated that policy.
The implementation of GPS based technology involves a number of separate objectives or outcomes – related only by the fact that they depend on GPS. These separate objectives must be considered, costed and subjected to separate risk management and cost benefit justification leading to a separate implementation decision.
Treating these as separate projects is not only essential to a valid justification of these different but related objectives but is essential if timely and optimal implementation of this important technology is to be achieved.
Having spent considerable amounts of public and industry money on this project it is essential that momentum in this overall initiative not be lost by artificial bundling of these separate objectives into a single project with the associated controversy regarding a wide mandate for ADS-B OUT.
The proposed discussion paper and associated cost benefit analysis of these projects must deal with, and report on, these separate projects as separate projects.
BACKGROUND
The ASAC organisations understand that GPS based technology – including GNSS navigation and ADS B – is important new technology for the provision of ATM services which, if applied appropriately, is capable of significant cost savings and improved services and safety.
Australia has spent significant sums of public and/or industry money developing this technology. Accordingly, the ASAC organisations believe that it is important that appropriate implementation of this technology be expedited so that the expected cost savings can be achieved.
Unfortunately, it appears that appropriate implementation of some aspects of this technology is being delayed by what seems to be an almost ideological push to achieve a very wide ADS-B mandate from the very outset. It appears that this objective is forcing an attempt to implement these changes as a single project making the decision an all or nothing outcome. No other nation is taking this ‘big bang’ approach. It is our view that this ‘big bang’ approach is delaying implementation of clearly cost beneficial aspects of this technology while the controversial aspects of a wide ADS-B mandate is debated.
Further to this and equally importantly, debate on these initiatives remains technology driven rather than outcomes based. That is, proposals for the implementation of this technology are based on the existence and success of this technology, not on the need to achieve an identified and justified business objective.
BASIS of IMPLEMENTATION DECISIONS
Implementation of this technology should be progressive. Individual business objectives need to be clearly identified and pursued as separate projects so that those which are ready and/or urgent can be implemented as soon as appropriate – not delayed by other more controversial objectives – so that the momentum in this project is not lost.
The ASAC organisations note that it is government policy that changes to airspace management – which would include these technologies – will be on a risk management and cost benefit basis. ASAC applauds this policy, recently announced by the Minister, and well received by the whole of industry. The ASAC organisations insist that it is clear that the decisions to implement this technology come under this policy and hence that each separate implementation decision must be on a risk management and cost benefit basis.
PROJECT OBJECTIVES
It seems to sport aviation that the development of this technology to date has identified the following separate objectives which are addressed by these technologies.
1. Cost savings and improved outcomes from GNSS Navigation.
2. Implementation of GPS based technology to assist the avoidance of CFIT accidents.
3. Replacement of existing SSR with ADS-B. (Previously known as Option B.)
4. Extension of the ADS-B mandate beyond current radar coverage for air-to-air conflict warning etc. (Previously known as Option C and D.)
There may be others but there are at least these four.
These objectives are not interdependent and the decision to implement must be considered, costed and justified separately.
Some arguments have been advanced that there are economic reasons for simultaneous implementation of some of these objectives. Despite these arguments, the decision to proceed or not in each case is not interconnected as these are independent objectives connected only by the fact that they depend on GPS.
1. GNSS Navigation
A very strong case and plea was made at the most recent meeting of the GIT and ABIT teams, that the delay in implementation of this technology is costing significant sums of money in refurbishing existing aids which would not be required after implementation of GNSS Nav. It is clear that this project can go ahead and it should not be delayed at cost to the nation and the industry because of controversial aspects of other related but not dependant projects.
2. CFIT accidents
This category of accident has actually cost lives. Implementation of the GPS technology to assist the avoidance of these accidents does not depend on ADS-B technology. Any delay in the implementation of this technology threatens to cost lives and should not be tolerated.
3. Replacement of existing SSR with ADS-B
This project – previously referred to as Option B – is clearly cost beneficial and, so far as ASAC understands, is not controversial. An ADS-B OUT mandate for all in Classes A and C and for IFR only in Class E would allow this project to proceed with very significant savings.
4. Extension of the ADS-B Mandate
This project is clearly not cost beneficial nor can it be justified on a risk management basis – not even for the protection of the travelling public.
It is well established that the collision risk in en route airspace is negligible being a few to several orders of magnitude less than design standards for major structural failure.
Circuit and radio procedures at untowered airfields combine to make radio alerted see-and-avoid very successful for collision avoidance in the terminal airspace. Provision of a further means of alert at very considerable cost to GA in this airspace in Australia is not justified.
SIMULTANEOUS IMPLEMENTATION
The only rational argument proposed is that simultaneous implementation would allow some cost savings and a cross subsidy of installation of ADS-B in GA.
Firstly, the cost savings are much less than the actual marginal cost so simultaneous implementation is not cost beneficial.
Secondly, any savings which accrue from the other aspects of this project can be applied to a subsidy at any time after initial implementation. A staged implementation will allow the possibility of using this money for R&D projects which may reduce the cost of implementation rather than simply applying this money to a subsidy.
IMPLEMENTATION IN SPORT AIRCRAFT
Some classes of aircraft – sports aircraft and some ultralights – have no need of any of the services provided by any of these projects. The cost and power drain of the necessary avionics makes fitment in these aircraft impractical and draconian.
These aircraft hold a general exemption from the carriage of transponders in Class E airspace.
Attached are two documents providing a brief justification for this exemption both for safety and security reasons.
It is important to note that this exemption is not only justified on the basis of cost and inability to power but also on a risk management basis. The nature of operations by this category of aircraft means that these aircraft do not represent a credible hazard.
When it comes to collision risk it is established that even unaltered see-and-avoid from such aircraft is effective. A paper justifying this conclusion has been previously supplied to DOTARS ASTRA and CASA. This paper supplied separately.
Bob Hall
President, ASAC
-----------------------------------------------------------------------------
And one more to come.
Final from Dr.R.J.Hall
-----------------------------------------------------------------------------
Appendix B
Basis For Cost-Benefit Analysis of the Extension of ADS-B Beyond Replacement of Radar Like Services.
Dr. R. J. Hall
President, ASAC
10/11/05
ASAC has provided Airservices and ASTRA with a detailed analysis of the ASTRA cost benefit analysis (Appendix B1). The response by the ABIT Chair did not add any information and left our conclusions unchanged. I refer to this document for detail and the following summary is provided here.
The cost benefit study by ASTRA;
“Cross Industry Business Case and Cost-benefit Analysis: ADS-B Avionics Fitment” V1.1 – ASTRA-CIBC 01 ,
reaches a wrong conclusion for two reasons:
1. It assumes fitment of ADS-B IN by GA in calculating the benefits but it does not include the cost of this fitment in the total cost calculation. (Outside radar coverage and third party intervention, ADS-B IN is required for any benefit.)
2. The cost benefit includes cost savings for accident types not requiring fitment of ADS-B OUT by other aircraft. Specifically CFIT and facilitated reductions in SAR times. This is an outcome of fitment in the affected aircraft only. Recommended elective fitment meets this outcome.
This study does show that replacement of some SSR radar with ADS-B is justified as proposed.
The mandate required to meet this proposal is for those receiving a radar service – that is, for all in Classes A and C and for IFR in Class E.
Extension of the mandate beyond that which is required to meet this service provision must depend on the hazard addressed by requiring fitment by all and the cost of this mitigator. Of the accident types discussed by ASTRA only mid-air collision meets these requirements. Discussion by all in meetings of ASTRA and ABIT confirms the view that it is this accident type which drives the push for this mitigator.
ASAC points out that the mid-air collision hazard in Classes E and G is very small. There is no significant hazard en route and the hazard is limited to the terminal area of uncontrolled airfields.
The hazard in the terminal area is addressed by NAS 2c CTAF procedures and depends on radio alerted see-and-avoid. It is also further mitigated by TCAS and transpoders. The size of this hazard does not justify a very expensive third mitigator as follows.
Based on ASTRA figures (see below) the cost of providing an ADS-B alert in this airspace is, over the period of project, $110 million. This is composed of $30 million for installation of ADS-B OUT in additional GA aircraft and an estimated $80 million for an 80% fitment of ADS-B IN in GA.
The benefit achieved, even based on the optimistic figures for the effectiveness of this second mitigator in the terminal area quoted by ASTRA, is $17 Million or 0.8 fatalities saved per year.
Cost – benefit comparison based on the ASTRA report
Figures from the “Cross Industry Business Case and Cost-benefit Analysis: ADS-B Avionics Fitment” V1.1 – ASTRA-CIBC 01
Cost/Benefit of the Extension of ADS-B beyond replacement of radar
Comparison of Scenario B and D – (See Table on page 8 of 39 of the ASTRA report).
Costs
Cost of fitment of ADS-B OUT for GA in Scenario D is $m99 total
Cost of fitment of ADS-B OUT for GA in Scenario B (replacement of existing radar) is $m69
Additional cost of ADS-B OUT for GA $m30
Cost of fitment of ADS-B IN was not quantified by ASTRA.
Assuming the cost and fitment rate of ADS-B IN to be the same as ADS-B OUT this cost was estimated as the same as ADS-B OUT. This is believed to be conservative and estimates the total cost of a single combined installation as $16,000. I have seen estimates of $30,000. ASTRA could be asked to refine this estimate – but we cannot see that this outcome would be significantly altered in terms of the decision supported.
Estimated cost of 100% fitment of ADS-B IN on the same basis as ADS-B OUT $m99
As only one aircraft needs to be fitted a fitment level of 80% would suffice. This leaves a 2% chance of neither aircraft being fitted – which seems a reasonable level.
i.e. Cost of fitment of ADS-B IN for GA = $m80
Total cost of deriving the benefits assumed in the ASTRA report $m110
Benefits
Quantified as fatalities saved by mid-air collisions avoided CFIT accident avoided and reduced SAR times.
Collision accidents avoided 0.8 pa
CFIT accidents avoided 1.56 pa
Reduced SAR times 1.05 pa
Total 3.41 pa
Accidents saved by ADS-B mandate – i.e. accidents requiring fitment in other aircraft
Collision accident only – 0.8 pa
Value of benefit – 3.41 fatalities avoided pa = $m72.2 total – (50.6 to GA and 22.7 to community)
Value of benefit from mandate (collision accidents only) - $m17 ($m72.2 /3.41 x 0.8 = $m17)
Total actual benefit from mandatory fitment $m17
Appendix B1
COMMENTS ON ASTRA ADS-B REPORT
“CROSS INDUSTRY BUSINESS CASE AND COST BENEFIT ANALYSIS”
Dr. R. J. Hall
President, ASAC
20/06/05
SUMMARY
The proponents of ADS-B claim that ADS-B provides the opportunity to improve aviation safety and reduce costs. The cost benefit analysis presented in the ASTRA Report shows unequivocally that this is not true.
Improved safety outcomes depend heavily on extension of ADS-B to regions not currently covered by radar. The central accident type driving these views is a midair collision. This ASTRA report and associated CASA reports show that these accidents occur essentially exclusively in the region of an airfield with more than half in the circuit itself. Application of ADS-B to prevent this accident type depends on a GA VFR pilot monitoring a moving map display in the circuit area. Experience shows that this procedure would significantly increase accidents at airports not reduce them. Standard TCAS procedures requires a commercial IFR pilot to turn off the TCAS warning prior to entry into the circuit to avoid distraction in the this phase of flight.
The other safety outcomes claimed in the ASTRA report do not depend on ADS-B as the appropriate mitigator.
The proposal is far from low cost. The real cost of the combined project is more than $m 300 including some $m 200 (largely by GA) for the extension of ADS-B coverage to achieve the claimed benefits to GA. These benefits are realistically valued at less than $m 25 over the assumed life of the project (19 years). (See below)
The data does show that ADS-B can provide a radar-like service for ATC purposes at reduced cost to Airservices. However, this is core safety technology and the savings achieved (3-5% reduction in the costs of en route services) do not justify exposure to the financial and operational risks associated with a move to ADS-B until there is actual international operational experience and certainty regarding the choice of ADS-B operating system in the US and Europe.
Where ADS-B is used to replace radar, this data and simple logic shows that ADS-B OUT should be mandated based on ATC service requirements. That is ADS-B OUT should be mandated for all in Classes A and C and for IFR operations in Classes E and D. Other existing procedures should apply to VFR for Class D airspace and the NAS recommendations for Class E airspace – see attached.
This approach is not only logical, but it:
a) will impose costs on sectors which require or desire services,
b) is risk management based, and will deliver good safe outcomes,
c) will maximise real return for investment to Airservices and hence introduce real savings to the major airlines,
i) by incorporating savings from both replacement of radar with ADS-B and Nav aids with GNSS based avionics,
ii) and minimise mandated costs to those actually necessary to achieve these outcomes.
and, hence, will maximise reduction in ATC charges for ATC service users.
Security Considerations
If security considerations override this risk management outcome then the existing exemptions for unpowered craft must be retained. This is justified by the draconian effect of imposition of this requirement on these craft combined with the improbability of these craft reaching a centre of population without the assistance of a powered craft.
DETAILED COMMENTS
This analysis needs to consider two projects:
Project 1. The replacement of some existing SSR radar services by ADS-B. This project is largely not controversial but has a decision time line requiring an initial decision by first quarter 2006.
Project 2. The extension of ADS-B services beyond current radar coverage. This project involves very considerable additional investment, is very controversial and does not have a specific decision time line.
Decoupling these projects allows a timely decision regarding the replacement of some SSR radar with ADS-B while allowing time for consultation and for the important controversial decisions involved in this project to be based on real experience with ADS-B.
SAFETY OUTCOMES
The widespread enthusiasm for this project derives from the perceived safety benefits associated with midair collision avoidance. This depends on widespread extension of ADS-B coverage outside current radar coverage – Project 2 (Scenario D in the ASTRA report).
The accident record relied on in this ASTRA Report, backed by extensive analysis and modeling, shows that midair collision hazard exists exclusively in the region of airfields.
CASA examined the Australian midair collision record and concluded that ADS-B would have reduced fatalities by this cause by 80%. Examination of the Australian accidents used to justify the conclusion by CASA shows that all but 2 occurred in the region of an airfield. 14 out of 29 accidents were assumed avoided by ADS-B. 9 out of the 14 collisions assumed avoided occurred in the circuit itself. No allowance was made for accidents caused by inappropriate use of ADS-B.
There have been no collisions involving RPT aircraft and no en route collision in this airspace. Detailed analysis and modeling confirm that this is the expected result – that is, it does not depend on ‘luck’.
Collision avoidance procedures based on ADS-B coverage requires GA to fit both ADS-B OUT and ADS-B IN and a sophisticated moving map display. More importantly, implementation of the information provided to collision avoidance in the region of an airfield requires that a GA VFR pilot monitor that moving map display in the circuit area – ie during take off, circuit and landing.
Because of the distraction caused, current TCAS procedures require that the TCAS warning be turned off when approaching the circuit area.
Experience in glider operations has identified excessive monitoring of GPS improved cockpit displays as a significant factor in a number of recent glider-to-glider midair collision accidents.
Current proposals for revised CTAF procedures at uncontrolled airfields rely on the proven practices used in the US which use an improved alert process which enhances, not replaces, see-and-avoid. These procedures encourage pilots to look outside the aircraft rather than concentrate on an alert from within the aircraft.
The suggestion that a GA VFR pilot should be encouraged to monitor a moving map display during take off, circuit and landing is of very great concern.
Application away from the region of an airfield will have no practical effect as the accident record and extensive analysis and modeling shows that there is no hazard in en route airspace. Estimates of number of aircraft in this airspace show that the maximum number in all of Classes E and G (ie outside existing radar coverage) is conservatively high at ca 300. Ask yourself the following. How much money would you spend to prevent a road collision if there were 300 cars outside the main centres of population? Then remember that cars move in two dimensions not three.
The claims of cheaply obtained improved safety are illusory.
Cost Benefit Analysis
The revised benefit/cost ratio (Table on p 8 of the report) shows that replacement of some SSR radar by ATS-B saves considerable capital investment for Airservices. These benefits to Airservices are highest for Project 1 (Scenario B in the ASTRA Report). These benefits to Airservices are halved in Project 2 (Scenario D in the ASTRA report).
The only significant benefit claimed by this corrected report now lies in the GA sector. The benefits accruing to the other sectors are minor.
(The nature of the errors in the report as first released do not engender confidence and suggest that the rush to decision on this project involves very significant risks which are not appropriate to such a decision. By way of example, the average flight time for a domestic flight was accidentally entered at 10 times the actual value. This error resulted in an inflated return to the larger airline sector. Several other instances of erroneously inflated numbers occurred. This is not to comment on the professionalism of those involved as this is not in doubt. However, it does indicate haste not appropriate to such a decision.)
These comments will firstly examine Project 2 – extension of ADS-B beyond current radar coverage and then some comments on Project 1. More details provided in Appendix B1
C COST BENEFIT of EXTENSION OF ADS-B BEYOND CURRENT RADAR COVERAGE – PROJECT 2
The ASTRA Report claims that the cost benefit analysis is conservative and underestimates the benefit/cost situation. This is untrue.
The benefit/cost outcome for Project 1 (Scenario B in the ASTRA report) is estimated conservatively but the benefit/cost outcome for Project 2 (Scenario D) and to a lesser extent for Scenario C (ASTRA Report) is overestimated thus exaggerating the benefit/cost outcome from the additional investment involved in Project 2. (see table below)
Benefits to GA
The assumed improved safety outcomes are quantified by predicted fatalities assumed saved by mandated ADS-B OUT.
These are summarised in the following table:
ADS-B to current radar coverage Extension of ADS-B beyond current radar coverage Assumed Fatalities
Saved in Project 2 Mandate ADS-B
Accident type Project 1
Scenario B Scenario C Project 2 Scenario D Require ADS-B out Require ADS-B in
Mid-air collision Not included Not included Included 0.8 pa Yes Yes
CFIT Not included 60% fitment Included 1.56 pa No No
SAR Not included Not included Included 1.05 pa No No
Nav Aid Rationalisation Partial Partial Complete No No
1. The revised cost benefit data reported, after removal of errors in the earlier report, shows that the remaining benefits claimed are confined to the GA sector. Benefits claimed for other sectors are marginal at best.
2. The benefits claimed for GA are all indirect and result from assumed improvements in safety.
a) The report assumes an 80% reduction in fatalities due to midair collision. However these collision occur exclusively in the region of airfields. Any effect of ADS-B on this accident type depends on fitment of ADS-B IN, a sophisticated moving map display and rely on an associated recommendation that GA VFR pilots monitor a moving map display during take off circuit and landing. These savings are at best exaggerated and more probably invalid.
b) Avoidance of CFIT accidents depends on a GPS moving map display and does not require ADS B OUT in other aircraft. This outcome will be achieved much more cost effectively simply by the take-up of accurate moving map displays and must be totally removed from this analysis.
c) 35% geographical coverage down to 5000’ is a ineffective means of assisting SAR times. Savings associated with the facilitation of SAR depends on ongoing monitoring of tracks by VFR pilots outside current radar coverage. This is not current practice within radar procedures. No ongoing cost of either manual or automatic monitoring VFR traffic outside of controlled airspace or in Class E is included. This outcome is better achieved using an emergency locator beacon.
The benefits were quantified by the number of fatalities avoided. The ASTRA Report calculated 3.41 pa for Project 2 (full geographic coverage or Scenario D in the ASTRA report) but are more likely zero to 0.4 pa as a result of mandated ADS B OUT – but only then provided this is accompanied with general fitment of ADS-B IN.
3. Rationalisation of, and hence saving from, Nav aids does not depend on an ADS-B OUT mandate. Aircraft dependant on Nav aids need fit C-145/146 TSO GNSS navigators not ADS-B OUT. GA does not need, and the ADS-B system does not depend on, fitment of ADS-B OUT to implement this change. Navigational outcomes are not relevant to the mandate of ADS-B.
4. If Airservices does monitor VFR traffic in Classes E or G then this will introduce a very real problem with duty of care and will introduce ongoing additional costs to Airservices including either or both surveillance costs and/or insurance costs.
Overall
Except for possible benefits from a reduction in midair collisions, the benefits claimed in the ASTRA Report for Project 2 (Scenario D) are not outcomes of mandating ADS-B.
The actual benefit from midair collisions would be more like zero to 0.4 fatalities pa. This outcome would be better addressed by improved application of NAS CTAF procedures and concentration on, and improved training of GA pilots in alerted see-and-avoid and appropriate use of radio.
Costs to GA
Firstly GA has no means of obtaining information for ADS-B unless GA also fit ADS-B IN.
The total cost to GA for Project 2 (Scenario D) is already $m 99 or $m38.6 more than Project 1 (Scenario B). This is for fitment of ADS-B OUT. The actual cost to GA of achieving the outcomes assumed in this report is likely to be more than twice that reported because these depend on full GA equipage with ADS-B IN and a sophisticated moving map display by 2020. The total cost will be something in excess of $m200. The actual additional cost for Project 2 (Scenario D) is then ca $m140.
Conclusion
Project 2 cannot be justified based on the figures reported in the ASTRA Report.
COST JUSTIFICATION OF REPLACEMENT OF RADAR WITH ADS-B – PROJECT 1
Overall, eventual replacement of some SSR radar by ADS-B seems justified for the service provider.
The change moves the major investment from the service provider to GA. The beneficiaries are Airservices and the airlines.
Unless this cost is picked up by Airservices, then this represents a very heavy subsidy of the big end of town by the small end of town which cannot be justified under any circumstances. To hold GA to ransom over this subsidy to achieve an immediate take up is iniquitous and unacceptable.
How ever or when ever this is introduced, equity demands that investment must be made by the service provider.
While the implementation of Scenario B is a matter for the big end of town the following comments seem relevant.
* This is a complete change to the core technology of the business of the service provider to a new and essentially untried technology.
* This change is made for a return which is reported as (only) 3-5% of the cost of en route services.
* This report does not include the normal due diligence for such a change appropriate to even a public company let alone a public utility, such as Airservices, with significant safety outcomes.
* Very significant financial and safety risks are associated with this change which are not addressed.
a) There is no operational experience with this technology and it would be prudent to assume that there will be some implementation problems.
b) Perhaps more importantly, it remains unclear just which of the ADS-B systems under trial will be adopted by the US and Europe. If Australia ends up with an Australia specific system, the cost of avionics in Australia will be high and further development will be limited. It seems likely that Australia would, eventually, have to at least consider a re-fit.
Added to these risks associated with Project 1 is the very considerable ‘duty of care’ risk associated with collection of data on aircraft movements based on a fitment of avionics mandated by CASA.
OVERALL
It is my contention that this investment should be delayed until there is international operational experience with the system and certainty regarding the ADS-B system implemented in the international market, even if this delay would result in significant additional investment to maintain the current system. Given that the NZ SSR radars are older than those in Australia, but otherwise identical, it does not seem that replacement at this time is essential and refurbishment, under the present circumstances, would be a cost effective way forward. If that was impossible then a quantitative financial risk assessment would need to be carried out. I doubt that this would leave much of the 3 – 5% return on the bottom line intact.
SECURITY ISSUES
If this risk management basis for decision is overridden by security issues then, especially given the very large distances between the site of operations and any significant population centre, it is essential that current exemptions from carriage of transponder for unpowered aircraft unable to power these devices (largely gliders – GFA and HGFA – and balloons), based on the absence of ‘an engine driven generator capable of continuously powering such a device’ must be retained and applied to ADS-B. The craft included in this category would be unable to reach a population centre without assistance of a powered craft.
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Appendix B
Basis For Cost-Benefit Analysis of the Extension of ADS-B Beyond Replacement of Radar Like Services.
Dr. R. J. Hall
President, ASAC
10/11/05
ASAC has provided Airservices and ASTRA with a detailed analysis of the ASTRA cost benefit analysis (Appendix B1). The response by the ABIT Chair did not add any information and left our conclusions unchanged. I refer to this document for detail and the following summary is provided here.
The cost benefit study by ASTRA;
“Cross Industry Business Case and Cost-benefit Analysis: ADS-B Avionics Fitment” V1.1 – ASTRA-CIBC 01 ,
reaches a wrong conclusion for two reasons:
1. It assumes fitment of ADS-B IN by GA in calculating the benefits but it does not include the cost of this fitment in the total cost calculation. (Outside radar coverage and third party intervention, ADS-B IN is required for any benefit.)
2. The cost benefit includes cost savings for accident types not requiring fitment of ADS-B OUT by other aircraft. Specifically CFIT and facilitated reductions in SAR times. This is an outcome of fitment in the affected aircraft only. Recommended elective fitment meets this outcome.
This study does show that replacement of some SSR radar with ADS-B is justified as proposed.
The mandate required to meet this proposal is for those receiving a radar service – that is, for all in Classes A and C and for IFR in Class E.
Extension of the mandate beyond that which is required to meet this service provision must depend on the hazard addressed by requiring fitment by all and the cost of this mitigator. Of the accident types discussed by ASTRA only mid-air collision meets these requirements. Discussion by all in meetings of ASTRA and ABIT confirms the view that it is this accident type which drives the push for this mitigator.
ASAC points out that the mid-air collision hazard in Classes E and G is very small. There is no significant hazard en route and the hazard is limited to the terminal area of uncontrolled airfields.
The hazard in the terminal area is addressed by NAS 2c CTAF procedures and depends on radio alerted see-and-avoid. It is also further mitigated by TCAS and transpoders. The size of this hazard does not justify a very expensive third mitigator as follows.
Based on ASTRA figures (see below) the cost of providing an ADS-B alert in this airspace is, over the period of project, $110 million. This is composed of $30 million for installation of ADS-B OUT in additional GA aircraft and an estimated $80 million for an 80% fitment of ADS-B IN in GA.
The benefit achieved, even based on the optimistic figures for the effectiveness of this second mitigator in the terminal area quoted by ASTRA, is $17 Million or 0.8 fatalities saved per year.
Cost – benefit comparison based on the ASTRA report
Figures from the “Cross Industry Business Case and Cost-benefit Analysis: ADS-B Avionics Fitment” V1.1 – ASTRA-CIBC 01
Cost/Benefit of the Extension of ADS-B beyond replacement of radar
Comparison of Scenario B and D – (See Table on page 8 of 39 of the ASTRA report).
Costs
Cost of fitment of ADS-B OUT for GA in Scenario D is $m99 total
Cost of fitment of ADS-B OUT for GA in Scenario B (replacement of existing radar) is $m69
Additional cost of ADS-B OUT for GA $m30
Cost of fitment of ADS-B IN was not quantified by ASTRA.
Assuming the cost and fitment rate of ADS-B IN to be the same as ADS-B OUT this cost was estimated as the same as ADS-B OUT. This is believed to be conservative and estimates the total cost of a single combined installation as $16,000. I have seen estimates of $30,000. ASTRA could be asked to refine this estimate – but we cannot see that this outcome would be significantly altered in terms of the decision supported.
Estimated cost of 100% fitment of ADS-B IN on the same basis as ADS-B OUT $m99
As only one aircraft needs to be fitted a fitment level of 80% would suffice. This leaves a 2% chance of neither aircraft being fitted – which seems a reasonable level.
i.e. Cost of fitment of ADS-B IN for GA = $m80
Total cost of deriving the benefits assumed in the ASTRA report $m110
Benefits
Quantified as fatalities saved by mid-air collisions avoided CFIT accident avoided and reduced SAR times.
Collision accidents avoided 0.8 pa
CFIT accidents avoided 1.56 pa
Reduced SAR times 1.05 pa
Total 3.41 pa
Accidents saved by ADS-B mandate – i.e. accidents requiring fitment in other aircraft
Collision accident only – 0.8 pa
Value of benefit – 3.41 fatalities avoided pa = $m72.2 total – (50.6 to GA and 22.7 to community)
Value of benefit from mandate (collision accidents only) - $m17 ($m72.2 /3.41 x 0.8 = $m17)
Total actual benefit from mandatory fitment $m17
Appendix B1
COMMENTS ON ASTRA ADS-B REPORT
“CROSS INDUSTRY BUSINESS CASE AND COST BENEFIT ANALYSIS”
Dr. R. J. Hall
President, ASAC
20/06/05
SUMMARY
The proponents of ADS-B claim that ADS-B provides the opportunity to improve aviation safety and reduce costs. The cost benefit analysis presented in the ASTRA Report shows unequivocally that this is not true.
Improved safety outcomes depend heavily on extension of ADS-B to regions not currently covered by radar. The central accident type driving these views is a midair collision. This ASTRA report and associated CASA reports show that these accidents occur essentially exclusively in the region of an airfield with more than half in the circuit itself. Application of ADS-B to prevent this accident type depends on a GA VFR pilot monitoring a moving map display in the circuit area. Experience shows that this procedure would significantly increase accidents at airports not reduce them. Standard TCAS procedures requires a commercial IFR pilot to turn off the TCAS warning prior to entry into the circuit to avoid distraction in the this phase of flight.
The other safety outcomes claimed in the ASTRA report do not depend on ADS-B as the appropriate mitigator.
The proposal is far from low cost. The real cost of the combined project is more than $m 300 including some $m 200 (largely by GA) for the extension of ADS-B coverage to achieve the claimed benefits to GA. These benefits are realistically valued at less than $m 25 over the assumed life of the project (19 years). (See below)
The data does show that ADS-B can provide a radar-like service for ATC purposes at reduced cost to Airservices. However, this is core safety technology and the savings achieved (3-5% reduction in the costs of en route services) do not justify exposure to the financial and operational risks associated with a move to ADS-B until there is actual international operational experience and certainty regarding the choice of ADS-B operating system in the US and Europe.
Where ADS-B is used to replace radar, this data and simple logic shows that ADS-B OUT should be mandated based on ATC service requirements. That is ADS-B OUT should be mandated for all in Classes A and C and for IFR operations in Classes E and D. Other existing procedures should apply to VFR for Class D airspace and the NAS recommendations for Class E airspace – see attached.
This approach is not only logical, but it:
a) will impose costs on sectors which require or desire services,
b) is risk management based, and will deliver good safe outcomes,
c) will maximise real return for investment to Airservices and hence introduce real savings to the major airlines,
i) by incorporating savings from both replacement of radar with ADS-B and Nav aids with GNSS based avionics,
ii) and minimise mandated costs to those actually necessary to achieve these outcomes.
and, hence, will maximise reduction in ATC charges for ATC service users.
Security Considerations
If security considerations override this risk management outcome then the existing exemptions for unpowered craft must be retained. This is justified by the draconian effect of imposition of this requirement on these craft combined with the improbability of these craft reaching a centre of population without the assistance of a powered craft.
DETAILED COMMENTS
This analysis needs to consider two projects:
Project 1. The replacement of some existing SSR radar services by ADS-B. This project is largely not controversial but has a decision time line requiring an initial decision by first quarter 2006.
Project 2. The extension of ADS-B services beyond current radar coverage. This project involves very considerable additional investment, is very controversial and does not have a specific decision time line.
Decoupling these projects allows a timely decision regarding the replacement of some SSR radar with ADS-B while allowing time for consultation and for the important controversial decisions involved in this project to be based on real experience with ADS-B.
SAFETY OUTCOMES
The widespread enthusiasm for this project derives from the perceived safety benefits associated with midair collision avoidance. This depends on widespread extension of ADS-B coverage outside current radar coverage – Project 2 (Scenario D in the ASTRA report).
The accident record relied on in this ASTRA Report, backed by extensive analysis and modeling, shows that midair collision hazard exists exclusively in the region of airfields.
CASA examined the Australian midair collision record and concluded that ADS-B would have reduced fatalities by this cause by 80%. Examination of the Australian accidents used to justify the conclusion by CASA shows that all but 2 occurred in the region of an airfield. 14 out of 29 accidents were assumed avoided by ADS-B. 9 out of the 14 collisions assumed avoided occurred in the circuit itself. No allowance was made for accidents caused by inappropriate use of ADS-B.
There have been no collisions involving RPT aircraft and no en route collision in this airspace. Detailed analysis and modeling confirm that this is the expected result – that is, it does not depend on ‘luck’.
Collision avoidance procedures based on ADS-B coverage requires GA to fit both ADS-B OUT and ADS-B IN and a sophisticated moving map display. More importantly, implementation of the information provided to collision avoidance in the region of an airfield requires that a GA VFR pilot monitor that moving map display in the circuit area – ie during take off, circuit and landing.
Because of the distraction caused, current TCAS procedures require that the TCAS warning be turned off when approaching the circuit area.
Experience in glider operations has identified excessive monitoring of GPS improved cockpit displays as a significant factor in a number of recent glider-to-glider midair collision accidents.
Current proposals for revised CTAF procedures at uncontrolled airfields rely on the proven practices used in the US which use an improved alert process which enhances, not replaces, see-and-avoid. These procedures encourage pilots to look outside the aircraft rather than concentrate on an alert from within the aircraft.
The suggestion that a GA VFR pilot should be encouraged to monitor a moving map display during take off, circuit and landing is of very great concern.
Application away from the region of an airfield will have no practical effect as the accident record and extensive analysis and modeling shows that there is no hazard in en route airspace. Estimates of number of aircraft in this airspace show that the maximum number in all of Classes E and G (ie outside existing radar coverage) is conservatively high at ca 300. Ask yourself the following. How much money would you spend to prevent a road collision if there were 300 cars outside the main centres of population? Then remember that cars move in two dimensions not three.
The claims of cheaply obtained improved safety are illusory.
Cost Benefit Analysis
The revised benefit/cost ratio (Table on p 8 of the report) shows that replacement of some SSR radar by ATS-B saves considerable capital investment for Airservices. These benefits to Airservices are highest for Project 1 (Scenario B in the ASTRA Report). These benefits to Airservices are halved in Project 2 (Scenario D in the ASTRA report).
The only significant benefit claimed by this corrected report now lies in the GA sector. The benefits accruing to the other sectors are minor.
(The nature of the errors in the report as first released do not engender confidence and suggest that the rush to decision on this project involves very significant risks which are not appropriate to such a decision. By way of example, the average flight time for a domestic flight was accidentally entered at 10 times the actual value. This error resulted in an inflated return to the larger airline sector. Several other instances of erroneously inflated numbers occurred. This is not to comment on the professionalism of those involved as this is not in doubt. However, it does indicate haste not appropriate to such a decision.)
These comments will firstly examine Project 2 – extension of ADS-B beyond current radar coverage and then some comments on Project 1. More details provided in Appendix B1
C COST BENEFIT of EXTENSION OF ADS-B BEYOND CURRENT RADAR COVERAGE – PROJECT 2
The ASTRA Report claims that the cost benefit analysis is conservative and underestimates the benefit/cost situation. This is untrue.
The benefit/cost outcome for Project 1 (Scenario B in the ASTRA report) is estimated conservatively but the benefit/cost outcome for Project 2 (Scenario D) and to a lesser extent for Scenario C (ASTRA Report) is overestimated thus exaggerating the benefit/cost outcome from the additional investment involved in Project 2. (see table below)
Benefits to GA
The assumed improved safety outcomes are quantified by predicted fatalities assumed saved by mandated ADS-B OUT.
These are summarised in the following table:
ADS-B to current radar coverage Extension of ADS-B beyond current radar coverage Assumed Fatalities
Saved in Project 2 Mandate ADS-B
Accident type Project 1
Scenario B Scenario C Project 2 Scenario D Require ADS-B out Require ADS-B in
Mid-air collision Not included Not included Included 0.8 pa Yes Yes
CFIT Not included 60% fitment Included 1.56 pa No No
SAR Not included Not included Included 1.05 pa No No
Nav Aid Rationalisation Partial Partial Complete No No
1. The revised cost benefit data reported, after removal of errors in the earlier report, shows that the remaining benefits claimed are confined to the GA sector. Benefits claimed for other sectors are marginal at best.
2. The benefits claimed for GA are all indirect and result from assumed improvements in safety.
a) The report assumes an 80% reduction in fatalities due to midair collision. However these collision occur exclusively in the region of airfields. Any effect of ADS-B on this accident type depends on fitment of ADS-B IN, a sophisticated moving map display and rely on an associated recommendation that GA VFR pilots monitor a moving map display during take off circuit and landing. These savings are at best exaggerated and more probably invalid.
b) Avoidance of CFIT accidents depends on a GPS moving map display and does not require ADS B OUT in other aircraft. This outcome will be achieved much more cost effectively simply by the take-up of accurate moving map displays and must be totally removed from this analysis.
c) 35% geographical coverage down to 5000’ is a ineffective means of assisting SAR times. Savings associated with the facilitation of SAR depends on ongoing monitoring of tracks by VFR pilots outside current radar coverage. This is not current practice within radar procedures. No ongoing cost of either manual or automatic monitoring VFR traffic outside of controlled airspace or in Class E is included. This outcome is better achieved using an emergency locator beacon.
The benefits were quantified by the number of fatalities avoided. The ASTRA Report calculated 3.41 pa for Project 2 (full geographic coverage or Scenario D in the ASTRA report) but are more likely zero to 0.4 pa as a result of mandated ADS B OUT – but only then provided this is accompanied with general fitment of ADS-B IN.
3. Rationalisation of, and hence saving from, Nav aids does not depend on an ADS-B OUT mandate. Aircraft dependant on Nav aids need fit C-145/146 TSO GNSS navigators not ADS-B OUT. GA does not need, and the ADS-B system does not depend on, fitment of ADS-B OUT to implement this change. Navigational outcomes are not relevant to the mandate of ADS-B.
4. If Airservices does monitor VFR traffic in Classes E or G then this will introduce a very real problem with duty of care and will introduce ongoing additional costs to Airservices including either or both surveillance costs and/or insurance costs.
Overall
Except for possible benefits from a reduction in midair collisions, the benefits claimed in the ASTRA Report for Project 2 (Scenario D) are not outcomes of mandating ADS-B.
The actual benefit from midair collisions would be more like zero to 0.4 fatalities pa. This outcome would be better addressed by improved application of NAS CTAF procedures and concentration on, and improved training of GA pilots in alerted see-and-avoid and appropriate use of radio.
Costs to GA
Firstly GA has no means of obtaining information for ADS-B unless GA also fit ADS-B IN.
The total cost to GA for Project 2 (Scenario D) is already $m 99 or $m38.6 more than Project 1 (Scenario B). This is for fitment of ADS-B OUT. The actual cost to GA of achieving the outcomes assumed in this report is likely to be more than twice that reported because these depend on full GA equipage with ADS-B IN and a sophisticated moving map display by 2020. The total cost will be something in excess of $m200. The actual additional cost for Project 2 (Scenario D) is then ca $m140.
Conclusion
Project 2 cannot be justified based on the figures reported in the ASTRA Report.
COST JUSTIFICATION OF REPLACEMENT OF RADAR WITH ADS-B – PROJECT 1
Overall, eventual replacement of some SSR radar by ADS-B seems justified for the service provider.
The change moves the major investment from the service provider to GA. The beneficiaries are Airservices and the airlines.
Unless this cost is picked up by Airservices, then this represents a very heavy subsidy of the big end of town by the small end of town which cannot be justified under any circumstances. To hold GA to ransom over this subsidy to achieve an immediate take up is iniquitous and unacceptable.
How ever or when ever this is introduced, equity demands that investment must be made by the service provider.
While the implementation of Scenario B is a matter for the big end of town the following comments seem relevant.
* This is a complete change to the core technology of the business of the service provider to a new and essentially untried technology.
* This change is made for a return which is reported as (only) 3-5% of the cost of en route services.
* This report does not include the normal due diligence for such a change appropriate to even a public company let alone a public utility, such as Airservices, with significant safety outcomes.
* Very significant financial and safety risks are associated with this change which are not addressed.
a) There is no operational experience with this technology and it would be prudent to assume that there will be some implementation problems.
b) Perhaps more importantly, it remains unclear just which of the ADS-B systems under trial will be adopted by the US and Europe. If Australia ends up with an Australia specific system, the cost of avionics in Australia will be high and further development will be limited. It seems likely that Australia would, eventually, have to at least consider a re-fit.
Added to these risks associated with Project 1 is the very considerable ‘duty of care’ risk associated with collection of data on aircraft movements based on a fitment of avionics mandated by CASA.
OVERALL
It is my contention that this investment should be delayed until there is international operational experience with the system and certainty regarding the ADS-B system implemented in the international market, even if this delay would result in significant additional investment to maintain the current system. Given that the NZ SSR radars are older than those in Australia, but otherwise identical, it does not seem that replacement at this time is essential and refurbishment, under the present circumstances, would be a cost effective way forward. If that was impossible then a quantitative financial risk assessment would need to be carried out. I doubt that this would leave much of the 3 – 5% return on the bottom line intact.
SECURITY ISSUES
If this risk management basis for decision is overridden by security issues then, especially given the very large distances between the site of operations and any significant population centre, it is essential that current exemptions from carriage of transponder for unpowered aircraft unable to power these devices (largely gliders – GFA and HGFA – and balloons), based on the absence of ‘an engine driven generator capable of continuously powering such a device’ must be retained and applied to ADS-B. The craft included in this category would be unable to reach a population centre without assistance of a powered craft.
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Just in case you missed it.......
Do not have time for a legthy post now, but I do believe that there is a flly spec'd and will be available for deployment end 2008 if the go ahead is given, solution sub $10k and this is from the horses mouth for a change.
I also wonder if as I think LeadsSled made a point what will it add o new a/c. Well if for GA a/c the cost of a coneventional Mode C + Encoder kit was deducted (you would be buying that anyway) from the ADSB kit...it might ad say $4400 to your new a/c purchase. Or if they said they said you would still get the ADSB "upgrade subsidised" then you would only pay for the cost of mode C now. Ok some RAAA guys do not buy mode C now, but in my opinion they should now anyway, even if its not law.
Geeif we all had Mode C minimum and lots of Radar coverage, and all RPT (even low capacty) had TCAS, maybe none of this would be worth it. But ADSB is way cheaper than the alternative.
Its simple, and many other benefits can be spun off it for not much cost.
Ohh and for those of you who think big brother will be tracing your every Class G flight to invoice you, turn it to "private" mode or whatever it will be called, just like squawking 1200.......nobody will know.
Some of you are scared of ghosts.
J
I also wonder if as I think LeadsSled made a point what will it add o new a/c. Well if for GA a/c the cost of a coneventional Mode C + Encoder kit was deducted (you would be buying that anyway) from the ADSB kit...it might ad say $4400 to your new a/c purchase. Or if they said they said you would still get the ADSB "upgrade subsidised" then you would only pay for the cost of mode C now. Ok some RAAA guys do not buy mode C now, but in my opinion they should now anyway, even if its not law.
Geeif we all had Mode C minimum and lots of Radar coverage, and all RPT (even low capacty) had TCAS, maybe none of this would be worth it. But ADSB is way cheaper than the alternative.
Its simple, and many other benefits can be spun off it for not much cost.
Ohh and for those of you who think big brother will be tracing your every Class G flight to invoice you, turn it to "private" mode or whatever it will be called, just like squawking 1200.......nobody will know.
Some of you are scared of ghosts.
J
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Location: Golden Road to Samarkand
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LeadSled.... ease back on the long posts, even if you're quoting a document. People won't read it. You repeated stuff several times. Insert a link to the document and deliver your perspective in short bites, that way it's clear and concise as to what you're trying to convey.