**Reply to FAA** **Docket No. FAA-2007-29305; Notice No. 07-15, RIN
2120-AI92. Automatic Dependent Surveillance -- Broadcast (ADS-B) Out
performance requirements to support Air Traffic Control (ATC) service**

A. My initial response (FAA-2007-29305-0040.1) clearly showed that
General Aviation (GA) gets minimal benefit from ADS-B Out equipage. The
one area that has some potential for benefit is Search and Rescue (SAR)
but that is minimized by the lack of ADS-B coverage in mountainous areas
and many places throughout the CONUS within a few thousand feet of the
surface. This has been verified with the FAA where a telecon revealed
that the currently planned ADS-B ground infrastructure is only designed
to match current radar coverage. In other words, no improvement in
mountainous areas and throughout the US closer to the ground (to include
pattern altitude).

I request that the FAA provide data to help clarify the potential for
SAR improvement (which means ADS-B Out reception by the ADS-B ground
network), traffic announcement (TIS-B) and weather reception (FIS-B)
(All of these will be used to define full ADS-B functionality). This
data shall be as follows:

1\) A map that shows the coverage for full ADS-B functionality as a
function of height above local ground surface (AGL height).

2\) A map that shows all CONUS airports and whether full ADS-B
functionality is available at that airport at pattern altitude. For
example, it could have circles to represent each airport and those that
have full ADS-B functionality at pattern altitude are colored green
while those that do not have full ADS-B functionality are red. To
accompany this, provide a document that lists each airport by state and
whether it does or does nothave full ADS-B functionality at pattern
altitude.

B. My understanding of the ADS-B Out equipment is limited but if it does
not have the position determination functionality built into it, then I
am assuming that the GA aircraft would have to have a TSOd GPS
(GPS/WAAS) receiver as well. Since not all GA aircraft have TSOd GPS
(GPS/WAAS) receivers, this could substantially increase the cost to each
aircraft owner if this mandate is implemented. That information needs to
be clearly spelled out in the NPRM.

C. Some comments have suggested that full ADS-B capability be mandated.
This will only further increase the cost to the GA community when the
supposed benefits have not been determined to be worth the cost.
Discussion of specific capabilities is below:

1\) Traffic awareness: I personally am quite happy using see and avoid
along with flight following. Some people suggest that the airport
traffic pattern is the riskiest area for mid-airs. While that seems
reasonable, it is also not a significant killer. According to the AOPA
2007 Nall Report, page 21:

> *Midair Collisions*
>
> ***6 total \[accidents\]/4 fatal \[accidents\]***
>
> *Collisions between aircraft in flight are relatively rare. Most
> happen in day VFR conditions, frequently in or near an airport traffic
> pattern. Total midair collisions for 2006 dropped to six from the
> previous year's 10. Fatal midair accidents remained at four, with nine
> persons killed. As collision avoidance technology becomes more
> widespread in general aviation, these numbers may improve in coming
> years.*

From page 4 of the Nall Report, in 2006 there were 1319 fixed-wing GA
accidents, 273 fatal fixed-wing accidents and 488 fixed-wing GA
fatalities.

That means that mid-air accidents account for 6/1319 or 0.45% of
fixed-wing GA accidents, 4/273 or 1.47% of fatal-fixed wing accidents
and 9/488 or 1.84% of all fixed-wing GA fatalities.

Given that pilot errors are a factor in around 79% of fatalities,
mid-airs are hardly the serious threat that justifies costly avionics to
receive TIS-B type information. That of course assumes that TIS-B
information is available at all airport pattern altitudes which has not
been proven as true by the FAA to my knowledge.

I was not able to analyze the mid-air accidents but it is possible that
had one or both planes used flight following/traffic advisory services
from ATC, and/or used one of the commercially available traffic
detection systems such as the Zaon or Monroy portable collision
avoidance systems, then this already minor source of GA accidents and
fatalities may have been reduced. Regardless, while reducing mid-airs to
zero is certainly a desirable goal, realistically that may never happen.

2\. Weather information: In the last five years I have made
approximately four flights where having on-board weather would have been
helpful. I was able to safely complete those flights with a combination
of using Flight Service and landings (typically in conjunction with
getting fuel) to check Internet-based weather information.

I also have available XM weather on a Garmin 396 should I determine that
it is of sufficient value to justify the cost. I have not justified
doing so and do not expect to in the future. Therefore, paying the
likely exhorbitant cost of ADS-B In/Out to get "free" weather is
likewise not justifiable.

The FAA could evaluate subsidizing the cost of XM and similar weather
services if they really believe that it will save lives. Other options
include allowing suspension of service when not needed and rental of a
Garmin x96 for those few trips when on-board weather would minimize
landings to check weather. Perhaps commercial services could provide
cheaper options such as daily or block subscriptions. The Aviator level
from XM is \$50 a month or about \$1.67 a day. Perhaps charging \$3-5 a
day for the few days that I need it would be of value and encourage more
people who can benefit from on-board weather to use it. If such a
subscription service were available, there are additional flights where
I would have used it (longer cross-countries and overnight trips). Still
the percentage of flights where on-board weather would have been used is
small.

Another point to consider is that on-board weather could contribute to
an increase in weather related fatalities because people are tempted to
thread the needle of dangerous weather. Time will tell. Remember that
79% of fatal accidents are attributable to pilot error. Judgment cannot
be replaced with technology.

D. I asked one FAA employee how many SSR radars are likely to be
decommissioned if this NPRM becomes a mandate. The answer was around
40%. That obviously is a key to the FAA benefit side to the equation.
However, forcing GA aircraft owners with a huge avionics bill to save
the FAA money is blatantly wrong. GA comments are overwhelmingly against
this NPRM because it fails to meet any reasonable cost-benefit/return on
investment analysis for the GA community. I will clarify my GA viewpoint
in that some high end GA aircraft (jets, etc) may benefit. But the
typical GA pilot I know will not.

E. Airlines, cargo carriers, air taxi operators, etc all seem to be in
favor of it. Wonderful. That they are wholeheartedly in favor of this
NPRM when the NPRM uses such noncommittal phrases as below shows an
element of faith that may not be warranted and is hardly sufficient to
mandate ADS-B Out equipage on the GA community.

> **"At this time the FAA cannot determine the extent to which
> separation standards might be reduced."**
>
> **"The FAA may examine the possible reduction of separation standards
> once ADS--B has been certified to meet existing separation standards
> safely and consistently.**

If they see a benefit then justify the system on their assumed benefits.
If the 40% SSR reduction never takes place because GA aircraft continue
to use Mode C, adjust the FAA cost-benefit analysis accordingly but **DO
NOT** continue down the path of mandated ADS-B Out equipage for the GA
community just to justify the current quagmire that the FAA seems to be
jumping into.

F. It appears that the choice of UAT for GA is of questionable utility.
The data capacity to support weather may not be justified given the wide
availability weather from services like XM, which others have pointed
out has greater coverage (including altitude) than ADS-B. If this proves
correct, then the currently planned system design may be flawed.
Awarding a contract for a system without getting agreement on its
eventual purpose (as substantiated by the negative reception by the GA
community) seems to be a backward process.

G. Some comments have opined that people will rush to equip with ADS-B.
That may be true for commercial aircraft but no one can substantiate a
ground swell of desire by GA pilots to equip with ADS-B. My recollection
of the typical poll/survey on ADS-B is that all were fundamentally
flawed in the wording of the question because they did not properly
provide info to the survey taker of the true costs and lack of benefits
as it applies to this NPRM.

If you want to get a true picture of ADS-B acceptance, provide factual
information on coverage as I requested in the beginning, inform the GA
community that they get nothing with ADS-B Out only, provide full costs
to install ADS-B Out only and full ADS-B functionality avionics to
include TSOd GPS (GPS/WAAS) receivers as required. In some cases this
may mean major panel rework which will significantly inflate the final
cost.

H. Joseph Budge, in his comments (FAA-2007-29305-0125.1) provided this
statement "The FAA estimates that 244,828 GA aircraft will be equipped
with ADS-B in the study period." Despite the fact that this number is
higher than the number of active aircraft (221,943) in the 2006 General
Aviation and Part 135 Activity Survey, page 1-5, it is mind-boggling
that anyone would expect any significant GA compliance with this
proposed mandate once GA aircraft owners realize the uselessness of it.

I. If my view (and that of others) that requiring UAT for the GA fleet
because of bandwidth needs to support weather are unrealistic as
discussed above, the a single frequency (1090ES) for all aircraft that
equip may be the best solution. This may provide ADS-B infrastructure
cost savings to the FAA. Even the NPRM on Page 56952 states "Weather and
flight information for 1090ES equipped aircraft is generally provided by
commercial products."

J. Since Mode-C will still be required on GA aircraft, and TCAS may
remain a requirement, collision avoidance between TCAS equiped aircraft
and Mode-C equiped aircraft may be enhanced if the Mode-C requirement is
expanded to include more airspace. Since Mode-C is far cheaper than
ADS-B Out this solution improves collision avoidance not only with TCAS
equiped aircraft but GA aircraft that use a Zaon/Monroy type system. ATC
also benefits from improved aircraft situational awareness because more
aircraft will be monitored by primary and SSR systems. Note that I am
not requesting that Mode-C equipage be expanded from current required
airspace. I am offering a suggestion to be examined to see if it has
merit.

In summary, my position continues that this NPRM is flawed and offers no
substantive benefit to the overall GA community. Any effort by the FAA
to continue with this mandate to justify a reduction in SSR radars is
wrong. The notion that NextGen will solve capacity problems may be
flawed as well. Remember that technology will not make up for lack of
concrete. The FAA needs to conduct a major review of ADS-B, the
frequency band selected, and consider rescoping the ADS-B contract
before significant money is wasted.

Ron Lee