Comments on the ADS-B Aviation Rulemaking Committee (ARC)
Recommendations REF: Docket No. FAA-2007-29305

Overall it appears that the ARC is assuming that the proposed ADS-B Out
mandate is a done deal despite the rather tepid portion of
Recommendation 9 of not mandating it for most of the GA community:

> **"If the ADS--B mandate results in the low altitude segment of the
> aviation community investing more into the system than the benefits
> enabled, the FAA should not mandate ADS--B Out for that segment of the
> community."**

As a private pilot and aircraft owner I am disappointed in this poor
response to my comments submitted on the original NPRM. While I have not
read it completely in the short time available for review, it appears
that many of the points I raised in FAA-2007-29305-0040.1 were ignored.

Examples are below:

Original Comment: The benefit data presented in the Aerospace document,
\"ADS-B Benefits Enabled from Improved En Route Conflict Probe
Performance\" requires a Congressionally mandated peer review to ensure
that GPS enabled cost savings are not duplicated to justify multiple FAA
programs and are not lost in other negative cost factors such as airline
generated delays, inadequate infrastructure, passenger shoe removal
requirements, etc.

**New Comment:** Unless this is done the cost-benefit data presented is
questionable.

Original Comment: A. ADS-B touted as a means to solve flight delays with
no justification:

This NPRM uses the possible reduced en route separation as implicit
proof that it will solve traffic congestion. \"Without ADS-B, the
increase in demand could result in increased congestion and the denial
of ATC service to some users of the NAS (NPRM para II.A, page 56951).\"
\"Therefore, this rulemaking is expected to help achieve a level of
surveillance accuracy that would support reducing aircraft separation
standards. ADS-B is an essential component of the NextGen platform and
is necessary to achieve a level of capacity in the NAS commensurate with
future growth (NPRM para IV. A., page 56952)\". \"This proposed rule
embraces a new approach to surveillance that can lead to greater and
more efficient utilization of airspace (NPRM page 56966).\"

This NPRM fails to prove that a decrease in en route separation will
lessen flight delays. It is commonly believed within the general public
that significant reasons for flight delays are the hub and spoke system,
weather, inadequate number of runways and possibly gate facilities,
scheduling practices and the significant replacment of larger aircraft
(737 class) with regional jets that carry far fewer passengers per
aircraft.

In AOPA Pilot, October 2007, page 14, under More than 3,000 people set
Delta straight, the following comment is made reference flight delays:
\"\.....GA is somehow responsible for traffic delays. Here's the truth:
Most airline delays are because of the airlines' own scheduling
practices and weather. So says the Department of Transportation.\"

**New Comment:** Failure to provide independent and realistic
cost-benefit data makes the business case for even the airlines
unbelievable. In addition, some of the ARC suggestions, such as
improvingADS-B coverage, will make the overall cost-benefit result less
positive.

Original Comment: 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.

**New Comment:** Even though most possible benefits to GA pilots are
only realized with ADS-B In, there is an assertion that ADS-B Out will
provide significantly better traffic advisory services. Of course this
has major flaws in that most GA pilots I know do not talk to ATC. The
second is that ADS-B coverage may not extend to the regions where
mid-airs are most likely to occur. Yet the data to show planned coverage
is not available. To extend it to pattern altitude as suggested by the
ARC raises the cost side of the cost-benefit equation and has not been
evaluated to my knowledge.

Original Comment: D. No demonstrated safety improvement for GA aircraft.

ADS-B is often suggested as being a means to dramatically lower
accidents and fatalities. This is mentioned in the NPRM in paragraph VI.
A, page 56961:

\"According to FAA accident statistics compiled by the MITRE
Corporation, the Capstone safety program reduced the aircraft fatal
accident rates for Alaska part 135 operators equipped with Capstone
avionics by 45%. While this accident reduction is not solely
attributable to ADS-B, the ADS-B information in the flight deck did
provide increase pilot awareness of surrounding traffic and directly
contributed to the accident rate reduction.\"

**New Comment:** Failure to provide realistic assessments of safety
issues makes safety comments mere platitudes that cannot be
substantiated.

Original Comment: E. Costly Avionics to Meet this Mandate.

Page 56963 of the NPRM shows that the range of equipment and
installation costs for GA aircraft range from \$4,326 to \$17,283. On
page 56967 , it is stated that: \"On the low end, the dollar value may
represent a software upgrade or OEM option change. On the high end, the
dollar value may represent a new installation of upgraded transponder
systems necessary to assure accuracy, reliability and safety.\"

The Garmin GDL 90 ADS-B unit had a suggested retail price of \$7,995 in
2006 but still requires a suitable display for received ADS-B In
information. With display and installation this is probably over
\$10,000.

Thus this NPRM is attempting to mandate very costly ADS-B Out avionics
for which the GA pilot will get minimal to no benefit. No rationale
person could make a credible argument that this would meet a reasonable
cost-benefit analysis. Almost all benefits mentioned throughout this
NPRM are geared towards the airline sector and the FAA.

**New Comment**: Another point that has probably not been evaluated is
that to get full ADS-B functionality may require significant panel
rework on the many aircraft that have no panel space for new equipment.

Original Comment: G. The current FAA plan may compromise safety

In the FAA press release on this subject, \"FAA Wants Aircraft Equipped
for Satellite-Based Navigation by 2020\", Release No. A0C 17-07, October
2, 2007,
http://www.faa.gov/news/press_releases/news_story.cfm?newsId=9632

\"Aviation must take the big step into the next generation of
technology,\" said Acting FAA Administrator Bobby Sturgell. \"It\'s
safer and more accurate. Satellite technology is here to stay.\"

Any reduction in primary radars, whether to secondary surveillance radar
(SSR) and/or ADS components, is a reduction in safety in my opinion as a
VFR GA pilot. SSR reportedly do not pick up GA aircraft not using a Mode
C transponder. Hence, air traffic control loses important traffic
information whenever a primary radar is eliminated.

**New Comment:** This is a prime setup for the law of unintended
consequences in that flight safety may be compromised with ADS-B Out as
envisioned by the NPRM.

ARC Recommendation 9 attempts to justify the "business case" for the GA
community where none exists as well documented in my original comment
submission.

> "Investigate the value of adding the following services to the SBS
> Program:
>
> • Expanded low-altitude NRA surveillance services,
>
> • Automatic closure of flight plans at NRA airports, and
>
> • Flight service station (FSS) improvements."

**New Comment:** The first item increases the FAA cost thus negatively
impacts the FAA cost-benefit ratio. Item two is of zero benefit to most
pilots I know who don't file VFR flight plans. Item three is ambiguous
and may have no direct tie to ADS-B Out. The bottom line here is that
this appears to be a stretch to define some marginal benefit from ADS-B
Out to the GA community.

The ARC should have recognized the groundswell opposition of GA
pilots/aircraft owners against this NPRM and made an unequivocal
statement excluding the "low altitude" GA community from this proposed
mandate. By "low altitude" I mean below 18,000 feet minimum and possibly
as high as around 25,000 feet for higher performance GA aircraft.

Ron Lee