FINAL REGULATORY IMPACT ANALYSIS 

FINAL RULE 

AUTOMATIC DEPENDENT SURVEILLANCE – BROADCAST (ADS-B) OUT 

PERFORMANCE REQUIREMENTS TO SUPPORT AIR TRAFFIC CONTROL 

SERVICE 

(TITLE 14, CODE OF FEDERAL REGULATIONS, PART 91) 

Office of Aviation Policy and Plans 

Regulatory Analysis Division 

August 18, 2009

U.S. Department 

Of Transportation 

FEDERAL AVIATION 

ADMINISTRATION 

Washington, D.C. 20591 
1

Table of Contents 

1.0 Executive Summary................................................................................................ 2 

2.0 Introduction............................................................................................................. 3 

2.1 The Advantages of ADS-B Over Radar.................................................................... 5 

2.2 The ADS-B Out Final Rule....................................................................................... 6 

2.3 Market Failure........................................................................................................... 7 

2.4 General Assumptions for the Benefits Analysis and Government Cost Analysis.... 9 

2.5 Definition Of Scope ................................................................................................ 11 

3.0 Definition Of Approach .............................................................................................. 11 

4.0 Scenarios Analyzed..................................................................................................... 12 

4.1 No-Rule Baseline Scenario..................................................................................... 12 

4.1.1 Definition ......................................................................................................... 12 

4.1.2 Cost to Aircraft Operators of the Baseline Scenario........................................ 12 

4.1.3 Cost to FAA of Continuing Full Radar Surveillance Under the Baseline 

Scenario..................................................................................................................... 12 

Surveillance........................................................................................................... 12 

4.1.4 Benefits ............................................................................................................ 14 

4.2 ADS-B Out – The Final Rule (Preferred Alternative)............................................ 14 

4.2.1 Definition ......................................................................................................... 14 

4.2.2 Requirements of the Rule................................................................................. 14 

4.2.3 Industry Estimation of ADS-B Equipage Costs .............................................. 15 

4.2.4 Cost to FAA to Provide Surveillance Under the ADS-B Out Scenario.......... 37 

4.2.5 Benefits of ADS-B Out.................................................................................... 39 

4.2.5.1 High Altitude Operations Over the Gulf of Mexico ................................. 40 

4.2.5.2 Improved En Route Conflict Probe Performance ..................................... 41 

4.2.5.3 More Accurate Metering Because of Increased Accuracy ....................... 49 

4.2.5.4 Increased Ability to Allow Optimized Profile Descent Procedures ............. 51 

4.2.5.5 Net Impact on Carbon Dioxide Emissions.................................................... 56 

4.3 Multilateration Alternative Scenario................................................................. 64 

4.3.1 Definition ......................................................................................................... 64 

4.3.2 Cost to Industry................................................................................................ 65 

4.3.3 Cost to FAA ..................................................................................................... 65 

4.3.4 Benefits of Multilateration Surveillance.......................................................... 66 

5.0 Summary Comparison of Costs and Benefits .................................................... 67 

6.0 Additional Programmatic Benefits of ADS-B Out ............................................... 71 

6.1 Increased Ability to Conduct Operations at Low Altitudes over the Gulf of 

Mexico .............................................................................................................................. 71 

6.2 Enhanced Search and Rescue Capability.............................................................. 71 

6.3 Enhanced Surveillance Where Radar is Currently Weak ..................................... 74 

Appendix A Legacy Infrastructure Costs ..................................................................... 76 

Appendix B – Reduced Delay over Gulf of Mexico..................................................... 80 

Appendix C Optimal Routing ..................................................................................... 107 

Appendix D Conflict Probe Sensitivity Analysis ....................................................... 116 

Appendix E A Timeline of ADS-B Out Costs and Benefits....................................... 117 
2

1.0 Executive Summary 

The solution to managing growth in the National Airspace System (NAS) is the Next 

Generation Air Transportation System, or NextGen, which will assure the safe and 

efficient movement of people and goods as demand increases. NextGen will use 

technology to allow precise surveillance, permit accurate real-time communication, and 

vastly improve situational awareness. 

 

ADS-B is the chosen new technology for surveillance in the NextGen system. It is a key 

component in achieving many of the goals set forth in the NextGen Integrated Plan. 

ADS-B is a critical component of NextGen and is being developed to transform today’s 

radar-based aviation system to handle increased aviation demand. By itself, ADS-B 

presents significant benefits, but as a component of the NextGen system, the benefits will 

substantially increase. 

We review the following three alternatives for surveillance in this analysis: 

• Baseline radar – Maintain the current radar-based surveillance system and replace 

radar facilities when they wear out. 

• ADS-B – Aircraft operators equip to meet performance requirements required by 

the rule and the FAA provides surveillance services based on downlinked aircraft 

information. 

• Multilateration – The FAA provides surveillance using multilateration. 

The estimated costs of the final rule are the costs of ADS-B Out incremental to radar. 

The estimated incremental cost of the ADS-B Out rule ranges from a low of $3.3 billion 

($2.2 billion at 7% present value) to a high of $7.0 billion dollars ($4.1 billion at 7% 

present value). These costs include costs to the government, as well as to the aviation 

industry and other users of the airspace, to deploy ADS-B and are incremental to 

maintaining surveillance via current technology (radar). The aviation industry will begin 

incurring costs for avionics equipage in 2012 and will incur total costs ranging from $2.5 

billion ($1.4 billion at 7% present value) to $6.2 billion ($3.3 billion at 7% present value) 

with an estimated midpoint of $4.4 billion ($2.3 billion at 7% present value) from 2012 to 

2035. The estimated compliance cost of affected foreign operated airplanes operating in 

the United States is about $5.6 million to $134 million, with a midpoint around $70 

million.1

 These estimated foreign operator costs are not included in this analysis. 

The estimated quantified benefits of the rule range from $6.8 billion ($2.1 billion at 7% 

present value) to $8.5 billion ($2.7 billion at 7% present value) and primarily result from 

savings in fuel, operating cost and time, the net reduction in CO2 emissions from more 

efficient flights and the consumer surplus associated with the additional flights 

accommodated because of the rule. The table below summarizes costs and benefits 

discounted by 7%. 

 

1

 Official Airlines Guide. 
3

Table E.1 Summary of Costs and Benefits in Billions of 2009 Dollars Discounted by 7% 

2.0 Introduction 

Automatic Dependent Surveillance-Broadcast (ADS-B) is an advanced surveillance 

technology that enables equipped aircraft to periodically broadcast their identification, 

current position, altitude, and velocity, through an onboard transmitter, which can be 

received by ADS-B ground stations and by other aircraft appropriately equipped to 

receive this information. ADS–B Out provides air traffic controllers with real-time 

position information that is, in most cases, more accurate than the information available 

with current radar-based systems. With more accurate information, ATC will be able to 

position and separate aircraft with improved precision and timing. 

 The part of the ADS-B system that broadcasts various aircraft information is called 

“ADS-B Out”. The part of the system that provides aircraft with the ability to receive 

other aircrafts’ ADS-B information and other aeronautical information is called “ADS-B 

In”. The rule mandates ADS-B Out for operations in certain airspace. 

The rule will require most aircraft to be equipped with avionics equipment that meets 

ADS-B Out performance standards. The rule will apply to aircraft operating in Class A, 

B, and C airspace, and in the Class E airspace at and above 10,000 ft MSL over the 48 

contiguous United States and the District of Columbia, excluding the airspace at and 

below 2,500 ft above ground level (AGL). The rule also applies to all airspace within 30 

nautical miles (NM) of an airport listed in Title 14 of the Code of Federal Regulations (14 

CFR), Part 91, Appendix D, from the surface upward to 10,000 feet mean sea level 

(MSL) and all airspace above the ceiling and within the lateral boundaries of a Class B or 

Class C airspace area designated for an airport upward to 10,000 feet MSL. Additionally, 
4

the rule will apply to aircraft operating in Class E airspace at and above 3,000 feet MSL 

over the Gulf of Mexico from the coastline of the Untied States out to 12 nautical miles. 

The rule mandates a compliance date of 2020. The FAA has entered into service 

contracts with vendors who will provide an ADS-B ground surveillance infrastructure 

that includes the provision of Flight Information Services-Broadcast (FIS-B) and Traffic 

Information Services - Broadcast (TIS-B) in 2013. If these services are not available by 

that time, the FAA will consider extending the compliance date of the final rule. As the 

ground component of the ADS-B infrastructure becomes mature, the agency plans on 

decommissioning selected noncritical secondary surveillance radar sites. The agency 

plans on retaining approximately 50% of the current secondary radar sites and 100% of 

the existing primary radar systems that will serve as a redundant backup system in the 

event of a large scale ADS-B service disruption.2 The rule will not mandate ADS-B In 

equipment, but the service contractor will provide ground services to enable ADS-B In. 

This analysis presents estimates of the costs and incremental (relative to a radar 

alternative) benefits of the rule (the ADS-B Out scenario) as well as a second alternative - 

multilateration. The costs of a baseline scenario assumes that we continue to use and 

replace radar without further supplementing existing radar service and without requiring 

ADS-B Out or providing services for ADS-B. We also look at the costs of the alternative 

approach of using multilateration rather than radar or ADS-B Out. 

Table 1 summarizes the substantive differences between the proposed rule and the final 

rule. We also made editorial changes and clarifications as explained in the preamble. 

 

2

After exploring various back-up alternatives, the FAA believes maintaining a smaller set of secondary 

radar systems provides the greatest level of certainty. This is because FAA has long-standing experience 

with secondary surveillance radar systems and they are already in place. 
5

Table 1 

Substantive Differences between the Proposed Rule and the Final Rule 

Issue Area The NPRM— The final rule— Effects on 

Costs/Benefits 

Technical 

Standard 

Order

Proposed performance 

standards as defined in 

TSO–C166a (1090 MHz ES) 

or TSO–C154b (UAT). 

Requires performance 

standards as defined in 

TSO–C166b (1090 MHz ES) 

or TSO–C154c (UAT). 

Proposed requiring all 

aircraft above FL240 to 

transmit on the 1090 MHz 

ES broadcast link. 

Requires all aircraft in Class 

A airspace (FL180 and 

above) to transmit on the 

1090 MHz ES broadcast 

link. 

Possible minimal 

increase in costs 

Airspace

Proposed ADS–B 

performance standards for 

operations in all Class E 

airspace at and above 10,000 

feet MSL. 

Requires ADS–B 

performance standards for 

operations in Class E 

airspace at and above 10,000 

feet MSL, excluding the 

airspace at and below 2,500 

feet AGL. 

Possible decrease in 

costs 

NACP Proposed a NACP ≥ 9, which 

provides navigation accuracy 

< 30 meters. 

Requires NACP < 0.05 NM. 

(NACP ≥ 8) 

No effect on ADS-B 

Out benefits 

SIL Proposed a SIL of 2 or 3 Requires an SDA of 2 or 3 

Requires a SIL of 3 

Antenna 

Diversity 

Proposed antenna diversity 

in all 

airspace specified in the rule. 

Does not require antenna 

diversity. 

No effect on ADS-B 

Out benefits, lower 

GA costs 

Total 

Latency

Proposed latency in the 

position source < 0.5 

seconds and latency in the 

ADS–B source < 1 second. 

Requires uncompensated 

latency 

≤ 0.6 seconds and maximum 

total latency ≤ 2.0 seconds. 

Message 

Elements

Proposed a broadcast 

message element for 

“receiving ATC services.” 

Does not require a broadcast 

message element for 

“receiving ATC services.” 

An ability 

to turn off 

ADS–B Out 

Proposed that the pilot be 

able to turn off ADS–B 

transmissions if directed by 

ATC. 

Does not require the pilot be 

able to disable or turn off 

ADS–B transmissions. 

2.1 The Advantages of ADS-B Over Radar 

According to operational evaluations, ADS-B provides improved accuracy over radar in 

almost every air traffic scenario. The ADS-B required by the rule is capable of achieving 

accuracy to within 30 meters, a capability exceeding any existing radar. ADS-B also 

provides more timely information updates than conventional radar. Unlike radar, the 

accuracy and integrity of ADS-B Out is uniform and consistent throughout the service 
6

areas. Therefore, the ability of air traffic control to accurately identify and locate aircraft 

that are further away from air traffic control facilities will be better than radar. ADS-B 

Out also provides more information to air traffic controllers, such as aircraft dimensions 

and aircraft heading, than the current system does, especially in non-radar areas. 

Furthermore, ADS-B position reports are not subject to interference (clutter) from terrain, 

ground structures, flocks of birds, or thunderstorms; whereas, radar is. 

2.2 The ADS-B Out Final Rule 

ADS-B Out will provide enhanced surveillance in areas where secondary surveillance 

radar (SSR) capability currently exists as well as over the Gulf of Mexico and areas in 

Alaska. The FAA believes that it is reasonable to require that aircraft meet the 

performance necessary for ADS-B Out for operation in airspace that currently requires 

transponders. With this rule, the FAA adds Section 91.225 to 14 CFR which requires 

ADS–B Out for operations in Class A, B, and C airspace. In addition, the rule requires 

that aircraft meet ADS-B Out performance requirements to operate in the Gulf of Mexico 

from the coastline of the United States out to 12 NM at and above 3,000 feet MSL. 

Similar to the transponder requirements, ADS-B Out also will be required within 30 NM 

of an airport listed in 14 CFR Part 91, Appendix D, from the surface upward to 10,000 

feet MSL. The rule will permit aircraft not originally certificated with an engine-driven 

electrical system or not subsequently certified with such a system installed (such as a 

balloon or glider) to conduct operations without ADS-B Out under ATC authorization in 

the airspace within 30 NM of an airport listed in Appendix D if the operations are 

conducted: (1) outside any Class A, Class B, or Class C airspace area; and (2) below the 

altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 

10,000 feet MSL, whichever is lower. The rule also requires aircraft meet ADS-B Out 

performance requirements to operate in Class E airspace within the 48 contiguous states 

and the District of Columbia at and above 10,000 feet MSL, excluding the airspace at and 

below 2,500 feet above the surface. 

Generally, Class A airspace is that airspace from 18,000 feet MSL to and including FL 

600, including the airspace overlying the waters within 12 NM of the coastline of the 

United States. This rule will not require aircraft to meet the ADS-B Out performance 

standards for aircraft that operate in airspace beyond 12 NM from the U.S. coastline and 

do not enter U.S. domestic airspace.3

Class B airspace area locations shall include at least one primary airport around which the 

Class B airspace area is designated. The lateral limits should be initially designed in a 

circular configuration centered on the primary airport. The outer limits of the airspace 

shall not exceed a 30 NM radius from the primary airport and will generally be divided 

into three concentric circles: an inner 10 NM radius, a middle 20 NM radius, and an outer 

30 NM radius. The inner 10 NM radius may be subdivided based on operational needs, 

 

3

 There are numerous Offshore Airspace Areas that are designated as Class A airspace and the boundaries

of those airspace areas extend beyond 12 NM from the coastline of the U.S. and into international waters. 

Under agreement with ICAO, the U.S. provides ATC services in these areas and may designate the airspace 

accordingly in order to indicate to pilots the type of ATC services that may be provided. 
7

runway alignment, adjacent regulatory airspace, or adjacent airports. The vertical limits 

of a Class B airspace normally should not exceed 10,000 feet MSL. The inner 10 NM 

area shall normally extend from the surface to the upper limits of the airspace. The floor 

of the area between 10 and 20 NM will normally have a floor between 2,800 and 3,000 

feet above airport elevation. This floor shall remain constant for that segment, but may 

be adjusted considering terrain and adjacent regulatory airspace. The floor of the area 

between 20 and 30 NM will normally be between 5,000 and 6,000 feet above the airport 

elevation. Class B airspace areas generally are configured and appear as an upside-down 

wedding cake and surround the nation’s busiest airports in terms of airport operation or 

passenger enplanements. The configuration of each Class B airspace area is individually 

tailored and is designed to contain all published instrument procedures. An ATC 

clearance is required for all aircraft to operate in the airspace area, and all aircraft that are 

so cleared receive separation services within the airspace. Under this rule, ADS-B Out 

will be required for aircraft operating in this airspace. Class B airspace areas experience 

a high volume of aircraft operations and complex transitions from the en route to the 

terminal environment. Consequently, ADS-B Out can result in better ATC surveillance 

and situational awareness for controllers and pilots in these areas. 

Generally, Class C airspace lateral limits are initially designed as two circles centered on 

the airport reference point. The inner circle is a 5 NM radius, and the outer circle is a 10 

NM radius. The vertical limits of a Class C airspace should be 4,000 ft above the 

primary airport’s field elevation (charted in MSL). The airspace within the 5 NM circles 

shall extend down to the surface and the airspace between the 5 and the 10 NM circles 

shall extend no lower than 1,200 ft AGL. Although the configuration of each Class C 

area is individually tailored, the airspace lateral and vertical limits are in accordance with 

the information above, to the extent possible. For a site to be considered for Class C 

airspace designation, the airport must be serviced by an operational airport traffic control 

tower and a radar approach control; and either an annual instrument operations count of 

75,000 at the primary airport, an annual instrument operations count of 100,000 at the 

primary and secondary airports in the terminal area hub, or an annual count of 250,000 

emplaned passengers at the primary airport. Additionally, each person intending to 

operate an aircraft within Class C airspace must establish two-way radio communications 

with the ATC facility providing air traffic services prior to entering the airspace and must 

maintain those communications while within the airspace. 

 2.3 Market Failure 

Given the benefits that ADS-B equipage will generate, it might initially appear that users 

of the system will have economic incentives to equip with ADS-B even in the absence of 

a federal requirement to do so. However, it is to each operator’s advantage to wait until 

everyone else has equipped or at least until each user knows that all other users will equip 

within a defined time horizon because full benefits of ADS-B will not be realized until a 

sizable percent of aircraft are equipped within a given airspace. Specifically, stakeholder 

analysis of whether to equip voluntarily will not take into account positive externalities 

that equipage will have on other stakeholders. These externalities create a “last mover 

advantage” because users who equip prior to other users will have to wait longer and face 
8

greater uncertainty before seeing a full return on their investment. As a result, users will 

have incentives to delay ADS-B equipage, and there is a significant risk that the aviation 

system will never achieve the critical mass of ADS-B-equipped users that is needed to 

generate benefits. The rule will correct this market failure. 

The delay reduction and fuel savings generated for users of ADS-B (and the 

“performance-based” NAS that it enables) depend highly on extensive adoption among 

users. According to a recent study, “without extensive equipage adoption among airlines 

... ADS-B therefore offers little value except in cases where an airline is a heavy user of 

an ADS-B equipped hub and can gain value from reduced separation between its own 

aircraft and improved management of surface traffic.”4

In other words, the financial analysis for an individual firm or individual pilot is very 

different from the industry-wide analysis. An individual will bear a full share of the 

equipage costs but will only receive benefits if a substantial number of other users in the 

airspace in which that firm operates also equip. 

This introduces two factors with negative impacts on any individual firm’s analysis of 

ADS-B: delayed benefits and uncertainty. If some other users in the relevant airspace 

have not yet committed to ADS-B, any firm considering ADS-B will know that benefits 

will not fully realized until the other users adopt the technology—assuming those users 

choose to adopt the technology at all. In a financial environment where the aviation 

industry requires extremely fast returns on capital investments, individual stakeholders 

will likely heavily discount future returns both for the time value of money and for the 

uncertainty over whether those benefits will arise at all. Many stakeholders may only 

consider the very limited known benefits that they will achieve, assuming no action by 

other users; these benefits, as noted above, are unlikely to be sufficient to justify the 

capital investment. The impact to the rest of the industry from enabling others to achieve 

benefits will not be considered in an individual firm’s analysis. 

Those who install ADS-B late in the adoption process will be, in essence, “free riders” 

because they will receive many of the benefits as those who installed earlier in the 

process, but will have invested less cost on a present value basis, since the time between 

investment and payback will be significantly shorter. Furthermore, those who install 

ADS-B early in the adoption process will not only have to bear the cost of capital for that 

investment, but the cost of the equipment, installation and maintenance may be higher 

due to manufacturers being in the steep part of the learning curve. 

An appropriately-structured government mandate, combined with government investment 

in the necessary air traffic control infrastructure such as ADS-B ground stations (another 

precondition for achieving user benefits), can address this market failure by eliminating 

uncertainty associated with user benefits. With a known mandate deadline, users can 

make an undistorted evaluation of the optimal time to equip. The mandate provides 

 

4

 Marais, Karen and Annalisa L. Weigel, “Encouraging and Ensuring Successful Technology Transition in 

Civil Aviation,” Department of Aeronautics and Astronautics, Massachusetts Institute of Technology, 

Cambridge, MA, March 2006. http://esd.mit.edu/wps/esd-wp-2006-07.pdf
9

certainty that other preconditions necessary to achieve benefits will be met even though 

they are out of an individual user’s control. 

Because of the rule industry knows that everyone will have to equip by a specified time 

period and the FAA will have to install the necessary ground equipment early to meet the 

rule’s compliance date. Some operators will equip early because they will be able to 

achieve benefits early. Some may equip early because of when their aircraft is due for 

maintenance cycle (it is more cost effective to install the avionics when they send the 

aircraft out for a major maintenance cycle which they do every 5 years), and some may 

equip early to get the experience with the system. 

In summary, mandating ADS-B Out equipage to operate in designated airspace is 

necessary because market failures will otherwise dissuade individual users from adopting 

the technology that will generate net benefits for society. The issues these market 

failures generate include an incomplete accounting of societal benefit, a potential time lag 

between a firm’s investment and benefits, and uncertainty about whether those benefits 

will be achieved at all. Government action is required in order to achieve the capacity, 

safety, and efficiency benefits of ADS-B. 

The FAA currently believes it would be premature to mandate ADS-B In equipage, 

because standards to accommodate air-to-air applications are not in place yet. In the 

future, the agency expects to move forward with reduced separation standards and 

possibly allow some self-separation, and at that point further rulemaking may be 

warranted. 

2.4 General Assumptions for the Benefits Analysis and Government Cost Analysis 

The following general assumptions are used in the analysis. Scenario- and benefitspecific assumptions are listed later within the individual sections. 

• All costs and benefits are denominated in 2009 dollars. 

• The final rule will be published in 2010 and have a compliance date of 2020. 

• Present value rates are 3% and 7%. 5

• Costs that are consistent across scenarios are not included. For instance, primary 

radar will be maintained across all scenarios and therefore the cost to continue 

primary radar is not included in any scenario. We assume that all NAS infrastructure 

costs other than surveillance, such as cost of runways, runway extensions and air 

traffic control facilities are the same across all the scenarios and we assume that all 

 

5

 Except for discounting of the social cost of carbon which uses 5% for the low value and 2.5% for the high 

value, as noted in the interagency report titled “Highlights of Appendix15A: Social Cost of Carbon for

Regulatory Impact Analysis under Executive Order 12866.” 
10

NAS personnel costs are the same across scenarios. Therefore we do not consider 

these costs in any of the scenarios. 

• Period of Analysis: 2009-2035. 

• The agency intends to provide ADS-B services where radar surveillance exists today 

(plus the Gulf of Mexico and areas in Alaska). We may in the future decide to 

implement ADS-B services in other areas. However, for the purpose of the 

regulatory impact analysis, we assume ADS-B surveillance and broadcast service will 

only be provided in areas where we have radar today, plus the Gulf and Juneau. 

• The ADS-B ground infrastructure and rules and procedures will be in place by 2013 

to support the following applications and services.

Services: 

• ATC Surveillance, and 

• FIS-B and TIS-B and ADS-R. 

Applications: 

o Final approach runway occupancy awareness, 

o Enhanced visual acquisition, 

o Enhanced visual approach, 

o Airport surface situational awareness, and 

o Conflict detection. 

 

• For the purposes of the regulatory impact analysis we assume that current separation 

standards will be maintained in radar surveillance airspace 6

. However, the FAA is 

investigating whether and to what extent ADS-B may allow the FAA to reduce 

separation standards. 

• Once ADS-B Out is implemented in the Gulf of Mexico and assuming a 5 mile 

separation standard is approved based on ADS-B Out data being available for 

separation purposes, the hourly capacity for sectors in the Houston CTA7/FIR8 is 

estimated to increase from 56 to 84 aircraft. This capacity is higher than that used in 

the NPRM because of additional routes and resectorization.9 Also, additional 

capacity at key airports in Mexico is expected to be complete soon and this will 

further alleviate the constraints built into the original capacity gains. 

 

6 With the implementation of ADS-B application of radar separation standards can now be applied in the 

non-radar airspace of the Gulf Of Mexico.

7

 Control Area: A control area is airspace wholly contained beyond the 12 mile limit whereby an ICAO 

state has been designated as the ATS authority for the control of air traffic. 

8

Flight Information Region: FIR’s designate regions for informational services only, not ATC control.

9

 Houston, Merida, and Monterrey Centers are close to finalizing a new RNP-10 route structure that will

add additional routes and capacity. Additionally, Houston and Merida Center are planning to resectorize 

airspace to more efficiently handle GOMEX traffic and increase capacity. 
11

• We assume that low-altitude operations over the Gulf of Mexico will be equipped 

with ADS-B Out because of a Memorandum of Agreement (MOA)10 signed by the 

FAA and helicopter operators, among others, and not because of the rule. The 

platform/helicopter companies have agreed to equip with appropriate avionics and 

equipment to take advantage of FAA enhancements to the communications, weather 

reporting, and surveillance capabilities outlined in the Agreement. The FAA will 

install ground equipment under the MOA. The MOA is to be renewed every five 

years. Therefore we do not include the costs and benefits of low altitude operations 

over the Gulf of Mexico as a function of the rule. 

• We assume there will be no self-separation. 

• While there may be some improvements in air traffic controller productivity with 

ADS-B Out, we are unable to quantify any improvement at this point. 

2.5 Definition Of Scope 

The ADS-B Out scenario analysis includes user costs incurred and benefits attained due 

to the final rule, as well as the costs incurred by the government to deploy and maintain a 

surveillance system. Costs and benefits that will occur without the rule are not included 

in the analysis. Costs that are incurred in anticipation of the rule are included, as are the 

benefits resulting from those expenditures. 

 3.0 Definition Of Approach 

In the following sections we present costs and benefits of the following scenarios: 

• A radar baseline scenario to represent current surveillance practice and a 

universe without the final rule, 

• ADS-B Out scenario to represent the final rule, 

• Multilateration as a surveillance alternative to ADS-B. 

We compare the costs and benefits of the ADS-B Out scenario with those of the baseline 

scenario to derive the incremental costs and benefits of ADS-B Out. The multilateration 

and baseline scenarios demonstrate an alternative to the ADS-B Out scenario. 

 

10 Memorandum of Agreement between Federal Aviation Administration, and Helicopter Association 

International, Platform/Helicopter companies, Platform Owners and Helicopter Operators to Enhance 

Communication, Weather and Surveillance Capabilities Gulf of Mexico. 
12

4.0 Scenarios Analyzed 

4.1 No-Rule Baseline Scenario 

4.1.1 Definition 

The baseline scenario is the no-rule scenario. Under this scenario we maintain the 

current radar-based surveillance system, and replace radar facilities once they wear out. 

This scenario assumes no expansion beyond the current Operational Evolution Plan 

(OEP). 

This section presents the cost of continuing full radar surveillance, which we compare to 

alternative scenarios. It assumes that all other components of the air traffic system 

remain constant over the scenarios and therefore these costs are not included. These 

components include runways, air traffic facilities and personnel. Also, we assume the 

cost of primary radars and precision runway monitoring systems will be constant across 

all scenarios and therefore we do not include them. 

4.1.2 Cost to Aircraft Operators of the Baseline Scenario 

There will be no direct cost to aircraft operators because they are already equipped to 

operate under the current radar-based system. 

 

4.1.3 Cost to FAA of Continuing Full Radar Surveillance Under the Baseline 

Scenario 

Surveillance

Airborne Surveillance Radar 

With this scenario we include the cost of continuing to support all classes of airborne 

secondary (beacon) radars (i.e. terminal and en route), and surface surveillance radar and 

the cost of replacing these radars at the end of their life cycles.11

The specific secondary surveillance radar includes BI4, BI5, BI6 and Mode S radar. The 

ASR-11 (primary/secondary surveillance radar) is a terminal air traffic control radar 

system that replaces current analog systems with new digital technology. These costs are 

also included. The ASR-11 system consists of two electronic subsystems: primary 

surveillance radar and secondary surveillance radar sometimes called the beacon. 

Surface Surveillance Radar 

Surface surveillance radar includes Airport Surface Detection Equipment (ASDE-3 and 

ASDE-X/3X). ASDE-3 provides radar surveillance of aircraft and airport surface 

vehicles at high activity airports. ASDE-3 is a primary radar for surface surveillance and 

 

11 Exhibit 300 Attachment 2, Business Case Analysis Report - Future Surveillance, JRC Phase 2A, pg. 35. 
13

is combined with the Airport Movement Area Safety System (AMASS ) software which 

provides conflict alerts based on ASDE-3 surveillance data. 

ASDE-X is a traffic management system that fuses information from radar, 

multilateration and other sensors, for the airport surface that provides seamless coverage 

and aircraft identification to air traffic controllers. The system uses a combination of 

surface movement radar and transponder multilateration sensors to display aircraft 

position labeled with flight call signs on an ATC tower display. The costs of ASDE-3, 

ASDE-X/3X and AMASS are included below. 

The cost to sustain and replace airborne and surface radar, assuming there is no ADS-B 

Out, would be $2.9 billion 12 ($1.2 billion when discounted by 7%) over the years 2009 to 

2035. The aggregate costs by year are presented in Table 2 below. 

Table 2 

Cost to Sustain and Replace Radar without ADS-B Out

2009K $ 

Source: FAA SBS Program and Terminal Surveillance 

 

12 The FAA developed these estimates internally. 
14

We assume the life cycle of the current ground-based surveillance systems is 20 years 

from their initial service.13

4.1.4 Benefits 

There is one benefit of the baseline scenario relative to the other alternatives, and that is 

certainty. We know it works with today’s margin of safety. 

4.2 ADS-B Out – The Final Rule (Preferred Alternative) 

4.2.1 Definition 

Under this scenario, aircraft operators will equip to meet the performance requirements of 

the rule. The FAA will make surveillance services available based on down-linked 

aircraft information. 

Costs presented in this section will be borne both by the FAA and industry. The FAA has 

been incurring costs to install ground facilities in order to provide ADS-B services. Costs 

incurred before 2009 are considered sunk costs and are not included in the FAA costs of 

the rule presented in this report. We assume industry will begin incurring costs in 2012. 

4.2.2 Requirements of the Rule 

The rule requires that no person may operate an aircraft in the following airspace unless 

that aircraft meets ADS-B Out performance requirements laid out in the final rule unless 

otherwise authorized or directed by air traffic control (ATC). 

• Class A, Class B, and Class C airspace areas, and in the Class E airspace at and 

above 10,000 ft MSL over the 48 contiguous United States and the District of 

Columbia, excluding the airspace at and below 2,500 ft above ground level 

(AGL). 

• U.S. airspace over the Gulf of Mexico, which is from the coastline of the United 

States out to 12 nautical miles at and above 3,000 feet MSL. 

• Within 30 nautical miles of an airport listed in 14 CFR, Part 91, Appendix D, 

from the surface upward to 10,000 feet MSL. 

However, the rule will permit aircraft not originally certificated with an engine-driven 

electrical system or not subsequently certified with such a system installed (such as a 

balloon or glider) to conduct operations without ADS-B Out in the airspace within 30 

nautical miles of an airport listed in Appendix D if the operations are conducted: (1) 

outside any Class B or Class C airspace area; and (2) below the altitude of the ceiling of a 

Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever 

is lower. 

 

13 Exhibit 300 Attachment, Business Case Analysis Report for Future Surveillance, JRC Phase 2A, pg. 5. 
15

While in the affected airspace, each person operating an aircraft equipped with ADS-B 

Out must operate this equipment at all times in the transmit mode, including when on the 

airport surface. 

4.2.3 Industry Estimation of ADS-B Equipage Costs

4.2.3.1 Introduction

Despite some significant changes between the NPRM and final rule language, there has 

been very little change in the total compliance costs. The seven percent present value 

base-case cost in the NPRM is $2.1 billion and in the final rule is $2.3 billion. 

This section starts with a discussion of the changes between the NPRM and final rule 

which affect the ADS-B Out estimated total costs. Next, we define a set of assumptions 

used to estimate ADS-B Out costs for equipping aircraft in the NAS. We then discuss the 

derivation of the future affected U.S. aircraft fleet. Next, we explain the methods used to 

estimate ADS-B Out equipage costs on transport category turbojet, turboprop and 

General Aviation (GA) aircraft. Lastly, we follow the ADS-B Out cost discussion with 

an estimate of the cost savings from learning curve efficiencies and additional 

maintenance and operating 14costs. 

Industry has commented that there remains some ambiguity related to the performance 

standards because the RTCA documents and associated Technical Standard Orders 

(TSOs) were not finalized. The final determination, at the time of this analysis, is 

unknown. These cost estimates are based on industry’s understanding of the performance 

characteristics discussed in RTCA meetings up to June 2009. Any significant changes in 

the performance characteristics could have an impact on the estimated ADS-B Out 

equipage costs provided in this analysis. 

NPRM and Final U.S. Fleet, Unit Costs, and Estimated Total Cost Changes

This section discusses changes between the NPRM and final rule which affect the ADS-B 

Out estimated costs. 

The three changes between the NPRM and final rule are: 

• U.S. fleet, 

• ADS-B Out unit cost, and 

• ADS-B Out estimated total cost. 

We estimated the changes to the U.S. fleet by comparing the number of aircraft during 

the NPRM and final rule analysis for the forecasted years of 2012 and 2025. In this final 

rule analysis, the large category turbojet fleet dropped 21.47 percent in 2012 and dropped 

12.47 percent in 2025 from that of the NPRM. The regional turboprop fleet dropped 

 

14 The operating costs consist of additional fuel burn caused by the weight of hardware mandated by this

final rule. 
16

17.15 percent in 2012 and 22.5 percent in 2025. These two declines occurred because of 

the downturn in the economy. Lastly, in this final rule analysis, the GA fleet rose onethird of a percentage in 2012 and another two percent in 2025. Table 3 details these 

results.

Table 3 

ADS-B Out unit costs for modern large category turbojet airplanes were similar for the 

NPRM and the final rule. For the older large category turbojet airplanes (DC-9/10, 737 

classics, A300, etc.) industry reported the final rule unit costs rose between 20-30 percent 

from those in the NPRM. One reason for the higher unit costs may be the need to recoup 

high fixed costs as many older airplanes have been parked or retired. To recoup their 

initial development costs and with fewer large category turbojet airplanes in the fleet, the 

unit costs rose. Another reason for the higher unit costs is that in the NPRM, our lower 

bound ADS-B Out equipage cost estimate should have included the cost of aircraft 

manufacturer’s service bulletins. 

Regional turboprop ADS-B Out unit costs between the NPRM and final rule were 

similar. The ADS-B Out unit costs for GA piston engine airplanes and rotorcraft dropped 

10-15 percent. With more ADS-B Out providers in the marketplace and the FAA 

relaxing the antenna diversity costs GA unit costs dropped. Lastly, ADS-B Out unit costs 

for GA turboprop and turbojet engine aircraft increased by 20-30 percent. We do not 

have a reason for this price increase. 

For the base-case scenario, ADS-B Out estimated final rule total costs for modern large 

category turbojet airplanes, relative to those in the NPRM, were up about 20 percent. 

Including the cost of manufacturer’s service bulletins in the lower bound estimates 

largely explains the increase in the base-case costs. Regional turboprops ADS-B Out 

final rule total costs dropped about 90% in the final rule because ADS-B Out costs will 

be prohibitive for analog/hybrid regional turboprop airplanes. The final rule assumed 

that analog/hybrid regional turboprop airplanes will be retired prior to the rule’s effective 

date. The cost to retire an analog/hybrid regional turboprop early is much less than 

retrofitting with ADS-B Out. Lastly, ADS-B Out estimated final rule total costs for GA 

turboprop and turbojet engine aircraft decreased from the NPRM by about 15 percent 

because of the drop in unit costs for GA piston engine airplanes. 
17

4.2.3.2 Equipage Cost Assumptions

The ADS-B Out equipage cost evaluation for this final rule makes the following 

assumptions: 

1. The base year is 2009. 

2. This final rule will be published in 2010. 

3. The analysis period extends for 27 years from 2009 through 2035. 

4. Compliance date is 2020. 

5. The ADS-B ground infrastructure will be in service and fully operational by 

2013.15

6. Manufacturers will invest in equipping newly delivered aircraft after a federal 

commitment of two appropriation-funding cycles. 

7. Manufacturers of large category turbojet or regional turboprop will start 

equipping ADS-B Out avionics on new aircraft deliveries in 201216 because it will 

be cheaper to purchase new aircraft with the avionics installed than to retrofit in 

2020. 

8. Large category turbojet and regional turboprop aircraft will start retrofitting active 

aircraft in 2013 in order to minimize costs associated with retrofitting the aircraft 

outside of its heavy maintenance cycle. All active large category turbojet and 

regional turboprop aircraft will be fully equipped with ADS-B Out by 2020. 

9. GA aircraft and Rotorcraft will start equipping new aircraft deliveries in 2012 and 

retrofitting active aircraft in 2013. All active GA and Rotorcraft aircraft will be 

fully equipped by 2020. 

10. All U.S.-certificated large category turbojet or regional turboprop passenger and 

cargo aircraft will equip with ADS-B Out because they will operate in the 

airspace required by this final rule. 

11. Active U.S.-certificated GA aircraft and Rotorcraft currently equipped with 

transponder equipment17 will equip with ADS-B Out equipment because they will 

operate in the final rule’s affected airspace. Operators of GA aircraft without 

ADS-B Out transponder equipment could request ATC deviations prior to 

operating in the airspace affected by this final rule. Table 4 shows the current 

number of U.S.-certificated GA aircraft and Rotorcraft with transponder 

equipment: 

 Table 4 

 

15 http://www.faa.gov/news/speeches/news_story.cfm?newsId=7649 

16 2013 is dependent on the appropriate funds being available from assumption 6. 

17 2006 FAA General Aviation and Air Taxi Survey. 
18

12. Experimental, Sport and Other aircraft will not equip with ADS Out. Operators 

of these aircraft could request ATC deviations prior to operating in the airspace 

affected by this final rule.18

 

13. Equipment costs are based on catalog pricing. 

14. The analog/hybrid regional turboprop airplanes will not select an upgrade because 

the upgrade cost will be prohibitive. 

15. We accept industry’s performance-based cost estimates. 

16. The FAA assumes that only 20% of analog large category transport turbojet 

airplanes will choose to equip with ADS-B Out capability because the upgrade 

cost will be prohibitive. 

4.2.3.3 Fleet Discussion

This section discusses the fleets that will need to comply with the final rule in the future. 

The discussion draws upon forecasts covering the period from 2009 through 2025, as 

well as extended forecasts for 2026-2035. The section begins with a discussion of the 

expected affected airplanes, and then discusses in detail the derivation of the future 

affected fleet of large category turbojet, regional turboprop, general aviation and 

rotorcraft. 

Large Category Turbojet Aircraft

The 2009 published FAA turbojet fleet annual unit forecast for 2009 to 2025 forms the 

basis for estimating the number of affected large category turbojet aircraft. This forecast 

covers wide body, narrow body and regional turbojet aircraft operated by US-certificated 

carriers and includes new deliveries and retirements. A bottom-up forecast was 

developed for each aircraft group and then summed to arrive at an aggregate. To estimate 

the large category turbojet fleet after 2025, we use the FAA long-term passenger turbojet 

fleet annual unit forecast for 2025-2035. These forecasts project the population of large 

category and regional turbojets to nearly double in the analysis interval. 

Regional Turboprop Aircraft

The 2009 published FAA turboprop fleet annual unit forecast for 2009 to 202519 forms 

the basis for estimating the number of affected regional turboprop aircraft. This forecast 

categorizes regional turboprop aircraft by the number of airplane seats, operated by UScertificated carriers, and includes new deliveries and retirements. A bottom-up forecast 

was developed for each aircraft group by seat and then summed to arrive at an aggregate. 

 

18 ibid. 

19 FAA Aerospace Forecast 2009-2025, Table 21 & 21. 
19

We estimated the regional turboprop fleet from 2026-2035 by using the 10-year average 

percent change from the 2010-2020 period. The FAA projects that the number of 

regional turboprop aircraft to decline about five percent from 2009 to 2035.20

General Aviation Aircraft

The 2009 published FAA general aviation fleet annual unit forecast for 2009 to 2025 

forms the basis for estimating the number of affected general aviation aircraft. These 

forecasts cover fixed wing, rotorcraft, experimental, sport and other general aviation 

aircraft operated by US certificated carriers and includes new deliveries and retirements. 

We extended the general aviation fleet from 2026-2035 by using the 10-year average 

percent change from the 2010-2020 period.21 We project the number of fixed wing 

general aviation aircraft will increase approximately 13 percent and the number of 

rotorcraft to nearly double. 

4.2.3.4 Equipment Specifications

This section describes the new standards used herein to estimate the compliance cost for

ADS-B Out avionics this final rule requires. The ADS-B Out system will consist of a 

position source, an ADS-B transmitter, altimetry sensors, flight crew interfaces and other 

avionics. This equipment will require integration to correctly transmit the ADS-B Out 

data. 

 

In the United States, two different datalinks have been adopted for ADS-B Out: 

o 1090 MHz Extended Squitter (1090 ES), and 

o 978 MHz Universal Access Transceiver (978 UAT). 

TSO-C166b defines the equipment requirements for 1090ES ADS-B equipment. TSOC154c defines the equipment requirements for UAT ADS-B equipment. Future versions 

of these TSO’s will be acceptable for rule compliance however, previous versions of the 

TSO’s are not acceptable to operate in airspace defined by 14 CFR 91.225. 

This is a performance-based rule, and thus there is no equipment requirement for the 

position source. Any position source meeting the accuracy and integrity requirements 

described in 14 CFR 91.227 is acceptable. Based on responses from industry, three types 

of position sources have been evaluated for costs including Global Navigation Satellite 

System (GNSS) equipment compliant with Technical Standard Order (TSO) C145a or 

TSO-146a, GNSS equipment compliant with TSO-C129a, and GNSS equipment 

compliant with TSO-C196. 

 

20 FAA Aerospace Forecast 2009-2025, Table 26. “U.S. Regional Carriers Passenger Aircraft”. 

21 FAA Aerospace Forecast 2009-2025, Table 27. “Active General Aviation and Air Taxi Aircraft”. 
20

The minimum broadcast message element set for aircraft equipage for ADS-B Out used 

in the cost estimates defined below.22

Each aircraft must broadcast the following information, as defined in TSO–C166b or 

TCS–C154c. The pilot must enter information for message elements listed in (7) through 

(10) of this section during the appropriate phase of flight: 

 (1) The length and width of the aircraft; 

 (2) An indication of the aircraft’s lateral and longitudinal position; 

 (3) An indication of the aircraft’s barometric pressure altitude; 

 (4) An indication of the aircraft’s velocity; 

 (5) An indication if TCAS II or ACAS is installed and operating in a mode that can 

generate resolution advisory alerts; 

 (6) If an operable TCAS II or ACAS is installed, an indication if a resolution advisory is 

in effect; 

 (7) An indication of the Mode 3/A transponder code specified by ATC; 

 (8) An indication of the aircraft’s call sign that is submitted on the flight plan, or the 

aircraft’s registration number; 

 (9) An indication if the flight crew has identified an emergency, radio communication 

failure, or unlawful interference; 

 (10) An indication of the aircraft’s “IDENT” to ATC; 

 (11) An indication of the aircraft assigned ICAO 24-bit address; 

 (12) An indication of the aircraft’s emitter category; 

 (13) An indication of whether an ADS–B In capability is installed; 

 (14) An indication of the aircraft’s geometric altitude; 

 (15) An indication of the Navigation Accuracy Category for Position (NACP); 

 (16) An indication of the Navigation Accuracy Category for Velocity (NACV); 

 (17) An indication of the Navigation Integrity Category (NIC); 

 (18) An indication of the System Design Assurance (SDA); and 

 (19) An indication of the Source Integrity Level (SIL). 

4.2.3.5 ADS-B Out Equipage Cost Estimate

We contacted manufacturers, industry associations, and ADS-B equipage providers and 

requested estimates for ADS-B equipage and installation costs. We requested estimates 

of airborne installation costs, by aircraft model, for the output parameters listed in the 

Equipment Specifications section. The manufacturers and industry associations we 

contacted were: 

• Airbus, 

• Aircraft Owners and Pilots Association, 

• Aviation Communication and Surveillance Systems, 

• Boeing, 

• Free Flight Systems, 

• Garmin, 

 

22 §91.227 
21

• General Aviation Manufacturers Association, 

• Honeywell, 

• National Business Aviation Association, 

• Raytheon, and 

• Rockwell. 

Not every manufacturer or ADS-B equipage provider we contacted responded to our 

ADS-B cost request. For those that did respond, each used a different methodology to 

develop their cost estimates. The differences in methodologies could be partially 

responsible for the variance in our cost estimates. These industry representatives have 

been actively involved in the performance requirements process. They are well aware of 

current and potential changes to the performance requirements. 

For analytical purposes, we grouped aircraft types into classes with similar avionics 

architecture. The aircraft equipment classes potentially subject to the ADS-B Out 

performance requirements are: 

 

• Large Category Turbojet Airplanes 

o Classic – B-707, B-727, B-737-100/200, B-747-100/200/300, A-300/310, 

DC-8, DC-9, DC-10, MD-80/81/82/83 and L-1011.

o Neo-Classic – B-757-200/300, B-767/200/300, B-737-300/400/500/600, 

B-747-400, MD-11, MD-87/87/90 and A-319/320/321/340. 

o Modern – B-777, B-737-700/800/900, B-717, B-767-400, A318/330/350/380. 

o New production aircraft. 

• Regional Aircraft

o Jet – BAE-146, RJ70 and RJ85, CRJ100/200/440/700, Do328JET, ERJ135/130/145/170/175/190/195, and F28/50/70/100. 

o Turboprop – ATR42/72, Beech 99/1900, DHC-8, Do328, EMB-120, 

Jetstream J31/41/42, L-188, Metro Saab 340 and Shorts 330/360. 

o New production aircraft. 

• GA

o Single engine Piston - Airplanes with a maximum takeoff weight under 

12,500 pounds. 

o Multi engine Piston – Piston powered airplanes with more than one 

engine. 

o Turboprop – Single and multi-engine turboprop airplanes. 

o Turbojet - Single and multi-engine jet airplanes. 

o Rotorcraft - Single and multi-engine helicopters. 

o New production aircraft. 
22

For each aircraft class listed above, we categorized the aircraft’s ADS-B equipage status 

into three distinct groups. 

• Not Equipped – aircraft is not equipped for ADS-B Out functionality and 

requires major avionics component additions or equipment to make it capable 

of transmitting ADS-B Out information. 

• Latent – aircraft that can be made capable of ADS-B Out operation by adding 

broadcast link capabilities or interfacing to existing Global Navigation 

Satellite System (GNSS) equipment. 

• Equipped – aircraft that can be ADS-B Out capable with a software update. 

We provide a low and high range of cost estimates associated with various operational 

and technical issues. The dollar value ranges consist of a wide variety of avionics within 

each aircraft group. The aircraft architecture within each equipment group can vary, 

causing different carriage, labor and wiring requirements for the installation of ADS-B 

Out equipment. Volume discounting versus single line purchasing also affects the dollar 

value ranges. 

This rule does not require specific equipment; rather the equipment must meet certain 

performance specifications. Since this is a performance-based rule, industry may choose 

how to meet that performance standard with either a low or high cost of compliance 

alternative. A minimum equipment set that represents the expected minimum compliance 

may cost more in the future because it lacks upward compatibility. The low end estimate 

may include a minimum equipment option, a minor software upgrade, an Original 

Equipment Manufacturer (OEM) option change or a ground-based backup solution. The 

high end estimate includes the airborne design that integrates both ADS-B Out capability 

and provisions for future ADS-B and may also include a new or upgraded position 

source, a new installation or upgraded avionics system necessary to comply with the rule, 

or a system that will provide a cost-effective option for manufacturers and operators to 

integrate future GNSS 23 upgrades.24 The base-case estimate represents a fleet where 

about half of the airplanes need only the low cost solutions and the other half of the 

airplanes are outfitted with the more expensive upgrades. 

We did not include ADS-B Out operator training costs because we assumed the costs to 

be minimal.25 

 

23 Future upgrades of GNSS might include greater availability or accuracy of the signals. These types of 

upgrades may enable additional applications, improved use of existing applications (such as increased 

efficiency or availability of ADS-B enabled operations) or a reduction in aircraft separation; but what those 

applications are will be difficult to ascertain at this point. Generically speaking, an incremental 

improvement in the performance of the position source could allow us to incrementally improve our air 

traffic control procedures and thereby improve efficiency and capacity. 

24 Even though this scenario is designed to look at ADS-B Out adoption in isolation, in practice the 

availability of equipment offering only ADS-B Out technology may be limited. Therefore, in practice the 

cost of adopting ADS-B Out may include the voluntary or unavoidable purchase of some functionality not

strictly required by the ADS-B Out regulation. 

25 The FAA determined training costs will be minimal because no significant training will be required. 
23

Large Category and Regional Turbojet ADS-B Out Equipment and Fuel Burn Costs

This section first covers the estimated ADS-B Out equipage costs plus the cost of 

additional fuel burn to large category and regional turbojets due to the added weight of 

ADS-B Out equipment. 

The manufacturers provided us with ADS-B Out equipage costs estimates either by 

equipment type or for the following equipage types:

• Classic, 

• Neo-classic, and 

• Modern. 

The manufacturers who provided costs by equipment groups either estimated a total cost 

of ADS-B Out hardware, included the costs of installation kits and installation, or 

provided detailed breakdowns of the various costs. 

The ADS-B Out equipment costs for large category and regional turbojet airplanes are 

straightforward. Industry provided ADS-B Out unit costs by the equipment class units 

discussed in the Fleet Discussion section. The FAA assumes that only 20% of analog air 

transport turbojet airplanes will choose to equip with ADS-B Out capability because the 

upgrade cost will be prohibitive. 

To satisfy the manufacturers’ request to keep individual aircraft pricing confidential, we 

calculated a low and high range for unit costs by dividing the total low and high cost 

estimate by the number of affected large category turbojet airplanes. This range includes 

cost for all hardware and installation. The unit costs for large category turbojet airplanes 

range from about $19,000 to $1.7 million. The dollar value ranges consist of a wide 

variety of avionics within each aircraft group. The avionic costs vary based on the state 

of an aircraft’s architecture, volume discounting, a minor software upgrade versus a 

major transponder or position source replacement, or an operator’s decision to install 

avionics that take advantage of future GNSS upgrades.

26 We note that in the NPRM, our 

lower bound ADS-B Out cost estimate should have included the cost of aircraft 

manufacturer’s service bulletins. 

For 2012 through 2035 we estimated the newly delivered turbojet costs by multiplying 

unit costs by the annual number of new aircraft deliveries. Based on the FAA turbojet 

forecast, the retrofitting of aircraft in the current operating fleet as of 2013 was assumed 

to be uniformly distributed over 2013 through 2019. For each of the seven years, ADS-B 

Out retrofit costs for turbojets were estimated by multiplying unit costs by one-seventh of 

 

26The result of these different compliance decisions was a wide range of cost estimates. 
24

the active 2013 fleet. The new turbojet aircraft deliveries from 2012-2035 were assumed 

to have avionics component additions or equipment to make them capable of transmitting 

ADS-B Out information. The incremental costs we estimated for these new deliveries 

included either minor additional avionic or software upgrade. 

The total cost to equip active and newly delivered turbojets from 2012 through 2035 

ranges from about $1.0 billion to $2.4 billion with a base-case average of $1.7 billion. 

Table 5 summarizes the range estimate in constant dollars, and at three and seven percent 

present value rate for large category and regional turbojets.27

Table 5 

The ADS-B Out equipage weight ranges from a low of three pounds to a high of 12 

pounds.28 The base-case assumes 7.5 pounds of added weight per turbojet aircraft. We 

used these weights to calculate a cost range for the average additional fuel burn for 

turbojet airplanes operating during the analysis period. 

Given that fuel burn range, we used the methodology for incremental fuel burn, per 

flight, per pound of additional weight for turbojet aircraft from our published economic 

values.29 We obtained the average annual cycles per turbojet aircraft from BACK 

Aviation Solutions. The gallons of additional fuel burn equals the incremental fuel burn 

per flight, per pound, multiplied by the average annual cycles (flights) multiplied by the 

low, base-case and high added weight estimates. Lastly, we multiply the estimated 

additional gallons of fuel burn by the jet fuel price forecast30 to obtain a range of the 

annual cost of the added weight to the U.S. operated turbojet fleet. 

A range of the estimated added fuel burn costs for the installation of ADS-B Out in US 

operated large category and regional turbojets for 2009 - 2035 is shown in the Table 6. 

 

27 Discussions with ADS-B Out providers. See section 4.2.3.5 ADS-B Out Equipage Cost Estimate for 

further detail. 

28The manufacturer mentioned the worst case could be up to 200 additional pounds of weight for a 

minimally equipped, analog aircraft attempting to be fully compliant with future navigation and 

surveillance upgrades. It is highly unlikely that anyone will choose to invest the money to upgrade their 

aircraft to that level of capability when it is likely to be retired before an operator could recover the 

investment. 

29 “Economic Values for FAA Investment and Regulatory Decisions, A Guide”, December 31, 2004. 

30 FAA Aerospace Forecast 2009-2025, Table 18. “U.S. MAINLINE AIR CARRIER FORECAST 

ASSUMPTIONS – Jet Fuel Prices”. 
25

Table 6 

Regional Turboprop Aircraft ADS-B Out Equipment Costs

This section explains how the regional turboprop aircraft ADS-B Out equipment costs 

were estimated. We also explain why there is no additional fuel burn expense and why 

the costs to regional turboprops are lower than those estimated in the NPRM. 

The manufacturers who responded with regional turboprop equipage costs provided us 

with costs estimates for the following equipage types: 

• Saab 340, 

• ATR, 

• Regional Turboprop, and 

• New Production Turboprop. 

For these equipment groupings they provided the following detailed cost estimates by 

equipment class: 

• Transponder and GPS Status, 

• GNSS Equipage Cost, 

• Datalink Equipage Cost, 

• Installation Cost, 

• Currently Installed Transponder upgrade cost, 

• Installation Kit Cost, or 

• Individual Component Cost. 
26

The ADS-B Out equipment costs for regional turboprop airplanes are straightforward. 

Industry provided ADS-B Out unit costs by airplane equipment class units discussed in 

the Fleet Discussion section above. 

To satisfy the manufacturers’ request to keep individual aircraft pricing confidential, we 

calculated a low and high range for unit costs by dividing the total low and high cost 

estimate by the number of affected regional turboprop airplanes. This range includes cost 

for all hardware and installation. The unit costs for regional turboprop airplanes range 

from about $12,000 to $466,800. The dollar value ranges consist of a wide variety of 

avionics within each aircraft group. The avionic costs vary based on the state of an 

aircraft’s architecture, volume discounting, a minor software upgrade versus a major 

transponder or position source replacement, or an operator’s decision to install avionics 

that take advantage of future GNSS upgrades. 

It is unlikely that the analog/hybrid regional turboprop airplanes will select an upgrade 

because the upgrade cost will be prohibitive. We consulted with industry about the active 

analog/hybrid regional turboprop fleet and were informed that these turboprops operated 

with less than 40 seats. Therefore, for the final rule, we assume active analog/hybrid 

regional turboprop aircraft, under 40 seats, will not upgrade with ADS-B Out and will 

retire early. 

We consulted with appraisal companies31 and determined the annual residual value of 

regional turboprop, under 40 seats, depreciate between seven to 14 percent, with a basecase of 10 percent. We obtained the current value of regional turboprop aircraft under 40 

seats from our published economic values,32 applied the residual value depreciation and 

included the costs of early retirement of the analog/hybrid regional turboprops to the 

costs of retrofitting and equipping regional turboprops for this final rule. 

These costs included the early retirement of active analog/hybrid regional turboprop 

airplanes and the equipage of active and new production regional turboprop aircraft. The 

active aircraft in 2013, from the FAA turboprop forecast, were uniformly distributed over 

2013 through 2019. For each of the seven years, ADS-B Out costs for regional turbojets 

were estimated by multiplying unit costs by one-seventh of the active 2013 fleet. 

The manufacturers did not provide an equipage weight for ADS-B Out on regional 

turboprops. In the NPRM, we assumed the weight for an ADS-B Out transponder on 

regional turboprop aircraft will be about the same as weight as existing transponders and 

therefore the change will be negligible and there will be no additional weight or fuel burn 

costs. We received no comments about this assumption. 

The total cost to equip and retire certain regional turboprop aircraft with ADS-B Out 

from 2012 through 2035 ranges from about $7.5 million to almost $41.6 million with a 

 

31 Avitas, ACI 

32 “Economic Values for FAA Investment and Regulatory Decisions, A Guide”, December 31, 2004. 
27

base-case average of nearly $24.6 million. Table 7 summarizes the range estimate of 

constant dollars, three and seven percent present value rate.33

Table 7 

General Aviation Aircraft ADS-B Out Equipment Costs

This section explains how the final rule’s general aviation aircraft base-case ADS-B Out 

equipment costs of $2.7 billion were estimated. We used general aviation industry 

equipment cost estimates, the FAA fleet forecast, and assumptions about the current fleet 

equipped with a transponder. We first discuss the industry cost estimates received. We 

then discuss our adjustments to the number of affected helicopters covered by the 

Memorandum of Agreement (MOA) between the FAA and the helicopter association 

(HAI) and operators. Once the foundation for the general aviation fleet is set, the ADS-B 

Out cost estimation is straightforward; multiply the number of affected general aviation 

aircraft by unit costs. 

The manufacturers provided GA ADS-B Out equipage costs for the following equipage 

types: 

• Single Engine Piston, 

• Multi Engine Piston, 

• Turbo Prop, 

• Turbo Jet, 

• Rotorcraft, and 

• Experimental. 

 

33 Discussions with ADS-B Out providers. See section 4.2.3.5 ADS-B Out Equipage Cost Estimate for 

further detail. 
28

For those equipment groups they provided costs for the following categories: 

• Equipment Cost, 

• Fleet Size, 

• Installation Time, 

• Installation Hourly Cost, 

• Total Cost, and 

• Total Fleet Cost. 

There is currently a signed Memorandum of Agreement (MOA) between the FAA, the 

HAI, and helicopter operators for operation in the Gulf of Mexico. In this agreement, 

helicopter operators in the Gulf of Mexico agree to equip with "appropriate avionics and 

equipment to take advantage of FAA enhancements to the communications, weather 

reporting, and surveillance capabilities". The MOA has not yet been implemented, but 

with a compliance date of 2020 in the final rule, it is likely the helicopter operators will 

equip to be in accordance with the MOA before the required compliance date of this final 

rule. For this analysis, we are assuming that 9% of the active and newly delivered 

helicopter fleet will be operating in the Gulf of Mexico with ADS-B Out equipment 

voluntarily installed.34 Therefore, we reason that this portion of the industry will equip 

without the rule and the compliance costs for the Gulf of Mexico-operated (nine percent 

of total rotorcraft fleet) rotorcraft will equal zero. 

To satisfy the manufacturers’ request to keep individual aircraft pricing confidential, we 

calculated a low and high range for unit costs by dividing the total low and high cost 

estimate by the number of affected general aviation airplanes. This range includes cost 

for all hardware and installation. The unit costs for general aviation aircraft range from 

about $5,000 to $20,000. We note that the unit costs for GA aircraft are less than those 

used in the NPRM because there are more ADS-B manufactures in the market place. The 

dollar value ranges consist of a wide variety of avionics within each aircraft group. The 

avionic costs vary based on the state of an aircraft’s architecture, volume discounting, a 

minor software upgrade versus a major transponder or position source replacement, or an 

operator’s decision to install avionics that take advantage of future GNSS upgrades. 

The methodology to estimate ADS-B Out equipment costs for the GA fleet is based on 

the 2006 FAA General Aviation and Air Taxi Survey,35 and we calculated the percentage 

of U.S. certificated GA aircraft and rotorcraft currently equipped with transponder 

equipment. We applied this percentage to the GA fleet from the Fleet Discussion section 

above to determine the number of newly delivered and active GA aircraft that will equip 

with ADS-B Out. 

 

34Based on conversations with the Helicopter Association International (HAI) and FAA. 

35http://www.faa.gov/data_statistics/aviation_data_statistics/general_aviation/ 
29

For 2012 through 2035 we estimated the newly delivered GA aircraft costs by 

multiplying unit costs by the annual number of new GA aircraft deliveries. The 

retrofitting of aircraft in the current operating fleet as of 2013, from the FAA GA 

forecast, was assumed to be uniformly distributed over 2013 through 2019. For each of 

the seven years, ADS-B Out retrofit costs, for active GA aircraft was estimated by 

multiplying unit costs by one-seventh of the active 2013 fleet. 

The total cost to equip GA aircraft from 2012 through 2035 ranges from about $1.6 

billion to about $3.9 billion with a base-case average of $2.7 billion. Table 8 summarizes 

the range estimate of constant dollars, three and seven percent present value rate.

Table 8 

Table 9 shows the distribution of the constant GA costs by GA engine, turbojet and 

rotorcraft aircraft. 

Table 9 

In the NPRM, we assumed the weight for an ADS-B Out transponder, on a GA aircraft, 

will be about the same as weight existing transponders and therefore the change will be 

negligible and there will be no additional weight or fuel burn costs. We requested 

comments from industry on this assumption. Industry informed us the ADS-B Out 

equipage weight ranges from a low of three pounds to a high of five pounds.36 The basecase assumes four pounds of added weight per turbojet aircraft. We accept those 

comments and used these weights to calculate a cost range for the average additional fuel 

burn for GA aircraft operating during the analysis period. 

 

36The manufacturer mentioned the worst case could be up to 200 additional pounds of weight for a 

minimally equipped, analog aircraft attempting to be fully compliant with future navigation and 

surveillance upgrades. It is highly unlikely that anyone will choose to invest the money to upgrade their 

aircraft to that level of capability when it is likely to be retired before an operator could recover the 

investment. 
30

We obtained the incremental fuel burn, per flight, per pound of additional weight and 

utilization for GA aircraft from our published economic values.37 The gallons of 

additional fuel burn equals the incremental fuel burn per hour, per pound, multiplied by 

the average annual utilization, multiplied by the low, base-case and high added weight 

estimates. Lastly, we multiply this product by the jet fuel forecast38 to obtain a range of 

the annual cost of the added weight to the U.S. operated GA fleet. 

A range of the estimated added fuel burn costs for the installation of ADS-B Out in US 

operated GA fleet for 2009 - 2035 is shown in the Table 10. 

Table 10 

4.2.3.6 ADS-B In –Turbojet, Turboprop and GA Aircraft Costs are Premature

An example of an ADS-B In application is United Parcel Service (UPS) and FAA 

working together to implement a system at Louisville, Kentucky (SDF) airport to 

increase airport capacity and efficiency while significantly reducing vulnerability to 

runway incursion events, both in terms of events and the damage sustained should an 

event occur. UPS and FAA have developed a concept to create a system that will use 

ADS-B surveillance at SDF, along with a Surface Management System and a scheduling 

and sequencing system to meet the demands of the future. UPS is also installing a 

Cockpit Display of traffic Information (CDTI) for certain proposed operational 

application such as merging and spacing, Surface Area Moving Management, and CDTI 

Assisted Visual Spacing capability in all of its B-757, B-767, B-747-400, A-300, and 

MD-11 fleets. 

We have attempted to estimate the costs for equipping aircraft with the avionics 

necessary to perform the initial ADS-B In applications described in this rule. At the time 

of this analysis, there were no FAA specifications for ADS-B In. The FAA anticipates 

completing a TSO that outlines standards for the initial ADS-B In applications by the end 

of fiscal year 2010. 

 

37 “Economic Values for FAA Investment and Regulatory Decisions, A Guide”, December 31, 2004. 

38 FAA Aerospace Forecast 2009-2025, Table 18. “U.S. MAINLINE AIR CARRIER FORECAST 

ASSUMPTIONS – Jet Fuel Prices”. 
31

4.2.3.7 Learning Curve Efficiencies

In 1939,39 T.P. Wright40 recognized the repetition of the same operation results in 

reduced efforts expended on that operation.41 Direct labor man-hours necessary to 

complete a unit of production will decrease by a constant percentage each time the 

production quantity is doubled. Learning or cost improvement occur due to workers 

increases in efficiency and implicit training. T.P. Wright found that an 80% learning 

efficiency has been a common occurrence in aircraft production. This section will 

estimate the learning efficiency42 cost savings for the installation of ADS-B Out 

equipment in turbojet, turboprop and GA aircrafts for an 80% learning efficiency.43

We estimate the labor hour efficiencies for the production and installation of ADS-B Out 

on the xth set of airplanes (Yx) as follows: 

Yx = a * xb

Where Yx = cumulative average time to produce and install a number of units, 

 a = time to produce and install the first unit by equipment group, 

 x = the sequential period of production and installation time, 

 b = index of learning ( b = log (learning curve) / log (2)), 

 learning curve = 80. 

In order to estimate the learning efficiency savings for providing and installing ADS-B 

Out on newly delivered and active aircraft, we used the industry-provided hours and 

Department of Labor44 hourly labor rates, per equipment group, required to produce and 

install ADS-B Out. The learning efficiencies begin in 2013 and extend to 2035, the end 

of the analysis period. Table 11 shows the hours and hourly labor rates, per equipment 

group, required to install ADS-B Out. 

 

39 The learning curve effect states that the more times a task has been performed, the less time will be

required on each subsequent iteration. This relationship was first quantified in 1936 at Wright-Patterson Air 

Force Base in the United States. In the late 1960s Bruce Henderson of the Boston Consulting Group 

(BCG) began to emphasize the implications of the experience curve for strategy and in 1972 published 

“Perspectives on Experience”. This book explains the experience curve effect, which is an observation that 

the costs of virtually every class of products decline by a constant and predictable percentage over time, as 

a function of experience. Recently, in 1991, Charles J. Teplitz published the “The Learning Curve 

Deskbook” which provides a basic understanding of the underlying theory of learning curves, as well as 

ready access to commonly used learning curve models, formulas, and tables. 

40 Theodore Paul Wright (May 25, 1895 – August 21, 1970) was a U.S. aeronautical engineer, educator, 

and served as administrator of the Civil Aeronautics Administration during 1944 – 1948. 

41“American Methods of Aircraft Production”, T.P. Wright, 1939. 

42The rate of learning may be higher than the 80% presented in this regulatory impact analysis. If so, the 

learning efficiencies may be under estimated. 

4380% learning has been a common occurrence for over 65 years since T.P Wright recognized the concept 

in 1939. 

44 Department of Labor, Bureau of Labor Statistics. Occupational Employment and Wages 
32

Table 11 

Next we summed the new aircraft deliveries for 2012 with the new deliveries and the 

one-seventh of the active fleet from 2013 to define the first period of our sequential 

periods of installation time, x. Our second period of installation time was defined as 

2014, our third as 2015 and so on until 2035. The follow graph presents the 80% 

learning curve for a 30 hour time to produce and install the sequential units of newly 

delivered and active aircraft. 

For each sequential period, we multiplied the number of ADS-B Out installations, by the 

labor cost, by the labor hours a * xb

.

 No efficiencies occur in year one because the 

learning has not yet begun. The majority of the learning efficiencies occur from 2014-

2019, because during this period the active fleet was retrofitted. 

Lastly, these labor learning efficiencies were subtracted from the labor costs we 

estimated in ADS-B Out Equipage Cost Estimate section. 

Table 12 details the total ADS-B Out costs of this final rule, including learning 

efficiencies for labor, for large category turbojet aircraft in the 2009-2035 analysis 

interval. Learning curve efficiencies lowers the seven percent present value base-case 

estimate by approximately $100 million. When we queried industry for ADS-B costs 

Efficiencies for 30 Hours

0

5

10

15

20

25

30

35

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Sequential Years

Hours
33

associated with this final rule, the ADS-B out hardware costs resulted in a wide range 

with installation labor costs constant across all the cost ranges below. 

Table 12 

Table 13 details the total ADS-B Out costs of this final rule, including learning 

efficiencies for labor, for regional turboprop aircraft in the 2009-2035 analysis interval. 

Table 13 

Table 14 details the total ADS-B Out costs of this final rule, including learning 

efficiencies for labor, for GA aircraft in the 2009-2035 analysis interval. 

Table 14 

4.2.3.8 ADS-B Out Maintenance Costs

In this section we discuss our assumptions and cost estimates for the maintenance and 

replacement intervals for the ADS-B Out equipment required by this final rule. As we 

received no comments on our modeling approach, the final rule is using the same 

approach to estimate maintenance and replacement costs as the NPRM. For the 

maintenance interval we use Mean Time To Repair (MTTR). For the replacement 

interval we use Mean Time Between Failure (MTBF). 
34

Industry provided us with MTTR and MTBF times, in hours, for most large category 

turboprop and regional turboprop aircraft types. For other aircraft types we assumed 

MTTR and MTBF will be the same as an equivalent aircraft group and class. We used 

the individual original purchase prices provided by industry for cost of replacement 

avionics due to failure. For MTTR, we estimated the repair costs at three percent of the 

purchase price. We also assumed these replacement and repairs will occur at the aircraft 

scheduled maintenance checks and therefore will not generate aircraft downtime costs. 

We assumed minimal incremental MTTR and MTBF costs for neo-classic and modern 

turbojet aircraft that could be made capable of ADS-B Out operation by adding data link 

capabilities, interfacing to existing Global Navigation Satellite System (GNSS) 

equipment, or that may need additional programming updates that could be upgraded at 

nearly no cost. These neo-classic and modern turbojet airplanes currently have 

transponders and position sources, so there is nearly no future incremental replacement or 

maintenance costs with this final rule. 

We obtained estimates for the annual average hours flown by aircraft group from BACK 

Aviation Solutions. Table 15 shows the annual average hours by aircraft group estimates 

we will use to estimate when MTBF and MTTR will occur. 

Table 15 

We then estimated the replacement and maintenance interval, in years, for ADS-B Out 

equipment based on the average annual number of hours that aircraft operate. Table 16 

shows the intervals, in years, for replacement and maintenance of ADS-B Out equipment. 

AIRCRAFT EQUIPMENT

BODY CLASSIFICATION AVERAGE

Narrow Body J2 2,857

Narrow Body J3 1,677

Narrow Body J4 1,500

Regional Jets J2 2,003

Widebody J2 3,101

Widebody J3 2,529

Widebody J4 3,307

Turboprops TP, TP4 1,305

AVERAGE ANNUAL NUMBER OF HOURS FLOWN
35

Table 16 

Tables 17 and 18 shows the estimated maintenance and replacement costs for ADS-B Out 

equipage in turbojet and turboprop aircraft during the 2009-2035 analysis interval. 

Table 17 

Table 18 

The manufacturers and vendors did not provide us with MTBF or MTTR details for GA 

aircraft. However, based on Table 1.7 of the 2006 FAA General Aviation and Air Taxi 

Survey, the following annual average hours flown by aircraft group is calculated as: 

Table 19 

The reason we assumed GA aircraft will not incur maintenance or repair cost is these 

aircraft have low utilization rates relative to commercial airplanes. Industry provided 

MultiMode Receiver Narrow J2 NarrowJ3 Narrow J4 Regional WideJ2 WideJ3 WideJ4 TP

Analog MTBF 7 12 13 10 6 8 6 15

Digital MTBF 9 15 17 12 8 10 8 19

Analog MTTR 3 6 7 5 3 4 3 8

Digital MTTR 7 12 13 10 6 8 6 15

 Replacement and Maintenance Intervals In Years 
36

MTBF and MTTR hours for Large Category and Regional Turbojet and Regional 

Turboprop aircraft in order to estimate ADS-B Out intervals. We assumed the Large 

Category and Regional Turbojet and Regional Turboprop aircraft MTBF and MTTR data 

will apply to the GA aircraft. The hourly MTBF estimates ranged from 20,000 to 45,000 

hours depending on aircraft group. Because GA aircraft operate fewer hours than 

transport category aircraft, even at the bottom end of the range, the minimum 

replacement of an ADS-B Out unit on a GA aircraft will occur well beyond the analysis 

interval. Similarly, MTTR ranges fell between 10,000 to 15,000 hours, which again will 

occur outside of the analysis interval for a GA aircraft. Thus, for the GA aircraft 

analyzed within the analysis interval, the MTBF and MTTR costs will be minimal. 

In the next section, these additional ADS-B Out equipage maintenance and replacement 

costs will be summed with the costs of additional fuel burn, purchasing and installing 

ADS-B Out, and upgrading avionic systems. 

4.2.3.9 ADS-B Out Aircraft Equipage Cost Summary

The following tables summarize the range estimate of constant dollars, three and seven 

percent present value costs to industry over the 2009–2035 analysis interval. The low 

cost estimates represent the minimal compliance cost outcome or a programming 

compliance change. The high cost estimates means a transponder or position source 

replacement or an operator’s decision to install avionics that take advantage of future 

GNSS upgrades. The base case estimate represents a fleet where about half the airplanes 

are easily upgraded for future GNSS products and the other half meet the minimum 

requirements of the final rule. 

These cost estimates include ADS-B Out equipage, installation, maintenance, additional 

fuel burn costs and learning curve savings. Based on our MTTR and MTBF assumptions 

stated earlier, maintenance and replacement costs for ADS-B Out for GA aircraft equals 

zero because the maintenance and replacement times will occur beyond 2035. The dollar 

value ranges consist of a wide variety of avionics within each aircraft group. The aircraft 

architecture within each equipment group can vary, causing different carriage, labor and 

wiring requirements for the installation of ADS-B Out equipment. Volume discounting 

versus single line purchasing also affects the dollar value ranges. We believe the basecase estimate is the most representative outcome. Table 20 shows the maintenance costs 

are included only in the base-case for the total cost calculation. 
37

Table 20 

4.2.4 Cost to FAA to Provide Surveillance Under the ADS-B Out Scenario

ADS-B Out implementation requires integration of four major components: ground 

infrastructure (ground based transceivers), automation, data45 and avionics.46

 The FAA has entered into a vendor contract with ITT to provide ADS-B surveillance 

uplink and downlink services, TIS-B and FIS-B services. The vendor will install and 

maintain the ground equipment necessary to provide ADS-B uplink and downlink 

services to air traffic control. The costs for ADS-B Out presented in this report are an 

estimate of what the contractor will charge the FAA to provide these services and also 

include the costs of automation interfaces and program office costs. 

The costs of the ADS-B Out scenario also include radar costs, which include the cost to 

sustain existing radar until ADS-B Out is operational (sustain costs), the cost to operate 

backup radar (backup costs), and the cost to decommission some radar as ADS-B 

 

45 Integration of data is part of the ADS-B In ground costs. 

46 Exhibit 300 Attachment 2 Business Case Analysis Report for Future Surveillance JRC Phase 2a, pg. 12.
38

becomes operational (decommissioning costs). Under the radar baseline scenario, the 

FAA will incur costs of $2.9 billion over 27 years ($1.2 billion when discounted by 7%) 

as detailed in Table 2. Under the ADS-B Out scenario, the FAA will incur total legacy 

surveillance costs of $1.9 billion ($975 million when discounted by 7%). In other words, 

the FAA will spend $1 billion ($271 million when discounted by 7%) less on radar under 

the ADS-B Out scenario, because it will cut back on the number of radar. However, the 

FAA will incur $1.8 billion for the ADS-B Out surveillance services ($1.1 billion when 

discounted by 7%). Therefore, while the agency may be saving money on radar, it will 

be spending more on ADS-B services, so there will be no net cost savings to the FAA 

from the ADS-B Out program. Total costs to the FAA of the ADS-B Out scenario are 

higher than total costs of the radar baseline scenario. 

The cost of the ground segment under the ADS-B Out scenario (not including Juneau, but 

including legacy surveillance costs) is estimated to be $3.7 billion ($2.0 billion) over 29 

years as presented in Table 21. This includes total ADS-B Out ground costs of $1.8 

billion ($1.1 billion when discounted by 7%), and total legacy surveillance costs of $1.9 

billion ($974 million when discounted by 7%)47

. 

Table 21 

ADS-B Out Scenario Total Ground Costs: The Rule 

(not including Low Altitude Operations in the Gulf of Mexico, Capstone or Juneau) 

(2009K $) 

 

47 The FAA developed these estimates internally. 
39

The costs of this rule will be borne by both industry and the government, and benefits 

will accrue to industry and to the flying public, as discussed in the benefits section. 

Industry will incur costs ranging from $2.4 billion ($1.3 billion when discounted by 7%) 

to $6.1 billion ($3.3 billion when discounted by 7%). Estimated benefits accruing to 

industry and the flying public range from $6.8 billion ($2.1 billion when discounted by 

7%) to $8.8 billion ($2.8 billion when discounted by 7%). 

4.2.5 Benefits of ADS-B Out 

ADS-B Out will enable improved surveillance services across the en route, terminal, and 

surface environments by providing a robust, highly accurate, timely four-dimensional 

surveillance data link, based on the downlink of the aircraft’s Global Positioning System 

(GPS) parameters. ADS-B Out is designed to improve the capacity and efficiency of the 

NAS, maintain safety, and provide a flexible, expandable platform to accommodate 

future air traffic growth. 

The FAA is not engaging in this rulemaking simply to meet the level of surveillance that 

exists in the current infrastructure, or to establish a new surveillance system that would 

only enable separation performance equivalent to that realized today. ADS-B Out 

performance is intended to go beyond today’s standards for accuracy and provide a 

platform for the next generation air transportation system. 

The following quantified benefit estimates apply to both domestic operators and foreign 

operators as they operate in U.S. controlled airspace. However, we did not break out 

benefits between domestic and foreign operators. Earlier we provided a separate cost 

estimate for foreign firms, which we did not include in the costs of the rule, but we do not 

provide a separate benefit estimate corresponding to those costs. Benefits are slightly 

overestimated because they include benefits to foreign operators but do not include the 

costs to foreign operators. 

Quantifiable benefit areas and associated estimated benefits are presented in Table 22 

below. Derivations of these estimates are described in the following sections. 

Table 22 

 Quantified ADS-B Out Benefits 

2009$ M 
40

4.2.5.1 High Altitude Operations Over the Gulf of Mexico

Assumptions

• IOC for communications and weather over the Gulf of Mexico 9/2009, 

• IOC for surveillance 12/09, 

• Capacity benefits phase in beginning in 2012 and by 2019 100% of the active 

fleet is equipped, and 

• Delays are limited to, or capped at 20 minutes.48

Delay Savings and Additional Flights Due to Increased Capacity over the Gulf of 

Mexico (Benefits of Reduced Delay and Value of Additional Flights Accommodated

We estimate that the benefit of increased capacity for high altitude operations that will be 

achieved with ADS-B Out over the Gulf of Mexico measured in reduced delays is $1.7 

billion ($463 million at 7% present value). We also estimate that ADS-B Out will 

accommodate an additional 290,550 flights over the Gulf of Mexico during the period 

from 2017 through 2035. We estimate the benefit of these additional flights is $572 

million ($118 million at 7% present value). Appendix B has details on the methods we 

used to estimate these benefits. 

ADS-B Out can potentially decrease delays over the Gulf of Mexico by allowing air 

traffic controllers to separate traffic to radar standards rather than oceanic standards. 

While the rule does not mandate ADS-B Out performance requirements over the Gulf of 

Mexico beyond 12 miles from the U.S. shore, all high altitude aircraft that fly into and 

out of the U.S. over the Gulf of Mexico will have to be equipped to the standards of the 

rule because these aircraft will be traversing airspace that requires ADS-B performance. 

The FAA will provide ADS-B surveillance capability under the vendor service contract. 

Currently, controllers need to build a margin of safety into airspace where there is no 

radar. In non-radar areas like the Gulf of Mexico controllers separate aircraft by 10 to 15 

minutes, which is equivalent to 80 to 120 miles lateral separation. ADS-B Out 

 

48 “approximately 20 minutes represents the highest level of average delay realized in actual practice even 

at highly congested airports”, FAA Airport Benefit Cost Analysis Guidance, page 16, FAA Airport Benefit 

Cost Analysis http://www.faa.gov/regulations_policies/policy_guidance/benefit_cost/media/faabca.pdf 
41

surveillance in these areas will allow closer separation of aircraft because air traffic 

controllers will be able to see aircraft and achieve radar-like separation. This will lead to 

fewer delays and higher levels of traffic than would be the case without ADS-B Out. 

Optimal Routing and More Direct Routing Over the Gulf of Mexico – Benefits of 

Decreased Flying Distance

Provision of ATC surveillance above FL240 for non-radar regions over the Gulf of 

Mexico will allow for optimal and more direct routing of flights. We estimate that $384 

million ($144 million at 7% present value) might be achieved in time saved due to 

optimal routing and more direct routing over the Gulf. Details of how these benefits were 

estimated are shown in Appendix B. 

Due to lack of surveillance and limited communication at high altitudes, non-radar 

separation procedures restrict aircraft flying high altitude operations over the Gulf to a 

limited number of routes or to a path avoiding the non-radar region completely. The 

introduction of radar-like separation attained by providing surveillance and improved 

communications services in the Gulf of Mexico will permit the creation of additional 

routes or the granting of more direct requests. This will allow for more efficient routes, 

which will result in decreased flying distance. Decreased flying distance can be 

translated into time saved, which can be valued in terms of aircraft direct operating costs 

and passenger value of time. 

4.2.5.2 Improved En Route Conflict Probe Performance 

Conflict Probe Benefits

The Conflict Probe is a tool designed to assist the air traffic controllers in their key role 

of ensuring the safe and expeditious movement of aircraft. It does this by constructing 

aircraft trajectories – the predicted flight path of aircraft in 3-D position and time -- based 

on detailed flight models, the aircraft’s flight plan, and surveillance data. These 

trajectories are then continuously “probed” for possible separation violations between 

aircraft – i.e., “conflicts” -- and the controller is notified accordingly. The warning time 

for these conflicts is limited only by the trajectory accuracy, and thus strategic problem 

notification is supported for enhanced safety and efficiency. Controller action and pilot 

requests may also be checked before they are implemented with “trial” trajectories, 

further improving safety and facilitating the granting of these requests. 

Assumptions

• The mean distance of prevented maneuvers = 1.04 NM. 

• An average speed of 356 NM per hour per prevented maneuver will save .0029th

of an hour (1.04 NM/356 nmph).49

 

49 FAA (2003), “Controller-Pilot Data Link Communications (CPDLC Build 1A) Benefits Analysis.” 
42

• Given a value of time per IFR hour of $4,43150 the average prevented maneuver 

will save $12.94($4,431 x .0029). 

• Estimate 65% of the remaining conflicts are vector maneuvers.51 

• The mean path length of vector maneuvers not eliminated with ADS-B is 4.01 

NM. 

• With ADS-B the efficiency of the remaining vector maneuvers will increase by 

1/8 of the maneuver distance. 

• Using an average speed of 356 NM per hour each vector maneuver made more 

efficient will save .0014th of an hour (4.01 NM /8 =.50 NM; convert to hours .50 

NM/356 = .0014). 

• Given a value of time per IFR hour of $4,431 each more efficient maneuver 

($4,431 x .0014) will save $6.24. 

• Conflict probe benefits begin in 2017. 

• Controllers act on 10% 52 to 63.35% 53 of conflict alerts, with 10% giving a lower 

bound estimate and 63.35% giving an upper bound estimate. 

• Slight discrepancies are due to round off error. 

Controllers act on the knowledge that an aircraft on their display may have travelled for 

up to 12 seconds with no display update. To compensate for this less than precise radar 

surveillance information, the actual spacing between aircraft is usually larger than the 

minimum separation required. The minimum allowed en route separation is 5 nautical 

miles, but high performance aircraft can travel up to 1.5 nautical miles laterally during 

the time between updates on the radar display.54

 

With the greater precision of ADS-B, it is possible that controllers will put less of a 

buffer between aircraft in flight. With less of a buffer, there may be less maneuvering of 

aircraft and consequently less fuel consumed and less delays (less time spent in aircraft 

maneuvers). Because of the uncertainty of whether the knowledge that display data will 

be more precise with ADS-B will result in air traffic controllers actually reducing the 

buffer between aircraft, Mitre estimated the benefits that could result if their conflict 

probe tool alerted less frequently due to more precise ADS-B data. The Mitre study,55

provides the basis for the methodology and some data for the benefits estimated here, but 

some of our assumptions differ from those in the study. Because the study was 

performed before the latest FAA forecast was released, the Mitre study does not use this 

latest forecast, while the estimates provided here do. 

 

50 Includes aircraft direct operating cost and passenger value of time and is based on the 2009 TAF and

ATO-F FY09 economic values. 

51“ADS-B Benefits Enabled from Improved En Route Conflict Probe Performance”, The Mitre 

Corporation, August 27, 2007. 

52 Human Factors Research and Engineering Group AJP-61, FAA 

53 Subject matter experts in Air Traffic Organization – Finance, now called IP&A, Operations Research 

group 

54Ibid. 

55 “ADS-B Benefits Enabled from Improved En Route Conflict Probe Performance” 
43

According to Mitre’s analysis, the excess separation can be reduced by at least .5 NM for 

each aircraft due to ADS-B, removing a total of 1 NM of excess separation due to the 

slower update rate of radar.56 The total separation reduction from 8 to 7 NM allowed by 

ADS-B could support increased flight efficiency in two ways. First, some maneuvers are 

eliminated completely because of the reduction in the number of alerts. Without ADS-B, 

the conflict probe would issue an alert if two aircraft were going to lose 8 NM lateral 

separation. Two aircraft equipped with ADS-B would only set off a conflict probe alert if 

they were going to lose 7 NM lateral separation. Fewer maneuvers translate into a time 

savings, which translate into a cost savings. According to data from the FAA’s Air 

Traffic Organization – Finance 57 (ATO-F) there would have been an added path distance 

of 1.04 NM per avoided maneuver, which translates into a time savings of .0029 hours. 

Second, the lateral (vector maneuvers) that remain are expected to be more efficient due 

to the smaller separation distance that must be obtained as illustrated in the Mitre 

analysis. ATO-F estimated the mean path length of vector maneuvers not eliminated 

with ADS-B is 4.01 NM. These maneuvers could be made one eighth more efficient58 

eliminating .50 NM which translates to a time savings of .0014 hours. 

To estimate the benefit of prevented maneuvers, Mitre estimated a conflict probe alert 

rate for both 8 NM and 7 NM separation by applying a URET-like conflict probe to 

recorded Base Year (2006) CONUS-wide data59 with 8 NM separation to represent radar 

and 7 NM separation to represent ADS-B bounds. The analysis used a 10 minute lookahead time and each alert occurred in en route airspace and would have been notified to 

an en route controller. Five days, each day being near the 90% busiest day in the NAS, 

were analyzed. 

The measured alert counts at each separation value for each of the five days are presented 

in the table below. At an 8 NM separation, the average number of conflict probe alerts is 

53,122 and at a 7 NM separation the average number of conflict probe alerts is 45,155. 

Table 23 

Measured Alert Counts 

 

56 Mitre estimated excess separation due to radar surveillance error. To estimate excess separation due to 

radar surveillance error they used “comparative studies of radar and Global Positioning System (GPS) data 

as recorded for actual flights (e.g. Paglione and Ryan, 2005) and other documented parameters such as 

wind prediction error, Flight Technical Error (FTE), and speed estimation error. 

57 The name of this FAA office has been changed to IP&A, Operations Research group, since they supplied 

the data. 

58Mitre analysis, August 27, 2009, page 28. 

59This is recorded CONUS-wide en route track and flight plans as generated by the Enhanced Traffic 

Management System (ETMS). 
44

To obtain alert rates, IFR handles60 in the continental United States, for each of the five 

days were obtained from ATADS.61, 62 Pairwise combination handles per day were 

calculated by subtracting the number of handles from the square of handles and dividing 

by two. This represents all possible combinations of handles over the continental U.S. 

for that day and is used as the denominator in the calculations of the alert rates. 

Table 24 

IFR handles over the continental U.S. 

Measured alert counts are taken as a percent of the pair-wise handle combinations per day 

for each of the two separation values (8 NM and 7 NM). This gives the percent of handle 

combinations that result in a conflict probe alert for each separation value according to 

the Mitre analysis; 5.54E-06 for 8 NM and 4.71E-06 for 7 NM separation. 

Table 25 

Alert Rate Per Pair-wise Handle for 8 NM and 7 NM Separation 

 

60IFR Aircraft Handled. The number of ARTCC enroute IFR departures multiplied by two, plus the number 

of en route IFR overs. This formula assumes that the number of departures (acceptances, extensions, and 

organizations of IFR flight plans) is equal to the number of arrivals (IFR flight plans closed). 

61 http://aspm.faa.gov. # of handles is also available through Opsnet. 

62 Excludes Anchorage and Guam. 
45

To forecast future conflicts these alert rates are applied to the forecast of daily pair-wise 

handle combinations over the continental U.S., which is computed from the number of 

IFR handles from the 2009 FAA Aerospace Forecast.63 The table below illustrates how 

we estimated the number of prevented conflicts due to predicted fewer alerts with 7 NM 

separation rather than 8NM separation. We assume that the conflict probe increased 

accuracy benefit begins in 2017 64 and continues through the lifecycle. 

For example in 2017, we project 129,100 IFR handles per day over the continental U.S. 

or 8.33 B pair-wise combination handles per day. To determine the number of URET 

conflict probe alerts expected under the baseline (8NM separation), we multiply pair-wise 

combination handles by the radar alert rate of 5.54E-06 to derive daily baseline conflicts 

of 46,192. This would represent the number of times per day the conflict probe would 

alert without ADS-B (8 NM separation). Similarly to obtain the number of URET 

conflict probe alerts expected with ADS-B we multiply pairwise combination handles by 

the 7NM separation alert rate of 4.71E-06 to derive 39,264 or the number of times per 

day the URET conflict probe would alert with ADS-B surveillance. The potential 

prevented maneuvers are 6,928 daily. However, experience indicates that controllers do 

not always act on the URET conflict probe alerts. Studies indicate that the number of 

times a controller acts on a conflict probe alert can be as low as 2% of conflict probe 

alerts to as high as 100%. The Mitre conflict probe analysis assumed that controllers 

would act on 100% of the conflict probe alerts. In the regulatory impact analysis of the 

NPRM, we assumed that controllers would have acted on 63.35% of these conflicts. In 

this final regulatory impact analysis, to be conservative, we add a lower bound estimate 

of conflict probe benefits that assumes that controllers only act on 10% 65 of conflict 

probe alerts. Table 26 uses 63.35% as the percent of conflict probe alerts that controllers 

 

63 Table 33, IFR Handled at FAA Air Route Traffic Control Centers, 2009 FAA Aerospace Forecast, less 

handles over Guam and Anchorage. 

64 The conflict probe is planned to be available to the R-side controller by 2016. 

65 Based on discussions with personnel in FAA’s Human Factors Research and Engineering Group AJP61. The lower bound number is also supported by studies including: Adaptation and adoption of 

technologies: Examination of the User Request Evaluation Tool (URET), Kevin Corker, Martin 

Howard, Martijn Mooij, San Jose Sate University, November 1, 2005, which indicated that about 2% of 

alerts are acted on and Human Factors Analysis of Safety Alerts in Air Traffic Control, Kenneth 

Allendoerfer, Human Factors Team – Atlantic City, ATO-P Ferne Friedman-Berg, Ph.D., Human Factors 

Team – Atlantic City, ATO-P Shantanu Pai, Engility Corporation November 2007 which concluded that 

13%-19% of alerts are acted on. 
46

act on. The number of actual prevented conflicts in the example is 4,389 in 2017 (6,928 

times 63.35%). The dollar value of each prevented maneuver is $12.94 (see assumptions 

above for calculation) and the total dollar value of prevented maneuvers per day is 

$56,805.66 

Table 26 

Estimate of Prevented Conflicts and Savings for Prevented Maneuvers 

In addition to eliminating potential conflicts that occur between 7 NM and 8 NM, ADS-B 

could make some maneuvers of aircraft that trigger an alert within the 7 NM separation 

more efficient. In 2017, we estimate 39,264 conflict probe alerts given a 7NM separation 

alert threshold (daily handle pairs of 8.33 billion times the 7 NM conflict probe alert rate 

4.71E-06 = 39,264). If controllers acted on 63.35% of these conflict alerts, 24,874 

potential conflicts would be maneuvered in 2017. Sixty-five percent of the remaining 

maneuvers (16,168) can be made more efficient because of ADS-B surveillance data. 

The dollar value of the increased efficiency is $6.24 per maneuver as explained under the 

 

66 Discrepancies due to round off error. 
47

assumptions above. Savings for the remaining vector maneuvers is $100,827 per day in 

2017. 
48

Table 27 

Estimates of Remaining Vector Maneuvers and Savings for Increased Efficiency of 

Some Remaining Maneuvers 

Table 28 shows annual savings in 2009 dollars given that controllers act on the alerts 

63.35% of the time, the high benefit estimate. For example for 2017, we add savings 

from prevented maneuvers ($56,805) plus savings for more efficient vector maneuvers 

($100,827) for daily total savings ($157,631) and derive an annual savings of $57.5 

million. Since we estimate 78% equipage in 2017 we claim 78% of the $57.5 million 

savings in year 2017. 

Table 28 

Dollar Value of Conflict Probe Performance Benefits – High 
49

The analysis is repeated with a 10% rate of controllers acting on conflict probe alerts. 

The estimated dollar savings are presented below. 

Table 29 

Dollar Value of Conflict Probe Performance Benefits – Low 

Estimated conflict probe benefits range from $267 million ($82 million when discounted 

by 7%) to $1.7 billion ($516 million when discounted by 7%).

4.2.5.3 More Accurate Metering Because of Increased Accuracy 

The improved accuracy and update rate of ADS-B position and speed information (over 

the accuracy, update rate, and information supplied by radar) will impact the capabilities 

of controller automation. One aspect of current automation is a metering capability 

called the Traffic Management Advisor (TMA). TMA is a decision support tool for en 

route controllers that optimizes arrival flows into busy airports. The controller display 

provides exact times for each aircraft to reach the arrival fix so that runway throughput is 

optimized. Because predictions of runway throughput and metering times are based on 

surveillance inputs, the increased accuracy and update rate of ADS-B, over radar, should 

allow better predictions, leading to an incremental increase in runway throughput. 

TMA was developed by NASA as part of the Center TRACON Automation System 

(CTAS). Many NASA studies have examined the uncertainty in initial position, aircraft 

speed, aircraft weight, and winds, and how these uncertainties introduce errors into the 

CTAS calculations of meter fix arrival times. The study, “CTAS Error Sensitivity, Fuel 

Efficiency, and Throughput Benefits” (NASA 1996), compared the meter fix uncertainty 

of the current system, TMA (with the addition of weather information from the Integrated 

Terminal Weather System - ITWS) and a planned upgrade to TMA called the En route 

Descent Advisor (EDA). Table 30 presents a summary of the meter fix uncertainty 

information from the NASA paper. A further study comparing EDA and TMA, “EDA 

July 2004 Simulation Overview,” (NASA 2004) presented similar results. 
50

Table 30 

Meter Fix Uncertainty from NASA Study 

ADS-B surveillance information should further reduce the uncertainty in initial position 

and speed allowing more accurate meter fix delivery. The “En route Descent Advisor 

Performance Analysis Final Report” (NASA, 2004) examined the CTAS input factors 

(e.g. position, speed, wind , weight, etc.) closely to determine the contribution of each to 

the meter fix uncertainty. They found that speed and initial position uncertainty account 

for approximately 40 percent of the remaining error. Table 31 repeats the information 

given in Table 30, but also applies the additional 40 percent reduction that would occur 

with no initial position and speed variance. Table 31 implies that if all position and speed 

error could be eliminated the remaining variance would be 13 seconds. If only half the 

variance could be eliminated the remaining would be 17 seconds. It is assumed in this 

estimate that the increased accuracy and update rate of ADS-B in the en route airspace, 

and the ability to downlink speed information directly into the automation (as opposed to 

the current method of estimating speed from multiple radar hits over time) will eliminate 

half the remaining variance due to speed and position uncertainty seen in the current 

system. 

Table 31 

Meter Fix Uncertainty with Increased Accuracy 

Table 31 also lists the meter fix uncertainty as a percentage of the uncertainty in current 

operations. TMA reduces the meter fix uncertainty by 66 percent (44 percent of the 

original); the addition of EDA should bring the total uncertainty reduction to 83 percent 

(17 percent of original). If the speed and position accuracy from surveillance information 

were twice as accurate as current information, the final reduction would amount to an 86 

percent decrease in meter fix uncertainty (14 percent of original). 

To translate the analysis described above into an economic benefit, we first examined the 

benefit of different arrival variance changes on airport delay using an equilibrium 
51

queuing model. The inputs for the model include current Future Airport Capacity Task 

(FACT 2) airport capacities, current demand profiles at each airport, and future projected 

operations from the Terminal Area Forecast (TAF). The model allows changes in the 

arrival variance that should reflect the changes in uncertainty described in Tables 30 and 

31. The benefits of TMA, TMA plus EDA, and TMA plus EDA plus ADS-B increased 

accuracy were tabulated. The ratio of the incremental ADS-B increased accuracy 

benefits to the TMA benefits equaled approximately 0.05. This leads us to believe that 

the increased accuracy of ADS-B information should at least result in a 5 percent increase 

in benefits beyond current TMA projections. In reality this estimate is conservative, 

because it already assumes that the introduction of ADS-B information will be 

incremental to EDA, a program that is still in the planning stages but will most likely 

come to fruition before full ADS-B equipage. 

The TMA Program Office completed a future benefits analysis in February 2007 that was 

submitted and approved within the FAA. The report presented yearly benefit results for 

18 TMA airports through 2020. We leveraged these TMA results to estimate the 

additional benefit due to ADS-B. We first scaled the TMA results to reflect the current 

approved aircraft direct operating costs (ADOC) and value of passenger time (PVT) 

values. The ratio described in the previous paragraph was then applied to the TMA 

results in 2020 to estimate the additional benefits due to increased surveillance 

information. The benefits were assumed to begin by 2020 and continue through the SBS 

lifecycle. The 2020 benefit was extrapolated through 2035 using a linear scaling based 

on the growth in yearly operations at each relevant airport from the TAF. 

The estimated benefits are $1.4 billion ($400 million when discounted by 7%). 

4.2.5.4 Increased Ability to Allow Optimized Profile Descent Procedures 

Optimized Profile Descents (OPDs)67 are Area Navigation (RNAV) / Required 

Navigation Performance (RNP) terminal arrival procedures specifically designed to keep 

an aircraft at idle or near idle power from the Top of Descent (TOD) where descent 

begins, during the entire arrival until the Final Approach Fix (FAF). Thus, the aircraft can 

leave En Route airspace, enter Terminal airspace and descend smoothly to landing at the 

airport runway. The OPD eliminates step-down altitudes normally used and the 

associated inefficient power adjustments, whereby the aircraft must increase power at 

each step to level off. These procedures result in increased savings in fuel, and reduced 

noise and emissions. In addition, since little or no air traffic control vectoring of the 

aircraft is required during the procedure, the radio frequency is less congested. 

OPDs are currently more feasible with RNAV68 at low traffic densities and with similarly 

equipped aircraft. For multiple OPDs to occur, the aircraft must be sequenced and spaced 

accurately. Aircraft are normally sequenced to metering fixes using speed control and 

radar vectors. Radar is used to establish and monitor the separation interval between 

 

67 OPDs may also be referred to as continuous descent approaches or CDAs. 

68And in the future will be feasible with RNP procedures. 
52

arriving aircraft. The fidelity of the radar information directly impacts the air traffic 

controller's ability to maintain an appropriate interval. 

As the amount of traffic increases, it becomes progressively more difficult for controllers 

to allow OPDs because of interfering flight paths from other arriving and departing traffic 

in the terminal, especially when more than one runway is in use. OPDs are often not 

used at very high traffic density situations. 

Another factor limiting the use of OPDs is related to the inefficiencies involved in 

metering to the fix. OPD uses merging and spacing to bring aircraft to the TOD. In the 

Merging and Spacing (M&S) application, precise speed instructions are sent from the 

ground to en route aircraft to properly sequence aircraft approaching the terminal area. 

The SBS program is developing both a ground and cockpit tool that can be used to 

optimize aircraft spacing to enable OPDs during increased levels of approach and 

departure activity than is currently feasible. A prototype tool is being developed for UPS 

to use in their Airline Operations Center. When this tool is mature it will be incorporated 

into FAA traffic flow management automation to allow FAA controllers to space aircraft 

from multiple carriers across multiple dependent merge fixes into an airport using future 

surveillance data. 

The increased accuracy and fidelity of the ADS-B Out positioning solution, combined 

with the SBS merging and spacing tool provides a more sophisticated metering solution, 

allowing controllers to meter aircraft with varying performance characteristics to 

different merge points. Therefore, ADS-B has the potential to increase OPD usage. 

Assumptions for OPD benefit estimates: 

• OPD can save on average69 273 pounds of fuel per aircraft. 

• Fuel cost per pound = $.291. Estimated fuel cost per gallon is $1.9570 (2009 $) 

which converts to $.291 given 6.7 pounds per gallon of fuel. 

• Benefit can only be achieved during visual meteorological conditions (VMC) 

conditions because reduced weather in the extended terminal area can hinder 

OPDs. 

• NAS wide start year for OPD is 2014. 

• OPDs can be accomplished without ADS-B Out at traffic densities71 up to 40%. 

 

69 The average of 181 lbs and 364 lbs saved per fight from “Continuous Descent FAA COE Noise Study 

Projects”, Captain Bob Hilb, UPS Airlines, May 25, 2005. 

70 “Economic Information for Investment Analysis Data Package,” 4/24/2009, Operations Research, ATOFinance. 

71 We define traffic density as arrivals over capacity. 
53

• OPDs at traffic densities from 40% to 70% cannot be accomplished without ADSB Out and a spacing tool.72

• 50% of the fuel savings are attributed to ADS-B Out with spacing tool. We 

assume the rest is due to RNAV procedures. 

• Spacing tool will be available at the Top 100 Airports. 

 

• Only air carrier and commuter airlines will have sufficient economic incentive to 

apply OPDs on a day-to-day basis. 

• Commuter operations comprise 66% of Air Taxi and Commuter operations. 

The increased ability to allow OPD benefits were estimated by multiplying the average 

fuel savings per OPD arrival to the percent of flights that arrive at each of the top 100 

airports during periods when demand is between 40 and 70 percent of VMC capacity. 

The benefit was only taken during VMC (good weather) because reduced weather 

conditions in the extended terminal area may hinder OPDs. Estimates were developed 

separately for the 100 busiest airports. The benefits were assumed to begin NAS-wide in 

2014 (and 2009 for UPS airports) and only apply to air carrier and commuter aircraft. 

Additionally, we further degraded the benefit by attributing much of the savings for 

OPDs during the spacing tool regime to other necessary elements like RNAV/RNP. To 

take account of the additional necessary elements, the SBS program office only claimed 

one half of the final spacing tool regime OPD benefit. 

We took all Air Carrier Operations and Commuter Operations from the 2008 TAF at the 

top 100 airports forecasted to the year 2035. Since operations include landings and 

takeoffs we divided operations by 2 to estimate landings which could benefit from OPD. 

Table 32 shows a sample of operations from the TAF.73

Table 32 

Air Carrier and Commuter Operations 

 

72 With the exception of OPDs performed in Southern California. 

73This table includes more than just the top 100 airports, but we only include top 100 in our calculations. 
54

Benefits start to accrue in 2014, the year we expect the OPD procedures to be instituted 

NAS wide. Benefits increase with equipage which we assume is 27% in 2014 and grows 

to 100% by 2020. Below is the assumed ADS-B equipage rate. 

Table 33 

Percent of ADS-B Out Equipage 

Table 34 shows the percent of time that various weather conditions occur at a sample set 

of airports. We only take benefit for OPDs performed during visual meteorological 

conditions and as indicated in the table below, ABE experienced VMC conditions 71.7% 

of the time. 

Table 34 

Percent of Time Various Weather Conditions Occur 

Source: National Climatic Data Center 

30 year average 

Table 35 shows the percentage of flights that arrive during periods when the traffic 

density is between 40% and 70% of capacity. 
55

Table 35 

Percent of the Time that Demand is Between 40% and 70% of Capacity 

Source: ATO-Finance, Investment and Analysis Office 

Calculation of benefits at ABQ in 2021 as an example: 

Air Carrier and Commuter Operations = 108,335 

Estimated Landings = (108,335)/2 = 54,168 

Percent of Air Carrier and Commuter Aircraft that are ADS-B Out Equipped = 100% 

Number of A/C and Commuter A/C ADS-B Equipped = 54,168 

Percent of the time that ABQ has VMC conditions = 97.5% 

Number of flights during VMC conditions = 97.5% x 54,168 = 52,813 

Percent of flights that arrive during periods where demand is between 40 and 70% 

(medium density) = 14% 

Number of flights arriving during medium density periods = 14% x 52,813 = 7,394 

Estimated average fuel savings per airport = 272.7 pounds 

Estimated fuel savings at ABQ in 2021 due to ADS-B = 7,394 x 272.7 = 2,016,300 

pounds 

Estimate average cost of fuel per pound = $.291 

Estimated monetized value of fuel savings due to OPD = 2,016,300 x $.291 = $586,743 

Percent attributed to ADS-B with spacing tool = 50%

Monetized value of fuel savings due to ADS-B with spacing tool in millions of $= 

($586,743 x 50%)/1,000,000 = $.30 million. 
56

Table 36 

Estimated Dollar Benefits due to OPD by Airport by Year 

2009$ M 

Table 37 

Total Estimated Benefits of Optimal Profile Descent

4.2.5.5 Net Impact on Carbon Dioxide Emissions 

ADS-B will result in both decreases and increases in carbon dioxide (CO2) emissions, 

with a net reduction in CO2 emissions, as explained below. 
57

Reduced CO2 Emissions

Assumptions and Conversion Factors 

• Price per gallon of jet fuel = $1.95, 

• Pounds of fuel per gallon = 6.7, 

• Pounds per metric ton = 2204.6, 

• 1 metric ton of fuel = 3.156 MT of CO2, 

• 2010 Global Social Cost of Carbon (SCC) per metric ton of CO2 ranges from a 

low value of $4.88 to a high value of $36.46, expressed in 2009 dollars, 

• SCC grows at the annual rates listed below 

Average Annual 

Growth Rate(%) 

5% 

Average 

2.5 % 

Average 

2010-2020 3.6% 1.7% 

2020-2030 3.7% 1.8% 

2030-2040 2.7% 1.6% 

2040-2050 2.1% 1.1% 

Some portion of the ADS-B Out benefits is reduced fuel consumption. Reduced cost of 

fuel benefits aircraft operators (and possibly consumers if reduced costs can be passed 

on). However, there is an additional environmental benefit to reducing fuel consumption 

and that is the benefit we present here. Fuel burn creates CO2 emissions which remain in 

the atmosphere for long periods, becoming well-mixed throughout the earth’s 

atmosphere, with long-term effects on the global climate. 

To estimate the benefits of reduced CO2 emissions we have to monetize the impact that 

changes in greenhouse gas (GHG) emissions will likely have on the environment. A first 

step in monetizing these benefits is to determine the incremental damage associated with 

changes in GHG emissions, in particular CO2 emissions. These incremental or marginal 

damages are frequently described in the published literature74 as the Social Cost of 

Carbon (SCC) and are measured as the net present value of climate change impacts over 

hundreds of years from an additional metric ton of CO2 emitted to the atmosphere at a 

particular point in time. Based on an interagency report titled “Highlights of 

Appendix15A: Social Cost of Carbon for Regulatory Impact Analysis under Executive 

Order 12866”, we use a set of range values for the social cost of carbon (expressed in 

terms of $/MT of CO2) to monetize the reductions in CO2 emissions. For 2010, the 

global social cost of carbon per metric ton of CO2 ranged from $4.88 to $36.46, 

expressed in 2009 dollars. 

 

 

74 See Tol, Richard, 2005. "The Marginal Damage Cost of Carbon Dioxide Emissions: an Assessment of 

the Uncertainties." Energy Policy 33: 2064-2074. 
58

It is widely believed that because GHGs tend to accumulate in the atmosphere and have 

very long residence time, future emissions are likely to produce larger incremental 

damages as physical and economic systems become more stressed. The IPCC Fourth 

Assessment Report estimated that climate-related economic damages resulting from an 

additional ton of carbon emissions are likely to grow at a rate between 2 and 4 percent 

annually. Consistent with the interagency guidance noted above, we allow the real 

global SCC to increase over time. By 2035, the range values reported above increased to 

$11.63 and $56.30, per metric ton of CO2. 

With ADS-B surveillance, we expect that less fuel will be burned because of fewer and 

more efficient en-route maneuvers, more efficient traffic management, increased use of 

optimal profile descent, more optimal and direct routing over the Gulf of Mexico and 

fewer delays on the ground for aircraft waiting for take-off over the Gulf of Mexico. In 

the benefit calculations (except the optimal profile descent benefit75) we estimated the 

number of hours saved due to ADS-B either in the air or on the ground and multiplied 

these hours by the appropriate aircraft direct operating cost (ADOC). The ADOC 

includes a fuel component. To estimate the fuel savings, the benefits were first reestimated using only the aircraft direct operating cost of fuel. The estimated dollars 

saved on fuel are presented in the table below. 

 

75 The optimal profile descent benefit consists entirely of fuel savings. 
59

Table 38 

Dollar Value of Fuel 

Savings

 

To estimate fuel savings we divided the dollar value of fuel savings by $1.95,76 to derive 

gallons of fuel saved. Gallons of fuel were converted to pounds of fuel saved (multiply 

by 6.7) and then to metric tons (divide by 2204.6). Metric tons of fuel consumed were 

converted to metric tons of CO2 emissions (multiply by 3.15677). Table 39 shows these 

results. 

 

76 FAA Forecast 2009-2025, Table 18, System Current $ converted to 2009 dollars and averaged for the 

years 2009-2025. 

77 IPCC, Aviation and the Global Atmosphere, Cambridge University Press, 1999, pg. 33. 
60

Table 39 

Total Metric Tons of CO2 Abated 

Increased CO2 Emissions

ADS-B Out will also result in some increased CO2 emissions into the atmosphere; 

however the overall net result is a reduction in CO2 emissions. We estimate the 

additional CO2 emissions that will result from additional flights accommodated over the 

Gulf of Mexico, and from the additional fuel burn that will result from weight added to 

aircraft because of the avionics. 
61

Additional Flights Over the Gulf of Mexico – CO2 Emissions

Assumptions and Conversion Factors

• Average duration of additional flight over the Gulf – 4.33 hours, and 

• ADOC per hour for fuel = $1,861.5.78

Table 40 

Total Additional Metric Tons of Fuel Consumed and of CO2 Produced Due to 

Additional Flights Over the Gulf of Mexico 

The FAA used the ETMS flight plan data and extracted origin and destination airports for 

all flights that included sectors ZHU72 or ZHU79 to create a unique list of origin 

destination pairs. 

The flight time for flights between these city pairs was derived from the ETMS database 

and scheduled flight data (commercial) from OAG/Innovata. The average duration of 

 

78 Economic Information for Investment Analysis, Prepared for Operations Research/ATO-F, April 24, 

2009, 50% of block hour variable cost for air carrier – TAF ($3,724) is attributed to fuel. 
62

these flights was 4.33 hours.79 Each additional flight was multiplied by 4.33 to obtain 

additional flight hours. These additional flight hours were multiplied by the fuel 

component of the aircraft direct operating cost per block hour ($1,861.5) to derive 

additional fuel costs. Additional fuel costs were divided by an average price per gallon of 

fuel ($1.95) to determine additional gallons of fuel consumed. Gallons of fuel consumed 

were converted to pounds of fuel consumed (multiply by 6.7) which were converted to 

metric tons (divide by 2204.6). Metric tons of fuel consumed were converted to metric 

tons of CO2 by multiplying by 3.156. 

Additional Weight of Avionics

ADS-B avionics can add from 3 to 12 pounds of weight to an aircraft which results in 

added fuel burn. We calculate the range of extra CO2 emissions produced by the 

additional fuel burn. Total additional pounds of jet and GA fuel that would be consumed 

if ADS-B avionics added 3 pounds of weight and if ADS-B avionics added 12 pounds of 

weight to each aircraft are indicated in the table below. We convert pounds to metric 

tons (divide by 2204.6) and metric tons to CO2 (multiply by 3.156). The additional 

metric tons of CO2 produced would be 22,823 if ADS-B avionics added 3 pounds of 

weight and 56,613 if the avionics added 12 pounds of weight to each aircraft as displayed 

in the table below. Table 41 is an example that shows the high estimate of additional 

metric tons of fuel consumed. 

Table 41 

Additional Pounds of Fuel Consumed Due to Added Weight of Transponders 

 

79MCR/SETA.
63

We added additional CO2 produced by the additional flights over the Gulf of Mexico 

(11,519 K MT) to the additional CO2 consumed by the added weight of the avionics (22.8 

K MT for the low end of the range and 56.6 K MT for the high end of the range). The 

additional CO2 produced ranges from 11,542 K MT to 11, 576 K MT. 

To produce a range of net CO2 savings we subtract the high net CO2 produced (11,576 K) 

from the low net CO2 saved (16,409) for the low estimate (4,833 K MT) and subtract the 

low net CO2 produced (11,542K) from the high net CO2 (18,610) saved for the high 

estimate (7,068 K MT) of net CO2 savings. 

Table 42 

Total Metric Tons of CO2 Saved 

In Table 43, we convert the net reduction in CO2 emissions into a dollar value by 

multiplying the net reduction by the social cost of carbon. We calculate results using a 

low and high social cost of carbon. Table 43 shows the result of using the low global 

SCC with the estimated low net reduction in CO2 emissions and the high global SCC 

with the estimated high net reduction in CO2 emissions to illustrate the low and high 
64

bounds. The benefit from a net reduction in CO2 emissions ranges from $27 million to a 

high of $300 million, undiscounted. 

Table 43 Benefit of Net Reduction in CO2 

Emissions

4.3 Multilateration Alternative Scenario 

4.3.1 Definition 

Multilateration was one of the original technologies the FAA considered when exploring 

alternative surveillance sources in the early 1990s. The agency established several testbeds for multilateration. The incremental development of multilateration eventually led 

to the certification and deployment of ASDE-X and 3X systems for surface surveillance. 

Multilateration functions by triangulating aircraft position based on time difference of 

arrival of signals to multiple ground stations. For multilateration surveillance, an aircraft 

must have at least 4 ground stations receiving its transponder information.80 It can 

 

80 Exhibit 300 Attachment 2 Business Case Analysis Report for Future Surveillance, JRC Phase 2a, pg. 6. 
65

function with both existing and future transponders such as Modes A/C, Mode S short 

and future extended squitter transponders. Multilateration is currently in use as a surface 

surveillance tool through the ASDE-X program, and has been tested for use in supporting 

the Terminal and En Route airspace domains.81

4.3.2 Cost to Industry 

There are no costs to industry related to surveillance with multilateration because the 

current fleet is equipped with transponders, which will function with multilateration 

surveillance. 

 

General aviation operators who aren’t equipped for weather and traffic services in the 

cockpit could obtain these capabilities with multilateration by installing equipment on the 

aircraft and by subscribing to weather services. Accordingly, we did not include these 

costs in this analysis for either the multilateration scenario or the radar baseline scenario. 

We assume those operators would not willingly incur the costs of weather and traffic 

because for the most part they have not done so to date. 

4.3.3 Cost to FAA 

We estimate it will cost FAA $3.0 billion ($1.7 billion when discounted by 7%) to 

provide surveillance using multilateration over the 29 years. This will include facilities 

and equipment and operating and maintenance costs for multilateration ground facilities 

to provide core surveillance and the cost to sustain radar facilities until multilateration is 

operational. We do not include the cost of providing broadcast services with 

multilateration. 

Included in the estimates of multilateration surveillance costs are costs of facilities and 

equipment, operations and maintenance costs, radar sustain costs and radar 

decommissioning costs. Multilateration does not require a separate backup system due to 

its built-in redundancies. Multilateration surveillance costs are presented in Table 44 

below. 

 

81 Exhibit 300 Attachment 2 Business Case Analysis Report for Future Surveillance, JRC Phase 2a, pg. 10
66

Table 44 

Cost to Provide Core Surveillance Using Multilateration 

2009$ K 

4.3.4 Benefits of Multilateration Surveillance 

Our research did not identify any other feasible benefits of multilateration compared to 

radar. Multilateration may have the potential to improve accuracy but it would not be 

practical to do so, since it could require ground stations in locations where it may not be 

feasible. It is possible that in some locations multilateration could allow for tighter 

separation, but it might require too many multilateration ground stations for 

multilateration to be cost effective for reducing separation. 

While multilateration could provide radar-like separation in some parts of the Gulf of 

Mexico, it is not feasible to provide radar like services throughout the entire area of the 

Gulf. This is due to limitations in the number and location of platforms, which would 

house the ground stations. We assume that multilateration surveillance would provide 

the same functionality as radar, and we have estimated no benefits from multilateration 

surveillance beyond those achieved by the current radar system. 
67

5.0 Summary Comparison of Costs and Benefits 

The costs of the ADS-B Out, multilateration, and the radar baseline scenarios are 

summarized in Table 45 below with present values displayed in Tables 46 and 47. 

Estimated FAA surveillance costs are $3.7 billion ($2.05 billion when discounted by 7%) 

and exceed the radar baseline by $810 million ($800 million when discounted by 7%). 

Avionics costs in these tables are presented at the midpoint between the high and low 

estimates. In later tables, we will present the avionics costs as a range. The midpoint of 

estimated user costs to equip is $4.37 billion ($2.12 billion when discounted by 7%). 

Table 45 

Summary of Costs of Multilateration, Radar Baseline and ADS-B Out Scenarios 

2009$ B 
68

Table 46 

Summary of Costs of Multilateration, Radar Baseline and ADS-B Out Scenarios 

2009$ B at 3% Present Value 

Table 47 

Summary of Costs of Multilateration, Radar Baseline and ADS-B Out Scenarios 

2009$ B at 7% Present Value 

Table 48 summarizes the costs and benefits and shows the difference between the ADS-B 

Out scenario and the radar baseline scenario. Tables 49 and 50 present the same costs 
69

and benefits discounted by 3% and 7% respectively. Avionics costs range from a low of 

$2.5 billion ($1.4 million when discounted by 7%) to a high of $6.2 billion ($3.3 billion 

when discounted by 7%) over the time horizon of the analysis. The total incremental cost 

of the ADS-B Out scenario (including government costs) ranges from $3.3 billion ($2.2 

billion when discounted by 7%) to $7.0 billion ($4.1 when discounted by 7%) more than 

the radar baseline scenario. 

We estimated that benefits range from $6.8 billion ($2.1 billion when discounted by 7%) 

to $8.5 billion ($2.7 billion when discounted by 7%). These are incremental to the radar 

baseline. 

If benefits are high and costs are low (best case scenario), we estimate $5.2 billion ($590 

million when discounted by 7%) of net benefits. If benefits are low and costs are high, 

we estimate negative net benefits. 

Table 48 

 Summary of Costs and Benefits 

2009$ B 

The bulk of the ATC efficiency benefits from ADS-B Out are expected to occur after the 

compliance date of the rule. However, the FAA’s deployment strategy for surveillance 

equipment has the potential to allow benefits to be realized earlier than this conservative 

estimate. For example, if FAA decided to roll out ADS-B surveillance coverage 

regionally, aircraft operating primarily in the covered region may choose to equip faster 

than the rule mandates. A higher density of equipped aircraft in specific regions could 

permit increased use of procedures that yield benefits. 
70

Table 49 

Summary of Costs and Benefits 

2009$ B at a 3% Present Value 

Table 50 

Summary of Costs and Benefits 

2009$ B at a 7% Present Value 
71

Even though the quantitative benefits of the ADS-B Out rule do not always exceed the 

costs, the FAA has made a reasoned determination that the quantitative and the 

qualitative benefits exceed the costs. The bulk of the costs are incurred from the effective 

date of the rule (2010) to the compliance date (2020), while most of the benefit from 

ATC efficiencies occur after the compliance date. The FAA is mandating ADS-B Out 

because we view ADS-B Out as a springboard to NextGen which could lead to further 

benefits in the future; some of the benefits have yet to be identified and some have not 

yet been quantified. Also, as explained in the market failure section, there is a lack of 

incentive for operators to voluntarily equip with ADS-B Out. Once all the aircraft within 

an airspace are equipped with ADS-B Out, operators who also equip their aircraft with 

ADS-B In can begin to accrue benefits such as continuing visual approaches in marginal 

conditions or reduced aircraft to aircraft conflicts. The FAA views ADS-B as a means to 

accommodate the expected increase in demand for surveillance and separation services 

with less delay than would be possible with the current radar system. As mentioned in 

the preamble, “to accommodate the projected level of traffic without adding delay, more 

comprehensive surveillance in the NAS, including more radar sites in certain areas, 

would be necessary.” However, increasing the number of radars in the NAS does not 

solve the inherent limitation of radar technology, and would not enable the FAA to 

eventually reduce current separation standards. Also, radar does not provide the 

capability to provide services on the flight deck as ADS-B does. 

6.0 Additional Programmatic Benefits of ADS-B Out 

In addition to the rule-oriented benefits of ADS-B discussed above, there are additional 

benefits of ADS-B associated with the overall ADS-B program. These include increased 

ability to conduct operations at low altitudes over the Gulf of Mexico, enhanced search 

and rescue capability, and enhanced surveillance where radar is currently weak. These 

benefits are discussed below. 

6.1 Increased Ability to Conduct Operations at Low Altitudes over the Gulf of 

Mexico 

There is currently a signed Memorandum of Agreement (MOA) between the FAA, the 

Helicopter Association International (HAI), helicopter operators, and oil and gas platform 

owners to improve low altitude service in the Gulf of Mexico. In this MOA, helicopter 

operators agree to equip with appropriate avionics and equipment to take advantage of 

FAA enhancements to communications, weather reporting, and surveillance capabilities. 

In this regulatory impact analysis we reason that, since helicopter operators in this region 

would equip with or without the rule, the associated benefits and costs are attributable to 

the overall ADS-B program but not the rule itself. 

6.2 Enhanced Search and Rescue Capability 

 

One of the objectives of the ADS-B program is to make techniques and services 

associated with radar surveillance also available for non-radar airspace through use of 
72

ADS-B, including enhanced search and rescue (SAR). While ADS-B should not be 

considered a replacement for Emergency Locator Transmitters (ELTs), when an aircraft 

is reported missing, ADS-B can enhance SAR operations by providing the last known 

surveillance position. The new 406MHz ELT has an activation rate of 81-81 percent in 

actual accidents but the ELTs in most General Aviation aircraft have an activation rate of 

73 percent. The benefit of enhanced SAR operations is an increased likelihood of survival 

for those involved in aviation accidents. When radar coverage is not available and an 

aircraft is reported missing, SAR teams most often don’t know where to start looking. 

Also, even when an accident doesn’t directly result in fatalities, many people who survive 

the accident die of exposure because they cannot be found quickly. SAR activities, 

however, can be better focused if surveillance data is available for a flight presumed 

missing. By knowing the position of the aircraft prior to the accident, the time duration 

of the search operation can be greatly reduced. By reducing the search times and locating 

the accident site quickly, the cost and resources to conduct the operations are also greatly 

reduced. According to a published report from the Alaska Wing Civil Air Patrol, in 2008, 

there were 211 SAR missions in Alaska, totaling 705 flight hours. Aircraft used vary 

from single-engine ($150-$500 per hour), multi-engine ($6,500 per hour), and helicopters 

($2,500-3,200). 

The anticipated SAR benefits from having ADS-B surveillance coverage in non-radar 

inter-mountain areas like in the Rocky Mountains of Colorado can best be understood by 

looking at the benefit Alaska has realized as a result of their Capstone project and how 

their SAR operations have been affected. FAA Capstone avionics continuously broadcast 

the GPS-based position of the aircraft and other information through ground stations to 

Anchorage Center and other aircraft, and is available to operators for flight following. 

The potential for monitoring the location of FAA Capstone-equipped aircraft, and having 

the capability to note the loss of ADS-B data from an aircraft, could benefit the SAR 

process when an aircraft is overdue or reported missing, whether or not the aircraft’s 

onboard Emergency Locator Transmitter (ELT) functions. The track data can also be 

retrieved by the Anchorage Center if the aircraft is reported missing or overdue, to 

determine the last known position. 

To fully understand how ADS-B technology can augment ELT information for SAR, it is 

important to understand the mechanism of the ELTs, their reliability, and advances in 

technology and their associated costs. Currently General Aviation aircraft are required 

(by Congressional mandate in 1972) to equip with an ELT that is battery powered and 

activates upon severe impact. It is supposed to emit a signal on a specified radio 

frequency. The original ELTs manufactured to FAA specifications emitted a signal on the 

121.5/243 MHz frequency. However, they had an activation rate of less than 25% in 

actual crashes and a 97% false-alarm rate, i.e., sending SAR teams on missions where a 

signal was heard but no aircraft accident occurred. In 1985, a newer version became 

available that improved the activation rate to 73% in actual crashes but at a $200-500 cost 

plus cost of installation. In February 2009, however, the 121.5 frequency was no longer 

being monitored for distress signals because of the high rate of false alarms. Recently, an 

even more advanced model has been developed (406 MHz) and it activates 81-83% of the 

time but they are relatively expensive. 
73

Additionally, hand-held, portable versions of an ELT called Emergency Position 

Indicating Radio Beacon (EPIRB) have become available. These types of tracking and 

alerting devices and services are growing in number and sophistication so it is only a 

matter of time until they will most likely leap-frog 406 ELTs in reliability and 

functionality. For comparison of ELTs, see Table 52. 

Table 52 

 Comparison of Emergency Locator Transmitters 

Emergency Locator Transmitters (ELTs) – All are battery powered 

 ELT Cost to 

Operator in 

addition to 

avionics 

Activation 

rate in 

actual 

accidents 

Comments 

Original mandated 

(1973) 

121.5/243MHz ELT 

TSO-C91 

Approx. $100 Less than 

25% False alarm rate 97% 

Improved ELT 

(1985) 

121.5/243MHz 

TSO-C91A 

$200-500 cost 

including 

installation 

73% 

February 1, 2009, the satellite 

system discontinued monitoring 

of 121.5/243 distress signals 

due to poor accuracy and high 

no. of false signals 

ICAO int’l required 

406MHz ELT 

TSO-C126 (uses 

digital technology); 

voluntary in US 

$1,000 cost not 

including 

installation 

81-83% 

More accurate and near 

instantaneous; Allows SAR 

personnel to have vital 

information specific to operator 

and aircraft 

Emergency Position 

Indicating Radio 

Beacon (EPIRB). 

Variable cost; 

hand-held (no 

installation) 

Depends on 

the selected 

option 

EPIRBs are battery-powered, 

very portable, completely 

waterproof, and they float. They 

have signal options. 

However, ADS-B has the potential to be used to provide continuous positioning 

information, while also providing other services, such as weather and traffic information. 

This is especially useful if an aircraft is reported overdue or missing, yet no ELT signal 

has been observed. ADS-B does not depend on battery-powered emission of a signal to 

indicate the last known position. It has been tested and, in fact, used for rescue purposes 

in Alaska. A Capstone SAR example occurred in 2002 when a pilot flew from Bethel 75 

miles north to the village of Marshall, Alaska. He didn’t return. As a National Guard 

helicopter prepared to launch for search and rescue operations, rescue organizers turned 

to air traffic controllers, who called upon the aircraft’s ADS-B track and were able to 

vector the rescue helicopter directly to the aircraft’s last known position. Barely two and 

a half hours after he was reported missing, the pilot had been picked up, alive. 
74

More recently, in December 2008, in Colorado, where the installation of a wide-area 

multilateration (WAM) system was being tested, a glimpse of the benefit from having 

flight tracking data for SAR was realized. WAM is a surveillance system that is less 

robust and less sophisticated than ADS-B but it can be used for tracking flights. It is 

important to note that in this instance, WAM was not being used for air traffic operations. 

However, when an aircraft was reported missing, which was not under ATC radar 

surveillance, WAM data was reviewed to locate the last tracked position of the aircraft. In 

this type of terrain, if the estimate of the location of an accident is off by one valley, a 

day can be added to any search effort. The WAM data in this test-environment instance 

reduced the search area from what would have been approximately a 30 by 30-mile area 

to a 1 by 1-mile area. The site was located within 3.5 hours of the accident. 

Unfortunately, there were no survivors but if there were, the likelihood of survival would 

have been greater since the threat of death from exposure to the elements would not have 

been a factor. 

6.3 Enhanced Surveillance Where Radar is Currently Weak

 

The FAA's ADS-B rule is designed to replicate the coverage of FAA's current alignment 

of surveillance radars. The degree to which actual ADS-B coverage may exceed this 

requirement is currently unknown. Since ADS-B ground stations are smaller, cheaper, 

and more flexibly deployed than conventional radar installations, it will be easier for the 

FAA to expand surveillance coverage and broadcast services than it is today. The 

effective range of ADS-B ground stations is still limited by line of sight considerations, 

but can extend down to the ground and can receive ADS-B signals from over 200 miles 

away. The relatively small size of ADS-B ground stations should enable greater 

scalability of NAS surveillance, even in areas with challenging terrain such as the Rocky 

Mountains. An ADS-B compatible multilateration system designed to provide 

surveillance to mountainous airports is already under development in the state of 

Colorado. Opportunities for expansion of NAS surveillance capability will be examined 

on a case-by-case basis. Surveillance can also be established through parties entering into 

agreements with the FAA that provide ADS-B services given considerations such as 

future ADS-B applications testing, early equipage of ADS-B avionics, or cost-sharing. 

The FAA’s SBS office has supported analysis of this additional service coverage at 

airport locations below the current minimum radar coverage. FAA estimates that there 

are potentially 1048 airports which may benefit from this coverage. The maximum 

potential aggregate national benefit, based on standard ASR benefit criteria, is projected 

to have a net present value (NPV) of $610 million but this does not account for any 

marginal costs for extending the currently proposed ITT ADS-B laydown and is not 

currently part of the proposed investment program. 

Additionally, various states including Minnesota and Wisconsin are contemplating piggy 

backing onto FAA’s ITT ADS-B implementation contract to expand the coverage beyond 

the current laydown to fill in gaps. For instance 5 airports in Minnesota will gain 

coverage under the ITT laydown that are not currently covered down to 2000’ AGL. 

Minnesota is examining a supplementary purchase of ADS-B receivers to fill gaps in its 
75

coverage for another 16 airports and Wisconsin is contemplating purchasing two 

receivers to cover 13 airports. 
76

Appendix A Legacy Infrastructure Costs

Table A.1 

Legacy Sustain Costs Under ADS-B Out Scenario 2009 $ 

Legacy Sustain 

Airborne

Legacy Sustain 

Surface

Total Legacy 

Sustain

3% Discount 

Rate

7% Discount 

Rate

Legacy 

Sustain 

Discounted 

at 3%

Legacy 

Sustain 

Discounted 

at 7%

Total $588,393 $171,506 $759,899 $643,599 $530,535

Year

2009 $61,644 $24,084.52 $85,728 1 1 $85,728 $85,728

2010 $42,336 $19,223.37 $61,559 0.9709 0.9346 $59,766 $57,532

2011 $40,600 $16,054.30 $56,654 0.9426 0.8734 $53,402 $49,484

2012 $40,580 $17,320.57 $57,901 0.9151 0.8163 $52,988 $47,264

2013 $40,561 $14,252.63 $54,814 0.8885 0.7629 $48,702 $41,817

2014 $40,543 $14,252.63 $54,795 0.8626 0.7130 $47,267 $39,068

2015 $40,524 $14,252.63 $54,777 0.8375 0.6663 $45,875 $36,500

2016 $40,507 $13,528.50 $54,035 0.8131 0.6227 $43,935 $33,650

2017 $40,489 $19,551.44 $60,040 0.7894 0.5820 $47,396 $34,944

2018 $39,425 $12,306.07 $51,731 0.7664 0.5439 $39,647 $28,138

2019 $38,362 $6,679.76 $45,042 0.7441 0.5083 $33,515 $22,897

2020 $37,302 $0.00 $37,302 0.7224 0.4751 $26,947 $17,722

2021 $32,900 $0.00 $32,900 0.7014 0.4440 $23,075 $14,608

2022 $28,505 $0.00 $28,505 0.6810 0.4150 $19,410 $11,828

2023 $24,116 $0.00 $24,116 0.6611 0.3878 $15,944 $9,353

2024 $0 $0.00 $0 0.6419 0.3624 $0 $0

2025 $0 $0.00 $0 0.6232 0.3387 $0 $0

2026 $0 $0.00 $0 0.6050 0.3166 $0 $0

2027 $0 $0.00 $0 0.5874 0.2959 $0 $0

2028 $0 $0.00 $0 0.5703 0.2765 $0 $0

2029 $0 $0.00 $0 0.5537 0.2584 $0 $0

2030 $0 $0.00 $0 0.5375 0.2415 $0 $0

2031 $0 $0.00 $0 0.5219 0.2257 $0 $0

2032 $0 $0.00 $0 0.5067 0.2109 $0 $0

2033 $0 $0.00 $0 0.4919 0.1971 $0 $0

2034 $0 $0.00 $0 0.4776 0.1842 $0 $0

2035 $0 $0.00 $0 0.4637 0.1722 $0 $0
77

Table A.2 

Legacy Backup Cost for ADS-B Out Surface and Airborne Backup (2009 K$) 

Legacy Backup 

Surface

Legacy 

Backup 

Airborne

Total Legacy 

Backup

3% 

Discount 

Rate

7% 

Discount 

Rate

Total Legacy 

Backup 

discounted 

at 3%

Total 

Legacy 

Backup 

discounted 

at 7%

Total $0 $812,255 $812,255 $487,113 $263,286

Year

2009 $0 $0.00 $0 1 1 $0 $0

2010 $0 $0.00 $0 0.9709 0.9346 $0 $0

2011 $0 $0.00 $0 0.9426 0.8734 $0 $0

2012 $0 $0.00 $0 0.9151 0.8163 $0 $0

2013 $0 $0.00 $0 0.8885 0.7629 $0 $0

2014 $0 $18,423.60 $18,424 0.8626 0.7130 $15,892 $13,136

2015 $0 $18,423.60 $18,424 0.8375 0.6663 $15,429 $12,276

2016 $0 $18,423.60 $18,424 0.8131 0.6227 $14,980 $11,473

2017 $0 $18,423.60 $18,424 0.7894 0.5820 $14,544 $10,723

2018 $0 $18,988.94 $18,989 0.7664 0.5439 $14,553 $10,329

2019 $0 $19,554.28 $19,554 0.7441 0.5083 $14,550 $9,940

2020 $0 $20,119.62 $20,120 0.7224 0.4751 $14,535 $9,559

2021 $0 $22,332.81 $22,333 0.7014 0.4440 $15,664 $9,916

2022 $0 $24,546.00 $24,546 0.6810 0.4150 $16,715 $10,186

2023 $0 $8,604.32 $8,604 0.6611 0.3878 $5,688 $3,337

2024 $0 $54,134.42 $54,134 0.6419 0.3624 $34,747 $19,621

2025 $0 $54,134.42 $54,134 0.6232 0.3387 $33,735 $18,337

2026 $0 $54,134.42 $54,134 0.6050 0.3166 $32,752 $17,138

2027 $0 $54,134.42 $54,134 0.5874 0.2959 $31,798 $16,016

2028 $0 $54,134.42 $54,134 0.5703 0.2765 $30,872 $14,969

2029 $0 $54,134.42 $54,134 0.5537 0.2584 $29,973 $13,989

2030 $0 $54,134.42 $54,134 0.5375 0.2415 $29,100 $13,074

2031 $0 $54,134.42 $54,134 0.5219 0.2257 $28,252 $12,219

2032 $0 $54,134.42 $54,134 0.5067 0.2109 $27,429 $11,419

2033 $0 $54,134.42 $54,134 0.4919 0.1971 $26,631 $10,672

2034 $0 $54,134.42 $54,134 0.4776 0.1842 $25,855 $9,974

2035 $0 $28,935.91 $28,936 0.4637 0.1722 $13,417 $4,983
78

Table A.3 

Radar Decommissioning Costs (2009 K$) 

Decommission

ing

3% Discount 

Rate

7% 

Discount 

Rate

Decommissi

oning Costs 

Discounted 

at 3%

Decommissioni

ng Costs 

Discounted at 

7%

Total $42,589 $29,636 $18,663

Year

2009 $0 1 1 $0 $0

2010 $0 0.9709 0.9346 $0 $0

2011 $0 0.9426 0.8734 $0 $0

2012 $0 0.9151 0.8163 $0 $0

2013 $0 0.8885 0.7629 $0 $0

2014 $0 0.8626 0.7130 $0 $0

2015 $0 0.8375 0.6663 $0 $0

2016 $416 0.8131 0.6227 $338 $259

2017 $623 0.7894 0.5820 $492 $363

2018 $3,740 0.7664 0.5439 $2,866 $2,034

2019 $3,740 0.7441 0.5083 $2,783 $1,901

2020 $3,532 0.7224 0.4751 $2,551 $1,678

2021 $8,726 0.7014 0.4440 $6,120 $3,874

2022 $8,726 0.6810 0.4150 $5,942 $3,621

2023 $7,479 0.6611 0.3878 $4,945 $2,901

2024 $5,609 0.6419 0.3624 $3,600 $2,033

2025 $0 0.6232 0.3387 $0 $0

2026 $0 0.6050 0.3166 $0 $0

2027 $0 0.5874 0.2959 $0 $0

2028 $0 0.5703 0.2765 $0 $0

2029 $0 0.5537 0.2584 $0 $0

2030 $0 0.5375 0.2415 $0 $0

2031 $0 0.5219 0.2257 $0 $0

2032 $0 0.5067 0.2109 $0 $0

2033 $0 0.4919 0.1971 $0 $0

2034 $0 0.4776 0.1842 $0 $0

2035 $0 0.4637 0.1722 $0 $0
79

Table A.4 

Other Legacy Costs for ADS-B Out Scenario (2009 K$)

Legacy 

Upgrade 

Remaining 

ASDE-3 

Surface

3% Discount 

Rate

7% Discount 

Rate

ASDE-3 

Discounted 

at 3%

ASDE-3 

Discounte

d at 7%

Total $252,998 $204,828 $162,372

Year

2009 $0.0 1 1 $0 $0

2010 $0.0 0.9709 0.9346 $0 $0

2011 $6,222.9 0.9426 0.8734 $5,866 $5,435

2012 $76,603.5 0.9151 0.8163 $70,103 $62,531

2013 $42,394.2 0.8885 0.7629 $37,667 $32,342

2014 $34,398.0 0.8626 0.7130 $29,672 $24,525

2015 $7,313.5 0.8375 0.6663 $6,125 $4,873

2016 $7,313.5 0.8131 0.6227 $5,947 $4,554

2017 $3,045.1 0.7894 0.5820 $2,404 $1,772

2018 $3,045.1 0.7664 0.5439 $2,334 $1,656

2019 $3,045.1 0.7441 0.5083 $2,266 $1,548

2020 $3,045.1 0.7224 0.4751 $2,200 $1,447

2021 $21,115.2 0.7014 0.4440 $14,810 $9,375

2022 $3,045.1 0.6810 0.4150 $2,074 $1,264

2023 $3,045.1 0.6611 0.3878 $2,013 $1,181

2024 $3,045.1 0.6419 0.3624 $1,955 $1,104

2025 $3,045.1 0.6232 0.3387 $1,898 $1,031

2026 $3,045.1 0.6050 0.3166 $1,842 $964

2027 $3,045.1 0.5874 0.2959 $1,789 $901

2028 $3,045.1 0.5703 0.2765 $1,737 $842

2029 $3,045.1 0.5537 0.2584 $1,686 $787

2030 $3,045.1 0.5375 0.2415 $1,637 $735

2031 $3,045.1 0.5219 0.2257 $1,589 $687

2032 $3,045.1 0.5067 0.2109 $1,543 $642

2033 $3,045.1 0.4919 0.1971 $1,498 $600

2034 $3,045.1 0.4776 0.1842 $1,454 $561

2035 $5,870.5 0.4637 0.1722 $2,722 $1,011
80

Appendix B – Reduced Delay over Gulf of Mexico 

Increased Capacity over the Gulf of Mexico - Benefits of Reduced Delay

Current non-radar separation in the Gulf of Mexico constrains the number of flights that 

can operate in each of the Air Route Traffic Control Center Gulf (ARTCC) sectors 

(ZHU79 and ZHU72). According to ZHU controllers many flights experience ground or 

air delay because of this constrained airspace. Currently delay only occurs during highly 

seasonal peak traffic days.82 As demand increases we expect days with delays to

increase. 

The first step in the analysis was to estimate the increase in capacity that might 

reasonably be achieved by radar-like separation. Discussions with representatives from 

Houston Center revealed that the monitor alert parameter (MAP) value 83 is 12 for Sector 

ZHU 72and 18 for sector ZHU 79, the two sectors comprising the high altitude airspace 

over the Gulf of Mexico. The average time an aircraft spends in the region (both sectors) 

is 32 minutes. Combining these gives an hourly capacity of 56 aircraft in today’s 

environment. Once ADS-B Out is implemented in the Gulf of Mexico and assuming a 5 

mile separation standard is approved based on ADS-B Out data being available for 

separation purposes, the hourly capacity for sectors in the Houston CTA84/FIR 85 is 

estimated to increase from 56 to 84 aircraft. This capacity is higher than that used in the 

NPRM due to the following recently planned enhancements not originally known: 

Houston Center is now planning a 3rd GOMEX high altitude sector raising the combined 

MAP value for all 3 sectors to an estimated 45; second, a new RNP-10 route structure 

will add to the number of routes available and thereby add to the capacity of the airspace; 

third, Merida Center plans to add an additional high altitude sector to increase Mexico’s 

capacity in receiving and transferring aircraft across the common boundary with Houston, 

and lastly, additional capacity at key airports in Mexico is expected to be complete soon, 

further alleviating the constraints built into the original capacity estimates for Mexico. 

We started with actual operations over the Gulf of Mexico for each day in 2008. This 

data was obtained from the FAA Air Traffic Data Activity System (ATADS) Houston 

Oceanic operations counts for each day in 2008. 86

 

For example, on December 31, 2008, there were a total of 308 oceanic operations tracked 

by the Houston Center (ZHU). This represents the number of operations over the Gulf of 

Mexico on that day as displayed in Table B.1 below.

 

82 ATO En Route Services, Surveillance and Broadcast Services Benefits Basis of Estimate, June 2006, 

FAA ATO, pg. 41. 

83 The MAP value is the maximum number of aircraft that can be managed by a sector simultaneously with 

the exception that the MAP value can be exceeded for brief intervals. 

84 Control Area: A control area is airspace wholly contained beyond the 12 mile limit whereby an ICAO 

state has been designated as the ATS authority for the control of air traffic 

85 Flight Information Region: FIR’s designate regions for informational service's only, not ATC control.

86 Available on the FAA Office of Policy and Plans (APO) website: http://www.apo.data.faa.gov/ 
81

Table B.1 

Number of Flights over the Gulf of Mexico on 12/31/2008 

CENTERS: Oceanic

Oceanic 

 

Departures Overflights 

 

Date Air

Carrier

Air

Taxi

General

Aviation Military AirCarrier

Air

Taxi

General

Aviation Military Total Total

12/31/2008 0 0 0 0 267 4 18 19 308 4,702

Total: 0 0 0 0 267 4 18 19 308 4,702

In this way, we collected the number of operations over the Gulf of Mexico for every day 

in 2008. The second column of Table B.2 (highlighted in yellow) gives a snapshot of the 

number of actual operations organized from high to low for the 31 days in 2008 with the 

highest number of operations. The highest operation day in 2008 was 616. Then we 

reduced the number of operations by 10% to account for operations that only made small 

incursions into oceanic sectors. The third column in Table B.2 is a snapshot of the 

starting point from which we forecast operations to represent future years. 
82

Table B.2 

Estimated Number of Flights Per Day 

ATADS 

2009

ATADS 

reduced by 

10% 1.4% 4.3% 5.2% 5.8% 5.5% 4.5% 4.2% 4.1% 4.1%

Start of 

4% growth

Day 2008 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

1 616 554 562 586 616 652 688 719 749 780 812 844 878

2 572 515 522 544 572 606 639 668 695 724 754 784 815

3 567 510 517 540 567 601 634 662 689 718 747 777 808

4 539 485 492 513 539 571 602 629 655 682 710 739 768

5 532 479 485 506 532 563 594 621 647 674 701 729 758

6 530 477 484 504 530 561 592 619 644 671 698 726 755

7 525 473 479 500 525 556 587 613 638 665 692 720 748

8 511 460 466 486 511 541 571 597 621 647 673 700 728

9 505 455 461 481 505 535 564 590 614 639 666 692 720

10 500 450 456 476 500 530 559 584 608 633 659 685 713

11 490 441 447 466 490 519 547 572 596 620 646 672 698

12 488 439 445 464 488 517 545 570 593 618 643 669 696

13 483 435 441 460 483 512 540 564 587 611 637 662 688

14 473 426 432 450 473 501 528 552 575 599 623 648 674

15 469 422 428 446 469 497 524 547 570 594 618 643 669

16 465 419 424 442 465 493 520 543 565 589 613 637 663

17 464 418 423 442 464 491 518 542 564 587 611 636 661

18 464 418 423 442 464 491 518 542 564 587 611 636 661

19 461 415 421 439 461 488 515 538 561 584 608 632 657

20 458 412 418 436 458 485 512 535 557 580 604 628 653

21 457 411 417 435 457 484 511 533 556 579 602 626 651

22 453 408 413 431 453 480 506 529 551 574 597 621 646

23 451 406 412 429 451 478 504 526 548 571 594 618 643

24 450 405 411 428 450 477 503 525 547 570 593 617 641

25 449 404 410 427 449 476 502 524 546 568 592 615 640

26 449 404 410 427 449 476 502 524 546 568 592 615 640

27 445 401 406 423 445 471 497 519 541 563 586 610 634

28 444 400 405 422 444 470 496 518 540 562 585 609 633

29 435 392 397 414 435 461 486 508 529 551 573 596 620

30 431 388 393 410 431 457 482 503 524 546 568 591 614

31 430 387 392 409 430 455 480 502 523 544 567 589 613

To forecast operations for years out to 2035, we derived total operations for the U.S. to 

and from Latin America using several forecasts from the 2009 FAA forecast. 87 We 

multiplied the average seats per aircraft (international) 88 by the scheduled passenger 

capacity and load factors 89 to obtain passengers per aircraft. Then we divided the total 

passenger traffic to and from the U.S. from Latin America 90 by the average passengers 

per aircraft91 to derive the estimated total flights and computed the percent change in 

operations from year to year, as presented in Table B.3. 

 

87 FAA Aerospace Forecasts, Fiscal Years 2009-2025, U.S. Department of Transportation, Federal Aviation 

Administration, Office of Policy and Plans. 

88 Table 9 FAA Aerospace Forecasts, Fiscal Years 2009-2025 

89 Table 13 FAA Aerospace Forecasts, Fiscal Years 2009-2025 

90 Table 8 FAA Aerospace Forecasts, Fiscal Years 2009-2025 

91 Table 9 FAA Aerospace Forecasts, Fiscal Years 2009–2025 
83

Table B.3 

Forecast of High Altitude Operations in Gulf of Mexico 
84

Using the estimated growth in operations up to year 2018 as presented in the last column 

of Table B.3 and derived from the FAA forecast 92 and an assumed 4% growth rate after 

2018, we increased each daily number of flights starting in the third column of Table B.2 

out to the year 2035. The percent change in operations (shown in the last column of 

Table B.3) is indicated on the top row of Table B.2 above (which shows a snapshot of 

flights growing per year). The specific tables from which the numbers in Table B.3 

originate in the FAA forecast are indicated in the top row of Table B.3. 

Next we took our forecast (Table B.2 – Estimated Number of Flights per Day) and 

counted the number of days for each year that would experience operations falling into 

various daily demand groupings. Table B.4 presents a snapshot of these groupings for 

selected years. For instance, we estimate that in 2015 there will be four days during 

which high altitude operations will be less than 200, 33 days with operations from 200 to 

249, 42 days with 250 to 299 operations and so on. 

 

92 FAA Aerospace Forecasts Fiscal Years 2006-2017, U.S. Department of Transportation, Federal Aviation 

Administration Office of Policy & Plans. 
85

Table B.4 

Unconstrained Daily Demand 93

In order to estimate the delay for each level of operations under the base case scenario 

(no surveillance over the Gulf) and under the ADS-B Out scenario (ADS-B surveillance 

over the Gulf) a queuing model developed by MCR Federal was used. 

To run the queuing model with hourly capacities, we needed an hourly demand profile. 

ZHU ARTCC provided the hourly demand profile based on the four busiest days in 2003. 

This profile was applied to the midpoint of each of the daily operations groupings to 

derive an hourly demand profile for each level of operations. Table B.5 displays the 

hourly demand profile for a day for 675 flights (representing the midpoint of operations 

from 650 to 699). For example, 12.8% of the 675 operations or 86 operations occurs at 

10 a.m. 

 

93 A complete table of unconstrained daily demand showing number of days for each year from 2009 to 

2035 in each daily demand group can be found in Table B.14 below. 
86

Table B.5 

Hourly Demand Profile on Peak Days 

This hourly demand distribution for the midpoint of each daily demand grouping was 

input into the queuing model. The queuing model was then run for the base case capacity 

(56 aircraft per hour) and the surveillance capacity (84 aircraft per hour). The queuing 

model produced a probability distribution of delay minutes for each grouping. 

We assume that delays beyond 20 minutes per flight are not acceptable 94 and we will not 

accommodate demand for flights if the delay is expected to surpass 20 minutes. 

According to the queuing model 20-minute delays are encountered at daily flight levels 

of 675 under the baseline and 1025 under the surveillance case. We therefore constrain 

demand at 675 for the baseline and at 1025 for the surveillance case. Table B.6 shows 

demand constrained at 675 flights for the baseline and Table B.7 shows demand 

constrained at 1025 flights for the surveillance case. 

 

94 “approximately 20 minutes represents the highest level of average delay realized in actual practice even 

at highly congested airports, FAA Airport Benefit Cost Analysis Guidance, page 16, FAA Airport Benefit

Cost Analysis http://www.faa.gov/regulations_policies/policy_guidance/benefit_cost/media/faabca.pdf 
87

Table B.6 

Daily Demand Constrained at 675 Flights 95 – Baseline 

 

95 A complete table of daily demand constrained at 675 flights showing number of days for each year from

2009 to 2035 in each daily demand group up to and including 675 can be found in Table B.22 below. 
88

Table B.7 

Daily Demand Constrained at 1025 Flights – Surveillance Case 

Table B.8 shows the results of the queuing model when run for a daily demand level of 

675. The results show that at 675 daily flights there will be 13500 minutes of total delay 

for the base case capacity and 86 minutes total delay for the surveillance capacity at the 

50th percentile. This works out to 20 minutes per flight under the base case and .13 

minutes per flight under the surveillance scenario. The daily savings in hours between 

the base case and surveillance case is estimated to be 224 at a daily flight level of 675 

((20-.13) x 675/60). 
89

Table B.8 

Delay for Baseline (56/hour) and Surveillance (84/hour) 

Scenarios at a Daily Flight Level of 675 

At daily demand levels beyond 675, for the base case since we capped flights at 675 we 

calculate delay of 20 minutes for each of the 675 flights ((20 x 675)/60=225 hours). 

Then we subtract the surveillance delay which is (.41 x 725)/60 = 4.95) and subtract from 

the baseline delay (225-4.95 =220 hours) for the net savings in hours with ADS-B. 

Table B.9 

Results of Queuing Model for Base Case and Surveillance Case at 725 Daily Flights 
90

The daily delay in minutes at each demand level for the baseline and surveillance is 

presented in Table B.10. For instance, at a demand level of 675 we estimated delays of 

20 minutes per aircraft under the baseline and .13 minutes with surveillance using the 

queuing model. We then convert to total delay hours per year by multiplying the delay 

times the midpoint of the daily flights (or demand) grouping times the number of days 

that we have forecast for that grouping divided by 60. So for a demand level of 675, 

under the baseline, the delay is calculated as follows: (20 x 675 x 76)/60 = 17,100. 

For the ADS-B surveillance case, delays of 20 minutes occur at 1025 flights. We do not 

accommodate flights beyond that level and calculate delay hours per year as we did for 

the baseline. So for a demand level of 975 under the ADS-B surveillance case, the delay 

is calculated as follows: (13.31 x 975 x 3)/60 = 649. 

Total delay in hours under the baseline is 22,680 and under the surveillance case it is 

2,977. The surveillance case results in a savings of 19,703 hours relative to the baseline 

in 2025 as illustrated in the table below. 
91

Table B.10 

Delay Savings for Daily Flight Levels of Demand 

We assume that capacity would be phased in starting in year 2012 to reach full 

compliance by 2020 as presented in Table B.11. 96 Therefore, the full amount of delay 

savings cannot be achieved until 2020. Table B.11 summarizes annual delay savings in 

hours and indicates phasing in of equipment with the resulting hours that we estimate will 

be saved under the surveillance case relative to the baseline. It then computes an 

economic value of the delay hours saved. The factors used in computing the economic 

value of delay savings benefits are in Table B.13. 

 

96 The phasing depends on estimated Gulf equipage and allocation of ADS-B separation to more altitudes 

over time. 
92

Table B.11 

Annual Delay Savings in Hours, Capacity Phasing, Hours Saved and Economic 

Value of Delay Savings (2009 M$) 

Table B.12 

Passenger Value of Time 97, 

98 99

 

97 Source for Passenger Capacity and Load Factor is “Supporting Documentation for the Economic Factors 

Used in Investment Analysis,” pg. 17, Federal Aviation Administration, December 7, 2006, Final. 

98 Source for Hourly Values of Time 2000 U.S. $ Per Passenger is “Economic Values for FAA Investment 

and Regulatory Decisions, A Guide, Draft final Report, December 31, 2004, Prepared for FAA Office of 

Aviation Policy and Plans. 

99 GDP Chained Price Index, Budget of the United States Government, Fiscal Year 2007, Table 10.1—

Gross Domestic Product and Deflators Used in the Historical Tables: 1940-2011. 
93

Table B.13 

Factors Used to Compute Economic Value 

The dollar value of one hour of delay savings was calculated using the factors in Table 

B.13. The distribution of traffic among air carrier and commuter, air taxi, GA and 

military was computed using the oceanic overflight data from ATADS. This provided a 

weighting for the hourly costs of delay. 

Aircraft direct operating costs (ADOC) are estimated per hour on the ground as $2,037 

for air carriers TAF, $533 for air taxis and $297 for general aviation.100 Average 

passenger value of time is derived by multiplying passenger capacity by load factor 101 to 

derive passengers per aircraft and multiplying passengers per aircraft by the hourly value 

of passenger time102. These values are presented in Table B.13. Values used to calculate 

hourly passenger value of time per aircraft is found in Table B.12. 

The value of $3,857 per one hour of delay savings was derived by taking a weighted 

average of the sum of ADOC ground operating costs and the average passenger value of 

time for each type of operations, weighted by the percent of traffic accounted for by each 

type. This value was then multiplied by the hours saved (Table B.11) each year to derive 

an economic value of delay savings. These delay savings were then discounted at 3% 

and 7%. The analysis did not take into account any downstream delay savings that might 

be achieved due to ADS-B. Downstream delay occurs when an aircraft that is delayed 

causes further delays in the system. Therefore, the benefits are underestimated. 

We estimated the benefits of avoiding delays that would be encountered by high altitude 

operations are $1.7 billion or $946 million when discounted at 3% and $463 million 

when discounted at 7%. These results are presented in Table B.11. 

 

 

100 Economic Information for Investment Analysis Data Package, Prepared for Operations Research/ATOF, pg. 6, Federal Aviation Administration, April 24, 2009. 

101 Economic Information for Investment Analysis Data Package, Prepared for Operations Research/ATOF, pg. 7, Federal Aviation Administration, April 24, 2009. 

102 Source for Hourly Values of Time 2000 U.S. $ Per Passenger is “Economic Values for FAA Investment 

and Regulatory Decisions, A Guide, Final Report, October 3, 2007, Prepared for FAA Office of Aviation 

Policy and Plans. 
94

Additional Flights Accommodated by ADS-B

As mentioned above, our analysis assumes that flight delays in excess of 20 minutes will 

not be tolerated. Demand levels that could result in flight delays above 20 minutes are 

not accommodated. The queuing analysis indicated that without surveillance over the 

Gulf, delays of 20 minutes occur at a level of operations of 675 per day. If there is 

surveillance, (as would be the case with ADS-B) delays would occur at daily flight levels 

of 1025. On days that we anticipate demand in excess of 675, ADS-B technology would 

accommodate more flights. Starting in 2014 we forecast that there will be days on which 

daily flight demand will exceed 675 as indicated in Table B.15. In this analysis we 

assume that with ADS-B surveillance flights between 675 and 1025 per day will be 

accommodated, as explained below. 

Table B.14 

Unconstrained Daily Demand 

The difference in number of flights that would be accommodated given ADS-B 

surveillance in the Gulf of Mexico are presented in Table B.15 below. For each demand 

level above 675, the difference in flights between that level and the next (50 flights) is 
95

multiplied by the number of days that we expect that level of demand according to our 

forecast. 

Table B.15 

Additional Flights Accommodated Because of Surveillance 

For instance, according to our forecast, in 2016 there will be 2 days, during which 

demand will reach 725 flights per day and one day during which it will reach 775 flights. 

ADS-B technology will allow an additional 50 flights above the level that will be 

tolerated without surveillance for each of 2 days ((725-675) x 2 = 100) and an additional 

100 flights (775-675 x 1 =100) for the one day with 775 flights. The technology will 

allow for the accommodation of 200 more flights in 2016 than the base case. 

Consumer Surplus Analysis

Assumptions

• Over the time horizon there will be no change in the size of the airplane, no 

change in the load factor and no change in the current way goods are delivered. 

• Elasticity of demand β = -1 103

. 

 

103 To better capture aggregate consumer responses to a change in federal policies, FAA frequently adopts 

a unitary elastic demand curve, for example, see FAA’s 1995 Cost Allocation Study. Estimates of the 

own-price elasticity of demand typically range between -0.7 to 1.5. The lower bound of -0.7 is frequently 

cited as an estimate for short-haul business travel while the upper bound is an estimated for long-haul 

domestic travel. In a book titled “Straight and Level: Practical Airline Economics”(2008), Stephen 

Holloway reports other own-price elasticities including a -1.04 for long-haul international business travel 

and a -1.15 for long-haul domestic business. Similarly, if one considers the meta-study conducted in 2002 

by Gillen, Morrison, Stewart, Air Travel Demand Elasticities: Concepts Issues and Measurement, a -1 

own-price elasticity clearly falls within the interval estimates reported in that study. 
96

To estimate the economic benefit associated with the additional passengers as a result of 

implementing ADS-B, a consumer surplus approach was adopted. For the purpose of 

calculating the net surplus triangle it is assumed that the demand curve over the relevant 

range of aircraft operations can be approximated by a constant elasticity of demand 

curve, i.e, P(q) = aq-1, with the price elasticity of demand equal to -1. The following 

formula is then used each year to calculate the consumer surplus associated with the 

additional passengers: 

where P(q) is the unit elasticity demand curve, Q1 is the number of passengers 

without ADS-B, Q2 is number of passengers with ADS-B. 

Figure 1 graphically illustrates this calculation for a given year. The net economic 

benefit associated with serving additional passengers is represented by the shaded area. 

The vertical axis measures the natural log of average air fare; the horizontal axis 

measures the natural log of average seats. 

Figure 1 

Table B.16 displays the data for each year used in the consumer surplus. 

P1

P2

Ln (Fare)

Q1 Q2 Ln (Seats)

Dt
97

Table B.16 Consumer Surplus Estimates 
98

Optimal and More Direct Routing Benefits 

The FAA examined the top twenty city pairs from the US to Mexico and south whose 

direct paths crossed the non-radar region for April 2003 and estimated savings in nautical 

miles (NM-I) that could result with radar-like separation. Appendix C describes in more 

detail how these savings were estimated. Table B.17 shows the savings in NM for the 

month of April 2003 for twenty city pairs over the Gulf that could have been achieved 

with the creation of more efficient routes. 104 There were a total of 4,063 flights between 

the twenty city pairs in April 2003. Of these flights, 1,105 were flights that flew through 

the non-radar region that could have benefitted from optimal routing. The table shows 

how much savings in NM could be achieved through optimal routing for flights between 

each city pair. For instance, direct routing could save 18.3 NM for flights operating 

between Miami (MIA) and Mexico City (MMMX). A potential average savings of 15 

NM could be achieved by flights that operate between the twenty city pairs. 

We estimate the number of flights per year that fly through non-radar regions and could 

potentially save 15 NM per flight with more optimal routing. In April of 2003 there were 

1105 of these flights. April represents about 9% of the yearly traffic load. We estimate 

that in 2003 there were about 12,266 flights through the non-radar regions that could 

have derived benefit from optimal routing. We estimate that these flights will grow at 

about 4% a year. Optimal routing could save each of these flights 15 NM each. Table 

B.20 below indicates the annual number of flights and total savings each year that might 

be achieved from optimal routing. 

Another 756 flights avoided the non-radar region either because the aircraft or crew may 

not be certified to fly that far from shore or because of limited capacity along the nonradar routes because of traffic. Some of these flights could be granted a more direct route 

with the advent of surveillance. We estimate that flights that could benefit from direct 

routing through the Gulf is equal to about 10.8% of the number of flights through the 

Gulf. 105

Table B.17 shows how much savings in NM could be achieved if these flights could fly 

through the non-radar area. For instance, flying through the non-radar region could save 

a flight between Miami (MIA) and Mexico City (MMMX) 30.8 NM. We estimate that 

direct routing could save these flights on average 67.8 NM per flight. 

 

104 ATO En Route Services, Surveillance and Broadcast Services Benefits Basis of Estimate, June 2006, 

Federal Aviation Administration, Air Traffic Organization, pg. 53 

105 These flights that currently avoid the non-radar regions of the Gulf are not included in the count of

flights that fly through the Gulf. 
99

Table B.17 

Optimal Route Savings Between Selected City Pairs Based on April 2003 Flights 

Table B.18 

Dollar Value of an Hour Saved with Optimal and More Direct Routing 

City 1 City2 Number of 

Flights

Count of 

flights 

already 

on 

optimal 

route or 

weather 

related

Count of 

current 

non-radar 

flights

Savings per 

flight 

current nonradar 

routes 

(nmi)

Count of 

flights that 

avoided 

region

Savings per 

flight that 

avoided nonradar route 

(nmi)

Total savings 

(nmi)

MIA MMMX 574 0 292 18.3 282 30.8 14,030

IAH MMUN 338 183 155 12.4 1922

DFW MMUN 292 156 136 2.6 354

ATL MMMX 271 152 119 5.8 690

MSP MMUN 215 215 0

ATL MMUN 219 122 97 30.6 2968

ORD MMUN 212 169 10 30.6 33 82.3 3022

JFK MMMX 217 118 99 5.8 574

CLT MMUN 198 6 8 30.6 184 82.3 15,388

EWR MMUN 185 73 61 30.6 51 82.3 6064

IAH MZBZ 183 183 0

DTW MMUN 168 117 17 30.6 34 82.3 3318

EWR MMMX 158 91 67 5.8 389

DEN MMUN 137 66 71 133.3 9464

IAH MROC 126 126 0

STL MMUN 130 130 0

IAH MGGT 116 111 0

IAH MSLP 111 111 0

PHL MMUN 108 24 9 30.6 75 82.3 6448

JFK MMUN 105 44 35 30.6 26 82.3 3211

TOTAL 4063 2197 1105 264.9 756 67,842
100

Table B.19 

Daily Demand Constrained at 625 

 
101

Table B.20 

Value of Optimal and More Direct Routing Over the Gulf of Mexico 

(2009 $M) 

 

We estimated total savings in nautical miles that could be achieved by more direct routes 

through the Gulf by estimating the number of flights that could fly these routes (10.8% of 

the number of flights over the Gulf) and multiplying that by an average savings of 67.8 

NM per flight. Because adding these additional flights into the Gulf would also add 

demand to the High Altitude capacity model, we decided that the benefit would only 

accrue on days where there is little to no delay and we chose days with a demand level of 

less than 625. To estimate number of flights per year we multiplied the number of days 

that we expected demand to be at various levels times that level and times 10.8% and 

summed all the levels. Table B.19 shows number of days each year that we would 

encounter various daily demand levels. For instance, in 2015 we expect there will be 42 

days when there will be an average demand for 275 flights. We multiply 42 by 275 and 

by 10.8% and do this for all the daily demand bins up to, but not including 675, and sum 

the results for an estimated 14,302 flights that could benefit from more direct routes over 

the Gulf. We then multiply the number of flights by the average savings per flight 

(14,302 x 67.8) to derive a total potential savings for 2015 of 971,099 NM. These 

benefits are achieved as capacity is phased in, beginning in 2012, based on industry 

equipage. We computed total savings (NM) (632,850 for 2015) by adding potential 

optimal non-radar route savings (294,600 for 2015) to potential additional flight savings 

(971,099 for 2015) and multiplying the sum by the percent capacity phasing (50% for 

2015) 

. 
102

To monetize these savings we converted total savings into hours saved by dividing total 

savings (NM) by an average airspeed of 390 (632,850 divided by 390 for 2015). We then 

converted hours saved to value of hours saved by multiplying hours saved by the sum of 

the weighted averages of aircraft direct operating costs airborne and the passenger value 

of time as presented in Table B.18 ($5,599). Refer to Table B.20 for potential savings in 

miles, savings converted to total savings in miles, total savings in hours and total savings 

converted to dollars (benefits) and discounted benefits. 

The result was an estimated benefit of $384.37 million dollars ($245.39 million when 

discounted by 3% and $143.82 million when discounted by 7%) as indicated in Table 

B.20. 
103

Table B.21 

Unconstrained Daily Demand 
104

Table B.22 

Daily Demand Constrained at 675 Flights 
105

Table B.23 

Daily Demand Constrained at 1025 Flights 
106

Table B.24 

Additional Flights
Appendix C Optimal Routing 

Details on Optimal Routing of High Altitude Operations Over the Gulf of Mexico

Optimal Routing Of High Altitude Operations Over the Gulf of Mexico 

Problem: Due to the lack of surveillance and limited communication at high altitudes, 

non-radar separation procedures restrict aircraft to the available airways. 

Capability/Direct Impact: By providing surveillance and improved communication 

services, radar-like separation can be applied which enables enhanced dynamic air traffic 

management. Enhanced dynamic traffic management can, in effect, increase the number 

of available airways by granting directs. 

Outcome/Benefit: Enhanced dynamic air traffic management increases direct routing, 

which should lead to a reduction in flight distances and times. Reduction in flight 

distances and times translates to savings in aircraft direct operating costs and passenger 

value of time. 

Baseline Information: Current flights between Gulf city pairs either file one of the 10 

available non-radar routes, or file a path that avoids the non-radar region completely. 

Figure 1 displays the non-radar region, the non-radar routes, and two important SUAs 

that constrict traffic. 

Flights crossing the non-radar region of the Gulf of Mexico are constrained to routes with 

set entry and exit fixes. Because of spacing restrictions and arrival/departure stream 

flows, controllers sometimes treat routes as one-way corridors. The addition of 

surveillance across the gulf would provide more optimal routing to flights that already 

file within the non-radar region in two ways. First, it would allow new entry/exit 

locations on the U.S. side of the region. The ability to allow new entry/exit points on the 

U.S. side should allow controllers to grant more directs from U.S. locations to the fixes 

on the Mexican airspace border. Second, it would allow controllers to build additional 

routes. Although the necessity of creating one-way routes for separating arrival and 

departure streams will still exist, controllers can build these routes much closer together 

than is possible with the current non-radar separation standards. This addition of airways 

should allow both inbound and outbound traffic to fly paths closer to the optimal route. 

Flights that avoid the non-radar region may do so because the aircraft or crew may not be 

certified to fly that far away from shore, or the capacity along the non-radar routes may 

be limited due to traffic or weather [flights that are constrained due to capacity or lack of 

surveillance accounts for 10.8% of flights between city pairs]. Added surveillance should 

increase capacity along current non-radar routes and allow addition of available routes, 

and assumed equipage of these flights should allow them to take the more optimal routes 

through the Gulf. 
108

 Figure 1. Airspace and routes in the Gulf of Mexico. 

The light shaded region is the non-radar airspace. The dark shaded regions are two Special Use Airspace 

(SUA) areas. The lines in the light shaded region are the current routes through the region. 

We first examined the top twenty city pairs from the US to Mexico and south whose 

direct paths crossed the non-radar region for April 2003. We chose to examine savings in 

terms of excess distance between current routes and more direct routes, where possible. 

The data source was ETMS-recorded filed flight paths. We considered savings from the 

two general categories mentioned in the previous paragraphs. 

For flights that already fly through the non-radar region, we explored if the current route 

was the most optimum of the available routes to the destination. If not, we assumed the 

addition of surveillance would increase capacity along the more optimum route and 

additional parallel routes would be created to allow more direct paths between entry and 

exit points. In some situations, we also examined if directs from US locations to current 

fixes on the Mexican border would save distance. 

We also investigated savings for flights that avoided the non-radar region. An attempt 

was made to determine if these circuitous routes around the region were weather-related. 

If a route between city pairs was filed more than 20% of the time, we assumed that it was 

not weather-related, but involved either capacity or equipage considerations. We 

removed routes filed less than 20% of the time from the analysis. Savings for this second 
109

category focused on allowing these flights to take the more optimal non-radar region 

route. 

Table C-1 displays the excess distance data for the top twenty city pairs. The savings are 

broken into columns for flights that took routes through the non-radar regions and those 

who avoided the non-radar region. 

Table C-1 

Optimal route savings between selected city pairs 

City 1 City2 Count 

Count 

of 

flights 

already 

on 

optimal 

route or 

weather 

related 

Count 

of 

current 

nonradar 

flights 

Savings 

per 

flight 

current 

nonradar 

routes 

(NM) 

Count 

of 

flights 

that 

avoided 

region 

Savings 

per 

flight 

that 

avoided 

nonradar 

route 

(NM) 

Total 

savings 

(NM) 

MIA MMMX 574 0 292 18.3 282 30.8 14,030 

IAH MMUN 338 183 155 12.4 1922 

DFW MMUN 292 156 136 2.6 354 

ATL MMMX 271 152 119 5.8 690 

MSP MMUN 215 215 0 

ATL MMUN 219 122 97 30.6 2968 

ORD MMUN 212 169 10 30.6 33 82.3 3022 

JFK MMMX 217 118 99 5.8 574 

CLT MMUN 198 6 8 30.6 184 82.3 15,388 

EWR MMUN 185 73 61 30.6 51 82.3 6064 

IAH MZBZ 183 183 0 

DTW MMUN 168 117 17 30.6 34 82.3 3318 

EWR MMMX 158 91 67 5.8 389 

DEN MMUN 137 66 71 133.3 9464 

IAH MROC 126 126 0 

STL MMUN 130 130 0 

IAH MGGT 116 111 0 

IAH MSLP 111 111 0 

PHL MMUN 108 24 9 30.6 75 82.3 6448 

JFK MMUN 105 44 35 30.6 26 82.3 3211 

TOTAL 4063 67,842 
110

Using only these twenty city pairs and the fact that April represents 9% of the yearly 

traffic load, we estimate savings of approximately 750,000 NM a year from more optimal 

routes. 

MIA-MMMX 

While most routes across the non-radar region are already direct, there is one notable 

exception. The most travel in the non-radar region takes place between Miami and 

Mexico City (574 flights in April 2003). The northern route (292 flights April 2003) 

between Miami and Mexico City has a turn in the gulf designed to avoid an SUA just 

west of the Florida Keys. With better surveillance, a new route, or a direct could be 

granted that would cut 18 NM off the current route and still avoid the SUA. This new 

route would also be 31 NM less than the current southern route (282 flights April 2003) 

that does not penetrate the non-radar region. See Figure 2. 

Figure 2: Routes between Miami and MMMX. 

The light shaded region is the non-radar region and the dark shaded regions are two SUA areas. The solid 

lines are common northern and southern routes. The dashed line is the proposed shorter route. 

IAH-MMUN 

The current route structure includes non-radar routes that are close to the optimum path 

between major city pairs (e.g. IAH-CUN, IAH- MID). However, many times one of 

these routes is used as a one-way corridor causing flights in the opposite direction to use 
111

a non-optimum route. Although the necessity of creating one-way routes for separating 

arrival and departure streams may still exist, controllers can build these routes much 

closer together than is possible with the current non-radar separation standards. This 

addition of airways should allow both inbound and outbound traffic to fly a route closer 

to the optimal route. 

During April 2003 there were 338 flights between IAH and MMUN. Half the flights 

(nearly all from IAH to MMUN) flew on the solid path flown in Figure 3. If we assume 

the same departure path (which ends on the MUSYL fix), we find that the dotted path 

(not a current route) is 12 NM shorter than the flown route. Most of the flights from 

MMUN to IAH already go on a very direct route. There were very few flights that did 

not cross the non-radar region between these cities, and their path may be weather 

related. 

Figure3: Route from IAH to MMUN. 

The solid line is most common route April 2003; the dashed line is shorter route by 12 miles. The light 

shaded region is the non-radar region.
112

Northeast-MMUN 

Most of the flights during April 2003 from CLT, JFK, and EWR to MMUN and back 

generally followed one of the three paths seen in Figure 4. Most flights from ATL to 

MMUN and some from both DTW and ORD also took similar routes to MMUN with 

some variation at the extreme North of Figure 4. Between all of these city pairs there are 

more routes that avoid the non-radar region (Florida route) than can be explained because 

of weather. 

If capacity were to increase because of surveillance, then most of these flights could take 

a route close to the optimum middle route (dashed path in Figure 4) saving 30.6 NM over 

the western case and 80.2 NM over the Florida route. 

Figure 4. Routes between Northeast and MMUN. 

All lines are common routes (April 2003). The dashed line is most optimum route. The light shaded region 

is the non-radar region and the dark shaded regions are two SUA areas. 
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East-MMMX 

Flights from JFK, EWR, and ATL to MMMX during April 2003 generally took one of 

the two routes shown in Figure 5. The southern route is more direct by 5.8 NM. If 

capacity were to increase, more of these flights could take a route closer to the southern 

route. A few of the recorded flights took routes that did not penetrate the non-radar 

region. There were so few of these that we assume these deviations were weather related. 

Figure 5. Routes between East and MMMX. 

The solid lines are common routes. The light shaded region is the non-radar region and the dark shaded

regions are two SUA areas. 

DEN-MMUN 

Flights from DEN to MMUN in April 2003 took one of two routes. Over half filed a 

southern route that entered Mexico near McAllen, Texas and hugged the coast before 

flying to MMUN (dotted path in Figure 6). The more direct filed route through the nonradar region is over 400 NM shorter than the southern route. 

Over half the return flights from MMUN to DEN have filed routes that start with a 

NAVAID directly across from McAllen, Texas. We suspect that these flights also 

followed a route similar to those on the trip from DEN to MMUN and ETMS truncates 

the data when the flight is passed to the US. However, to be conservative, we use the 
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direct path from MMUN to McAllen to estimate all the southern routes between DEN 

and MMUN. Using this route we find that flights that use the non-radar region route save 

133 NM each. 

Figure 6. Routes between DEN and MMUN. 

Lines are common routes. The dark shaded region is the non-radar region. 

Other flights: 

Midwest-MMUN: Flights between STL and MSP in April 2003 generally took one of 

two routes across the non-radar region. The flights picked up both of these routes near 

New Orleans. The distance difference was negligible. Most flights from ORD and half 

the flights from DTW also take these paths. The other ORD and DTW flights take an 

eastern route that coincides with the traffic from the Northeast to MMUN. 

IAH-other cities: Nearly all the flights from IAH to Central or South American cities in 

the top twenty follow a single path that already exits at the most direct point available on 

the Mexican border (fix MARTE). 

DFW-MMUN: These flights are already generally direct. We could calculate a slight 

savings of 2.6 NM a flight by sending planes going from DFW to MMUN direct from the 

end of the departure path from DFW (BILEE fix) to the exit point on the Mexican border 

(KEHLI fix) instead of going first to the entry point on the U.S. side of the current non-
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radar area (KLAMS fix). The return flights (also on A766) were already optimum. This 

gives a total savings in April 2003 of 354 NM. 
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Appendix D Conflict Probe Sensitivity Analysis 

The conflict probe benefit area was one of the two benefit areas for which we estimated a 

range of low and high benefits. There is some amount of uncertainty regarding how 

frequently air traffic controllers act on URET alerts. As explained above, studies and 

subject matter expert judgment indicate that air traffic controllers may not use conflict 

probe as frequently as originally assumed. In the regulatory evaluation we estimated 

results assuming controllers act on 10% of the URET conflict probe alerts for the low 

benefit estimate and 63% for the high benefit estimate. 

In this section we estimate net benefits for 4 different controller act on rates: 63%, 30%, 

10% and 2% holding all other variables constant. The highlighted lines show results 

from the regulatory evaluation. The conclusion that we draw is that the act-on rate does 

not have much of an impact on the final conclusions. Regardless of the rate that 

controllers act on conflict alerts, given our assumptions, if all other benefits are high and 

costs are low, the rule will be cost beneficial. If all other benefits are low and costs are 

high the rule will not be beneficial at any of the act-on rates considered when the results 

are discounted. 
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Appendix E A Timeline of ADS-B Out Costs and Benefits 

Timeline of ADS-B Out Costs (millions of undiscounted 2009 $) 

Notes: Avionics costs include equipment acquisition, installation costs, fuel burn, mean time between 

failure and mean time to repair. 
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Timeline of ADS-B Out Benefits (millions of undiscounted 2009 $)