It must have seemed straightforward enough to FAA planners. They had laid down a mandate back in 2010 that by midnight on Dec. 31, 2019, all aircraft flying in the NAS must carry ADS-B avionics. Surely, the planners reckoned, 10 years’ notice was enough time for everyone to comply.
It hasn’t quite worked out that way and, with five years to go, full industry compliance by 2020 is starting to look a tad unlikely, despite the FAA’s recent dire and unequivocal warnings that the deadline is real and unyielding for everyone. Hence the agency’s October 28 “Call to Action” meeting, which summoned representatives of 54 airlines, OEMs, avionics manufacturers and associated alphabet organizations to Washington to examine the impediments to compliance experienced by the close to 200,000 U.S.-registered aircraft that are still unequipped, versus the less than 5,000 that are. Media representatives were not invited.
Possibly, the FAA planners expected that the 54 invited organizations and their more than 100 attendant representatives at the summit would listen up and promptly get the show back on the road, following FAA Deputy Administrator Whitaker’s earlier exhortation to operators that “the ADS-B infrastructure has been completed, so we have done our part of the bargain.”
Impediments to Equipage
So what impediments did attendees raise? Here are samples from three key players.
Doug Carr, NBAA vice president of regulatory and international affairs, noted that “NBAA has been engaged on ADS-B with the FAA for many years, and we will continue that engagement as we approach the 2020 deadline.” However, Carr expressed concerns about the challenges of maintaining privacy on ADS-B-equipped aircraft, particularly with the increasing number of private, and uncontrolled, Internet-based aircraft tracking programs. How can those be limited, he asked? Other concerns included the continuing presence of RAIM “holes” at certain locations which can affect departures; the need to upgrade FAA ATC technology to match that of new aircraft to reap benefits from operators’ investments; the delay in FAA adoption of the Congressionally approved equipment financing program; the removal of system inefficiencies that limit direct routes and increase fuel burn; and the need for greater international operational standardization.
In a letter to the FAA before the meeting, AOPA president Mark Baker urged the agency to quickly address the economic impacts of the mandate and the logistical challenges of meeting them. “The minimum investment of $5,000 to $6,000 to install ADS-B-out equipment is far too high” for many GA operators, he said, “especially given that roughly half of the general aviation fleet includes more than 81,000 certified, piston-powered, fixed-wing aircraft–not including experimental aircraft–that are valued at $40,000 or less, and GA owners have no way to recoup their costs of new equipage.”
At the meeting, Jim Coon, AOPA senior vice president for government affairs and advocacy, noted that the weighted median retail value of those 81,000 aircraft is $25,000, and added that unless alternative solutions to the ADS-B-out cost barrier are found, “we risk parking thousands of GA aircraft because of the mandate in its current form”
Might the mandate change to accommodate those who risk having to park their aircraft after Dec. 31, 2019? Not according to the FAA’s Whitaker, who reiterated unequivocally, in his opening remarks, “We are not here to rewrite the rule; rather, we are here to discuss any barriers we have in meeting the mandate. The mandate is not changing.”
Accordingly, Paula Derks, president of the Aircraft Electronics Association, whose members operate virtually all of the nation’s avionics shops, stated at the meeting that “the repair industry is ready, willing and able to meet the ADS-B-out mandate,” as the shops are trained and prepared for the Dec. 31, 2019 deadline.
However, she pointed out, while Congress had long ago approved the creation of an FAA-administered public/private partnership to help aircraft operators purchase ADS-B and other NextGen avionics, the agency has not formally advised the avionics industry or the aircraft operators that such a program even exists, let alone provide information about its terms and conditions. As each day passes, the backlog of potential funding applicants grows larger and larger. What’s more, it isn’t as though the FAA will be miserly handing out public money to outfit executive barges: this will be private investors’ money, not taxpayers’ money, and it is available down to the smallest Cessna, which does raise a key question.
While the shops have been diligently spending money building staffing numbers and inventory to prepare for the approaching tidal wave of ADS-B-out business (the 200,000 unequipped aircraft) has the FAA been equally busy recruiting and training the team of employees that can cope with such an onslaught of funding applications?
Although not widely reported, AIN understands that certain airlines and the FAA are said to recognize that the 2020 mandate could make a full ADS-B transition awkward. But this is not because of delayed installation of ADS-B-out units. Rather, it would be because the legacy GPS units in some older aircraft–such as earlier 737s–don’t meet a key performance characteristic known as SA-AWARE, which is required to provide the higher accuracy and integrity levels of today’s ADS-B-out. AIN learned that the affected air carriers had proposed being granted some “flexibility” by way of an extension to the mandate to 2025. Possibly, the extension may have to do with the expected overseas sale of those aircraft although, in theory, they should not be allowed to fly in the NAS after 2019. Nevertheless, it was suggested that FAA officials had committed to work out a framework for those carriers within which such an extension could be accommodated.
Airline Response
Representatives from the Regional Airline Association and from the association’s Flight Technology Committee participated in the FAA’s Call to Action meeting. “Like other commercial operators, our members will have to meet this modernization effort by 2020 and are working with aircraft manufacturers and the FAA toward potential solutions for this implementation schedule to ensure our fleets are ready, said Stacey Bechdolt, senior director, safety and technical affairs and regulatory counsel.
Following the October 28 Call to Action, Airlines for America (A4A) stated, “We appreciate the FAA’s call to action and willingness to discuss how ADS-B can be used effectively. ADS-B has the potential to deliver important benefits to the traveling public and the national airspace system. Today, stakeholders were able to share with the FAA the need to ensure international standardization and deliver benefits from this important technology. We hope the FAA responds positively to ensure this important capability can be used.”
The next step in the FAA’s outreach process will be resolving the barriers to avionics installations identified at October’s Call to Action. For this, a working group called Equip 2020 has been formed under the NextGen Institute, and led by Maj. Gen. Marke “Hoot” Gibson, USAF Ret., executive director of the NextGen Institute. The first meeting date for Equip 2020 was scheduled for November 18.
Will your current GPS be compatible with your new ADS-B out unit?
After its ADS-B Call to Action meeting, the FAA distributed to attendees a summary of the barriers to compliance by midnight on Dec. 31, 2019, that were raised at the meeting. The eight-page summary describing the barriers, and the FAA’s proposed 32 individual action plans to overcome them, was to be reviewed at the first meeting of the Equip 2020 working group on November 18. While the action plans deal separately with issues affecting air carriers and general aviation, the proposed air carrier solutions may also be applicable to corporate operators.
Of particular importance is the summary’s note regarding the use of certain legacy GPS receivers as ADS-B position sources. The summary stated:
In the final ADS-B out rule, the FAA identified three [GPS] solutions capable of consistently meeting the performance requirements under all conditions; the third-generation and fourth-generation receivers, and tightly coupled inertial reference units. Operators who equip with other position sources, such as first and second-generation GPS receivers, may experience outages that limit their access to the airspace defined in the rule, according to the agency.
Within the large transport-category aircraft community, several aircraft manufacturers currently offer only the first two generations of GPS receiver (compliant with FAA TSO-C129 and TSO-C196). Third-generation receivers are scheduled to be available in 2018 (compliant with TSO-C145), and fourth-generation receivers that take advantage of modernized GPS and other constellations will not be available until after 2020.
AIN understands that certain GPS receivers manufactured by specific companies do, in fact, meet the accuracy and integrity standards demanded by ADS-B in the 2010 final rule. These GPS systems make use of third-generation GPS receivers meeting TSO C-145/146. At least one manufacturer claims its GPS systems are already compatible with Egnos and other SBAS augmentation systems. Consequently, operators are encouraged to confirm the level of ADS-B position source compliance of their GPS units with their manufacturers.