ADS-B requirement

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jrenwick
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Joined: Thu Apr 01, 2004 8:34 pm

ADS-B requirement

Post by jrenwick »

I'm reposting this because I first put it in an inappropriate place:

I'm very concerned that the ADS-B rule as currently written will do a lot of harm to airports underlying Class B airspace.

I fly out of one such: Lake Elmo Airport, MN (21D), a few miles northeast of Minneapolis-Saint Paul International (MSP). Our airport authority is actually projecting a reduction in the number of based aircraft at the MSP "reliever" airports around 2020 because of owners choosing to relocate outside the Mode C veil rather than incur the cost of ADS-B installation.

This will hurt the owners of rental hangars; it will lower hangar values overall, and even make some impossible to sell; it will squeeze the few remaining FBOs at eleven or so public airports located under our Class B airspace. The same situation probably applies to airports under any other Class B shelf in the country.

I'm even more concerned about aircraft owners based outside of the 30NM veil who won't be required to install ADS-B, and who will simply stop coming to airports near MSP (and other major airports) in 2020. This has to be a huge problem for all airport businesses located below Class B airspace.

John Collins, Government Technical Specialist at AOPA, has submitted a very well thought-out proposal that the FAA eliminate the requirement for ADS-B in aircraft operating inside the 30NM Mode C veil when below 10,000 feet, down to the surface. It deserves favorable comment, which you can submit here:

http://www.noticeandcomment.com/John-Co ... 23232.aspx

Here's the document:
John_Collins_-_Exemption_Rulemaking.pdf
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John Renwick
Minneapolis, MN
Former owner, '55 C-170B, N4401B
'42 J-3 Cub, N62088
'50 Swift GC-1B, N2431B, Oshkosh 2009 Outstanding Swift Award, 2016 Best Continuously Maintained Swift
bagarre
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Re: ADS-B requirement

Post by bagarre »

One only has to look at College Park to see the affects of extra airspace burdens on small airports. And there was no cost involved with flying there.
Even my field, W00 lost half their fleet when the SFRA was put in place.

But ADS-B? Anyone up for a $8,000 hamburger? :cry:
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GAHorn
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Re: ADS-B requirement

Post by GAHorn »

This is exactly the same issue I brought up a few months ago and couldn't seem to gain any traction with it.
If there is no intent to intrude into the Class C airspace... then there is no reason to provide ADS-B Out for ATC controlling that airspace. In addition, ATC will have radar by definition in Class C airspace...so ADS-B observation of non-entry aircraft is of no ATC benefit. This is no different than present ATC specialists who program their consoles to disregard txpdr returns above or below their sectors.

But it will make metropolitan airports outside Class C airspace unavailable to non-equipped aircraft and it will force unnecessary and expensive equipment upgrades to small aircraft who have no other use for it. It's a nail in the coffin of GA.

In the Houston area that will exclude about 2 dozen airports.... like DWH (Hooks), CXO (Conroe/Montgomery Co.), TME (Houston Exec.), Cleveland, TX, N. Houston, W. Houston, Baytown, Sugarland, Weiser, .... the list is amazing and catastrophic to General Aviation.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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GAHorn
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Re: ADS-B requirement

Post by GAHorn »

jrenwick wrote:I'm reposting this because I first put it in an inappropriate place:

I'm very concerned that the ADS-B rule as currently written will do a lot of harm to airports underlying Class B airspace.

I fly out of one such: Lake Elmo Airport, MN (21D), a few miles northeast of Minneapolis-Saint Paul International (MSP). Our airport authority is actually projecting a reduction in the number of based aircraft at the MSP "reliever" airports around 2020 because of owners choosing to relocate outside the Mode C veil rather than incur the cost of ADS-B installation.

This will hurt the owners of rental hangars; it will lower hangar values overall, and even make some impossible to sell; it will squeeze the few remaining FBOs at eleven or so public airports located under our Class B airspace. The same situation probably applies to airports under any other Class B shelf in the country.

I'm even more concerned about aircraft owners based outside of the 30NM veil who won't be required to install ADS-B, and who will simply stop coming to airports near MSP (and other major airports) in 2020. This has to be a huge problem for all airport businesses located below Class B airspace.

John Collins, Government Technical Specialist at AOPA, has submitted a very well thought-out proposal that the FAA eliminate the requirement for ADS-B in aircraft operating inside the 30NM Mode C veil when below 10,000 feet, down to the surface. It deserves favorable comment, which you can submit here:

http://www.noticeandcomment.com/John-Co ... 23232.aspx

Here's the document:
John_Collins_-_Exemption_Rulemaking.pdf

John, can you repost the notice/comment link above? (It appears broken.)
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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jrenwick
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Joined: Thu Apr 01, 2004 8:34 pm

Re: ADS-B requirement

Post by jrenwick »

gahorn wrote:John, can you repost the notice/comment link above? (It appears broken.)
Sorry about that! Try this one:

http://www.noticeandcomment.com/John-Co ... 23232.aspx

There's a "Submit a Comment" link in the middle-right of the page. Click on that, and it will take you to where you can enter comments.
John Renwick
Minneapolis, MN
Former owner, '55 C-170B, N4401B
'42 J-3 Cub, N62088
'50 Swift GC-1B, N2431B, Oshkosh 2009 Outstanding Swift Award, 2016 Best Continuously Maintained Swift
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GAHorn
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Re: ADS-B requirement

Post by GAHorn »

Thanks. I submitted a comment agreeing with Mr. Collins... and ADDED my comment that the rule should be changed to raise the ceiling to non-equipped aircraft to 12,500' MSL as a MINIMUM in lieu of the 10,000' proposed,.... and/or 14,000' MSL (or 2,000' AGL) to allow aircraft to transit mountainous areas.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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jrenwick
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Joined: Thu Apr 01, 2004 8:34 pm

Re: ADS-B requirement

Post by jrenwick »

gahorn wrote:Thanks. I submitted a comment agreeing with Mr. Collins... and ADDED my comment that the rule should be changed to raise the ceiling to non-equipped aircraft to 12,500' MSL as a MINIMUM in lieu of the 10,000' proposed,.... and/or 14,000' MSL (or 2,000' AGL) to allow aircraft to transit mountainous areas.
Thank you George!

BTW, the regulation already excludes Class E airspace at and above 10,000' MSL but below 2500' AGL. See FAR 91.225(d)(4).
John Renwick
Minneapolis, MN
Former owner, '55 C-170B, N4401B
'42 J-3 Cub, N62088
'50 Swift GC-1B, N2431B, Oshkosh 2009 Outstanding Swift Award, 2016 Best Continuously Maintained Swift
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MoonlightVFR
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Re: ADS-B requirement

Post by MoonlightVFR »

What is the estimated total cost to the aviation community directly effected by the ADS B ?

The right congressional interest in GA can help accommodation to this looming rule change. Does the AOPA have a contingent walking the halls inside the beltway?

GA needs help right now.

Regards
gradyb, '54 B N2890C
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GAHorn
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Re: ADS-B requirement

Post by GAHorn »

Despite it's name and previous reputation.... AOPA has become a huge advertising agent and competitor to the aviation service industry.
(Example: As an insurer of airplanes.... you might have always advertised in AOPA magazine... but THESE days... AOPA is your competitor!)

AOPA has drunk the Kool-Aid and is all in favor of anything which helps sell avionics and technology because it brings them so much money.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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jrenwick
Posts: 2045
Joined: Thu Apr 01, 2004 8:34 pm

Re: ADS-B requirement

Post by jrenwick »

gahorn wrote:...AOPA has drunk the Kool-Aid and is all in favor of anything which helps sell avionics and technology because it brings them so much money.
This may be true, but on the other hand:

John Collins, who wrote the draft position on eliminating the requirement below Class B airspace, works for AOPA, and wrote it in that capacity.

If you google "AOPA ADS-B," you can find things like this:
The high cost of the necessary avionics and the lack of direct benefits are the two greatest barriers to the adoption of ADS-B Out by a large segment of general aviation operators.

The current cost to install mandated ADS-B Out equipment is at least $5,000 to $6,000. An AOPA analysis of the FAA’s Aircraft Registry shows that at least 81,564, or 43 percent, of the 188,099 piston-powered, fixed-wing, certified general aviation airplanes on the FAA registry have an average retail value of $40,000 or less. The weighted average value for this segment is $25,865.

When stacked up against these numbers, the price to meet the mandate is excessive and unreasonable for a large segment of the GA fleet, especially when the operator does not derive any benefit for equipping beyond the ability to continue to fly in the same airspace used today. In order to receive the added situational awareness benefits of traffic and weather information in the cockpit, aircraft owners must also install ADS-B In equipment.
I found that here: http://www.aopa.org/Advocacy/Air-Traffi ... cast-ADS-B

At the same time, AOPA is trying to help lower implementation costs for small aircraft owners: http://www.aopa.org/News-and-Video/All- ... on-mandate

I think they're our friends on this issue.
John Renwick
Minneapolis, MN
Former owner, '55 C-170B, N4401B
'42 J-3 Cub, N62088
'50 Swift GC-1B, N2431B, Oshkosh 2009 Outstanding Swift Award, 2016 Best Continuously Maintained Swift
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