WASHINGTON, D.C. — An FAA-sponsored “call to action” summit to encourage the aviation industry to equip to meet the Jan. 1, 2020, deadline for the Next Generation Air Transportation System (NextGen) brought general aviation advocates out in force, with one message: The costs outweigh the benefits for GA pilots.
Sean Elliott, the Experimental Aircraft Association (EAA) vice president of advocacy and safety, told FAA officials that while the recreational aviation community is willing to work toward a modernization of the national airspace system, mandated ADS-B — Automatic Dependent Surveillance Broadcast, the cornerstone of NextGen — compliance is still fraught with too many hurdles to motivate general aviation aircraft owners to install the costly equipment.
Elliott emphasized that the low installation rate in GA aircraft so far — only about 6,200 aircraft out of 157,000 in the fleet — is due to a dubious cost/benefit ratio for aircraft owners.
“Even the newest ADS-B units are priced at several thousand dollars, plus $1,000 or more for installation,” said Elliott. “The expense of a single piece of equipment that costs 10% to 25% of the value of an entire airplane makes no sense to many of these aircraft owners, especially with little or no safety or situational awareness improvements, nor a reduction in cockpit workload.”
In an Oct. 28 letter sent to the FAA, Aircraft Owners and Pilots Association (AOPA) President Mark Baker noted that the minimum investment of $5,000 to $6,000 to install ADS-B-Out equipment is “far too high” for many GA pilots, especially given that the general aviation fleet includes at least 81,564 certified, piston-powered, fixed-wing aircraft that are valued at $40,000 or less, and that GA owners have no way to recoup their costs.
The actual number of GA aircraft valued at or below $40,000 could be much higher if experimental aircraft are also taken into account, he added.
Pushing ahead with the mandate as written will ground thousands of general aviation aircraft at a time when the industry is just beginning to recover from the recession, Baker warned.
“It would be irresponsible to insist on enforcing a mandate that does not reflect the realities of general aviation flying and would cause irreparable harm to this industry,” Baker wrote, adding that affordable, portable solutions for ADS-B-In exist today and urging the FAA to revisit the question of acceptable equipment to meet its ADS-B-Out mandate.
“A mandate that is neither affordable nor relevant for a majority of aircraft within the national airspace system will only create additional challenges and confusion,” EAA’s Elliott added. “The agency and the aviation community’s stakeholders cannot sugarcoat these hurdles, because they could drive people out of aviation.”
At the summit, Michael Whitaker, FAA deputy administrator, warned the mandate’s deadline is not changing.
“We are not here to rewrite the rule; rather, we are here to discuss any barriers we have in meeting the mandate,” Whitaker said in his opening remarks to begin the summit. “The mandate is not changing.”
That’s good news to the members of the Aircraft Electronics Association, whose president, Paula Derks, said at the summit that the repair station industry is “ready, willing and able” to meet the 2020 deadline.
“With more than 160,000 general aviation airplanes to equip by the deadline, the capacity for repair stations to meet the U.S. installation demand is shrinking each day,” she said. “Aircraft owners who procrastinate installing this safety-enhancing equipment will face a potential backlog as the deadline quickly approaches.”
However, she issued her own “call to action” to the FAA regarding the NextGen GA Fund, a congressionally authorized loan guarantee program designed to accelerate the rollout of NextGen by providing access to quick, affordable financial incentives to help aircraft owners finance NextGen installations. The public-private partnership formed between the U.S. Congress, the aerospace industry and the private-sector investment community has about $550 million in funding.
“Despite industry-wide efforts to promote early equipage, the FAA is dragging its feet on the incentive program by not approving the loan guarantee certificates for the NextGen GA Fund,” Derks said. “Until the FAA issues the loan guarantee certificates, nothing moves on this program. Keep in mind that the monies raised for financing these loans are from private investors. Our industry is not asking for government money; we are only asking for the FAA to issue the loan guarantee certificates as it was directed by Congress to do so. The FAA’s failure to implement the loan guarantee program as authorized by Congress is costing the industry an additional 1 to 3 percentage points when financing ADS-B equipment. It’s time for action on this issue; we need a ‘can-do’ approach from the FAA to break down this barrier to equipage, not a ‘can’t do’ culture.”
At the current cost of ADS-B there will be few single engine planes installing this equipment. For those unlucky enough to use airports under that 30 mile ring that surrounds class b airspace airports, there will be many that just depart in dark mode, transponder off, stay low and then fly out from under the ring. After that they’d probably leave the transponder off until their first stop, in case they were being tracked, not easy to track a primary radar return flying low. The cost of this equipment needs to come way down, to the level of a low cost transponder or it will not be adopted by the piston single engine fleet.
The FAA in this instance for sure is behaving like just another self serving bureaucracy which has become the norm in our federal government. They’re not there to serve their masters, the people in this democratic and constitutional republic, but to serve themselves and their own career ends. They need their career “ends” booted by those to whom they are responsible as their overseers, the Congress. Just like with the 3rd Class Medical reform issue, this too will require Congress to step in and build a fire under the FAA to get it right. It will probably take another election, the presidential election of 2016 and a change of regime, hopefully to one in which adults are in charge, before any meaningful action is taken.
Because of the expense, most GA pilots will just turn off their existing transponder if they have one and fly “under the radar” and stay away from areas that where they might actually make sense. I don’t see this making the skys safer, quite the contrary. Onerous requirements do exactly the opposite, and turns us into criminals to boot.
If they don’t reverse this requirement then I predict that some with transponders only will simply remove the transponders from their aircraft rather than upgrade to ADSB and thus join those other small airplanes that never got transponders in the first place. The removal of transponders would give the FAA even less opportunity to view general aviation aircraft rather than giving them more opportunity and control. This is commonly referred to as “back firing on them”.
A hearty “thank you” is due to those GA organizations finally substantively pushing back on this inappropriate and poorly conceived FAA ADS-B FAR 91.225/91.227 mandate. FAA’s NextGen and ADS-B plan, as presently formulated, simply isn’t going to work. Further, it isn’t going to happen at any price, because it is flawed from the foundation. Hence, loan guarantees for ADS-B are unnecessary and irrelevant because ADS-B installation isn’t going to happen the way FAA advocates. Further, FAR 91.225 and 91.227 need to be immediately suspended or rescinded. If FAA fails to do so, the necessary action must be taken by Congressional action (e.g., appropriation riders) to force FAA’s hand. Both these criteria are poorly formulated applying faulty requirements. In fact, the entire NextGen plan needs to be reviewed and reformulated by a high-level industry led group, outside of FAA’s control. If key FAA’s executives don’t yet understand the reality of the seriousness of the present FAA ADS-B deadline folly, then they too likely need to be replaced.