On Wed, 05 Mar 2008 01:24:16 GMT, (Ron Lee)
wrote in :

You can read them by accessing the Regulations.gov website via mine:

http://stopads-b.org/ADS.htm or directly he

http://tinyurl.com/33k9m2

They are on page 11 of the comments area.

Both essentially agree with my position that this is an expensive
mandate that offers very little to the typical GA pilot. I strongly
recommend reading their comments.

Ron Lee

Below are excerpts of comments of some of the key players. It appears
to me, that DoD sees ADS-B as a means to surveil aircraft operations,
and because of the sensitivity of their missions and costs to
implement, they desire noncompliance. Boeing is interested in
assuring that the NPRM is compatible with their grand ATC system. The
air carriers are hoping that ADS-B will provide enhanced NAS capacity
through reduced separation standards and additional routes. And
everyone is concerned about the cost and marginal benefits.


Here's what the DoD has to say:


http://www.regulations.gov/fdmspubli...ontentType=pdf
As a user, DoD requires access to all elements of the NAS and
requires Special Use Airspace (SUA) for conducting missions in
support of the National Security Strategy and the National
Military Strategy. Under various circumstances, e.g. age of
aircraft fleet, funding requirements, etc., some DoD aircraft may
not meet equipage requirements and will need accommodation from
the FAA to operate in the designated ADS-B Out airspace....

5) Comment: The FAA needs to continue to work with the DoD and
DHS to ensure that concerns about ADS-B security are adequately
addressed prior to the issuance of the final ADS-B rule.

Rationale: ADS_B is a new standard adopted by many aviation
authorities worldwide which offers a great leap forward in
aircraft surveillance capabilities. More information is made
available than before with conventional primary and secondary
radar technologies. Because AES_B does not require major
conventional radar ground infrastructure, by its nature, it makes
the position of aircraft in flight and intent generally available
to everyone. In this regard, DoD believes there are some
potential security vulnerabilities which need to [be] addressed.
There are several specific concerns noted in FAA planning
documents, including unauthorized use of ADS-B information for
introducing false targets/aircraft spoofing into the system. A
through security assessment involving DoD and DHS is needed to
determine ADS-B risks and appropriate countermeasures.
Additionally, a technique for detecting ADS-B spoofing which is
independent of the ADS-B system is required. ...

6) Comment: The FAA, DHS, DOJ, NSA and DoD will need to develop
operational procedures for special USG flights (such as low
observable surveillance aircraft, combat air patrol missions,
counter=drug missions, counter-terrorism missions, VIP transport,
law enforcement surveillance, etc.), that are inconsistent with
broadcasting their position over a link that can be easily
received and resolved. State aircraft, due to national security
issues, will require special accommodations in ADS-B assigned
airspace.



I found Boeing's comment also constructive:


http://www.regulations.gov/fdmspubli...ntentType=msw8
Enclosed are comments from Boeing Commercial Airplanes concerning
the subject proposed rule. While we recognize the value and merit
of ADS-B as one of the central elements of the NextGen Air
Transportation System, we find that certain requirements of the
NPRM should be substantially amended to meet this goal. The
attached comments detail our following overall concerns, which
a

" ADS-B needs to be integrated with the overall Communication,
Navigation, and Surveillance solution for increased capacity, cost
reductions, and enhanced safety.

" The NPRM should allow use of existing ADS-B equipage for early
applications, as is being done in Europe, Australia, and Canada.

" Additional equipage to support an ADS-B mandate should be
based on an agreed CNS-ATM plan and concept of operations which is
globally accepted by ANSPs.

" Financial and/or procedural incentives which ensure positive
cost/benefits and early equipage should be considered.

" The reported position accuracy, integrity, and availability
requirements should not be based on WAAS (or SBAS), as long as
transmitted positions meet the quality requirements for the
intended applications.

" The plan to continue radar separation concepts using ADS-B as
a radar replacement does not appear to be appropriate.

" All users generating ADS-B Out signals should use 1090MHz.


The Air Transport Association of America, Inc.[1] filed this comment:


http://www.regulations.gov/fdmspubli...ontentType=pdf
II. INTEREST OF ATA ATA is the principal trade and service
organization of the U.S. scheduled airline industry, and its
members account for over ninety percent (90%) of the passenger and
cargo traffic that U.S. scheduled airlines carry annually. ATA’s
members provide a full range of domestic and international
commercial air transportation services for passengers and shippers
with a combined fleet (currently) of 4,288 aircraft. The proposed
rule would apply to all airplanes that ATA members maintain and
operate and all their future airplane acquisitions. Thus, ATA and
its members have a vested interest in the outcome of this
rulemaking. ATA members also have a direct and material interest
in the efficiency, capacity and safety of the NAS. As FAA is well
aware, important sectors of the NAS often approach – and sometimes
exceed – current capacity limits, especially when weather affects
the system, which causes flight delays, inefficient routings and
increased fuel consumption, in order to maintain the highest level
of system safety. ADS-B deployment and NextGen offer significant
improvements over the existing outdated, radar-based ATC system.
These additional reasons drive ATA’s interest in this rulemaking
proceeding.

III. EXECUTIVE SUMMARY ATA strongly supports ADS-B technology and
the development and deployment at the earliest possible date of
the NextGen system. ATA consistently has expressed the view that
ADS-B is a foundational technology for NextGen. We appreciate the
FAA’s extensive, ground-breaking work underlying the ADS-B NPRM,
much of which is not credited in the proposal. However, our
principled support for ADS-B and NextGen must give way in this
instance to our concerns that the NPRM is poorly conceived and, as
a result, will not serve the public interest in a modern ATC
system that increases airspace capacity and reduces aviation’s
impact on the environment. We are also concerned that the NPRM, if
implemented as proposed, will not produce a benefit to regulated
parties (and, by extension, to the traveling and shipping public)
but will, on the other hand, commit the aviation industry to
enormous costs. Thus, as discussed in detail below, the NPRM fails
to meet important substantive objectives and it also fails to
satisfy crucial administrative requirements. Its lack of an
appropriate implementation program and relevant airworthiness
standards, and its dual-link architecture cause specific concerns.
For these reasons, ATA recommends that FAA publish a supplemental
NPRM that establishes an appropriate standard for ADS-B
performance and deploys ADS-B Out in two phases. ATA’s proposal
will, in fact, accelerate the public benefits of ADS-B technology
and advance the understanding of all stakeholders – FAA, airlines,
aircraft manufacturers and avionics manufacturers – concerning the
capabilities and limitations of ADS-B Out technology while
providing important information for developing ADS-B In standards
and applications. This will also reduce the risk of additional
equipage changes for ADS-B In in the future.


1 Members a ABX Air, Inc.; Alaska Airlines, Inc.; Aloha
Airlines; American Airlines, Inc.; ASTAR Air Cargo, Inc.; Atlas
Air, Inc.; Continental Airlines, Inc.; Delta Air Lines, Inc.;
Evergreen International Airlines, Inc.; Federal Express
Corporation; Hawaiian Airlines; JetBlue Airways Corp.; Midwest
Airlines, Inc.; Northwest Airlines, Inc.; Southwest Airlines Co.;
United Airlines, Inc.; UPS Airlines; and US Airways, Inc.
Associate Members a Air Canada, Air Jamaica Ltd. and
Mexicana....

B. FAA Should Develop Financial Incentives to Support the ADS-B
Program. As discussed in Section VIII, the proposed rule would not
specifically obligate FAA to facilitate user benefits until after
2019, when all airplanes were equipped with ADS-B Out. At that
time, airspace users could begin accumulating returns on their
investments provided that FAA reduces radar traffic separation
standards and also applies those standards to areas which
currently have no radar coverage. The Regulatory Evaluation
assesses potential limited benefits that may be available before
2020, but the proposed rule would provide no guarantee that those
benefits could be realized. In addition, there is a natural
incentive for individual operators to delay implementing ADS-B Out
until others have developed the system, and avoid assuming a
larger share of the cost of operating the NAS surveillance system.
Direct financial incentives are appropriate to counteract these
deficiencies, and encourage the development of ADS-B Out by
accelerating the availability of its benefits. The ATA concurs
with the ADS-B ARC that, “…some combination of financial
incentives and operational benefits will be needed to
significantly accelerate ADS-B equipage before the compliance date
of the proposed rule.”10 The ARC Report also cites certain
precedents for direct incentives, lists several financial methods
and timing factors that should be considered.11 The ATA emphasizes
that it would be advantageous to make incentives for ADS-B
implementation available as early as possible before the expected
2012 FAA reauthorization, and to provide incentives for in-service
ADS-B demonstrations and evaluations. The ATA recommends that FAA
develop financial incentives for airspace users to support a
recommended two-phase program, accelerate implementation, and
perform in-service demonstrations and evaluations....




http://www.regulations.gov/fdmspubli...ontentType=pdf
SANDIA Aerospace
2.3 Mixed Aircraft Types UAS are coming to the airspace at some
point in the future, they will be mixed in the light sport
aircraft, main stream general aviation, very light jets, business
jets, commercial traffic, hot air balloons, sail planes,
parachutes, military aircraft, and possibly commercial space
traffic. The current system as it is proposed cannot support all
these types in all the airspace, i.e., where there is no ground
station coverage in particular, but also because of some of the
cost drivers discussed in Section 3. Wide spread equipage with UAT
based ADS-B could solve this problem if the cost is kept down.
Again, if the cost is reasonable and the benefits are guaranteed,
long term voluntary equipage will likely happen in large numbers.
The requirement for 1090ES above FL240 seems to go against this
potential benefit. There will be ground station coverage at those
altitudes so mixed transceivers should not be a problem. However,
at lower altitudes where ground station coverage is not available
mixed equipage could become an issue. Requirement for UAT based
ADS-B in areas that do not have ground station coverage would
address this with the lower cost more capable system. UAT
transmitters and transceivers, if some of the cost drivers
discussed below were relieved, could be manufactured small,
light-weight, battery-powered, and cost effective to address all
vehicles in the airspace. These small light-weight and battery
powered units could be restricted to VFR only, and possibly from
Class A and B airspace, while greatly benefitting [sic] the
overall safety of the NAS. The NPRM currently discourages
development of such units because it implies they could not be
used long term. As an example: Section III of the NPRM states that
ADS-B out would be required for operations in Class E airspace in
the gulf, but does not specify UAT or 1090ES. UAT makes more sense
from a cost and capability perspective and equipage of one, not
either, will provide better service to all users in the NAS and
especially when they go beyond the 12 nm NAS boundary. If all the
aircraft had the same system they may be compelled to adopt ADS-B
in as well for the traffic, with or without ground station
coverage and potential for weather datalink benefits. 2.4 Future
Applications Future applications are best suited to a system with
100% or near 100% equipage. In order to achieve that level of
equipage the avionics must be cost effective. Achieving cost
effectiveness for all aviation segments would be best served by
allowing less costly navigation sources and transceivers than the
ones required by the NPRM. Allowing VFR GPS units to be used as
the navigational source for light sport, experimental, and other
low end aircraft in VFR conditions would keep their cost down and
offer benefits to the system as a whole. It would increase
voluntary equipage. Requiring aircraft that fly in areas without
ground station coverage to have UAT would also benefit the system.
This can be accomplished in two ways: 1) Put UAT ground stations
at all public use airports; or 2) require UAT on all aircraft that
land at airports that are below ground station coverage. ...