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Comment against the ADS-B Out NPRM or you will have to waste up to
$17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee |
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On Sat, 16 Feb 2008 16:12:11 GMT, (Ron Lee)
wrote in : Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee It would seem that there is about a 12 hour deficit in our comment period: http://nerulepcfs01.erulemaking.net/outage.htm Thank you for visiting Regulations.gov. We are currently conducting planned system maintenance that began at 7:35:05 AM on February 16, 2008 and should be complete by 06:00PM. We appreciate your patience as we work to keep the site operating at peak performance. |
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![]() "Ron Lee" wrote in message ... Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee Prove it, dickhead. |
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"BakedandFried" wrote:
"Ron Lee" wrote: Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee Prove it, dickhead. He has a link on that web page to a document where attempts to do just that. So how's the trolling going? |
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On Feb 16, 6:32 pm, Jim Logajan wrote:
"BakedandFried" wrote: "Ron Lee" wrote: Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee Prove it, dickhead. He has a link on that web page to a document where attempts to do just that. So how's the trolling going? Well...you're one for one so far. But I'm hopeful you'll do better soon. Love, Your Mom. |
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"Ron Lee" wrote in message ... Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics. http://stopads-b.org/ADS.htm Done! Thanks for the reminder Ron. We are already over-regulated, and to think that the FAA will further reach into my pocket in their effort to cost-shift the burden of maintaining their antiquated radar facilities is unacceptable. If the traffic increase is as they forecast, I fully expect to hear more and more ATC replies like: "VFR flight following unavailable" or "unable,... what're your intentions?" I'll be damned if I pay for boxes that benefit them, and it'll actually reduce my services. |
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On Sat, 16 Feb 2008 16:12:11 GMT, (Ron Lee)
wrote in : Comment against the ADS-B Out NPRM or you will have to waste up to $17,000 on a useless piece of avionics http://stopads-b.org/ADS.htm Ron Lee Here's my comment: Docket ID FAA-2007-29305 Docket Title ADSB Out Performance Requirements to Support ATC Document ID FAA-2007-29305-0002 Document Title Automatic Dependent Surveillance--Broadcast (ADS-B) Out Performance Requirements To Support Air Traffic Control (ATC) Service Sirs: This NPRM imposes a severe financial hardship on General Aviation operators without providing anything close to commensurate benefits. Many GA aircraft are valued at less than the cost of equipping them with the equipment that would be required by this NPRM. Because the equipment proposed in this NPRM only provides for one-way transmission of flight positional data to ATC, it offers the pilot NONE of the potential benefits of a full ADS-B system such as weather information, and conflicting traffic information. Inequity: --------- Clearly this NPRM was drafted to benefit the air carriers, who already have GPS and Mode S transponders installed in their aircraft, and ATC surface surveillance and control. If this inequitable NPRM should be enacted, it will price a significant percentage of the GA fleet out of the skies. There are only about 19,382 US air carrier aircraft, or about 11% of the 219,780 GA aircraft fleet, so GA will be funding 89% of this NPRM which largely benefits airline operations at hub airports. Military Exempt: ---------------- As there is no plan in this NPRM to implement ADS-B for military aircraft, so they will remain largely invisible to ATC, the airlines, and GA. Clearly this NPRM is not only inequitable in the burden it imposes on GA operators, but it is fundamentally flawed in it failure to address ALL aircraft operating in the National Airspace System. Vulnerability: -------------- Because ADS-B is a satellite-based system, it is vulnerable to solar activity. It is well known that solar flairs and coronal mass ejections are capable of rendering satellite based communications inoperable. Imagine the potential chaos that would ensue if all air traffic control in the NAS were dependent on ADS-B, and it were rendered useless by a solar storm, and the existing FAA radars were decommissioned! Further, the ADS-B system relies upon the aircraft's onboard GPS equipment and Mode S transponder for aircraft positional information that is broadcast to ATC. This is a fundamental difference from the current system of ground-based radars that relies solely on the laws of physics for aircraft positional information. This difference introduces the possibility of rogue aircraft spoofing the system by broadcasting erroneous ADS-B positional information. This is considerably more difficult when radar is employed for confirming the position air traffic. Further, the current radar based ATC system is decentralized, as the radars are located in many installations throughout the country. In the event of an equipment failure, only the area served by the nonfunctioning radar is impacted. In the case of ADS-B, there is considerably less system tolerance for equipment failures, and there are single points of failure that can bring the entire system down. Trading Proven Technology For Unproven: -------------------------------------- If the current radars are to be decommissioned in favor of replacement with ADS-B technology, there will be precious little equipment that the FAA can employ to verify the true position of aircraft, and in the event of solar disruption of the ADS-B system, there will be no other system available for ATC. Summary: -------- So, if the current ADS-B OUT NPRM is enacted, GA (89%) will have to install 219,780 ADS-B units at a projected cost of up to $17,000.00 each, and receive none of the ADS-B IN benefits such as air traffic depiction and weather information. The sole advantage will be ATC's positional information of GA aircraft in areas lacking radar coverage, and on the ground. The NPRM does not address military operation, nor solar communications disruptions, not the loss of verifiability provided by existing radars, and it would abandon existing proven technology. If a private corporation were to attempt to market a product with such an unfavorable price/performance ratio, it would be a complete failure. Best regards, Larry Dighera |
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![]() Larry, that is an excellent comment. That is why having many people provide their viewpoints is so imporatnt since I do see all the problems with this NPRM. There is only one nit with your summary: Summary: The sole advantage will be ATC's positional information of GA aircraft in areas lacking radar coverage, and on the ground. My discussions with FAA ADS folks is that the currently planned coverage for ADS-B ground units is only to meet the same coverage provided by radars today. Thus there will be no improvement in the mountain areas and many places in the USA just a thousand or so feet AGL. One concern I have is that the NPRM, if changed, may be to force complete ADS-B (In and Out) functionality. That will make it more expensive for thinsg that I do not need. I have terrain awareness in my GNS 430W and may turn it off since it is a nuisance flying in the mouyntains. Weather...I can get a 496 if I really need real time weather. I have done fine without it so far. Either use Flight Service or land and get updates. Ron Lee |
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My gut feeling is, that this NPRM is an attempt to address the runway
incursion issue, and that ADS-B information would be used to augment or replace radar information about the location of aircraft on the airport surface. I don't know what the plan is. The NTSB comment sounds like it may agree with your point however I don't see ADS-B Out only solving that problem. If you are correct, that is just another reason why it may only help the airlines and the FAA. Ron Lee |
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