March 4, 2008
What’s at Issue
NATA has submitted comments to the FAA regarding rules proposing to implement ADS-B technologies.
Re: Docket No. FAA-2007-29305, Notice of Proposed Rulemaking, Automatic Dependent Surveillance–Broadcast (ADS-B) Out Performance Requirements To Support Air Traffic Control (ATC) Service
The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA’s 2,000 member companies own, operate and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation and the military.
The members of NATA support the Federal Aviation Administration’s (FAA) program to establish ADS-B as a key element of the infrastructure for the NextGen Concept of Operations. An assessment of NextGen technologies clearly demonstrates that their implementation will generate environmental and economic benefits for the communities they serve as well as consumers, the aviation industry, state and federal governments, and the nation. The on-demand air charter industry, including those companies operating technologically advanced aircraft, such as very light jets, are committed to supporting the vision for transformation of the National Airspace System (NAS) led by the U.S. Joint Planning and Development Office (JPDO).
NATA members support implementation of ADS-B IN and ADS-B OUT as a means to enhance safety and increase capacity and efficiency for all aircraft and airport operators. Operators represented by NATA typically connect many markets in which the NAS has not provided the radar services traditionally required to support near all-weather air and ground operations. Most operators have experienced en-route and terminal area inefficiencies that ADS-B OUT and IN applications should remedy. These inefficiencies typically occur at and between the smaller community airports NATA members serve. ADS-B applications will reduce ATC workload and provide safety of flight operations as benefits for the public and the entire air transportation industry.
NATA proposes that the FAA develop a joint (FAA-Industry) ADS-B Transition Plan directed towards on-demand operators, with emphasis on those that provide services to smaller community airports.
NATA members have expressed a willingness to commit time and resources to participate with the FAA in a NextGen operational demonstration that would culminate in final operational services. The association believes that the supporting data and operational experience resulting from such a demonstration will provide significant benefits in the following areas:
Energy savings
Carbon footprint reduction
Environmental impact management through departure and arrival procedures that accommodate community interests related to particularly noise-sensitive areas
Fleet departure and arrival management practices with greater precision, safety, capacity and efficiency, including enhanced visual approaches and closer spacing in instrument meteorological conditions (IMC)
Accelerated airspace expansion through evolutionary processes through trials in non-congested airspace.
Including under-utilized areas of the NAS, for which radar services have not been traditionally provided, in the proposed transition plan offers unique and vital benefits. Underutilized airports and airspace typify the target of market expansion for emerging on-demand air transport operators. Implementation of ADS-B in these areas can provide an orderly, well proven, community supported, sustainable process for accelerating implementation of certain operating capabilities envisioned in the JPDO NextGen Concept of Operations. Lessons learned in these parts of the NAS can then be used with high confidence in the more congestion-challenged regions of the NAS such as the Northeast region.
A clear presentation of the path to be followed by both the FAA and industry is required to achieve the benefits of ADS-B. The NPRM does not provide the industry accurate and complete definition of technical requirements/specifications for design/manufacture, certification and installation of both ADS-B Out and IN equipment.
Prior to the issuance of a final rule, NATA believes it is necessary that the FAA aggressively develop and publish, as part of the final regulations, a phased plan of equipage, financial incentives and operational benefits for operators and equipment owners in all affected sectors of the industry. The impact to small businesses, whether they are in the equipment manufacturing, installation/maintenance or operational sectors of the industry, must be accurately addressed by the FAA. The vast majority of those impacted by the proposed implementation of ADS-B technologies will be small business entities and individual general aviation operators.
Again, NATA’s members support the FAA’s effort to establish ADS-B as a key element of the infrastructure for the NextGen Concept of Operations. However, the FAA must ensure that this coming mandate will be both beneficial and affordable for all users of the National Airspace System.
Sincerely,
Eric R. Byer
Vice President, Government & Industry Affairs