Time is Running Out!

This article covers the goings on in the ADS-B space in the past year. It is the third article in a series. The first was in the June 2016 issue. It was a tutorial about the ADS-B system and configuration considerations. The second article appeared in the August 2017 issue. Like this one, it was an update on the ADS-B scene. If you are still deciding upon your ADS-B solution, you should read the prior articles – Juggling the ADS-B Options and What is happening on the ADS-B Scene?.  The considerations about what to install haven’t changed. The gold-standard installation is still 1090 “Out” with dual-band “In.”

As of the publication date, we are about 14 months from the deadline of January 1, 2020. It is obvious not all the projected aircraft will be equipped by 2020. It’s not apparent what, if anything, the FAA will do about that!

Current Status of Installations

Installation of 1090 ES units continues to overwhelmingly dominate Out installations. Only about 6.4% of the ADS-B Out units installed in the U.S. GA space last year were 978 MHz units. This percentage could increase going forward if there is a surge of lowest cost/minimum compliance customers willing to accept the limitations of 978 Out. They will pair an existing Mode C transponder with a 978 Out transmitter with integral GPS (if they don’t have a usable WAAS GPS source).

Figure 1 shows the trend of GA installations though June 2018 and the goal/expectation of 100,000 U.S. GA fixed-wing installations by the end of 2019. As of the end of June 2018, there were 43,250 good GA installations. My projections show that installations will reach the 80,000 range by the 2020 deadline, including cleanup of aircraft that are currently non-performing emitters (NPE). That will leave about 80,000 aircraft of the approximately 160,000 on the U.S. GA registry that are either hangar queens, awaiting equipage, no longer desirous of flying in rule airspace, or the owners are banking on a delay.

Figure 2 shows the percentage of NPEs for various classes of aircraft. The good news is that this shows improvements in all classes except air carriers over the prior year. Experimentals/LSAs continue to have the worst NPE percentages.

What is Happening in the GA Hardware Markets?

Hardware offerings for the lower end of the GA 1090 Out market stabilized in the last year. Prices have stopped falling and appear to be about 10% lower than last year. There were few new Out product introductions. Manufacturers are in the production stage now. There really isn’t time for a new vendor or product to establish itself and gain market penetration. At this point, approximately 50% of my projected GA installations have already been installed.

Apareo, Garmin, L3/Lynx and Trig appear to be the winners in the 1090 space. That hasn’t changed from last year. There have been several innovative 978 Out products introduced over the last year. In light of the very limited enthusiasm for 978 Out products, it is unclear what their market penetration will be.

The portable In market, in contrast, continues to see a variety of new products that generally have wireless connectivity to tablets or panel-mounted screens. Stratux, the DIY dual band receiver, now has a version with an AHRS.

View From the Repair Stations

I interviewed several repair shops that service GA aircraft for their view of what is happening. They continue to be frustrated with the sense from some owners that the FAA will delay. Their volume of installations nearly doubled in 2017. More than 75% of customers so far have some other unrelated work done during an installation. Their lead times are extending but still not to the crunch stage. They think that will change in 2019. As the deadline draws nearer, they see approaching their limit for installing units. Shops are struggling to find good technicians. They feel the rebate program provided only a minor spike to the market. They are not requiring slot reservations or anything beyond their normal deposits. They see equipment manufacturers as being able to keep up with demand. They do not expect the FAA to delay the deadline.

So far, 1090 Out remains the overwhelming preference. They haven’t seen a distinct shift toward minimum compliance customers. Most users are installing some form of In via integral receivers or portables. Shops feel Cirrus aircraft and post-1990 Cessnas are easier installations, even though they may involve integration with a flight management system (FMS). This is because of newer wiring, fewer prior upgrades, and better documentation.

International Mandates

There have been no new international mandates since the Mexico announcement in February 2017, which matched the U.S. timing but was 1090 only. So far, no other nations have adopted the 978 frequency for Out or In. European authorities have admitted that installations are falling short of their goals, which were much less broad than those of the U.S. They have not said what they are going to do about it.

UAS and Airplanes

There has been no new regulatory action regarding UAS and aircraft, but I suspect some loosening of UAS regulations in the near future. There continues to be experimentation toward expanding UAS operations using ADS-B and other technologies.

Totally Satellite-Based ADS-B Services

Experiments toward a completely satellite-based ADS-B system continue. The satellite-based approach is attractive because it would provide worldwide coverage including over oceans. This could also be a turnkey ATC system for countries without a radar infrastructure. The most prominent of these experiments is with the low-orbiting Iridium/Aireon satellites and NavCanada and the FAA. It is not on the near horizon for general aviation. I suspect military ELINT satellites, both ours and adversaries, have been tracking Mode C emitters for years. Mode S ES would add another whole level of specificity to those efforts.

The Rebate Program

The rebate program ended in September 2017. About 10,200 of the 20,000 slots were paid out. I consider the program a bust. The goals seemed to have been to create awareness of ADS-B, as well as the 2020 deadline, and to front-load installation shops. The effort seemed to be undone by perceptions that hardware prices would drop further, equipment capabilities would increase, and/or the deadline would be extended.

Currently, ADS-B data is being fused into the ATC system, along with Mode C traffic and primary radar returns. The FAA has software to select the most valid information. At the time of this writing, no control towers had installed ADS-B In receivers for traffic. At this point, the FAA has not revealed any special day-one plans. One thing not to expect is any reduction in radar sites. The FAA has been quietly walking back one of the big cost savings in the original NextGen justification. Now they need primary radar for security reasons and secondary radar for backup of ADS-B!

The FAA’s Outreach

The FAA continues to promote ADS-B Out, the benefits of In, and deadline awareness. They are expected to announce additional FIS-B (weather) products this year. As always, whether you receive the new products is dependent on the software in your receiver. They are also going to announce a policy on acrobatic planes and maneuvers, which is expected to be similar to the Mode C policies. I expect the FAA will address new implementation issues as they crop up. These efforts will become increasingly intense as the deadline approaches.

The FAA is also proactively pursuing NPE issues. They recently implemented a software program that will allow them to disregard non-compliant Out transmissions and to not send traffic to them. In some instances, they have sent out certified letters to NPE owners telling them to fix a situation.

Exemption 12555

In 2015, the FAA granted a limited waiver regarding some GPS sources called Exemption 12555 (also known as “twelve triple nickel” by the cool people). It is just now becoming well known to the aviation public beyond the airlines. It is not an exemption from the ADS-B Out requirement. It was granted in response to a petition by the airline industry via their trade group, Airlines for America.

The optics of the exemption are much worse than the reality. It is a limited exemption, under certain conditions of GPS satellite unavailability, for airplanes with some already installed older-style GPS receivers attached to Mode S ES transponders to fly in rule airspace. With some equipment, predictive software must be run before every flight, alternate routing may be required, and secondary radar coverage must be available. That could be very onerous, so there will be tremendous pressure to bring those aircraft into full compliance.

This is not the same as the NavWorx GPS controversy. Operators had to designate specific aircraft by August 2018 and state when they would become fully compliant or at the latest be removed from service by the end of 2024. It is expected to be multi-thousands of aircraft, including foreign air carriers flying into U.S. airspace. All aircraft with the specified types of GPS receivers can apply for this exemption. Aircraft with WAAS receivers won’t need the exemption. The five-year period is to allow some aircraft to be retired before being expensively upgraded. It also allows upgrades to be done at major maintenance checks and to allow a new generation of GPS multi-frequency/multi-constellation GPS receivers to become available.

After initially considering 12555 a cave to the airlines, I have come around to a different position. I now see it as a partial tactical retreat by the FAA to give the airlines some relief without compromising safety and having minimal impact on system operation. By granting the exemption so far ahead, it also makes it more awkward for the airlines to ask for an overall delay.

Will the FAA Delay?

Now the critical question: Will the FAA delay the deadline? The FAA has adamantly and consistently stated they will not delay. They state that Out is a critical component of the NextGen modernization effort, and we have had 10 years to comply. I do not believe a new FAA administrator will change things.

The situation is impacted by four user groups: the airlines, the military, business aviation, and non-business GA. Each party has different needs and political power.

The Airlines Situation

All the major airlines have publicly stated they will be compliant or utilize Exemption 12555 by the mandate date. Some airlines are near 100% compliant now. I doubt any airline will gamble on a delay. That is because, for example, even a small Boeing 737 can generate well over $100,000 per day in revenue that is lost forever if it is grounded. Secondly, if an airline is fully or partially grounded, their customers will go to the competition. Thirdly, complying airlines will be reluctant to lend a hand to non-complying ones in asking for a delay.

Airlines installations have shown by far the largest year-over-year increases and progress toward goals of any aircraft category.

Airlines plan backwards from a needed date. They install equipment at heavy maintenance checks and often only one segment at a time, such as wiring or antennas. Expensive hardware is installed last. Airlines are pros at fleet-wide retrofits. Airlines hitherto have not generally installed WAAS GPS receivers because they already have a variety of navigation sources fused together for their needed accuracy. Compliance costs for airliners vary widely depending on age of equipment and what avionics have been previously installed. Airlines are not typically installing In. There are some interesting future applications such as In enabled closer in-trail separation of aircraft.

More than 99% of the passenger enplanements are flown by the airlines, so their interests are far more apparent to the politicians. However, in this case the airlines are in a weak position to ask for a delay due to the already discussed Exemption 12555. Also, their failed privatization/corporatization effort has weakened their clout.

The Military Situation

The Department of Defense (DoD) has major concerns about security issues with ADS-B Out. However, they recently signed an agreement with the FAA as to how they will comply with the mandate. This essentially takes the DoD out of any FAA delay calculations. The General Accounting Office issued a very critical report blaming the DoD for ignoring critical security issues since 2008 when ADS-B was being designed. Previously, the FAA could filter out military operations. Now with flight-tracking systems like FlightAware, using ADS-B and multi-laterization technologies, the public and bad actors can track all transponder and Out equipped aircraft.

The expectation is that the DoD’s fleets of transport aircraft, tankers, VIP aircraft, and trainers will be the first to install Out. The drone, stealth aircraft, and tactical aircraft may get some sort of exemption. There are about 12,000 DoD aircraft, of which about 3,500 are in the categories that the DoD is putting a priority on equipping. At the time of this writing, it is unclear how many will be done before the deadline. Incidentally, the FAA’s fleet of aircraft will be compliant by the deadline.

The Business Aviation Situation

Business aviation is the segment seemingly most skeptical of the Out deadline. They are trailing badly on installations, and many seem to be banking on an extension. The business aviation fleet has a tremendous variety of configurations and a substantial number of older aircraft. One repair shop said owners are more interested in installing Wi-Fi than Out! He also said 50% of the owners are trying to do it cheaply, the other 50% doing it right. A typical bizjet ADS-B Out only installation might be above $100,000. Business aviation has privacy concerns too, but unlike the DoD, they don’t have the leverage to get their desires.

Both the airlines and bizjet operators tend to see no immediate benefit of Out. Therefore, they view it as a tax to be paid as late as possible. They see no In benefits because they already have some form of weather like Sirius or onboard radar and traffic like TCAS. Additionally, they are almost always on IFR flight plans with access to center and TRACON weather and traffic. Airline and bizjet installations are much more expensive than lower-end GA installations. That is because of higher specifications, dealing with pressure vessels, integration with multiple systems, the need for specific STCs, documentation, and training. Interestingly, there are stories of dual-band In receivers and iPad/laptops with ForeFlight type software on the glareshields of some extremely expensive aircraft!

The Non-Business GA Fleet Situation

The non-business GA fleet is the largest but the least politically powerful player in the ADS-B debate. This weak position is due to the FAA’s early and consistent messaging on the ADS-B deadline and the poor uptake on the rebate program.

Summary of Delay or Not?

In my opinion, the FAA will not delay. That is because the airlines will have complied, the DoD has an agreed upon plan, the business jet community is too fractured to be effective, and the rest of GA is impotent on this issue. I expect some sorts of very limited, short-term accommodations for non-complying aircraft with pain attached. This may take the form of delayed handling, longer routes, denial of service during peak hours, etc. The normal inoperative equipment and ferrying for maintenance practices will undoubtedly continue. I feel any overall delay would have to be driven by Congress, which looks unlikely at this time.

Conclusion

Fourteen months and counting. There is no indication from the FAA of a delay, and in my opinion an overall delay is not likely. If you intend to use a shop for an installation, it’s best to be alert to changes in their lead times. Better to install now. That will illuminate you as traffic. Even better, install In as well for cockpit display of weather and traffic. Until next year…