Dick Smith's submission to CASA

Dear Sir

In relation to the discussion paper DP 0410AS “Carriage and use of Automatic Dependent Surveillance – Broadcast (ADS-B) Avionics” I wish to make the following comments.

I do not know which known risk is being addressed for Visual Flight Rules (VFR) aircraft.  From what I have been told, the risk of a VFR to VFR or VFR to IFR collision in low level enroute airspace in Australia is so minimal that it is virtually not a genuine safety consideration.

There does seem to be a push in Australia to capture all VFR aircraft “in the system”.  It must be noted that other leading aviation countries have resisted this trend, as safety is not significantly improved and the cost to the industry cannot be justified.

I understand the risk of collision is much greater in close proximity to airports, where ADS-B would not be a cost efficient risk reducer.  For example, if an enroute controller was monitoring the enroute airspace using ADS-B, there could be 20, 30 or even more airports in the area.  It would not be possible for the controller to monitor all traffic, both IFR and VFR, close to each of these airports. 

I have always understood that collisions close to non-tower airports are prevented by disciplined circuit procedures (including radio) and high visual alertness.

The discussion paper mentioned that ADS-B could be advantageous in the reduction in CFIT accidents.  I point out that modern Enhanced Ground Proximity Warning Systems can be contained in each individual aircraft at a reasonably low cost and do not require the involvement of air traffic control.  It is obvious that flight crew normally have more time to analyse CFIT warnings for an individual aircraft compared to air traffic control monitoring many aircraft – even with an automatic system.

Enhanced Ground Proximity Warning System databases are now readily available and are even now being provided in some hand-held GPS units at a very low cost.

The dot points in paragraphs 3.5.10, 3.5.11 and 3.5.12 (in relation to improvements in enroute and terminal safety) mix up ADS-B out and aircraft fitted with moving map and traffic displays.  These really should be separated as a simple ADS-B out unit could be provided under a subsidised scheme, however a unit with moving map and traffic displays would be considerably more expensive and is unlikely to be provided under a subsidised system.

I believe CASA should thoroughly investigate whether the proposals to lead the world with ADS-B technology for VFR aircraft (especially considering the proposals for mandatory fitment) are not driven by an obsession to bring VFR enroute aircraft back into the system rather than a true risk based cost benefit safety assessment.

I believe great discipline will need to be applied to separate the obvious cost advantages which will be given to air traffic control providers and the major users – i.e. the airlines – by the removal of enroute Secondary Surveillance Radar compared to the actual reduction in risk for VFR aircraft which generally operate below 10,000ft, therefore well away from IFR and commercial airline aircraft.

Increasing costs and complexity are making general aviation less attractive for many VFR pilots.  Instead they are travelling by other forms of transport and participating in alternative recreation activities.  The decline in general aviation is obvious from the statistics showing reduced flying hours and avgas sales.  Should this decline continue, there will be no need for ADS-B for VFR aircraft as there won’t be any still flying!  Of course, any increased costs for VFR aircraft can only hasten this decline.  It would be ironic if the introduction of the ADS-B system to lessen the risk of collision actually worked by forcing more aircraft out of the sky, leaving fewer aircraft with which to collide.

I believe the best way to manage the risk is to adopt the best, proven techniques from around the world and implement them in Australia.  To implement the costly and unproven ADS-B, which does not address any significant known risks, may itself create risks that have not been addressed – such as diffusion of responsibility.

There is also a privacy concern – many VFR pilots do not want their flight continuously monitored by a Government authority.

Yours faithfully

Dick Smith