First I’d like to correct my last my last Best Equipped, Best Served (BEBS) blog. It was inaccurate to say that BEBS is intended to incentivize compliance with the ADS-B (out) mandate. It is really intended to incentivize equipage of all NextGen communication, navigation, and surveillance (CNS) technologies. The origin of BEBS came out of the RTCA Task Force 5 recommendation that FAA expedite aircraft equipage of NextGen technologies in order to maximize benefits and to “establish a National Airspace System (NAS) where users who have aircraft with higher aircraft performance/capability levels get higher levels of service.” While this sounds like a perfectly reasonable and sound recommendation, I’d feel a lot better if someone tested the assumption that expediting equipage is necessary before charging off with guns blazing.
In any event, the first step would to examine the collection of NextGen technologies to determine which: (1) provide the most synergy for the NextGen development, (2) are most likely to provide significant stand-alone benefits, (3) are least likely to provide significant stand-alone benefits, and (4) can contribute most through the expediting of increased equipage levels. This initial assessment can help focus the BEBS effort and may possibly demonstrate that early aircraft equipage is not the driving issue that everyone has assumed it to be, especially since the corresponding NextGen automation infrastructure is barely under development yet. A more natural assumption might be that the equipage percentage would rise non-linearly with the increase in actual realized operational enhancements and benefits provided by NextGen.
But back to the problem: how do you encourage (or incentivize) aircraft operators to buy expensive NextGen CNS technology? Why not start by assuming that it’s the same approach you’d take to get anyone to buy anything. For example, how does someone decide which new vehicle to buy? (an imperfect but sufficient analogy) There are five (5) obvious considerations that go into any decision to make a significant investment in expensive technology.
Consideration #1: Does the technology offer a genuine benefit that I cannot achieve without it?
If I want to routinely drive in snow conditions or over off-road terrain, I need to buy 4-wheel drive technology or I won’t be able to do that very well or safely. Likewise, if aircraft operators want to routinely fly above FL290 they’ll have to buy a new super-precise altimeter so they can enter the Reduced Vertical Separation airspace where precise altitude maintenance has been determined to be a requirement for ensuring safety. If they want to fly into Class B airspace they’d better have a radio and a Mode C transponder because those, too, have been determined to be requirements for ensuring safety. The point is that these operators will purchase the technology because it grants them access to operational and economic opportunities they wouldn’t have without it AND they accept the premise for the restrictions as being valid, fair, and reasonable.
Conversely, restrictions that can be interpreted as capricious and arbitrary are quite another matter. During the 1990s, motorcycles were prohibited from using the 17 mile PUBLIC road along the perimeter of the Monterey Peninsula in California (think Pebble Beach) because the local community found them “annoying”. Also during the ‘90s, motorcycles were not permitted on the HOV lanes in Virginia because; according to some absurdly infantile (I read it!) “analysis” by the VA DMV, they posed a “safety hazard”. The arrogance and condescension of those government policies infuriated the motorcycle community. By the same token, I’d fully expect arbitrary BEBS restrictions to result in the same, or probably far greater, outrage from the aviation user community. It is crucial that any limitations to access of public airspace based upon the technology aboard the aircraft absolutely MUST be seen by the aircraft operators as being valid, fair and reasonable. Without that, BEBS restrictions are more likely to incentivize litigation than equipage.
Consideration 2: How valuable are the benefits to me?
If I live in Florida, how badly do I need snow capable 4-wheel drive technology? Similarly, what is an aircraft operator’s justification to equip with ADS-B (out)? Aircraft operators who currently operate largely outside of radar coverage will gain significant benefits through “radar” enroute and terminal services and will be eager to equip without any additional incentive. But for the majority of users, ADS-B (out) offers almost no benefits despite the very dubious and unproven claim that controllers will be able to use airspace more efficiently simply because of faster track update rates and more precise position data. (This could be a topic for a subsequent blog) Any attempt to incentivize voluntary ADS-B (out) equipage would probably be an effort in futility, hence the need for a mandate.
GPS, on the other hand, provides significant benefits to users if for no the reason than for the simplicity of navigation if offers. I haven’t used a AAA map to navigate my car since I bought my GPS navigation system, so I’d imagine that pilots would find an aviation GPS system even more desirable. Even users with operations into isolated airport can get GPS benefits through the development of Localizer Approaches with Vertical Guidance charts and procedures. GPS offers so much in potential benefits to individual aircraft that achieving high equipage levels will probably not require any additional incentives.
On the other hand, the Data Comm technology as currently described seems to focus on transmitting non-tactical flight plan clearances, routing changes, and other data to the cockpit. While these data transmitting capabilities would certainly provide operational efficiencies beneficial to the ATC system, the value to the users would consist primarily of receiving non-tactical data plus second order ATC efficiency benefits that may or may not be realized. Probably not until the Data Comm technologies begin providing direct tactical benefits to the user, such as real-time tactical information or ATC clearances within a highly automated ATC function, will the cost of equipping a fleet of aircraft make much economic sense. The incentive trigger here would be to be able to access tactical information that will give them an edge over their non-equipped competitors.
Consideration 3: Will the system allow me to utilize the beneficial technologies?
I may be able to buy a car with 600 horsepower engine technology, but I live in the Washington metro area and 550 of those horses would never leave the barn. Why would I buy it? While the raw potential benefits of GPS are enormous, additional published GPS routings and approach plates either replicate existing routings and approaches plates or they compete for the same airspace and controller attention. In congested, highly complex airspace that is operating at or near the human capacity of controllers, the LAST thing the system can accommodate is additional routings and/or transition and approach procedures. In these cases where the new technology cannot be safely accommodated, it is the system itself that will impede the level of equipage because the human controllers are unable to accommodate “special” procedures. Publishing hundreds or thousands of GPS routings and approaches isn’t the same as using them operationally since their use must be approved by the human air traffic controller sitting in front of a radar scope. An incentive might be a requirement that the new GPS charts must be developed in concert with their associated ATC facilities so that their application is complementary to, or at least compatible with, existing ATC procedures; increasing the likelihood of their being approved by ATC.
Consideration 4: Will the system be changed to allow me to fully utilize the NextGen technology?
For my 600 horsepower car analogy, is there an American Autobahn in the works? My new car’s engine is only an enabling technology and people have to remember that communications, navigation, and surveillance are also ENABLING TECHNOLOGIES, they are rarely the solution! NextGen often references the Collaborative Decision Making (CDM) development as a model for NextGen, but consider that even if CDM had perfect CNS capabilities, without the Flight Schedule Monitor (FSM) software capabilities that dispatchers and flow managers used to actually perform the CDM planning functions there would have been no CDM; there would have been NOTHING!
Like CDM, NextGen must develop a new ATC automation counterpart to FSM that will change the fundamental ATC process to accommodate and maximize the utility of the enabling technologies. Without that FSM equivalent, NextGen will also have NOTHING except for short term technical enhancements and next-step development, often referred to as system “modernization” or “replacement” programs!
While the NextGen 2025 vision implies a completely new ATC automation concept, I see very little ongoing or planned efforts to actually develop one. I don’t even detect an acknowledgement that such a critical infrastructure component is even required for NextGen. Without that clear acknowledgement, why would any operator have an interest in investing dwindling capital for new technologies that will clearly operate in a human limited ATC environment similar to the current system? An incentive to equip aircraft might be for FAA to show some interest in developing the actual NextGen automation capabilities instead of seemingly doing nothing tangible beyond publishing GPS routings and approach plates.
Consideration 5: Is there proof that this technology has actually produced any meaningful benefits?
As a car driver I can see the benefits of new car technology every day. When my model of motorcycle went from a five-speed to a six-speed transmission, I couldn’t buy a new one fast enough! Everyone will stipulate that the narrow spectrum of GOMEX, Alaska, and other users with isolated operations will gain significant benefit from both ADS-B (out) and GPS RNAV. However to reach any mass equipage level, all the other operators must also believe that their investments are going to return significant operational benefits. FAA should go beyond just announcing the number of GPS routes published or providing anecdotes of speculated GPS applications and actually document, quantify, and celebrate the actual operational benefits that have resulted from publishing a billion new GPS routings and approach plates. They should document, quantify, and celebrate the actual enhancements to procedures and the resulting benefits brought about by the deployment of ADS-B at Philadelphia and Louisville. FAA should take every opportunity to document, quantify, and celebrate every significant operational improvement brought about by NextGen technologies. (Of course, for credibility purposes, it would be critical that such documentation be provided by a neutral, objective organization completely independent of FAA and NextGen.) The incentive would come from the increased confidence aircraft operators would have that NextGen is real!
So What’s the Plan?
The NextGen technology that can provide the most operational benefits to users with the least amount of developmental risk and dependence on other NextGen developments is ADS-B (in). Simply enabling an aircraft to see other ADS-B aircraft is a monumental enhancement to aviation safety and would be a technology that aircraft operators of all sizes and types would rush to install. Therefore, my first “order of business” would be to stop all activity aimed at incentivizing ADS-B (out) and place a top priority on defining the initial specifications for ADS-B (in), with minimal functionality (e.g., traffic display) but with only “hooks” to future capabilities. A specific condition would be to not saturate the specification with requirements that support every envisioned NextGen function, and especially not something like supporting the Self Separation Airspace (SSA) concept, because that would make it a never ending task . (NOTE: the Self Separation Airspace concept would require FAA to abdicate its responsibility for aircraft separation assurance and place that responsibility on the pilots in the cockpit, and it “ain’t never, ever gonna happen.” In fact, this idea is so patently absurd that it should be immediately deleted from the NextGen 2025 vision and never spoken of again. Who dreams this stuff up?)
At the same time I’d pull back on publishing another thousand GPS routings and approach plates to focus agency effort and re-direct funding towards defining, designing, and developing the fundamental operational NextGen components and functional capabilities of the new tactical ATC automation functions (software, not hardware). I’d focus on developing and researching human factors (skinware), working models, simulations, and specific analyses instead of spending endless time and funds on excessive esoteric planning exercises (manure-ware).
I’d also expand the research on the digital air-ground tactical communications capabilities that will be required if a highly automated NextGen ATC system is ever going to be operationally deployable. Hopefully these combined efforts will be seen as a good faith effort by FAA and convince aircraft operators that FAA is serious about NextGen and will be there to develop and support the technology that will provide them with significant operational benefits. If aircraft operators gain some confidence in FAA’s commitment to NextGen, the likelihood of increased equipage levels will rise dramatically without the need to “incentivize” anyone.
It appears to me at least, that the claim that user equipage is critical to NextGen success may be a bit of an overstatement since it’s not clear how even immediate full equipage would positively impact development. Hoefully this does not reflect a belief that NextGen is primarily a communinations, navigation, and surveillance "transformation". In fact, someone far more cynical than I might even suspect that such a statement may actually be a preemptive effort to divert blame to aircraft operators if NextGen should fail. Don’t know; just sayin’.
FAA should LEAD by example from in-front (show progress) , not whip from behind (issue mandates). The bottom line is that if you have the right product at the right time at the right price, you shouldn’t have to force (oops, “incentivize”) anyone to buy it.