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JohnMcK
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This thread is in the RA-Aus forum section but I believe it is important enough for ALL members to start doing some serious research, some serious thinking, and taking some serious action about this one. Below is a copy of my post in the RA-Aus section of this forum.

 

ADS-B



 

 

 

 

 

Automatic Dependent Surveillance – Broadcast



 

 

 

 

 

 

 

 

 



 

 

 

 

Airservices /CASA (my Mistake both names are on the consultation paper http://casa.gov.au/newrules/airspace/jcp/jcp.pdf) are pushing ahead with ADS-B (a type of upmarket version of Flarm used by gliders and some ultralights at mixed airfields) This, in its current form, I believe, will be VERY BAD news for us. By 2012 all aircraft entering CTA will be required to have ADS-B fitted, and by 2014 all aircraft in CTAF® will require ADS-B.

 

CASA policy is to make all aerodromes that have a visit from one or more 10 seat aircraft per month a CTAF®. So starting 2014 if you want to go into or through a CTAF® you must have ADS-B, and by then most of the airfields we currently fly at or near or through will be CTAF®

 

The “estimated” cost of these units is $10,000 to $15,000 plus instillation?. They can only be repaired by a CASA approved Radio Tec. They will also need to be serviced every two years by an approved Tec. Most of us can’t fly our aircraft into Brisbane or some other major center for a service, So if you can’t put your plane on a trailer, think of what the call out fee might be.

 

There are suggestions that the government may cover the costs for the initial instillation for currently registered aircraft but not for any new aircraft in the future. But even if we get a “free” unit, the upkeep could "bankrupt" many of us. We will also sell out all our future members of RA-Aus, or if you belong to AOPA, SAAA etc, your future members, if we accept this in its current form. Also no one seems to know how big or how heavy these aviation units are or what their power consumption will be. There will be exemptions for aircraft with low battery capacity or no alternator etc, plus other undefined aviation uses. You could have airspace full of, say, gliders, hang gliders, paragliders etc but banned to ultralights. If so what is the point of having them compulsory outside of CTR.

 

Also, as I read the new regulations, If you don't have ADSB you won't be able to fly above 5,000 ft (QNH) regardless of the terrain.

 

My personal view is we need to lobby to at least stop them from being compulsory in CTAF®, and below 10,000 ft.

 

In the marine field this system is called AIS (no height requirement) and has been in operation for some time, and I guess is where the Aviation idea came from. This is now mandated for commercial shipping but you can buy pleasure craft versions of AIS for under $1000, which use is voluntary. Also non AIS equipped pleasure craft are not excluded from shipping lanes where AIS is compulsory for commercial shipping. Eg The narrow shipping lane up Cape York Peninsular. The great "sell" on the safety aspect of AIS doesn't gel either. Just look at the serious big ship collisions in the English Channel in recent years with ships fitted with AIS and all the alarms (TCAS equivalent). There is no real substitute for "see and avoid". Only aids to help you.

 

Also if any of you people out there have a "thing" about your personal privacy in sporting or pleasure pursuits, be advised that every single move you make in your aircraft fitted with ADSB, from key on to key off, will be tracked, recorded and logged by the government agencies. (track, height, time, bearing, speed, landings etc). If your IQ is greater than 10 you can work out future possible ramifications of this.

 

The military have rejected their compulsory instillation for now. My personal view is we should do the same under the current proposals.

 

John McK (wearing my personal and RA-Rus Board hat on this one)

 

 

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I think you are correct. Remember the "free" fitment is for ADS-B 'out' only, not ADS-B 'in', so we won't be able to see anything on a screen, but we can be seen, and yes we have to pay for the maintenance. Even if a screen is fitted, as I understand due to patent issues there will be no audio resolution advisories, so people have to keep their head in the cockpit instead of looking out. Considering that the risk is greatest in the circuit area, that is not a time to have your head in the cockpit. Does this mean it will be useless for small aircraft? How easily can any specific aircraft be tracked (as per Darren's unit) or false positions input?

 

Then there is the "which ADS-B system" question. VDL-4 like Europe? Dual 1090 ES and UAT like the US? If we choose the wrong one we might end up having to pay a fortune for units that are not mass produced for small aircraft by Garmin or similar. The USA is not mandating ADS-B for something like 10 years, so what is the hurry here? What happens if we choose a type and then have to change to be like the rest of the world in 5 or 10 years? It might be like the old Aussie DME - and will aircraft owners then have to pay to chage the unit to a new system?

 

Eventually ADS-B could be great, but at the moment there are a lot of variables to consider.

 

 

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Guest browng

So what form of action do you think we will be able to take? This seems like an absurd idea, but CASA do not have a track record of real absurdity, they usually end up tempering these demands with some realism, e.g. the transponder exemption for aircraft not built with an electrical system capable of powering one (like my '46 J3). Do we need to work on some form of specific exemptions, or a total dropping of the requirement? Either way, you are right, it is an issue that we need to address now, not simply wait until it's too late and then whinge about it.

 

 

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For those who would like more info on ATS-B (like I did) you can get a fairly good, though not technical, overview here: http://en.wikipedia.org/wiki/ADS-B

 

Any chance RA-Aus can make life easier for us by putting up a page on their site with their official view, and an opportunity for us to agree with it (perhaps using our Membership No to verify who we are) so a nice big response can go to CASA?

 

Some hard facts may also be useful for generating arguments against ADS-B.. i.e number of actual air-to-air collisions, number of near misses, number avoided by TCAS etc.

 

Assuming the worst happens and we get lumped with it, could RA-Aus consider hiring an electronics engineer to design and prototype an ADS-B unit for production by commision? On the face of it it doesnt seem that complex (24 bit UID + position "vector"). Seems to me getting the data for the vector would be the hardest bit. that and getting the device CASA approved..

 

 

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Guest pelorus32
[snip] The USA is not mandating ADS-B for something like 10 years, so what is the hurry here? [snip]

As I understand it one of the key drivers is to provide a replacement for SSR. Some of the SSR infrastructure is due for replacement in the timeframe being considered and some areas where Airservices want coverage doesn't have it. Therefore the view is "why would you renew SSR infrastructure when you could just mandate ADSB and shift cost burden to users?"

 

I think John Brandon has, elsewhere, made a very eloquent argument for there being a very likely cost burden on users. It's one thing putting, say, $30K of ADSB into a B200 worth several million dollars and earning its keep every day. It's quite another to spend say $10-12K in an aircraft costing say $120K - 10% of capital value that is used purely for recreation.

 

I think ADS-B is great technology - acknowledging the standards issues that I raised elsewhere and that Mazda has raised - but the cost burden is simply disproportionate.

 

Having said that there are strategies that CASA/Airservices could adopt. A recent example is with 406Mhz beacons. Australia slightly modified the standards and that cut the cost of the beacon to about 25% of the previous cost.

 

CASA/Airservices could call for a "per item" tender for ADSB out and ADSB with receive capabilities and make it clear to the tenderers that they need to provide a simple, cost effective solution with low capital cost to users. They have sufficient buying power to do that if they are representing a great swathe of the low end GA fleet and the RA fleet. they can do this in a way that no other organisation can.

 

Regards

 

Mike

 

 

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Guest browng
wow, not real friendly like on those forums are they...

No, and the vast majority don't seem to realize that there is airspace below 5000', or aircraft that can't support a transponder, let alone ADS-B. Frankly, if this is mandated, I'm going to be a bit concerned that those guys will be keeping any kind of visual watch, and that is going to make me very uncomfortable.

 

 

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I think John Brandon has, elsewhere, made a very eloquent argument for there being a very likely cost burden on users. It's one thing putting, say, $30K of ADSB into a B200 worth several million dollars and earning its keep every day. It's quite another to spend say $10-12K in an aircraft costing say $120K - 10% of capital value that is used purely for recreation.

Just imagine that same thing in something like a Hummelbird or a Lil Tinny where the aircraft cost is in the $10-12k ballpark - before you cough up $10k for the ADSB-out gear. Same deal for a lot of the "rag and tube" ultralights being sold second hand...

 

John Mck, any chance of a grand unified response from RA-Aus to CASA regarding this? something along the lines of the Sport Aircraft Associations on that other forum?

 

or just a "088_censored.gif.2b71e8da9d295ba8f94b998d0f2420b4.gif off CASA" might go well too.. :-p

 

 

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Guest Flyer40

Despite the potential safety spin-offs, the ADS-B issue is really only being driven by the money that ASA will save by eliminating both the capital upgrade and annual maintenance costs of the SSR network. I don't remember the figures, but I remember reading that the annual maintenance cost for SSR was in the order of $millions, and obviously the capital costs would be in the tens of millions.

 

It would be naive to oppose ADS-B because it's going to happen whether we like it or not. The smart thing to do would be to lobby to have ADS-B structured so that everybody benefits.

 

I believe that a model could be proposed that requires ASA to fund and supply ADS-B hardware to every aircraft in the Australian fleet, with them retaining ownership, upgrade and maintenance responsibility for that equipment. Much like Telstra owns, maintains and upgrades the phone on your wall (assuming you're still their customer).

 

Given the Australian fleet size, I believe this could be achieved for about half of just one years SSR maintenance bill. Which means that ASA would still be tens of millions of dollars in front.

 

In fact I think this is probably the only way to ensure the TCAS capability of ADS-B is fully realised.

 

Whadaya reckon?

 

 

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Remember that ADS-B is not the same as TCAS. TCAS operates with a Mode C transponder, not an ADS-B 'out' unit. TCAS gives an audio resolution advisory (i.e. it tells the airline pilot to climb, descend, turn etc). ADS-B 'in' has no resoution advisory. TCAS is effective. Yes, it means we need transponders and they cost a few thousand, but the cost is still lower than ADS-B, we can't be tracked, the technology is proven, and it actually tells pilots how to avoid a collision.

 

ADS-B can operate with Mode S squitter if we go for that version, but then we won't be compatible with the US (UAT for low level) or Europe. So if we import a foreign aircraft it will need to be fitted with whatever system we use.

 

UAT has the advantage of giving weather in the cockpit, but apparently we don't have the frequencies available here. The US are still undecided and they may yet all go for one Mode S squitter format rather than a high and low level format. It isn't known yet because they are not mandating ADS-B for 10 years or so.

 

As for the radars, in New Zealand they decided to upgrade the radars and wait to see what happens with ADS-B.

 

 

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Sain wrote:

 

"Any chance RA-Aus can make life easier for us by putting up a page on their site with their official view, and an opportunity for us to agree with it (perhaps using our Membership No to verify who we are) so a nice big response can go to CASA?"

 

There has been a notice on the bulletin board since August 24 regarding the ADS-B JCP, which by the way is an DOTRS/Airservices project not a CASA project. See www.raa.asn.au/notices.html

 

That notice makes a very simple statement: "The RA-Aus view is that aircraft operating in Class G, no matter what the altitude or the location [i.e. even in the vicinity of a CTAF®], should not be required to be equipped with ADS-B OUT."

 

The inference is that the association is OK with ADS-B in Class E and other CTA. You know that over practically all Australia Class G extends from the surface to FL18 except in those generally east coast corridors where it only extends to 8500 feet and FL125 i.e. to the Class E lower level. So even though an aircraft flying in Class G at or above 10 000 feet must use a mode A/C transponder your association is saying no ADS-B. The USA NPRM for ADS-B OUT does not require ADS-B in Class G; but of course their airspace structures differ from ours.

 

It is best if the responses to DOTRS are individual rather than standardised.

 

John Brandon

 

 

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Guest browng
It is best if the responses to DOTRS are individual rather than standardised.

John Brandon

Well here was mine. sent under my ARN as a GA owner/pilot rather than RAAus member due to the registration of my aircraft;

 

"As the owner/pilot of a vintage type, (1946 J3-C65), and also an Experimental category type, (Jodel D11), I am deeply concerned with the difficulty and cost of fitting this equipment to either of my aircraft, and the ongoing maintenance cost thereafter. At a time when general aviation is inexorably shrinking due to ever increasing costs, to mandate this for VFR operations in class G airspace, even in the vicinity of a CTAF® is simply a further nail in the coffin of the recreational element of GA, and seems to be in direct opposition to the stated objectives in the recent NPRM on the devolved regulation of recreational aviation, i.e. a cost structure that more reasonably reflects the type of use. The safety case is by no means overwhelming, opinion by no means unified, yet this could be the biggest blow to recreational aviation in many years, and at the SAAA/RAAus end of the spectrum possibly devastating"

 

 

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Guest Flyer40

Ive just read the cross industry business case. My assumptions in the post above were way out.

 

But I think there are some very positive messages coming out of the business case. Let me explain...

 

The business case looks at 3 scenarios:

 

a baseline scenario that represents continuation of the status quo (Scenario 1);

 

a scenario in which ADS-B OUT avionics are required for all IFR operations and for all

 

VFR operations that currently require carriage and use of a transponder (Scenario 2);

 

a scenario in which ADS-B OUT avionics are required for all IFR operations and for all

 

VFR operations that currently require carriage and use of VHF radio (this will be

 

implemented on a phased basis) (Scenario 3).

 

The costs of each scenario have been estimated, and include the capex and maintenance costs for ground based equipment as well as the ADS-B avionics costs for the various categories of aircraft (this is significant as I'll explain later). The avionics costs include a traffic/terrain display for GA category aircraft.

 

The value of the benefits have also been estimated, which include reduced SAR costs, reduced costs associated with CFIT and midair accidents, reduced fuel consumption, elimination of CAGRO etc etc.

 

The report doesn't deduct the benefits from the cost to tell us the final cost of each option. It's kind of improper to do that because not all the savings belong to ASA, but I'll give it a go anyway (rounding all figures up);

 

Scenario one final cost $271 million

 

Scenario two final cost $228 million

 

Scenario three final cost $222 million

 

In both safety and economic terms scenario three looks like the winner. You'll notice that the avionics cost is built into the equation. The report mentions the military self funding, but the only thing it says about civil funding is that the large aircraft will have ADS-B anyway by 2012 even under scenario one. I believe if you read between the lines there is real potential to see this report working to the assumption that GA owners wont have to pay for the equipment.

 

Shoot me down and call me idealistic, but there is potential to have a best-case situation that gives us terrain and traffic awareness in our cockpit, for free, in addition to reduced costs for ASA services because they'll be $49 million better off even after paying for our avionics.

 

The worst case is obviously that we have to pay for it while the government pockets the savings of $247 million.

 

I recommend you read the report (and at least let me know if I have misinterpreted it).

 

And at the same time keep telling them that its wrong to pass on the significant avionics cost to the individual when this report shows that ASA/DOTARS/government have a spare $249 million up their sleeve.

 

 

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As per John Brandon's post above it is better to put your own words to your reply. Read the document and make up your own minds. The RA-Aus message is we don't want ADSB to be compulsory in class G or any CTAF® Period. Other people on this forum may have different views, that is fine, we live in a democracy and can have different views. However whatever you do, take this seriously. GA people, particularly those who are upmarket, and/or fly IFR could probably live with this. RA-Aus types can't (and there are 8,000 of us now). HGFA and GFA and the Rotacraft people need to speak for themselves, but I am sure they can't live with this either in its current form. There are some powerful people in the "heavy" side of aviation who would be happy to keep all those "pesky little private planes" out in open paddocks and below 500 ft. Be vigilant. We have worked too hard to get where we are today. We can lose it through this business.

 

How to respond

 

Please forward your response to DOTARS by 31 October 2007 by one of the following means:

 

  • Fax Attn: ADS-B Proposal (02) 6274 7804
     
     
  • Post ADS-B Proposal, Office of Airspace Management,
    Department of Transport and Regional Services
    GPO Box 594
    Canberra ACT 2601
     
     
  • Email [email protected]
     
     

 

We, as Recreational Aviators must be very proactive on this matter. RESPOND NOW.

 

John McK

 

 

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Guest brentc

I personally can't see an issue with this topic if it's about improving safety. If they are talking 2012 for this technology to be mandatory I'm happy with that. I'll have plenty of time to start saving and by then who knows what technology will have done and how much we will have to pay? Given that a Garmin GTX330 ADSB transponder is around AUD$4k, units will definitely be available economically by then. As for ADSB-in, well who has TCAS now in their aircraft with a visual display? not many of us. I notice the GTX330 couples to the Garmin 396 for visual traffic displays, so all up for around <AUD$6k it's a lot less than the thousands more they are quoting in the discussion papers.

 

 

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The US FAA's NPRM for ADSB-OUT was released October 1. There is a copy on the RA-Aus server at www.raa.asn.au/navigation/ADSB_FAA_nprm.pdf

 

It's 300 KB and 100 pages but makes very interesting reading. There is no thought of subsidies to GA but the use of ADS-B OUT is only mandatory for VFR above 10 000 feet in Class E and in all other CTA.

 

John Brandon

 

 

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I've seen that US one and the AOPA US comments about it. The question is whether ADS-B in its current form does improve safety for small aircraft. Personally I don't think it does.

 

ADS-B out gives no reading in the aircraft to which it is fitted, just for those with ADS-B in - which will most likely be airline aircraft. So how many of us cruise at flight levels enroute?? I sure don't. So there is no collision risk with airline aircraft there, and assuming most GA/RAA pilots would rather spend the thousands on other things (training, engine overhauls, holidays etc) there won't be too many ADS-B ins in small aircraft. I'm sure the 'in' units will be more than $6,000. But even if they are $6,000, I'm sure we don't all have that money sitting around under our mattresses. I sure don't. Then there are fitting costs, maintenance costs etc.

 

Remember too that the airline aircraft have TCAS, so they get an audio resolution advisory if you are carrying a transponder. Of course there are non-transponder aircraft and wouldn't we all kick up a fuss if every aircraft had to have one? Why is everyone so accepting of ADS-B then?

 

OK, that's enroute. Now on approach/circuit. Now the airline aircraft are departing/descending into our airspace and there are plenty of bug smashers flying around. So we need to look out of the window. Remember that ADS-B out gives no information, and the expensive ADS-B in has no sound. So as you get near the airport and you are in the circuit, you have to look down at a screen for traffic!! To me this seems less safe, not an improvement in safety.

 

 

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One thing I think we may need to consider is the strategic direction of the RAAus - it can be presumed that we may be going to 750kg MTOW which will bring a lot of GA into the RA environment also the possibility of a controlled airspace endorsement that may also be coming in.

 

So when we think about what is best for today we also need to be aware of tomorrow and the implications of what we do today will have on the objectives for tomorrow.

 

Just wondering if this is something to also think about!

 

 

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Guest browng
it can be presumed that we may be going to 750kg MTOW ......

You really think so? I have my doubts. Part 103 is not through yet, but when it is, I believe it will fix us at the 600kg LSA limit, if only to be in line with the FAA. There is an entire new class of aircraft being manufactured around the world to comply with that FAA LSA criteria (and the RPL that goes with it), to increase MTOW beyond that will open a very big can of worms for CASA, and I don't think they will want that.

 

 

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Hi Ian,

 

I personally have no issue, and my understanding is, neither does the RA-Aus for ASDB to be fitted for entry into controlled airspace. My main concern is for the grass roots members of the RA-Aus. The ultralight people. We have become a major growth association, (while most others are shrinking) by looking after our members, and having a policy of affordable flying. "Safety with responsibility". Just look at what has happened to GA in the past few years. Now ask yourself why?

 

If we agree to this being compulsory outside CTA we are selling out not only the vast majority of our current members but also the vast majority of our future members. How are all our "Rag and Tube" members going to cope with this?. How are all the HGFA trike pilots going to cope with this, or all the roatacraft people? I will tell you how. They will be back in open paddocks like the early years. (and there are those who would prefer this to happen)

 

There is an old Latin saying "Cue Bono" It means "who benefits". We should all ask ourselves Who benefits from all this business. First, only the out link will be compulsory, who will benefit from this? Certainly not any recreation aviator. Where is the safety benefit in this if none of us has a down or in link? There isn't any. If there was a real concern about safety outside CTR the Government, instead of giving a $10,000 one off voucher for the up link only they could subsidize ALL aircraft in Australia (RPT included) with something like the current "Flarm" unit fitted to gliders. This is a very small box, draws next to no current, and costs about $600. This unit has in and out link, audio and visual collision avoidance, data logging, and output plotting for those with LCD screens. You can also have obstacle (power lines) and terrain (high ground) database alarms added. All this is available NOW for $600. (perhaps much cheaper if mass produced)

 

No I think we need to look further. Lets look at this from a "cue bono" aspect. - Who does really benefit. I have a few personal ideas. Perhaps some of you do also.

 

John McK

 

PS. In the interests of full disclosure. I have a Flarm unit fitted in my Drifter as I fly from a mixed ultralight and glider airfield. I have absolutely no connection with the manufacturer or sale of these units.

 

 

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Guest pelorus32

Hi John McK,

 

I'm with you on the who benefits question. I'm just going to play devil's advocate for a moment in the interests of making sure that we have our thinking and arguments clear.

 

You said:

 

"I personally have no issue, and my understanding is, neither does the RA-Aus for ASDB to be fitted for entry into controlled airspace."

 

I agree with that. I can also raise the issue that with a current Mode Charlie xponder there is NO benefit to the fitted a/c. There is however no suggestion that Airservices should pay for the transponder. We are talking about say $2,500 for a Garmin 327.

 

You have to go to a Mode Sierra xponder before the a/c itself gains benefit with TCAS.

 

So what's different with this proposal. You need a xponder for Class E now, and you need a xponder for CTA - what changes except the nature of the gear and therefore the cost?

 

BrownG

 

As for 600kg vs 750kg. Many of the aircraft that are approved to LSA or the UL are actually designed and built to 750kg MTOW. So what that means is that it is the legislation that is the limiting factor. With 600kg or 750kg however if you are given a MTOW of 580kg or 710kg you know that that is the design limitation of the a/c. At the moment lots of pilots are saying - "never mind 544kg cause we know the aircraft can carry more". I don't think that is very safe because often they don't really know.

 

My understanding is that with Part 103 we will initially get 600kg and the intention then is to put a submission to CASA to extend that where the a/c can demonstrate that the extra weight is within the design and construct standard of the a/c.

 

Regards

 

Mike

 

 

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Guest browng
BrownGAs for 600kg vs 750kg. Many of the aircraft that are approved to LSA or the UL are actually designed and built to 750kg MTOW. So what that means is that it is the legislation that is the limiting factor.

I understand that, I could put my 630kg J3 on the RAAus register by similar 'sleight of paper', but that was not my point, my point was that there is a direct linkage between the FAA 600kg limit and the FAA RPL, and that a US registered 600kg LSA carries the national 'N' registration recognized by international charter, as I believe will a part 103 RAAus administered aircraft carry 'VH' registration. The FAA RPL is the model for our impending 'Sport Pilot Licence', and the RPL is limited to 600kg. Overall we seem to be moving toward international standardization here, and I don't think CASA will be too keen to go it alone. I am aware that a submission is mooted, as is one from the SAAA (and allies) proposing a self administered limit up to the full PPL 5700kg, (indeed this is obliquely referred to in the part 103 NPRM), I do not however personally believe either will succeed, I hope I'm wrong, only time will tell.

 

 

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The interesting thing is that the US may possibly be going to 1400 lbs (636kg) if Cessna have their way and with the clout that they have one would have to say that the possibility is 51%+, it is all to do with the weight of their new LSA Skycatcher

 

 

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