Summary of the issue:
- In 2012, NAV CANADA agrees to invest up to $150 million in Aireon to launch their space-qualified Automatic Dependent Surveillance-Broadcast (ADS-B) service which requires receivers built into 66 Iridium NEXT satellites.
- By 2019, the Iridium NEXT constellation becomes complete, providing 100% coverage of the globe with 66 on-orbit satellites and 9 additional on-orbit spares. NAV CANADA becomes the first air navigation service provider worldwide to implement space-based ADS-B in its domestic airspace.
- By February 2022, NAV CANADA publishes its mandate requiring ADS-B Out equipage for Canadian airspace. Requirements in Class A and B airspace are identified to start February 23, 2023, and no sooner than February 23, 2026, in Class C, D, and E airspace.
- COPA begins to publish a series of articles highlighting concerns with the proposed implementation of the NAV CANADA mandate of ADS-B. See below for a list of COPA’s concerns regarding the ADS-B mandate, including how COPA does not agree with NAV CANADA having the authority to mandate or to call this requirement a mandate.
- COPA provides input to Transport Canada’s space-based ADS-B stakeholder consultation process, click here to read the full response.
- By March 2022, COPA and 12 additional aviation associations send a joint industry letter to the Minister of Transport indicating concerns with the ADS-B requirement and the process used to implement the announced changes.
- By August 2022, NAV CANADA announces a delay to its ADS-B out requirement implementation dates in response to concerns voiced by COPA and other stakeholders. Class A airspace equipage requirements started August 10, 2023, and Class B is set to start for spring 2024. Class C, D, and E airspace to now take place no sooner than 2028.
- By August 2023, NAV CANADA launches an online tool for pilots to check the performance of their equipment to see if they comply with the NAV CANADA ADS-B out requirement.
COPA continues to advocate for other alternatives that are less costly to meet the desired outcome of an ADS-B airspace structure; these alternatives need to be explored as possible solutions.
Aircraft equipment and installation requirements are defined in Airworthiness Chapter 551 – Aircraft Equipment and Installation – Canadian Aviation Regulations (CARs) section 551.103 – Transponder and Automatic Pressure Altitude Reporting Equipment.
What are COPA’s main areas of concern for the ADS-B mandate?
- Under what authority is the mandate being enabled? Is this a NAV CANADA or Transport Canada mandate?
- Lack of regulatory consultation and process
- Short notice of consultation before February 2023 deadline
- Different processes/requirements to enable changes to Class A and B airspace versus changes to Class C, D and E?
- The requirement to transmit to space and ground receivers (It is understood some ground-based infrastructure is needed for the system to operate safely.)
- The difficulty of industry to equip to meet 2023 deadline
- Costs to equip ($10-15,000 CAD per aircraft)
- Lack of Cost-Benefit analysis for the aviation community
- Misalignment with US system – access and cost impacts to cross-border operations (978UAT and 1090ES Ground-based not compliant in Canada.)
- Safety and security issues with ADS-B system and ADS-B reliance on GPS.
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