Recreational Aviation Australia this week said they supported an VFR ADS-B mandate provided it was implemented using a risk-based approach.
In a submission to departmental consultation on mandating ADS-B Out for VFR aircraft, including RAAus-registered aircraft, Chief of Aviation Cody Calder said a broad mandate could impose significant costs on their membership base.
"We are broadly supportive of ADS-B as a technology that improves airspace awareness and collision avoidance potential," he said.
"However, any mandate for ADS-B equipage should be implemented using a risk-based approach, particularly to avoid imposing unnecessary burdens on operators in remote or low-traffic areas, where the likelihood of aircraft conflict is minimal."
RAAus' data shows that only 40% of aircraft registered aircraft with them are fitted with a transponder, meaning the financial impacts of mandating ADS-B are significant.
"Consideration must be given to the economic viability for these stakeholders and the availability of ongoing government incentives and phased implementation pathways," Calder said.
RAAus has called on regulators to make sure any mandate for ADS-B in VFR is accompanied by proper training material for pilots.
"Any mandate must be accompanied by comprehensive training materials and awareness programs that focus on the correct operational use of ADS-B equipment," the RAAus submission states.
"Emphasis should be placed on retaining good airmanship practices, such as maintaining a proper visual lookout and radio procedures, and avoiding overreliance on technology, which could introduce new risk factors such as pilot complacency and distraction."
Among the concerns raised in the RAAus submission are:
- some RAAus aircraft don't have the electrical systems to power ADS-B units
- technology becomes obsolete quickly, resulting in costly re-fits
- a lack of engineers to fit ADS-B equipment
- more investment is needed in ground infrastructure to ensure adequate coverage
- ADS-B should not be a substitute for airspace strategy.
"We welcome continued collaboration with the Department and relevant agencies to ensure the safe, fair, and sustainable integration of ADS-B technology into Australian aviation," Calder said.
The Federal Government published a consultation paper last month exploring a mandate for VFR ADS-B, which remained open for public comment until 27 October.
According to a Discussion Paper attached to the consultation document, ADS-B has a role to play in enhancing safety, and the government expects expanding the mandate to cover VFR aircraft will deliver the following benefits:
- reduce the risk of mid-air collisions
- facilitate safe integration of emerging aviation technologies
- improve the quality of air traffic services
- increase SAR rescue efficiency
- provide more information in accident investigations.
A significant motivation for forcing VFR aircraft to adopt ADS-B is the rapid growth of uncrewed aerial systems and the emergence of eVTOLs used in advanced air mobility (AAM) operations as early as 2032.
A Federal Government subsidy for VFR aircraft owners to install ADS-B equipment has been in place since 2022, offering a subsidy of to 50% or $5000 for VFR aircraft owners who voluntarily fit ADS-B avionics in the form of panel-mounted systems or electronic conspicuity (EC) devices.
However, the subsidy scheme is thought to be under-subscribed due largely to a lack of engineers to fit the equipment.