Paul Mulwitz

While I am convinced by Capstone results and other information that ADS-B would be very beneficial to me as a VFR light plane operator, I feel this NPRM is premature. There are many questions that are not yet answered in this proposal or any other source that I am aware of. Until these issues are properly addressed, I feel it is too early to mandate equipment requirements for all aircraft. There are two different levels of issues that need to be addressed. First, the question of equipment requirements that are replaced by the new ADS-B equipment must be defined. Second, the procedures and requirements for pilot to controller communications with the new equipment environment must be considered both in general terms and details. It is clear that ADS-B equipment takes the functional place of other ground and airborne equipment in the NAS. However, this NPRM only calls for additional equipment to be placed in aircraft and doesn't address the issue of which old equipment can be removed. There should be a definition that states, for example, that ADS-B equipped aircraft don't need transponders to operate in the controlled airspace environments where the rules currently call for transponders as required equipment. I am not aware of any description of the method for communication between pilots and controllers in an environment that includes ADS-B equipment. I don't know if the new equipment will provide digital communications of ATC clearances, vectors, or other such items. A clear definition is needed of how such communications will take place. Will analog radio still be used for all pilot/controller communications? Will analog radio become obsolete under the new system? On a more detailed level, there is a need for new procedures under today's environment as aircraft are equipped with the new ADS-B equipment. There are already several areas where the ground equipment is in place, but there is no allowance that I am aware of in the standard requirements for the advantages and differences this equipment affords. For example, the customary reporting of altitude when a pilot contacts a controller for the first time is currently needed to allow the controller to calibrate the blind encoder error shown on his screen for mode-c transponder reports. This is not required and has no value when the reported altitude is GPS based rather than blind encoder based. To encourage early adoption in the light GA community and particlarly in the VFR community, I feel there should be an education program instituted and widely publicized that teaches primarily VFR pilots about the advantages of ADS-B and the procedures for using it. It is particularly important that the need for older obsolete equipment be removed from the rules so owners can balance more practical equipment costs against the performance gains afforded by the new equipment. If there is no reduction in required equipment as the functions are replaced by the new equipment then I doubt many owners will adopt the new standard.