AOPA Pilot Magazine - June 2019 - 97

with ADS-B Out equipment," the agency
wrote in the policy statement. "Therefore,
an ATC authorization allowing an operator
to deviate from the equipage requirements of
[FAR] 91.225 must be requested and obtained
prior to the operation."
ADS-B rules require that the operator of
an unequipped aircraft request an authorization at least one hour prior to the flight.
The FAA will not issue in-flight authorizations to operators of non-equipped aircraft,
nor will air traffic control facilities accept
telephone requests.
Only if ADS-B Out equipment fails in
flight will controllers be able to issue an airspace authorization to an airborne aircraft,
said Rune Duke, AOPA senior director of
airspace and air traffic. Otherwise an authorization must be requested at least one hour
in advance, through a website that is being
developed. "We can expect the website for
non-equipped authorizations to be available
before 2020, likely by December," he said.
Operators of scheduled flights should
not expect much in the way of accommodation. "Per-operation authorizations were not
intended to support routine and regular operations of non-equipped aircraft in ADS-B Out
airspace," the FAA stated. "The FAA will not
issue daily or routine authorizations for
scheduled operations. While ATC will consider requests from scheduled operators, it
is very unlikely to issue an authorization to
a scheduled operator on more than an occasional basis and is most likely to issue an
authorization when a compelling or unanticipated need to deviate from the ADS-B
Out equipage requirements exists. "It will
be difficult for unscheduled operators conducting operations at capacity-constrained
airports to obtain authorizations. Given the
complex and dynamic nature of operations
within this airspace, it is unlikely that ATC
will prioritize authorization requests for
unequipped aircraft over providing air traffic
services to aircraft equipped with ADS-B Out
equipment," the policy reads. "Unscheduled
operators with a need to access this airspace
on more than an occasional basis should
equip with ADS-B Out to ensure no disruption to operations."
An "unscheduled operator" is defined as
any flight that does not meet FAR 110.2's definition of scheduled operations, including

Part 135 commercial operations as well as
GA flights conducted under Part 91.
The FAA's Air Traffic Organization is
responsible for issuing preflight authorizations to unequipped aircraft under FAR
91.225(g), while its Aviation Safety organization will be responsible for post-flight
oversight of the operations. The system
will track both the issuance and denial of
airspace authorization requests. Any pilot
who operates a non-equipped aircraft in
ADS-B airspace without obtaining a preflight authorization in accordance with FAR
91.225(g)(2) will be deemed to have violated
the regulations.
AOPA is working closely with the FAA
on the final policies that will govern non-

The FAA is placing the
burden for approving
non-equipped aircraft
operations in ADS-B
rule airspace primarily
on the aircraft
operator-and not
on the FAA.
equipped aircraft flying in close proximity
to rule airspace. "We are making progress on
ironing out the policy that will govern pilots
and air traffic controllers should vectoring
and other air traffic clearances require a pilot
to fly into rule airspace without prior authorization," Duke said. "It could be a safety issue,
so we are working to ensure pilots and controllers do not unduly have their hands tied. If
you regularly fly near rule airspace, it is a good
idea to look at whether you need to equip."
OTHER CONSIDERATIONS

Pilots, especially renters who fly different
aircraft, must clearly understand ADS-B
rule airspace so they can avoid it when flying aircraft without ADS-B Out. Read the
pilot's guide, user manual, or flight manual
supplement for installed ADS-B Out hardware. They will advise you to power on your
ADS-B Out, and/or turn your transponder
to the ALT setting, immediately after turning on the avionics.

This has been a challenge for pilots who
learned years ago the memory aid, "Lights,
Camera, Action" as they turned on the landing light and transponder while rolling onto
the runway for takeoff. (The problem has
been seen repeatedly in failed Public ADS-B
Performance Reports received by aircraft
owners attempting to validate their installation and qualify for the FAA's rebate.) Many
are surprised to learn this rule is nothing
new; in Information for Operators 11012,
dated May 23, 2011, the FAA advises airline
pilots to "select transponder to the altitude
reporting position during pushback."
This is to ensure that aircraft are visible to
ATC surface surveillance systems. (Aircraft
with a Traffic Alert and Collision Avoidance
System, or TCAS, should wait until taking
the active runway to select traffic advisory/
resolution advisory mode.) Surface detection-and the time required for the associated
GPS receiver to determine its position-are
why ADS-B should be turned on before taxi,
not immediately before takeoff.
AOPA has been receiving a lot of questions about the two ADS-B datalinks, 1090
MHz Extended Squitter (1090ES) and
978 MHz Universal Access Transceiver
(978UAT). A 1090ES solution will be built
into a Mode S transponder, while 978UAT is
a remotely mounted unit that works in conjunction with an existing transponder. Both
are approved in the United States; however,
1090ES is required above 18,000 feet and also
is the only international standard-choose it
if you plan to operate outside the U.S. border.
In general, 978UAT hardware costs less
than 1090ES equipment. In most cases,
however, the cost of installing a 978UAT
product will be more than for a 1090ES
transponder. When considering solutions,
always compare installed costs, not just the
price of the hardware.
Want to save $500 on your installation? In
mid-April the FAA still had about 1,500 ADS-B
rebates remaining. They're available until
October 11 or all have been reserved, whichever occurs first. For more information, see
the website (faa.gov/go/rebate).
AOPA
EMAIL mike.collins@aopa.org

LEARN MORE

See AOPA's online ADS-B resources (aopa.
org/adsb) and ADS-B selection tool (aopa.
org/adsbselector).
www.aopa.org/pilot AOPA PILOT | 97

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AOPA Pilot Magazine - June 2019

Table of Contents for the Digital Edition of AOPA Pilot Magazine - June 2019