Nearly a thousand aircraft operating in European airspace are at risk of not being equipped with ADS-B Out avionics by the time the region’s airspace equipage mandate becomes effective next year.
The European Commission Implementing Regulation (EU) No. 1207/2011 is applicable to aircraft with a maximum takeoff weight of 5,700 kg/12,500 lbs. and maximum cruise velocity above 250 ktas. These aircraft types need the following aircraft electronics and equipment to become compliant:
- DO-260B transponders
- ADS-B Out capable GNSS/MMR/FMS
- EASA Approved STC Package
- Updated Aircraft Documentation
Europe’s ADS-B Out mandate was revised a few times after its first introduction and officially adopted in December 2013, originally requiring operators to comply by Jan. 8, 2015. However, once regulators learned that timeline was unachievable due to delays in certification and industry capacity constraints, the mandate was moved to June 7, 2020.
During a workshop held in Brussels on July 4, the European Commission confirmed it will keep the mandate in 2020 while working with stakeholders to navigate challenges to upgrading with ADS-B. At that workshop, Jürgen Lauterbach, manager of corporate aircraft purchasing at Lufthansa, made a statement reflecting the reality of equipage rates in Europe.
“The retrofit of the complete European fleet is just impossible at this point in time to be completed in 2020,” he said. “We will not be ready, it’s not possible, we’d like to support the project, no doubt about that, but we need to start with reliable plans from now.”
Avionics International inquired via email what progress the German airline has made on its ADS-B Out fleet equipage since then, and a representative stated they were unable to comment.
When asked the same question, other European carriers, including Finnair, SAS, Norwegian and Air France either did not reply or also were unable to comment, reflecting their preference to allow for a new implementation plan to be developed.
A European ADS-B Exemption?
The agency leading the charge in developing a new regulatory policy that will allow for some aircraft to be exempt from the mandate when it becomes effective next year is the Single European ATM Research Agency Deployment Manager (SESAR DM). A November 2018 SESAR DM survey of European aircraft owners and operators found that more than 7,750 aircraft are affected by the mandate. SESAR DM’s ADS-B team analyzed data from 3,700 of those aircraft and discovered that 15 to 25 percent of those surveyed would not be compliant in time.
“Currently EASA is developing a proposal for potential exemptions based on the ADS-B Implementation Plan developed by SDM, which will be assessed by the European Commission and should be published soon,” said Jan Stibor, ADS-B program manager for SESAR DM.
Aircraft operators surveyed by SESAR DM submitted plans to the agency that included each individual aircraft by type and variant, MSN and the registration number and its current ADS-B capability — whether the aircraft is already equipped or by what date it will be equipped.
The plans also include the phase-out date of aircraft where known, the phase-in dates for new aircraft that will become part of the fleet in the future, and finally the individual cost of equipping each airframe, according to Stibor.
“These plans were consolidated in a SDM-internal database, which was subsequently used to elaborate the ADS-B Implementation Plan,” Stibor said. “Potential exemptions should be based on these plans.”
While neither SESAR DM nor the European Commission were able to confirm what an exemption in Europe would look like, both stated that an exemption policy is being developed. The world’s current example of an ADS-B Out exemption policy primarily geared toward airlines exists in the United States, providing a template that Europe could choose to follow. However, that policy still requires aircraft to be equipped, but not with all of the electronics required by the FAA’s 2020 rule.
Under the FAA’s Exemption 12555 policy, a one-time grant of exemption for aircraft from 14 CFR § 91.227 (Federal Aviation Regulations) exists for aircraft that are ADS-B Out equipped using qualifying GPS receivers when their performance falls below the requirement and backup surveillance is available.
The FAA established that exemption to address the performance characteristics associated with the three different variants of GPS receivers that are currently found in air transport category aircraft. Operators use these receivers to meet the ADS-B Out navigation integrity category requirements.
However, the difference in Europe at this point — pending further analysis of SESAR DM’s survey — seems to be that too many aircraft simply aren’t equipped at all at this point.
Installations and ANSPs
What is causing the delay of equipage? The answer is complicated, but SESAR DM’s report confirmed several observations that stakeholders have been trying to resolve for several years. Two of the primary causes are a lack of harmonization between the different European states in terms of ADS-B ground station deployment and a lack of equipage plans for older aircraft by operators.
ADS-B ground stations are one of several means of achieving airspace coverage. It comes down to a business decision of each European Union air navigation service provider to design their surveillance infrastructure commensurate with the target level of service. This is much different from the situation in the U.S., where the FAA completed the ground infrastructure deployment for its entire flight information region in 2014.
According to state-by-state ADS-B ground station status data collected by SESAR DM, several countries, including Croatia, France, Latvia and Lithuania do not have ADS-B stations deployed at their main national and regional airports.
“Operational use of ADS-B exists in a few specific locations today, supporting the provision of Flight information service,” Stibor said. “ADS-B Ground coverage is being deployed rapidly; SDM estimates that with the current rate of deployment, almost all of EU continental airspace will have ASD-B ground coverage by 2023.”
Equipage delays are not all due to operators and air traffic companies, though. There are some aircraft models operating in Europe for which ADS-B Out upgrades compliant with the rule were only recently made available. One such model, the ATR-500 turboprop, did not have a DO-260B retrofit option available until late 2018.
Decisions to equip aircraft with ADS-B Out are also not always in control of operators. Some business aviation companies face complicated situations.
“It isn’t our choice about whether aircraft have ADS-B or not, ultimately it is the choice of our clients,” said Harry Jones, an aircraft maintenance engineer for Gama Aviation. “When they choose to make their upgrades, they make them, we have no direct control over that decision. The aircraft we have more direct control over for specific missions that are contract work related, they’re being retrofitted of course. But an owner of a Challenger 604 for example, it really is up to them when they choose to press the button.”
Many operators also have to consider the cost of the ADS-B Out upgrade as well, which in some cases for older aircraft might outweigh the actual value of the airplane itself. EASA estimates a cost range of $60,000 to $530,000 per aircraft for those that still need upgrades.
After the European Commission made it clear that the deadline for ADS-B Out equipage remains firm despite consideration of an exemption policy, MRO facilities have seen an uptick in demand for ADS-B Out upgrades.
“After the July workshop last year, we started seeing a significant increase in demand for ADS-B upgrades, including from some of the larger operators in Europe,” said Erik Louis, product manager for ADS-B Out at GKN Fokker Services, which has an installation facility in the Netherlands.
Some of the models GKN Fokker expects to see more demand for include the Boeing 747-400, 757-200 and 757-300 models. The company obtained EASA supplemental type certificates for those aircraft in February. They also provide upgrades for Airbus A320s, Boeing 737s, 767s and Bombardier Dash 8s as well as Fokker 50, 70 and 100 models.
Louis said upgrade costs can vary, but become more expensive based on the type of Global Navigation Satellite System (GNSS) source installed on the aircraft. Typical modification packages include modification packages include brackets, transponders, GNSS receivers and transponders, he said.
“There are cases when the only upgrade that is required is a Transponder upgrade or replacement, including wiring updates, which can be installed in an overnight,” Louis said. “However, in many cases the GNSS source needs to be upgraded, changed or replaced. Furthermore, as also indicated, in mainly older aircraft, adjacent equipment such as air data computers need to be upgraded.”
Once the European Commission approves a new ADS-B Out implementation plan, operators will have more clarity on what they need — and when.