Notice of Final Rule Making
x  7.4 Almost all the GNSS systems currently installed in IFR GA aircraft in Australia comply with TSO-C129a, not TSO-C145a/146a. For most GNSS-equipped GA aircraft, and especially recently-manufactured ones, being forced to replace existing TSO-C129a GNSS systems with ones that comply with TSO C145a/146a will involve major, expensive changes to instrument panels, radio racks and wiring harnesses because only one manufacturer has a system that can readily be installed. This would be an unnecessary and significant burden for owners of Cessna, Piper and Beech aircraft built in the last decade fitted with relatively new Honeywell/Bendix King avionics.

CASA’s response
7.1 1090 MHz ES has been established by ICAO as one of the international standards for ADS-B. Other standards for UAT and VDL Mode 4 have also been issued by ICAO. As with many other international standards for civil aviation, it is the prerogative of member states to select the standard of technology that it considers most beneficial for its particular situation taking into account international aviation inter-operability requirements.
The Asia-Pacific Air Navigation Planning and Implementation Regional Group (APANPIRG) of ICAO’s Asia-Pacific Regional Office has recommended that states in the Asia-Pacific region adopt 1090 MHz ES as the standard for interoperability and ICAO Asia-Pacific member states have stated that they will develop their ADS-B systems in accordance with that recommendation. These states include Singapore, Indonesia, Thailand, and China. For Australia, interoperability within South-East Asia is of the utmost importance to the safe and efficient management of international air transport traffic.
1090 MHz ES has been also selected as its ADS-B standard by the FAA USA, Transport Canada, and Eurocontrol. UAT will not be the basic data-link in the USA.
Since 2003, CASA has distributed information and consulted widely on the carriage and use of ADS-B. CASA has briefed the industry–based Standards Consultative Committee and its Airspace Users Sub-committee, and presented a number of working papers to the ASTRA ADS-B Implementation Team (ABIT), a joint industry/government forum established to address technical and operational issues surrounding ADS-B implementation and to coordinate the efforts of stakeholders.
CASA also directly sought the views of the Australian aviation industry before adopting 1090 MHz ES by issuing Discussion Paper DP0401AS in December 2004 for public comment and also urged the industry to provide its views. The outcome of that public consultation was published in September 2005 as a Summary of Responses to the Discussion Paper. The DP and SoR may be viewed on the CASA website.

Carriage and Use of Notice of Final Rule Making ADS-B Avionics
CASA and most of the aviation industry stakeholders consider that Australia’s adoption of 1090 MHz ES technology as its ADS-B standard ensures the greatest level of international harmonisation.
7.2 CASA is aware that there is at least one ADS-B equipment suitable for GA aircraft fitment that is currently available. It is likely that the issuing of ADS-B standards by Australia and the regulatory authorities in North America and Europe will encourage manufacturers to develop products suitable for GA aircraft fitment in the next few years.
7.3 and 7.4 CASA considers that the comments at 7.3 and 7.4 are outside the scope of the legislative change proposal that it put forward in that the fitment of ADS-B equipment is voluntary. Should aircraft operators have the concerns that this respondent has voiced, they may decide not to fit their aircraft at this particular stage. However, fitment of ADS-B will provide a significant safety benefit to IFR aircraft operators – greatly expanded ATS surveillance services in non-radar airspace areas as the ADS-B stations are rolled out by Airservices Australia.
Disposition
It has not been necessary to alter the final rule in response to these comments.
　
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