CASA’s response
The advice of CASA’s legal staff is that it is not necessary to further define the meaning of the abbreviation “ADS-B” for the purposes of the final rule. The provision in paragraphs 9B.2 and 9B.3 of the final rule is that any equipment constituting ADS-B transmitting equipment that is carried by an aircraft must meet the Appendix XI standards or be deactivated while the aircraft is within Australia. 
Disposition
It has not been considered necessary to add to or change to the definition of “ADS-B” in the final rule CAO.
COMMENT 6: MANDATORY ACTIVATION OF ADS-B TRANSMITTERS BY PILOTS
A pilot representative organisation stated that the rules should provide for mandatory activation of any ADS-B equipment fitted to an aircraft, as a routine pilot requirement. There is no provision for that in the regulatory and advisory material. AIP ENR 1.1 paragraph 72.1 only recommends activation. It is acknowledged that mandatory activation is achieved by effect of current transponder activation rules on the available avionics that combine SSR transponder and ADS-B controls. However, the NPRM presents an opportunity to make the rules robust for any future avionics that have separate SSR and ADS-B controls.

Carriage and Use of Notice of Final Rule Making ADS-B Avionics

CASA’s response
Mandatory carriage and use of ADS-B equipment was outside the scope of the NPRM. The situation is therefore basically covered by current AIP implementations in regard to the transponder activation requirement. The suggestion by the respondent for AIP instructions on ADS-B activation will be considered once the en-route radar replacement decision is made by Airservices Australia.
Disposition
Existing AIP ENR 1.1 section 72.1 is considered to be an appropriate instruction to pilots in the situation of voluntary fitment of ADS-B equipment.
COMMENT 7: ISSUES RELEVANT TO ADS-B FITMENT TO GENERAL AVIATION SECTOR AIRCRAFT – CASA choice of 1090 MHz Extended Squitter over UAT and VDL Mode 4, etc.
A respondent raised a number of issues specifically relevant to the fitment of ADS-B equipment in General Aviation aircraft. Those issues that are not covered in the previous comments are itemised hereunder:  
x  7.1 The NPRM should have explained why the 1090 MHz ES system had been chosen in preference to UAT or Mode 4 VDL and also explained CASA’s justification for specifying TSO-C166 as its standard. CASA should have sought public comments before adopting 1090 MHz ES in preference to the other systems. The NPRM does not adequately explain the fact that international approaches to ADS-B are far from aligned.
x  7.2 The major issue facing GA in relation to ADS-B is the availability and price of equipment. There are no transponders suitable for general aviation aircraft presently available that are certified to the standards required by the proposed rule. CASA should explicitly state what standards it intends to allow and if it intends to accept certification to JTSO-2C112a. If not, CASA should explain there are no transponder products currently available for general aviation.
x  7.3 If information is available which shows that TSO-C145a/146a equipment will be procurable from multiple vendors at prices consistent with, or less than, those currently associated with TSO-C129a avionics at some definite point in future, then CASA should devise a transition plan based on two dates. The first would be the date after which no more TSO-C129a equipment can be connected to ADS-B for the first time. The second would be the date by which the use of TSO-C129a equipment to supply positional data to ADS-B must cease. To accommodate economic and practical lifetimes for already-installed equipment, the first date should be no less than four years in future and the second should be no less than ten years after the first date. 
Page A10  Document NFRM 0601AS
　
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