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Canadian ADS-B update

NAV Canada since 2020 has been apprising aircraft owners and operators of their plans for Automatic Dependent Surveillance-Broadcast (ADS-B) deployments in Canada. In fact, Canadian ADS-B has been in the planning and deployment stages long before then, starting with the creation of Aireon in 2011. 

NAV Canada’s original ADS-B plan included two phases: Phase 1, February, 2021, Class A and Class E (above FL600) airspace; Phase 2, January 27, 2022, Class B airspace. But these plans were changed, pushing Class A and B to 2023, and changed again with Class B pushed to May 16, 2024. At that time, NAV Canada’s plans for Class C, D and E airspace were starting no earlier than 2026. That has been changed to no earlier than 2028. Recently, Transport Canada issued Advisory Circular AC 500-029, effective April 22, 2022, which outlines the compliance requirements. 

To enter Class B airspace, starting on May 16, 2024, most aircraft will be required to have ADS-B OUT with antenna diversity. Transport Canada (TC) has updated the Canadian Aviation Regulations (CARs), Airworthiness Chapter 551 –Aircraft Equipment and Installation, 551.103 Transponder and Automatic Pressure Altitude Reporting Equipment (effective 2023/07/17), to state that ADS-B OUT must include antenna diversity on specific types of transponders. 

NAV Canada recognizes that equipage may be an issue. In fact, Cirrus Aircraft, Diamond Aircraft and Kodiak (a Daher company), to name a few, have not completed their engineering studies. Purchasing a brand new Cirrus SR20 or SR22 aircraft will be equipped with a Garmin transponder which does not support antenna diversity. This is a short-term problem, while airframe manufacturers finalize their engineering efforts. Of note, Cirrus’s Vision Jet is equipped with a mode S transponder with antenna diversity.

To bridge the gap, NAV Canada has published AIC 26/23, which provides aircraft operators and pilots a process to request an exemption (on a flight-by-flight basis), allowing the flight to enter Class B airspace without ADS-B equipage. The request is submitted through NAV Canada’s website, no earlier than three business days before the flight (or five days if the flight takes place on a Sunday). Each request is reviewed by a NAV Canada staffer and either approved or rejected. Aircraft owners and operators can request a blanket exemption. This was created for those owner operators who are unable to equip based upon no engineering solution or equipage delays caused by product shortages or shop timelines. The ADS-B accommodation request form can be found at https://aar.navcanada.ca/en-CA/. 

Some Cirrus, Diamond and Kodiak owners have filed a one-time blanket exemption request with NAV Canada. Essentially, a letter requesting the exemption, as they wait for their aircraft manufacturer to create the necessary engineering documents followed by booking an installation appointment with their avionics shops. NAV Canada sees the blanket exemption as being applied to just a small number of operators. 

For other aircraft, again, a flight-by-flight exemption can be requested. This process is quite simple, with just a few pieces of technical information required. You will receive an email once your submitted exemption is reviewed and approved. In late May, I entered an exemption request onto the website and received an email with approval in roughly three hours.

For Canadian aircraft operating in American class A, B, C and ADIZ airspace, ADS-B OUT has been mandatory since 2020. The U.S. ADS-B environment is based upon a fabric of ground stations. The typical U.S. general aviation aircraft is equipped with antennas on the underside of the fuselage. Compliance to the Aireon’s space-based fabric will require an antenna installed on the top of the aircraft (like the antenna for TCAS). To facilitate compliance to both U.S. and Canadian requirements, an ADS-B transmitter which supports antenna diversity will be required. 

Garmin in March 2024 unveiled a complete avionics modernization program for the Cessna Citation CJ2, including the ability to add the GTX 345R transponder for ADS-B OUT capability with optional antenna diversity. Photo: Garmin

Michael Kussatz of Garmin International of Olathe, Kansas, explains, “This is the equivalent of having two transponders in a single product.” The requirement of antenna diversity adds complexity and cost to the technology, as well as to the installation time. 

No earlier than 2028, NC will require ADS-B OUT (1090 MHz) to enter Class C, D and E airspace. The interesting point is that NAV Canada is not a regulator. The CARs stipulate the need for antenna diversity for Class A1, A2, A3 or B1 installed equipment. Class A1S and B1S installed equipment may be installed with a single antenna. The defacto standard could be created through NAV Canada, not allowing an aircraft equipped with a single belly-mounted transponder antenna to be declined access to the airspace. General aviation flights see this behaviour from time to time when requesting transit through Class C or B airspace or when inbound to a NAV Canada towered airport. 

“The CBAA has been working with NAV Canada and Transport Canada to find a way forward as the pressure for space in congested areas of Canada is causing the need for ADS-B equipage,” says Anthony Norejko, President and CEO, Canadian Business Aviation Association (CBAA). “While the CBAA does not have a crystal ball, we feel the likelihood of NAV Canada meeting the 2028 date for Class C, D and E is relatively low. Most of our members do not see ADS-B as a hot topic.”

Robert Sincennes, VP Regulatory Affairs, CBAA, feels that equipage is less of an issue for CBAA members as their aircraft are for the vast majority already equipped given the need to fly in Class A airspace. 

“The association on behalf of members has, however, expressed concern about privacy and security issues,” Sincennes says. “With unencrypted ADS-B data, sites like FlightAware, OpenSky and ADS-B Exchange, aircraft and employee movements are easily tracked. Tracking of staff movements, during critical times for corporate entities could provide competitive information, which could be used in many different ways and yielding undesired outcomes. The association has suggested that a solution may be the cycling of transponder codes as a method to deal with privacy concerns.”

The Canadian Owners and Pilots Association (COPA) have been working with Transport Canada, NAV Canada and other industry partners to ensure a reasonable means of complying with the mandate. In early May 2024, Mark van Berkel, President and CEO of COPA, published a letter to the membership providing an ADS-B update, stating: “It is COPA’s opinion that there are challenges to implementing space-based ADS-B as it is currently defined, and to date, and with few exceptions, avionics and aircraft manufacturers have not been able to develop the necessary equipment and certification to meet the mandate for the general aviation aircraft.” 

Cirrus Aircraft’s Vision Jet is equipped with a mode S transponder with antenna diversity, which is a requirement still but under the microscope for aircraft entering Canadian Class B airspace, as of May 16, 2024.
Photo: Cirrus Aircraft

Jim Ferrier, Director of Aviation Operations at COPA, reports: “No one is questioning that ADS-B is the future of surveillance and can provide benefits to the industry, the problem arises when one looks closely at the costs that users are being asked to absorb to receive those benefits. Arguably, the ANS will gain significant operational advantages and potential savings, with a space-based ADS-B mandate, while most operators will have significant costs to receive few direct day-to-day operational and minimal safety benefits. When cost and benefit differences are examined, coupled with the apparent intention of Transport Canada to proceed without using the regulatory change process of CARAC, users begin to question how Transport Canada is representing the needs of the industry when significant benefits to the ANS are placed squarely on the financial backs of general aviation and business aviation. Some industry sources believe costs upwards of $750,000,000 to be spent by general aviation and business aviation owners and operators. If this really is about safety, there are better ways to implement technology for this cost. One only has to look at services available in the U.S., or low-cost technologies in use in Europe, and you can find ways to provide real safety benefits. 

“Thinking of our friends to the south, what is the impact of this mandate for those who will not meet the new equipage requirements? Are we now just going to close the airspace to this market and say sorry you are not welcome? Ultimately, this issue is much bigger than ADS-B equipage, it is the concern that this change appears to be setting the stage for circumventing process for any other potential future regulatory changes,” continues Ferrier. “Without following the regulatory process, it guarantees the needs and concerns of impacted stakeholders won’t be considered. Exactly what the process was established to avoid.” 

Ideally, Transport Canada and NAV Canada would collaborate with industry and users to craft an ADS-B solution which meets the needs of all parties, balancing safety, technology requirements, data and economics to a mutually desirable outcome.

My last discussions with ADS-B insiders suggest that of the 166,000 U.S. registered aircraft, 40,000 are equipped with 978 MHz systems and 126,000 are equipped with non-diverse 1090 MHz transponders. Roughly 25 per cent of the U.S. general aviation fleet are equipped with UAT ADS-B OUT hardware. Technologies like uAvionix’s skyBeacon and tailBeacon are roughly US$2,100 and, with two screws and three wires, can be installed in less than one hour by your AME (AMP in the U.S.). Again, UAT currently does not meet the Canadian ADS-B OUT mandate. But that’s not a problem until 2028, unless you fly higher than 12,500 feet.

For those pilots on a flight, not equipped with NAV Canada compliant ADS-B transponders, who may wish to enter Class B airspace, due to weather avoidance, will most likely be sanctioned by NAV Canada through the issuance of a CADORs. While it is not expected that ATC will deny the aircraft access to the airspace for safety reasons, the CADORS may be issued. The CADORS process incudes escalation to TC. It’s unclear (at this time) if monetary penalties and other sanctions would be applied against the pilot(s) and operator.

uAvionix’s skyBeacon and tailBeacon cost roughly US$2,100 and, with two screws and three wires, can be installed in less than one hour by an AME.
Photo: uAvionix

The question regarding the need for antenna diversity is a bit confusing for general aviation aircraft owners. The CARs section 551.103 indicates: “(4) Antenna installation (effective 2023/07/17) the antennas of the ADS-B equipment shall be installed so that: For Class A1, A2, A3 or B1 installed equipment, they comply with all antenna installation requirements specified in section 3.3 of RTCA DO-260B for a diverse installation and they transmit alternately towards the bottom and the top of the aircraft per the requirements specified in section 2.2.13.6 of RTCA DO-260B (“transmitting diversity”); or for Class A1S or B1S installed equipment, they comply with antenna installation requirements specified in section 3.3 of RTCA DO-260B for single antennas and it can be demonstrated that the equipment transmits satisfactorily to ground-based as well as space-based receiver in the normal aircraft operating envelope.”

TC has changed the CARs, allowing for non-antenna diverse transponders to be used based upon passing a test. Brant Aero, an airframe and avionics shop located in Brantford, Ont., are a bit confused on the specifications. From its perspective, testing an ADS-B OUT installation on the ground using its test tools, will comply with TC’s requirements. However, NAV Canada has its own testing tool, which for many ADS-B OUT installations are failing (a single parameter) while airborne. Industry insiders are finding that many 1090 MHz ADS-B installations with antenna diversity are failing NC’s airborne test (PAPR), specifically the PYIA criteria. It is currently unclear, how NAV Canada is dealing with this dichotomy. This confusion is causing some aircraft owners to delay equipage (and costs), until these issues are resolved. The implication being that aircraft owners and operators can right size the installation (or do nothing if equipped with 1090 MHz transponders equipped with single antennas).

TC’s latest statistics indicate: There is a total of 37,191 aircraft and rotorcraft; 34,922 weigh less than 12,500 pounds; 12,611 ultralight, advanced ultralight and amateur build aircraft and rotorcraft; and 2,269 weigh more than 12,500 pounds (think airliners). We might extrapolate that the bulk of Canadian aircraft are GA. The cost of ADS-B OUT equipage for the GA segment, using present day costs, could be as much at $750,000 or more. 

One challenge for general aviation equipage would be legacy aircraft without electrical systems. The NORDO radio communications process facilities those aircraft operating in and out of Class C aerodromes, using a simple telephone call to the tower to obtain landing rights. While NC provides an exemption process, the process requires three business days (up to five days for a weekend flight) to be executed, we would agree that this process is not comparable to the NORDO process and the flight behaviour of many GA pilots. The impact of the “no earlier than 2028” ADS-B mandate could cause a significant number of these pilot owners to sell their aircraft (with a high probability of the aircraft moving to the U.S.), essentially impacting the owner’s freedom to fly.

While NAV Canada and TC’s planning and announcements for Canadian ADS-B have been ongoing since before 2011, we are getting closer to the activation of the mandate into more Canadian airspace. Stay tuned over the next few months. | W