In this issue:
- NRC on anti-innovation ATC culture
- Evidence on arm’s-length safety regulation
- Eno report calls for ATC corporation
- Would an ATC corporation be constitutional?
- FAA’s dire FY 2016 budget
- GAO on aircraft cybersecurity vulnerability
- Upcoming Event
- News Notes
- Quotable Quotes
NRC Slams FAA’s Anti-Innovation Culture
In what the Washington Post called “the most scathing criticism to date for the pace of [FAA’s] efforts,” an expert committee appointed by the National Research Council has concluded that the FAA is not delivering anything like the original NextGen vision. “NextGen as currently planned will not have significant amounts of new automation (as was envisioned by the early JPDO [the Joint Program Development Office charged with coming up with what became NextGen]),” the experts concluded. The report continues, “New technologies under consideration imply changed operations to realize large value, . . . the FAA has not addressed this.” And, “Although some technologies and/or systems will be new, in most cases current plans call for them to be used in a way nearly identical to existing capabilities.”
While acknowledging the importance of replacing aging facilities and obsolete technologies, the committee found that NextGen is not “broadly transformational. . . . And thus it is not an implementation of the early JPDO vision. . . . Many of the specific goals described in early JPDO discussions, such as free flight or air traffic control based on predefined 4-D flight trajectories, to enable global optimization of the airspace, will not come to fruition in the foreseeable future.” Achieving such goals would require full deployment of advanced technologies, using those capabilities to support higher levels of automation, full equipage of nearly all aircraft and widespread revision of procedures. “Most important, however, they will await the organizational will to modify the human roles and responsibilities of the participants in the NAS.”
The committee concludes that, in effect, aviation stakeholders have been misled, and unless there are major changes in the status quo, they should adjust their expectations downward, because “NextGen has become a misnomer.”
This report reinforces my view that the ATC system’s problems go far beyond insufficient and unstable funding. They require major changes in both governance and organizational culture. In discussing resistance to changing traditional ATC roles, the committee notes that “a conservative safety culture that makes changes to procedures slow and expensive,” combined with both limited resources and inability to implement widespread change, has “stalled efforts to make the fundamental changes to the concept of operations that the JPDO envisioned.”
Discussing this point in more detail, the report delves into FAA’s organizational culture:
“The FAA and the United States rightly pride themselves on a devotion to safety and an excellent safety record to match. At the same time, a conservative safety culture can affect how quickly process and technological change can happen-a challenge in an arena where technologies change rapidly. Such a culture may inhibit the adoption of new technologies or increased automation that could potentially result in net improvements in both safety and efficiency. . . . [I]f the FAA is going to be held accountable for an extremely conservative safety culture-which has historically been the case-then it should be recognized that such conservatism will understandably bias the agency away from innovation. Thus, there are risks associated with a safety culture as well, not least of which are the opportunity costs due to not deploying improved (and potentially even safer) technologies and procedures in the long run.”
That risk-averse organizational culture is built into the DNA of the Air Traffic Organization because it is in the DNA of the FAA itself. That may be appropriate for the FAA as aviation safety regulator, but it is counter-productive in a 24/7 high technology business charged with operating and improving the infrastructure on which all U.S. aviation depends. That is why a precondition for changing the ATO’s anti-innovation culture is separating it from its safety regulator-just as Boeing, Exelis, Honeywell, and all the other aviation technology innovators are at arm’s length from the FAA safety regulator.
Putting the ATO at arm’s length from FAA, while necessary, is not sufficient to change its culture. It needs to be entirely outside of government, freed from the constraints of civil service so that it can recruit, properly compensate, and hold accountable for results top-notch program managers, engineers, and software people. It needs to be reoriented from constantly having to respond to oversight and micromanagement from 535 members of Congress, GAO, OIG, OMB, etc. and instead be directly accountable to a board of directors consisting of its aviation stakeholders. To deliver value to its customers, it needs to be able to make business decisions about which facilities to replace, consolidate, or shut down. And of course it needs to be paid directly by its customers for the services they receive, just as airports, railroads, and electric utilities are.
That is the case for ATC restructuring in a nutshell, and we are all indebted to the National Research Council for helping to make the case. (National Research Council, A Review of the Next Generation Air Transportation System: Implications and Importance of System Architecture, May 1, 2015)
What Happens After ATC Is Separated from Safety Regulation?
It’s understandable that some in aviation consider the idea of separating the ATO from the FAA as a kind of leap into the unknown, with possible negative consequences for air safety. The fact that such separation has been ICAO policy since 2001, and that more than 50 countries have each corporatized their ATC provider by separating it from the transport ministry that now regulates it at arm’s length, does not seem to have had much of an impact on those fears.
So I was pleased to learn that last summer the FAA itself asked MITRE Corporation to investigate six cases in which developed western nations made this transition. The six countries are Australia, Canada, France, Germany, New Zealand, and the United Kingdom. All six ANSPs are technologically sophisticated. Four have major oceanic airspace responsibilities, and all have at least some dense air traffic in the vicinity of major cities. The task given MITRE researchers was to document what happened to the safety regulator after the transition-governance, autonomy, structure, and funding-as well as lessons learned.
MITRE’s blandly titled “CAA International Structures” is dated October 2014. Its major findings are summarized in the initial 10 pages, followed by six appendices, describing each country’s transition in more detail. You can read it yourself at: https://www.mitre.org/sites/default/files/publications/pr-15-0859-caa-international-structures.pdf.
MITRE found that most of the civil aeronautics authorities (CAAs) are funded primarily from payments made by users, rather than taxes. This frees the safety regulator from reliance on the government’s budget. It also makes it vulnerable to downturns in funding due to reduced flying during recessions. But it also makes the aviation stakeholders more directly aware of the costs of the regulatory agency. Four of the six (all except France and Germany) have shifted “from a compliance-based model to a risk-based model” of air safety regulation-meaning that instead of enforcing prescriptive standards with equal vigor on everyone, they focus more attention on those that appear to pose greater than average safety risks. This proved to be a difficult culture shift, but so far “there is no evidence that a risk-based approach is less safe than a compliance-based one.” All the CAAs except the U.K.’s remained government organizations, and the latter was converted into a nonprofit corporation. Most CAAs also carry out an array of functions in addition to air safety regulation.
The longest discussion deals with separation of the ANSPs from the CAAs. As an overall conclusion, the MITRE team found that “In all cases, the separation of the ANSP from its CAA was reasonably successful. . . . There are no cases where ANSP separation was reversed, and MITRE did not discover any views that the system prior to separation was preferred.” Moreover, “The collective experience after separating the ANSP from its CAA is quite good. . . . Despite the many approaches to organizing the CAA and the ANSP, in each case the safety record of the ANSP was equal to, or better than, the record prior to the separation.”
Scalability is another issue discussed by the MITRE team, since that question has been raised by some stakeholders regarding the applicability of overseas ANSP reforms to the much larger United States. “During discussions with the CAAs, MITRE asked if there were any issues associated with the separation of the ANSP that would prevent scaling their CAA and regulatory systems to the size and complexity of the U.S. NAS. They could not think of any, but were quick to point out that their airspace was quite different from the U.S.”
Finally, “The CAAs we interviewed were unanimous in stating that the separation of the CAA from air traffic service provision was worth it. Among the benefits they expressed were an increased focus on safety by the Regulator and the ANSP, improved efficiency of the ANSP, reduction in total cost to users, and improved participation by aviation stakeholders.”
This report is an important contribution to the ongoing discussion of U.S. ATC restructuring.
Eno Report Calls for ATC Corporation
For the past year and a half, I have represented Reason Foundation as a member of the Eno Center for Transportation’s NextGen Working Group. Almost every month, I’ve racked up frequent flyer miles to and from Washington, to take part in working sessions, with nearly all aviation stakeholders participating. This week, the Working Group’s final report was released, coinciding with the Senate Commerce Committee hearing at which the group’s co-chair, former Sen. Byron Dorgan (D, ND), testified.
Besides providing a historical overview of U.S. air traffic control and its problems, the report includes six case studies of overseas ANSPs-government corporations in Australia, Germany, and New Zealand, a self-supporting ANSP within government (France), a for-profit public-private partnership (U.K.), and a nonprofit, stakeholder-governed corporation (Canada).
While those portions are important and well-done, the real meat of the report is Part 3, which analyzes four alternatives for U.S. ATC reform: a government corporation, a nonprofit corporation, a for-profit private corporation, and funding reform within the current structure. The latter two are rejected-the for-profit corporation for presenting some unique problems and having no stakeholder support, and the funding-reform-only approach for not addressing enough of the problems that need to be solved.
The discussion of the remaining two wisely notes differences between how government corporations overseas are often set up (as real businesses incorporated under corporate law, with significant autonomy) and typical U.S. government corporations such as Amtrak, the Postal Service, and the TVA. Weighing this realistic view against the statement of principles adopted previously by the Working Group, it finds both promise and limitations with this alternative. A similar analysis of the nonprofit, stakeholder-governed corporation finds only one extant example-Nav Canada-and judges that this would be a more drastic change than converting the ATO into a government corporation. In part because there are genuine trade-offs between the two, and in part because getting a consensus on one or the other among that diverse group of stakeholders would likely have been impossible, the report leaves it to the reader to weigh the pros and cons of each.
You can download the full report at http://www.enotrans.org/projects/nextgen-working-group.
Included on the home page is a list of members that agreed to be listed, along with co-chairs, former DOT Secretary Jim Burnley and former Sen. Byron Dorgan. Listed participants include 13 organizations and nine individuals, most of whose names you will recognize. The organizations include the Aerospace Industries Association, Business Roundtable, U.S. Chamber of Commerce, and U.S. Travel Association; two airlines (Alaska and American); Boeing; two airline associations (A4A and IATA); the Aircraft Owners & Pilots Association (AOPA), Reason Foundation; and two unions-ALPA and NATCA. Several other stakeholder groups attended some of the meetings and took an active part in Working Group discussions, but apparently did not agree with enough of the report to be listed.
Eno deserves our thanks for conceiving this project and providing logistical support for it over many months of spirited discussion and large amounts of time volunteered by Working Group members. The report is an important contribution to the much-needed conversation on fixing what’s wrong with our ATC system.
Would an ATC Corporation Be Constitutional?
Rep. Peter DeFazio (D, OR) is the ranking member of the House Transportation & Infrastructure Committee. Despite discussions with a number of knowledgeable people, he is not yet persuaded than an ATC corporation is the right solution for America’s ATC problems. So he asked the Congressional Research Service to look into whether such a corporation would be constitutional. Those questions would probably not arise with a government corporation, but DeFazio gave CRS an earlier version of the nine-page Term Sheet developed by the Business Roundtable’s advisory group on ATC reform. The term sheet lays out a specific proposal for a non-profit, federally chartered ATC corporation governed by a stakeholder board-basically, a U.S. adaptation of the Nav Canada model.
The CRS analysis, dated April 10th, was produced by a legal analyst whose name has been redacted from the copy in circulation. It briefly summarizes the Term Sheet’s proposal, but inserts a definition of primary responsibilities footnoted as having been provided by DeFazio’s office-and therein lies a basic flaw in the analysis. Those inserted sections assert that the corporation’s primary responsibilities will include “establishing air traffic control procedures similar to those currently existing in FAA Order JO7110.65V,” along with issuing instructions to pilots, implementing modernization programs, reporting violations to FAA, and taking part in international forums such as ICAO.
The inserted words within the quotation marks above provide the main rationale for the CRS finding that there may be constitutional concerns. Those words, if taken literally, would mean that the corporation itself would be establishing the rules of the air, which would run afoul of the legal principle that Congress cannot delegate legislative or regulatory authority to a private entity. The Term Sheet says no such thing, nor are ATC corporatization proposals intended to do that. The whole idea of separating ATC safety regulation from operation of the ATC system is to retain in government the power to make the regulations, with the corporation authorized to operate the system in compliance with current and future Federal Air Regulations (FARs).
The unnamed CRS analyst agrees that case law certainly allows for a private entity to propose new regulations, new flight procedures, and the adoption of new technologies (such as equipage with a new ATC technology). All the valuable work of RTCA’s NextGen Advisory Committee (NAC) would be irrelevant unless the law permitted such carefully worked out advice to FAA on what stakeholders think makes sense. The ATC corporation would play a similar role, hopefully making proposals that would speed up the routine use of curved RNP approaches, 4-D trajectories, etc.-but the final yes or no decisions would still be up to the FAA as safety regulator.
The report raises other concerns under the headings of Due Process (would the Corporation’s stakeholder board be coercing members who lose a vote over fees or equipage) and over whether the board members could be appointed by stakeholders instead of the President. The legal ins and outs here will require careful analysis, not my amateur non-lawyer speculations. But the report concludes with an escape hatch, recognizing a way out. “In many ways, the evaluation of whether the Corporation exercises ‘significant authority’ is analogous to whether it exercises ‘regulatory authority.’ To the extent that the Corporation is subject to significant FAA oversight; is limited to advising the FAA; or acting in a ministerial manner to implement FAA standards, it is unlikely to be exercising significant authority. Thus, a reviewing court is unlikely to consider the exercise of such authority by the Corporation to be an infringement on executive power.”
I watched part of the Senate Commerce Committee hearing on ATC reform, and was dismayed to hear that at least one witness and a number of Senators seem to think Congress can or will pull a funding rabbit out of some hat that will solve our ATC problems. Earth to Senators: there is a sequester going on.
The House Appropriations Committee approved the FY 2016 budget for the Department of Transportation and the Department of Housing & Urban Development (affectionately known as the THUD bill). Given overall budget limits, the total allowed for THUD was $55.1 billion. The portion allocated to FAA is $15.854 billion, which is 0.8% less than the actual budget for FY 2015 (which we’re in now). The line item for FAA Facilities & Equipment is $2.5 billion, 3.8% less than 2015 and the lowest total in 15 years. In the horse-trading that went on over amendments, a Republican measure to spend $25 million more on the Washington Metro was approved, offset by a $22 million cut in FAA overhead. Such are the ways of Congress, which is why so many stakeholders want to get NextGen and the rest of the Air Traffic Organization out of the federal budget and made self-supported from fees for ATC services.
To be sure, this is not the last word on the FAA budget. The THUD bill must be approved by the full House, and must then be reconciled with whatever DOT budget the Senate passes. Still, there is no sign here of a new infusion of funding into an FAA forced to make trade-offs among salaries, new technology, and refurbishing decrepit facilities.
One other trend worth noting is the “general fund contribution” to the FAA budget, long defended by general aviation and others as reflecting the general benefits of aviation to the U.S. economy, etc. Although it has averaged 23% of the budget over the past 15 years, not many have noticed its sharp downward trend since FY 2013. After hitting what seemed like a low of 17% in 2014, it plunged to 7.2% in 2015, and is just 6.4% in the budget approved by House appropriators last week. This trend suggests that the aviation community needs to start thinking about how to pay for the FAA’s non-ATC functions with something other than a disappearing general fund contribution.
GAO Report and Wired Story on Aircraft Cybersecurity Vulnerability
When I first read the recent Wired article in which hacker Chris Roberts (now under FBI investigation) claimed that he had hacked into airliner inflight entertainment systems-and from there into the flight management system in the cockpit-I dismissed this as highly unlikely. Who would design or install a passenger entertainment system that could provide an electronic pathway into critical safety-of-flight systems? And who would approve such systems?
But then I belatedly read GAO-15-370, “FAA Needs More Comprehensive Approaches to Address Cybersecurity as Agency Transitions to NextGen,” released April 14, 2015. There I learned, as John Croft summarized in Aviation Daily (May 2nd), that “the threat of intrusion is increasing as aircraft cockpits and the cabin share Internet Protocol (IP) connectivity, primarily through information systems connected to both the cockpit avionics and the inflight entertainment systems.” Oh-oh. Four cybersecurity experts told GAO investigators that “because firewalls are software components, they could be hacked like any other software and circumvented.” The report says that when the cabin and cockpit systems use the same physical wiring harness or router and both use the same IP platform, they could be vulnerable. Specifically, “A user could subvert the firewall and access the cockpit avionics system from the cabin,” according to one of GAO’s experts. Hence, “Internet connectivity in the cabin should be considered a direct link between the aircraft and the outside world, which includes potential malicious actors.”
The report goes on to criticize FAA for not taking cybersecurity seriously enough. Its Office of Safety (AVS) certifies new interconnected systems on an aircraft-specific basis, but started developing rules for certifying the cybersecurity of all new aircraft systems in 2013. It stopped work on that last year after deciding that it needed more outside input. In December FAA authorized an aviation rule-making committee (ARC) to study the issue and report back by May 2016.
That was before hacker Chris Roberts surfaced, claiming that he has hacked into the systems on board 737s, 757s, and A320s for the past several years, and is seeking to alert airlines and the FAA to their cybersecurity vulnerabilities. It’s frightening to think that he may have actually done what he claims to have done-including gaining access to an engine thrust control. It might be prudent for the FAA to insist on recommendations a lot sooner than May of next year.
Air Traffic Control: Symposium on Organizational Reform Options, Transportation Research Board, July 7, 2015, National Academy of Sciences Building, Washington, DC. (Robert Poole speaking). Details at: http://www.trb.org/PolicyStudies/Blank6.aspx.
Aireon Signs More Memoranda of Agreement. Space-based global ADS-B provider Aireon has announced two additional Memoranda of Agreement with ANSPs. Aireon will work with the Civil Aviation Authority of Singapore to define requirements and procedures for using its services in the Singapore Flight Information Region, including portions where there is no radar surveillance. Aireon has also signed a MOA with the Blue Med Functional Airspace Block, representing the ANSPs of Cyprus, Greece, Italy, and Malta, to assess the implementation of space-based ADS-B surveillance in their Mediterranean airspace.
Cat. III GBAS Expected by 2018. FAA announced last month that it expects to approve Category III autoland capability for GPS-based landing systems in the United States by 2018. At this point, the only FAA certified Ground-Based Augmentation System (GBAS) is Honeywell’s Smartpath, in service at Houston and Newark (as well as Boeing’s Moses Lake, WA airport test center). Delta and United are both using the systems at Houston and Newark for approved Cat. I landings, and have equipped significant portions of their Boeing fleets. Overseas airlines using the IAH and EWR approaches include British Airways, Emirates, and Lufthansa, with Virgin Atlantic, Air Berlin, Swiss Air, and Qantas among those purchasing GBAS-equipped aircraft. Honeywell has also completed initial flight demonstrations of GBAS at Shanghai Pudong International Airport.
UAV Collision Avoidance Testing in Europe. A Mid Air Collision Avoidance System (MIDCAS) for UAVs (aka drones) has been tested in Italy, under a project of the European Defense Agency, supported by 11 companies from five countries. MIDCAS uses detect-and-avoid sensors with full authority over the UAV’s flight control system. It flew a series of avoidance maneuvers on a Sky-Y UAV that was put on collision courses with manned aircraft on test flights from an air base in Italy. The project has also conducted simulations of how MIDCAS could operate within civil air traffic management systems.
Four ANSPs Working on Common Controller Work Station. The ANSPs of Germany, the Netherlands, Spain, and the U.K. have agreed to work together on developing specifications for their next-generation controller work position (CWP). The design phase is expected to take two years. Having a common CWP will make it easier for controllers to migrate from one ANSP to another, just as pilots certified on Airbus or Boeing planes can easily move from one airline to another. In the shorter term, shared development will spread the costs over a larger number of entities.
Hultgren Bill Would Revamp FAA’s Controller Hiring Process. Rep. Randy Hultgren (R, IL) last month introduced, with bipartisan co-sponsors, the Air Traffic Controllers Hiring Act of 2015. If enacted, it would un-do the FAA’s 2014 hiring process, which requires all candidates to first pass a “Biographical Questionnaire” and gives no advantage to graduates with college majors in air traffic control, via the FAA-promoted Collegiate Training Initiative. The bill would restore preferred status for CTI graduates, eliminate use of the Biographical Questionnaire, and allow candidates who have aged out from the 2014 hiring process, or who did not pass the BQ, to re-apply.
Frequentis Steps Up Remote Tower Business. Europe-based Frequentis has signed a cooperation agreement with the German Aerospace Center DLR to commercialize DLR remote tower technologies. Like our own NASA, DLR promotes technology transfer from its research efforts to industry. Frequentis VP Hannu Juurakko told Air Traffic Management that the company is in a unique position to become a one-stop shop for a complete virtual tower solution.
Lockheed Martin and CSC Win DUATS II Contracts. As part of its ongoing revamp of Flight Services (flight plan filings, weather briefings, and other services to private pilots), FAA put out for new bids its online service called DUATS (Direct User Access Terminal Service), provided until now by competing providers CSC and DTC. The competition resulted in Lockheed Martin and CSC as the winning providers. The contracts are for one year, with up to four possible one-year extensions. Lockheed Martin continues to operate the FAA’s Flight Service Stations under contract.
FAA Announces ERAM Completion. On April 30th the FAA announced that its new En-Route Automation System is operational at all 20 domestic en-route centers. Its predecessor, the ancient Host computer system, was finally shut down nationwide. Many years late and nearly $400 million over budget, ERAM’s lengthy development illustrates ongoing problems in FAA procurement, but is a welcome milestone in modernization. Though conceived before NextGen, it will serve as a platform for making use of information generated by NextGen capabilities such as ADS-B.
NATS CEO Steps Down. Richard Deakin, the CEO of the corporatized ANSP of the U.K., NATS for the past five years, has stepped down. NATS said the decision was “by mutual consent,” since the company is entering a new five-year price-cap regime and embarking on a new phase in the EU’s Single European Sky effort. Operations director Martin Rolfe will step in as interim CEO while NATS conducts an internal and external search process.
ICAO Commercialization Research Available Online. The International Civil Aviation Organization several years ago did case studies on the corporatization and/or privatization of airports and air traffic control in 26 countries. They are all available on the ICAO website. Go to: http://www.icao.int/sustainability/pages/Eap_ER_Databases_CaseStudies_ANSPs.aspx.
IBM Study on ATC Corporatization Available Online. “Reforming the Federal Aviation Administration: Lessons from Canada and the United Kingdom,” was commissioned last decade by the IBM Center for the Business of Government. Its authors are Professors Clinton V. Oster and John S. Strong, co-authors of the outstanding book on the global ANSP revolution, Managing the Skies. The report is online at: www.businessofgovernment.org/report/reforming-federal-aviation-administration-lessons-canada-and-united-kingdom.
“Managing ATC has always been an odd fit for FAA. It makes the agency a key service provider for a commercial air transport system that it also regulates, creating an inevitable conflict of interest. It also means ATC gets roped into the annual congressional appropriations process, making it difficult, for example, to get a steady, long-term financial commitment to deploying the satellite-based NextGen ATC system. ‘Many stakeholders have understandably lost confidence in FAA’s ability to modernize,’ [Chairman] Shuster has pointed out. . . . Will this be a year of genuine, radical restructuring of FAA that creates a separate Nav Canada-like entity to manage ATC? The debate will begin in earnest soon; this will likely be the overwhelming aviation policy issue on Capitol Hill this summer.”
-Editorial, “Foxx ‘Open’ to FAA Restructuring,” Air Transport World, April 30, 2015
“Unfortunately, neither business leaders nor the flying public can take the future health of U.S. aviation for granted. Challenges with the FAA’s provision of air traffic control services have existed for decades, but are now becoming more acute. FAA has failed to keep its equipment modernized for the entirety of its history, including during times of budgetary plenty. Our national air traffic control system relies on essentially the same technology-ground-based radar and voice radio transmission-as it did in the 1960s. FAA is operating enroute centers that are mostly over 50 years old. Almost all of the FAA’s surveillance technology is still analog. . . . The fact that the FAA has been consistently behind when it comes to innovation isn’t just an inconvenience-it has real costs for the users of the airspace and the public at large. . . . In the end, I believe the greatest risk to our system is allowing the status quo to continue, or pursuing more half-measures and calling them reform. We’ve been down that path. We cannot allow the fear of change to prevent us from doing what is needed.”
-Gov. John Engler, President, Business Roundtable, testimony before the Senate Commerce Committee, May 19, 2015
“Transitioning from a government organization to a private company is a serious undertaking. Some difficulty is reduced if the private company is not motivated by profit. There is no best time to do it other than now. The sensible way to approach the issue initially is to leave alone or encourage activities that are going well and to intervene in those areas that can be improved without real risk. The operation of the system itself is safe, effective, and is an essential service that operates 24/7. It is operated by dedicated professionals and should not be touched. New PBN activities, for example, should be encouraged and accelerated. On the other hand, intervention in overhead functions and acquisition should be started immediately. It will take a while to establish a self-sustaining organization in a changed direction, but benefits will accrue immediately and increase as the process progresses.”
-John Crichton, CEO, Nav Canada, “U.S. ATC Reform Issues Raised,” March 25, 2015
“If airlines really knew how much trauma (e.g., NOTAMs and outages) and unnecessary high cost (e.g., ILS flight inspection and approach light installation, operation, and maintenance) was associated with ILS, compared to the vastly better and less expensive GLS [GBAS], and especially if airlines had to pay the ‘fully allocated cost’ for today’s ILS’s, then the entire global airline community switch to GLS would start nearly immediately, likely with a major portion of the transition completed in less than 5 to 7 years, with full ROI payback. It is nothing short of a multi-national governmental disgrace that GLS-equipped aircraft are having to delay a full decade to fully use their already certified and functioning GLSs for Cat. III minima service. Each airline should be sending a ‘bill’ to [Administrator] Michael Huerta for reimbursement of a decade’s worth of wasted airborne systems investment.”
-Recently retired air transport test pilot and former flight standards official, private email, May 20, 2015 (used by permission)