Is ADS-B Training Required?
- Advanced Aircrew Academy
Now that Automatic Dependent Surveillance-Broadcast (ADS-B) Out is required (14 CFR § 91.225), is pilot training required to use it? Most pilots roll their eyes when thinking there may be one more training requirement. The short answer is…maybe.
A bit of history first. In 2010, an International Civil Aviation Organization (ICAO) planning group concluded that aircraft operators intending to receive ADS-B air traffic services must have the relevant operational approval [Ops Specs for Air Carriers and Letter of Authorization (LOA) for Part 91] from the operator's State of Registry.
In 2013, Hong Kong and Australia were early adopters of ADS-B, which required operator approval from their Civil Aviation Authority (CAA) (FAA for aircraft registered in the United States). The FAA issued Ops Spec / LOA A153 or A353 for those operators needing State approval.
The Ops Spec / LOA issuance required training as defined in the 8900.1 and Advisory Circular (AC) 90-114 (dated 12/8/2011). Appendix 1, item 2 c (7) listed 10 pilot training elements for "Pilots conducting operations under this authorization must be trained in the use and limitations of the installed ADS-B system." Many of those operators who received the authorization added a specialty curriculum to their approved training program manuals (Air Carriers) or added a course outline to their operations manual (to satisfy IS-BAO 220.127.116.11).
In 2016, AC 90-114A Change 1 was published, which listed only 2 training requirements for ADS-B; Pilot training if you use In Trail Procedures (ITP) and Maintenance training. No training requirements were listed for pilots if you are not using ITP. The AC 90-114B revision published on December 30, 2019 did not add any new training guidance.
In 2018, the FAA decommissioned Ops Spec / LOA A153 and A353. In FAA Notice N 8900.491, they provided nine justifications for State approval not being required. The most important justification was "The FAA's research of States' air traffic publications and circulars, as well as direct inquiries, could find no State that continues to require an operator to carry State of Registry operational approval." The notice also concluded "ADS-B Out requires no additional operational training."
That history review makes it seem pretty clear – ADS-B pilot training is not required if you are not using ITP. So where does the maybe come into the equation?
Part 91 operators receive authorization from the FAA to operate in certain PBN, HLA, RVSM, and CPDLC airspace through LOAs. Those LOAs require training. Typically, as part of the LOA application process with the FAA, you submit a course outline or syllabus to receive the authorization. PBN, HLA, RVSM, and CPDLC training is typically bundled in an International Procedures curriculum.
If LOA A153 or A353 were issued and the FAA approved an update to your International Procedures course outline or syllabus (along with the training chapter of your operations manual) which included training on ADS-B, that training would still be required for you. If you fall into that category, just update your course outline or syllabus removing the ADS-B training element to remove that requirement.
IS-BAO 18.104.22.168 may also lead you to believe ADS-B training still required by the statement "Prior to operations in airspace where specific CNS requirements exist, such as…ADS B/C, an operator shall have a process to ensure…flight crews engaged in operations in such airspace are qualified and authorized to conduct such operations." Since the ADS-B requirement no longer exists, the training (qualified and authorized) would no longer be an IS-BAO requirement.
If you were issued Ops Spec A153 or A353, your POI would have required adding a special curriculum segment to your approved training program manual for ADS-B Out. "Special" training is training conducted by an operator to qualify flight crew members beyond the scope of basic training. Special training is normally required for operations that require specific authorization by the operator's Ops Specs.
When Ops Spec A153 or A353 were decommissioned in 2018, you could have also removed the special curriculum from the training manual. We did not see many operators do this. But just because you have a special curriculum segment in the training manual does not mean you need to train on it. It just means IF you need to train on that topic, that is the training outline you will use.
One other place to look is your International Procedures special curriculum segment. Some operators have listed ADS-B training as a training element under International Procedures. If you still list that as a training element, you would need to train on it. If you fall into that category, just update your special curriculum segment removing the ADS-B training element to remove that requirement.
Do you want to train on it anyway?
Most pilot's opinion is if you can't control ADS-B from the cockpit (except by turning off the transponder) why should you train on it? That is a good point. The training should be operationally focused and concise. There are a few pilot operationally oriented topics we include in our short eLearning module.
- Verifying the Aircraft ID (flight ID) so if you hear ATC say "RE-ENTER ADS-B AIRCRAFT IDENTIFICATION" you know what to do
- ATC Phraseology differences in Canada and Australia
- Difference between TCAS and TIS-B
- FAA's new ADAPT tool to use if ADS-B is deferred to the MEL
For more information on Advanced Aircrew Academy's ADS-B online training module, check out our website.