SSA responds to ANPRM
Ah there are already very clear technical standards here, Mode C and S transponders, ADS-B, TCAS, and TABS. (FLARM does not really enter into it from a broader Aviation industry perspective... Especially because it is not compatible with TCAS or SSR). What the ANPR is asking about is wether some of these technologies should be mandated or not. Saying there needs to be more technology developed really does not seem helpful... And seems to be replying less to the ANPRM than you are criticising others for. Costs and installation issues with transponders or TABS are serious possible issues for *some* glider owners and are very much something the FAA expects in these responses.. and those folks worried about being affected by that should respond with supporting material (i personally hold little sympathy for folks flying near busy airspace, they should have transponders installed long ago--and those who have not may be helping force this whole thing other other owners. The cost issue, at least to me, is more about how many other gliders not near busy airspace will get caught up in a carriage mandate).
Any system needs to be as compatible as possible with what is in broad use today, and specifically this ANPRM is driven by the question from the NTSB about getting gliders visible to TCAS... Which needs a Mode C, Mode S transponder or TABS. And the FAA already has a massive SSR and ADS-B surveillance infrasructure, so any system better be compatible with that. There *is* a new standard/technology proposal, one developed with input/participation folks including in the UAV space... and that is TABS. Now the big questions there are what the carriage and use regulations for TABS devices might look like, and how many vendors will make those products and what they will be priced at (a chicken and egg problem). Nothing happens in broad aviation surveillance, collision avoidance, etc. without standards developed by RTCA and then adopted via TSO by the FAA and then actual install and use regulations. The road to any innovation there are ~decade long efforts by participants who want to contribute to RTCA standards, and right now we have more of those standards than we need, the practical question, and what the ANPRM is asking, are really which ones of these technologies gues, if any, should be mandated for gliders. Vendors are free within those standards to use new technology as much as they can (and for example modern FPGAs have helped lower transponder costs). We really do not need yet more standards/technology options.
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