With apologies to ASA members who have already seen this I thought I would post my reply to the ANPRM which is based on a lot of conversations and reading and may be helpful to any one wanting to submit a response.
Response to the FAA ANPRM on Transponder Requirement for gliders and TSO-C199
This is my personal view on the ANPRM and while I have tried to get all the facts correct, not even the FAA can answer everything completely or correctly. The more you review the subject the more complicated it gets. I apologize for any errors. My views are, in part, different from those of SSA who essentially want nothing changed and I believe this is unrealistic and I personally want to be as safe as practical.
The deadline for submitting testimony is this coming Monday August 17 and I urge everyone to send in comments. Numbers count. Feel free to use any, all, or none of the material below. Note that while I will be including answers to the ANPRM's specific questions I have not included them here as it would not make much sense without restating the questions but these are on the URL below. If you would like my answers I'll be happy to send them to you.
http://www.gpo.gov/fdsys/pkg/FR-2015...2015-14818.htm
The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.
Adding Power FLARM is of course a couple of thousand more.
Below my summary to the ANPRM with questions I am asking and the FAA has requested be included. Feel free to contact me if you want to discuss further but time is short.
We do not know what process the FAA will use after August 17
This is the link to file your submission
https://www.federalregister.gov/arti...nt-for-gliders
Thanks to Jim Herd, Eric Greenwell, Tom Seim, David Kinsell, Russ Owens for their inputs but all the comments are mine
John Hodgson
CFIMEL, CFII, CFIG
DG808C Minden
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Summary
1 The Minden incident reports point to the lack of an operating transponder in the glider but we should also note that Norcal ATC was routing a jet through airspace known to be frequented by gliders who were not required to have transponders. Local dialog between the glider community and ATC to establish procedures could have avoided the collision in the first place. Simply restricting descending high speed traffic to above 18,000 feet till west of the Pine Nut mountain range would have avoided the situation.
Two weeks after the Minden incident flying a King Air C90 I was routed over the exact same spot by Norcal. I declined the clearance instead requesting the Minden GPS Bravo approach and when cleared to CTAF frequency also monitored the glider frequency of 123.3.
2 Gliders, including those with self launch capability where the engine is only operating for maybe 10 minutes, have limited on board power resources that must be conserved for use throughout the flight including transponder use at the end of the flight that may be in high activity airspace and deploying and starting the engine at any time up to the point of touch down.
3 All airspace does not produce the same risks and while I fully agree that transponders should be required in certain high activity areas they do little but use power when squawking in areas that experience only light traffic such as the western deserts.
4 Glider flights can last to 10 hours or more putting great pressure on the conservation of power in flight and also recharging batteries over night for the next day.
5 The problem would be greatly simplified if use of transponder/TABS was required in certain high risk areas but remained voluntary outside of those areas. No glider pilot wants to be involved in a mid air collision.
6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.
7 Popular high activity glider routes can and should be identified and marked on sectional charts as are military routes. Pilots of power planes could be provided training by local CFIs on where gliders operate to increase their vigilance e.g. mountain ranges and cloud streets.
8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.
9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.
http://www.avweb.com/blogs/insider/A...-223824-1.html
http://www.airspacemag.com/daily-pla...956113/?no-ist
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Answers responding to the ANPRM specific questions not posted here
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I would like to ask the following questions and request answers with the findings of the ANPRM ......
1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?
Have flights filed on the glider on line contest web site been reviewed to see how they operate in the US air space?
http://www.onlinecontest.org/olc-2.0...=C0&sc=&st=olc
2 What cost does the FAA think it will take to install ADS-B in a glider when a TABS product is available? Using an estimated $6000 to comply that is as much as half the cost of many gliders flying today
3 What calculations have been made to consider the power requirements needed to support TABS on extended 10 hour day back to back flights?
4 Has the national airspace have been reviewed to determine high and low risk areas of glider to airplane mid air near misses and collisions?
5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?
6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?
7 Will tow planes require TABS or full ADS-B compliance?
8 Has the marking of high activity glider routes on sectionals been considered?
9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?
10 What will be the impact of TABS on glider cross county flights in Canadian and Mexican airspace but not landing outside the USA?
11 Does one, fortunately non fatal, mid air collision in a decade that could have easily been avoided justify the huge cost of mandating TABS on the US glider fleet, plus balloons and airplanes without electrical systems?
12 Will a representative be appointed to liase and communicate with the soaring community on an ongoing basis? And not just through SSA but a representative group throughout the country.
References:-
Federal register June 16, 2015
http://www.gpo.gov/fdsys/pkg/FR-2015...2015-14818.htm
TSO-C199 October 10, 2014
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TSO-C199.pdf
FAA presentation, D Walker, TSO-C199 TABS
http://www.icao.int/APAC/Meetings/20...20briefing.pdf
TRiG data sheets, TT21, TN70
Google ADS-B for drones (links above)
Thank you, John Hodgson