Ian Cant wrote:

First, transponders are GOOD TO HAVE.

Agreed

The real issues are economics - a $3000 transponder installation in a $5000 glider ? - and safety and minimizing regulatory encroachment on airspace use. When safety is concerned, the FAA is not generally concerned about user economics. So our arguments should be based on the safety issues alone.


Again, I'm wondering if there are mode A only transponders
in current manufacture which can be cheap and avoid the
24-month rechecks. 91.215(a) doesn't seem to require
mode C. And mode A aircraft can request waiver of mode C
requirement in a "mode C veil" at any time 91.215(d)(1).

My objections to the wording, not the intent, of the SSA petition go like this. It sets up a whole new class of airspace affecting only SOME users; 10 mile wide doughnuts around the existing 10 mile or 30 mile transponder veils. Are our charts not complicated enpugh already ? By implication, allowing transponder switchoff outside these doughnuts also requires transponder switchon [for those affected] while inside. If this is good for safety, how long before there is some creep, like a requirement that ALL operators in the doughnuts install transponders ?


The mileage wording does seem screwy. I wouldn't have written it this way.
I would have simply said "on aircraft without an electrical
system, the pilot may turn off the transponder if transponder use
is not required during that portion of the flight."

There is another section which allows the pilot to turn off
strobes at the pilot's discretion (to avoid distraction).
This is similar.


What I think is needed is a general policy statement from the FAA that transponders are GOOD TO HAVE AND USE and that anyone who voluntarily installs one when not required to will NOT be penalized if that installation and its operation does not meet all the requirements of the relevant FAR sections. That emphasises the voluntary nature of these installations and preserves the existing overall 'exemption'. It is permissive and flexible and should encourage widespread installation of transponders in cross-country gliders. It also gets away from the SSA 'liability letter' and the question of non-SSA pilots, and should keep us aligned with balloons and non-electric aircraft.


An excellent summary. I think perhaps SSA is starting with a petition
which is very limited in scope, and over time the CFR may get the change.

As a side issue, section 215b is hard to read, but appears to require either Modes A and C or Modes S and C. Section 217 then applies to both VFR and IFR and refers through section 413 [also both VFR and IFR] to Part 43 Appx E where altitude encoding accuracy tests are specified. The difference between VFR and IFR is only that IFR testing is 24-monthly, VFR is on installation and after any maintenance.

True, it is hard to read. 91.215(b) seems to mix "or's" with "and's"
so it is unclear if altitude reporting capability is required.
91.215(a) specifically mentions mode A only, so one would assume that is
OK, otherwise why would it be mentioned at all?

And 91.411 and 91.413 both seem to require 24 month inspection.
So whether you are VFR or IFR, you still have an inspection due
every 24 months ($50-$200). This is a real disincentive too...

I'm gonna say a Proximity poor-man's TCAS, and maybe a Mode A
transponder, is gonna be the cheapie way to go. Sure sure,
mode C is better, but the initial cost and continuing cost and
inspections are a lotta money.

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