TABS/TSO-C199 has been mentioned on r.a.s quite a few times before. The SSA has had representation in the development of TABS/TSO-C199 and I expect/hope folks in SSA management are well aware of it. The TABS/TSO-C199 TSO document is available from the FAA TSO library at http://rgl.faa.gov/Regulatory_and_Gu...e?OpenFrameSet. Technical folks who care about this stuff really should read that TSO.

The title on the current ANPRM is a little confusing, it is *not* just about the transponder exemption, but also includes whether gliders should also keep their current ADS-B Out 2020 Carriage mandate exemption (which might have more severe financial consequences than removing the transponder exemption). And TABS/TSO-C199 is also discussed in that ANPRM and the folks at the FAA involved in this ANPRM are very well aware of TABS/TSO-C199. The FAA is specifically asking for feedback about the the overall picture of transponders, ADS-B Out and TABS, and I would expect any SSA response would need to, and would do so.

The USA glider community needs to be careful in dealing with a very complex situation. You've got some suggestions here and raise some very good issues, but the SSA needs to first think though the issues before devising what to do. There might for example while TABS/TSO-C199 is interesting and may have some benefits there may be arguments where TABS/TSO-C199 would *not* be the best thing to do.

I share your concern about the limited time available here this stuff needs to be worked though by an SSA team looking at it. My understanding is a team is being put together to do so. A public forum just does not seem the right place to try to discuss some of these complex and political issues.