SSA petition to allow transponder to be turned off

For what it is worth, this is from the GA Inspector's Handbook, Chapter 50.
Here is the link to the whole document for those who want something to read
at bed time:

http://www.faa.gov/avr/afs/faa/8700/

A. Surveillance Policy. Airshows, fly-ins, and

other gatherings of general aviation aircraft and airmen

are opportunities for the Federal Aviation Administration

(FAA) to present a positive image to the aviation

community with whom we work and the general

public. Many of the aircraft operators attending these

aviation events are regular users of our air traffic and

flight service facilities, but their contact with Flight

Standards personnel may have been rare. Most of the

people who fly their airplanes to fly-in events and

airshows are aviation enthusiasts and hobbyists and are

not employed in the aviation industry as pilots.

(1) The FAA would like this important segment

of airspace users to have a very positive image of

inspectors and the safety activities inspectors perform.

Therefore, the FAA encourages inspectors to establish

early contact with sponsors and organizers of aviation

events so that informational and Aviation Safety

Program activities can be planned to serve attendees.

(2) Under no circumstances should these gatherings

be targeted for a blanket sweep inspection of

spectator airmen and aircraft.



"Andy Durbin" wrote in message
om...
One year at Hobbs, New Mexico, every contestant's parachute was
checked for currency by an FAA inspector. The infamous "ramp check".
Don't know how many he found but he probably had a nice day away from
the office.

NSF, the organizer of contests at Hobbs, now has a rigger available
before most (all?) contests and he does a lot of business.


Andy (GY)

Ah yes,

The FAA Order 8700.10. For even more exciting reading, try the 8400.10 for
Flight Ops issues, or maybe even the 2150.3 for Enforcement and Compliance
guidelines.

They are all twice as effective as two bagger of Sleepytime Extra!

Jim

"Ivan Kahn" wrote in message
news:22w%b.65463$Xp.310457@attbi_s54...
For what it is worth, this is from the GA Inspector's Handbook, Chapter
50.
Here is the link to the whole document for those who want something to
read
at bed time:

http://www.faa.gov/avr/afs/faa/8700/

A. Surveillance Policy. Airshows, fly-ins, and

other gatherings of general aviation aircraft and airmen

are opportunities for the Federal Aviation Administration

(FAA) to present a positive image to the aviation

community with whom we work and the general

public. Many of the aircraft operators attending these

aviation events are regular users of our air traffic and

flight service facilities, but their contact with Flight

Standards personnel may have been rare. Most of the

people who fly their airplanes to fly-in events and

airshows are aviation enthusiasts and hobbyists and are

not employed in the aviation industry as pilots.

(1) The FAA would like this important segment

of airspace users to have a very positive image of

inspectors and the safety activities inspectors perform.

Therefore, the FAA encourages inspectors to establish

early contact with sponsors and organizers of aviation

events so that informational and Aviation Safety

Program activities can be planned to serve attendees.

(2) Under no circumstances should these gatherings

be targeted for a blanket sweep inspection of

spectator airmen and aircraft.



"Andy Durbin" wrote in message
om...
One year at Hobbs, New Mexico, every contestant's parachute was
checked for currency by an FAA inspector. The infamous "ramp check".
Don't know how many he found but he probably had a nice day away from
the office.

NSF, the organizer of contests at Hobbs, now has a rigger available
before most (all?) contests and he does a lot of business.


Andy (GY)

Ivan Kahn wrote:

(2) Under no circumstances should these gatherings
be targeted for a blanket sweep inspection of
spectator airmen and aircraft.

I agree with this. It would kinda tick off the organizers, after all...

"Andy Durbin" wrote in message
. com...
One year at Hobbs, New Mexico, every contestant's parachute was
checked for currency by an FAA inspector. The infamous "ramp check".
Don't know how many he found but he probably had a nice day away from
the office.

Notice these were contestants, not spectators. If I were
an organizer, I'd be pleased that this was going on (covering
my butt, and making it safer for the other participants, in
some cases.) I'd guess the Reno Air Races get a lot of
internal scrutiny and FAA scrutiny.

Finbar wrote:

I think it's an oversight, rather than foolishness: airplanes ARE
required to have transponders, and this rule was written for them.

Gliders aren't required to have transponders, and when the rules were
written, they were extremely rare in gliders.

Hmmm...as far as I know airplanes do not have a general requirement for
transponders. 91.215 is poorly written, but neither it nor 91.205
seem to require a transponder be installed in all airplanes. Not
sure where you may have seen this...

My reading seems to indicate that if an operable transponder is installed,
it must be inspected (91.411 and/or 91.413 as applies) and
turned on. There are various exceptions for how to operate
it if it's out of inspection or otherwise inop.

So if one IS installed, there are things to do, but I've never read any
requirement that a transponder MUST be installed in all airplanes.

Now beyond that there are some airspaces that require transponders,
with some exceptions for gliders, aircraft without engine-driven
electrics, etc. All to allow the Baby Aces and Cubs and gliders
and the like to access airports under B and C rings without requiring
a transponder. Grandfathered in, it seems... And we rode the coattails
of the ol' farts that kept it this way...

Beware, however, a much greater evil. The San Jose FSDO
required a local pilot who wanted to certify his Experimental
Speed Canard to install a transponder for certification.
Not optional, but required by the FSDO for his experimental.
I've never heard of this as a requirement for good ol'
152's and 172's when flown outside of 91.215(b)(1-5), so
I don't know why he got hit with it for his experimental
(especially since his home airport was in "G" airspace
with only "E" above).

As far as I know, the Fresno FSDO 100+ NM south didn't
require a transponder for the recent experimental certification
of an RV-3. Do FSDO's have the discretion to
require transponders of experimentals on a case by case basis?
Perhaps so. A bit odd and not too consistent it might seem...

I've personally had a mechanic pull out a transponder with
a log entry, and then flown a plane for 6 months without it
below 10,000 ft in "E" and "G" airspace. Even had an FAA DPE
do a checkride in the plane. Nobody even blinked...straight
faces all around...

But maybe I'm missing something and all airplanes with
engine driven electrics ARE required to have transponders.
Maybe someone can point me to a reference...

As far as getting a transponder OR getting a Proxalert (etc),
I'd definitely go proxalert first...no-brainer there.
Lots of squawking targets out there, and me squawking too
does almost nothing to improve safety (since radar watching ATC
will rarely be in contact with them in my most common
scenarios). Me watching the other squawks, and then
looking outside in that direction: now that'll help...

"Mark James Boyd" wrote in message
news:4039aef8$1@darkstar...

As far as getting a transponder OR getting a Proxalert (etc),
I'd definitely go proxalert first...no-brainer there.
Lots of squawking targets out there, and me squawking too
does almost nothing to improve safety (since radar watching ATC
will rarely be in contact with them in my most common
scenarios). Me watching the other squawks, and then
looking outside in that direction: now that'll help...


None of the new crop of reasonably priced passive detectors gives bearing to
the threat info. They do display threat altitude and range. Takes thousands
of additional dollars to get bearing info.

I flew with the ProxAlert in my glider at Minden this last week. Didn't
"see" any other gliders using transponders, just power aircraft.

--
bumper ZZ (reverse all after @)
"Dare to be different . . . circle in sink."

Hi Eric,

Indeed, the regulator would have a hard time explaining it. Since
it's possibly the dumbest reg in the entire 14 CFR, it would be hard
for anyone to explain. Given a chute that is out of date on a given
occasion, complying with the law should be considered criminal
stupidity. Here's the law:

"§ 91.307 Parachutes and parachuting.
(a) No pilot of a civil aircraft may allow a parachute that is
available for emergency use to be carried in that aircraft unless it
is an approved type and—
(1) If a chair type (canopy in back), it has been packed by a
certificated and appropriately rated parachute rigger within the
preceding 120 days; or

(2) If any other type, it has been packed by a certificated and
appropriately rated parachute rigger—

(i) Within the preceding 120 days, if its canopy, shrouds, and harness
are composed exclusively of nylon, rayon, or other similar synthetic
fiber or materials that are substantially resistant to damage from
mold, mildew, or other fungi and other rotting agents propagated in a
moist environment; or

(ii) Within the preceding 60 days, if any part of the parachute is
composed of silk, pongee, or other natural fiber, or materials not
specified in paragraph (a)(2)(i) of this section."

Yes folks, it's a regulation that prohibits a pilot from carrying
emergency equipment aboard an aircraft unless the equipment is not
available in case of emergency. I wouldn't even know where to begin.
I've seen a box of hammers display more intelligence. Oh well. It's
not as if the rest of 14 CFR is anywhere near as moronic, so this must
have been some sort of brain meltdown on someone's part. If it
referred to REQUIRED equipment (parachutes are required for
aerobatics, for example) it would make a lot of sense - but it
doesn't.

Surprisingly, this stroke of genius survived the recent cleanup of the
regs. And if someone gets ramp-checked before takeoff by one of those
- fortunately rare - power-altered officials one occasionally runs
into, and their chute is out of date, I'd love to hear them explain to
the nice official why they're carrying emergency equipment in direct
contravention of a law that makes it illegal to do so.

Anyway, enough about that!

The reason I asked about what happens if you turn off a transponder in
flight was that I imagine most/all the pilots who have equipped their
gliders with them are doing exactly that, i.e., turning off the
transponders when they don't feel they're necessary. It's sensible,
but it's illegal. Nobody's been busted so far, but I wonder... About
10-15 years ago we had a brief period when the FAA suddenly started a
get-strict policy and enforcing all these "petty" rules, and AOPA and
the aviation press were warning pilots not to talk to ANYONE from the
FAA without a lawyer present. Remember the days when some airline
pilots filed a NASA form after every flight, just in case? Cooler
heads prevailed, and our FAA field personnel were allowed to go back
to doing their jobs promoting safety instead of playing "gotcha" with
obscure regulations, but who knows what the future will bring, and who
knows how many of those disappearing transponders will have been
digitally recorded for the benefit of some enterprising career-minded
young investigator? The trouble with bad laws is that sooner or later
some dimwits show up and enforce them. It's not like it hasn't
happened before. And unlike flying with an out-of-date chute, when
you turn off a transponder your crime is broadcast to the world (or,
technically, your compliance with the law is no longer broadcast!).

As to whether transponders are a good idea, obviously given infinite
panel space, money and power they are. Given limited supplies of
each, I am wondering if some kind of TCAS wouldn't be better. All the
power aircraft are transmitting, but most of the ones squawking 1200
are not talking to ATC and do not have TCAS. So even if you have a
transponder, they don't know about you. If you had a budget TCAS, you
could at least see them (or, with a transponder, you could try asking
for flight following...) The big transports may be a more impressive
threat, but getting clobbered by a C-182 or one of the many low-flying
(clearly not on flight following!) GA aircraft I see out there, from
warbirds to Lears (!), could be pretty fatal too. So I'm wondering
about that one.

Cheers!

Finbar wrote:
And unlike flying with an out-of-date chute, when
you turn off a transponder your crime is broadcast to the world (or,
technically, your compliance with the law is no longer broadcast!).

Of course, the nice thing about Mode C (as opposed to Mode S), is that
ATC doesn't know who you are, unless you explicitly identify yourself.

The big transports may be a more impressive threat, but getting
Clobbered by a C-182 or one of the many low-flying
(clearly not on flight following!) GA aircraft I see out there, from
warbirds to Lears (!), could be pretty fatal too. So I'm wondering
about that one.

I can see and avoid GA aircraft ahead of me, and the ones behind aren't
closing on me all that fast, so there's some chance they'll see me in
time. The thing about transports is that at the altitudes I'm flying
they are moving fast relative to me, and either climbing or descending
at a fairly high rate. In my experience, the aircraft I've had near
miss experiences with have been other gliders, airliners, and military
aircraft, in roughly that order of frequency. I see GA aircraft all of
the time, but so far, always at enough distance to avoid.

If the passive proximity warning systems prove to be effective, I'd say
they are a decent alternative, except perhaps in those areas where there
no radar coverage. Since I normally have the transponder off in those
areas, it's not a huge disadvantage. But, I've yet to come across much
objective evidence that convinces me they are effective. Maybe as
Bumper and others use them for a while, I'll be convinced...

Marc

Finbar wrote:
The reason I asked about what happens if you turn off a transponder in
flight was that I imagine most/all the pilots who have equipped their
gliders with them are doing exactly that, i.e., turning off the
transponders when they don't feel they're necessary. It's sensible,
but it's illegal. Nobody's been busted so far, but I wonder... About
10-15 years ago we had a brief period when the FAA suddenly started a
get-strict policy and enforcing all these "petty" rules, and AOPA and
the aviation press were warning pilots not to talk to ANYONE from the
FAA without a lawyer present. Remember the days when some airline
pilots filed a NASA form after every flight, just in case? Cooler
heads prevailed, and our FAA field personnel were allowed to go back
to doing their jobs promoting safety instead of playing "gotcha" with
obscure regulations, but who knows what the future will bring, and who
knows how many of those disappearing transponders will have been
digitally recorded for the benefit of some enterprising career-minded
young investigator? The trouble with bad laws is that sooner or later
some dimwits show up and enforce them. It's not like it hasn't
happened before. And unlike flying with an out-of-date chute, when
you turn off a transponder your crime is broadcast to the world (or,
technically, your compliance with the law is no longer broadcast!).

I'm told by SSA officials and others that talk to FAA people frequently
about airspace issues that the FAA knows glider pilots turn off their
their transponders sometimes, and the FAA doesn't care about that.
Mainly, they are just really happy the pilot is willing and able to
carry one.

I'm sure ATC doesn't care, either, if a VFR transponder signal
disappears 50 miles from their Class B airspace, as long as it was
heading away from them. Signals disappear for various reasons, such loss
of radar coverage and equipment failure. They aren't going to send out a
posse to get you; mainly, they are just glad you have one when you are
close to them.

To the best of my knowledge, this exemption seems to be a good one for
glider pilots. It will legalize what some of us already do, and make
putting in a transponder slightly more interesting to those that adhere
strictly to the rules. Safety may increase ever so slightly. The biggest
benefit might be we won't have to have talk about the issue any more,
and can go back to other things.
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Eric Greenwell
Washington State
USA

Experts, correct me where I'm wrong.

1. An operating transponder, not being interrogated, is simply a receiver
with a low current drain.
2. When interrogated by a ground radar or TCAS, a transponder transmits a
short "squitter" at 175 or 250 watts which is a BIG current drain.
3. Flying in an area with many interrogations per minute is likely to be a
congested area where the transponder is needed and a wise pilot would keep
it on despite the current draw.
4. Flying away from a congested area toward a remote area with few
interrogations, the transponder automatically cuts back on its current draw
by operating less and less as a transmitter and more as a receiver.

So, where is the need to turn it off? Doesn't the transponder effectively
manage its own current draw to match the level of congestion? Move away
from congested areas and the current draw is minimal. I haven't read of a
case where the transponder is sucking batteries flat and if that happened,
how much additional battery capacity is needed to keep it running for the
whole flight? (I can remember pilots carrying car starting batteries to run
a vacuum tube radio. No imaginable suite of avionics would draw that much
current today.)

So, aside from the cost of a transponder installation, what is the concern?

Bill Daniels

p.s. Having suffered a couple of alternator failures at night in hard IFR
with single engine airplanes, I became very interested in the current draw
of each bit of avionics. My calculations showed is that if the aircraft
battery is in good condition and fully charged at the point where the
alternator failed, and the pilot swiftly switches off the alternator field
with the split master, the battery will run a full IFR panel longer than the
fuel will last. I tested that calculation and it proved true with good
safety margins.

Bill Daniels wrote:
Experts, correct me where I'm wrong.

1. An operating transponder, not being interrogated, is simply a receiver
with a low current drain.

Not so low: my Becker (175 W version), with the ACK 30 encoder, draws
about 400 ma. In very cold weather (winter wave flying), this rises
50-100 ma because of encoder heating.

2. When interrogated by a ground radar or TCAS, a transponder transmits a
short "squitter" at 175 or 250 watts which is a BIG current drain.

True, though internal to the instrument; the battery and wiring won't
see a spike.

3. Flying in an area with many interrogations per minute is likely to be a
congested area where the transponder is needed and a wise pilot would keep
it on despite the current draw.

I agree, but the increase is only 130 ma at 1200 interogations/sec! The
increases I've seen in Southern California are more like 30 ma, and just
a few milliamps when there are only 3 or 4 radars hitting it.

4. Flying away from a congested area toward a remote area with few
interrogations, the transponder automatically cuts back on its current draw
by operating less and less as a transmitter and more as a receiver.

So, where is the need to turn it off? Doesn't the transponder effectively
manage its own current draw to match the level of congestion? Move away
from congested areas and the current draw is minimal.

It's still 400 ma with the encoder, a significant but not overwhelming
amount for the typical 7 amphour battery. 400 ma may be what all the
other instruments are pulling, so it cuts the battery life in half.
Still, a 7 AH battery should easily last 7+ hours.

I haven't read of a
case where the transponder is sucking batteries flat and if that happened,
how much additional battery capacity is needed to keep it running for the
whole flight? (I can remember pilots carrying car starting batteries to run
a vacuum tube radio. No imaginable suite of avionics would draw that much
current today.)

So, aside from the cost of a transponder installation, what is the concern?

Having a transponder on for the entire flight likely means the pilot has
to charge it (or put in a different one) everyday, rather than every
other day. The battery may need replacing more often, say every 3 years
instead of 4 or 5. Gliders with batteries smaller than 7 AH probably
could get by with, say, a 4 AH battery by using the transponder for only
a couple of hours instead of full time.

I don't think these concerns are important if you think you need a
transponder, and I suspect it's the ~$2000 cost that stops most people,
plus the $50-$70 every two years to have it tested.

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Eric Greenwell
Washington State
USA