SSA responds to ANPRM

I am in the "no transponder needed" group.
Reasons why:
1. I don't trust my safety to a sleep-deprived AT controller.
2. I take responsibility for my safety via a PCAS device which does not take any system power as it has it's own battery.
3. Gliders have been flying for over 100 years, mostly without them.
4. Glider pilots look out the window much more than power pilots.
5. Hang gliders and paragliders are not considered in this ruling and they often fly XC every chance they get, staying as high as we do and traveling far.
6. Most glider flying takes place over rural areas with minimal traffic.
7. Add your contribution here! I didn't think of them all.

Just be aware that if the exceptions go away ADS-B out will be required above 10,000 feet after 2020.

if you have a transponder you will need to purchase an approved GPS source that currently costs about $3000 with installation.

if you don't have a transponder then you will to purchase and install a transponder as well for another $3000 or so.

Also as I understand it the 150Watt Mode S transponder such at the Trig TT21, will not be acceptable after 2020 to meet the ADS-B out. So even if you have a transponder you may need to purchase another one.

of course it is possible that the FAA may just modify the exceptions and allow only a transponder or 150W transponders or currently non-approved ADS-B out sources, or some other modification.

The FAA currently says it is ok to install non-Approved GPS source for ADS-B out in experimental aircraft, but is unclear if this will be acceptable to use above 10,000 feet or not (seems like probably not)

Brian

On Wednesday, August 12, 2015 at 12:57:41 PM UTC-7, Brian wrote:
Just be aware that if the exceptions go away ADS-B out will be required above 10,000 feet after 2020.

I know you use plural for exemption*s* but to make it perfectly clear to everybody, there are two separate exemptions, one for transponders and one for ADS-B. It is possible that the FAA could remove one of both exemptions and/or add TABS as an alternate carriage requirement.

While I can personally see some strong arguments for mandatory transponder carriage, especially near busy airspace I am a little less inclined to want to push for ADS-B, it's much more of a mess and still relatively expensive.. But with the FAA so committed to ADS-B hype, I'd hold out little hope for the FAA to not want ADS-B out carriage. If that does happen then at a minimum I expect the glider community needs to argue strongly to allow the alternate adoption of TABS (with favorable installation and carriage regulations). And I fully expect the FAA wants that TABS mandate, and knows that full 1090ES is impractical, but hey maybe a good hammer to pound the glider community with to make adopting TABS look a nicer option. And the question then becomes what exactly do the carriage and installation requirements for TABS look like (you don't want TABS install requirements looking *anything* like the early 1090ES Out STC based install procedures)?


if you have a transponder you will need to purchase an approved GPS source that currently costs about $3000 with installation.

If you have a *suitable* Mode S transponder.

There is no way of adding 1090ES Out to a Mode C transponder.... there could be an option of adding UAT-Out as a separate box but that is potentially a dangerous move with so many gliders being PowerFLARM equipped and not able to see UAT-Out equipped traffic.

if you don't have a transponder then you will to purchase and install a transponder as well for another $3000 or so.

If you don't have a *suitable Mode-S transponder*.

Not all Mode S transponders will be practically upgradeable to 1090ES Out, e.g. as I understand it some Becker Mode S units are not usable, but few if any of those are installed in gliders in the USA.

Also as I understand it the 150Watt Mode S transponder such at the Trig TT21, will not be acceptable after 2020 to meet the ADS-B out. So even if you have a transponder you may need to purchase another one.

Yes a good point, but frustratingly unfortunate thing for the FAA to do.

As you say, the Trig TT-21 will *not* meet the FAA 2020 ADS-B Out carriage mandate because Trig (and TT-21 owners) got screwed over by the FAA requiring higher output power transponders for 1090ES Out than required elsewhere in the world (presumably done by the FAA to save them costs on adding more ground stations)... a saving grace there would be to allow TABS carriage in place of full transponder + 1090ES Out as the TT-21 should meet that requirement. (Speaking only from the viewpoint of the TABS output power specs,actually getting at Trig TT-21 configured as a TABS device may require more work, maybe even a firmware update, likely will only have compatibility with specific GPS sources etc.). That is one of the reasons that if Transponder and/or ADS-B out exemptions were removed for gliders that TABS should be offered as an alternate means of compliance (but not necessarily providing access to all the same airspace.. but I'd hope for Class A being OK.). Having in place suitable TABS installation/carriage regulations would let Trig TT-21 transponders be used for TABS.


of course it is possible that the FAA may just modify the exceptions and allow only a transponder or 150W transponders or currently non-approved ADS-B out sources, or some other modification.

The FAA currently says it is ok to install non-Approved GPS source for ADS-B out in experimental aircraft, but is unclear if this will be acceptable to use above 10,000 feet or not (seems like probably not)

You can effectively install a wide rang of GPS sources in ADS-B Out in an experimental aircraft today... but the moment you want to use that to meet the requirement of the 2020 Carriage mandate you must use a suitably TSO'ed GPS source, of if in an experimental aircraft you can also use a "meets performance requirements of...(relevant TSO) " GPS source. And the FAA is threatening that if you don't have such a TSO'ed or "meets requirement of... (TSO)" GPS source the FAA ADS-B ground infrastructure (that delivers ADS-R and TIS-B services) will stop working with your ADS-B Out device in future.

A "meets the performance of... (some TSO)" is very different from any old GPS source. With the "meets performance of..." usually just deferred to the manufacturer documenting that the device meets that performance of whatever TSO. The CFR 14 regulation language around this type of stuff is very consistent and I would expect any similar "meets performance of..." to apply to GPS sources used in gliders, either for 1090ES Out full compliance or TABS.. A glitch in similar wording there for the 2020 ADS-B Out carriage mandate that was not consistent was changed in the last year or so after pressure from the EAA. And I expect that "meets performance of.." wording would be used in any future regulation changes for gliders just as it does for experimental power aircraft, including today above 10,000' and EVEN MORE experimental aircraft can use that after 2020 to operating in Class A, B and C airspace including IFR flights (i.e. notionally a lot more stringent than most gliders would ever experience).

Whether or not anybody agrees with removing carriage exemptions, if they do end up being removed then it is important that the SSA (with help from the EAA etc.) monitors any such regulation development to ensure that "meets performance of..." language also applies to GPS sources for ADS-B Out and TABS in gliders. That should be a minor thing, and hopefully the FAA wants to see worded that way anyhow.



Brian

When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?

Before PowerFlarm I had a couple twin
turboprop airliners sneak up on me at
4000' (well below any proposed
transponder mandatory altitude). I saw
another get cosy with a glider and
towplane at about 1000' AGL.

With PowerFLARM I see ADS-B (airline kit
already) from ten miles or so away - lots
of time to get out of their way if
necessary.

If I fall out of a wave or thermal, I'll find
another one or meet another farmer.

On Wednesday, August 12, 2015 at 1:21:42 PM UTC-7, son_of_flubber wrote:
When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?

You likely need to define what you mean by "high-performance", it is probably not what I mean by high-performance (light-jet up to airliners).

Many "high performance" aircraft are required to install TCAS today, and have been for ages (the USA lead that move, in direct response to horrifically fatal airliner-GA light aircraft mid-air collisions, with the FAA pushed there by the NTSB as it is now being done so with this latest ANPRM). e.g. part 121 10-30 seats require TCAS I (and most modern installs are likely to actually be TCAS II), 30 seats require TCAS II. Many other high performance aircraft voluntarily equip with TCAS II, e.g. the entire fleets of many fractional share/lease business jet operators are TCAS II equipped. Many military transport aircraft, e.g. the big USAF C5s that say might be carrying hundreds of troops, are TCAS II equipped.

The high adoption of TCAS II with airliners etc. is one of the leading reasons that makes carriage of transponders so effective near busy airspace, where a midair collision with a glider could kill hundreds of innocent passengers. Somehow warping that reality to require more TCAS adoption before you might want to adopt transponders makes no sense. And leading with that argument may make the glider community look ignorant of current TCAS adoption rates or benefits, or unconcerned about he risks to airliners etc. in high-traffic areas.

Maybe pointing out where *you* fly there is such little airliner and fast-jet etc. traffic that mandatory transponder adoption is an unreasonable cost, money better spent on other saftey etc.

On Wednesday, August 12, 2015 at 5:32:05 PM UTC-4, Darryl Ramm wrote:
On Wednesday, August 12, 2015 at 1:21:42 PM UTC-7, son_of_flubber wrote:
When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?

You likely need to define what you mean by "high-performance", it is probably not what I mean by high-performance (light-jet up to airliners).

A high performance aircraft (according to 61.31) is an aircraft with an engine of more than 200 horsepower. I'm mostly concerned with those that fly too fast for practical 'see and avoid' and with pilots who are not aware of gliders.

I get occasional benefit from my Trig TT-21. If more high performance planes had TCAS, I'd get more benefit.

On Wednesday, August 12, 2015 at 5:10:21 PM UTC-7, son_of_flubber wrote:
On Wednesday, August 12, 2015 at 5:32:05 PM UTC-4, Darryl Ramm wrote:
On Wednesday, August 12, 2015 at 1:21:42 PM UTC-7, son_of_flubber wrote:
When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?

You likely need to define what you mean by "high-performance", it is probably not what I mean by high-performance (light-jet up to airliners).

A high performance aircraft (according to 61.31) is an aircraft with an engine of more than 200 horsepower. I'm mostly concerned with those that fly too fast for practical 'see and avoid' and with pilots who are not aware of gliders.

I get occasional benefit from my Trig TT-21. If more high performance planes had TCAS, I'd get more benefit.

Many of those very fast aircraft (light jets on up) are already TCAS equipped. TCAS in 200+ hp singles, forget about it. Low-end TCAS II in GA/light jets is ~$20k+ (Garmin GTS 8000), plus compatible transponder, plus displays, plus install costs, plus STC/approval hassles, which is an amazingly low price for TCAS-II but still expensive if it is possible at all in a particular small GA aircraft.

Mandating TCAS in GA piston aircraft is just never going to happen. Not with much more affordable ADS-B solutions aimed at the low-end GA market, and not with the FAA pushing the hell out of ADS-B. And think carefully if you want to argue a position that AOPA and EAA and other aviation lobby groups would find silly and just offensive. But as more GA aircraft get ADS-B In (and Out) they can at least see you transponder via TIS-B (when in both SSR and ADS-B ground coverage) and ADS-B Out or TABS if they are installed (as I expect will likely end up being mandated for gliders...). Once many GA aircraft are equipped with ADS-B Out it is very compelling for them to also equip with ADS-B In to be able to receive all FAA ADS-B services. Portable dual link ADS-B In receivers are $1k today, add your own tablet display.

While I appreciate those who believe transponders in every aircraft helps safety, I guess they have more spare cash than I and my $18K glider... I also almost never fly above 10K, so it's not urgent, but the requirement would stop me from going to the occasional wave camp, where radio contact with center is required to open the window and they know I'm there.

So while I'm still working and putting kids through college, and mostly flying recreationally on the east coast, I'd hate to have to fork out the Dosh to pay for something that realistically doesn't guarantee anything (see recent F-16 vs C150, both with transponder, plus several other mid airs...), and I only need it for the rare occasion when I travel someplace else for the joy of a new and different flight experience.

Thanks SSA. Not so much to those who want to restrict my enjoyment of soaring...