SSA responds to ANPRM

On Tue, 11 Aug 2015 11:22:11 -0700, Ron Gleason wrote:

On Tuesday, 11 August 2015 12:03:08 UTC-6, David Kinsell wrote:
No one has commented yet on the SSA response? Likely to be the biggest
impact to soaring in the U.S. in many many years. On the SSA site if
you haven't seen it yet. Maybe pilots flying out of lower states just
don't worry about it.

I was very happy to see it posted a week before the deadline to give
people a chance to read it before submitting their own response. Gave
some background info on the Reno crash that I hadn't heard before,
about rerouting big iron arrivals through the wave area, and the NTSB
investigator believing that was a contributing factor.

The comments about relying on PowerFlarm are not likely to be
persuasive to the FAA, they undoubtedly are well aware of it, and
probably perceive it as being an offshoot system with only minimal
compatibility with the nextgen system they're putting in place.
There's more than a grain of truth to that, although ADS-B is so poorly
done it leaves the door open to alternatives.

-Dave

Thanks for the heads up. Interesting read and I am glad the SSA put the
effort into this response. I do not agree with all the facts and
opinions but since I did not send in a response to the SSA or FAA (yet)
I am happy to live with the results


Currently I'm seeing only 145 responses, posted through the 12th. AOPA
has posted one, substantially similar to SSA saying the current situation
is adequate. The lack of response so far will likely lead to the FAA
proceeding down the current path of removing the glider exemption from
10K to 18K feet.

http://tinyurl.com/qb4gmao

Surprised at some of the comments on RAS, some people think this is just
about transponders. It's about transponders and the ADS-B Out mandate,
there is little chance FAA would require transponders and add a new
exemption for ADS-B.

People keep bringing up PowerFlarm, those comments at best are nothing
more than an irritation to FAA, there is no possibility that PF will be
accepted as a suitable alternative to ADS-B. The FAA and pilots of
powerplanes want to see the glider traffic, and PF doesn't provide that.

I've seen the suggestion that gliders be allowed to turn off transponders/
ADS-B at their discretion to help with the power problem, that's a non-
starter also. Remember the Reno glider was transponder equipped and it
was intentionally turned off. I think I've heard the battery hadn't been
charged after a previous flight, not sure if that's true.

SSA brought up that only 17% of aircraft are TCAS equipped, but those
tend to be large, expensive, high capacity planes that fly much more
often than others. They're also the type that if involved in a collision
with a glider, the sport could get shut down. But in any case, any
discussion about TCAS is backwards-looking, many of those same aircraft
are already equipped with ADS-B both in and out. This ANPRM is about ADS-
B, regardless of what it says in the title.

A surprising number of comments both here and to the FAA have said all
gliders should be transponder equipped (which will certainly mean ADS-B
out equipped). Really folks? A trainer flying from a low elevation
airport, far away from a large airport, and it's supposed to be
equipped? The 10K requirement for mandatory transponder usage is of
course arbitrary, but isn't it unreasonable to require it there with much
more numerous small Cessna's buzzing around under 10K without the
requirement?

The current best options for ADS-B out in gliders are low-power
transponders like the Trig TT22, with a horrendously over-spec'd and over-
priced GPS source added. The TT22 power is listed as 6 watts typical,
significant but not crippling for a glider. I fly with an older Becker
mode C, entire panel is powered from a large battery and solar cells,
never have to supply additional charging. Flexible solar cells are still
quite expensive when purchased for a glider, they haven't come down in
line with costs for other cells.

Current thinking on TABS appears to be incremental changes to the above
to get the cost down:

http://tinyurl.com/pxlk2xd

That presentation talks about commercial grade GPS units that have been
screened. At least they're showing flexibility in the requirements. The
current TSO'ed WAAS units add so much to the installation cost with
nebulous benefits for glider installations.

ADS-B Out sends signals to local aircraft for collision avoidance, as
well as to the ground stations for retransmission on the other
frequency. Of course that's also needed for TIS-B and FIS-B traffic and
weather. The 250 watt peak power of a Class 1 transponder is not needed
for short-range air to air collision avoidance, but that's where we're
headed for a normal ADS-B out installation. Not sure what the peak power
from PF is, but certainly a lot less than 250 watts.

Just a couple days left, but really need more submissions to the FAA in
order to shape the regulations into something acceptable for gliders.
Bringing down the peak power requirements while still allowing operation
to 18K is at the top of my list, along with continued work on make the GPS
requirements reasonable. Frankly, I don't think more "We're OK, some of
us use PF" comments will be productive in changing the course of the
regulations. Airliners want to see glider traffic on their TCAS or ADS-B
In, knowing a glider might get out of the way if equipped, and the PF is
working, isn't adequate.

-Dave