ANPRM - removal of transponder exception for gliders

On Tuesday, June 16, 2015 at 12:05:29 PM UTC-7, Steve Leonard wrote:
On Tuesday, June 16, 2015 at 1:32:53 PM UTC-5, jfitch wrote:

If the proposed rule making and TS0-C199 equipment could be so aligned that existing ADB compliant installations (in gliders there are only 2 or 3 brands), preferably with cheap or existing GPS receivers can be made to work (and I can see no reason why it would be technically difficult) then for many private gliders the cost would be low. For gliders with no current Mode S transponder, the costs would be approximately what a transponder install costs today ($3K maybe?).

I think you mixed a couple of terms. If you have an ADS-B compliant installation, you don't need the cheap/existing GPS source. If you have Mode S, then if the regs align and you can get a cheap/existing GPS approved, then the cost would be low.

But, this is "supposed" to be an option for a system that is to be much lower cost than a transponder. Not as something to put with you existing transponder. Think "handheld radio price-point". The exemption exists primarily because the cost was too great. The lack of an electrical system was chosen as a dividing line.

In the mean time, we wait as Darryl Ramm reads TSO-C199 to see how the government has once again written a spec to assure high prices...

Steve Leonard

I should have said ADS-B compliant transponders. No one has (to my knowledge) and ADS-B complete installation in a glider. But the Mode S transponders commonly installed in gliders all have the "capability" if connected to a compliant GPS, or were at least sold as such. Currently I am told that the compliant GPS costs far more than the transponder.

We have seen what cheap, non-certified equipment in this arena costs: the unregulated PowerFlarm transponder is around $2K once installed. Hard to see how a regulated transponder of any sort will be less. Is TABS intended to be a whole new class of equipment, replacing a transponder, or are those of us who fly near busy commercial space (such as RNO which started the whole thing) going to end up having to have both? Again, my glider and most of the privates flying around RNO lack only a cable (and regulatory approval) to make the promise of TABS a reality tomorrow.

On Wednesday, June 17, 2015 at 1:31:10 AM UTC-5, jfitch wrote:

I should have said ADS-B compliant transponders. No one has (to my knowledge) and ADS-B complete installation in a glider. But the Mode S transponders commonly installed in gliders all have the "capability" if connected to a compliant GPS, or were at least sold as such. Currently I am told that the compliant GPS costs far more than the transponder.

We have seen what cheap, non-certified equipment in this arena costs: the unregulated PowerFlarm transponder is around $2K once installed. Hard to see how a regulated transponder of any sort will be less. Is TABS intended to be a whole new class of equipment, replacing a transponder, or are those of us who fly near busy commercial space (such as RNO which started the whole thing) going to end up having to have both? Again, my glider and most of the privates flying around RNO lack only a cable (and regulatory approval) to make the promise of TABS a reality tomorrow.

To my read, and admittedly, it is not as complete as it should be yet, is that TABS is not in addition to a transponder or ADS-B, but in place of it. However, it will NOT allow you access to airspace that currently requires a transponder. It will be there as a beacon to TCAS and other systems onboard the properly equipped airplanes (TCAS I, II, TAWS, etc). In reading the "high level" descriptions, I am not even sure it will talk to ground based radar. It also sounds like it does nothing to inform you of other TABS equipped airplanes.

What you have is not the promise of TABS, but of ADS-B Out (Mode S Transponder plus GPS input for position). TABS is going to be far less than what you will have. But probably will cost far more than what you have paid so far. Time will tell on the cost.

Steve Leonard

My read of the proposed rule change is as follows:
The proposed change would lift the current glider exception. The current exemption allows us to not have a transponder (or ADSB or TABS in the future) when:
1. Fly within 30 miles of the class B (mode C veil) and under the shelf.
2. Fly above 10,000 feet MSL
3. Fly in class B or C.

What else?

Thanks,
Jamie Shore

I just can't get out of my mind the camel that got his nose under the
tent...

Once the transponder requirement is lifted, how long before ADS-B
becomes required above 10,000'? That's 4,000' AGL maximum where I fly.
What about TCAS, etc.? Forget batteries, I'm looking for a 300-mile
long carbon nanotube reinforced extension cord so I can keep my
batteries up. Either that or dilithium crystals...

And BTW, with the extra weight and drag of the extension cord, how will
that affect my lift/drag ratio and vector triangle?

On 6/17/2015 6:37 AM, Steve Leonard wrote:
On Wednesday, June 17, 2015 at 1:31:10 AM UTC-5, jfitch wrote:
I should have said ADS-B compliant transponders. No one has (to my knowledge) and ADS-B complete installation in a glider. But the Mode S transponders commonly installed in gliders all have the "capability" if connected to a compliant GPS, or were at least sold as such. Currently I am told that the compliant GPS costs far more than the transponder.

We have seen what cheap, non-certified equipment in this arena costs: the unregulated PowerFlarm transponder is around $2K once installed. Hard to see how a regulated transponder of any sort will be less. Is TABS intended to be a whole new class of equipment, replacing a transponder, or are those of us who fly near busy commercial space (such as RNO which started the whole thing) going to end up having to have both? Again, my glider and most of the privates flying around RNO lack only a cable (and regulatory approval) to make the promise of TABS a reality tomorrow.
To my read, and admittedly, it is not as complete as it should be yet, is that TABS is not in addition to a transponder or ADS-B, but in place of it. However, it will NOT allow you access to airspace that currently requires a transponder. It will be there as a beacon to TCAS and other systems onboard the properly equipped airplanes (TCAS I, II, TAWS, etc). In reading the "high level" descriptions, I am not even sure it will talk to ground based radar. It also sounds like it does nothing to inform you of other TABS equipped airplanes.

What you have is not the promise of TABS, but of ADS-B Out (Mode S Transponder plus GPS input for position). TABS is going to be far less than what you will have. But probably will cost far more than what you have paid so far. Time will tell on the cost.

Steve Leonard

--
Dan Marotta

On Wednesday, June 17, 2015 at 8:50:58 AM UTC-4, Jamie Shore wrote:
My read of the proposed rule change is as follows:
The proposed change would lift the current glider exception. The current exemption allows us to not have a transponder (or ADSB or TABS in the future) when:
1. Fly within 30 miles of the class B (mode C veil) and under the shelf.
2. Fly above 10,000 feet MSL
3. Fly in class B or C.

What else?

Your summary is correct, but it lumps together a range of possible outcomes. The FAA is not posing a YES/NO question.

A non-exhaustive enumeration of possible outcomes:

Outcome 0 - No change to current regulations

Outcome 1 - TABS required, Transponder not required, ADS B not required

Outcome 2 - TABS not required, Transponder required, ADS B not required

Outcome 3 - TABS not required, Transponder not required, ADS B in/out required

Outcome N - Some optimal combination of TABS, Xpndr, ADS-B,required.

The FAA solicits comments on the costs and benefits of any and all of the possible outcomes and then they will decide.

On Wednesday, June 17, 2015 at 7:55:48 AM UTC-7, Dan Marotta wrote:
I just can't get out of my mind the camel that got his nose under
the tent...



Once the transponder requirement is lifted, how long before ADS-B
becomes required above 10,000'?* That's 4,000' AGL maximum where I
fly.* What about TCAS, etc.?* Forget batteries, I'm looking for a
300-mile long carbon nanotube reinforced extension cord so I can
keep my batteries up.* Either that or dilithium crystals...



And BTW, with the extra weight and drag of the extension cord, how
will that affect my lift/drag ratio and vector triangle?




On 6/17/2015 6:37 AM, Steve Leonard
wrote:



On Wednesday, June 17, 2015 at 1:31:10 AM UTC-5, jfitch wrote:


I should have said ADS-B compliant transponders. No one has (to my knowledge) and ADS-B complete installation in a glider. But the Mode S transponders commonly installed in gliders all have the "capability" if connected to a compliant GPS, or were at least sold as such. Currently I am told that the compliant GPS costs far more than the transponder.

We have seen what cheap, non-certified equipment in this arena costs: the unregulated PowerFlarm transponder is around $2K once installed. Hard to see how a regulated transponder of any sort will be less. Is TABS intended to be a whole new class of equipment, replacing a transponder, or are those of us who fly near busy commercial space (such as RNO which started the whole thing) going to end up having to have both? Again, my glider and most of the privates flying around RNO lack only a cable (and regulatory approval) to make the promise of TABS a reality tomorrow.


To my read, and admittedly, it is not as complete as it should be yet, is that TABS is not in addition to a transponder or ADS-B, but in place of it. However, it will NOT allow you access to airspace that currently requires a transponder. It will be there as a beacon to TCAS and other systems onboard the properly equipped airplanes (TCAS I, II, TAWS, etc). In reading the "high level" descriptions, I am not even sure it will talk to ground based radar. It also sounds like it does nothing to inform you of other TABS equipped airplanes.

What you have is not the promise of TABS, but of ADS-B Out (Mode S Transponder plus GPS input for position). TABS is going to be far less than what you will have. But probably will cost far more than what you have paid so far. Time will tell on the cost.

Steve Leonard





--

Dan Marotta

While the battery issue was a good argument long ago, it isn't valid anymore. A single 10AH lithium will run what most people have in the cockpit - including an active transponder - for more hours than there are daylight. The equipment is much more power efficient, and the batteries better

On Wednesday, June 17, 2015 at 10:34:01 AM UTC-5, jfitch wrote:

While the battery issue was a good argument long ago, it isn't valid anymore. A single 10AH lithium will run what most people have in the cockpit - including an active transponder - for more hours than there are daylight. The equipment is much more power efficient, and the batteries better

And this will likely be worked in to the response of why there is no need to take away the exemption. Voluntary installation is being accomplished in the areas that need it most. Battery technology is improving so a repeat of the event of 2006 (transponder off to conserve battery for radio) is much less likely to be repeated. Requiring mandatory installation, even if limited to "just gliders" is still going to be a significant financial burden, just as it was when the initial exemption was created. Maybe even more-so now, as the cost of the hardware continues to increase.

In further reading of the spec for TABS, it will not be a low cost option as the initial intent of COTS type GPS has been lost in the requirements. My suspicion is that a Trig TT22 will cost less than the first TABS system to hit the market.

SSA is aware of this ANPRM, and is discussing how to respond.

Steve Leonard
Region 10 SSA Director (among other things)

On Wednesday, June 17, 2015 at 11:34:01 AM UTC-4, jfitch wrote:

While the battery issue was a good argument long ago, it isn't valid anymore. A single 10AH lithium will run what most people have in the cockpit - including an active transponder - for more hours than there are daylight. The equipment is much more power efficient, and the batteries better


If the FAA can get behind putting a non-TSO'd LiPO4 battery in a certified aircraft, then the only real question is whether there is any reason to treat gliders differently than other GA aircraft:

Due to the tapered nose, it is difficult/impossible/expensive to squeeze a full complement of modern gadgets into the panel of many gliders. When gadgets are installed above the original panel, they compromise 'see and avoid'. 'See and Avoid' is profoundly important because gliders routinely fly in formation and in close proximity to each other. TABS, Transponders, ADS-B add little value in formation flying.

Likewise, the non-display-parts of avionics compete for limited space with O2 tank, survival gear, water etc.. When space gets tight, getting everything to fit gets expensive. Glider manufacturers put low and strict limitations on the weight added equipment and luggage. The sensitivity of gliders to weight and balance add additional constraints.

Due to space limitations and/or carbon fiber, it can be difficult to get the proper spacing between the antennas of multiple avionics devices and at the same time obtain the desired range and directional coverage. Externally mounted antennas increase drag and are subject to damage in off-airport landings. The preference for internally mounted antennas makes it harder to achieve a compatible and effective array of antennas.

On Wednesday, June 17, 2015 at 10:14:26 AM UTC-7, son_of_flubber wrote:
On Wednesday, June 17, 2015 at 11:34:01 AM UTC-4, jfitch wrote:

While the battery issue was a good argument long ago, it isn't valid anymore. A single 10AH lithium will run what most people have in the cockpit - including an active transponder - for more hours than there are daylight. The equipment is much more power efficient, and the batteries better


If the FAA can get behind putting a non-TSO'd LiPO4 battery in a certified aircraft, then the only real question is whether there is any reason to treat gliders differently than other GA aircraft:

Due to the tapered nose, it is difficult/impossible/expensive to squeeze a full complement of modern gadgets into the panel of many gliders. When gadgets are installed above the original panel, they compromise 'see and avoid'. 'See and Avoid' is profoundly important because gliders routinely fly in formation and in close proximity to each other. TABS, Transponders, ADS-B add little value in formation flying.

Likewise, the non-display-parts of avionics compete for limited space with O2 tank, survival gear, water etc.. When space gets tight, getting everything to fit gets expensive. Glider manufacturers put low and strict limitations on the weight added equipment and luggage. The sensitivity of gliders to weight and balance add additional constraints.

Due to space limitations and/or carbon fiber, it can be difficult to get the proper spacing between the antennas of multiple avionics devices and at the same time obtain the desired range and directional coverage. Externally mounted antennas increase drag and are subject to damage in off-airport landings. The preference for internally mounted antennas makes it harder to achieve a compatible and effective array of antennas.

It is the non-TSO'd entire electrical system in a glider that is more of an impediment to strict regulatory requirements, battery is but a small detail (the Pb batteries we all use are likewise non TSO'd). It the object is just to stop hitting each other, then my solution still stands as the best/easiest/cheapest. MOD paperwork and empire building of course.

On Wednesday, June 17, 2015 at 7:50:58 AM UTC-5, Jamie Shore wrote:
My read of the proposed rule change is as follows:
The proposed change would lift the current glider exception. The current exemption allows us to not have a transponder (or ADSB or TABS in the future) when:
1. Fly within 30 miles of the class B (mode C veil) and under the shelf.
2. Fly above 10,000 feet MSL
3. Fly in class B or C.

What else?

Thanks,
Jamie Shore

My reading is that if all exemptions for sailplanes were removed from the language of FAR 91.215, then all sailplane operations within 30 nm of the airports listed in FAR 91 Appendix D section 1 would require transponders regardless of altitude. Not sure if that's the same as what you said or not.

S