change in ADS-B rule interpretation!

[Bob Pasker]

from https://www.federalregister.gov/articles/2015/02/09/2015-02579/automatic-dependent-surveillance-broadcast-ads-b-out-performance-requirements-to-support-air-traffic


>>>Under paragraph (b)(1) of that section, in order to operate an aircraft below 18,000 feet MSL and in identified airspace described subsequently in § 91.225, an aircraft must be equipped with equipment that "meets the requirements of TSO-C166b; or TSO-C154c . . .". In reviewing these paragraphs, the FAA notes that the regulatory text implies that the equipment must meet all the requirements of the referenced TSOs. As the ADS-B Out rule is a performance-based rule, it was not the FAA's intent to arguably limit operators to only install equipment marked with a TSO in accordance with 14 CFR part 21, subpart O. The FAA's intent was to permit equipment that meets the performance requirements set forth in the referenced TSOs.


>>> In the NPRM, the FAA proposed in § 91.225(a)(1) and (c)(1) that the equipment installed "Meets the performance requirements in TSO-C-166a" (72 FR 56947, 56971). The inadvertent removal of the word "performance" in the paragraphs implementing these provisions in the final rule was in error and resulted in confusion as to whether the regulation permits other than equipment marked with a TSO, provided that equipment met the specified performance requirements.


So it looks like the equipment must meet the TSO performance requirements, but it doesn't necessarily have to be TSO'd

This is great news!

[[email protected]]

On Tuesday, February 10, 2015 at 7:10:40 AM UTC-6, Bob Pasker wrote:
> from https://www.federalregister.gov/articles/2015/02/09/2015-02579/automatic-dependent-surveillance-broadcast-ads-b-out-performance-requirements-to-support-air-traffic
>
>
> >>>Under paragraph (b)(1) of that section, in order to operate an aircraft below 18,000 feet MSL and in identified airspace described subsequently in § 91.225, an aircraft must be equipped with equipment that "meets the requirements of TSO-C166b; or TSO-C154c . . .". In reviewing these paragraphs, the FAA notes that the regulatory text implies that the equipment must meet all the requirements of the referenced TSOs. As the ADS-B Out rule is a performance-based rule, it was not the FAA's intent to arguably limit operators to only install equipment marked with a TSO in accordance with 14 CFR part 21, subpart O. The FAA's intent was to permit equipment that meets the performance requirements set forth in the referenced TSOs.
>
>
> >>> In the NPRM, the FAA proposed in § 91.225(a)(1) and (c)(1) that the equipment installed "Meets the performance requirements in TSO-C-166a" (72 FR 56947, 56971). The inadvertent removal of the word "performance" in the paragraphs implementing these provisions in the final rule was in error and resulted in confusion as to whether the regulation permits other than equipment marked with a TSO, provided that equipment met the specified performance requirements.
>
>
> So it looks like the equipment must meet the TSO performance requirements, but it doesn't necessarily have to be TSO'd
>
> This is great news!

AOPA and EAA have been lobbying for such a change for quite some time now. I wonder if this also applies to operating GA aircraft and gliders in and under B and C airspace. If in fact TSO'd equipment is NOT necessary under 18,000', that would open the door to cheaper, even portable ADS-B out equipment, just what the doctor ordered.

[Bob Pasker]

the way I read (b) [amended as per my original email] and (d) is that yes, this includes Class B and C airspace


(b) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft below 18,000 feet MSL and in airspace described in paragraph (d) of this section unless the aircraft has equipment installed that--
(1) Meets the requirements in--
(i) TSO-C166b; or
(ii) TSO-C154c, Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS-B) Equipment Operating on the Frequency of 978 MHz;

(d) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft in the following airspace unless the aircraft has equipment installed that meets the requirements in paragraph (b) of this section: (1) Class B and Class C airspace areas;

[Bill T]

I believe that the GPS reciever still needs to be WAAS compliant to provide ADSB out data. The key would be to approve portable ADSB out devices, currently available for about $1500 with WAAS GPS built in, for use in glider tow and gliders. It sure would save out club a heap of $$$ for the tow plane, we are under the class b shelf.

BillT

[jfitch]

On Tuesday, February 10, 2015 at 12:20:37 PM UTC-8, Bill T wrote:
> I believe that the GPS reciever still needs to be WAAS compliant to provide ADSB out data. The key would be to approve portable ADSB out devices, currently available for about $1500 with WAAS GPS built in, for use in glider tow and gliders. It sure would save out club a heap of $$$ for the tow plane, we are under the class b shelf.
>
> BillT

I thought most GPS units installed in gliders (at least in the last few years) were WAAS compliant.

[Bill T]

Most GPS units in gliders may be WAAS compliant, but with the previous language they were not approved to provide adsb out because they do not have the TSO Certification.
BillT

[jfitch]

On Tuesday, February 10, 2015 at 8:17:50 PM UTC-8, Bill T wrote:
> Most GPS units in gliders may be WAAS compliant, but with the previous language they were not approved to provide adsb out because they do not have the TSO Certification.
> BillT

It appears in the new rules that it only has to meet the performance requirements. Furthermore the wording would suggest it is up to the installer to decide that it does until the FAA indicates otherwise? Which is reversed from TSO. Almost any GPS engine is WAAS compliant now. But I don't know what else is involved in meeting the 'performance requirement'. It seems like there is hope though, given that the spec was written while vacuum tubes were still in common use.

I'm sure Darryl will jump in at any moment and set me straight.

[[email protected]]

On Wednesday, February 11, 2015 at 12:39:47 AM UTC-6, jfitch wrote:
> On Tuesday, February 10, 2015 at 8:17:50 PM UTC-8, Bill T wrote:
> > Most GPS units in gliders may be WAAS compliant, but with the previous language they were not approved to provide adsb out because they do not have the TSO Certification.
> > BillT
>
> It appears in the new rules that it only has to meet the performance requirements. Furthermore the wording would suggest it is up to the installer to decide that it does until the FAA indicates otherwise? Which is reversed from TSO. Almost any GPS engine is WAAS compliant now. But I don't know what else is involved in meeting the 'performance requirement'. It seems like there is hope though, given that the spec was written while vacuum tubes were still in common use.
>
> I'm sure Darryl will jump in at any moment and set me straight.

More on the subject this morning on the AVweb website:
http://www.avweb.com/avwebflash/news/FAA-Amends-ADS-B-Rule223533-1.html

I'm also eager to see what Darryl will make of this.

[Darryl Ramm]

On Tuesday, February 10, 2015 at 5:10:40 AM UTC-8, Bob Pasker wrote:
> from https://www.federalregister.gov/articles/2015/02/09/2015-02579/automatic-dependent-surveillance-broadcast-ads-b-out-performance-requirements-to-support-air-traffic
>
>
> >>>Under paragraph (b)(1) of that section, in order to operate an aircraft below 18,000 feet MSL and in identified airspace described subsequently in § 91.225, an aircraft must be equipped with equipment that "meets the requirements of TSO-C166b; or TSO-C154c . . .". In reviewing these paragraphs, the FAA notes that the regulatory text implies that the equipment must meet all the requirements of the referenced TSOs. As the ADS-B Out rule is a performance-based rule, it was not the FAA's intent to arguably limit operators to only install equipment marked with a TSO in accordance with 14 CFR part 21, subpart O. The FAA's intent was to permit equipment that meets the performance requirements set forth in the referenced TSOs.
>
>
> >>> In the NPRM, the FAA proposed in § 91.225(a)(1) and (c)(1) that the equipment installed "Meets the performance requirements in TSO-C-166a" (72 FR 56947, 56971). The inadvertent removal of the word "performance" in the paragraphs implementing these provisions in the final rule was in error and resulted in confusion as to whether the regulation permits other than equipment marked with a TSO, provided that equipment met the specified performance requirements.
>
>
> So it looks like the equipment must meet the TSO performance requirements, but it doesn't necessarily have to be TSO'd
>
> This is great news!

Unfortunately this is just non-news. Kind of as the notice implies this is just a minor typo correction and really does not mean what you are hoping it means.

Many CFR 14 regulations that specify carriage of a TSO device use similar "meets requirements" wording. e.g. 14 CFR 91.215 which mandates transponder carriage, there you go opening paragraph... "...must meet the performance and environmental requirements...". What this means if you end up in an argument with an FAA inspector over an installation where some box does not have a TSO document, well that can get complex, but hopefully this area is somewhat familiar to A&Ps actually installing stuff in aircraft. And often comes up in discussion including on r.a.s. before.

Unfortunately say reading TSO-C-166a won't help most people, as with most TSO's it just refers to RTCA standards documents, in this case largely DO-260A, but it also pulls in other RTCA standard. And you can't get free access to and of those standards. Whether governments should be basing regulations on proprietary documents that citizens do not have free access to is a longer discussion.

And these TSOs affect the UAT or 1090ES Out (or Out/In) part of the ADS-B picture, the specification of the GPS input required to provide ADS-B Out in a certified aircraft and/or to meet the 2020 carriage mandate requirements also get captured in enough additional places outside of that one specific chain of regulations/TSO/RTCA standards.

Nobody is going to be helped to produce anything as radical as a low-cost portable ADS-B Out transmitter based on this minor change in wording. The device still has to meet a complex set of RTCA requirements, that preclude doing exactly that, And for example the device still has to be connected to altitude encoders, Mode A setting controls, etc. And to be installed in a certified aircraft still require field approval based on a prior STC install that paired a specific ADS-B out device and IFR/WAAS spec GPS. This is mostly an "inside-baseball" thing that might be useful for say a manufacture of avionics to enter the USA market faster then they otherwise would, and avoid a little TSO related delay, but not RTCA standards compliance testing, etc.

And when discussing aviation regulations in any way with TSOed or IFR or WAAS GPS we are not talking about your typical consumer GPS that has WAAS. It has a specific complex set of technical requirements, that a consumer device cannot meet, and cannot meet the "performance requirements of". Things like hoping to ever broadly utilize more COTS GPS for ADS-B Out purposes in the USA absolutely requires new regulation that does *not* require meeting the performance requirements of the TSOs that specify that today (e.g. TSO-C145c). In fact the relevant regulations and ACs in use today already us "meet the performance requirement of TSO-C145" etc. type wording, that does not help jack with solving the complex/expensive GPS requirements for ADS-B out. Which is why TSO-C199 which has come up in other threads here recently, is interesting, as it does exactly that.... for limited airborne traffic awareness/collision avoidance beacon only purposes it completely steps away from any of these "IFR/WAAS" (e.g. TSO-C145c type) GPS "meets performance of" type requirements.

[Darryl Ramm]

On Wednesday, February 11, 2015 at 7:00:42 AM UTC-8, wrote:
> On Wednesday, February 11, 2015 at 12:39:47 AM UTC-6, jfitch wrote:
> > On Tuesday, February 10, 2015 at 8:17:50 PM UTC-8, Bill T wrote:
> > > Most GPS units in gliders may be WAAS compliant, but with the previous language they were not approved to provide adsb out because they do not have the TSO Certification.
> > > BillT
> >
> > It appears in the new rules that it only has to meet the performance requirements. Furthermore the wording would suggest it is up to the installer to decide that it does until the FAA indicates otherwise? Which is reversed from TSO. Almost any GPS engine is WAAS compliant now. But I don't know what else is involved in meeting the 'performance requirement'. It seems like there is hope though, given that the spec was written while vacuum tubes were still in common use.
> >
> > I'm sure Darryl will jump in at any moment and set me straight.
>
> More on the subject this morning on the AVweb website:
> http://www.avweb.com/avwebflash/news/FAA-Amends-ADS-B-Rule223533-1.html
>
> I'm also eager to see what Darryl will make of this.

I think on one hand AV Web may overstates this, but on the other hand they are partially correct and mostly in the sense where this can get used as a shell game. e.g. manufacturers sometimes produce a TSO'ed device and a non-TSO'ed equivalent device and differentiate the two based on price even though they have little difference in actual manufacturing cost. And they sell the two devices to different markets, e.g. experimental vs. IFR aircraft (and where installers in some cases may erroneously believe they absolutely require to have a TSO'ed device when they may not).

In this case I don't expect this will actually significantly change any ADS-B Out costs in the USA not for some time. For example it is still a market where very few vendors can manufacturer any ADS-B Out device or GPS receiver that ... meets performance requirements of.. any TSO. Maybe not until vendors start producing an ADS-B Out devices with integrated GPS sources do I expect to see an ADS-B Out price drop. And prices will come down in general as 2020 approaches and people actually feel compelled to start installing anything (again gliders are exempt from most of the carriage requirements).. In which case I would not be surprised if manufacturers avoid formal TSOs and utilize the ...meets performance parts say at least for the internal GPS. And I would not be surprised if some vendors keep playing pricing shell games.

[Darryl Ramm]

On Tuesday, February 10, 2015 at 8:17:50 PM UTC-8, Bill T wrote:
> Most GPS units in gliders may be WAAS compliant, but with the previous language they were not approved to provide adsb out because they do not have the TSO Certification.
> BillT

Many consumer GPS chipset based GPS receivers in gliders may utilize WAAS/SBAS technology. But that is *very* different than what is meant by a IFW/WAAS GPS receiver like specified for example in TSO-C145 and the RTCA standards it incorporates.

I would be surprised if there is any GPS receivers installed in any glider gliders that is "WAAS Compliant" if that means TSO-C145, if not that then "compliant" to what standard?

[Darryl Ramm]

Bill T > wrote:
> I believe that the GPS reciever still needs to be WAAS compliant to
> provide ADSB out data. The key would be to approve portable ADSB out
> devices, currently available for about $1500 with WAAS GPS built in, for
> use in glider tow and gliders. It sure would save out club a heap of $$$
> for the tow plane, we are under the class b shelf.
>
> BillT

I am not aware of any ADS-B *Out* product priced at about $1,500 with or
without being portable or with or without a built-in "WAAS GPS".

I suspect you are confusing this ADS-B Out and ADS-B In. Portable ADS-B
*In* receivers typically include a consumer grade WAAS chipset to locate
the aircraft's own position on weather and traffic displays and to provide
location/navigation data for external PDA/PNA/tablet navigation software.

ADS-B Out in gliders and towplane provides little value over other options
that are actually available, installable and well understood today. If you
want glider-glider and glider-towplane collision avoidance technology
install a PowerFLARM. If you are concerned about other traffic, PowerFLARM
PCAS and ADS-B 1090ES In can help, as can installing a transponder...
especially if the concern is fast jets and airliners.

If you operate under a Class B shelf your towplane will already have a
transponder, and unfortunately will also be required to equip with ADS-B
Out by January 2020. If not already equipped with one you should look at a
Mode-S 1090ES Out compatible transponder like a Trig TT-22. UAT Out devices
would be a very bad idea in a towplane as they won't be seen on a
PowerFLARM.

[Darryl Ramm]

And just today L3 announced more details of their L3 Lynx ADS-B products,
they do apparently include non-TSOed but TSO performance meeting GPS
devices... details are very thin. MSRP is $3,200 for a display less UAT Out
and In box (there is a cheaper UAT Out only box but no pricing yet) and
$6,800 for a Mode S/1090ES Out/1090ES In/UAT In box. All include a
built-in GPS source. The transponder packaging and power consumption are
likely to be quite unsuitable for use in gliders even if somebody wanted to
spend $6,800 plus installation costs. For the GA users this is targeted at
these products may be compelling, especially for older aircraft not
equipped with an IFR/WAAS GPS and an old (high risk if needing repair)
transponder. And I expect prices to drop further as 2020 approaches.

L3 refer to the included internal GPS in these devices as a "Rule Compliant
Position Source"... in other words that GPS is not TSOed but does "meet the
performance requirements of..." (likely TSO-C145c). So you do see effects
of that all that CFR14 91 "meets performance of..." wording here, no word I
could find on the actual TSO status of the boxes themselves. If L3 do not
TSO them expect a pile of confusion/arguments out there in GA A&P land...

[Mike Schumann[_2_]]

On Wednesday, February 11, 2015 at 4:27:24 PM UTC-5, Darryl Ramm wrote:
> Bill T > wrote:
> > I believe that the GPS reciever still needs to be WAAS compliant to
> > provide ADSB out data. The key would be to approve portable ADSB out
> > devices, currently available for about $1500 with WAAS GPS built in, for
> > use in glider tow and gliders. It sure would save out club a heap of $$$
> > for the tow plane, we are under the class b shelf.
> >
> > BillT
>
> I am not aware of any ADS-B *Out* product priced at about $1,500 with or
> without being portable or with or without a built-in "WAAS GPS".
>
> I suspect you are confusing this ADS-B Out and ADS-B In. Portable ADS-B
> *In* receivers typically include a consumer grade WAAS chipset to locate
> the aircraft's own position on weather and traffic displays and to provide
> location/navigation data for external PDA/PNA/tablet navigation software.
>
> ADS-B Out in gliders and towplane provides little value over other options
> that are actually available, installable and well understood today. If you
> want glider-glider and glider-towplane collision avoidance technology
> install a PowerFLARM. If you are concerned about other traffic, PowerFLARM
> PCAS and ADS-B 1090ES In can help, as can installing a transponder...
> especially if the concern is fast jets and airliners.
>
> If you operate under a Class B shelf your towplane will already have a
> transponder, and unfortunately will also be required to equip with ADS-B
> Out by January 2020. If not already equipped with one you should look at a
> Mode-S 1090ES Out compatible transponder like a Trig TT-22. UAT Out devices
> would be a very bad idea in a towplane as they won't be seen on a
> PowerFLARM.

PowerFLARM would be a great solution if it supported TIS-B and was coupled with an ADS-B OUT solution. Without TIS-B support, I'm totally uninterested.

[Darryl Ramm]

Mike Schumann > wrote:
> On Wednesday, February 11, 2015 at 4:27:24 PM UTC-5, Darryl Ramm wrote:
>> Bill T > wrote:
>>> I believe that the GPS reciever still needs to be WAAS compliant to
>>> provide ADSB out data. The key would be to approve portable ADSB out
>>> devices, currently available for about $1500 with WAAS GPS built in, for
>>> use in glider tow and gliders. It sure would save out club a heap of $$$
>>> for the tow plane, we are under the class b shelf.
>>>
>>> BillT
>>
>> I am not aware of any ADS-B *Out* product priced at about $1,500 with or
>> without being portable or with or without a built-in "WAAS GPS".
>>
>> I suspect you are confusing this ADS-B Out and ADS-B In. Portable ADS-B
>> *In* receivers typically include a consumer grade WAAS chipset to locate
>> the aircraft's own position on weather and traffic displays and to provide
>> location/navigation data for external PDA/PNA/tablet navigation software.
>>
>> ADS-B Out in gliders and towplane provides little value over other options
>> that are actually available, installable and well understood today. If you
>> want glider-glider and glider-towplane collision avoidance technology
>> install a PowerFLARM. If you are concerned about other traffic, PowerFLARM
>> PCAS and ADS-B 1090ES In can help, as can installing a transponder...
>> especially if the concern is fast jets and airliners.
>>
>> If you operate under a Class B shelf your towplane will already have a
>> transponder, and unfortunately will also be required to equip with ADS-B
>> Out by January 2020. If not already equipped with one you should look at a
>> Mode-S 1090ES Out compatible transponder like a Trig TT-22. UAT Out devices
>> would be a very bad idea in a towplane as they won't be seen on a
>> PowerFLARM.
>
> PowerFLARM would be a great solution if it supported TIS-B and was
> coupled with an ADS-B OUT solution. Without TIS-B support, I'm totally uninterested.

Oh jeez what a surprise?

Where exactly is this mythical place you fly? What gliders do you fly today
and with what collision avoidance technology? What glider do you own?
Presumably if it is GA or other non-glider traffic that is your concern
that you have been posting for years on r.a.s. about you have been
operating transponders in your glider(s) for all that time right? If you
fly out of a club and have all these concerns about GS and other traffic
where you fly then presumably you have worked to have all their gliders
transponder equipped years ago, if not why not?

[[email protected]]

On Thursday, February 12, 2015 at 12:27:05 PM UTC-6, Darryl Ramm wrote:
> Mike Schumann > wrote:
> > On Wednesday, February 11, 2015 at 4:27:24 PM UTC-5, Darryl Ramm wrote:
> >> Bill T > wrote:
> >>> I believe that the GPS reciever still needs to be WAAS compliant to
> >>> provide ADSB out data. The key would be to approve portable ADSB out
> >>> devices, currently available for about $1500 with WAAS GPS built in, for
> >>> use in glider tow and gliders. It sure would save out club a heap of $$$
> >>> for the tow plane, we are under the class b shelf.
> >>>
> >>> BillT
> >>
> >> I am not aware of any ADS-B *Out* product priced at about $1,500 with or
> >> without being portable or with or without a built-in "WAAS GPS".
> >>
> >> I suspect you are confusing this ADS-B Out and ADS-B In. Portable ADS-B
> >> *In* receivers typically include a consumer grade WAAS chipset to locate
> >> the aircraft's own position on weather and traffic displays and to provide
> >> location/navigation data for external PDA/PNA/tablet navigation software.
> >>
> >> ADS-B Out in gliders and towplane provides little value over other options
> >> that are actually available, installable and well understood today. If you
> >> want glider-glider and glider-towplane collision avoidance technology
> >> install a PowerFLARM. If you are concerned about other traffic, PowerFLARM
> >> PCAS and ADS-B 1090ES In can help, as can installing a transponder...
> >> especially if the concern is fast jets and airliners.
> >>
> >> If you operate under a Class B shelf your towplane will already have a
> >> transponder, and unfortunately will also be required to equip with ADS-B
> >> Out by January 2020. If not already equipped with one you should look at a
> >> Mode-S 1090ES Out compatible transponder like a Trig TT-22. UAT Out devices
> >> would be a very bad idea in a towplane as they won't be seen on a
> >> PowerFLARM.
> >
> > PowerFLARM would be a great solution if it supported TIS-B and was
> > coupled with an ADS-B OUT solution. Without TIS-B support, I'm totally uninterested.
>
> Oh jeez what a surprise?
>
> Where exactly is this mythical place you fly? What gliders do you fly today
> and with what collision avoidance technology? What glider do you own?
> Presumably if it is GA or other non-glider traffic that is your concern
> that you have been posting for years on r.a.s. about you have been
> operating transponders in your glider(s) for all that time right? If you
> fly out of a club and have all these concerns about GS and other traffic
> where you fly then presumably you have worked to have all their gliders
> transponder equipped years ago, if not why not?

Darryl,
The industry is reacting fast to the clarifying information from the FAA:
http://www.aopa.org/News-and-Video/All-News/2015/February/12/NavWorx-ADSB?WT.mc_id=150213epilot&WT.mc_sect=tec
Here is your ADS-B OUT box for $699, including WAAS GPS engine. Only good for experimental and kit built LSAs but a good start.
I have a transponder and PFlarm in my 'experimental' glider but would this be an option for those in high-traffic areas who right now don't fly with a transponder? PFlarm shows ADS-B targets very precisely and obviously ATC would know where you are. What's your take on that, Darryl? Mike S, no need to chime in!
Herb

[Darryl Ramm]

On Friday, February 13, 2015 at 1:43:37 PM UTC-8, wrote:
> On Thursday, February 12, 2015 at 12:27:05 PM UTC-6, Darryl Ramm wrote:
> > Mike Schumann > wrote:
> > > On Wednesday, February 11, 2015 at 4:27:24 PM UTC-5, Darryl Ramm wrote:
> > >> Bill T > wrote:
> > >>> I believe that the GPS reciever still needs to be WAAS compliant to
> > >>> provide ADSB out data. The key would be to approve portable ADSB out
> > >>> devices, currently available for about $1500 with WAAS GPS built in, for
> > >>> use in glider tow and gliders. It sure would save out club a heap of $$$
> > >>> for the tow plane, we are under the class b shelf.
> > >>>
> > >>> BillT
> > >>
> > >> I am not aware of any ADS-B *Out* product priced at about $1,500 with or
> > >> without being portable or with or without a built-in "WAAS GPS".
> > >>
> > >> I suspect you are confusing this ADS-B Out and ADS-B In. Portable ADS-B
> > >> *In* receivers typically include a consumer grade WAAS chipset to locate
> > >> the aircraft's own position on weather and traffic displays and to provide
> > >> location/navigation data for external PDA/PNA/tablet navigation software.
> > >>
> > >> ADS-B Out in gliders and towplane provides little value over other options
> > >> that are actually available, installable and well understood today. If you
> > >> want glider-glider and glider-towplane collision avoidance technology
> > >> install a PowerFLARM. If you are concerned about other traffic, PowerFLARM
> > >> PCAS and ADS-B 1090ES In can help, as can installing a transponder....
> > >> especially if the concern is fast jets and airliners.
> > >>
> > >> If you operate under a Class B shelf your towplane will already have a
> > >> transponder, and unfortunately will also be required to equip with ADS-B
> > >> Out by January 2020. If not already equipped with one you should look at a
> > >> Mode-S 1090ES Out compatible transponder like a Trig TT-22. UAT Out devices
> > >> would be a very bad idea in a towplane as they won't be seen on a
> > >> PowerFLARM.
> > >
> > > PowerFLARM would be a great solution if it supported TIS-B and was
> > > coupled with an ADS-B OUT solution. Without TIS-B support, I'm totally uninterested.
> >
> > Oh jeez what a surprise?
> >
> > Where exactly is this mythical place you fly? What gliders do you fly today
> > and with what collision avoidance technology? What glider do you own?
> > Presumably if it is GA or other non-glider traffic that is your concern
> > that you have been posting for years on r.a.s. about you have been
> > operating transponders in your glider(s) for all that time right? If you
> > fly out of a club and have all these concerns about GS and other traffic
> > where you fly then presumably you have worked to have all their gliders
> > transponder equipped years ago, if not why not?
>
> Darryl,
> The industry is reacting fast to the clarifying information from the FAA:
> http://www.aopa.org/News-and-Video/All-News/2015/February/12/NavWorx-ADSB?WT.mc_id=150213epilot&WT.mc_sect=tec
> Here is your ADS-B OUT box for $699, including WAAS GPS engine. Only good for experimental and kit built LSAs but a good start.
> I have a transponder and PFlarm in my 'experimental' glider but would this be an option for those in high-traffic areas who right now don't fly with a transponder? PFlarm shows ADS-B targets very precisely and obviously ATC would know where you are. What's your take on that, Darryl? Mike S, no need to chime in!
> Herb

Herb, thanks for the link, I'll reply more including about that specific UAT transceiver when I have more time, but briefly.

This UAT transceiver would be a *very* bad option for gliders flying in high-traffic areas.

Unlike a transponder UAT Out does not interoperable with TCAS, certainly would never cause an RA to be issued. That big old jet airliner could fly right though you with no warning... its' simply just universally assumed that any aircraft getting near an airliner, fast-jet etc. at a minimum has a transponder (or a transponder and UAT Out, or a transponder with 1090ES Out, but *never* UAT Out only).

The dual-link insanity in the USA cases more problems than is worth. You can't just talk about ADS-B without needing to be clear about what link layer....

Be careful assuming PowerFLARM shows ADS-B traffic at all... It does shows 1090ES Out traffic very precisely, however it does not show UAT traffic *at all*. You would not see an aircraft equipped with this transceiver with a PowerFLARM.

As far as I know the PowerFLARM at least as it exists today (and I have no idea of future plans) does not support ADS-R (or TIS-B) and so cannot use the FAA's ground based infrastructure that can (if you are in range) translate between link layers, (and even if it did the receiving glider would also need ADS-B Out properly set up to advertise the aircraft is capable of receiving ADS-B on the right link layer.... so the ground infrastructure broadcasts traffic to it on the link-layer it can receive that on). Even if you had all this it would only work in areas at at altitudes where three is ADS-B ground station line of sight coverage. A painfully obvious issue there is that at many gliderports, small airports, large airports, etc.the traffic pattern and higher is all below this ADS-B ground infrastructure coverage. And a UAT Out equipped aircraft in that area just won't be seen by a 1090ES In equipped aircraft and visa-versa. The only solution there is for all aircraft to be equipped with receivers for both link layers (e.g. 1090ES In and UAT In). Many manufacturers are doing exactly that, and there is no way I'd put ADS-B In anything in a GA aircraft that was not dual-link receive.

For all these reasons it is important that anybody who really wants to equip a glider or towplane with ADS-B out does so with 1090ES Out systems. We should see prices on those 1090ES Out systems and GPS units continue to fall.. And the flip side of this is most glider or towplane pilots have no need to equip with ADS-B Out anything. PowerFLARM and/or Transponders provide a lot of value today without needing ADS-B Out.

[Andy Blackburn[_3_]]

On Friday, February 13, 2015 at 2:47:45 PM UTC-8, Darryl Ramm wrote:
>
> Unlike a transponder UAT Out does not interoperable with TCAS, certainly would never cause an RA to be issued. That big old jet airliner could fly right though you with no warning... its' simply just universally assumed that any aircraft getting near an airliner, fast-jet etc. at a minimum has a transponder (or a transponder and UAT Out, or a transponder with 1090ES Out, but *never* UAT Out only).
>

This is a critical point.

Most of the traffic out there, if it is carrying any form of ADS-B Out at all, is likely carrying 1090ES Out today (it's the only variant used in Europe and the only variant aircraft flying in Class A in the US carry). The fact that you cannot substitute ADS-B Out carriage for transponder carriage under the regulations is precisely because ADS-B does not activate the RA collision avoidance in TCAS. Take that plus the antenna diversity requirements under the FARs and it seems likely that most aircraft owners in the US will find it easier to equip with a Mode S transponder plus ADS-B 1090 ES Out plus either 1090 ES In or dual-link ADS-B in (it's pretty cheap to provide 1090ES and UAT In "just in case" and to get weather data services - most OEMs are doing this and it would be nice if a future version of PowerFLARM did this too).

I find it difficult to understand why anyone would equip with the duplicate transmitter, antennas, and endure the maintenance, etc, to equip a transponder plus ADS-B UAT Out when the simple solution is to get a Mode S and (at some point) add a (less expensive every day) GPS source to upgrade the transponder to 1090ES Out. The number of scenarios where you are outside ATC SSR coverage but within line of sight to an ADS-R ground station to pick up whatever misguided souls decided to equip with UAT Out only (and not a transponder) are too remote to bother with, and certainly not worth giving up TCAS. Yes, you could always equip with EVERYTHING, but your aircraft will be a porcupine of antennas and it isn't at all clear that you gain very much.

For gliders the best migration path is pretty clear: if you fly mostly with other gliders, get a PowerFLARM, if you fly near a busy airport with a lot power traffic, get a Mode S transponder that can upgrade to 1090 ES Out as the OEMs figure out how to get cheaper GPS sources to market. If you are worried about both scenarios, get both bits of gear.

9B

[Dan Marotta]

http://upload.wikimedia.org/wikipedia/commons/9/96/Beechcraft_RC-12N_Huron_in_flight.jpg

On 2/14/2015 8:06 AM, Andy Blackburn wrote:
> On Friday, February 13, 2015 at 2:47:45 PM UTC-8, Darryl Ramm wrote:
>> Unlike a transponder UAT Out does not interoperable with TCAS, certainly would never cause an RA to be issued. That big old jet airliner could fly right though you with no warning... its' simply just universally assumed that any aircraft getting near an airliner, fast-jet etc. at a minimum has a transponder (or a transponder and UAT Out, or a transponder with 1090ES Out, but *never* UAT Out only).
>>
> This is a critical point.
>
> Most of the traffic out there, if it is carrying any form of ADS-B Out at all, is likely carrying 1090ES Out today (it's the only variant used in Europe and the only variant aircraft flying in Class A in the US carry). The fact that you cannot substitute ADS-B Out carriage for transponder carriage under the regulations is precisely because ADS-B does not activate the RA collision avoidance in TCAS. Take that plus the antenna diversity requirements under the FARs and it seems likely that most aircraft owners in the US will find it easier to equip with a Mode S transponder plus ADS-B 1090 ES Out plus either 1090 ES In or dual-link ADS-B in (it's pretty cheap to provide 1090ES and UAT In "just in case" and to get weather data services - most OEMs are doing this and it would be nice if a future version of PowerFLARM did this too).
>
> I find it difficult to understand why anyone would equip with the duplicate transmitter, antennas, and endure the maintenance, etc, to equip a transponder plus ADS-B UAT Out when the simple solution is to get a Mode S and (at some point) add a (less expensive every day) GPS source to upgrade the transponder to 1090ES Out. The number of scenarios where you are outside ATC SSR coverage but within line of sight to an ADS-R ground station to pick up whatever misguided souls decided to equip with UAT Out only (and not a transponder) are too remote to bother with, and certainly not worth giving up TCAS. Yes, you could always equip with EVERYTHING, but your aircraft will be a porcupine of antennas and it isn't at all clear that you gain very much.
>
> For gliders the best migration path is pretty clear: if you fly mostly with other gliders, get a PowerFLARM, if you fly near a busy airport with a lot power traffic, get a Mode S transponder that can upgrade to 1090 ES Out as the OEMs figure out how to get cheaper GPS sources to market. If you are worried about both scenarios, get both bits of gear.
>
> 9B
>

--
Dan Marotta

[Charlie M. (UH & 002 owner/pilot)]

On Saturday, February 14, 2015 at 11:20:10 AM UTC-5, Dan Marotta wrote:
> http://upload.wikimedia.org/wikipedia/commons/9/96/Beechcraft_RC-12N_Huron_in_flight.jpg
>
>
>
>
> On 2/14/2015 8:06 AM, Andy Blackburn
> wrote:
>
>
>
> On Friday, February 13, 2015 at 2:47:45 PM UTC-8, Darryl Ramm wrote:
>
>
> Unlike a transponder UAT Out does not interoperable with TCAS, certainly would never cause an RA to be issued. That big old jet airliner could fly right though you with no warning... its' simply just universally assumed that any aircraft getting near an airliner, fast-jet etc. at a minimum has a transponder (or a transponder and UAT Out, or a transponder with 1090ES Out, but *never* UAT Out only).
>
>
>
> This is a critical point.
>
> Most of the traffic out there, if it is carrying any form of ADS-B Out at all, is likely carrying 1090ES Out today (it's the only variant used in Europe and the only variant aircraft flying in Class A in the US carry). The fact that you cannot substitute ADS-B Out carriage for transponder carriage under the regulations is precisely because ADS-B does not activate the RA collision avoidance in TCAS. Take that plus the antenna diversity requirements under the FARs and it seems likely that most aircraft owners in the US will find it easier to equip with a Mode S transponder plus ADS-B 1090 ES Out plus either 1090 ES In or dual-link ADS-B in (it's pretty cheap to provide 1090ES and UAT In "just in case" and to get weather data services - most OEMs are doing this and it would be nice if a future version of PowerFLARM did this too).
>
> I find it difficult to understand why anyone would equip with the duplicate transmitter, antennas, and endure the maintenance, etc, to equip a transponder plus ADS-B UAT Out when the simple solution is to get a Mode S and (at some point) add a (less expensive every day) GPS source to upgrade the transponder to 1090ES Out. The number of scenarios where you are outside ATC SSR coverage but within line of sight to an ADS-R ground station to pick up whatever misguided souls decided to equip with UAT Out only (and not a transponder) are too remote to bother with, and certainly not worth giving up TCAS. Yes, you could always equip with EVERYTHING, but your aircraft will be a porcupine of antennas and it isn't at all clear that you gain very much.
>
> For gliders the best migration path is pretty clear: if you fly mostly with other gliders, get a PowerFLARM, if you fly near a busy airport with a lot power traffic, get a Mode S transponder that can upgrade to 1090 ES Out as the OEMs figure out how to get cheaper GPS sources to market. If you are worried about both scenarios, get both bits of gear.
>
> 9B
>
>
>
>
>
>
> --
>
> Dan Marotta

ROTFLMAO.......

[[email protected]]

On Saturday, February 14, 2015 at 10:20:10 AM UTC-6, Dan Marotta wrote:
> http://upload.wikimedia.org/wikipedia/commons/9/96/Beechcraft_RC-12N_Huron_in_flight.jpg
>
>
>
>
> On 2/14/2015 8:06 AM, Andy Blackburn
> wrote:
>
>
>
> On Friday, February 13, 2015 at 2:47:45 PM UTC-8, Darryl Ramm wrote:
>
>
> Unlike a transponder UAT Out does not interoperable with TCAS, certainly would never cause an RA to be issued. That big old jet airliner could fly right though you with no warning... its' simply just universally assumed that any aircraft getting near an airliner, fast-jet etc. at a minimum has a transponder (or a transponder and UAT Out, or a transponder with 1090ES Out, but *never* UAT Out only).
>
>
>
> This is a critical point.
>
> Most of the traffic out there, if it is carrying any form of ADS-B Out at all, is likely carrying 1090ES Out today (it's the only variant used in Europe and the only variant aircraft flying in Class A in the US carry). The fact that you cannot substitute ADS-B Out carriage for transponder carriage under the regulations is precisely because ADS-B does not activate the RA collision avoidance in TCAS. Take that plus the antenna diversity requirements under the FARs and it seems likely that most aircraft owners in the US will find it easier to equip with a Mode S transponder plus ADS-B 1090 ES Out plus either 1090 ES In or dual-link ADS-B in (it's pretty cheap to provide 1090ES and UAT In "just in case" and to get weather data services - most OEMs are doing this and it would be nice if a future version of PowerFLARM did this too).
>
> I find it difficult to understand why anyone would equip with the duplicate transmitter, antennas, and endure the maintenance, etc, to equip a transponder plus ADS-B UAT Out when the simple solution is to get a Mode S and (at some point) add a (less expensive every day) GPS source to upgrade the transponder to 1090ES Out. The number of scenarios where you are outside ATC SSR coverage but within line of sight to an ADS-R ground station to pick up whatever misguided souls decided to equip with UAT Out only (and not a transponder) are too remote to bother with, and certainly not worth giving up TCAS. Yes, you could always equip with EVERYTHING, but your aircraft will be a porcupine of antennas and it isn't at all clear that you gain very much.
>
> For gliders the best migration path is pretty clear: if you fly mostly with other gliders, get a PowerFLARM, if you fly near a busy airport with a lot power traffic, get a Mode S transponder that can upgrade to 1090 ES Out as the OEMs figure out how to get cheaper GPS sources to market. If you are worried about both scenarios, get both bits of gear.
>
> 9B
>
>
>
>
>
>
> --
>
> Dan Marotta

Dan, are those the new PowerFlarm B-X antennae? I bet they want you to pay for a license for every one of them!

[Bill T]

Darryl, thanks for the information. It's a lot to digest.

We are under the Class B, well within the 30nm veil. 3 of or 4 club gliders have Trig transponders. Many of our private owners are running trig or power flarm.
Our concern is the ADSB out requirement for the tow plane. We have an old basic Mode C transponder, not a nice 1090ES capability, and no GPS recieve in the tow plane. I've been looking at some of the FreeFlight equipment for adsb out only, and the seem to be UAT only. Some of their In -Out equipment would offer wifi connections for those that may fly with a tablet. But honestly, in the Pawnee there is not much room.

We are now within 5 yrs of the deadline. I can't see the FAA letting the mandate of 2020 slipping. It would be great to hear from other operators as to their installations.

BillT

[Darryl Ramm]

Bill T > wrote:
> Darryl, thanks for the information. It's a lot to digest.
>
> We are under the Class B, well within the 30nm veil. 3 of or 4 club
> gliders have Trig transponders. Many of our private owners are running trig or power flarm.
> Our concern is the ADSB out requirement for the tow plane. We have an old
> basic Mode C transponder, not a nice 1090ES capability, and no GPS
> recieve in the tow plane. I've been looking at some of the FreeFlight
> equipment for adsb out only, and the seem to be UAT only. Some of their
> In -Out equipment would offer wifi connections for those that may fly
> with a tablet. But honestly, in the Pawnee there is not much room.
>
> We are now within 5 yrs of the deadline. I can't see the FAA letting the
> mandate of 2020 slipping. It would be great to hear from other operators
> as to their installations.
>
> BillT

Bill, I empathize with the cost and hassle of all this. Yes don't bet
against the 2020 mandate happening.

Yes the low-cost FreeFlight systems are UAT-Out only, just not technology I
would want to see used around a glider fleet because of PowerFLARM 1090ES
compatibility.

I would just keep an eye on the market for Mode S transponders with 1090ES
out capability, and especially watch out for bundled transponder/GPS
systems that are likely to come out with built-in WAAS/IFR GPS that meets
the 2020 mandate requirements.

I know lots of towplanes with old large Mode C transponders that if a
upgraded to Mode S may just end up junking those transponders, some have
Becker Mode C transponders and they would still be great candidates for
transplanting to gliders. Andy's comments on antennas is relevant here too,
don't forget that different installations require additional antennas,
integration to a common altitude encoder, squawk control knobs/displays
etc. Some of the install costs may be non-trivial.

I don't know if your towplanes have PowerFLARM or not but I suspect any
ADS-B In system may just be too expensive and complex in a towplane and
won't integrate with PowerFLARM so can't be in the same display/will have
duplicate traffic reports etc.

As 2020 gets closer I also hope clubs and FBOs operating towplanes near
areas requiring ADS-B out (or wanting to add it anyhow) share what they are
doing.

[Andy Blackburn[_3_]]

Has anyone done a total cost of ownership analysis comparing UAT vs 1090ES for an aircraft with a Mode C transponder already installed? - including installation, antennae, and some allowance for the fact that the Mode C unit may need replacing anyway eventually. From a casual scan it seems like going 1090ES Out isn't any more expensive than UAT Out for the boxes alone (despite the fact that you are tossing the Mode C box when you go 1090ES). But with 1090EA you also save on cost and hassle of installation and maintenance of duplicate transmitters and, most important, don't get painted into a corner being incompatible with Flarm 1090ES In, since towplanes spend more time close to glider than any other aircraft type.

Andy (9B)

[Darryl Ramm]

Andy Blackburn > wrote:
> Has anyone done a total cost of ownership analysis comparing UAT vs
> 1090ES for an aircraft with a Mode C transponder already installed? -
> including installation, antennae, and some allowance for the fact that
> the Mode C unit may need replacing anyway eventually. From a casual scan
> it seems like going 1090ES Out isn't any more expensive than UAT Out for
> the boxes alone (despite the fact that you are tossing the Mode C box
> when you go 1090ES). But with 1090EA you also save on cost and hassle of
> installation and maintenance of duplicate transmitters and, most
> important, don't get painted into a corner being incompatible with Flarm
> 1090ES In, since towplanes spend more time close to glider than any other aircraft type.
>
> Andy (9B)

I would be surprised if any towplanes have ADS-B out installed because of
cost, or anybody who has bothered to get a serious installation quote. Who
wants to rush into this with rapid changing product availability? Right
now there are still very limited choices, especially for certified aircraft
(there are just not many ADS-B Out or suitable GPS boxes available, and any
337 approval requires use of previous STC approved GPS and ADS-B Out box
combination).

The only ADS-B related thing I would do with a towplane today is if
required to or wanting to install a Transponder I would make sure it can
support 1090ES Out as required for the 2020 Mandate. Like a Trig TT-22,
TT-33 or Garmin GTX-330. Otherwise it is just so early to want to install
this stuff. ... But certainly consider installing a PowerFLARM in a
towplane....

[Andy Blackburn[_3_]]

On Sunday, February 15, 2015 at 9:37:47 PM UTC-8, Darryl Ramm wrote:
>
> I would be surprised if any towplanes have ADS-B out installed because of
> cost, or anybody who has bothered to get a serious installation quote. Who
> wants to rush into this with rapid changing product availability? Right
> now there are still very limited choices, especially for certified aircraft
> (there are just not many ADS-B Out or suitable GPS boxes available, and any
> 337 approval requires use of previous STC approved GPS and ADS-B Out box
> combination).
>
> The only ADS-B related thing I would do with a towplane today is if
> required to or wanting to install a Transponder I would make sure it can
> support 1090ES Out as required for the 2020 Mandate. Like a Trig TT-22,
> TT-33 or Garmin GTX-330. Otherwise it is just so early to want to install
> this stuff. ... But certainly consider installing a PowerFLARM in a
> towplane....

Yes - absolutely no need to rush - especially for towplanes and particularly ones that are adequately equipped for their current flying environment. Things are evolving too rapidly in the ADS-B world and costs should come down.

[[email protected]]

The invisible hand of the market is already at work. Someone listed a FreeFlight 1201 GPS/WAAS source box on ebay for only $495 due to an avionics "upgrade." The market is moving faster than we think when someare already upgrading fron their current ADS-B solution. Normal price is about $3K. Someone should snap that up (I would but I'm in Canada so not required.)

http://www.ebay.com/itm/FREEFLIGHT-GPS-WAAS-1201-SENSOR-P-N-84100-02-0301-/301524540775?pt=Motors_Aviation_Parts_Gear&hash=item4634435d67&vxp=mtr

[Peter von Tresckow]

> wrote:
> The invisible hand of the market is already at work. Someone listed a
> FreeFlight 1201 GPS/WAAS source box on ebay for only $495 due to an
> avionics "upgrade." The market is moving faster than we think when
> someare already upgrading fron their current ADS-B solution. Normal price
> is about $3K. Someone should snap that up (I would but I'm in Canada so not required.)
>
> http://www.ebay.com/itm/FREEFLIGHT-GPS-WAAS-1201-SENSOR-P-N-84100-02-0301-/301524540775?pt=Motors_Aviation_Parts_Gear&hash=item4634435d67&vxp=mtr

Last year at Oshkosh I talked to a bunch of the avionics manufacturers with
existing ADS-B boxes. Just about all of them were working on various self
contained drop in boxes. I expect the price for one of these boxes to come
down in the near future.

Pete