ANPRM - removal of transponder exception for gliders

[[email protected]]

https://www.federalregister.gov/articles/2015/06/16/2015-14818/transponder-requirement-for-gliders

[son_of_flubber]

'Send comments on or before August 17, 2015.'

[Sarah[_2_]]

On Tuesday, June 16, 2015 at 8:54:47 AM UTC-5, wrote:
> https://www.federalregister.gov/articles/2015/06/16/2015-14818/transponder-requirement-for-gliders

Thanks for the alert. At least the FAA is soliciting input.

It also appears on a quick read that this implies requiring ADSB-out compliance for gliders with TABS...

What "TABS" TSO-C199 devices on the market currently? Google shows me recent announcements, but no price info. It appears these are "certificated" GPS data sources for a mode-S 1090es.

Expect another note for the "no electrical system" exemption for power aircraft?

[jfitch]

On Tuesday, June 16, 2015 at 6:54:47 AM UTC-7, wrote:
> https://www.federalregister.gov/articles/2015/06/16/2015-14818/transponder-requirement-for-gliders

Can someone briefly explain TABS? From some cursory reading it appears to be a low cost, low featured alternative to ADS-B, using tested but commercial grade GPS receivers. Does it use a different transmitter, or it is connected through your Mode S and use the digital transmission features already in place?

Many who have fitted Mode-S transponders already have the equipment and electrical load to transmit position and velocity data to the collision avoidance system. If Flarm would just certify their GPS as TSO-C199 compliant, then many of us would already have the equipment required. This would seem to be the easy way to make the most people happy. If TABS requires yet another device, GPS receiver, and antenna, I will be reluctant to install it.

[son_of_flubber]

FAA TABS briefing April 2015

http://www.icao.int/APAC/Meetings/2015%20ADSBSITF14/SP08b_FAA%20TABS%20briefing.pdf

[jfitch]

On Tuesday, June 16, 2015 at 9:21:27 AM UTC-7, son_of_flubber wrote:
> FAA TABS briefing April 2015
>
> http://www.icao.int/APAC/Meetings/2015%20ADSBSITF14/SP08b_FAA%20TABS%20briefing.pdf

"Brief" is right - doesn't say much at all. First couple of pages of Google results aren't much more enlightening.

[son_of_flubber]

On Tuesday, June 16, 2015 at 11:32:16 AM UTC-4, jfitch wrote:

> Many who have fitted Mode-S transponders already have the equipment and electrical load to transmit position and velocity data to the collision avoidance system. If Flarm would just certify their GPS as TSO-C199 compliant, then many of us would already have the equipment required.

Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?

Does PowerFlarm alert to TABS equipped aircraft?

[son_of_flubber]

On Tuesday, June 16, 2015 at 12:40:05 PM UTC-4, jfitch wrote:
> On Tuesday, June 16, 2015 at 9:21:27 AM UTC-7, son_of_flubber wrote:
> > FAA TABS briefing April 2015
> >
> > http://www.icao.int/APAC/Meetings/2015%20ADSBSITF14/SP08b_FAA%20TABS%20briefing.pdf
>
> "Brief" is right - doesn't say much at all.

Follow the link on the link.
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TSO-C199.pdf


On Tuesday, June 16, 2015 at 1:19:19 PM UTC-4, son_of_flubber wrote:

> Does PowerFlarm alert to TABS equipped aircraft?

From http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TSO-C199.pdf


"a. Functionality TABS equipment developed under this TSO are intended to make aircraft with an installed device visible to TAS, TCAS I, TCAS II and ADS-B IN equipped aircraft."

PowerFlarm has ADS-B In, so TABS equipped aircraft should(?) show up in PowerFlarm. And (possible wishful thinking) this would work outside the range of ADS-B ground station?

[Steve Leonard[_2_]]

> On Tuesday, June 16, 2015 at 11:32:16 AM UTC-4, jfitch wrote:
>
> > Many who have fitted Mode-S transponders already have the equipment and electrical load to transmit position and velocity data to the collision avoidance system. If Flarm would just certify their GPS as TSO-C199 compliant, then many of us would already have the equipment required.

Nope, Jfitch. You would not. TABS will transmit your position for a TCAS enabled plane to see. Flarm does not do that. Only way to do that now is with a transponder. Maybe in a couple of years (the TSO for TABS was just released in October of 2014), there will be a complete, TABS system available. But, it will have to cost a whole bunch less than a transponder to draw any real interest in adoption.

On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:

> Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
>

Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.

> Does PowerFlarm alert to TABS equipped aircraft?

No. PowerFlarm will not alert TABS equipped aircraft. PowerFlarm only "alerts" other Flarm devices as to your presence. TABS will be a "dumb" system, as it only talks. It does not listen. It will tell the heavies "Look out! Something is out here!" But it will not tell you "Look out! Something is trying to run over you!"

My read on this based on my current understandings.

Steve Leonard

[Steve Leonard[_2_]]

On Tuesday, June 16, 2015 at 12:39:06 PM UTC-5, son_of_flubber wrote:

> PowerFlarm has ADS-B In, so TABS equipped aircraft should(?) show up in PowerFlarm. And (possible wishful thinking) this would work outside the range of ADS-B ground station?

Sorry. Mis-read your initial question. It is possible that PowerFlarm might be alerted to a TABS equipped airplane. However, with the TSO just released in October, I would not expect to see a TABS solution inside of two years from now. And the guys at Flarm would be the ones that can give the final answer.

Steve Leonard

[son_of_flubber]

On Tuesday, June 16, 2015 at 1:44:47 PM UTC-4, Steve Leonard wrote:

> On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
>
> > Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
> >
>
> Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
>

My limited understanding... Due to the 130 watt output, the TT21 is not 2020 compliant, so even if I invested in a TSO'd GPS source, I could not use the TT21's ADS-B out capability. The 250 watt 2020 requirement is based on the closing speed of two aircraft and since a glider is slow (or stationary in wave) I'd conjecture that it was not needed. ADS-B out at 130 watts is much better than no ADS-B out.

From Trig website:

What are the differences between the TT21 and TT22?
Both models have the same physical dimensions and advantages of size and ease of installation. The TT21 is a 130 watt Class 2 transponder; this makes it ideal for light sports and regular GA use. The TT22 is a 250 watt Class 1 transponder, ideally suited to higher performance and/or high altitude performance types.
In the U.S. the FAA has stated that Class 1 transponders must be used to be '2020 complaint' For U.S. customers Trig recommends the TT22 unit for this reason.

[jfitch]

On Tuesday, June 16, 2015 at 10:44:47 AM UTC-7, Steve Leonard wrote:
> > On Tuesday, June 16, 2015 at 11:32:16 AM UTC-4, jfitch wrote:
> >
> > > Many who have fitted Mode-S transponders already have the equipment and electrical load to transmit position and velocity data to the collision avoidance system. If Flarm would just certify their GPS as TSO-C199 compliant, then many of us would already have the equipment required.
>
> Nope, Jfitch. You would not. TABS will transmit your position for a TCAS enabled plane to see. Flarm does not do that. Only way to do that now is with a transponder. Maybe in a couple of years (the TSO for TABS was just released in October of 2014), there will be a complete, TABS system available. But, it will have to cost a whole bunch less than a transponder to draw any real interest in adoption.
>
> On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
>
> > Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
> >
>
> Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
>
> > Does PowerFlarm alert to TABS equipped aircraft?
>
> No. PowerFlarm will not alert TABS equipped aircraft. PowerFlarm only "alerts" other Flarm devices as to your presence. TABS will be a "dumb" system, as it only talks. It does not listen. It will tell the heavies "Look out! Something is out here!" But it will not tell you "Look out! Something is trying to run over you!"
>
> My read on this based on my current understandings.
>
> Steve Leonard

I was not suggesting that the Flarm alone would alert TABS equipped aircraft, but the GPS already installed in the Flarm could be used as a GPS source for your already installed Mode S transponder, all that is then required is a cable.

The best solution for both gliders and light power is exactly this - using the installed Mode S capability as a transmitter and cheap GPS for not as capable - but still perfectly adequate for collision avoidance - substitute for ADS-B out.

[jfitch]

On Tuesday, June 16, 2015 at 11:04:56 AM UTC-7, son_of_flubber wrote:
> On Tuesday, June 16, 2015 at 1:44:47 PM UTC-4, Steve Leonard wrote:
>
> > On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
> >
> > > Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
> > >
> >
> > Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
> >
>
> My limited understanding... Due to the 130 watt output, the TT21 is not 2020 compliant, so even if I invested in a TSO'd GPS source, I could not use the TT21's ADS-B out capability. The 250 watt 2020 requirement is based on the closing speed of two aircraft and since a glider is slow (or stationary in wave) I'd conjecture that it was not needed. ADS-B out at 130 watts is much better than no ADS-B out.
>
> From Trig website:
>
> What are the differences between the TT21 and TT22?
> Both models have the same physical dimensions and advantages of size and ease of installation. The TT21 is a 130 watt Class 2 transponder; this makes it ideal for light sports and regular GA use. The TT22 is a 250 watt Class 1 transponder, ideally suited to higher performance and/or high altitude performance types.
> In the U.S. the FAA has stated that Class 1 transponders must be used to be '2020 complaint' For U.S. customers Trig recommends the TT22 unit for this reason.

A very cursory reading of TSO-C199 suggests that a TT21 would work for this, probably needing a firmware update. The transmit power required appears to be 70 watts.

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?).

[Steve Leonard[_2_]]

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

[[email protected]]

On Tuesday, June 16, 2015 at 2:32:53 PM UTC-4, jfitch wrote:
> On Tuesday, June 16, 2015 at 11:04:56 AM UTC-7, son_of_flubber wrote:
> > On Tuesday, June 16, 2015 at 1:44:47 PM UTC-4, Steve Leonard wrote:
> >
> > > On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
> > >
> > > > Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
> > > >
> > >
> > > Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
> > >
> >
> > My limited understanding... Due to the 130 watt output, the TT21 is not 2020 compliant, so even if I invested in a TSO'd GPS source, I could not use the TT21's ADS-B out capability. The 250 watt 2020 requirement is based on the closing speed of two aircraft and since a glider is slow (or stationary in wave) I'd conjecture that it was not needed. ADS-B out at 130 watts is much better than no ADS-B out.
> >
> > From Trig website:
> >
> > What are the differences between the TT21 and TT22?
> > Both models have the same physical dimensions and advantages of size and ease of installation. The TT21 is a 130 watt Class 2 transponder; this makes it ideal for light sports and regular GA use. The TT22 is a 250 watt Class 1 transponder, ideally suited to higher performance and/or high altitude performance types.
> > In the U.S. the FAA has stated that Class 1 transponders must be used to be '2020 complaint' For U.S. customers Trig recommends the TT22 unit for this reason.
>
> A very cursory reading of TSO-C199 suggests that a TT21 would work for this, probably needing a firmware update. The transmit power required appears to be 70 watts.
>
> 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?).

What do people see for transponder install costs? There seems to be quite
a few already installed out there, but I haven't heard what it takes
beyond what the units cost.

Matt

[son_of_flubber]

> What do people see for transponder install costs? There seems to be quite
> a few already installed out there, but I haven't heard what it takes
> beyond what the units cost.
>
> Matt

Having just spent a good soaring day driving to the airport, trailering the glider to the avionics shop appointment, then back to the home airport, then driving back home from the home airport, I'd note that Avionic's technician's availability, capacity, and willingness to work on gliders is a hidden cost. The fee quoted for biennial transponder certification by two shops was $50 and $125.

The previous owner who installed my Trig trailered four hours one way to a tech who was willing to install it.

[George Haeh]

In a glass glider, you can mount a
transponder internal antenna in the nose
cone, and trailer it to a power A&P who
can certify it for $90 or so.

Carbon requires either an external
antenna and ground plane (maybe upper
and lower) or routing coax to the fin while
making very sure it won't in any way
interfere with the elevator pushrod.

Maintaining power is a big problem as
you can't just slap a solar panel on a
turtledeck without treating the underlying
area to maintain structural integrity with
the higher temperatures.

Many gliders now run Flarm which does a
really good job of spotting ADS-B traffic
from way far away without eating up
power. Flarm gives pilots the information
to get out of the way of any ADS-B emitter
and should be acceptable as a minimal
means of compliance.

If the authorities allow us to use Flarm as
a position source to a Trig, we would be
visible to ATC and ADS-B receivers.

[Bill T]

We just paid on average, $150 per aircraft for an avionics tech to come to use with his portable equipment and complete the two year check on 4 gliders and a tow plane. $125/aircraft plus shared travel expenses.

From what I can find on TABS, it can be about the size on a Nano GPS reciever, self contained battery operated, but no details about transmitter antenna requirements. TABS is designed for gliders, free balloons, hang gliders and parachute, para gliders. So it could be about the size of a SPOT and carried by the pilot, not the aircraft.

At a reasonable cost, it's a lot better than being grounded. How much did you pay for your SPOT and Nano?
BillT

[Dan Marotta]

I installed my TT-22 myself so cost was limited to coaxial cable a TNC
for the transponder and a BNC for the antenna plus the cost of the
antenna. Then I paid an avionics shop to test the installation. I
don't recall what that cost. BTW, my LAK-17a is EXPERIMENTAL.

On 6/16/2015 1:05 PM, wrote:
> On Tuesday, June 16, 2015 at 2:32:53 PM UTC-4, jfitch wrote:
>> On Tuesday, June 16, 2015 at 11:04:56 AM UTC-7, son_of_flubber wrote:
>>> On Tuesday, June 16, 2015 at 1:44:47 PM UTC-4, Steve Leonard wrote:
>>>
>>>> On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
>>>>
>>>>> Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
>>>>>
>>>> Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
>>>>
>>> My limited understanding... Due to the 130 watt output, the TT21 is not 2020 compliant, so even if I invested in a TSO'd GPS source, I could not use the TT21's ADS-B out capability. The 250 watt 2020 requirement is based on the closing speed of two aircraft and since a glider is slow (or stationary in wave) I'd conjecture that it was not needed. ADS-B out at 130 watts is much better than no ADS-B out.
>>>
>>> From Trig website:
>>>
>>> What are the differences between the TT21 and TT22?
>>> Both models have the same physical dimensions and advantages of size and ease of installation. The TT21 is a 130 watt Class 2 transponder; this makes it ideal for light sports and regular GA use. The TT22 is a 250 watt Class 1 transponder, ideally suited to higher performance and/or high altitude performance types.
>>> In the U.S. the FAA has stated that Class 1 transponders must be used to be '2020 complaint' For U.S. customers Trig recommends the TT22 unit for this reason.
>> A very cursory reading of TSO-C199 suggests that a TT21 would work for this, probably needing a firmware update. The transmit power required appears to be 70 watts.
>>
>> 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?).
> What do people see for transponder install costs? There seems to be quite
> a few already installed out there, but I haven't heard what it takes
> beyond what the units cost.
>
> Matt

--
Dan Marotta

[[email protected]]

On Tuesday, June 16, 2015 at 8:31:58 PM UTC-5, Dan Marotta wrote:
> I installed my TT-22 myself so cost was limited to coaxial cable a
> TNC for the transponder and a BNC for the antenna plus the cost of
> the antenna.* Then I paid an avionics shop to test the
> installation.* I don't recall what that cost.* BTW, my LAK-17a is
> EXPERIMENTAL.
>
>
>
>
> On 6/16/2015 1:05 PM,
> wrote:
>
>
>
> On Tuesday, June 16, 2015 at 2:32:53 PM UTC-4, jfitch wrote:
>
>
> On Tuesday, June 16, 2015 at 11:04:56 AM UTC-7, son_of_flubber wrote:
>
>
> On Tuesday, June 16, 2015 at 1:44:47 PM UTC-4, Steve Leonard wrote:
>
>
>
> On Tuesday, June 16, 2015 at 12:19:19 PM UTC-5, son_of_flubber wrote:
>
>
>
> Is it reasonable to argue that a Trig TT21 (130 watt) should be acceptable for glider use due to my lower speed, rather than just the TT22 (250 watt)? Is there any chance that the FAA would grandfather in TT21s in any new regulations?
>
>
>
> Son, your transponder (TT21) is already acceptable. No need to "grandfather" it.
>
>
>
> My limited understanding... Due to the 130 watt output, the TT21 is not 2020 compliant, so even if I invested in a TSO'd GPS source, I could not use the TT21's ADS-B out capability. The 250 watt 2020 requirement is based on the closing speed of two aircraft and since a glider is slow (or stationary in wave) I'd conjecture that it was not needed. ADS-B out at 130 watts is much better than no ADS-B out.
>
> From Trig website:
>
> What are the differences between the TT21 and TT22?
> Both models have the same physical dimensions and advantages of size and ease of installation. The TT21 is a 130 watt Class 2 transponder; this makes it ideal for light sports and regular GA use. The TT22 is a 250 watt Class 1 transponder, ideally suited to higher performance and/or high altitude performance types.
> In the U.S. the FAA has stated that Class 1 transponders must be used to be '2020 complaint' For U.S. customers Trig recommends the TT22 unit for this reason.
>
>
> A very cursory reading of TSO-C199 suggests that a TT21 would work for this, probably needing a firmware update. The transmit power required appears to be 70 watts.
>
> 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?).
>
>
> What do people see for transponder install costs? There seems to be quite
> a few already installed out there, but I haven't heard what it takes
> beyond what the units cost.
>
> Matt
>
>
>
>
>
> --
>
> Dan Marotta

Same as Dan, installed the Microair many years ago myself in my Experimental glider. VFR only transponder check runs $100 in our Chicago area club, an avionics shop does all club gliders and tow ships as well as on average 10 private gliders, no fuss.

[jfitch]

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.

[Steve Leonard[_2_]]

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

[Jamie Shore]

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

[Dan Marotta]

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

[son_of_flubber]

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.

[jfitch]

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

[Steve Leonard[_2_]]

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)

[son_of_flubber]

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.

[jfitch]

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.

[[email protected]]

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