SSA responds to ANPRM

[David Kinsell[_2_]]

No one has commented yet on the SSA response? Likely to be the biggest
impact to soaring in the U.S. in many many years. On the SSA site if you
haven't seen it yet. Maybe pilots flying out of lower states just don't
worry about it.

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

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

-Dave

[Ron Gleason]

On Tuesday, 11 August 2015 12:03:08 UTC-6, David Kinsell wrote:
> No one has commented yet on the SSA response? Likely to be the biggest
> impact to soaring in the U.S. in many many years. On the SSA site if you
> haven't seen it yet. Maybe pilots flying out of lower states just don't
> worry about it.
>
> I was very happy to see it posted a week before the deadline to give
> people a chance to read it before submitting their own response. Gave
> some background info on the Reno crash that I hadn't heard before, about
> rerouting big iron arrivals through the wave area, and the NTSB
> investigator believing that was a contributing factor.
>
> The comments about relying on PowerFlarm are not likely to be persuasive
> to the FAA, they undoubtedly are well aware of it, and probably perceive
> it as being an offshoot system with only minimal compatibility with the
> nextgen system they're putting in place. There's more than a grain of
> truth to that, although ADS-B is so poorly done it leaves the door open
> to alternatives.
>
> -Dave

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

[[email protected]]

I personally disagree with the SSA response. I have responded directly to the FAA.

I think all gliders should have transponders all the time. Whether we like it or not, we must coexist with the rest of the aviation traffic in the airspace we share. You read that correctly, share, we do not own the airspace we fly in. If we have another collision between a glider and a substantial powered aircraft we are going to wish all we had to deal with was a low level FAA rule making decision. Transponders are a very important part of this coexistence. They are not particularly expensive and modern implementations are power efficient.

FLARM is a very narrow minded slice of that coexistence. It warns us of other gliders and transponder equipped aircraft, but does not reciprocate by broadcasting your own location to other airplanes. It is very low power with no installation standards and thus of dubious range and certainty, especially for fast movers. There is absolutely no way FLARM will ever be approved by the FAA as a substitute for a transponder.

We have an approved traffic system in the USA and most of the rest of the world, it is called ADS-B. For all of its faults, it is interoperable between all types of aircraft in nearly every part of the world. They say that possession is 9/10ths of the law. If the sky was clouded with gliders squawking 1202 on mode S/ES ADS-B we would have a much better chance of getting the ATC's attention. Right now they barely realize we are here.

[Sean Fidler]

I basically agree with Mark.

That said, I do t have a transponder yet. I think it's time, and certainly by 2020 it will be time.

Let's hope they get the price down and quality up as much as possible.

[Sierra Whiskey]

FWIW:

1) Transponders will give a false sense of security and teach vigilant glider pilots to trust that ATC is keeping tabs on their location for traffic deconfliction. This will result in less situational awareness for some pilots. (It is inevitable)

2) Transponders do nothing to separate gliders from VFR traffic squaking VFR and tracking in or out of an uncontrolled airfield. Not everyone is talking to ATC or getting flight following. And despite popular opinion, not everyone has an onboard collision avoidance system. (At least everything at my flight school lacks this capability)

3) If an immediate requirement for Transponders in gliders with electrical systems is imposed all gliders without a transponder will be out $2000 now, and another $2000-$5000 in 5 years when they have to upgrade to ADS-B. Why not wait till 2020? (Can't put a price on safety, but the FAA sure can harm a sport and form of flight training by imposing expensive requirements. The pilot shortage is near!!!)

4) In relation to my first point, the Flarm unit is far superior in my mind because it improves a pilots situational awareness and allows the glider pilot the chance to see and avoid. Let's not kid ourselves, glider pilots are looking out the window a hell of a lot more than a Bonanza flying VFR for that $100 hamburger. I would rather know where they are than have them run into me and my shiney new transponder.

5) If I have a battery failure in flight under a transponder requirement, do I need to land immediately in the nearest farm field? It is more likely that a glider will run out of sufficient battery power than an aircraft with an engine driven electrical system. Once the batteries run out of power the glider is now back to the same situation it was prior to the requirement. Waiting for ADS-B has some benefit here as the smaller units being developed for UAS are quite energy efficient.

I realize Flarm cannot be the solution. But I do think encouraging the use of a device that adds situational awareness is far more effective than trusting that a ground based radar and ATC operator are going to have communications with the traffic.

[JS]

Maybe you own the STC for SGS 2-33 electrical systems and you're going to make the STC available gratis?
Jim

On Tuesday, August 11, 2015 at 8:28:57 PM UTC-7, wrote:
> I think all gliders should have transponders all the time.

[Sean Fidler]

I fully agree transponders leave much to be desired per the arguement for upgrading to ADSB.

One thing that irritates me a bit is the idea that FAA (and associated political talking heads) are currently trying their best to force me to put N numbers on my "toy" quadcopter's and outfit them with ADSB. Utterly ridiculous idea, right ;-) ? Hmmmm? Be careful what you ask for folks.

With that, I don't feel much like complaining about being asked to outfit my modern sailplane with ANY or some 2 way traffic avoidance equipment. In my glider (rural Michigan), I do regularly fly along the edge of two class C airspace (Lansing and Grand Rapids) and one B airspace (Detroit). I truly enjoy watching the commercial traffic flying all around me on FLARM during these moments. It is something fun to do since most pilots in MI wont buy a FLARM (either).

Perhaps I did not read the article very well. I thought the discussion was regarding a "potential" ADSB requirement for 2020, NOT a mandatory transponders now, then ADSB in 2020. Ill go back and re-read. I agree that would be a bit more harsh, agreed. Most of the glider community would $hi# a chicken, agreed. No surprise there.

On the other hand (see hobby drone regulations), I don't think the FAA is in the mood to mess around any longer. They want a complete air traffic control system and far less risk. They are covering their collective butts and of course...that costs us money. Remember, the government has no money. In fact they have -19 trillion and counting.

I would blame CNN and NPR to be honest. This is a favorite theme of theirs.. They have 1-3 stories per week about how drones almost "brought down" an airliner. Unfortunately they are not fabrications. Gliders (and the rest) are just getting scooped up in that reform blizzard. Its way to late to separate gliders from the movement.

Just last week onCNN (Aug 5, 2015) - http://www.cnn.com/2015/08/01/us/drone-airliner-jfk/

Good times, good times!

Sean
7T

On Tuesday, August 11, 2015 at 11:57:05 PM UTC-4, Sierra Whiskey wrote:
> FWIW:
>
> 1) Transponders will give a false sense of security and teach vigilant glider pilots to trust that ATC is keeping tabs on their location for traffic deconfliction. This will result in less situational awareness for some pilots. (It is inevitable)
>
> 2) Transponders do nothing to separate gliders from VFR traffic squaking VFR and tracking in or out of an uncontrolled airfield. Not everyone is talking to ATC or getting flight following. And despite popular opinion, not everyone has an onboard collision avoidance system. (At least everything at my flight school lacks this capability)
>
> 3) If an immediate requirement for Transponders in gliders with electrical systems is imposed all gliders without a transponder will be out $2000 now, and another $2000-$5000 in 5 years when they have to upgrade to ADS-B. Why not wait till 2020? (Can't put a price on safety, but the FAA sure can harm a sport and form of flight training by imposing expensive requirements. The pilot shortage is near!!!)
>
> 4) In relation to my first point, the Flarm unit is far superior in my mind because it improves a pilots situational awareness and allows the glider pilot the chance to see and avoid. Let's not kid ourselves, glider pilots are looking out the window a hell of a lot more than a Bonanza flying VFR for that $100 hamburger. I would rather know where they are than have them run into me and my shiney new transponder.
>
> 5) If I have a battery failure in flight under a transponder requirement, do I need to land immediately in the nearest farm field? It is more likely that a glider will run out of sufficient battery power than an aircraft with an engine driven electrical system. Once the batteries run out of power the glider is now back to the same situation it was prior to the requirement. Waiting for ADS-B has some benefit here as the smaller units being developed for UAS are quite energy efficient.
>
> I realize Flarm cannot be the solution. But I do think encouraging the use of a device that adds situational awareness is far more effective than trusting that a ground based radar and ATC operator are going to have communications with the traffic.

[[email protected]]

I am in the "we should all have transponder" group.
We share the airspace and need to participate fully.
All the arguments about power consumption and battery capability are null.
Gliders should have transponders first and FLARM in addition if wanted.
No system is perfect.
Change is always being promised.
But transponders are the here and now.
I have both. When I fly around Reno it is comforting to hear approach control and the commercial aircraft reporting that they "see" me on their systems.
The largest flaw I see and experience with FLARM is the inconsistency of installation and performance. It is far from a comfortingly stable and predictable safety system. All the chat streams on this forum verify this point.

[Tango Eight]

On Tuesday, August 11, 2015 at 11:28:57 PM UTC-4, wrote:
> I personally disagree with the SSA response. I have responded directly to the FAA.
>
> I think all gliders should have transponders all the time.

We look forward to your five figure donation to our club to equip about 20 gliders (and our tow plane) with transponders that might be interrogated (optimistically) 10% of their flight time.

Yours is a crappy broad brush solution to a problem some do not have at this particular point in time.

Evan Ludeman, Post Mills Soaring Club, Post Mills, VT

[Soartech]

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

[Brian[_1_]]

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

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

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

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

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

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

Brian

[son_of_flubber]

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

[George Haeh]

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

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

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

[Darryl Ramm]

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

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

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

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

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

[Darryl Ramm]

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

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

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

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

If you have a *suitable* Mode S transponder.

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

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

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

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

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

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

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

>
> of course it is possible that the FAA may just modify the exceptions and allow only a transponder or 150W transponders or currently non-approved ADS-B out sources, or some other modification.
>
> The FAA currently says it is ok to install non-Approved GPS source for ADS-B out in experimental aircraft, but is unclear if this will be acceptable to use above 10,000 feet or not (seems like probably not)

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

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

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


>
> Brian

[WaltWX[_2_]]

I believe that the SSA has taken the correct position on the ANPRM. The cost benefit to equip cannot justify the benefit of avoiding mid air collisions with gliders AT THIS TIME. My comment to the SSA was this:

"If the FAA cannot assure collision avoidance, via positive ATC, for all aircraft that are equipped with a transponder or ADS-B then the safety benefit, if any, of mandating use of the technology is marginal and the cost to the gliding community of implementing this change is not justified."

However, my personal opinion is that at some point, gliders, UAVs, and all other aircraft will have to equip ( ground to infinity) to provide some kind of "Electronic VFR" for separation and collision advisories or avoidance. Right now there is just too much uncertainty with a chaos of operational and proposed systems(Mode A, Mode S, ADS-B, TABs, etc). Google and the UAV community are working on low power/cost transponder that may do the job. I feel that all pilots should take some responsibility for replacing eyeballs with some kind of electronic advisory/resolution. That inexpensive technology is not there yet for most aviation (except for glider to glider with FLARM).

So... the best strategy is to wait for things to evolve before the 2020 mandate. It looks like incorporating UAV into the NAS system will be the driver for low cost transponders that may be appropriate for gliders.

Walt Rogers WX

[son_of_flubber]

On Wednesday, August 12, 2015 at 5:32:05 PM UTC-4, Darryl Ramm wrote:
> On Wednesday, August 12, 2015 at 1:21:42 PM UTC-7, son_of_flubber wrote:
> > When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?
>
> You likely need to define what you mean by "high-performance", it is probably not what I mean by high-performance (light-jet up to airliners).

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

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

[Darryl Ramm]

On Wednesday, August 12, 2015 at 5:10:21 PM UTC-7, son_of_flubber wrote:
> On Wednesday, August 12, 2015 at 5:32:05 PM UTC-4, Darryl Ramm wrote:
> > On Wednesday, August 12, 2015 at 1:21:42 PM UTC-7, son_of_flubber wrote:
> > > When gliders are required to install Mode-S transponders, will high performance aircraft be required to install TCAS?
> >
> > You likely need to define what you mean by "high-performance", it is probably not what I mean by high-performance (light-jet up to airliners).
>
> A high performance aircraft (according to 61.31) is an aircraft with an engine of more than 200 horsepower. I'm mostly concerned with those that fly too fast for practical 'see and avoid' and with pilots who are not aware of gliders.
>
> I get occasional benefit from my Trig TT-21. If more high performance planes had TCAS, I'd get more benefit.

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

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

[Squeaky]

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

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

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

[D M[_2_]]

I also caution, any glider owner/operator that is considering FLARM Only,
that if
the FAA changes the FAR part 91.113 (Right of Way Rules) from the words
"See
and Avoid" to the words "Sense and Avoid" you will probably need to add a
transponder with ADSB anyway. If your in the market to getting something
new, I would strongly consider a transponder that meets the 2020 compliance

language over just FLARM. Just trying to save you some money. The changes
are coming. D

[David Kinsell[_2_]]

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

> On Tuesday, 11 August 2015 12:03:08 UTC-6, David Kinsell wrote:
>> No one has commented yet on the SSA response? Likely to be the biggest
>> impact to soaring in the U.S. in many many years. On the SSA site if
>> you haven't seen it yet. Maybe pilots flying out of lower states just
>> don't worry about it.
>>
>> I was very happy to see it posted a week before the deadline to give
>> people a chance to read it before submitting their own response. Gave
>> some background info on the Reno crash that I hadn't heard before,
>> about rerouting big iron arrivals through the wave area, and the NTSB
>> investigator believing that was a contributing factor.
>>
>> The comments about relying on PowerFlarm are not likely to be
>> persuasive to the FAA, they undoubtedly are well aware of it, and
>> probably perceive it as being an offshoot system with only minimal
>> compatibility with the nextgen system they're putting in place.
>> There's more than a grain of truth to that, although ADS-B is so poorly
>> done it leaves the door open to alternatives.
>>
>> -Dave
>
> Thanks for the heads up. Interesting read and I am glad the SSA put the
> effort into this response. I do not agree with all the facts and
> opinions but since I did not send in a response to the SSA or FAA (yet)
> I am happy to live with the results


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

http://tinyurl.com/qb4gmao

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

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

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

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

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

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

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

http://tinyurl.com/pxlk2xd

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

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

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

-Dave

[Benedict Smith]

So is sight not counted as a sense now? Would they prefer you to touch or
smell it?

At 22:05 13 August 2015, D M wrote:
>I also caution, any glider owner/operator that is considering FLARM Only
>that if
>the FAA changes the FAR part 91.113 (Right of Way Rules) from the word
>"See
>and Avoid" to the words "Sense and Avoid" you will probably need to add a

>transponder with ADSB anyway. If your in the market to getting something
>new, I would strongly consider a transponder that meets the 2020
complianc
>
>language over just FLARM. Just trying to save you some money. The
changes
>are coming. D
>
>

[[email protected]]

Sight seems to be a sensation that is decreasing in acuity. At least, it has more competition from in cockpit PDAs, electronic varios, electronic maps, and FLARM displays. I have shared thermals with pilots who have made more than one circle with their eyes and fingers down on the panel, NOT outside the cockpit. I have had several close encounters with other gliders where the pilots face and eyes are involved with the electronics, NOT outside. I had a pilot who was new to the area tell me with great enthusiasm how he had programmed his two handheld Garmin GPS units to use while flying for his gold badge and use that information along with several pages of finely printed numbers to help him make go/no-go decisions. I flew beside him on the same ridge for several miles and he never looked outside his cockpit once.
We do need passive systems that are always on.

[[email protected]]

With apologies to ASA members who have already seen this I thought I would post my reply to the ANPRM which is based on a lot of conversations and reading and may be helpful to any one wanting to submit a response.

Response to the FAA ANPRM on Transponder Requirement for gliders and TSO-C199

This is my personal view on the ANPRM and while I have tried to get all the facts correct, not even the FAA can answer everything completely or correctly. The more you review the subject the more complicated it gets. I apologize for any errors. My views are, in part, different from those of SSA who essentially want nothing changed and I believe this is unrealistic and I personally want to be as safe as practical.
The deadline for submitting testimony is this coming Monday August 17 and I urge everyone to send in comments. Numbers count. Feel free to use any, all, or none of the material below. Note that while I will be including answers to the ANPRM's specific questions I have not included them here as it would not make much sense without restating the questions but these are on the URL below. If you would like my answers I'll be happy to send them to you.
http://www.gpo.gov/fdsys/pkg/FR-2015-06-16/html/2015-14818.htm
The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.
Adding Power FLARM is of course a couple of thousand more.
Below my summary to the ANPRM with questions I am asking and the FAA has requested be included. Feel free to contact me if you want to discuss further but time is short.
We do not know what process the FAA will use after August 17
This is the link to file your submission
https://www.federalregister.gov/articles/2015/06/16/2015-14818/transponder-requirement-for-gliders

Thanks to Jim Herd, Eric Greenwell, Tom Seim, David Kinsell, Russ Owens for their inputs but all the comments are mine
John Hodgson
CFIMEL, CFII, CFIG
DG808C Minden
/////////////////////

Summary
1 The Minden incident reports point to the lack of an operating transponder in the glider but we should also note that Norcal ATC was routing a jet through airspace known to be frequented by gliders who were not required to have transponders. Local dialog between the glider community and ATC to establish procedures could have avoided the collision in the first place. Simply restricting descending high speed traffic to above 18,000 feet till west of the Pine Nut mountain range would have avoided the situation.
Two weeks after the Minden incident flying a King Air C90 I was routed over the exact same spot by Norcal. I declined the clearance instead requesting the Minden GPS Bravo approach and when cleared to CTAF frequency also monitored the glider frequency of 123.3.
2 Gliders, including those with self launch capability where the engine is only operating for maybe 10 minutes, have limited on board power resources that must be conserved for use throughout the flight including transponder use at the end of the flight that may be in high activity airspace and deploying and starting the engine at any time up to the point of touch down.
3 All airspace does not produce the same risks and while I fully agree that transponders should be required in certain high activity areas they do little but use power when squawking in areas that experience only light traffic such as the western deserts.
4 Glider flights can last to 10 hours or more putting great pressure on the conservation of power in flight and also recharging batteries over night for the next day.
5 The problem would be greatly simplified if use of transponder/TABS was required in certain high risk areas but remained voluntary outside of those areas. No glider pilot wants to be involved in a mid air collision.
6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.
7 Popular high activity glider routes can and should be identified and marked on sectional charts as are military routes. Pilots of power planes could be provided training by local CFIs on where gliders operate to increase their vigilance e.g. mountain ranges and cloud streets.
8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.
9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.
http://www.avweb.com/blogs/insider/AEA-Google-to-the-Rescue-on-ADS-B-223824-1.html
http://www.airspacemag.com/daily-planet/googles-future-air-force-180956113/?no-ist

////////////////////////////////////
Answers responding to the ANPRM specific questions not posted here

///////////////////////////////////
I would like to ask the following questions and request answers with the findings of the ANPRM ......

1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?
Have flights filed on the glider on line contest web site been reviewed to see how they operate in the US air space?
http://www.onlinecontest.org/olc-2.0/gliding/index.html?c=C0&sc=&st=olc
2 What cost does the FAA think it will take to install ADS-B in a glider when a TABS product is available? Using an estimated $6000 to comply that is as much as half the cost of many gliders flying today
3 What calculations have been made to consider the power requirements needed to support TABS on extended 10 hour day back to back flights?
4 Has the national airspace have been reviewed to determine high and low risk areas of glider to airplane mid air near misses and collisions?
5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?
6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?
7 Will tow planes require TABS or full ADS-B compliance?
8 Has the marking of high activity glider routes on sectionals been considered?
9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?
10 What will be the impact of TABS on glider cross county flights in Canadian and Mexican airspace but not landing outside the USA?
11 Does one, fortunately non fatal, mid air collision in a decade that could have easily been avoided justify the huge cost of mandating TABS on the US glider fleet, plus balloons and airplanes without electrical systems?
12 Will a representative be appointed to liase and communicate with the soaring community on an ongoing basis? And not just through SSA but a representative group throughout the country.

References:-
Federal register June 16, 2015
http://www.gpo.gov/fdsys/pkg/FR-2015-06-16/html/2015-14818.htm

TSO-C199 October 10, 2014
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TSO-C199.pdf

FAA presentation, D Walker, TSO-C199 TABS
http://www.icao.int/APAC/Meetings/2015%20ADSBSITF14/SP08b_FAA%20TABS%20briefing.pdf

TRiG data sheets, TT21, TN70
Google ADS-B for drones (links above)

Thank you, John Hodgson

[Bill T]

John, tow planes operating within a mode C veil or above 10,000 MSL are required to have ADS-B Out by 2020.

BillT

[danlj]

A few years ago an FAA study reviewing midair stated that more that half occurred
- on weekends
- in VMC
- at traffic-pattern altitude
- on weekends.
See and avoid does not work well because each pilot really can't see very much of the sky - sharp vision is about 1% of the sphere, most of the sky is eclipsed by glider, pax, & hat, & the aircraft on a collision course in stationary in our visual field.

The drone revolution is just beginning.

We do need electronic augmentation for the task. The FAA is taking on responsibility for the conversation, a good thing.

We have a legacy system in ADS-B, with dated technology, but abandoning this for Flarm-like technology is fraught.

I think comments to the FAA are best that propose feasible ways to augment collision avoidance where collisions are most likely & where they are most costly.

[Darryl Ramm]

John

Lots of great points here, some rambling comments on a few techncial things or things I could not follow...

On Friday, August 14, 2015 at 5:01:53 PM UTC-7, wrote:

> The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.

$6000 costs seem high. If I had to guesstimate an _upper_ cost for a TABS device in the near future, I'd expect something like a Trig TT-21 + $1,000 for a GPS source. That is based on triangulating costs for products like the new non-TSO $850 Garmin GPS 20A.. since it meets the full ADS-B our performance requirements having it pass the TABS approval tests should be relatively easy. And no I'm not implying that cost to be affordable or is justified for many glider pilots, just pointing out what I expect a high cost would be.

However that assumes sensible install regulations (anything close to the ADS-B Out STC mess that happened early on woudl be a disaster) and collaboration between vendors of Class A and B TABS devices.... and in general I expect dedicated TABS devices to just include a suitable GPS source. NexNav has announced their "low-cost" TABS Class B Micro-i GPS source. No real clarity on what they mean by low-cost, and I expect they will really sell to OEMs..


> 6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.

I doubt anybody who is not a glider pilot will understand what an energy line are. Their loss :-)

Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA do. At one time there was talk of sales of models without 1090S In in the USA, I'm not sure if any sales actually happened (it's a very bad idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).


> 8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.

There are no TABS Class A devices on the market today, and no manufacturer TSO approved. A Trig TT-21 might be a possible to use as a TABS device since the TABS TSO spec is (a good thing) designed to allow existing Mode S transponders to potentially be backed into use as TABS device. There is certainly *potential* for TABS devices to be say smaller/lighter than say even the current Trig packaged Transponder (which are *great* transponders), e.g. look at what Sagetech does today for Mode S UAV transponders.... http://www..sagetechcorp.com/unmanned-solutions/

Any actual TABS carriage and installation regulation for use in gliders would clearly need to allow that TABS device use above 15,000. The folks who developed the TABS standard understand that. The 15,000' limit in a Class 2 Transponder is not directly relevant in any technical sense here... Installation and carriage regulations or TABS devices needs to be developed, what that looks like if any, is important but it will need to be clearly separated from current transponder regulations...


> 9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.

I expect the FAA would argue that is what TABS is intended to achieve, and lots of folks, including suppliers to the UAV/drone industry, had input into that TSO's development.


> 1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?

TABS/TSO-C199 is a technical product standard. The FAA or RTCA standards just are not going to deal with things like physical size or cost, and that is a good thing, let the market work on that. The FAA can hand wave (largely correctly) that TSO-C100 targets costs by say allowing use of consumer GPS chipset technology (by the avionics manufacture, not owners/pilots connecting random consumer GPS devices), and leveraging exiting Mode S technology/Mode S manufacturer capability. And while all that is a big step for the FAA, TABS devices are still complex and are still likely to be relatively expensive until they reach some significant volume, and that won't even start to happen until there are carriage/install regulations. For better or worse I expect many players here want to make the glider community the test case.. But ultimately volume is going to need something like UAV use... not that I am excited about having larger UAVs flying around putting manned aircraft at risk.

There should not be a specific technical issue with TABS and 15,000'. And the folks developing the TABS standard understand this. But it is absolutely great to point out things like any TABS usage regulation should allow operation in wave windows (or maybe rather the FAA should be required to allow TABS devices in any wave window agreements that requires transponders and/or 1090ES Out devices). I'd have s similar wish for Class A airspace in general, but wave windows impact lots more glider pilots than the few doing Class A IFR flights.


> 5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?

I am not following at all what you are asking for here with "non-TSO approval".

Do you want the FAA to mandate all gliders have to carry PowerFLARM? As well as Transponder? As well as TABS? or allowing PowerFLARM to drive TABS GPS? And what TSO? There is no TSO, or underlying RTCA standard at all that is really relevant to FLARM, nor is there any effort to develop one... any consideration about that was what ended up being TABS. And TABS per-se is just a beacon/output system, it does not require any input or display or anything close to Flarm for actual workable traffic warning in glider-on-glider situations. And how does the FAA approve a device without a TSO? The use of "non-TSO" products that's are made say in experimental aircraft requires a TSO spec for the device to be built towards, even if it's not actually TSO approved.

FLARM technology exists becasue it was possible to innovate and develop stuff for such as small specialized market without the usual high cost associated with regulations and bureaucracy. (It's amusing to think what the entire initial development cost of FLARM was and compare that to how many RTCA or FAA standards meetings you could actually conduct for that same cost :-))

I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?

And I know you said TCAS-like, and I know you know what TCAS is but others reading this won't know what you mean exactly. Like what TCAS capability? You might have meant more ADS-B In traffic systems or various CDTI/ADS-B In solutions, but none of those systems will offer anything like TCAS-II RA capabilities. There is also a "cannot not" typo in there that is confusing.

And the FAA could point out there are already several choices of ADS-B in solutions that are compatible with TABS devices and all suitable to different extent in gliders... including obviously the 1090ES In option in PowerFLARM, as well as ADS-B In portable devices from Stratus and Garmin... but I really expect the glider community does not want the FAA pushing/mandating ADS-B In or similar product use in gliders.

> 6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?

This is not an issue with Mode S transponders, or TABS. And I would expect new transponders (including any likely to be installed due to removal of the exemption) are likely to be Mode-S transponders.

And it may be that this problem is overstated even for Mode C transponders. A lot of the folklore about this dates back to old Mode A/C SSR systems. In discussion with ATC staff (including radar techs) in places like Reno they strongly wanted gliders to be transponder equipped and were not concerned about this. I would be surprised if SSR and TCAS cannot handle synchronous garbling from a few aircraft (TCAS II for example has de-correlator designed to handle degarbling several overlapping transponders), large gaggles may be more of a challenge. But a large gaggle of gliders with Mode C transponders and possible synchronous garbling *is* going to get noticed on an SSR radar and ATC should help route traffic around that.

> 7 Will tow planes require TABS or full ADS-B compliance?

Airplanes are not a part of this ANPRM, and right now this should not really be a question... what towplanes requirements are is clear in the current regulations. But it ultimately would be an interesting thing to ask for TABS in special cases such as towplanes or maybe powered aircraft in general to provide partial coverage of where ADS-B Out will be needed after 2020. I hope AOPA and the EAA are watching this and willing to push on it if TABS does take off.

> 9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?

I expect the FAA would argue that the SSA has been quite involved in this. For example the SSA has had representation at meetings that lead to the TSO-C199/TABS. I am not clear how much any of that has been discussed within SSA management or communicated to members.

[David Kinsell[_2_]]

On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:



>
> Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA
> do. At one time there was talk of sales of models without 1090S In in
> the USA, I'm not sure if any sales actually happened (it's a very bad
> idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).
>
>

Craggyaero has them on their website, at a very substantial discount. I
hate to see that too, but expect people buy them.

More common is probably turning off the TCAS type of alerts since the
proximity alarms get annoying.

-Dave

[Darryl Ramm]

On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
> On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:
>
>
>
> >
> > Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA
> > do. At one time there was talk of sales of models without 1090S In in
> > the USA, I'm not sure if any sales actually happened (it's a very bad
> > idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).
> >
> >
>
> Craggyaero has them on their website, at a very substantial discount. I
> hate to see that too, but expect people buy them.
>
> More common is probably turning off the TCAS type of alerts since the
> proximity alarms get annoying.
>
> -Dave

I see one mention of "Core Pure" on one page at Craggy and a price but nowhere to actually buy one. I'm hoping it really is not for sale. Richard???

Likewise there is scattered mention of Core Pure on the Cumulus Soaring Web site but no "Pure" device listed for actual sale.

For reasons that now should be cleaner with ADS-B/1090ES Out adoption and possible TABS futures, glider pilots/owners in the USA really should want to have a 1090ES capable receiver in their PowerFLARM.

[Ramy[_2_]]

Posting on behalf of Jim Herd:

As we have discussed, the FAA ANPRM on TABS is a really big deal for soaring with the potential to cost us all $5000 or so. I have studied this extensively, which is hard to do because so little information is available. I have spoken with the Trig CEO and FAA officials directly involved, so I probably know as much as anyone. I have submitted extensive testimony to the FAA ANPRM and I think it would be very informative to most soaring pilots. It might also inspire them to get involved enough to testify themselves. It is not difficult to do. Strong testimony, even if short, will have an impact, especially if it is deeper than "I can't afford TABS". We all have to take a broader view than that. The FAA wants our input and they have assured me that even asking a series of questions will be welcomed. For example, what about tow planes? What about the 15000' limit issue? What about thermal gaggles? What about upgrading existing mode S xpdrs? When will the mandate happen?


Basically, the new world of aviation involves every object in certain airspace "seeing" all other objects "electronically" with very accurate positioning. This provides for much better safety and much closer spacing - hence accommodating increasing commercial traffic density. In such airspace, it is hard to fathom how gliders can co-exist without being electronically "visible" to ATC and all traffic around them. It is like turning a car headlights on at night - to show other drivers you are there.

Whatever your position, you should make your case to the FAA as I have done.. Feel free to extract points from my testimony or construct your own. My belief is that limited high risk airspace should be mandated for gliders to be squawking, and in the new environment existing xpdrs won't cut it. I need a new one and so may you. But there are many creative ways to limit the pain that the FAA has not yet considered, and I lay out a bunch in my testimony. We can't avoid the excruciating detail because that's where the devil lurks.


My testimony is here:

https://drive.google.com/file/d/0B-9x1FWfSL-fTWZ3dEZWMWZrcEU/view?pli=1


You can file with the FAA here (deadline is August 17):

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


Ramy, feel free to forward this note to soaring pilots who should read it.

Cheers,

Jim Herd

Minden



And here is the text of my ANPRM testimony, as in the link above.


FAA,

I am retired from Silicon Valley as Vice President of Business Development and General Manager of two Divisions of a public corporation, with a technical background and now living in Nevada near Lake Tahoe. I fly a Bonanza and an auxiliary-powered sailplane with a combined 4000 hours in 17 years, flying all across the North American Continent and elsewhere in the world. Aviation is a major passion of mine, for sport and personal transport. I have extensively studied the situation regarding your ANPRM on TABS, including reading a lot of related material and conversing with players in the game such as soaring pilots, power pilots, airline pilots, avionics manufacturers and FAA personnel. I have no personal dog in the hunt, no concern over any added cost burden to me, and I fully recognize the larger picture of protecting everyone in the national air space by fully deploying Next Gen and ADS-B. I will testify here in some depth because the FAA is clearly thirsting for input (to its credit), because the complex nature of the subject warrants it, and I think I have significant impartial contributions to make based on extensive study.

First, it is impossible for me or anyone else to respond to your specific ANPRM questions at this time. The necessary background knowledge is simply not available anywhere. For example, no TABS device is commercially available so no-one knows the cost or power consumption. In good faith, I will nevertheless respectfully submit the findings from my research along with some carefully considered constructive suggestions.

Overview


The general concepts of Next Gen, ADS-B, and TABS are very good. The long-standing transponder exemption for gliders is indefensible in high risk areas, based on the simple fact that "see and be seen" is a failed principle since a glider often presents the visual profile of the edge view of a razor blade. Kudos to the FAA for recognizing this and addressing it. But as always, the devil is in the detail.

Undoubtedly, many folks in the soaring community will react negatively to this ANPRM, based in part on their unavoidable lack of knowledge and the perception that the FAA is "strong-arming" the situation. This, even though I realize your ANPRM is merely asking questions and seeking input. No-one likes a rush to judgment or the feeling of being bullied. And to be fair, glider pilots reasonably perceive little or no value to them from TABS (ADS-B IN weather and traffic is not involved). This, despite the obvious benefit of potentially avoiding airborne conflicts.


Frankly, the absence of an extensive open dialog between the entire soaring community and the FAA has set back the cause considerably, in my humble opinion, and negative impressions have hardened. But a much more constructive and cooperative context can be generated through dialog and education, and a genuine atmosphere of cooperation and goodwill. The current ANPRM does not do that.

As for the power plane community (which for the most part does not understand the gliding community, and visa versa), most of them find it unconscionable that gliders and other aircraft are still universally exempt from the transponder mandate. Those folks are strongly in favor of some type of mechanism to bring gliders into view (electronically speaking) in areas of major threat such as illustrated by the Hawker jet that hit a glider a few years ago in a major soaring location that is visible from my house.


Summary


To be clear and concise, the primary issues here are these:


1. The critical phase of education and informal "outreach" regarding TABS, before any formal ANPRM, is missing. So suspicion and obstruction may dominate until we all back up and engage in a full dialog.

2. Cost of TABS - purchase, installation, adding electrical power, and testing. Cost is most likely not significantly less than current low-end ADS-B OUT devices on the market, and perceived as "unaffordable" with no benefit to the soaring community. TABS does address the power consumption issue, but Trig Avionics has largely solved that one already.

3. TABS is an overreach and arbitrary blanket mandate covering most air space across the country, including air space with virtually no risk to anyone in the air. I realize the ANPRM doesn't go that far, but the writing is perceived to be on the wall.

4. FAA has so far blocked the authorization to turn OFF TABS or any xpdr in a glider in certain air space with insignificant threat. Power consumption, even with a Trig TT21, is a very significant issue for long cross country soaring flights.

5. There is strong potential for new technologies overwhelming the TABS TSO, even before the 2020 mandate. Early obsolescence may be assured.


ANPRM Process


Looking at the ANPRM process first, rather than the substance of the matter.. The ANPRM is premature since almost no soaring pilot or anyone else in the aviation world knows anything about TABS as a commercial product because there isn't one in any store, merely TSO C-199. And even with extensive research, the necessary facts are unavailable. Compounding this is the fact that most soaring pilots have no clue about Next Gen and ADS-B, so they don't have the broader context in which TABS is envisioned. Therefore, it is not useful to ask for feedback at this time. Instead, the correct phase we should enter is one of informal information sharing and education - both ways. The wider aviation community (glider and power pilots) needs to understand TABS and its context, and the FAA needs to understand the special nuances of soaring. Only then can we do quality work together to find the right compromise solution.

So I urge you to step back and initiate a phase of education and informal communication back and forth, but perhaps that is already your intent. I suggest you do this through prominent attendance at the next Soaring Convention (February 18 to 20, Greenville, South Carolina) with a booth and a presentation on TABS, writing in SOARING magazine, reading and even participating in the relevant chat groups, and other vehicles of outreach to soaring pilots. And of course the FAA has many of its own vehicles of outreach and education through publications and special events. Before the TABS ANPRM was issued, there was very little information or dialog anywhere in aviation about this new concept called TABS. So the industry simply is not ready for this ANPRM. And make no mistake, TABS may be the most significant change in U..S. soaring for a decade.


The entire industry needs to understand the broader context of TABS. Also, power pilots need to be educated that soaring gliders present a threat to them only in limited and well-defined high activity air space regions, so power pilots and the whole aviation industry (and the general public) can become comfortable with some compromises regarding air space mandates for gliders. You could reach out to power pilots to educate them with articles in the aviation Press, attendance and presentations at Sun 'N' Fun, Oshkosh, etc. Note that there is no commercial entity that will do this work of education, because companies such as Garmin (who is heavily educating the industry on ADS-B) foresee no payback for any efforts regarding TABS. And Trig is too small to educate the U.S. aviation industry.

What Problem Are We Trying to Solve?


May I suggest that we must all narrow down the focus and answer this: what is the real problem we are trying to solve here? Broad brush answers (such as "remove the xpdr exemption") will only lead to sweeping and over-burdensome proposed solutions that will generate very negative reactions as "excessive" and "unworkable". Instead, a targeted approach will be viewed as more reasonable and acceptable. Specifically, the problem is: unseen aircraft (gliders in this case) posing threats to other aircraft in very specific airspace because they are electronically invisible. Therefore the solution should be the least invasive technology, mandated only in the airspace at significant risk.

I think we can collectively narrow the technical specs within the TSO to reduce cost and power, but this has to be achieved through a cooperative team of "experts" covering all factions. It would include a close look at specific internal circuits that consume power in the TABS box and how to turn them off when not needed. For example, there is little value to anyone in a glider squawking while on the ground because gliders almost never operate at busy airports. So turning off the transmit circuits based on a GPD ground speed less than 30 knots is not difficult. As a Silicon Valley guy, I know this can be done, even though I know extensive work was done on TSO C-199. Also, the air space at significant risk is vastly less than all controlled airspace across the USA and everywhere above 10,000' msl (the usual transponder mandated areas).


For example, there are vast areas of the Desert West (a favorite haunt of glider pilots due to exceptional lifting air) with no airliners below 28,000' and very few other powered aircraft. Here, "big sky" and "see and be seen" are reasonable practical principles with extremely low risk for non-glider aircraft. So the area to be mandated for TABS in gliders can and should be limited to known high risk air space, involving perhaps a new designation of air space type. A specific suggestion might be to extend the "30 mile veil" that surrounds all class Bravo airports, to include veils around class Charlie. Each sensitive area of the country should be reviewed as a cooperative project with regional FAA personnel and local soaring pilots and other interested parties. Specific defined airspace of high risk would be the work product.


Glider Pilots' Needs

Gliding is not a homogeneous sport with a single set of needs so it is important to understand the subsets of needs. For example, primary glider training needs air space uninhibited by TABS because it would seriously damage the sport, already in a long term decline, if training costs at commercial operations have to increase to cover TABS. This is actually reasonably achievable because primary training can usually be restricted to below 10,000' msl and outside class B, C, & D. On the other end is the high-end cross country gliders and their pilots - this is my personal situation. We clearly need access to air space above 10,000' msl, and power consumption for long duration flights is the primary concern.


My personal view is that some type of ADS-B OUT is necessary for my glider, and I recognize I must replace my current mode C xpdr ($$$). Another subset of the sport is the vintage glider community with beloved old metal aircraft with a very small battery (if any), few avionics (if any), and a hull value of less than $20,000. These pilots aren't looking to soar hundreds of miles but they do need reasonably unimpeded access to certain airspace. So I suggest the key here is for FAA personnel to fully understand soaring at the level of the handful of sub-categories that exist, as well as regional differences which are very significant. Then you can work to accommodate critical needs without destroying the sport with overreach. This nuanced approach is standard practice for the FAA as you have worked over many decades to construct special "niche" situations all through the FARs.


Turn Transponders OFF?


Another innovative policy would be to allow glider pilots to turn off their transponders or TABS in certain low risk airspace. I know this has been considered by the FAA in the past and rejected, but I urge you to reconsider. From my own experience soaring around the Western USA, there is less than 10% of the soaring arena where a transponder or TABS has any practical merit below FL180 because there simply is virtually no powered traffic. This modest relaxation would dramatically reduce power consumption and improve support for TABS in the glider community. Do you want to risk a glider unable to squawk or communicate when returning to a busy traffic area because s/he has depleted batteries from squawking at nobody for many hours? Similarly, gliders with auxiliary engines such as mine must retain adequate power for an air restart as a prime safety matter.


Subsidize TABS

In New Zealand, a few years ago their CAA subsidized mode S transponder installation into the glider fleet to the tune of about 50% of the end user cost. In the broader context this was a very modest and practical investment that achieved the goal of smoothing the transition for this small but important aviation community without a major outcry from the soaring community. I realize this has the disadvantage of being "precedent setting", but the FAA already has that precedent with Capstone in Alaska, and there was no backlash in New Zealand. A move like this would greatly diminish the objections to your game plan, so I suggest you look at the economics and consider what might be done.


TABS Product Specs


Early indications are that the TABS TSO won't significantly reduce power consumption from modern transponder products already on the market. The tea leaves indicate we will be at about 200 milliamps for TABS, which is an insignificant change from the current Trig transponder model TT21, but no company has made a commitment on that yet. And hardware pricing looks like it may be in the area of $3500 plus installation of around $500 and then whatever added on-board electrical power solution may be necessary for each unique installation. Also, it is not known if TABS will be subject to the same initial installation certification and retesting every two years, as with conventional xpdrs. All up, this is likely to be in excess of $5000, plus ongoing costs also. So this is no cheaper than the low end of conventional ADS-B OUT products already available in the wider aviation market, and certainly a very expensive pill to swallow for many glider pilots, clubs, and commercial operators who sustain themselves on a shoe-string. Many gliders are only worth between $10,000 and $20,000, and some only $5,000. So we need clever ways to make this cheaper and use less power and not required in some gliders.

Expand the TSO to Increase TABS Volume


The TSO is clearly a laudable first effort to minimize cost, power, and other impacts to sailplane pilots and businesses. My research indicates that more can be done. For example, the FAA will need to deal with balloons, power planes with no electrical system, and UAVs. A collective solution can lead to a single TSO and a vastly larger market for the commercial industry to be attracted to serve TABS and therefore the usual benefits of innovation and price competition that comes from American free-market Capitalism. You see, with less than 4,000 gliders in the USA this segment is an unattractive business proposition for the avionics industry. Consequently, retail price of TABS (for gliders only) will be severely affected by low volume. If combined with other special segments of aviation, I suspect prices could be cut in half due to volume and competition.

As far as I know, the only avionics company working on TABS is Trig in Scotland. We must find ways to interest competing companies such as Becker and Dittel, who have been the industry standard for decades for gliders and all other similar applications such as LSA. A proactive initiative is needed here. What will it take to create an attractive commercial proposition and a competitive environment? Also, how can the existing installed base of transponders in gliders be upgraded to comply with TABS, rather than mandating the expense of a totally new transponder? My experience indicates this would be doable with existing mode S transponders in gliders.


Google, Amazon & Sagetech

As I'm sure you know, Google, Amazon, and others are aggressively entering the huge UAV market for commercial applications. There are credible forecasts of game changing ADS-B OUT technology in the near term, driven by the needs of the burgeoning UAV industry segment. Possible ADS-B OUT devices an order of magnitude lighter, smaller, cheaper, and less power! Undoubtedly, the brain power and investment is already in place to potentially quickly overwhelm the TABS TSO technology. And the end objective of "see and be seen" is exactly the same for UAVs and gliders and balloons and power planes with no electrical system. So why can't we merge all these converging interests to create an attractive market volume? And the FAA should be out front and the catalyst for this exciting prospect!

Reference the Google "Loon" project that is based in my home town of Minden, Nevada:

http://www.airspacemag.com/daily-planet/googles-future-air-force-180956113/?no-ist


Reference Sagetech: http://www.sagetechcorp.com/unmanned-solutions/#.VcuE2cvJAuQ

What About PowerFLARM (PF)?


https://flarm.com/

As you know, the soaring community in the USA has begun to gravitate to a product called PowerFLARM for collision avoidance (glider-to-glider). This is clear evidence that soaring pilots and businesses are fully aware of mid-air risks and willing to commit resources to do something about it - when it is perceived to make sense. Note that PowerFLARM serves an entirely different need than TABS, though the similarities often cause confusion, and it costs less than $2000 with owner-installation being doable. There is no hard data yet for lives saved in the USA, but it is hard to prove a negative. Likely, lives have been saved already.

PF is primarily for glider-to-glider risks, though it also acts similar to TCAS by "seeing" transponders, but it has no ADS-B OUT. There is a totally different risk profile between gliders that involves avoiding false alarms as gliders "gaggle" like a corkscrew in large thermals. ADS-B or TABS would be in constant alarm mode for ATC due to close proximity, but with no real threat. How would this "non-conflict" scenario be handled by ATC when their screen lights up with a gaggle of gliders incorrectly portrayed as in mortal danger from each other?

PF is able to recognize and ignore these common non-threat scenarios. The greatest danger for glider-to-glider impact is when cruising straight and level in opposite directions along what we call "energy lines". That can be ridge lift along a mountain ridge, mountain wave along the leading edge of the familiar lenticular clouds, or cumulus cloud streets. I can report a personal near-fatal near miss of that type. In June of 2013 I was cruising along in my glider at 16,000 feet msl under a cloud street and heading south straight-and level near Richfield, Utah. Another glider was under that same cloud street at the same altitude in the opposite direction. Closing speed was about 200 knots. I was absolutely looking out the window and directly ahead. I caught the other glider out the corner of my eye as he passed by about 100 feet away! I spoke with the other pilot afterwards and he had exactly the same experience as me. See and avoid simply doesn't work in that situation, and neither would TABS because most gliders won't be talking to ATC and won't have ADS-B traffic on-board.

Flarm has a tremendous track record in Europe, where it has been prominent for nearly a decade and is now almost 100% installed in gliders - 25,000 installations, voluntarily. The European device has different electronics but the same principles, and the record of mid-air collisions has markedly decreased as Flarm has become ubiquitous. There is an undeniable linkage and lives have been saved. Again, this is addressing glider-to-glider threats in "high energy" areas with no relevance to the rest of aviation because in Europe gliders are usually very close to terrain and often below ridge lines.. This is airspace where other traffic almost never ventures, for obvious reasons. I urge the FAA to allow PowerFLARM to evolve without regulatory intervention, as it has in Europe.

But PF is irrelevant to the TABS discussion because PF does not transmit 1090ES or 978UAT. But wait, perhaps the manufacturer of PF can develop a TSO-compliant integrated device to incorporate TABS? As you know, there is a trend for integrating avionics all across the aviation world. If cost was reasonable, this would be highly attractive to the soaring community because PF is already building credibility and momentum as a valued cockpit asset for U.S. gliders. The FAA should prompt a joint dialog to see what might be possible. I could also foresee a joint project between PF and Trig people that could lead to a single integrated box, though it does add to the power consumption burden.

Electrical Power Budget


I have studied this and I can offer my own personal data which is quite typical in the soaring world. My glider is a standard certified German DG800B, new in 2000 and still a current design, with an auxiliary engine that is used typically for 10 minutes for launch and then not again, unless I need a boost to stay off the ground and get back home safely from a cross-country flight which takes me up to 300 miles away or further. It has the factory certified electrical design with four 6 volt gel-cell lead-acid batteries wired in series and parallel to provide 24 Ah at 12v. This power source drives the entire aircraft - engine start, engine up-haul (it folds away in the fuselage), and avionics. Further, as you know, batteries degrade from the day they are manufactured, and even "deep cycle" batteries such as these should not be drained below 50% or damage and shortened life will ensue. Therefore, in practical terms, I have available approximately 10 Ah if I start with fully charged batteries. Charging sounds easy but can be a real challenge when the aircraft is tied down on a ramp with no 110v electrical power available, and the on-board batteries are not easily removed. BTW - a set of batteries costs about $450 and they should be replaced every 3 years or so, but if abused with deep discharge and/or poor recharging, every year.

My suite of avionics is actually very modest in power consumption because I use an old black and white moving map screen rather than the modern large bright color screens that are ubiquitous in modern cross-country gliders. So my average continuous current draw is about 1.5 amps, with no transponder and no PowerFLARM. That's about 6.5 hours of flying capacity on the batteries. But in June, flying out of Parowan, Utah I flew 5 days back-to-back of 7 hours each day. Each day I landed with about 12.2v which is nominally below 50% battery capacity, and I know from personal experience when my batteries are that low I may not have the power necessary to up-haul my engine and then start the motor if needed to get home. This is a significant safety issue.

This exact scenario happened to me in 2012 after a long flight of 10 hours and over 1,000 kms. I had to either restart the engine to get home, or land in an open cultivated field. Such an "outlanding" is always considered an emergency procedure in a modern glider due to the 50 to 1 glide and the landing speed of 60 knots with over 1000 pounds of mass. In that case, I had 12.1v and the engine struggled to up-haul at pattern altitude, and there was insufficient power to crank the engine to get home. I proceeded with a pattern to land in the field. On very short final I pressed the starter again and it very sluggishly cranked and started. I avoided an emergency out-landing onto unknown terrain when at 10 feet altitude. So you can see the critical nature of on-board power.

Power Solutions


So what solutions are available to solve the electrical power shortage? More batteries would be possible, but that presents its own problems with cost, wiring, W&B, stowage, recharge and regulatory approval. It is also possible to separate the engine batteries from avionics batteries, as is done in some gliders, so as to retain starting battery reserve for a "relight". But this would involve an electrical design challenge, a factory T.N., an STC, a 337, or some other burdensome and costly action. And this would not solve the total battery power needed. Surely this process can be streamlined in regulatory terms?

There are new battery chemistries that promise higher power density, but we all know of the Boeing 787 fires with Lithium Ion batteries. Some experimental gliders are enjoying success with LiFePO4 (lithium phosphate) chemistry, which provides about 30% better power density. But these batteries are also lighter and change W&B, they still contain Lithium which is a "bad" chemical (reactive and flammable and poison), and they still employ internal circuits to control "thermal runaway", and of course those circuits can and do fail. I suggest the FAA should explore what is safe and what could be given blanket approval to help solve the on-board power problem for standard certified gliders.

Another partial solution is on-board solar panels. I have investigated that for my own glider and here is the data. A double set of solar panels on the engine bay doors (the only location approved by the glider manufacturer and used by them as an option for new gliders) would yield an average of about 1.5 amps continuous in the western U.S. with a lot of sun. Probably nearer to 1 amp or less in heavy cloud and when sun angle is lower. These solar panels are designed and available from only one company in the soaring world and that is Strobl Solar GmbH in Germany. A July 2015 quotation from Strobl for my glider is 1707 Euro or US$1873, plus installation of about $500. This would solve at least part of my power shortfall, but not enough if I install TABS, PowerFLARM, and a modern moving map screen.

Other solutions to improve the electrical power situation include "donor batteries" out on the ramp. That involves conventional large 12v lead-acid batteries that are charged by 110v (wherever available) during the soaring day and then moved to the glider on the ramp for attachment and charging overnight via an inverter and a 12v charger. This system can and does work, but is fraught with practical challenges such as the complex wiring and components involved and the risk of disrupting the charge accidentally and the safety risks associated with moving large donor flooded-cell lead-acid batteries back and forth. Cost can be about $500 with recurring cost for the donor battery. And of course, the on-board batteries can accept no more than a full charge anyway, so on-board capacity is not improved.

Ground solar panels are also employed by many soaring pilots for recharge after the flying day. I use a conventional 20W panel that yields about 1 amp average, but it can only help while the glider is on the ramp which is usually early morning and late evening on back-to-back soaring days (roughly 4 hours of usable sun in summer). I plan to double this ground solar charging this winter, and the total cost of this system is about $1000.

Bottom line


The national air space needs better protection for everyone in it because "see and be seen" doesn't work adequately for high risk areas, and that will inevitably mean a limited mandated technology solution for gliders and other aircraft currently "exempted". The primary issues here are cost, on-board power, defining the minimum air space in which a TABS device is mandated, and education for all concerned factions. The successful solution is going to be more nuanced than that envisioned in the TSO C-199 and the ANPRM, and newer technology may overwhelm the TABS TSO before 2020. But the good news is that new technology presents a great opportunity to bundle TSO C-199 with UAVs to dramatically improve attractiveness and acceptance for gliders.


I look forward to joining with the FAA to get this solved, which I believe demands that we all step back and work together to seek clever compromises as I have suggested here. So please extend the study period, engage the best available contributors from the soaring community & other factions of aviation, collaborate as I have suggested, and embark on a mutual education phase before developing solid proposals. Together we can solve this.

Jim Herd

[Darryl Ramm]

OK I can't resist. More random comments. Lots of the original (including lots of good stuff) cut out to shorten to the bits I wanted to comment on.

On Saturday, August 15, 2015 at 12:26:04 AM UTC-7, Ramy wrote:
> Posting on behalf of Jim Herd:
>
> As we have discussed, the FAA ANPRM on TABS is a really big deal for soaring with the potential to cost us all $5000 or so.

The ANPRM is for removing the transponders exemption not directly about TABS. Although e FAA also asked for comment on that. The $5,000 clearly does not apply to transponder costs, at least for most modern gliders (yes older certified gliders needing a battery install and an STC and God knows what else... possibly who know $$$).

As I posted before in this thread I'm not sure a $5,000 estimate for TABS is really fair. Maybe, maybe not. It may be unfair to assume the worse case GPS cost based on current TSO-C145c GPS sources. Or at least to be more fair show how that estimate is calculated. Bur even say if it was $3,500 or so (Trig TT-21 say $1,000 for a TABS compatible GPS and some install work) that may be too much for many owners. I'm not defending the value, just more concerned that going in with what might be inflated cost claims can be easily shot down. Certified vs. experimental glider install costs may vary here as well.

> 3. TABS is an overreach and arbitrary blanket mandate covering most air space across the country, including air space with virtually no risk to anyone in the air. I realize the ANPRM doesn't go that far, but the writing is perceived to be on the wall.

TABS is a TSO technical product spec, with no installation or carriage regulations or draft regulations to comment on--and that would be critically important to keep watch of. So what overreach/blanket mandate are you talking about?

> 4. FAA has so far blocked the authorization to turn OFF TABS or any xpdr in a glider in certain air space with insignificant threat. Power consumption, even with a Trig TT21, is a very significant issue for long cross country soaring flights.

How/where/when has the FAA blocked any authorization to turn off TABS? There is no regulation at all in place that covers TABS usage so how have they blocked anything? Individuals at the FAA involved with the development of TABS may or may not have a position on that (I have no idea). What you mean?

> 5. There is strong potential for new technologies overwhelming the TABS TSO, even before the 2020 mandate. Early obsolescence may be assured.

The big thing with TABS is it is compatible with/is just an simplification of Mode S and 1090ES Out and the corresponding GPS requirements. And for example compatible with ADS-B In devices as they develop and increase their capabilities, and all the FAA ADS-B Ground infrastructure. That is a good thing. What other new technology are you talking about? Saying new technology will replace TABS is also implying that technology will replace Mode S and 1090ES Out. That just does not make sense. What future RTCA standards are you talking about? Companies are free to innovate with how they implement TABS devices, using whatever state of the art cost modern RF output stages, microprocessor and FPGA hardware, etc. But nobody is going to be "innovating" with the underlying RTCA technical standards behind a this, not for decades...


> Expand the TSO to Increase TABS Volume
>
>
> The TSO is clearly a laudable first effort to minimize cost, power, and other impacts to sailplane pilots and businesses. My research indicates that more can be done. For example, the FAA will need to deal with balloons, power planes with no electrical system, and UAVs. A collective solution can lead to a single TSO and a vastly larger market for the commercial industry to be attracted to serve TABS and therefore the usual benefits of innovation and price competition that comes from American free-market Capitalism. You see, with less than 4,000 gliders in the USA this segment is an unattractive business proposition for the avionics industry. Consequently, retail price of TABS (for gliders only) will be severely affected by low volume. If combined with other special segments of aviation, I suspect prices could be cut in half due to volume and competition.

Expand the TSO? What do you mean? The TSO is just a technical spec, it has nothing to say about actual installation or use regulations use in any type of aircraft.

I'm not sure where the belief that TABS was designed just for gliders comes from, and there is certainly no reason why TABS devices could not be used in other applications... and the TSO was clearly developed with that in mind, even if NTSB pressure on TCAS compatibility with gliders following the Minden mid-air was a key driving factor for this TSO development. This stuff came from LPSE (Low Power Surveillance Equipment) work, largely in Europe, where there were concerns that some regulators wanted to strap these systems to everything, including skydivers... you can even still see the roots of that in the close contact RF exposure concerns in TSO-C199.


> Google, Amazon & Sagetech
>
> As I'm sure you know, Google, Amazon, and others are aggressively entering the huge UAV market for commercial applications. There are credible forecasts of game changing ADS-B OUT technology in the near term, driven by the needs of the burgeoning UAV industry segment. Possible ADS-B OUT devices an order of magnitude lighter, smaller, cheaper, and less power! Undoubtedly, the brain power and investment is already in place to potentially quickly overwhelm the TABS TSO technology. And the end objective of "see and be seen" is exactly the same for UAVs and gliders and balloons and power planes with no electrical system. So why can't we merge all these converging interests to create an attractive market volume? And the FAA should be out front and the catalyst for this exciting prospect!

I think you would find all those folks know about TABS already. SageTech seem to be well positioned to produce TABS devices if a larger/UAV marker exists for them. That may well be what it takes to get TABS devices really affordable, I don't expect just meeting the needs of the USA soaring community will result in a really low-cost device. On the other hand I am personally not excited about lots of UAVs flying around representing risk to manned aircraft. TABS or no TABS. And while TABS has some potential benefit I'm also concerned that the glider community does not end up being the route that eventually results in hang gliders, paragliders, parachutists, model aircraft, etc. getting caught up in what might be be unnecessary regulations/restrictions requiring use of TABS devices. I'm really split on the whole thing.... but if it ever got to the point of gliders losing the ADS-B Out exemption then having TABS as an alternate option would be a good thing.


> PF is primarily for glider-to-glider risks, though it also acts similar to TCAS by "seeing" transponders, but it has no ADS-B OUT. There is a totally different risk profile between gliders that involves avoiding false alarms as gliders "gaggle" like a corkscrew in large thermals. ADS-B or TABS would be in constant alarm mode for ATC due to close proximity, but with no real threat. How would this "non-conflict" scenario be handled by ATC when their screen lights up with a gaggle of gliders incorrectly portrayed as in mortal danger from each other?

ATC would presumably do nothing to try to separate the gliders. As they would not do anything today, especially when obvious to ATC that the aircraft are gliders thermalling together. TABS has a squawk code, and presumably/hopefully regulations would require a glider specific squawk code to make this clear to ATC the targets they see are gliders (and they may see them more via 1090ES and the FAA ground based ADS-B receiver network than via SSR given the design of TABS).

In many places gliders are not themselves in radio communication with ATC at all. However a gaggle of gliders being visible to ATC would help ATC route other traffic around the gaggle. Just like NORCAL Approach does today for transponder equipped gliders in the Reno area... the world does not end, sirens don't go off disrupting NORCAL Approch, when a bunch of gliders get in a gaggle.


> But PF is irrelevant to the TABS discussion because PF does not transmit 1090ES or 978UAT. But wait, perhaps the manufacturer of PF can develop a TSO-compliant integrated device to incorporate TABS? As you know, there is a trend for integrating avionics all across the aviation world. If cost was reasonable, this would be highly attractive to the soaring community because PF is already building credibility and momentum as a valued cockpit asset for U.S. gliders. The FAA should prompt a joint dialog to see what might be possible. I could also foresee a joint project between PF and Trig people that could lead to a single integrated box, though it does add to the power consumption burden.

UAT per-se is mostly irrelevant to TABS, TABS is 1090ES Out only.

TABS is also not equivalent to PowerFLARM as TABS is 1090ES Out only, the TSO-C199 provides *no* 1090ES In, no traffic display or warning capability.

PowerFLARM (at least most sold in the USA) is already a device with 1090ES In and so is relevant to the TABS discussion with gliders. As it is directly compatible/capable of "seeing" any TABS equipped aircraft. And using it's FLARM traffic warning magic to give more useful warnings to glider pilots than any ADS-B In solution can provide. PowerFLARM will also be able to deduplicate other gliders that were PowerFLARM and TABS equipped.

Efforts to produce a hybrid device seem a little suspect for a very small market (gliders in the USA... but who knows, eventually the equivalent to TABS may takes off overseas.. and potentially aimed more at GA if say work/lobbying pressure in the UK is successful).

> Such an "outlanding" is always considered an emergency procedure in a modern glider due to the 50 to 1 glide and the landing speed of 60 knots with over 1000 pounds of mass.

Huh? Inconvenient always. To be taken seriously, but an *emergency*? Really?

[David Kinsell[_2_]]

On Fri, 14 Aug 2015 23:04:44 -0700, Darryl Ramm wrote:

> On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
>> On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:
>>
>>
>>
>>
>> > Not all PowerFLARM actually receive 1090ES, most (all?) sold in the
>> > USA do. At one time there was talk of sales of models without 1090S
>> > In in the USA, I'm not sure if any sales actually happened (it's a
>> > very bad idea IMNSO becasue of 1090ES Out/possible future TABS
>> > compatibility).
>> >
>> >
>> >
>> Craggyaero has them on their website, at a very substantial discount.
>> I hate to see that too, but expect people buy them.
>>
>> More common is probably turning off the TCAS type of alerts since the
>> proximity alarms get annoying.
>>
>> -Dave
>
> I see one mention of "Core Pure" on one page at Craggy and a price but
> nowhere to actually buy one. I'm hoping it really is not for sale.
> Richard???
>
> Likewise there is scattered mention of Core Pure on the Cumulus Soaring
> Web site but no "Pure" device listed for actual sale.
>
> For reasons that now should be cleaner with ADS-B/1090ES Out adoption
> and possible TABS futures, glider pilots/owners in the USA really should
> want to have a 1090ES capable receiver in their PowerFLARM.

Posting on 1/26/2014 from Remde on ras:

"I will have a limited supply of the PowerFLARM Core Pure version 1.0
(without audio output hardware) available in a few days."

Sounds like that was a premature announcement and the product got yanked
soon after. Craggy still has it in a comparison chart with USD end-user
price listed, hopefully just really old data. W&W has so little info on
the PF line listed it makes you wonder if they're actually trying to sell
anything. No displays, no antennas, no info on all the stupid little
keys you have to buy.

And I really wish PF users would keep their TCAS type alerts turned on, I
had a close encounter with a friend while I was pinging away with Mode C.

-Dave

[David Kinsell[_2_]]

On Sat, 15 Aug 2015 02:39:34 -0700, Darryl Ramm wrote:

> OK I can't resist. More random comments. Lots of the original
> (including lots of good stuff) cut out to shorten to the bits I wanted
> to comment on.
>
> On Saturday, August 15, 2015 at 12:26:04 AM UTC-7, Ramy wrote:
>> Posting on behalf of Jim Herd:
>>
>> As we have discussed, the FAA ANPRM on TABS is a really big deal for
>> soaring with the potential to cost us all $5000 or so.
>
> The ANPRM is for removing the transponders exemption not directly about
> TABS. Although e FAA also asked for comment on that. The $5,000 clearly
> does not apply to transponder costs, at least for most modern gliders
> (yes older certified gliders needing a battery install and an STC and
> God knows what else... possibly who know $$$).
>

The title of the ANPRM talks about transponders. Start requiring
transponders and that means ADSB-Out is required, maybe 2020, maybe we
get an extension. The whole ANPRM is poorly written, including the
title, but there can't be any doubt that's the direction the FAA wants to
head. Get the foot in the door with the transponder, then kick it open a
little later. I don't think that's a totally bad thing, but we need to
shape the regulations to the extent possible to make them acceptable for
glider use.

-Dave

[David Kinsell[_2_]]

On Sat, 15 Aug 2015 14:15:58 +0000, David Kinsell wrote:

> On Fri, 14 Aug 2015 23:04:44 -0700, Darryl Ramm wrote:
>
>> On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
>>> On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:
>>>
>>>
>>>
>>>
>>> > Not all PowerFLARM actually receive 1090ES, most (all?) sold in the
>>> > USA do. At one time there was talk of sales of models without 1090S
>>> > In in the USA, I'm not sure if any sales actually happened (it's a
>>> > very bad idea IMNSO becasue of 1090ES Out/possible future TABS
>>> > compatibility).
>>> >
>>> >
>>> >
>>> Craggyaero has them on their website, at a very substantial discount.
>>> I hate to see that too, but expect people buy them.
>>>
>>> More common is probably turning off the TCAS type of alerts since the
>>> proximity alarms get annoying.
>>>
>>> -Dave
>>
>> I see one mention of "Core Pure" on one page at Craggy and a price but
>> nowhere to actually buy one. I'm hoping it really is not for sale.
>> Richard???
>>
>> Likewise there is scattered mention of Core Pure on the Cumulus Soaring
>> Web site but no "Pure" device listed for actual sale.
>>
>> For reasons that now should be cleaner with ADS-B/1090ES Out adoption
>> and possible TABS futures, glider pilots/owners in the USA really
>> should want to have a 1090ES capable receiver in their PowerFLARM.
>
> Posting on 1/26/2014 from Remde on ras:
>
> "I will have a limited supply of the PowerFLARM Core Pure version 1.0
> (without audio output hardware) available in a few days."
>
> Sounds like that was a premature announcement and the product got yanked
> soon after. Craggy still has it in a comparison chart with USD end-user
> price listed, hopefully just really old data. W&W has so little info on
> the PF line listed it makes you wonder if they're actually trying to
> sell anything. No displays, no antennas, no info on all the stupid
> little keys you have to buy.
>
> And I really wish PF users would keep their TCAS type alerts turned on,
> I had a close encounter with a friend while I was pinging away with Mode
> C.
>
> -Dave

Oops, meant PCAS, not TCAS

[glidergeek]

I did my part Docket Number FAA-2015-2147 now do yous

http://www.regulations.gov/#!submitComment;D=FAA-2015-2147-0001

I find and opinion that the requirement for ads b out for gliders to be prohibitivly expensive and not as effective as you might think. With over 1050 hrs logged cross country flights over 10,000' in the USA NAS I find that the exposure to other VFR or IFR traffic to be minimal if not nil. The cost to equip glider that fly over 10,000' / 2500' above terrain will destroy this activity/sport. Please consider the exposure versus the actual accident rate in the past 15-20 years as minimal if not negligible.

N43MD

[[email protected]]

Darryl
I'll try to clarify my thinking recognizing I likely have errors
1

[[email protected]]

Darryl
>>>>>>I'll add a few comments where it might be helpful to explain my thinking and reduce confusion. This topic gets more complex with every new comment and like the FARS many are in conflict with each other. Hopefully I am not about to make it worse. My responses to you preceded by >>>>>

On Friday, August 14, 2015 at 10:15:52 PM UTC-7, Darryl Ramm wrote:
> John

Lots of great points here, some rambling comments on a few techncial things or things I could not follow...

On Friday, August 14, 2015 at 5:01:53 PM UTC-7, wrote:

> The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.

$6000 costs seem high. If I had to guesstimate an _upper_ cost for a TABS device in the near future, I'd expect something like a Trig TT-21 + $1,000 for a GPS source. That is based on triangulating costs for products like the new non-TSO $850 Garmin GPS 20A.. since it meets the full ADS-B our performance requirements having it pass the TABS approval tests should be relatively easy. And no I'm not implying that cost to be affordable or is justified for many glider pilots, just pointing out what I expect a high cost would be.

However that assumes sensible install regulations (anything close to the ADS-B Out STC mess that happened early on woudl be a disaster) and collaboration between vendors of Class A and B TABS devices.... and in general I expect dedicated TABS devices to just include a suitable GPS source. NexNav has announced their "low-cost" TABS Class B Micro-i GPS source. No real clarity on what they mean by low-cost, and I expect they will really sell to OEMs..
>>>>> costs were based on Trig list prices of $2800 for their TT21, plus ~1000 for the GPS WAAS box, and 1900 for solar panels (recent quote), with a conservative $500 for instillation. I put this in one of the answers to the ANPRM specific questions and apologize for not commenting on the inclusion of solar in the costs. I may well be wrong but I don't think the FAA gave much thought to our costs and especially in the lower cost machines in the fleet

> 6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.

I doubt anybody who is not a glider pilot will understand what an energy line are. Their loss :-)

Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA do. At one time there was talk of sales of models without 1090S In in the USA, I'm not sure if any sales actually happened (it's a very bad idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).
>>>>> I had hope they would ask about high energy lines and better understand soaring and the issues. Important I think to get them to understand the difference to collision risk in areas with high activity of mixed traffic and the rest of the airspace
>>>>> 1090ES will not need mode C transponders in fact I understand they will have to be removed

> 8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.

There are no TABS Class A devices on the market today, and no manufacturer TSO approved. >>>>> but note the Federal Register says the FAA is encouraging us to adopt TABS
A Trig TT-21 might be a possible to use as a TABS device since the TABS TSO spec is (a good thing) designed to allow existing Mode S transponders to potentially be backed into use as TABS device. There is certainly *potential* for TABS devices to be say smaller/lighter than say even the current Trig packaged Transponder (which are *great* transponders), e.g. look at what Sagetech does today for Mode S UAV transponders.... http://www.sagetechcorp.com/unmanned-solutions/

Any actual TABS carriage and installation regulation for use in gliders would clearly need to allow that TABS device use above 15,000. The folks who developed the TABS standard understand that. The 15,000' limit in a Class 2 Transponder is not directly relevant in any technical sense here... Installation and carriage regulations or TABS devices needs to be developed, what that looks like if any, is important but it will need to be clearly separated from current transponder regulations...
>>>>>By suggesting class 2 I suspect the FAA does not understand that gliders operate over 15000. So I don't think we can assume that TABS will allow use to 18,000

> 9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.

I expect the FAA would argue that is what TABS is intended to achieve, and lots of folks, including suppliers to the UAV/drone industry, had input into that TSO's development.
>>>>> I don't know if the FAA took a clean sheet of paper to write the TABS spec considering issues that will affect us such as power draw etc or simply decided the lowest power currently existing class 2 transponder would be OK and picked the TRiG TT21. The volume alone for gliders will not interest the suppliers very much. Unique to gliders and especially in the west is the need to operate upto 18,000


> 1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?

TABS/TSO-C199 is a technical product standard. The FAA or RTCA standards just are not going to deal with things like physical size or cost, and that is a good thing, let the market work on that. The FAA can hand wave (largely correctly) that TSO-C100 targets costs by say allowing use of consumer GPS chipset technology (by the avionics manufacture, not owners/pilots connecting random consumer GPS devices), and leveraging exiting Mode S technology/Mode S manufacturer capability. And while all that is a big step for the FAA, TABS devices are still complex and are still likely to be relatively expensive until they reach some significant volume, and that won't even start to happen until there are carriage/install regulations. For better or worse I expect many players here want to make the glider community the test case.. But ultimately volume is going to need something like UAV use... not that I am excited about having larger UAVs flying around putting manned aircraft at risk.

There should not be a specific technical issue with TABS and 15,000'. And the folks developing the TABS standard understand this. But it is absolutely great to point out things like any TABS usage regulation should allow operation in wave windows (or maybe rather the FAA should be required to allow TABS devices in any wave window agreements that requires transponders and/or 1090ES Out devices). I'd have s similar wish for Class A airspace in general, but wave windows impact lots more glider pilots than the few doing Class A IFR flights.
>>>>>pretty such the same as 9 above. We need to make sure these issues are put on the table to be recognized by the FAA and debated

> 5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?

I am not following at all what you are asking for here with "non-TSO approval".
>>>>> Is it compliant with the FARS to permanently install a piece of non TSO equipment in a standard certificated aircraft?
Do you want the FAA to mandate all gliders have to carry PowerFLARM? >>>>> No not FAA mandatory (government is the problem not the solution) but it should be highly encouraged within the soaring community. I would like to think everyone approaching me on the Whites at 120 knots will have one .As well as Transponder? As well as TABS? >>>>> Yes transponder till 2020 or a TABS as and when we have a suitable device available or allowing PowerFLARM to drive TABS GPS? >>>>> a combined TABS/PF would be ideal but I doubt that can be made to happen And what TSO? >>>>> has to be TSO exempt or use the TABS idea of manufacturers certifying themselves There is no TSO, or underlying RTCA standard at all that is really relevant to FLARM, nor is there any effort to develop one... any consideration about that was what ended up being TABS. And TABS per-se is just a beacon/output system, it does not require any input or display or anything close to Flarm for actual workable traffic warning in glider-on-glider situations. And how does the FAA approve a device without a TSO? The use of "non-TSO" products that's are made say in experimental aircraft requires a TSO spec for the device to be built towards, even if it's not actually TSO approved.
>>>>>> if gliders with TABS turned it off to save power had PF then that would advise of an airplane threat and TABS could then be turned on from standby to provide a signal
FLARM technology exists because it was possible to innovate and develop stuff for such as small specialized market without the usual high cost associated with regulations and bureaucracy. (It's amusing to think what the entire initial development cost of FLARM was and compare that to how many RTCA or FAA standards meetings you could actually conduct for that same cost :-))

I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?
>>>>> Don't want it TSO of course as we would likely never get that but want instillation permitted in standard cert aircraft.
And I know you said TCAS-like, and I know you know what TCAS is but others reading this won't know what you mean exactly. Like what TCAS capability? >>>>> threat alerts and avoidance guidance. But i meant as compared to other systems such as TAS, TIS, PCAS and even PF You might have meant more ADS-B In traffic systems or various CDTI/ADS-B In solutions, but none of those systems will offer anything like TCAS-II RA capabilities. There is also a "cannot not" typo in there that is confusing. >>>>>thanks, I'll blame the spell checker
>>>>>> TCAS is of course understood by FAA for whom it is intended. They say that current TCAS will continue to be useable but the new TCAS spec will avoid the interrogation need of signals as they will be provided that data by ADS-B
And the FAA could point out there are already several choices of ADS-B in solutions that are compatible with TABS devices and all suitable to different extent in gliders... including obviously the 1090ES In option in PowerFLARM, as well as ADS-B In portable devices from Stratus and Garmin... but I really expect the glider community does not want the FAA pushing/mandating ADS-B In or similar product use in gliders.

> 6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?

This is not an issue with Mode S transponders, or TABS. And I would expect new transponders (including any likely to be installed due to removal of the exemption) are likely to be Mode-S transponders.
>>>>> Mode C is still required with within a TABS device or stand alone. Mode A has to be rejected by TABS spec
And it may be that this problem is overstated even for Mode C transponders. A lot of the folklore about this dates back to old Mode A/C SSR systems. In discussion with ATC staff (including radar techs) in places like Reno they strongly wanted gliders to be transponder equipped and were not concerned about this. I would be surprised if SSR and TCAS cannot handle synchronous garbling from a few aircraft (TCAS II for example has de-correlator designed to handle degarbling several overlapping transponders), large gaggles may be more of a challenge. But a large gaggle of gliders with Mode C transponders and possible synchronous garbling *is* going to get noticed on an SSR radar and ATC should help route traffic around that.
>>>>> I asked this question and was told that ATC will still see a cluster of "hits" and yes could route traffic around that area. But they cannot determine if a glider on glider incident is about to happen. ATC can suppress data on their screen but will they restore it when the gaggle breaks up a few minutes later? I don't believe this has been considered by the authorities.

> 7 Will tow planes require TABS or full ADS-B compliance?

Airplanes are not a part of this ANPRM, and right now this should not really be a question... what towplanes requirements are is clear in the current regulations. But it ultimately would be an interesting thing to ask for TABS in special cases such as towplanes or maybe powered aircraft in general to provide partial coverage of where ADS-B Out will be needed after 2020. I hope AOPA and the EAA are watching this and willing to push on it if TABS does take off.
>>>>>>In most parts of the country tow planes can operate below 10,000 but not high altitude airports in the west. If tow planes had the same requirements as gliders it would be cheaper for the operators who are in large part financially challenged.

> 9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?

I expect the FAA would argue that the SSA has been quite involved in this. For example the SSA has had representation at meetings that lead to the TSO-C199/TABS. I am not clear how much any of that has been discussed within SSA management or communicated to members.
>>>>>Yes I am sure the FAA had input on the spec creation from people such as SSA. Based on the SSA response to the ANPRM does that make you feel good?

[Darryl Ramm]

John

Great stuff, let me try to cut stuff out and reply to some points. Sorry if I mangle this even further.

I think your submission is great, there are just a few things there that I see there, some of which have also come up in questions from other folks as well. And maybe this will help folks out.

I'm hoping this helps, not trying to be a pain.

Darryl

On Saturday, August 15, 2015 at 12:34:15 PM UTC-7, wrote:
> Darryl

>>>>> costs were based on Trig list prices of $2800 for their TT21, plus ~1000 for the GPS WAAS box, and 1900 for solar panels (recent quote), with a conservative $500 for instillation. I put this in one of the answers to the ANPRM specific questions and apologize for not commenting on the inclusion of solar in the costs. I may well be wrong but I don't think the FAA gave much thought to our costs and especially in the lower cost machines in the fleet

Thanks for that, it's a great way to highlight power concern/possible costs.. I'm a little doubtful about the cost/return of Solar Panels for many owners, they don't deliver as much power as some folks think, and I flew with large Strobl panels for several seasons. They were kinda handy for charging when the glider was left tied down etc. and the batteries are not removable for ground charging. For lots of gliders I'd hope larger/more modern batteries are a possible option. The corner cases of installing batteries, dealing with STCs, for older gliders are a serious worry... where those gliders may be far distant from high density traffic areas.

>>>>>By suggesting class 2 I suspect the FAA does not understand that gliders operate over 15000. So I don't think we can assume that TABS will allow use to 18,000

The folks involved in the FAA development of TABS do understand this. The "Class 2" is just a way of saying... base this standard on a sensible existing low-power transponder RTCA standard to let manufacturers leverage existing designs/tests/approval processes etc.. it does not imply any 15,000' operational limitation on what a TABS device is designed to do.... (it's not designed to primarily operate as a legacy Mode A/C/S transponder for SSR interrogation.. which is what drove the legacy 15,000' Class 2 limit).

There is absolutely nothing wrong with stating that need, and it is probably good to do so. I just did not want people assuming there is necessarily a problem with TABS at 15,000' or sending too much time on this when they may want to prioritize other points they want to make.

> > 9

>>>>> I don't know if the FAA took a clean sheet of paper to write the TABS spec considering issues that will affect us such as power draw etc or simply decided the lowest power currently existing class 2 transponder would be OK and picked the TRiG TT21. The volume alone for gliders will not interest the suppliers very much. Unique to gliders and especially in the west is the need to operate upto 18,000

TABS/TSO-C199 is far from a clean-sheet design, it obviously leverages Mode S/1090ES but directly in the process to get there it derives from previous regulatory/standards work on LPSE (Low Power Surveillance Equipment)/ Low Power Mode S, especially in Europe. Those European organizations will be watching what happens in the USA...

Believe me folks involved in this know it has to work at least up to the floor of Class A airspace. Remember that the FAA development of TABS is directly in response to the NTSB pressure from the mid-air with the Hawker jet over the Pinenuts, and regardless what actually was the collision height, the NTSB is very clear the issue extends right up to Class A and that is broadly understood.

Again, there is no harm in stating that need clearly for TABS carriage/use regulations.

>5.
>>>>>> if gliders with TABS turned it off to save power had PF then that would advise of an airplane threat and TABS could then be turned on from standby to provide a signal

That is a neat idea, but unfortunately it has some serious problems, that I suspect are, like lots of ADS-B things maybe not obvious.

PowerFLARM (assuming a version with 1090ES In) only directly "sees" nearby 1090ES Out equipped aircraft. (Because of it's European roots it will not receive UAT direct or ADS-R or TIS-B transmissions and even if PowerFLARM could receive ADS-R or TIS-B, the FAA ground infrastructure would not provide those services unless the TABS device is transmitting on 1090ES.. an interesting Catch 22 situation (oh what a fun complex mess ADS-B is).

A PowerFLARM may see other transponder but not 1090ES Out equipped aircraft via PCAS (most UAT Out equipped aircraft would also have a transponder, but it's not guaranteed they will), but even then PCAS may not provide a reliable/far enough warning. And even though TABS is largely abotu aircraft-aircraft sensign and collison avoidance the device is seen by ATC, the FAA ground infrastructure would not 'see" the glider's TABS device when it is turned off, or it would appear and disappear at different times, say when a controller might be looking out into the distance to provide separation or traffic advisories, not a situation I expect ATC folks would be happy with. So while an interesting idea it probably has enough issues that it may not be worth pursuing. What I expect will really get TABS power use down, is competition in the market, (and for better or worse) a market developing for TABS use with UAVs/drones.

> I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?
> >>>>> Don't want it TSO of course as we would likely never get that but want instillation permitted in standard cert aircraft.

I'm still not clear what you are asking exactly, and the FAA might be equally confused. PowerFLARM can be installed today in certified gliders.... especially because it is not being used to meet any FAA requirement. I suspect this general area may just be best to avoid getting into.

>>>>>> TCAS is of course understood by FAA for whom it is intended. They say that current TCAS will continue to be useable but the new TCAS spec will avoid the interrogation need of signals as they will be provided that data by ADS-B

It sounds like you are talking about the "hybrid surveillance" capability in the *current* TCAS II 7.1 spec? That technology uses ADS-B to provide long range surveillance of other aircraft and to avoid pinging their Mode S transponders (which helps save bandwidth.. but a huge bandwidth hog is Mode C transponders near TCAS.. IMNSHO it would have been better long long ago for the FAA to start a slow phase out of Mode C transponders,.. another very seperate discussion). The TCAS II transponder interrogator takes over for closer aircraft, and RAs are only every issued based on transponder interrogation. TABS devices are designed to fully work with TCAS II 7.1.

There is just no pure ADS-B based collision avoidance technology that will replace TCAS II on the horizon, the (huge) step of getting there would be RTCA development of a relevant standard. And there are very good security related reasons to not want a last-ditch collision avoidance technology like a TCAS II RA to rely on ADS-B alone... for that reason alone I hope TCAS II stays around for a long while.


>>>>> Mode C is still required with within a TABS device or stand alone. Mode A has to be rejected by TABS spec

Legacy Mode C SSR interrogation is supported in TABS devices, but SSR and TCAS II systems will largely interrogate them via Mode S. I believe, but am not entirely sure, some of of the arguments for leaving the Mode C support in there is compatibility with old TCAD systems that interrogate Mode C only, and for broad applicability of the standard with very old legacy Mode A/C only SSR (should no really be a factor in the USA).

Be careful with "Mode A has to be rejected by TABS". TABS supports the "Mode A" squawk code. It's there, and critically important.. e.g. that squawk code is transmitted by the TABS 1090ES out with ATC will see, but you are correct that a TABS box won't reply to old legacy Mode A SSR interrogations.. and there is just little need to so just dropping it from the requirement simplifies things. That squawk code over 1090ES Out is how ATC will be able to tell a TABS equipped aircraft is a glider, is squawking a code for an emergency etc.

> >>>>> I asked this question and was told that ATC will still see a cluster of "hits" and yes could route traffic around that area. But they cannot determine if a glider on glider incident is about to happen. ATC can suppress data on their screen but will they restore it when the gaggle breaks up a few minutes later? I don't believe this has been considered by the authorities.

But ATC just cannot can't help if a glider on glider event is about to happen... there is no way they have enough positional information, can pay the necessary attention and neither should glider pilots want them to. ATC can see that what they are seeing on their displays are gliders and know not to worry about that glider-glider traffic conflict. I am just not sure this is worth worrying about.


> > 7 Will tow planes require TABS or full ADS-B compliance?

> >>>>>>In most parts of the country tow planes can operate below 10,000 but not high altitude airports in the west. If tow planes had the same requirements as gliders it would be cheaper for the operators who are in large part financially challenged.

I agree it is a *great* thing to ask for, but the comment was written could be read that there is confusion about current regulations. To be clear I suspect a good way is to state that the current regulations are clearly ... but that it could makes a lot of sense to allow tow planes to utilize TABS in future becasue ... (and I would hope that tow planes make a great test case for TABS in powered aircraft and that may get support from other aviation organizations).


> > 9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?

> >>>>>Yes I am sure the FAA had input on the spec creation from people such as SSA. Based on the SSA response to the ANPRM does that make you feel good?

No not really. I was simply pointing out how I expect some FAA folks would respond to that comment.

[[email protected]]

On Saturday, August 15, 2015 at 4:11:54 PM UTC-7, Darryl Ramm wrote:
> John
>
> Great stuff, let me try to cut stuff out and reply to some points. Sorry if I mangle this even further.
>
> I think your submission is great, there are just a few things there that I see there, some of which have also come up in questions from other folks as well. And maybe this will help folks out.
>
> I'm hoping this helps, not trying to be a pain.
>
> Darryl. thanks and I'll use this in final tweaks to my response to the ANPRM. A month ago I did not know what TABS was so have come aways and clearly show how little I still understand about the technology or the process. I did want to put issues on the table suspecting that this is at least in part driven by politics and the soaring movement is low on the totem pole and we could be badly hurt in the review and eventual ruling. Better to make a point even if it is a bit off the mark than not have it considered. I am encouraged by conversations with our FAA contact that they are genuinely interested in giving the matter proper consideration.
I think as a last action I will post my answers to the questions in the ANPRM that might be useful to people wanting to put in a couple of hours generating a response before Monday when they close the book on comments. Cheers, John

[[email protected]]

My responses to the questions in the FFA's ANPRM on transponder operation in gliders. Some of these are self explanatory but for others you will need to see the specific question in the federal register on the URL below. You are welcome to verify and use these

Responses below to ANPRM questions as in the Federal Register
http://www.gpo.gov/fdsys/pkg/FR-2015-06-16/html/2015-14818.htm


A TSO-C199 TABS

A1 TABS could be used in certain circumstances if the specification is appropriate i.e. cost, power requirements, physical size. These are not known at this stage and no TABS product can be purchased today
A2 No one solution fits all the needs to reasonably protect any and all users of the airspace.
Sectional charts could be better used to highlight areas of intensive glider operations. Local ATC and glider operations should work to define the needs in areas shared by other types of aircraft. eg as defined today for B and C airspaces.
The needs in these areas are very different from gliders operating in lightly used air space such as cruising on mountain ranges that are generally in remote areas where any airline traffic is far above in class A airspace.
Gliders by definition have limited power resources and need the flexibilty to use transponders in high activity areas but not in more remote places where the risks are much lower.
I suggest TABS or transponders are required in high traffic areas that are defined locally but are subject to pilot discretion otherwise. Glider pilots have no more desire to be involved in a mid air collision than does any one else.
Consider a well travelled glider route. An out and return from Minden NV south of Reno Class C south to the White Mountains past Bishop CA then the return. In the Minden airport area glider traffic patterns are to the east and power to the west and it is the local practice to make frequent radio calls on CTAF giving position reports and intention. This is completely successful in keeping the sky safe. Above 10,000 feet most gliders use transponders over the Carson Valley and the Pinenut mountains to the east and Sierras to the west. Normal approach should route aircraft as far from these areas as possible considering the limitations of ATC resources and TCAS type devices carried by many aircraft and all in the transport category.
Some older glider models are too low cost to justify the significant cost of transponder and/or TABS devices and need areas where they can operate with the current glider exemption.
South of the Pinenuts there is little traffic and no point in wasting power squawking into the blind, power that will be needed later. On the White Mountains there can be intensive high speed (120 knots so closing at 200 knots and more) glider traffic going north and south all seeking the same high energy lines. TABS is of zero protection here nor the "see and avoid" concept with sleek low profile machines that are essentially invisible to the human eye till it is too late to take evasive action. Here we need the non TSO PF, the European version of which has saved many lives.
Flights can last 10 hours and more and returning to the Carson Valley some hours later we need to have operating transponders. Also sufficient power is needed for self launch gliders for engine extension and start up that may be required at any stage of flight.
A3 No glider manufacturer offers a TABS device in a new machine as no product is available today. I have a Becker transponder that was installed in my glider in 2005 by the manufacturer, DG Sailplanes, for 2268 Euros and solar panels on the engine bay doors were 1033 Euros. The solar panels are not able to maintain voltage with the transponder and radio operating.
FAA representatives at OSH said TRiG would be the supplier of TABS. TRiG told me their low power TT21 transponder lists for $2800, the necessary TN70 GPS WAAS box for US 800$ to 1000, additional solar panels will cost $1900 with an estimated $500 plus for instillation. So an estimate of US$6300 on top of the money invested initially of 2400 Euros for a Becker Mode-C that is now just a paper weight.
A.3.1 Estimate ~$6300 as in A2
A3.2 USD 500+
A3.3 Unknown
A4 No plans as no TABS solution is available today. Cannot answer till we know cost, power budget, physical size and issues such as if class 2 is useable above 15,000 feet

B Transponder equipment and use in gliders

B1 No, but it should be modified. Low power, low cost, small size TABS devices need to be available for new instillations. Existing Mode C transponders cannot be used so the voluntary investment already made in safety is just thrown away.
Transponder/TABS use should be required in high density traffic areas defined locally by ATC and user groups. These areas should provide necessary protection for air space users but allow use with the exemption by gliders such as those used for basic training and with low hull value where the high cost of TABS cannot be economically justified. Transponder/TABS use in all other parts of the national air space should remain at the discretion of the PIC.
B2 Gliders will return after long flights with exhausted batteries and not be able to squawk in high risk areas and self launch gliders will not be able to deploy and start engines. Other avionics such as radios will not be able to transmit and and GPS devices will be unable to provide guidance. Short answer - safety will be compromised with perhaps disastrous results simply from using power in low risk areas
B3 See A3. Same questions
B4 If I have to junk my Becker Mode C transponder I guess I might as well go ADS-B despite the cost. So that is a very reluctant yes.

C ADS-B out in gliders

C1 Not all gliders should be required to incur the cost, power and size issues of installing ADS-B and equipment and use should be based on the air space and usage. One piece of airspace is not the same as another.
Gliders operating below 10,000 feet engaged in operations such as basic training near the airport of operation should not be burdened with this unnecessary and significant cost.
Local ATC and glider operations should work out the areas where ADS-B out is required based on local operations and use in other areas should remain excluded.
C2 There has only been one mid air incident in the last 9 years between a glider and an airplane. If ATC had not been vectoring high speed traffic through a known area of high intensity glider activity this incident would not have occurred. Local ATC and glider operations should negotiate sensible operating rules.
Glider to glider mid airs and near misses are a much more significant factor. The risk to airplanes from the rapidly growing and uncontrolled drone fleet is far higher as is currently being reported by airline crews.
C3 See A3 same questions
C4 I don't understand the question as the only TABS solution on the horizon is I believe from TRiG and that includes their TT21 mode S transponder. If by the question you mean a Mode C transponder must be retained or added in case ADS-B does nor work the answer is absolutely no. Ignoring cost I have no power or space in my glider to carry both systems. Not an option
C5 I have no plans today to add ADS-B to my glider as I do not understand the cost, power, space requirements and no product exists. Further my Becker 4401 meets the current requirements and changing today will prevent me taking advantage of future developments that likely will be cheaper and lower power.

D Additional considerations

D1 There has been only one mid air in the last 9 years between an airplane and a glider in the US air space but many more airplane to airplane and glider to glider, so glider to airplane would not seem to be a high risk justifying removing the glider exemption to transponder operation considering the cost, power, space and operating issues gliders uniquely have. Drone to aircraft is rapidly emerging as a much higher risk than glider to airplane.
To make glider operations safer without unnecessarily burdening the glider community the air space should be analyzed and solutions for each type proposed. e.g.
i High activity areas with mixed types of aircraft where transponders/TABS devices are required such as near class B, C and on approach and departure paths of IFR traffic at those major airports. Note that gliders do not normally operate in IFR conditions or flight plans. Air space should be segmented laterally and vertically and rules for use established between local ATC and glider operations. The Minden incident in 2006 might have been avoided if the glider had an operating transponder and would not have occurred if the jet had not been vectored through an known area of intense glider traffic. Time is a factor too as for instance gliders rarely operate at night. Weather conditions play are part as well as to when and where gliders can operate.
ii Areas of intense glider activity such as the ridges of the east coast Appalachian mountains and in the west mountain ranges such as the Sierras, Whites and Wasatch should be marked on charts as are MOAs. Glider traffic generally moves north south along these geographic features and power traffic east west minimizing risk. Gliders are unlikely to be operating at the selected altitudes as airplanes do following the VFR and IFR rules.
iii The risk between gliders operating in competitions and on long distance routes can be minimized with FLARM technology. FLARM has prevented many glider to glider incidents in Europe and PF is needed in the US for high risk glider to glider operations. Voluntary installation with some level of oversight by the Sailplane and Soaring Association especially for sanctioned contests and meets will be a satisfactory management system. Some soaring event are already mandating PF use.
It should be noted that gliders with PF can see transponder transmissions from other aircraft and take necessary avoidance action although PF cannot be seen by TCAS type devices nor ATC. But PF gives gliders the capability to "see and avoid" aircraft using transponders and at that point the transponder/TABS could then be activated.
D2 I have not had a collision or near miss in any aircraft
D3 I have had potential near misses in glider to glider situations avoided by the common practice of position reports in the blind on 123.3 but this is not a robust procedure
D4 No. I operate within 30 miles of but outside of and above some of the airspaces mentioned
Yes. I routinely operate above 10,000 MSL
D5 I rarely use ATC services flying my glider but I monitor the appropriate frequencies as necessary.

[George Haeh]

So far there's at least 145 responses -
plus others pending review. Keep 'em
coming!

http://www.regulations.gov/#!docketBro
wser;rpp=25;po=0;dct=PS;D=FAA-2015-
2147

[Brian[_1_]]

One point I haven't seem mentioned as a common issue with any device is miminum voltage, many devices require 12 volts or more which can be difficult to maintain with batteries for more than a few hours especially at high altutudes. This is why Becker, Dittel and Trig equipment is often so popular as they are usually specéd to operate down to 10 volts.

Brian

[Brian[_1_]]

Also I think we should be cautious with how we say that Transponders/ADS-B/TABS should be required in some areas, as I think this is what the FAA thinks they are asking, they think these specific areas are Class B (veil), Class C and above 10,000 feet. ie. where the exceptions currently apply.

Brian

[[email protected]]

On Sunday, August 16, 2015 at 7:19:25 PM UTC-7, Brian wrote:
> One point I haven't seem mentioned as a common issue with any device is miminum voltage, many devices require 12 volts or more which can be difficult to maintain with batteries for more than a few hours especially at high altutudes. This is why Becker, Dittel and Trig equipment is often so popular as they are usually specéd to operate down to 10 volts.
>
> Brian

THis is a non-issue today. Using LiFePO4 batteries solves virtually all power problems. I flew last week with a 15Ah LiFePO4 Powerizer battery. I flew for 5 days, total of 20.7 hours. An Oudie, Flarm brick, LX S80 vario, radio and Trig transponder. All were on starting at least 30 minutes before launch and at the end of the last day I was still seeing 12.4 volts. All systems working perfectly.

[Sierra Whiskey]

Sad story.

http://www.foxnews.com/us/2015/08/17/three-dead-in-midair-collision-small-planes-authorities-say/

If only they BOTH had Transponders?

[Dan Marotta]

What do you fly and where do you locate such a large battery?

My LAK-17a has a tail battery compartment which takes three 12v 2AH Pb
batteries wired in parallel and a 12v 9AH Pb battery in the baggage
compartment. I have replaced the tail battery with lead ingots and the
baggage battery with a LiFePO4 10AH direct replacement battery and
installed a 12AH LiFePO4 battery behind the seat back. These have not
let me down for the past year of use.

Maybe I could install a battery box in the fuselage aft of the landing
gear...

On 8/16/2015 8:30 PM, wrote:
> THis is a non-issue today. Using LiFePO4 batteries solves virtually all power problems. I flew last week with a 15Ah LiFePO4 Powerizer battery. I flew for 5 days, total of 20.7 hours. An Oudie, Flarm brick, LX S80 vario, radio and Trig transponder. All were on starting at least 30 minutes before launch and at the end of the last day I was still seeing 12.4 volts. All systems working perfectly.

--
Dan Marotta

[Squeaky]

Sad story.

http://www.foxnews.com/us/2015/08/17/three-dead-in-midair-collision-small-planes-authorities-say/

If only they BOTH had Transponders?

It's highly likely both did.. just like BOTH the F-16 and C150 did in the SC mid-air. So transponders alone do not eliminate the risk, and as noted, since there has only been one incident with a glider/non-glider in the past nine years, why would we mandate something which isn't affordable to all, causes issues with battery/power over long flights if not allowed to be turned off/managed, and clearly, does not eliminate the risk???

[David Kinsell[_2_]]

On Sun, 16 Aug 2015 21:37:23 +0000, George Haeh wrote:

> So far there's at least 145 responses -
> plus others pending review. Keep 'em coming!
>
http://www.regulations.gov/#!DocketBrowser;rpp=25;po=0;dct=PS;D=FAA-2015-
2147


They finally released some more, now 195 total. Still a rather pathetic
response given the likely impact on the sport. Midnight eastern time
tonight is deadline.

The Amodei letter talks about a glider-Airbus near miss close to Reno,
SSA talked about a 737 near miss (glider had transponder). Maybe the
real problem is the Minden-Reno area.

-Dave

[George Haeh]

Two Jet - Cessna midairs, likely with
everybody squawking, makes me
seriously sceptical that simply having
everybody squawking solves the problem.

Today's the last day until midnight EST to
comment.

[Brian[_1_]]

>
> THis is a non-issue today. Using LiFePO4 batteries solves virtually all power problems. I flew last week with a 15Ah LiFePO4 Powerizer battery. I flew for 5 days, total of 20.7 hours. An Oudie, Flarm brick, LX S80 vario, radio and Trig transponder. All were on starting at least 30 minutes before launch and at the end of the last day I was still seeing 12.4 volts. All systems working perfectly.

Using product specs I get you are using are drawing about 1A. 2.2 amps when transmitting. What when showing 12.4 amps what does your voltage drop to while transmitting, if not using a low power radio, you may not be transmitting anything readable, although I suspect if the voltage dropped to0 low the LIFEPO4 circuitry would just be shutting everything down. Could be rather annoying to have everything reset when you push the transmit button.

I believe the 15AH battery is the larger size battery similar in size the a 12Ah Lead Acid. Some gliders it is difficult to mount this size of battery..

You obviously aren't getting 20 hrs of use without charging it, the specs don't support that. So would it last on a 8 or 10 hour flight with temps below 0C (I show they do pretty well at low temps only losing about 10% of capacity at 0C). The specs say it probably would work if we don't transmit to much and if you have room for that large of a battery.

Brian

[[email protected]]

> Using product specs I get you are using are drawing about 1A. 2.2 amps when transmitting. What when showing 12.4 amps what does your voltage drop to while transmitting, if not using a low power radio, you may not be transmitting anything readable, although I suspect if the voltage dropped to0 low the LIFEPO4 circuitry would just be shutting everything down. Could be rather annoying to have everything reset when you push the transmit button.
>
> I believe the 15AH battery is the larger size battery similar in size the a 12Ah Lead Acid. Some gliders it is difficult to mount this size of battery.
>
> Brian

Hi Brian,
Yes, it is a direct replacement for the 12AH lead battery. I have the smaller standard size, also in LiFePO4 as a back-up battery. I had readable radio transmissions upon landing. Nothing cut out. The battery information says it has a protection circuit to turn it off when it is depleted. The battery output is 14.2 volts when fresh off the charger.
It has been a very happy experience using these new batteries. And, they are very light.

[Renny[_2_]]

On Monday, August 17, 2015 at 10:45:15 AM UTC-6, George Haeh wrote:
> Two Jet - Cessna midairs, likely with
> everybody squawking, makes me
> seriously sceptical that simply having
> everybody squawking solves the problem.
>
> Today's the last day until midnight EST to
> comment.

Well, the deadline has passed and there were 218 responses posted. There were some excellent responses from many individuals and the responses included comments from the: SSA, EAA and AOPA. Now, does anyone know how long it takes before we learn of any FAA decision? Thanks!

[Jonathan St. Cloud]

Both had transponders and they were both under positive control of the tower. I have never been a supporter of the big sky theory, too many close calls and one actual for me.

On Monday, August 17, 2015 at 7:03:19 AM UTC-7, David Kinsell wrote:
> On Sun, 16 Aug 2015 21:37:23 +0000, George Haeh wrote:
>
> > So far there's at least 145 responses -
> > plus others pending review. Keep 'em coming!
> >
> http://www.regulations.gov/#!DocketBrowser;rpp=25;po=0;dct=PS;D=FAA-2015-
> 2147
>
>

[Andrew Serota]

I think there are two arguments going on here, each not in direct conflict with the other.

I think it's reasonable to claim that many feel ADS-B, PF, and Mode C Transponders (or any forthcoming technology) makes gliders more visible to traffic who would otherwise not 'see and avoid' a glider. I have not read many (if any) claims that adding any of the aforementioned instrumentation would make soaring unsafe.

Instead, counterpoints claim that 'see and avoid' is 'adequate' (post mid-air) or that the consequences of mandating any instrumentation is too costly for someone to continue soaring, especially for gliders with a low hull value or gliders without a native electrical system, do not directly respond to the discussion prompting the proposed mandate of the aforementioned equipment. Since discussions about past practice and the costly consequences of a mandate are not direct responses about the ANPRM, I anticipate the FAA will not give much, if any, weight to those responses.

I think a constructive discussion starts with the question, how can a glider's participation in the NAS be safer for everyone? I think we would all be surprised if we thought the FAA would publish this ANPRM and return with an answer of "nothing." For that reason, I feel that the SSA's response is short sighted and does not help us contribute to the FAA's process of rulemaking.

I commented directly on the ANPRM because I believe that the FAA will require something. That something ought to be standards of transmitted information, rather than a particular system, so that the wonderful minds in our community (or at Google) could innovate a balanced solution that does not cost very much, has low electrical draw from a battery, and allows us to be visible to fast moving traffic.

I empathize with several comments about the cost of adding equipment to a fleet of 2-33's. My PW-2 GAPA barely has enough instrumentation (and cockpit) to inform me that my vertical speed is 10kts down. But I fly in the congested northeast, and if I can avoid a close encounter on my way down by making it easier for some other pilot to see me, then I feel it is my responsibility to do so.

Andrew Serota

[Darryl Ramm]

Ah there are already very clear technical standards here, Mode C and S transponders, ADS-B, TCAS, and TABS. (FLARM does not really enter into it from a broader Aviation industry perspective... Especially because it is not compatible with TCAS or SSR). What the ANPR is asking about is wether some of these technologies should be mandated or not. Saying there needs to be more technology developed really does not seem helpful... And seems to be replying less to the ANPRM than you are criticising others for. Costs and installation issues with transponders or TABS are serious possible issues for *some* glider owners and are very much something the FAA expects in these responses.. and those folks worried about being affected by that should respond with supporting material (i personally hold little sympathy for folks flying near busy airspace, they should have transponders installed long ago--and those who have not may be helping force this whole thing other other owners. The cost issue, at least to me, is more about how many other gliders not near busy airspace will get caught up in a carriage mandate).

Any system needs to be as compatible as possible with what is in broad use today, and specifically this ANPRM is driven by the question from the NTSB about getting gliders visible to TCAS... Which needs a Mode C, Mode S transponder or TABS. And the FAA already has a massive SSR and ADS-B surveillance infrasructure, so any system better be compatible with that. There *is* a new standard/technology proposal, one developed with input/participation folks including in the UAV space... and that is TABS. Now the big questions there are what the carriage and use regulations for TABS devices might look like, and how many vendors will make those products and what they will be priced at (a chicken and egg problem). Nothing happens in broad aviation surveillance, collision avoidance, etc. without standards developed by RTCA and then adopted via TSO by the FAA and then actual install and use regulations. The road to any innovation there are ~decade long efforts by participants who want to contribute to RTCA standards, and right now we have more of those standards than we need, the practical question, and what the ANPRM is asking, are really which ones of these technologies gues, if any, should be mandated for gliders. Vendors are free within those standards to use new technology as much as they can (and for example modern FPGAs have helped lower transponder costs). We really do not need yet more standards/technology options.

[Sean Fidler]

Shouldn't hang and paragliders also have ADSB? ;-)

If a toy helicopter needs too...

FAA?

[Steve Leonard[_2_]]

On Tuesday, August 18, 2015 at 11:53:16 AM UTC-5, Darryl Ramm wrote:
> The cost issue, at least to me, is more about how many other gliders not near busy airspace will get caught up in a carriage mandate.
>

Completely agree, says the man with lots of gliders showing up to his name on the FAA registry. All of which, when flown from my home gliderport, have the potential to get over 10,000 MSL over the field with the closest Class C airspace 15 or more miles away. And it is not particularly busy there.

Steve Leonard

[JS]

Steve, this brings us back an old question:
Can one of the required devices be swapped back and forth between aircraft?
Something like one Trig TXP with separate wiring harnesses, mounting trays and display heads in each glider. Or whatever the TABS devices end up being..
The TXP would likely require calibration every two years in each aircraft.
Does anyone make a transponder out of velcro?
Jim


On Tuesday, August 18, 2015 at 11:14:50 AM UTC-7, Steve Leonard wrote:
> On Tuesday, August 18, 2015 at 11:53:16 AM UTC-5, Darryl Ramm wrote:
> > The cost issue, at least to me, is more about how many other gliders not near busy airspace will get caught up in a carriage mandate.
> >
>
> Completely agree, says the man with lots of gliders showing up to his name on the FAA registry. All of which, when flown from my home gliderport, have the potential to get over 10,000 MSL over the field with the closest Class C airspace 15 or more miles away. And it is not particularly busy there.
>
> Steve Leonard

[Darryl Ramm]

JS > wrote:
> Steve, this brings us back an old question:
> Can one of the required devices be swapped back and forth between aircraft?
> Something like one Trig TXP with separate wiring harnesses, mounting
> trays and display heads in each glider. Or whatever the TABS devices end up being.
> The TXP would likely require calibration every two years in each aircraft.
> Does anyone make a transponder out of velcro?
> Jim

That is one of the questions. The TABS TSO does not exclude that, and some
of the thought possibility that lead to TABS were certainly for small
devices. The question will be what the install/carriage regulations will
look like. There might be concern with reliability of making connections to
antennas and static pressure sensors.... my expectation is this is all too
hard and likely won't be supported by install regulations but who knows. I
am more hoping that any TABS install regulations if they end up existing at
all are simple enough to allow low-cost fixed installs in certified
gliders. Maybe as easy as a Transponder today, but they have to be much
much easier than early ADS-B installs (which required STCs).

[George Haeh]

I have been slogging through the some
220 responses and came across a
response from the NTSB:

http://www.regulations.gov/contentStrea
mer?documentId=FAA-2015-2147-
0137&attachmentNumber=1&disposition
=attachment&contentType=pdf

"our main concern was to ensure that
gliders are detectable by an aircraft
equipped with a traffic alert and collision
avoidance system (TCAS)"

Gliders are already kept well away from
air carriers by Class B and C.

That makes the primary beneficiaries of
the ANPRM private jet owners able to
afford TCAS - $30K to $200K before
installation.

As long as they're transmitting ADS-B,
anybody with PowerFLARM knows
exactly where they are from several miles
away and can avoid.

[Ramy[_2_]]

On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
> I have been slogging through the some
> 220 responses and came across a
> response from the NTSB:
>
> http://www.regulations.gov/contentStrea
> mer?documentId=FAA-2015-2147-
> 0137&attachmentNumber=1&disposition
> =attachment&contentType=pdf
>
> "our main concern was to ensure that
> gliders are detectable by an aircraft
> equipped with a traffic alert and collision
> avoidance system (TCAS)"
>
> Gliders are already kept well away from
> air carriers by Class B and C.
>
> That makes the primary beneficiaries of
> the ANPRM private jet owners able to
> afford TCAS - $30K to $200K before
> installation.
>
> As long as they're transmitting ADS-B,
> anybody with PowerFLARM knows
> exactly where they are from several miles
> away and can avoid.

This can not be further from the truth! Is NTSB really that clueless? Are they assuming that air carriers are immediately in class A when outside of class B/C, or do they assume that gliders only fly in patterns around small airports outside class B/C? Anyone who is flying in Reno area, Las Vegas area, in the Bay Area and any other soaring area within 50 miles of a major airport knows that we sharing the same airspace with airliners, including inside Mode C veil!

Ramy

[jfitch]

On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
> I have been slogging through the some
> 220 responses and came across a
> response from the NTSB:
>
> http://www.regulations.gov/contentStrea
> mer?documentId=FAA-2015-2147-
> 0137&attachmentNumber=1&disposition
> =attachment&contentType=pdf
>
> "our main concern was to ensure that
> gliders are detectable by an aircraft
> equipped with a traffic alert and collision
> avoidance system (TCAS)"
>
> Gliders are already kept well away from
> air carriers by Class B and C.
>
> That makes the primary beneficiaries of
> the ANPRM private jet owners able to
> afford TCAS - $30K to $200K before
> installation.
>
> As long as they're transmitting ADS-B,
> anybody with PowerFLARM knows
> exactly where they are from several miles
> away and can avoid.

At least some air carriers are not transmitting ADS-B as of this writing. Southwest for example - none of their jets flying into and out of Reno show up on PowerFlarm. Biz jets seem to have a higher install rate than airlines.

[jfitch]

On Tuesday, August 18, 2015 at 10:07:01 PM UTC-7, Ramy wrote:
> On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
> > I have been slogging through the some
> > 220 responses and came across a
> > response from the NTSB:
> >
> > http://www.regulations.gov/contentStrea
> > mer?documentId=FAA-2015-2147-
> > 0137&attachmentNumber=1&disposition
> > =attachment&contentType=pdf
> >
> > "our main concern was to ensure that
> > gliders are detectable by an aircraft
> > equipped with a traffic alert and collision
> > avoidance system (TCAS)"
> >
> > Gliders are already kept well away from
> > air carriers by Class B and C.
> >
> > That makes the primary beneficiaries of
> > the ANPRM private jet owners able to
> > afford TCAS - $30K to $200K before
> > installation.
> >
> > As long as they're transmitting ADS-B,
> > anybody with PowerFLARM knows
> > exactly where they are from several miles
> > away and can avoid.
>
> This can not be further from the truth! Is NTSB really that clueless? Are they assuming that air carriers are immediately in class A when outside of class B/C, or do they assume that gliders only fly in patterns around small airports outside class B/C? Anyone who is flying in Reno area, Las Vegas area, in the Bay Area and any other soaring area within 50 miles of a major airport knows that we sharing the same airspace with airliners, including inside Mode C veil!
>
> Ramy

Ramy - the NTSB only said the part in the quotes, the rest of it was the opinion (or mistake) of the poster.

[Ramy[_2_]]

Oops, don't know how I missed the end of the quote. It didn't make sense to me that the NTSB will be so clueless. I am amazed that some glider pilots believe we

[David Kinsell[_2_]]

On Wed, 19 Aug 2015 03:32:29 +0000, George Haeh wrote:

> I have been slogging through the some 220 responses and came across a
> response from the NTSB:
>
> http://www.regulations.gov/contentStrea mer?documentId=FAA-2015-2147-
> 0137&attachmentNumber=1&disposition =attachment&contentType=pdf
>
> "our main concern was to ensure that gliders are detectable by an
> aircraft equipped with a traffic alert and collision avoidance system
> (TCAS)"
>
> Gliders are already kept well away from air carriers by Class B and C.
>
> That makes the primary beneficiaries of the ANPRM private jet owners
> able to afford TCAS - $30K to $200K before installation.
>
> As long as they're transmitting ADS-B, anybody with PowerFLARM knows
> exactly where they are from several miles away and can avoid.

You took that one sentence well out of context. With the advent of ADS-
B, the NTSB now believes gliders should also lose their ADS-B exemption.
ADS-B In capability is a whole lot cheaper than TCAS, and will be much
more widely deployed.

As I keep saying, this ANPRM isn't about transponders, it's about
transponders and ADS-B, as should be obvious from the survey questions
they asked. I believe FAA has decided to suck gliders into NextGen, and
are using the (extremely late) letters from Reid and Amodei as
justification. I'm generally in favor of that in principle, but hope we
can get regulations that make it more practical given the constraints of
gliders.

-Dave

[David Kinsell[_2_]]

On Tue, 18 Aug 2015 22:45:18 -0700, jfitch wrote:

> On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
>> I have been slogging through the some 220 responses and came across a
>> response from the NTSB:
>>
>> http://www.regulations.gov/contentStrea mer?documentId=FAA-2015-2147-
>> 0137&attachmentNumber=1&disposition =attachment&contentType=pdf
>>
>> "our main concern was to ensure that gliders are detectable by an
>> aircraft equipped with a traffic alert and collision avoidance system
>> (TCAS)"
>>
>> Gliders are already kept well away from air carriers by Class B and C.
>>
>> That makes the primary beneficiaries of the ANPRM private jet owners
>> able to afford TCAS - $30K to $200K before installation.
>>
>> As long as they're transmitting ADS-B, anybody with PowerFLARM knows
>> exactly where they are from several miles away and can avoid.
>
> At least some air carriers are not transmitting ADS-B as of this
> writing. Southwest for example - none of their jets flying into and out
> of Reno show up on PowerFlarm. Biz jets seem to have a higher install
> rate than airlines.

So SouthWest isn't using their transponders these days?? Hope you report
that to FAA.

[Bruce Hoult]

On Wednesday, August 19, 2015 at 4:44:32 PM UTC+3, David Kinsell wrote:
> On Tue, 18 Aug 2015 22:45:18 -0700, jfitch wrote:
>
> > On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
> >> I have been slogging through the some 220 responses and came across a
> >> response from the NTSB:
> >>
> >> http://www.regulations.gov/contentStrea mer?documentId=FAA-2015-2147-
> >> 0137&attachmentNumber=1&disposition =attachment&contentType=pdf
> >>
> >> "our main concern was to ensure that gliders are detectable by an
> >> aircraft equipped with a traffic alert and collision avoidance system
> >> (TCAS)"
> >>
> >> Gliders are already kept well away from air carriers by Class B and C.
> >>
> >> That makes the primary beneficiaries of the ANPRM private jet owners
> >> able to afford TCAS - $30K to $200K before installation.
> >>
> >> As long as they're transmitting ADS-B, anybody with PowerFLARM knows
> >> exactly where they are from several miles away and can avoid.
> >
> > At least some air carriers are not transmitting ADS-B as of this
> > writing. Southwest for example - none of their jets flying into and out
> > of Reno show up on PowerFlarm. Biz jets seem to have a higher install
> > rate than airlines.
>
> So SouthWest isn't using their transponders these days?? Hope you report
> that to FAA.

They of course have transponders, but only the most recent models of 737 have ADS-B.

Southwest still have quite a lot of -300 and -500 models which I believe will never be fitted with ADS-B. They will be retired by 2020.

The -700 and -800 models will be retrofitted with ADS-B by 2020. Some may have come with it from the factory (-800s?).

[[email protected]]

On Tuesday, August 18, 2015 at 1:08:29 PM UTC-4, Sean Fidler wrote:
> Shouldn't hang and paragliders also have ADSB? ;-)
>
> If a toy helicopter needs too...
>
> FAA?

And skydivers, birds, and especially mountains. People are always flying into that last one.

[George Haeh]

I have been slogging through the some
220 responses and came across a
response from the NTSB:

http://www.regulations.gov/contentStrea
mer?documentId=FAA-2015-2147-
0137&attachmentNumber=1&disposition
=attachment&contentType=pdf

"our main concern was to ensure that
gliders are detectable by an aircraft
equipped with a traffic alert and collision
avoidance system (TCAS)"

Gliders are already kept well away from
air carriers by Class B and C.

That makes the primary beneficiaries of
the ANPRM private jet owners able to
afford TCAS - $30K to $200K before
installation.

As long as they're transmitting ADS-B,
anybody with PowerFLARM knows
exactly where they are from several miles
away and can avoid.

[George Haeh]

Here in Canada the air carriers are pretty
much on ADS-B already; so my PF sees
them. Aside from the odd towplane, my
PF has only alerted me to one
transponder target.

I can receive several ADS-B returns on a
single flight.

[Dan Daly[_2_]]

On Wednesday, August 19, 2015 at 1:00:11 PM UTC-4, George Haeh wrote:
> Here in Canada the air carriers are pretty
> much on ADS-B already; so my PF sees
> them. Aside from the odd towplane, my
> PF has only alerted me to one
> transponder target.
>
> I can receive several ADS-B returns on a
> single flight.

Hi George - the Dash-8's running Ottawa-Montreal over Gatineau and MSC aren't ADS-B equipped; neither are the Ontario provincial aeromedical evac helos that buzz through our MFA area. We see their transponders. Only the 3pm flights from Europe come in showing ADS-B. I expect we'll see more as 2020 approaches since most of the Dash-8's will also be going into NY and Boston.

We also see a lot of GA traffic over the Ottawa River...

[George Haeh]

Here in Canada the air carriers are pretty
much on ADS-B already; so my PF sees
them. Aside from the odd towplane, my
PF has only alerted me to one
transponder target.

I can receive several ADS-B returns on a
single flight.

[Darryl Ramm]

On Tuesday, August 18, 2015 at 8:45:12 PM UTC-7, George Haeh wrote:
> I have been slogging through the some
> 220 responses and came across a
> response from the NTSB:
>
> http://www.regulations.gov/contentStrea
> mer?documentId=FAA-2015-2147-
> 0137&attachmentNumber=1&disposition
> =attachment&contentType=pdf
>
> "our main concern was to ensure that
> gliders are detectable by an aircraft
> equipped with a traffic alert and collision
> avoidance system (TCAS)"
>
> Gliders are already kept well away from
> air carriers by Class B and C.

That is serious misunderstanding of how controlled airspace works.

Scheduled airline traffic for example flies in Class A, B, C, D and E airspace in the USA. Class E airspace in particular is a concern with gliders and airliners near some busy traffic areas. For example in the Reno Area you have Airliners fling approaches into Reno sharing airspace with glider traffic in the Carson Valley. It is interesting to look down from a glider and see multiple B737s on approach to Reno. That is why pilot education, voluntary carriage of transponders, established gliders procedures with ATC, etc. are so important there. And many owners/pilots, clubs, FBOs, organizations like PASCO have down great work to support that. And why when incidents like airliners getting anywhere near close to a glider gets a lot of attention. And while the Reno area may be the poster-child for airliner-glider saftey concerns in the USA that situation is far from limited to the Reno Area.


> That makes the primary beneficiaries of
> the ANPRM private jet owners able to
> afford TCAS - $30K to $200K before
> installation.

There are many valuable inputs that people can and should be making about this ANPRM and related concerns, from all possible points of view, but stating inflammatory opinions like this that are based on such obvious misunderstands is not likely to do anybody any good.


> As long as they're transmitting ADS-B,
> anybody with PowerFLARM knows
> exactly where they are from several miles
> away and can avoid.

PowerFLARM ADS-B In is a helpful feature, but when it comes to high-speed threats like fast jets and airliners (especially above 250 knots above 10,000') the usefulness may be more for educating PowerFLARM users about where that traffic generally is and to avoid that entire area if possible.. or to help convince those owners/pilots to get a transponder.. which has happened in a few cases I know. I'm not so convinced it's that useful for a glider pilot reliably avoiding ADS-B Out equipped high-speed jet or airliner that does not know the glider is there. For that it seems making the glider visible to TCAS in the high speed jet or airliner is much more useful approach.

[George Haeh]

Here in Canada the air carriers are pretty
much on ADS-B already; so my PF sees
them. Aside from the odd towplane, my
PF has only alerted me to one
transponder target.

I can receive several ADS-B returns on a
single flight.