Transponder petition

[Ian Cant]

Wish we'd had this discussion before the SSA drafted its petition.

Seems to me the petition is unsatisfactory because it is confusing or poor law, it does not address the full set of transponder issues, and it just might open up an adverse review of our existing exemption. To address these concerns I sent my comments to the FAA, text below FYI.

If anyone agrees with me in part or in whole, why not add your comments to the docket too ?

Ian

"Comment on Docket FAA-2003-16475-1, exemption for gliders from continuous transponder operation.

I concur with the Soaring Society of America's contention that there is a public benefit and increased safety to be gained by encouraging glider operators to install battery-powered transponder equipment.

However, I also believe that the current wording of the request for exemption will lead to confusion over the status of transponder-equipped gliders and will not best achieve the desired goal.

The petiton requests relief only from the provisions of 14CFR 91-215(c), the requirement for continuous operation, and only when more than 40 miles from Class B or 20 miles from Class C airports. 14CFR 91-215(c) requires continuous operation in ALL airspace above 10,000 ft msl by reference to section 215-b(5)(I). Many gliders coduct a large portion of cross-country flights above 10,000 ft, usually in remote areas. As written, the request would appear to confirm that IF a transponder is installed then it must be in continuous operation in these circumstances.

In addition, the request does not address the provisions of section 217 regarding the calibration of the mode C pressure altitude reporting equipment.

Since there is no current requirement for a transponder to be installed at all, these deficiencies will probably continue to deter operators from installing transponders.

Currently, the decision is all-or-nothing; either do not install a transponder at all, or accept the requirements of continuous use and adherence to Mode C calibration requirements.

A better approach to achieving the desired encouragement of the installation of battery transponders might be to permit partial conformity with sections 215 and 216. Those operators who really never need transponders [such as local training operations well outside controlled airspace, or pilots who never fly at high altitudes or cross-country] continue to use the existing waiver at all times; those who occasionally fly cross-country could be permitted to install transponders but use them only when the pilot considers it appropriate to the conditions of each flight; and those who operate in relatively congested airspace may sensibly elect to conform fully with the provisions of the sections but perhaps conserve battery power by switching off when out of the congested area.

Possible wording might be along these lines: "Notwithstanding the provisions of 14CFR sections 215 and 217 and the existing exemptions for balloons, gliders and other aircraft not originally certificated with an engine-driven electrical power system, the operator of such an aircraft shall be permitted and encouraged to install a battery-powered transponder system and to use it as extensively as he considers appropriate. Such voluntary and safety-enhancing installations are encouraged but not required to comply with the provisions of sections 215 and 217 as applicable to airplanes."

I am a glider pilot, a member of SSA, and own 3 gliders. None currently have transponders, but I would probably install one in my primary cross-country aircraft if permitted to use it with flexibility."

[Jim Phoenix]

"Ian Cant" > wrote

", and it just might open up an adverse review of our existing exemption."

I suppose I could go search for it myself, but I was wondering what existing
exemption do we have? By "we" I presume you mean an exemption granted to the
SSA? The external data plate exemption?

Jim

[Ivan Kahn]

I don't agree with you reading of the request. I believe it is for relief
from 91.215(c) *unless* with 40 miles of Class B and 20 of Class C. So if
you are above 10,000' MSL, and at least the appropriate distances from Class
B & C, then the relief sought would apply. And if memory servers,
calibration of Mode C is only applicable to IFR.

Ivan

"Ian Cant" > wrote in message
...
> Wish we'd had this discussion before the SSA drafted its petition.
>
> Seems to me the petition is unsatisfactory because it is confusing or poor
law, it does not address the full set of transponder issues, and it just
might open up an adverse review of our existing exemption. To address these
concerns I sent my comments to the FAA, text below FYI.
>
> If anyone agrees with me in part or in whole, why not add your comments to
the docket too ?
>
> Ian
>
> "Comment on Docket FAA-2003-16475-1, exemption for gliders from continuous
transponder operation.
>
> I concur with the Soaring Society of America's contention that there is a
public benefit and increased safety to be gained by encouraging glider
operators to install battery-powered transponder equipment.
>
> However, I also believe that the current wording of the request for
exemption will lead to confusion over the status of transponder-equipped
gliders and will not best achieve the desired goal.
>
> The petiton requests relief only from the provisions of 14CFR 91-215(c),
the requirement for continuous operation, and only when more than 40 miles
from Class B or 20 miles from Class C airports. 14CFR 91-215(c) requires
continuous operation in ALL airspace above 10,000 ft msl by reference to
section 215-b(5)(I). Many gliders coduct a large portion of cross-country
flights above 10,000 ft, usually in remote areas. As written, the request
would appear to confirm that IF a transponder is installed then it must be
in continuous operation in these circumstances.
>
> In addition, the request does not address the provisions of section 217
regarding the calibration of the mode C pressure altitude reporting
equipment.
>
> Since there is no current requirement for a transponder to be installed at
all, these deficiencies will probably continue to deter operators from
installing transponders.
>
> Currently, the decision is all-or-nothing; either do not install a
transponder at all, or accept the requirements of continuous use and
adherence to Mode C calibration requirements.
>
> A better approach to achieving the desired encouragement of the
installation of battery transponders might be to permit partial conformity
with sections 215 and 216. Those operators who really never need
transponders [such as local training operations well outside controlled
airspace, or pilots who never fly at high altitudes or cross-country]
continue to use the existing waiver at all times; those who occasionally
fly cross-country could be permitted to install transponders but use them
only when the pilot considers it appropriate to the conditions of each
flight; and those who operate in relatively congested airspace may sensibly
elect to conform fully with the provisions of the sections but perhaps
conserve battery power by switching off when out of the congested area.
>
> Possible wording might be along these lines: "Notwithstanding the
provisions of 14CFR sections 215 and 217 and the existing exemptions for
balloons, gliders and other aircraft not originally certificated with an
engine-driven electrical power system, the operator of such an aircraft
shall be permitted and encouraged to install a battery-powered transponder
system and to use it as extensively as he considers appropriate. Such
voluntary and safety-enhancing installations are encouraged but not required
to comply with the provisions of sections 215 and 217 as applicable to
airplanes."
>
> I am a glider pilot, a member of SSA, and own 3 gliders. None currently
have transponders, but I would probably install one in my primary
cross-country aircraft if permitted to use it with flexibility."
>
>
>
>
>
>
>

[BTIZ]

Jim.. gliders and balloons and aircraft without an engine driven electrical
system are exempt from certain parts of FAR91.215, not required above
10,000MSL, not required in the ModeC veil around Class B (30nm and below the
ceiling of the local ClassB). But if you have one in the glider, "all
aircraft equipped with a transponder must have it operational at all times
they are airborne."

What the SSA "appears" to be looking for, is an "allowance" to turn the
transponder off when away from "high traffic areas" to save battery energy,
so they can still have an "operational transponder" that they can turn back
on when they return to the "high traffic volume area" instead of having a
dead battery, no radio and no glide computer.

BT

"Jim Phoenix" > wrote in message
...
>
> "Ian Cant" > wrote
>
> ", and it just might open up an adverse review of our existing exemption."
>
> I suppose I could go search for it myself, but I was wondering what
existing
> exemption do we have? By "we" I presume you mean an exemption granted to
the
> SSA? The external data plate exemption?
>
> Jim
>
>

[Jim Phoenix]

BT,

I know they are "exempt" from the rule - but that's bad terminology really,
they are simply compliant with the rule by not having transponders - not
really "exempt" from the rule in the pure form of the regulatory meaning - I
thought Ian was alluding to some other exemption the SSA had (besides the
data plate exemption).

My additional respectful comment to Ian is that the FAA is not going to
review any "previous or current exemption" - there isn't one. I presume the
FAA could try to re-write the rule - but you can bet that would lead to a
brick wall called the AOPA and EAA. As pointed out above by others in this
thread - gliders are a minority of the aircraft that enjoy the provisions of
the existing rule allowing aircraft *originally certificated* without an
electrical system to not have a transponder in certain airspace... blah blah
blah ad infinitum.

I see a dissenting vote has made a comment to the rule. It will be fun to
read the final rule and the FAA's reply to the comments - but I suppose you
have to like this sort of thing ;-)

This is a real tempest in a teapot, isn't it? My personal vote is to save my
coppers and buy a transponder someday, I really like the idea of showing up
big and bright on everybodys radars and TCAS's, and if I don't maybe I'll be
lucky enough to still be able to use my chute.

Jim

[Bob Greenblatt]

OK, I can't keep quiet on this any longer. I agree completely that adding a
transponder is likely to increase safety, that's why I did it. I think the
exemption is meaningless - we don't need one! If you are going to add a
transponder to your aircraft (and I urge you to do so) you ought to insure
that you have enough power to drive it and the rest of your electronics for
the duration of your expected flights. To do otherwise is simply
irresponsible.

A fully charged "standard" 7.5 AH battery will power one of the newer
transponders and encoders for more than 8 hours. And, that's here on the
east cost where the interrogations are almost constant. Why would anyone go
to the trouble of installing a transponder and encoder and not insure that
there is enough power to take advantage of it?

It's so simple to conform to the FARs (or CFRs or whatever they are) as they
presently exist. Attempting to achieve an exemption is misdirection of a lot
of energy better spent elsewhere.

So, put in a transponder and some extra batteries. There's always room. If
you can't find any think harder.

--
bobgreenblattATmsnDOTcom <--fix this before responding

[Roger Felton]

In *theory* the "standard" 7.5 AH battery will power your transponder for 8+
hours. Sealed Lead Acid batteries rarely achieve their advertised capacity in
ideal conditions even when new. Now age that battery for a year or two. Throw in
some repeated deep discharges. Now cold soak the battery for a few hours at
altitude. I think you'll find that your 7.5 AH battery has something more like 4
AH (or less) useable capacity. So you up the size of the battery to 12 AH. Yes
you can always find somewhere to put the additional equipment. However a real
problem is that there are a significant number of ships out there that are at
(or over) their max. allowable weight for non-lifting parts, and the 10+ lbs of
the additional battery and associated wiring is simply too much.
I think that ATC would much rather see you suddenly pop up on their radar when
approaching airspace than suddenly dissappear (from a dead battery) while in or
overflying their airspace.

RF

Bob Greenblatt wrote:

> OK, I can't keep quiet on this any longer. I agree completely that adding a
> transponder is likely to increase safety, that's why I did it. I think the
> exemption is meaningless - we don't need one! If you are going to add a
> transponder to your aircraft (and I urge you to do so) you ought to insure
> that you have enough power to drive it and the rest of your electronics for
> the duration of your expected flights. To do otherwise is simply
> irresponsible.
>
> A fully charged "standard" 7.5 AH battery will power one of the newer
> transponders and encoders for more than 8 hours. And, that's here on the
> east cost where the interrogations are almost constant. Why would anyone go
> to the trouble of installing a transponder and encoder and not insure that
> there is enough power to take advantage of it?
>
> It's so simple to conform to the FARs (or CFRs or whatever they are) as they
> presently exist. Attempting to achieve an exemption is misdirection of a lot
> of energy better spent elsewhere.
>
> So, put in a transponder and some extra batteries. There's always room. If
> you can't find any think harder.
>
> --
> bobgreenblattATmsnDOTcom <--fix this before responding

[Bill Daniels]

"Roger Felton" > wrote in message
...
> In *theory* the "standard" 7.5 AH battery will power your transponder for
8+
> hours. Sealed Lead Acid batteries rarely achieve their advertised capacity
in
> ideal conditions even when new. Now age that battery for a year or two.
Throw in
> some repeated deep discharges. Now cold soak the battery for a few hours
at
> altitude. I think you'll find that your 7.5 AH battery has something more
like 4
> AH (or less) useable capacity.

Not my experience but then I buy a new battery each season for less than the
price of a tow. Then I treat the new battery carefully so it does put out
the full rated AH. (Recharge it immediately, don't leave it charging all
week and top charge just before the flight.)

Bill Daniels

[Jim Vincent]

>Recharge it immediately, don't leave it charging all
>week and top charge just before the flight.)
>

IMO, top charging does not help. Most of the articles I've read on the care
and feeding of batteries advocate taking the battery off charge at least 8
hours before use. That may not be practical for most of us since that would
mean taking the battery off around 4 in the morning if you'r planning on taking
off at noon.

What I've found works the best is a good state of the art charger tailored to
the chemistry of your specific battery. Different batteries have different
peak voltages, charge rates, etc.

The best charger I've found is the HPX10 charger manufactured by Xenotronix, on
the web at http://www.xenotronix.com/products/leadacid/hpx-10.htm. If your
model is not listed, contact them and they can tweak the specs to your battery.

With this charger, my battery has increased capacity and should last many
seasons.

Jim Vincent
CFIG
N483SZ

[BTIZ]

>
>
> I know they are "exempt" from the rule - but that's bad terminology
really,
> they are simply compliant with the rule by not having transponders - not
> really "exempt" from the rule in the pure form of the regulatory meaning -
I
> thought Ian was alluding to some other exemption the SSA had (besides the
> data plate exemption).

ahhh.. true in that regard Jim... many people read the "except as noted in
para".. and an "exemption" instead of an "exception".. and I fell into his
trap.. thanx BT

[Bob Greenblatt]

On 2/26/04 5:33 PM, in article , "Roger
Felton" > wrote:

> In *theory* the "standard" 7.5 AH battery will power your transponder for 8+
> hours. Sealed Lead Acid batteries rarely achieve their advertised capacity in
> ideal conditions even when new. Now age that battery for a year or two. Throw
> in
> some repeated deep discharges. Now cold soak the battery for a few hours at
> altitude. I think you'll find that your 7.5 AH battery has something more like
> 4
> AH (or less) useable capacity. So you up the size of the battery to 12 AH. Yes
> you can always find somewhere to put the additional equipment. However a real
> problem is that there are a significant number of ships out there that are at
> (or over) their max. allowable weight for non-lifting parts, and the 10+ lbs
> of
> the additional battery and associated wiring is simply too much.
> I think that ATC would much rather see you suddenly pop up on their radar
> when
> approaching airspace than suddenly dissappear (from a dead battery) while in
> or
> overflying their airspace.
>
> RF
>
> Bob Greenblatt wrote:
I agree, but nevertheless am not sympathetic. You should load test your
batteries yearly. Get a new one if it's marginal. Lose some weight.

--
BobGreenblattAtmsnDotcom <--fix this before responding

[Mike Koerner]

I agree with Roger. I have a 33 AH battery in my sailplane and it won't
drive my transponder and encoder for a full day's flight often at cold
temperatures. Admittedly it's not a new transponder (I've had it since '84)
and it not a new battery (I'll replace it this season and see if that
helps). But even at 33 AH, I'd still have problems stringing flights
together (4 straight-out, crewless diamonds in four days in 2001 ;-).

I was surprised to hear about the SSA transponder petition (thanks Eric) but
I'm VERY pleased with it. It addresses a legal dilemma I've faced for a long
time. My thanks for the efforts of all involved. Here's how I responded to
the docket:


I strongly support the proposed exemption to transponder-on requirements for
gliders. This exemption will increase safety by encouraging the use of
transponders in gliders while operating in high traffic areas.


Many gliders have no electrical system at all. The use of transponders in
these aircraft is neither practical nor possible.



Other gliders have electrical systems but they do not have a means of
electrical power generation. These gliders are dependant on batteries.



A few gliders with battery-powered electrical systems have transponders. My
sailplane is one these.



However, the battery in my sailplane is not capable of operating my
transponder continuously. I often make flights of 8 to 10 hours duration and
300 to 500 miles distance. Despite having installed a much larger battery
than the sailplane was initially designed for, I am still unable to operate
the transponder for more than a few hours at a time.



Most of my soaring occurs in at low altitudes, in remote areas, off airways
where there are no other aircraft. Two significant exceptions, however, are
when I fly past Reno or Las Vegas. During the period of time that I am in
the vicinity of these cities, I would like to operate my transponder.



Under current regulations however, I can not do this. I am required to leave
my transponder on throughout the flight. But with the transponder on
continuously, my battery power is fully expended before I ever reach Nevada
(I fly out of Southern California).



The proposed exemption is a very sensible solution to this dilemma. It
allows me to operate the transponder in the areas where it may be useful,
instead of running the battery dead operating it in areas where it is not.



Mike Koerner