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.