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?