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."