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 he

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


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

https://www.federalregister.gov/arti...nt-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-pla...956113/?no-ist


Reference Sagetech: http://www.sagetechcorp.com/unmanned.../#.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