I think there are two arguments going on here, each not in direct conflict with the other.

I think it's reasonable to claim that many feel ADS-B, PF, and Mode C Transponders (or any forthcoming technology) makes gliders more visible to traffic who would otherwise not 'see and avoid' a glider. I have not read many (if any) claims that adding any of the aforementioned instrumentation would make soaring unsafe.

Instead, counterpoints claim that 'see and avoid' is 'adequate' (post mid-air) or that the consequences of mandating any instrumentation is too costly for someone to continue soaring, especially for gliders with a low hull value or gliders without a native electrical system, do not directly respond to the discussion prompting the proposed mandate of the aforementioned equipment. Since discussions about past practice and the costly consequences of a mandate are not direct responses about the ANPRM, I anticipate the FAA will not give much, if any, weight to those responses.

I think a constructive discussion starts with the question, how can a glider's participation in the NAS be safer for everyone? I think we would all be surprised if we thought the FAA would publish this ANPRM and return with an answer of "nothing." For that reason, I feel that the SSA's response is short sighted and does not help us contribute to the FAA's process of rulemaking.

I commented directly on the ANPRM because I believe that the FAA will require something. That something ought to be standards of transmitted information, rather than a particular system, so that the wonderful minds in our community (or at Google) could innovate a balanced solution that does not cost very much, has low electrical draw from a battery, and allows us to be visible to fast moving traffic.

I empathize with several comments about the cost of adding equipment to a fleet of 2-33's. My PW-2 GAPA barely has enough instrumentation (and cockpit) to inform me that my vertical speed is 10kts down. But I fly in the congested northeast, and if I can avoid a close encounter on my way down by making it easier for some other pilot to see me, then I feel it is my responsibility to do so.

Andrew Serota