Gliders Transponder exemption and Project EVA

Soarist

I will readily admit that I no longer make it a point to read the magazine
cover to cover or the endless RAS postings.

But I doubt that I was the only one shocked by the recent post on RAS about
the FAA Advance Notice Of Proposed Rulemaking (Anprm) regarding requests
for public comment on removal of the current transponder exception for
gliders.

It was even more shocking to stumble upon the fact that this issue was
already being addressed thru Project EVA which stands for ‘Electronic
Visibility via ADS-B’– is a joint partnership project aiming to enhance
flight safety by improving the visibility of general aviation (GA) pilots
to each other and to air traffic control through the transmission and
reception of Automatic Dependent Surveillance -Broadcast data and assessed
thru the review
of the compatibility of the different devices like LPAT, TABS, Mode S
transponders and Power-FLARM – and focuses on how traffic alerts support
the ‘See and Avoid’ concept.

TSO C199 is a standard for the “Traffic Awareness Beacon System (TABS)
for light aircraft without electrical systems, exempted from ADS-B OUT,
such as gliders, balloons and other aircraft with non-certified electrical
systems,�

http://www.nats.aero/projecteva/

So do some homework by at least reviewing the attached urls. Then petition
the SSA to step up to the plate and use some of it’s highly educated
and well written pilot members to come up with a comprehensive letter the
membership can modify and send to the FAA. This letter should request
a delay of any planned removal of the current transponder exception for
gliders while these new low cost low power systems designed for aircraft
with non-certified electrical systems are brought on line to provide the
necessary electronic visibility via ADS-B.

There are numerous other issues that should be included, such as what
options will be available to a pilot who has failing battery power. Will
he be
allowed to turn of a transponder to maintain other safety of flight
nstruments like varios, radio or supplemental navigation aids. What would
be his options if the battery falls to the point of the transponder going
off line, will he be required to land immediately, or face operating in
violation of the regulations? What if he is far from home or even a safe
airport for landing.

Additionally the FAA needs to provide soaring with an immediate blanket
authorization for all gliders, Experimental and Standard airworthiness to
use the advanced technology LiFePo4 batteries that are fundamental for
powering the systems it may be dictating all gliders to have and use.

So many questions and so little time, only 56 days to get letters off to
the FAA, my 2 cents M Eiler

https://www.federalregister.gov/arti...nt-for-gliders

http://www.icao.int/APAC/Meetings/20...20briefing.pdf


http://fasvig.org/ads-b-nats-update-on-project-eva

http://www.auvsishow.org/auvsi2015/p...54&Na v=False

http://www.avweb.com/blogs/insider/A...-223824-1.html

http://www.icao.int/APAC/Meetings/20...fing%20FAA.pdf

http://www.trig-avionics.com/products/tn70/\

http://www.aviationpros.com/press_re...t-gps-solution

http://www.ainonline.com/aviation-ne...av-micro-i-gps

http://www.aero-news.net/index.cfm?d...e-8e3650e8d399

http://www.aopa.org/Pilot-Resources/...ADS-B-Selector

TABS/TSO-C199 has been mentioned on r.a.s quite a few times before. The SSA has had representation in the development of TABS/TSO-C199 and I expect/hope folks in SSA management are well aware of it. The TABS/TSO-C199 TSO document is available from the FAA TSO library at http://rgl.faa.gov/Regulatory_and_Gu...e?OpenFrameSet. Technical folks who care about this stuff really should read that TSO.

The title on the current ANPRM is a little confusing, it is *not* just about the transponder exemption, but also includes whether gliders should also keep their current ADS-B Out 2020 Carriage mandate exemption (which might have more severe financial consequences than removing the transponder exemption). And TABS/TSO-C199 is also discussed in that ANPRM and the folks at the FAA involved in this ANPRM are very well aware of TABS/TSO-C199. The FAA is specifically asking for feedback about the the overall picture of transponders, ADS-B Out and TABS, and I would expect any SSA response would need to, and would do so.

The USA glider community needs to be careful in dealing with a very complex situation. You've got some suggestions here and raise some very good issues, but the SSA needs to first think though the issues before devising what to do. There might for example while TABS/TSO-C199 is interesting and may have some benefits there may be arguments where TABS/TSO-C199 would *not* be the best thing to do.

I share your concern about the limited time available here this stuff needs to be worked though by an SSA team looking at it. My understanding is a team is being put together to do so. A public forum just does not seem the right place to try to discuss some of these complex and political issues.

I have seen little on TABS information to define, cost, installation or even if it will be acceptable to the FAA. I see the neat little 1"X1" GPS WAAS capable receivers, but no information on the rest of the TABS unit, power or antenna requirement.

Many (some?) glider owners and clubs are installing transponders on their own. The ADSB mandate for tow planes will be hard enough on most clubs. But a lot of clubs may not be operating within the 30nm Mode C veil and will not be required to equip their tow planes. Luckily we are starting to see new transponders with GPS to meet the ADSB out requirement at a reasonable cost.

Snips
At 18:49 22 June 2015, Darryl Ramm wrote:
I expect/hope folks in SSA management are well aware of it.
this stuff needs to be worked though by an SSA team looking at it. My
understanding is a team is being put together to do so. A public forum
just does not seem the right place to try to discuss some of these complex
and political issues.

While I would take issue with the implication that the average pilot is not
competent to openly discuss and positively contribute regarding this issue.
The fact remains that Darryl’s post seems to have effectively halted any
discussion on RAS and will likely lead to a correspondingly pathetic amount
of unfocused written replies to the FAA’s ANPRM.

Saying that the SSA has been involved but apparently is just now coming up
with a team that will need to first look at the issues before devising what
to do. Should hardly be expected to give comfort to the U.S. glider pilots
who will be financially and permanently impacted by changes to these
exemptions.

Although the transponder exemption applies to all aircraft which were not
originally certificated with an engine-driven electrical system. This
recent ANPRM specifically applies only to gliders. Airplanes being left
out can easily be attributed to the fact that AOPA has significant
influence with the FAA thru their well funded effective lobbying
capabilities.

Conversely when we asked why we were unable to get SSA support during our
own struggle with the FAA and Cal Trans with saving soaring at Cal City.
We were eventually informed by an SSA official, that was because the SSA is
a 501c3 organization and it is forbidden by law from lobbying.

My intention was to raise the Red flag on this issue so that pilots were
informed enough to decide if they wanted to get involved or stand back and
let whatever happens happen.

M Eiler

Snips
At 18:49 22 June 2015, Darryl Ramm wrote:
I expect/hope folks in SSA management are well aware of it.
this stuff needs to be worked though by an SSA team looking at it. My
understanding is a team is being put together to do so. A public forum
just does not seem the right place to try to discuss some of these complex
and political issues.

While I would take issue with the implication that the average pilot is not
competent to openly discuss and positively contribute regarding this issue.
The fact remains that Darryl’s post seems to have effectively halted any
discussion on RAS and will likely lead to a correspondingly pathetic amount
of unfocused written replies to the FAA’s ANPRM.

Saying that the SSA has been involved but apparently is just now coming up
with a team that will need to first look at the issues before devising what
to do. Should hardly be expected to give comfort to the U.S. glider pilots
who will be financially and permanently impacted by changes to these
exemptions.

Although the transponder exemption applies to all aircraft which were not
originally certificated with an engine-driven electrical system. This
recent ANPRM specifically applies only to gliders. Airplanes being left
out can easily be attributed to the fact that AOPA has significant
influence with the FAA thru their well funded effective lobbying
capabilities.

Conversely when we asked why we were unable to get SSA support during our
own struggle with the FAA and Cal Trans with saving soaring at Cal City.
We were eventually informed by an SSA official, that was because the SSA is
a 501c3 organization and it is forbidden by law from lobbying.

My intention was to raise the Red flag on this issue so that pilots were
informed enough to decide if they wanted to get involved or stand back and
let whatever happens happen.

M Eiler

While they say the ANPRM applies to gliders, I read this to mean a congress persons interpretation of the rule. The rule actually only mentions gliders twice. Removing the word gliders from the rule would only affect motorgliders aka aircraft with a engine driven power source.

I don't for minute think that they really mean to remove the exception for only gliders with engine driven power sources.

Brian

Marty, I would like to believe that individuals are doing due diligence and research before speaking (on the forum) or posting to the FAA comment page.. I know I am researching the TABS tech requirements and what that means to gliders or other battery only, or no battery aircraft. The FAA needs to allow battery and wiring installations with field approvals from knowledgeable IAs and DARs for standard certificated aircraft. Plus the monetary impact for the equipment. This cannot be applied to gliders only, although gliders may have the most impact above 10,000 MSL. Not many J-3 Cubs, balloons or hang gliders above 10K.

Plus there are a lot of people on safari, or contest flying right now. I do agree that this needs to be kept on the forefront so pilots do respond smartly to the FAA comment board.

BillT