Transponder petition

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."

"Ian Cant" wrote

", and it just might open up an adverse review of our existing exemption."

I suppose I could go search for it myself, but I was wondering what existing
exemption do we have? By "we" I presume you mean an exemption granted to the
SSA? The external data plate exemption?

Jim

Jim.. gliders and balloons and aircraft without an engine driven electrical
system are exempt from certain parts of FAR91.215, not required above
10,000MSL, not required in the ModeC veil around Class B (30nm and below the
ceiling of the local ClassB). But if you have one in the glider, "all
aircraft equipped with a transponder must have it operational at all times
they are airborne."

What the SSA "appears" to be looking for, is an "allowance" to turn the
transponder off when away from "high traffic areas" to save battery energy,
so they can still have an "operational transponder" that they can turn back
on when they return to the "high traffic volume area" instead of having a
dead battery, no radio and no glide computer.

BT

"Jim Phoenix" wrote in message
...

"Ian Cant" wrote

", and it just might open up an adverse review of our existing exemption."

I suppose I could go search for it myself, but I was wondering what
existing
exemption do we have? By "we" I presume you mean an exemption granted to
the
SSA? The external data plate exemption?

Jim

BT,

I know they are "exempt" from the rule - but that's bad terminology really,
they are simply compliant with the rule by not having transponders - not
really "exempt" from the rule in the pure form of the regulatory meaning - I
thought Ian was alluding to some other exemption the SSA had (besides the
data plate exemption).

My additional respectful comment to Ian is that the FAA is not going to
review any "previous or current exemption" - there isn't one. I presume the
FAA could try to re-write the rule - but you can bet that would lead to a
brick wall called the AOPA and EAA. As pointed out above by others in this
thread - gliders are a minority of the aircraft that enjoy the provisions of
the existing rule allowing aircraft *originally certificated* without an
electrical system to not have a transponder in certain airspace... blah blah
blah ad infinitum.

I see a dissenting vote has made a comment to the rule. It will be fun to
read the final rule and the FAA's reply to the comments - but I suppose you
have to like this sort of thing ;-)

This is a real tempest in a teapot, isn't it? My personal vote is to save my
coppers and buy a transponder someday, I really like the idea of showing up
big and bright on everybodys radars and TCAS's, and if I don't maybe I'll be
lucky enough to still be able to use my chute.

Jim

OK, I can't keep quiet on this any longer. I agree completely that adding a
transponder is likely to increase safety, that's why I did it. I think the
exemption is meaningless - we don't need one! If you are going to add a
transponder to your aircraft (and I urge you to do so) you ought to insure
that you have enough power to drive it and the rest of your electronics for
the duration of your expected flights. To do otherwise is simply
irresponsible.

A fully charged "standard" 7.5 AH battery will power one of the newer
transponders and encoders for more than 8 hours. And, that's here on the
east cost where the interrogations are almost constant. Why would anyone go
to the trouble of installing a transponder and encoder and not insure that
there is enough power to take advantage of it?

It's so simple to conform to the FARs (or CFRs or whatever they are) as they
presently exist. Attempting to achieve an exemption is misdirection of a lot
of energy better spent elsewhere.

So, put in a transponder and some extra batteries. There's always room. If
you can't find any think harder.

--
bobgreenblattATmsnDOTcom --fix this before responding

In *theory* the "standard" 7.5 AH battery will power your transponder for 8+
hours. Sealed Lead Acid batteries rarely achieve their advertised capacity in
ideal conditions even when new. Now age that battery for a year or two. Throw in
some repeated deep discharges. Now cold soak the battery for a few hours at
altitude. I think you'll find that your 7.5 AH battery has something more like 4
AH (or less) useable capacity. So you up the size of the battery to 12 AH. Yes
you can always find somewhere to put the additional equipment. However a real
problem is that there are a significant number of ships out there that are at
(or over) their max. allowable weight for non-lifting parts, and the 10+ lbs of
the additional battery and associated wiring is simply too much.
I think that ATC would much rather see you suddenly pop up on their radar when
approaching airspace than suddenly dissappear (from a dead battery) while in or
overflying their airspace.

RF

Bob Greenblatt wrote:

OK, I can't keep quiet on this any longer. I agree completely that adding a
transponder is likely to increase safety, that's why I did it. I think the
exemption is meaningless - we don't need one! If you are going to add a
transponder to your aircraft (and I urge you to do so) you ought to insure
that you have enough power to drive it and the rest of your electronics for
the duration of your expected flights. To do otherwise is simply
irresponsible.

A fully charged "standard" 7.5 AH battery will power one of the newer
transponders and encoders for more than 8 hours. And, that's here on the
east cost where the interrogations are almost constant. Why would anyone go
to the trouble of installing a transponder and encoder and not insure that
there is enough power to take advantage of it?

It's so simple to conform to the FARs (or CFRs or whatever they are) as they
presently exist. Attempting to achieve an exemption is misdirection of a lot
of energy better spent elsewhere.

So, put in a transponder and some extra batteries. There's always room. If
you can't find any think harder.

--
bobgreenblattATmsnDOTcom --fix this before responding

I know they are "exempt" from the rule - but that's bad terminology
really,
they are simply compliant with the rule by not having transponders - not
really "exempt" from the rule in the pure form of the regulatory meaning -
I
thought Ian was alluding to some other exemption the SSA had (besides the
data plate exemption).

ahhh.. true in that regard Jim... many people read the "except as noted in
para".. and an "exemption" instead of an "exception".. and I fell into his
trap.. thanx BT

I don't agree with you reading of the request. I believe it is for relief
from 91.215(c) *unless* with 40 miles of Class B and 20 of Class C. So if
you are above 10,000' MSL, and at least the appropriate distances from Class
B & C, then the relief sought would apply. And if memory servers,
calibration of Mode C is only applicable to IFR.

Ivan

"Ian Cant" wrote in message
...
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."