SSA petition to allow transponder to be turned off

Tim Mara wrote:
you know..I sell transponders and have sold a lot of them to glider
owners....I have however been afraid from the start that once the FAA starts
to recognize larger numbers of gliders with transponders it could come back
to haunt us all...If we lose the exemption requiring transponders in
gliders, and we might now that the FAA sees that they can indeed be operated
from our battery power it could be just the straw that breaks the camels
back

First, this cat jumped out of the bag a couple of years ago: the FAA
knows about the Becker, and Microair, and they'll know about the Filser
and the others, as they become available.

....Soaring as a sport isn't growing even now in the US, adding more cost
to owning and operating gliders surely will not help...to many clubs and
many owners adding $2000+ to each and every glider plus the added expense to
keep them certified and working will certainly take more club type and older
gliders off line.

Second, I've been told by my director that the FAA is not keen to burden
the sport with another requirement; that they understand our situation.

snip

I hear a lot of grumbling about near misses while flying in and around
approaches to busy metro airports, while flying near military bases and so
on.....the simple truth is, if this is happening and I'm sure it is, the
answer is not in adding one more piece of electronics, the answer is in not
flying in these busy corridors.
...doing so will eventually cause this
airspace to be closed to all non-commercial aircraft and the eventual loss
of this and other airspace where traffic is not a problem

These corridors also have general aviation airplanes flying in them, so
we'd have a lot of allies if such restrictions were ever attempted. I
think losing the use airspace just because transponder equipped gliders
are flying in it is most unlikely. The idea that this could somehow lead
to losing airspace for general avaiation in areas that AREN'T busy is
incredible to me.

and before we all
know it an end to soaring as we know it today in this country...Public
opinion will outnumber the small number of pilots wishing to fly for fun.
Let the evening news, 60 minutes or 20/20 run some special on the dangers
glider pilots pose to airliners and every politician will support the public
opinion polls and side with them to get votes.

These doomsday scenarios are so hard to predict, I don't think we should
even try. Keep in mind that a there are a lot more general avaition
airplanes than there are gliders, and they fly into these busy areas a
lot more than we do, yet no one is suggesting they rip out their
transponders and just fly in the rural areas.

....the more we depend on
electronics the more we are keeping our heads down in the cockpits.

Transponder use doesn't do this: turn it on when you turn on the radio,
turn it off when you land. You don't look at it, you don't tune it, you
don't listen to it. It's just there.

...with
GPS and pocket nav's to guide us, flight computers to calculate for us and
transponders to shield (?) us we are also forgetting what we started doing
this for to begin with....look outside, there is real beauty to be seen
through the clear mecaplex that surrounds us....fly safe, but always fly for
fun

These are worthy issues, but separate from transponders.

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Eric Greenwell
Washington State
USA

Mark Zivley wrote:

I'm definitely in favor of gliders w/ transponders and see this as
another step towards conserving battery power for when you need it. i.e.
when you are near a high traffic airspace where the chances of crossing
paths with someone with either TCAS or ATC coverage is increased.

What about a discrete transponder code specifically for gliders??????

I understand that there is at least one area which has an agreement to
use (seems like it's 0440 or something similar) a code specifically for
gliders. Why not also work on getting this code agreed to for all of
the U.S. at the same time that they are working on the below mentioned
waiver.

Contacting your director will likely get you the latest information on
this subject, but here's what I was told last year:

-The Reno area does use 0440, and it works for them, because there are
many gliders flying there that do have transponders, and the controllers
are familiar with how a glider operate, so knowing which blip is a
glider is useful.

-The above is not true for most of the USA.

-The specific code, 0440, is used for other things around the country -
not many, but it means other changes would have to be made.

-Some have suggested making gliders easily identifiable by a specific
code might not work in our favor because controllers and others would
know "who" to be annoyed at, justified or not.

-So, the last I heard, doing a special code was likely to be on a
cas-by-case basis.

Keep up the good work!

Mark

Eric Greenwell wrote:

Check out the SSA website for the complete info on this petition, and
consider commenting to the FAA (comments due by March 1, via web site,
mail, fax, "eRulemaking portal"):

SSA Transponder Petition Published
By Dennis Wright
Posted Thursday, February 19, 2004

The SSA petition asks that SSA members be allowed to operate
transponder-equipped gliders with the transponders turned off, when
the glider is being operated more than 40 nautical miles from the
primary airport in Class B airspace and more than 20 nautical miles
from the primary airport in Class C airspace. Currently, Federal
Aviation Regulation 91.215[c] requires that all aircraft equipped with
a transponder and operating in controlled airspace have the
transponder on.

...more on the web site



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Eric Greenwell
Washington State
USA

"Eric Greenwell" wrote in message
...

SNIP-----
....the more we depend on
electronics the more we are keeping our heads down in the cockpits.

SNIP------

Eric Greenwell
Washington State
USA


Eric, I think you've been flying gliders as long as I have, but I must
strongly disagree with the statement above. I remember flying cross country
without a single electronic device - not even a radio. (A good retrieve
crew had to know how to set the dwell and adjust the carburetor on a Chevy
as well as how to outsmart the phone company with person-to-person, collect
calls.)

You can't argue that folding maps, scribbling notes on pads and working a
"prayer wheel" trying to make navigation by pilotage work when spending half
the time flying in tight circles is less distracting. Often you could add
trying to get it a pellet vario unstuck at the same time. That was a
serious "heads down" situation.(I still carry a well marked sectional and
little notebook with all the important facts and numbers.)

By comparison, grabbing a quick glance at a computer screen that tells me
everything and them returning my gaze outside is vastly safer and easier.
The only time "heads down" becomes a problem is when a pilot doesn't know
how to work the electronics. The present problem is pilots trying to learn
to use avionics in the air instead of on the ground. (A good season prep:
go sit in your glider for a couple of hours reading manuals and pushing
buttons.)

Like it or not, ubiquitous computing is a part of everyday life - including
gliding - and the "good 'ole days" weren't all that great.

Bill Daniels

Hi Bill,

I agree with you completely. The quoted statement is Tim Mara's, not mine.

Bill Daniels wrote:

"Eric Greenwell" wrote in message
...

SNIP-----

....the more we depend on
electronics the more we are keeping our heads down in the cockpits.

SNIP------


Eric Greenwell
Washington State
USA



Eric, I think you've been flying gliders as long as I have, but I must
strongly disagree with the statement above. I remember flying cross country
without a single electronic device - not even a radio. (A good retrieve
crew had to know how to set the dwell and adjust the carburetor on a Chevy
as well as how to outsmart the phone company with person-to-person, collect
calls.)

You can't argue that folding maps, scribbling notes on pads and working a
"prayer wheel" trying to make navigation by pilotage work when spending half
the time flying in tight circles is less distracting. Often you could add
trying to get it a pellet vario unstuck at the same time. That was a
serious "heads down" situation.(I still carry a well marked sectional and
little notebook with all the important facts and numbers.)

By comparison, grabbing a quick glance at a computer screen that tells me
everything and them returning my gaze outside is vastly safer and easier.
The only time "heads down" becomes a problem is when a pilot doesn't know
how to work the electronics. The present problem is pilots trying to learn
to use avionics in the air instead of on the ground. (A good season prep:
go sit in your glider for a couple of hours reading manuals and pushing
buttons.)

Like it or not, ubiquitous computing is a part of everyday life - including
gliding - and the "good 'ole days" weren't all that great.

Bill Daniels


--
-----
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Eric Greenwell
Washington State
USA

I'd have to disagree about the predictability of airspace loss. It
was predictable when the FAA came into existance. So far, the
predictions have been met or exceeded.

The predicton is simple. If it is possible to use a rule to restrict
those who now use the airspace, it will be used to restrict those
who use the airspace. The second corollary is that all rules are
restrictions in one form or another.

I'm trying to think of an example where the opposite has happened.
I can think of no airspace that was unavailable in the past and is
now available.

The trick is to decide when restrictions are really required. I contend
that the airspace rules that were in effect in 1959 were just as safe
as what we have now.


In article , Eric Greenwell
wrote:
Tim Mara wrote:
you know..I sell transponders and have sold a lot of them to glider
owners....I have however been afraid from the start that once the FAA starts
to recognize larger numbers of gliders with transponders it could come back
to haunt us all...If we lose the exemption requiring transponders in
gliders, and we might now that the FAA sees that they can indeed be operated
from our battery power it could be just the straw that breaks the camels
back

First, this cat jumped out of the bag a couple of years ago: the FAA
knows about the Becker, and Microair, and they'll know about the Filser
and the others, as they become available.

....Soaring as a sport isn't growing even now in the US, adding more cost
to owning and operating gliders surely will not help...to many clubs and
many owners adding $2000+ to each and every glider plus the added expense to
keep them certified and working will certainly take more club type and older
gliders off line.

Second, I've been told by my director that the FAA is not keen to burden
the sport with another requirement; that they understand our situation.

snip

I hear a lot of grumbling about near misses while flying in and around
approaches to busy metro airports, while flying near military bases and so
on.....the simple truth is, if this is happening and I'm sure it is, the
answer is not in adding one more piece of electronics, the answer is in not
flying in these busy corridors.
...doing so will eventually cause this
airspace to be closed to all non-commercial aircraft and the eventual loss
of this and other airspace where traffic is not a problem

These corridors also have general aviation airplanes flying in them, so
we'd have a lot of allies if such restrictions were ever attempted. I
think losing the use airspace just because transponder equipped gliders
are flying in it is most unlikely. The idea that this could somehow lead
to losing airspace for general avaiation in areas that AREN'T busy is
incredible to me.

and before we all
know it an end to soaring as we know it today in this country...Public
opinion will outnumber the small number of pilots wishing to fly for fun.
Let the evening news, 60 minutes or 20/20 run some special on the dangers
glider pilots pose to airliners and every politician will support the public
opinion polls and side with them to get votes.

These doomsday scenarios are so hard to predict, I don't think we should
even try. Keep in mind that a there are a lot more general avaition
airplanes than there are gliders, and they fly into these busy areas a
lot more than we do, yet no one is suggesting they rip out their
transponders and just fly in the rural areas.

....the more we depend on
electronics the more we are keeping our heads down in the cockpits.

Transponder use doesn't do this: turn it on when you turn on the radio,
turn it off when you land. You don't look at it, you don't tune it, you
don't listen to it. It's just there.

...with
GPS and pocket nav's to guide us, flight computers to calculate for us and
transponders to shield (?) us we are also forgetting what we started doing
this for to begin with....look outside, there is real beauty to be seen
through the clear mecaplex that surrounds us....fly safe, but always fly for
fun

These are worthy issues, but separate from transponders.

d b wrote:
I'd have to disagree about the predictability of airspace loss. It
was predictable when the FAA came into existance. So far, the
predictions have been met or exceeded.

The predicton is simple. If it is possible to use a rule to restrict
those who now use the airspace, it will be used to restrict those
who use the airspace. The second corollary is that all rules are
restrictions in one form or another.

I'm trying to think of an example where the opposite has happened.
I can think of no airspace that was unavailable in the past and is
now available.

The Hanford nuclear reservation (near Richland, WA, where I live) had a
640 square mile, 10,000' restriction on it when I began to fly gliders
in the 70's. In the early '80s, the FAA badgered the DOE into dropping
that restriction, and now we fly freely over it.

The FAA's objections, along with others, have kept the Yakima Firing
Range restricted area (Washington state) from growing, for which we are
very thankful.

We have added several wave windows in Washington and Oregon over the
last 20 years, so we can now use Class A airspace that was previously
unavailable.

The Umatilla Depot TFR (Oregon) that was imposed after 9/11 was a 5 mile
radius restriction to 10,000'; it was recently reduced to one fifth of
that and to only 5000'.

I'm sure you will understand why I might have different view of the FAA.
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Eric Greenwell
Washington State
USA

At the SSA convention, the discrete glider code was discussed again and
nothing's really changed from what Eric states. Unfortunately, code
assignments are exhausted in some regions and there is no likelihood of
securing a national glider code in any near term. The next time the FAA
asks Congress for billion$ to update the obsolete and failing system (FUD)
again, I suggest you write your representative WRT moving from 8-bit to
16-bit
codes for future expansion, since we're in the 21st century now. Since
there's no prospect of a single discrete code, there's no incentive for
development of a lower cost single code transponder for gliders. Squawk
09AF works for me. Can't imagine the situation getting any better in the
future.

In many cases this might seem to only require reasonable firmware and
software changes and wouldn't necessarily obsolete a lot of older
equipment. Like to hear if this is technically feasible or not.

Or maybe ask the FAA to assign the 'X' pulse to gliders exclusively. The
addition or supression of the X pulse (opposite of what it now does during a
reply) could ident the airframe as a glider to any interrogation. May open
the door for a single code with some software, firmware updates.

See http://www.airsport-corp.com/modec.htm

Frank Whiteley


"Eric Greenwell" wrote in message
...
Mark Zivley wrote:

I'm definitely in favor of gliders w/ transponders and see this as
another step towards conserving battery power for when you need it. i.e.
when you are near a high traffic airspace where the chances of crossing
paths with someone with either TCAS or ATC coverage is increased.

What about a discrete transponder code specifically for gliders??????

I understand that there is at least one area which has an agreement to
use (seems like it's 0440 or something similar) a code specifically for
gliders. Why not also work on getting this code agreed to for all of
the U.S. at the same time that they are working on the below mentioned
waiver.

Contacting your director will likely get you the latest information on
this subject, but here's what I was told last year:

-The Reno area does use 0440, and it works for them, because there are
many gliders flying there that do have transponders, and the controllers
are familiar with how a glider operate, so knowing which blip is a
glider is useful.

-The above is not true for most of the USA.

-The specific code, 0440, is used for other things around the country -
not many, but it means other changes would have to be made.

-Some have suggested making gliders easily identifiable by a specific
code might not work in our favor because controllers and others would
know "who" to be annoyed at, justified or not.

-So, the last I heard, doing a special code was likely to be on a
cas-by-case basis.

Keep up the good work!

Mark

Eric Greenwell wrote:

Check out the SSA website for the complete info on this petition, and
consider commenting to the FAA (comments due by March 1, via web site,
mail, fax, "eRulemaking portal"):

SSA Transponder Petition Published
By Dennis Wright
Posted Thursday, February 19, 2004

The SSA petition asks that SSA members be allowed to operate
transponder-equipped gliders with the transponders turned off, when
the glider is being operated more than 40 nautical miles from the
primary airport in Class B airspace and more than 20 nautical miles
from the primary airport in Class C airspace. Currently, Federal
Aviation Regulation 91.215[c] requires that all aircraft equipped with
a transponder and operating in controlled airspace have the
transponder on.

...more on the web site



--
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Eric Greenwell
Washington State
USA

If the floor of "class A" was the same now as it was in 1958, would
you need the window as much? In your examples, the areas
were smaller or didn't exist.

The FAA really got nasty when Dole was administrator.

In article , Eric Greenwell
wrote:
d b wrote:
I'd have to disagree about the predictability of airspace loss. It
was predictable when the FAA came into existance. So far, the
predictions have been met or exceeded.

The predicton is simple. If it is possible to use a rule to restrict
those who now use the airspace, it will be used to restrict those
who use the airspace. The second corollary is that all rules are
restrictions in one form or another.

I'm trying to think of an example where the opposite has happened.
I can think of no airspace that was unavailable in the past and is
now available.

The Hanford nuclear reservation (near Richland, WA, where I live) had a
640 square mile, 10,000' restriction on it when I began to fly gliders
in the 70's. In the early '80s, the FAA badgered the DOE into dropping
that restriction, and now we fly freely over it.

The FAA's objections, along with others, have kept the Yakima Firing
Range restricted area (Washington state) from growing, for which we are
very thankful.

We have added several wave windows in Washington and Oregon over the
last 20 years, so we can now use Class A airspace that was previously
unavailable.

The Umatilla Depot TFR (Oregon) that was imposed after 9/11 was a 5 mile
radius restriction to 10,000'; it was recently reduced to one fifth of
that and to only 5000'.

I'm sure you will understand why I might have different view of the FAA.

I'll get to my rant at the end.

First, a question: what happens if you turn off a transponder in
flight? Hypothetically, of course: would anybody notice? Would S&R
be sent out to look?

Second, a recollection: it's my recollection that ATC radar is
designed to filter out slow-moving targets. If that's the case,
transponders are only of any use to TCAD-equipped aircraft.
Apparently some ATC facilities are seeing the glider Xpdrs, so maybe
my recollection is wrong?

Third, evidently I now have a choice between a low-priced TCAD-type
device or a Xpdr. Having both is not an option: my panel is already
full, so stuff has to start coming out in order for me to put things
in.

Fourth, it is NOT illegal for me to turn off the TCAD-type device to
save my batteries, but it is illegal for me to turn of the Xpdr (my
home field is 33 nm from the primary airport). Score one for passive
rather than active collision avoidance. The passive device uses a lot
less power. Score two. The passive device is cheaper. Score three.

Fifth, it seems to me that an Xpdr should be fitted with a separate
battery, so that it doesn't threaten the much more important nav and
vario equipment by draining power from them. Similarly the Xpdr
should not drain the battery required to relight self-launchers.
Legally, I have no idea where you stand when you have a "working" Xpdr
on board, "turned on" but with a dead battery. But it's safer than
the alternative.

Now my rant: bad enough that regulators make dumb laws, but worse when
SSA compounds the error. Here's why -

Regulations that impose requirements on safety equipment that isn't
even required in the first place are logically bad law (not that bad
law is particularly unusual) because they create a disincentive to the
use of safety equipment. It reminds me of the reg about parachutes:
if my chute is past its repack date, it's perfectly legal for me to
use a seat cushion instead and leave the chute in my car. If I take
the chute anyway (as a seat cushion), it's illegal and I can get
busted. My chute's always properly packed (go ahead, check) but
that's not the point. Which of our regulators wants to explain to a
grieving family that the totally unnecessary fatality was caused, not
by the out-of-date parachute (which probably would have worked fine),
but by a regulation that REQUIRED LEAVING IT ON THE GROUND!
Similarly, a regulation that requires the use of a transponder, if
fitted, when transponders are not required, is a regulation that
encourages people to... not fit transponders. Poor logic, bad law.

This request for an exemption suffers from the same faulty logic. The
place where transponders are most important is... around the primary
airports of Class B and Class C airspace. This exemption request
removes the disincentive to carrying Xpdrs everywhere... except where
Xpdrs are important!

Rant over.

Finbar wrote:

I'll get to my rant at the end.

First, a question: what happens if you turn off a transponder in
flight? Hypothetically, of course: would anybody notice?

Maybe. If you disappeared from a controllers screen, it would be
noticed. A TCAS equipped airliner might notice - I don't know if there
is an alert function for such an event.

Would S&R
be sent out to look?

No.


Second, a recollection: it's my recollection that ATC radar is
designed to filter out slow-moving targets.

That's primary radar, because of ground clutter problems. It would be a
most unusual situation to eliminate a transponder return. They certainly
don't do it out here in the Pacific Northwest - I've asked.

If that's the case,
transponders are only of any use to TCAD-equipped aircraft.
Apparently some ATC facilities are seeing the glider Xpdrs, so maybe
my recollection is wrong?

Yes, mainly because of a confusion between primary (skin reflection)
reflection processing and transponder return processing.


Third, evidently I now have a choice between a low-priced TCAD-type
device or a Xpdr. Having both is not an option: my panel is already
full, so stuff has to start coming out in order for me to put things
in.

Fourth, it is NOT illegal for me to turn off the TCAD-type device to
save my batteries, but it is illegal for me to turn of the Xpdr (my
home field is 33 nm from the primary airport). Score one for passive
rather than active collision avoidance. The passive device uses a lot
less power. Score two. The passive device is cheaper. Score three.

I've wondered about this, also. In addition to the advantages mentioned,
they are portable and easily moved from one aircraft to another. The Big
Question: is the pilot safer with something like the Proxalert than a
transponder? I know one glider pilot using one, so we'll have at least
on experienced opinion in a few months.

Fifth, it seems to me that an Xpdr should be fitted with a separate
battery, so that it doesn't threaten the much more important nav and
vario equipment by draining power from them.

Pilots choice: most pilots monitor their battery voltage, so they can
turn off the transponder if the voltage gets low.

Similarly the Xpdr
should not drain the battery required to relight self-launchers.

Again, pilots choice. Self-launchers typically have much larger
batteries than unpowered gliders (mine has 36 amp hours), so powering
the transponder AND still having enough to start isn't a problem at all.

Legally, I have no idea where you stand when you have a "working" Xpdr
on board, "turned on" but with a dead battery. But it's safer than
the alternative.

It's not required to be transmitting if your battery is dead.

Now my rant: bad enough that regulators make dumb laws, but worse when
SSA compounds the error. Here's why -

Regulations that impose requirements on safety equipment that isn't
even required in the first place are logically bad law (not that bad
law is particularly unusual) because they create a disincentive to the
use of safety equipment.

I think it's an oversight, rather than foolishness: airplanes ARE
required to have transponders, and this rule was written for them.
Gliders aren't required to have transponders, and when the rules were
written, they were extremely rare in gliders.

It reminds me of the reg about parachutes:
if my chute is past its repack date, it's perfectly legal for me to
use a seat cushion instead and leave the chute in my car. If I take
the chute anyway (as a seat cushion), it's illegal and I can get
busted. My chute's always properly packed (go ahead, check) but
that's not the point. Which of our regulators wants to explain to a
grieving family that the totally unnecessary fatality was caused, not
by the out-of-date parachute (which probably would have worked fine),
but by a regulation that REQUIRED LEAVING IT ON THE GROUND!

It won't ever get explained that way: the puzzled regulator will be
dumbfounded that a pilot was so clueless, that he owned a parachute and
didn't take it along. The family should also be dumbfounded, as I would
be. Get it packed if the rule bothers you, carry it if doesn't. Sheesh.
Give it to a passenger...then I think you should have packed properly.

Similarly, a regulation that requires the use of a transponder, if
fitted, when transponders are not required, is a regulation that
encourages people to... not fit transponders. Poor logic, bad law.

I believe that pilots that WANT to carry a transponder do so, and those
that want to turn if off when far from heavy traffic, also do so. No one
has been busted for turning off his transponder, and lots of pilots do.
I also believe a lot of pilots that don't want to use a transponder, use
this rule as a convenient excuse. Basically, I think, getting this
exemption is about removing this excuse. I don't think there will be
sudden surge in transponder installations by glider pilots that can't
stand to be scofflaws. Even noticed how many pilots fly near cloudbase?

This request for an exemption suffers from the same faulty logic. The
place where transponders are most important is... around the primary
airports of Class B and Class C airspace. This exemption request
removes the disincentive to carrying Xpdrs everywhere... except where
Xpdrs are important!

I think you are saying it's a good idea. I do.

--
-----
change "netto" to "net" to email me directly

Eric Greenwell
Washington State
USA