SSA responds to ANPRM

No one has commented yet on the SSA response? Likely to be the biggest
impact to soaring in the U.S. in many many years. On the SSA site if you
haven't seen it yet. Maybe pilots flying out of lower states just don't
worry about it.

I was very happy to see it posted a week before the deadline to give
people a chance to read it before submitting their own response. Gave
some background info on the Reno crash that I hadn't heard before, about
rerouting big iron arrivals through the wave area, and the NTSB
investigator believing that was a contributing factor.

The comments about relying on PowerFlarm are not likely to be persuasive
to the FAA, they undoubtedly are well aware of it, and probably perceive
it as being an offshoot system with only minimal compatibility with the
nextgen system they're putting in place. There's more than a grain of
truth to that, although ADS-B is so poorly done it leaves the door open
to alternatives.

-Dave

On Tuesday, 11 August 2015 12:03:08 UTC-6, David Kinsell wrote:
No one has commented yet on the SSA response? Likely to be the biggest
impact to soaring in the U.S. in many many years. On the SSA site if you
haven't seen it yet. Maybe pilots flying out of lower states just don't
worry about it.

I was very happy to see it posted a week before the deadline to give
people a chance to read it before submitting their own response. Gave
some background info on the Reno crash that I hadn't heard before, about
rerouting big iron arrivals through the wave area, and the NTSB
investigator believing that was a contributing factor.

The comments about relying on PowerFlarm are not likely to be persuasive
to the FAA, they undoubtedly are well aware of it, and probably perceive
it as being an offshoot system with only minimal compatibility with the
nextgen system they're putting in place. There's more than a grain of
truth to that, although ADS-B is so poorly done it leaves the door open
to alternatives.

-Dave

Thanks for the heads up. Interesting read and I am glad the SSA put the effort into this response. I do not agree with all the facts and opinions but since I did not send in a response to the SSA or FAA (yet) I am happy to live with the results

On Tue, 11 Aug 2015 11:22:11 -0700, Ron Gleason wrote:

On Tuesday, 11 August 2015 12:03:08 UTC-6, David Kinsell wrote:
No one has commented yet on the SSA response? Likely to be the biggest
impact to soaring in the U.S. in many many years. On the SSA site if
you haven't seen it yet. Maybe pilots flying out of lower states just
don't worry about it.

I was very happy to see it posted a week before the deadline to give
people a chance to read it before submitting their own response. Gave
some background info on the Reno crash that I hadn't heard before,
about rerouting big iron arrivals through the wave area, and the NTSB
investigator believing that was a contributing factor.

The comments about relying on PowerFlarm are not likely to be
persuasive to the FAA, they undoubtedly are well aware of it, and
probably perceive it as being an offshoot system with only minimal
compatibility with the nextgen system they're putting in place.
There's more than a grain of truth to that, although ADS-B is so poorly
done it leaves the door open to alternatives.

-Dave

Thanks for the heads up. Interesting read and I am glad the SSA put the
effort into this response. I do not agree with all the facts and
opinions but since I did not send in a response to the SSA or FAA (yet)
I am happy to live with the results


Currently I'm seeing only 145 responses, posted through the 12th. AOPA
has posted one, substantially similar to SSA saying the current situation
is adequate. The lack of response so far will likely lead to the FAA
proceeding down the current path of removing the glider exemption from
10K to 18K feet.

http://tinyurl.com/qb4gmao

Surprised at some of the comments on RAS, some people think this is just
about transponders. It's about transponders and the ADS-B Out mandate,
there is little chance FAA would require transponders and add a new
exemption for ADS-B.

People keep bringing up PowerFlarm, those comments at best are nothing
more than an irritation to FAA, there is no possibility that PF will be
accepted as a suitable alternative to ADS-B. The FAA and pilots of
powerplanes want to see the glider traffic, and PF doesn't provide that.

I've seen the suggestion that gliders be allowed to turn off transponders/
ADS-B at their discretion to help with the power problem, that's a non-
starter also. Remember the Reno glider was transponder equipped and it
was intentionally turned off. I think I've heard the battery hadn't been
charged after a previous flight, not sure if that's true.

SSA brought up that only 17% of aircraft are TCAS equipped, but those
tend to be large, expensive, high capacity planes that fly much more
often than others. They're also the type that if involved in a collision
with a glider, the sport could get shut down. But in any case, any
discussion about TCAS is backwards-looking, many of those same aircraft
are already equipped with ADS-B both in and out. This ANPRM is about ADS-
B, regardless of what it says in the title.

A surprising number of comments both here and to the FAA have said all
gliders should be transponder equipped (which will certainly mean ADS-B
out equipped). Really folks? A trainer flying from a low elevation
airport, far away from a large airport, and it's supposed to be
equipped? The 10K requirement for mandatory transponder usage is of
course arbitrary, but isn't it unreasonable to require it there with much
more numerous small Cessna's buzzing around under 10K without the
requirement?

The current best options for ADS-B out in gliders are low-power
transponders like the Trig TT22, with a horrendously over-spec'd and over-
priced GPS source added. The TT22 power is listed as 6 watts typical,
significant but not crippling for a glider. I fly with an older Becker
mode C, entire panel is powered from a large battery and solar cells,
never have to supply additional charging. Flexible solar cells are still
quite expensive when purchased for a glider, they haven't come down in
line with costs for other cells.

Current thinking on TABS appears to be incremental changes to the above
to get the cost down:

http://tinyurl.com/pxlk2xd

That presentation talks about commercial grade GPS units that have been
screened. At least they're showing flexibility in the requirements. The
current TSO'ed WAAS units add so much to the installation cost with
nebulous benefits for glider installations.

ADS-B Out sends signals to local aircraft for collision avoidance, as
well as to the ground stations for retransmission on the other
frequency. Of course that's also needed for TIS-B and FIS-B traffic and
weather. The 250 watt peak power of a Class 1 transponder is not needed
for short-range air to air collision avoidance, but that's where we're
headed for a normal ADS-B out installation. Not sure what the peak power
from PF is, but certainly a lot less than 250 watts.

Just a couple days left, but really need more submissions to the FAA in
order to shape the regulations into something acceptable for gliders.
Bringing down the peak power requirements while still allowing operation
to 18K is at the top of my list, along with continued work on make the GPS
requirements reasonable. Frankly, I don't think more "We're OK, some of
us use PF" comments will be productive in changing the course of the
regulations. Airliners want to see glider traffic on their TCAS or ADS-B
In, knowing a glider might get out of the way if equipped, and the PF is
working, isn't adequate.

-Dave

I personally disagree with the SSA response. I have responded directly to the FAA.

I think all gliders should have transponders all the time. Whether we like it or not, we must coexist with the rest of the aviation traffic in the airspace we share. You read that correctly, share, we do not own the airspace we fly in. If we have another collision between a glider and a substantial powered aircraft we are going to wish all we had to deal with was a low level FAA rule making decision. Transponders are a very important part of this coexistence. They are not particularly expensive and modern implementations are power efficient.

FLARM is a very narrow minded slice of that coexistence. It warns us of other gliders and transponder equipped aircraft, but does not reciprocate by broadcasting your own location to other airplanes. It is very low power with no installation standards and thus of dubious range and certainty, especially for fast movers. There is absolutely no way FLARM will ever be approved by the FAA as a substitute for a transponder.

We have an approved traffic system in the USA and most of the rest of the world, it is called ADS-B. For all of its faults, it is interoperable between all types of aircraft in nearly every part of the world. They say that possession is 9/10ths of the law. If the sky was clouded with gliders squawking 1202 on mode S/ES ADS-B we would have a much better chance of getting the ATC's attention. Right now they barely realize we are here.

I basically agree with Mark.

That said, I do t have a transponder yet. I think it's time, and certainly by 2020 it will be time.

Let's hope they get the price down and quality up as much as possible.

FWIW:

1) Transponders will give a false sense of security and teach vigilant glider pilots to trust that ATC is keeping tabs on their location for traffic deconfliction. This will result in less situational awareness for some pilots. (It is inevitable)

2) Transponders do nothing to separate gliders from VFR traffic squaking VFR and tracking in or out of an uncontrolled airfield. Not everyone is talking to ATC or getting flight following. And despite popular opinion, not everyone has an onboard collision avoidance system. (At least everything at my flight school lacks this capability)

3) If an immediate requirement for Transponders in gliders with electrical systems is imposed all gliders without a transponder will be out $2000 now, and another $2000-$5000 in 5 years when they have to upgrade to ADS-B. Why not wait till 2020? (Can't put a price on safety, but the FAA sure can harm a sport and form of flight training by imposing expensive requirements. The pilot shortage is near!!!)

4) In relation to my first point, the Flarm unit is far superior in my mind because it improves a pilots situational awareness and allows the glider pilot the chance to see and avoid. Let's not kid ourselves, glider pilots are looking out the window a hell of a lot more than a Bonanza flying VFR for that $100 hamburger. I would rather know where they are than have them run into me and my shiney new transponder.

5) If I have a battery failure in flight under a transponder requirement, do I need to land immediately in the nearest farm field? It is more likely that a glider will run out of sufficient battery power than an aircraft with an engine driven electrical system. Once the batteries run out of power the glider is now back to the same situation it was prior to the requirement. Waiting for ADS-B has some benefit here as the smaller units being developed for UAS are quite energy efficient.

I realize Flarm cannot be the solution. But I do think encouraging the use of a device that adds situational awareness is far more effective than trusting that a ground based radar and ATC operator are going to have communications with the traffic.

I fully agree transponders leave much to be desired per the arguement for upgrading to ADSB.

One thing that irritates me a bit is the idea that FAA (and associated political talking heads) are currently trying their best to force me to put N numbers on my "toy" quadcopter's and outfit them with ADSB. Utterly ridiculous idea, right ;-) ? Hmmmm? Be careful what you ask for folks.

With that, I don't feel much like complaining about being asked to outfit my modern sailplane with ANY or some 2 way traffic avoidance equipment. In my glider (rural Michigan), I do regularly fly along the edge of two class C airspace (Lansing and Grand Rapids) and one B airspace (Detroit). I truly enjoy watching the commercial traffic flying all around me on FLARM during these moments. It is something fun to do since most pilots in MI wont buy a FLARM (either).

Perhaps I did not read the article very well. I thought the discussion was regarding a "potential" ADSB requirement for 2020, NOT a mandatory transponders now, then ADSB in 2020. Ill go back and re-read. I agree that would be a bit more harsh, agreed. Most of the glider community would $hi# a chicken, agreed. No surprise there.

On the other hand (see hobby drone regulations), I don't think the FAA is in the mood to mess around any longer. They want a complete air traffic control system and far less risk. They are covering their collective butts and of course...that costs us money. Remember, the government has no money. In fact they have -19 trillion and counting.

I would blame CNN and NPR to be honest. This is a favorite theme of theirs.. They have 1-3 stories per week about how drones almost "brought down" an airliner. Unfortunately they are not fabrications. Gliders (and the rest) are just getting scooped up in that reform blizzard. Its way to late to separate gliders from the movement.

Just last week onCNN (Aug 5, 2015) - http://www.cnn.com/2015/08/01/us/drone-airliner-jfk/

Good times, good times!

Sean
7T

On Tuesday, August 11, 2015 at 11:57:05 PM UTC-4, Sierra Whiskey wrote:
FWIW:

1) Transponders will give a false sense of security and teach vigilant glider pilots to trust that ATC is keeping tabs on their location for traffic deconfliction. This will result in less situational awareness for some pilots. (It is inevitable)

2) Transponders do nothing to separate gliders from VFR traffic squaking VFR and tracking in or out of an uncontrolled airfield. Not everyone is talking to ATC or getting flight following. And despite popular opinion, not everyone has an onboard collision avoidance system. (At least everything at my flight school lacks this capability)

3) If an immediate requirement for Transponders in gliders with electrical systems is imposed all gliders without a transponder will be out $2000 now, and another $2000-$5000 in 5 years when they have to upgrade to ADS-B. Why not wait till 2020? (Can't put a price on safety, but the FAA sure can harm a sport and form of flight training by imposing expensive requirements. The pilot shortage is near!!!)

4) In relation to my first point, the Flarm unit is far superior in my mind because it improves a pilots situational awareness and allows the glider pilot the chance to see and avoid. Let's not kid ourselves, glider pilots are looking out the window a hell of a lot more than a Bonanza flying VFR for that $100 hamburger. I would rather know where they are than have them run into me and my shiney new transponder.

5) If I have a battery failure in flight under a transponder requirement, do I need to land immediately in the nearest farm field? It is more likely that a glider will run out of sufficient battery power than an aircraft with an engine driven electrical system. Once the batteries run out of power the glider is now back to the same situation it was prior to the requirement. Waiting for ADS-B has some benefit here as the smaller units being developed for UAS are quite energy efficient.

I realize Flarm cannot be the solution. But I do think encouraging the use of a device that adds situational awareness is far more effective than trusting that a ground based radar and ATC operator are going to have communications with the traffic.

I am in the "we should all have transponder" group.
We share the airspace and need to participate fully.
All the arguments about power consumption and battery capability are null.
Gliders should have transponders first and FLARM in addition if wanted.
No system is perfect.
Change is always being promised.
But transponders are the here and now.
I have both. When I fly around Reno it is comforting to hear approach control and the commercial aircraft reporting that they "see" me on their systems.
The largest flaw I see and experience with FLARM is the inconsistency of installation and performance. It is far from a comfortingly stable and predictable safety system. All the chat streams on this forum verify this point.

Maybe you own the STC for SGS 2-33 electrical systems and you're going to make the STC available gratis?
Jim

On Tuesday, August 11, 2015 at 8:28:57 PM UTC-7, wrote:
I think all gliders should have transponders all the time.

On Tuesday, August 11, 2015 at 11:28:57 PM UTC-4, wrote:
I personally disagree with the SSA response. I have responded directly to the FAA.

I think all gliders should have transponders all the time.

We look forward to your five figure donation to our club to equip about 20 gliders (and our tow plane) with transponders that might be interrogated (optimistically) 10% of their flight time.

Yours is a crappy broad brush solution to a problem some do not have at this particular point in time.

Evan Ludeman, Post Mills Soaring Club, Post Mills, VT