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SSA responds to ANPRM



 
 
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  #21  
Old August 14th 15, 01:01 PM posted to rec.aviation.soaring
David Kinsell[_2_]
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Default SSA responds to ANPRM

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








  #22  
Old August 14th 15, 05:09 PM posted to rec.aviation.soaring
Benedict Smith
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Posts: 30
Default SSA responds to ANPRM

So is sight not counted as a sense now? Would they prefer you to touch or
smell it?

At 22:05 13 August 2015, D M wrote:
I also caution, any glider owner/operator that is considering FLARM Only
that if
the FAA changes the FAR part 91.113 (Right of Way Rules) from the word
"See
and Avoid" to the words "Sense and Avoid" you will probably need to add a


transponder with ADSB anyway. If your in the market to getting something
new, I would strongly consider a transponder that meets the 2020

complianc

language over just FLARM. Just trying to save you some money. The

changes
are coming. D



  #23  
Old August 14th 15, 07:38 PM posted to rec.aviation.soaring
[email protected]
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Posts: 266
Default SSA responds to ANPRM

Sight seems to be a sensation that is decreasing in acuity. At least, it has more competition from in cockpit PDAs, electronic varios, electronic maps, and FLARM displays. I have shared thermals with pilots who have made more than one circle with their eyes and fingers down on the panel, NOT outside the cockpit. I have had several close encounters with other gliders where the pilots face and eyes are involved with the electronics, NOT outside. I had a pilot who was new to the area tell me with great enthusiasm how he had programmed his two handheld Garmin GPS units to use while flying for his gold badge and use that information along with several pages of finely printed numbers to help him make go/no-go decisions. I flew beside him on the same ridge for several miles and he never looked outside his cockpit once.
We do need passive systems that are always on.
  #24  
Old August 15th 15, 01:01 AM posted to rec.aviation.soaring
[email protected]
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Default SSA responds to ANPRM

With apologies to ASA members who have already seen this I thought I would post my reply to the ANPRM which is based on a lot of conversations and reading and may be helpful to any one wanting to submit a response.

Response to the FAA ANPRM on Transponder Requirement for gliders and TSO-C199

This is my personal view on the ANPRM and while I have tried to get all the facts correct, not even the FAA can answer everything completely or correctly. The more you review the subject the more complicated it gets. I apologize for any errors. My views are, in part, different from those of SSA who essentially want nothing changed and I believe this is unrealistic and I personally want to be as safe as practical.
The deadline for submitting testimony is this coming Monday August 17 and I urge everyone to send in comments. Numbers count. Feel free to use any, all, or none of the material below. Note that while I will be including answers to the ANPRM's specific questions I have not included them here as it would not make much sense without restating the questions but these are on the URL below. If you would like my answers I'll be happy to send them to you.
http://www.gpo.gov/fdsys/pkg/FR-2015...2015-14818.htm
The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.
Adding Power FLARM is of course a couple of thousand more.
Below my summary to the ANPRM with questions I am asking and the FAA has requested be included. Feel free to contact me if you want to discuss further but time is short.
We do not know what process the FAA will use after August 17
This is the link to file your submission
https://www.federalregister.gov/arti...nt-for-gliders

Thanks to Jim Herd, Eric Greenwell, Tom Seim, David Kinsell, Russ Owens for their inputs but all the comments are mine
John Hodgson
CFIMEL, CFII, CFIG
DG808C Minden
/////////////////////

Summary
1 The Minden incident reports point to the lack of an operating transponder in the glider but we should also note that Norcal ATC was routing a jet through airspace known to be frequented by gliders who were not required to have transponders. Local dialog between the glider community and ATC to establish procedures could have avoided the collision in the first place. Simply restricting descending high speed traffic to above 18,000 feet till west of the Pine Nut mountain range would have avoided the situation.
Two weeks after the Minden incident flying a King Air C90 I was routed over the exact same spot by Norcal. I declined the clearance instead requesting the Minden GPS Bravo approach and when cleared to CTAF frequency also monitored the glider frequency of 123.3.
2 Gliders, including those with self launch capability where the engine is only operating for maybe 10 minutes, have limited on board power resources that must be conserved for use throughout the flight including transponder use at the end of the flight that may be in high activity airspace and deploying and starting the engine at any time up to the point of touch down.
3 All airspace does not produce the same risks and while I fully agree that transponders should be required in certain high activity areas they do little but use power when squawking in areas that experience only light traffic such as the western deserts.
4 Glider flights can last to 10 hours or more putting great pressure on the conservation of power in flight and also recharging batteries over night for the next day.
5 The problem would be greatly simplified if use of transponder/TABS was required in certain high risk areas but remained voluntary outside of those areas. No glider pilot wants to be involved in a mid air collision.
6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.
7 Popular high activity glider routes can and should be identified and marked on sectional charts as are military routes. Pilots of power planes could be provided training by local CFIs on where gliders operate to increase their vigilance e.g. mountain ranges and cloud streets.
8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.
9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.
http://www.avweb.com/blogs/insider/A...-223824-1.html
http://www.airspacemag.com/daily-pla...956113/?no-ist

////////////////////////////////////
Answers responding to the ANPRM specific questions not posted here

///////////////////////////////////
I would like to ask the following questions and request answers with the findings of the ANPRM ......

1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?
Have flights filed on the glider on line contest web site been reviewed to see how they operate in the US air space?
http://www.onlinecontest.org/olc-2.0...=C0&sc=&st=olc
2 What cost does the FAA think it will take to install ADS-B in a glider when a TABS product is available? Using an estimated $6000 to comply that is as much as half the cost of many gliders flying today
3 What calculations have been made to consider the power requirements needed to support TABS on extended 10 hour day back to back flights?
4 Has the national airspace have been reviewed to determine high and low risk areas of glider to airplane mid air near misses and collisions?
5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?
6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?
7 Will tow planes require TABS or full ADS-B compliance?
8 Has the marking of high activity glider routes on sectionals been considered?
9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?
10 What will be the impact of TABS on glider cross county flights in Canadian and Mexican airspace but not landing outside the USA?
11 Does one, fortunately non fatal, mid air collision in a decade that could have easily been avoided justify the huge cost of mandating TABS on the US glider fleet, plus balloons and airplanes without electrical systems?
12 Will a representative be appointed to liase and communicate with the soaring community on an ongoing basis? And not just through SSA but a representative group throughout the country.

References:-
Federal register June 16, 2015
http://www.gpo.gov/fdsys/pkg/FR-2015...2015-14818.htm

TSO-C199 October 10, 2014
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/1600df588a6f53ae86257d710070d105/$FILE/TSO-C199.pdf

FAA presentation, D Walker, TSO-C199 TABS
http://www.icao.int/APAC/Meetings/20...20briefing.pdf

TRiG data sheets, TT21, TN70
Google ADS-B for drones (links above)

Thank you, John Hodgson
  #25  
Old August 15th 15, 03:13 AM posted to rec.aviation.soaring
Bill T
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Default SSA responds to ANPRM

John, tow planes operating within a mode C veil or above 10,000 MSL are required to have ADS-B Out by 2020.

BillT
  #26  
Old August 15th 15, 04:44 AM posted to rec.aviation.soaring
danlj
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Default SSA responds to ANPRM

A few years ago an FAA study reviewing midair stated that more that half occurred
- on weekends
- in VMC
- at traffic-pattern altitude
- on weekends.
See and avoid does not work well because each pilot really can't see very much of the sky - sharp vision is about 1% of the sphere, most of the sky is eclipsed by glider, pax, & hat, & the aircraft on a collision course in stationary in our visual field.

The drone revolution is just beginning.

We do need electronic augmentation for the task. The FAA is taking on responsibility for the conversation, a good thing.

We have a legacy system in ADS-B, with dated technology, but abandoning this for Flarm-like technology is fraught.

I think comments to the FAA are best that propose feasible ways to augment collision avoidance where collisions are most likely & where they are most costly.
  #27  
Old August 15th 15, 06:15 AM posted to rec.aviation.soaring
Darryl Ramm
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Posts: 2,403
Default SSA responds to ANPRM

John

Lots of great points here, some rambling comments on a few techncial things or things I could not follow...

On Friday, August 14, 2015 at 5:01:53 PM UTC-7, wrote:

The current FAA proposals for TABS with TSO-C199 look to cost around $6000 for each glider plus the cost of downgrading your current mode C transponder if you have one to a paper weight. Battery draw will be reduced for anyone with a transponder now such as Becker but obviously an increase for ships without Mode C today and needing to add TABS.


$6000 costs seem high. If I had to guesstimate an _upper_ cost for a TABS device in the near future, I'd expect something like a Trig TT-21 + $1,000 for a GPS source. That is based on triangulating costs for products like the new non-TSO $850 Garmin GPS 20A.. since it meets the full ADS-B our performance requirements having it pass the TABS approval tests should be relatively easy. And no I'm not implying that cost to be affordable or is justified for many glider pilots, just pointing out what I expect a high cost would be.

However that assumes sensible install regulations (anything close to the ADS-B Out STC mess that happened early on woudl be a disaster) and collaboration between vendors of Class A and B TABS devices.... and in general I expect dedicated TABS devices to just include a suitable GPS source. NexNav has announced their "low-cost" TABS Class B Micro-i GPS source. No real clarity on what they mean by low-cost, and I expect they will really sell to OEMs..


6 A significant risk is glider to glider near misses on high energy lines that are used for fast cross country flying and where gliders are working in close proximity in the same space. Power FLARM (FLight and AlaRM) is an existing and viable solution that is being progressively adopted in the US and the European version of this is highly successful with a decade of experience. Power FLARM (PF) shows transponder activity permitting avoidance action but is not itself seen by TCAS type devices nor ATC but can be used in the glider to provide an alert and activate a transponder/TABS.


I doubt anybody who is not a glider pilot will understand what an energy line are. Their loss :-)

Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA do. At one time there was talk of sales of models without 1090S In in the USA, I'm not sure if any sales actually happened (it's a very bad idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).


8 TSO-C199 TABS is not yet available commercially and not understood by most of the US glider community. It appears to be just the lowest cost mode S transponder on the market today (TRiG TT21) with an external GPS WAAS (TN70) capability. The only concession from the authorities appears to be relaxation in the TSO process. Further this is a transponder class 2 that is only approved to altitudes to 15,000 feet. This is an expensive solution beyond the financial justification of many of the aircraft that will be required to install it.


There are no TABS Class A devices on the market today, and no manufacturer TSO approved. A Trig TT-21 might be a possible to use as a TABS device since the TABS TSO spec is (a good thing) designed to allow existing Mode S transponders to potentially be backed into use as TABS device. There is certainly *potential* for TABS devices to be say smaller/lighter than say even the current Trig packaged Transponder (which are *great* transponders), e.g. look at what Sagetech does today for Mode S UAV transponders.... http://www..sagetechcorp.com/unmanned-solutions/

Any actual TABS carriage and installation regulation for use in gliders would clearly need to allow that TABS device use above 15,000. The folks who developed the TABS standard understand that. The 15,000' limit in a Class 2 Transponder is not directly relevant in any technical sense here... Installation and carriage regulations or TABS devices needs to be developed, what that looks like if any, is important but it will need to be clearly separated from current transponder regulations...


9 Gliders, balloons, airplanes without electrical systems, and drones need their requirements studied, a single appropriate specification produced, and a commercial product developed. The electronics industry needs greater volume than just that provided by gliders to deliver a cost effective solution with ongoing development. Producing a specification with price, power, and size requirements that have yet to be defined is the first step. The recent proposals attributed to Google on low cost ADS-B transponders for drones show that development is far from over and early adopters will be penalized financially.


I expect the FAA would argue that is what TABS is intended to achieve, and lots of folks, including suppliers to the UAV/drone industry, had input into that TSO's development.


1 What was the specification defined for the TABS device? Especially cost, power, physical size, operating limitations e.g. 15,000 feet if that is a spec for the the class 2 transponder. What about glider operations to 18,000 and in wave windows (which ATC routes all other traffic around) to 40,000 feet and above?


TABS/TSO-C199 is a technical product standard. The FAA or RTCA standards just are not going to deal with things like physical size or cost, and that is a good thing, let the market work on that. The FAA can hand wave (largely correctly) that TSO-C100 targets costs by say allowing use of consumer GPS chipset technology (by the avionics manufacture, not owners/pilots connecting random consumer GPS devices), and leveraging exiting Mode S technology/Mode S manufacturer capability. And while all that is a big step for the FAA, TABS devices are still complex and are still likely to be relatively expensive until they reach some significant volume, and that won't even start to happen until there are carriage/install regulations. For better or worse I expect many players here want to make the glider community the test case.. But ultimately volume is going to need something like UAV use... not that I am excited about having larger UAVs flying around putting manned aircraft at risk.

There should not be a specific technical issue with TABS and 15,000'. And the folks developing the TABS standard understand this. But it is absolutely great to point out things like any TABS usage regulation should allow operation in wave windows (or maybe rather the FAA should be required to allow TABS devices in any wave window agreements that requires transponders and/or 1090ES Out devices). I'd have s similar wish for Class A airspace in general, but wave windows impact lots more glider pilots than the few doing Class A IFR flights.


5 What consideration has been given to glider on glider conflicts which typically are not in ATC radio contact and cannot not have TCAS type devices? Has a non TSO approval been considered for Power FLARM?


I am not following at all what you are asking for here with "non-TSO approval".

Do you want the FAA to mandate all gliders have to carry PowerFLARM? As well as Transponder? As well as TABS? or allowing PowerFLARM to drive TABS GPS? And what TSO? There is no TSO, or underlying RTCA standard at all that is really relevant to FLARM, nor is there any effort to develop one... any consideration about that was what ended up being TABS. And TABS per-se is just a beacon/output system, it does not require any input or display or anything close to Flarm for actual workable traffic warning in glider-on-glider situations. And how does the FAA approve a device without a TSO? The use of "non-TSO" products that's are made say in experimental aircraft requires a TSO spec for the device to be built towards, even if it's not actually TSO approved.

FLARM technology exists becasue it was possible to innovate and develop stuff for such as small specialized market without the usual high cost associated with regulations and bureaucracy. (It's amusing to think what the entire initial development cost of FLARM was and compare that to how many RTCA or FAA standards meetings you could actually conduct for that same cost :-))

I am kinda just lost about this point why would you want anything TSO or any other imaginable FAA approval or the FAA involved at all in anything related to PowerFLARM?

And I know you said TCAS-like, and I know you know what TCAS is but others reading this won't know what you mean exactly. Like what TCAS capability? You might have meant more ADS-B In traffic systems or various CDTI/ADS-B In solutions, but none of those systems will offer anything like TCAS-II RA capabilities. There is also a "cannot not" typo in there that is confusing.

And the FAA could point out there are already several choices of ADS-B in solutions that are compatible with TABS devices and all suitable to different extent in gliders... including obviously the 1090ES In option in PowerFLARM, as well as ADS-B In portable devices from Stratus and Garmin... but I really expect the glider community does not want the FAA pushing/mandating ADS-B In or similar product use in gliders.

6 How will ATC manage flight operations such as multiple gliders circling to gain altitude in the same thermal? Similarly gliders being launched behind a tow plane? And, formation flights where ATC typically asks for only the leader to operate a transponder?


This is not an issue with Mode S transponders, or TABS. And I would expect new transponders (including any likely to be installed due to removal of the exemption) are likely to be Mode-S transponders.

And it may be that this problem is overstated even for Mode C transponders. A lot of the folklore about this dates back to old Mode A/C SSR systems. In discussion with ATC staff (including radar techs) in places like Reno they strongly wanted gliders to be transponder equipped and were not concerned about this. I would be surprised if SSR and TCAS cannot handle synchronous garbling from a few aircraft (TCAS II for example has de-correlator designed to handle degarbling several overlapping transponders), large gaggles may be more of a challenge. But a large gaggle of gliders with Mode C transponders and possible synchronous garbling *is* going to get noticed on an SSR radar and ATC should help route traffic around that.

7 Will tow planes require TABS or full ADS-B compliance?


Airplanes are not a part of this ANPRM, and right now this should not really be a question... what towplanes requirements are is clear in the current regulations. But it ultimately would be an interesting thing to ask for TABS in special cases such as towplanes or maybe powered aircraft in general to provide partial coverage of where ADS-B Out will be needed after 2020. I hope AOPA and the EAA are watching this and willing to push on it if TABS does take off.

9 Has the inclusion of representatives of the soaring community been considered for the planning process to get sensible products and procedures defined and implemented?


I expect the FAA would argue that the SSA has been quite involved in this. For example the SSA has had representation at meetings that lead to the TSO-C199/TABS. I am not clear how much any of that has been discussed within SSA management or communicated to members.
  #28  
Old August 15th 15, 06:45 AM posted to rec.aviation.soaring
David Kinsell[_2_]
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Posts: 70
Default SSA responds to ANPRM

On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:




Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA
do. At one time there was talk of sales of models without 1090S In in
the USA, I'm not sure if any sales actually happened (it's a very bad
idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).



Craggyaero has them on their website, at a very substantial discount. I
hate to see that too, but expect people buy them.

More common is probably turning off the TCAS type of alerts since the
proximity alarms get annoying.

-Dave
  #29  
Old August 15th 15, 07:04 AM posted to rec.aviation.soaring
Darryl Ramm
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Posts: 2,403
Default SSA responds to ANPRM

On Friday, August 14, 2015 at 10:46:54 PM UTC-7, David Kinsell wrote:
On Fri, 14 Aug 2015 22:15:48 -0700, Darryl Ramm wrote:




Not all PowerFLARM actually receive 1090ES, most (all?) sold in the USA
do. At one time there was talk of sales of models without 1090S In in
the USA, I'm not sure if any sales actually happened (it's a very bad
idea IMNSO becasue of 1090ES Out/possible future TABS compatibility).



Craggyaero has them on their website, at a very substantial discount. I
hate to see that too, but expect people buy them.

More common is probably turning off the TCAS type of alerts since the
proximity alarms get annoying.

-Dave


I see one mention of "Core Pure" on one page at Craggy and a price but nowhere to actually buy one. I'm hoping it really is not for sale. Richard???

Likewise there is scattered mention of Core Pure on the Cumulus Soaring Web site but no "Pure" device listed for actual sale.

For reasons that now should be cleaner with ADS-B/1090ES Out adoption and possible TABS futures, glider pilots/owners in the USA really should want to have a 1090ES capable receiver in their PowerFLARM.

  #30  
Old August 15th 15, 08:26 AM posted to rec.aviation.soaring
Ramy[_2_]
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Default SSA responds to ANPRM

Posting on behalf of Jim Herd:

As we have discussed, the FAA ANPRM on TABS is a really big deal for soaring with the potential to cost us all $5000 or so. I have studied this extensively, which is hard to do because so little information is available. I have spoken with the Trig CEO and FAA officials directly involved, so I probably know as much as anyone. I have submitted extensive testimony to the FAA ANPRM and I think it would be very informative to most soaring pilots. It might also inspire them to get involved enough to testify themselves. It is not difficult to do. Strong testimony, even if short, will have an impact, especially if it is deeper than "I can't afford TABS". We all have to take a broader view than that. The FAA wants our input and they have assured me that even asking a series of questions will be welcomed. For example, what about tow planes? What about the 15000' limit issue? What about thermal gaggles? What about upgrading existing mode S xpdrs? When will the mandate happen?


Basically, the new world of aviation involves every object in certain airspace "seeing" all other objects "electronically" with very accurate positioning. This provides for much better safety and much closer spacing - hence accommodating increasing commercial traffic density. In such airspace, it is hard to fathom how gliders can co-exist without being electronically "visible" to ATC and all traffic around them. It is like turning a car headlights on at night - to show other drivers you are there.

Whatever your position, you should make your case to the FAA as I have done.. Feel free to extract points from my testimony or construct your own. My belief is that limited high risk airspace should be mandated for gliders to be squawking, and in the new environment existing xpdrs won't cut it. I need a new one and so may you. But there are many creative ways to limit the pain that the FAA has not yet considered, and I lay out a bunch in my testimony. We can't avoid the excruciating detail because that's where the devil lurks.


My testimony is he

https://drive.google.com/file/d/0B-9...cEU/view?pli=1


You can file with the FAA here (deadline is August 17):

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


Ramy, feel free to forward this note to soaring pilots who should read it.

Cheers,

Jim Herd

Minden



And here is the text of my ANPRM testimony, as in the link above.


FAA,

I am retired from Silicon Valley as Vice President of Business Development and General Manager of two Divisions of a public corporation, with a technical background and now living in Nevada near Lake Tahoe. I fly a Bonanza and an auxiliary-powered sailplane with a combined 4000 hours in 17 years, flying all across the North American Continent and elsewhere in the world. Aviation is a major passion of mine, for sport and personal transport. I have extensively studied the situation regarding your ANPRM on TABS, including reading a lot of related material and conversing with players in the game such as soaring pilots, power pilots, airline pilots, avionics manufacturers and FAA personnel. I have no personal dog in the hunt, no concern over any added cost burden to me, and I fully recognize the larger picture of protecting everyone in the national air space by fully deploying Next Gen and ADS-B. I will testify here in some depth because the FAA is clearly thirsting for input (to its credit), because the complex nature of the subject warrants it, and I think I have significant impartial contributions to make based on extensive study.

First, it is impossible for me or anyone else to respond to your specific ANPRM questions at this time. The necessary background knowledge is simply not available anywhere. For example, no TABS device is commercially available so no-one knows the cost or power consumption. In good faith, I will nevertheless respectfully submit the findings from my research along with some carefully considered constructive suggestions.

Overview


The general concepts of Next Gen, ADS-B, and TABS are very good. The long-standing transponder exemption for gliders is indefensible in high risk areas, based on the simple fact that "see and be seen" is a failed principle since a glider often presents the visual profile of the edge view of a razor blade. Kudos to the FAA for recognizing this and addressing it. But as always, the devil is in the detail.

Undoubtedly, many folks in the soaring community will react negatively to this ANPRM, based in part on their unavoidable lack of knowledge and the perception that the FAA is "strong-arming" the situation. This, even though I realize your ANPRM is merely asking questions and seeking input. No-one likes a rush to judgment or the feeling of being bullied. And to be fair, glider pilots reasonably perceive little or no value to them from TABS (ADS-B IN weather and traffic is not involved). This, despite the obvious benefit of potentially avoiding airborne conflicts.


Frankly, the absence of an extensive open dialog between the entire soaring community and the FAA has set back the cause considerably, in my humble opinion, and negative impressions have hardened. But a much more constructive and cooperative context can be generated through dialog and education, and a genuine atmosphere of cooperation and goodwill. The current ANPRM does not do that.

As for the power plane community (which for the most part does not understand the gliding community, and visa versa), most of them find it unconscionable that gliders and other aircraft are still universally exempt from the transponder mandate. Those folks are strongly in favor of some type of mechanism to bring gliders into view (electronically speaking) in areas of major threat such as illustrated by the Hawker jet that hit a glider a few years ago in a major soaring location that is visible from my house.


Summary


To be clear and concise, the primary issues here are these:


1. The critical phase of education and informal "outreach" regarding TABS, before any formal ANPRM, is missing. So suspicion and obstruction may dominate until we all back up and engage in a full dialog.

2. Cost of TABS - purchase, installation, adding electrical power, and testing. Cost is most likely not significantly less than current low-end ADS-B OUT devices on the market, and perceived as "unaffordable" with no benefit to the soaring community. TABS does address the power consumption issue, but Trig Avionics has largely solved that one already.

3. TABS is an overreach and arbitrary blanket mandate covering most air space across the country, including air space with virtually no risk to anyone in the air. I realize the ANPRM doesn't go that far, but the writing is perceived to be on the wall.

4. FAA has so far blocked the authorization to turn OFF TABS or any xpdr in a glider in certain air space with insignificant threat. Power consumption, even with a Trig TT21, is a very significant issue for long cross country soaring flights.

5. There is strong potential for new technologies overwhelming the TABS TSO, even before the 2020 mandate. Early obsolescence may be assured.


ANPRM Process


Looking at the ANPRM process first, rather than the substance of the matter.. The ANPRM is premature since almost no soaring pilot or anyone else in the aviation world knows anything about TABS as a commercial product because there isn't one in any store, merely TSO C-199. And even with extensive research, the necessary facts are unavailable. Compounding this is the fact that most soaring pilots have no clue about Next Gen and ADS-B, so they don't have the broader context in which TABS is envisioned. Therefore, it is not useful to ask for feedback at this time. Instead, the correct phase we should enter is one of informal information sharing and education - both ways. The wider aviation community (glider and power pilots) needs to understand TABS and its context, and the FAA needs to understand the special nuances of soaring. Only then can we do quality work together to find the right compromise solution.

So I urge you to step back and initiate a phase of education and informal communication back and forth, but perhaps that is already your intent. I suggest you do this through prominent attendance at the next Soaring Convention (February 18 to 20, Greenville, South Carolina) with a booth and a presentation on TABS, writing in SOARING magazine, reading and even participating in the relevant chat groups, and other vehicles of outreach to soaring pilots. And of course the FAA has many of its own vehicles of outreach and education through publications and special events. Before the TABS ANPRM was issued, there was very little information or dialog anywhere in aviation about this new concept called TABS. So the industry simply is not ready for this ANPRM. And make no mistake, TABS may be the most significant change in U..S. soaring for a decade.


The entire industry needs to understand the broader context of TABS. Also, power pilots need to be educated that soaring gliders present a threat to them only in limited and well-defined high activity air space regions, so power pilots and the whole aviation industry (and the general public) can become comfortable with some compromises regarding air space mandates for gliders. You could reach out to power pilots to educate them with articles in the aviation Press, attendance and presentations at Sun 'N' Fun, Oshkosh, etc. Note that there is no commercial entity that will do this work of education, because companies such as Garmin (who is heavily educating the industry on ADS-B) foresee no payback for any efforts regarding TABS. And Trig is too small to educate the U.S. aviation industry.

What Problem Are We Trying to Solve?


May I suggest that we must all narrow down the focus and answer this: what is the real problem we are trying to solve here? Broad brush answers (such as "remove the xpdr exemption") will only lead to sweeping and over-burdensome proposed solutions that will generate very negative reactions as "excessive" and "unworkable". Instead, a targeted approach will be viewed as more reasonable and acceptable. Specifically, the problem is: unseen aircraft (gliders in this case) posing threats to other aircraft in very specific airspace because they are electronically invisible. Therefore the solution should be the least invasive technology, mandated only in the airspace at significant risk.

I think we can collectively narrow the technical specs within the TSO to reduce cost and power, but this has to be achieved through a cooperative team of "experts" covering all factions. It would include a close look at specific internal circuits that consume power in the TABS box and how to turn them off when not needed. For example, there is little value to anyone in a glider squawking while on the ground because gliders almost never operate at busy airports. So turning off the transmit circuits based on a GPD ground speed less than 30 knots is not difficult. As a Silicon Valley guy, I know this can be done, even though I know extensive work was done on TSO C-199. Also, the air space at significant risk is vastly less than all controlled airspace across the USA and everywhere above 10,000' msl (the usual transponder mandated areas).


For example, there are vast areas of the Desert West (a favorite haunt of glider pilots due to exceptional lifting air) with no airliners below 28,000' and very few other powered aircraft. Here, "big sky" and "see and be seen" are reasonable practical principles with extremely low risk for non-glider aircraft. So the area to be mandated for TABS in gliders can and should be limited to known high risk air space, involving perhaps a new designation of air space type. A specific suggestion might be to extend the "30 mile veil" that surrounds all class Bravo airports, to include veils around class Charlie. Each sensitive area of the country should be reviewed as a cooperative project with regional FAA personnel and local soaring pilots and other interested parties. Specific defined airspace of high risk would be the work product.


Glider Pilots' Needs

Gliding is not a homogeneous sport with a single set of needs so it is important to understand the subsets of needs. For example, primary glider training needs air space uninhibited by TABS because it would seriously damage the sport, already in a long term decline, if training costs at commercial operations have to increase to cover TABS. This is actually reasonably achievable because primary training can usually be restricted to below 10,000' msl and outside class B, C, & D. On the other end is the high-end cross country gliders and their pilots - this is my personal situation. We clearly need access to air space above 10,000' msl, and power consumption for long duration flights is the primary concern.


My personal view is that some type of ADS-B OUT is necessary for my glider, and I recognize I must replace my current mode C xpdr ($$$). Another subset of the sport is the vintage glider community with beloved old metal aircraft with a very small battery (if any), few avionics (if any), and a hull value of less than $20,000. These pilots aren't looking to soar hundreds of miles but they do need reasonably unimpeded access to certain airspace. So I suggest the key here is for FAA personnel to fully understand soaring at the level of the handful of sub-categories that exist, as well as regional differences which are very significant. Then you can work to accommodate critical needs without destroying the sport with overreach. This nuanced approach is standard practice for the FAA as you have worked over many decades to construct special "niche" situations all through the FARs.


Turn Transponders OFF?


Another innovative policy would be to allow glider pilots to turn off their transponders or TABS in certain low risk airspace. I know this has been considered by the FAA in the past and rejected, but I urge you to reconsider. From my own experience soaring around the Western USA, there is less than 10% of the soaring arena where a transponder or TABS has any practical merit below FL180 because there simply is virtually no powered traffic. This modest relaxation would dramatically reduce power consumption and improve support for TABS in the glider community. Do you want to risk a glider unable to squawk or communicate when returning to a busy traffic area because s/he has depleted batteries from squawking at nobody for many hours? Similarly, gliders with auxiliary engines such as mine must retain adequate power for an air restart as a prime safety matter.


Subsidize TABS

In New Zealand, a few years ago their CAA subsidized mode S transponder installation into the glider fleet to the tune of about 50% of the end user cost. In the broader context this was a very modest and practical investment that achieved the goal of smoothing the transition for this small but important aviation community without a major outcry from the soaring community. I realize this has the disadvantage of being "precedent setting", but the FAA already has that precedent with Capstone in Alaska, and there was no backlash in New Zealand. A move like this would greatly diminish the objections to your game plan, so I suggest you look at the economics and consider what might be done.


TABS Product Specs


Early indications are that the TABS TSO won't significantly reduce power consumption from modern transponder products already on the market. The tea leaves indicate we will be at about 200 milliamps for TABS, which is an insignificant change from the current Trig transponder model TT21, but no company has made a commitment on that yet. And hardware pricing looks like it may be in the area of $3500 plus installation of around $500 and then whatever added on-board electrical power solution may be necessary for each unique installation. Also, it is not known if TABS will be subject to the same initial installation certification and retesting every two years, as with conventional xpdrs. All up, this is likely to be in excess of $5000, plus ongoing costs also. So this is no cheaper than the low end of conventional ADS-B OUT products already available in the wider aviation market, and certainly a very expensive pill to swallow for many glider pilots, clubs, and commercial operators who sustain themselves on a shoe-string. Many gliders are only worth between $10,000 and $20,000, and some only $5,000. So we need clever ways to make this cheaper and use less power and not required in some gliders.

Expand the TSO to Increase TABS Volume


The TSO is clearly a laudable first effort to minimize cost, power, and other impacts to sailplane pilots and businesses. My research indicates that more can be done. For example, the FAA will need to deal with balloons, power planes with no electrical system, and UAVs. A collective solution can lead to a single TSO and a vastly larger market for the commercial industry to be attracted to serve TABS and therefore the usual benefits of innovation and price competition that comes from American free-market Capitalism. You see, with less than 4,000 gliders in the USA this segment is an unattractive business proposition for the avionics industry. Consequently, retail price of TABS (for gliders only) will be severely affected by low volume. If combined with other special segments of aviation, I suspect prices could be cut in half due to volume and competition.

As far as I know, the only avionics company working on TABS is Trig in Scotland. We must find ways to interest competing companies such as Becker and Dittel, who have been the industry standard for decades for gliders and all other similar applications such as LSA. A proactive initiative is needed here. What will it take to create an attractive commercial proposition and a competitive environment? Also, how can the existing installed base of transponders in gliders be upgraded to comply with TABS, rather than mandating the expense of a totally new transponder? My experience indicates this would be doable with existing mode S transponders in gliders.


Google, Amazon & Sagetech

As I'm sure you know, Google, Amazon, and others are aggressively entering the huge UAV market for commercial applications. There are credible forecasts of game changing ADS-B OUT technology in the near term, driven by the needs of the burgeoning UAV industry segment. Possible ADS-B OUT devices an order of magnitude lighter, smaller, cheaper, and less power! Undoubtedly, the brain power and investment is already in place to potentially quickly overwhelm the TABS TSO technology. And the end objective of "see and be seen" is exactly the same for UAVs and gliders and balloons and power planes with no electrical system. So why can't we merge all these converging interests to create an attractive market volume? And the FAA should be out front and the catalyst for this exciting prospect!

Reference the Google "Loon" project that is based in my home town of Minden, Nevada:

http://www.airspacemag.com/daily-pla...956113/?no-ist


Reference Sagetech: http://www.sagetechcorp.com/unmanned.../#.VcuE2cvJAuQ

What About PowerFLARM (PF)?


https://flarm.com/

As you know, the soaring community in the USA has begun to gravitate to a product called PowerFLARM for collision avoidance (glider-to-glider). This is clear evidence that soaring pilots and businesses are fully aware of mid-air risks and willing to commit resources to do something about it - when it is perceived to make sense. Note that PowerFLARM serves an entirely different need than TABS, though the similarities often cause confusion, and it costs less than $2000 with owner-installation being doable. There is no hard data yet for lives saved in the USA, but it is hard to prove a negative. Likely, lives have been saved already.

PF is primarily for glider-to-glider risks, though it also acts similar to TCAS by "seeing" transponders, but it has no ADS-B OUT. There is a totally different risk profile between gliders that involves avoiding false alarms as gliders "gaggle" like a corkscrew in large thermals. ADS-B or TABS would be in constant alarm mode for ATC due to close proximity, but with no real threat. How would this "non-conflict" scenario be handled by ATC when their screen lights up with a gaggle of gliders incorrectly portrayed as in mortal danger from each other?

PF is able to recognize and ignore these common non-threat scenarios. The greatest danger for glider-to-glider impact is when cruising straight and level in opposite directions along what we call "energy lines". That can be ridge lift along a mountain ridge, mountain wave along the leading edge of the familiar lenticular clouds, or cumulus cloud streets. I can report a personal near-fatal near miss of that type. In June of 2013 I was cruising along in my glider at 16,000 feet msl under a cloud street and heading south straight-and level near Richfield, Utah. Another glider was under that same cloud street at the same altitude in the opposite direction. Closing speed was about 200 knots. I was absolutely looking out the window and directly ahead. I caught the other glider out the corner of my eye as he passed by about 100 feet away! I spoke with the other pilot afterwards and he had exactly the same experience as me. See and avoid simply doesn't work in that situation, and neither would TABS because most gliders won't be talking to ATC and won't have ADS-B traffic on-board.

Flarm has a tremendous track record in Europe, where it has been prominent for nearly a decade and is now almost 100% installed in gliders - 25,000 installations, voluntarily. The European device has different electronics but the same principles, and the record of mid-air collisions has markedly decreased as Flarm has become ubiquitous. There is an undeniable linkage and lives have been saved. Again, this is addressing glider-to-glider threats in "high energy" areas with no relevance to the rest of aviation because in Europe gliders are usually very close to terrain and often below ridge lines.. This is airspace where other traffic almost never ventures, for obvious reasons. I urge the FAA to allow PowerFLARM to evolve without regulatory intervention, as it has in Europe.

But PF is irrelevant to the TABS discussion because PF does not transmit 1090ES or 978UAT. But wait, perhaps the manufacturer of PF can develop a TSO-compliant integrated device to incorporate TABS? As you know, there is a trend for integrating avionics all across the aviation world. If cost was reasonable, this would be highly attractive to the soaring community because PF is already building credibility and momentum as a valued cockpit asset for U.S. gliders. The FAA should prompt a joint dialog to see what might be possible. I could also foresee a joint project between PF and Trig people that could lead to a single integrated box, though it does add to the power consumption burden.

Electrical Power Budget


I have studied this and I can offer my own personal data which is quite typical in the soaring world. My glider is a standard certified German DG800B, new in 2000 and still a current design, with an auxiliary engine that is used typically for 10 minutes for launch and then not again, unless I need a boost to stay off the ground and get back home safely from a cross-country flight which takes me up to 300 miles away or further. It has the factory certified electrical design with four 6 volt gel-cell lead-acid batteries wired in series and parallel to provide 24 Ah at 12v. This power source drives the entire aircraft - engine start, engine up-haul (it folds away in the fuselage), and avionics. Further, as you know, batteries degrade from the day they are manufactured, and even "deep cycle" batteries such as these should not be drained below 50% or damage and shortened life will ensue. Therefore, in practical terms, I have available approximately 10 Ah if I start with fully charged batteries. Charging sounds easy but can be a real challenge when the aircraft is tied down on a ramp with no 110v electrical power available, and the on-board batteries are not easily removed. BTW - a set of batteries costs about $450 and they should be replaced every 3 years or so, but if abused with deep discharge and/or poor recharging, every year.

My suite of avionics is actually very modest in power consumption because I use an old black and white moving map screen rather than the modern large bright color screens that are ubiquitous in modern cross-country gliders. So my average continuous current draw is about 1.5 amps, with no transponder and no PowerFLARM. That's about 6.5 hours of flying capacity on the batteries. But in June, flying out of Parowan, Utah I flew 5 days back-to-back of 7 hours each day. Each day I landed with about 12.2v which is nominally below 50% battery capacity, and I know from personal experience when my batteries are that low I may not have the power necessary to up-haul my engine and then start the motor if needed to get home. This is a significant safety issue.

This exact scenario happened to me in 2012 after a long flight of 10 hours and over 1,000 kms. I had to either restart the engine to get home, or land in an open cultivated field. Such an "outlanding" is always considered an emergency procedure in a modern glider due to the 50 to 1 glide and the landing speed of 60 knots with over 1000 pounds of mass. In that case, I had 12.1v and the engine struggled to up-haul at pattern altitude, and there was insufficient power to crank the engine to get home. I proceeded with a pattern to land in the field. On very short final I pressed the starter again and it very sluggishly cranked and started. I avoided an emergency out-landing onto unknown terrain when at 10 feet altitude. So you can see the critical nature of on-board power.

Power Solutions


So what solutions are available to solve the electrical power shortage? More batteries would be possible, but that presents its own problems with cost, wiring, W&B, stowage, recharge and regulatory approval. It is also possible to separate the engine batteries from avionics batteries, as is done in some gliders, so as to retain starting battery reserve for a "relight". But this would involve an electrical design challenge, a factory T.N., an STC, a 337, or some other burdensome and costly action. And this would not solve the total battery power needed. Surely this process can be streamlined in regulatory terms?

There are new battery chemistries that promise higher power density, but we all know of the Boeing 787 fires with Lithium Ion batteries. Some experimental gliders are enjoying success with LiFePO4 (lithium phosphate) chemistry, which provides about 30% better power density. But these batteries are also lighter and change W&B, they still contain Lithium which is a "bad" chemical (reactive and flammable and poison), and they still employ internal circuits to control "thermal runaway", and of course those circuits can and do fail. I suggest the FAA should explore what is safe and what could be given blanket approval to help solve the on-board power problem for standard certified gliders.

Another partial solution is on-board solar panels. I have investigated that for my own glider and here is the data. A double set of solar panels on the engine bay doors (the only location approved by the glider manufacturer and used by them as an option for new gliders) would yield an average of about 1.5 amps continuous in the western U.S. with a lot of sun. Probably nearer to 1 amp or less in heavy cloud and when sun angle is lower. These solar panels are designed and available from only one company in the soaring world and that is Strobl Solar GmbH in Germany. A July 2015 quotation from Strobl for my glider is 1707 Euro or US$1873, plus installation of about $500. This would solve at least part of my power shortfall, but not enough if I install TABS, PowerFLARM, and a modern moving map screen.

Other solutions to improve the electrical power situation include "donor batteries" out on the ramp. That involves conventional large 12v lead-acid batteries that are charged by 110v (wherever available) during the soaring day and then moved to the glider on the ramp for attachment and charging overnight via an inverter and a 12v charger. This system can and does work, but is fraught with practical challenges such as the complex wiring and components involved and the risk of disrupting the charge accidentally and the safety risks associated with moving large donor flooded-cell lead-acid batteries back and forth. Cost can be about $500 with recurring cost for the donor battery. And of course, the on-board batteries can accept no more than a full charge anyway, so on-board capacity is not improved.

Ground solar panels are also employed by many soaring pilots for recharge after the flying day. I use a conventional 20W panel that yields about 1 amp average, but it can only help while the glider is on the ramp which is usually early morning and late evening on back-to-back soaring days (roughly 4 hours of usable sun in summer). I plan to double this ground solar charging this winter, and the total cost of this system is about $1000.

Bottom line


The national air space needs better protection for everyone in it because "see and be seen" doesn't work adequately for high risk areas, and that will inevitably mean a limited mandated technology solution for gliders and other aircraft currently "exempted". The primary issues here are cost, on-board power, defining the minimum air space in which a TABS device is mandated, and education for all concerned factions. The successful solution is going to be more nuanced than that envisioned in the TSO C-199 and the ANPRM, and newer technology may overwhelm the TABS TSO before 2020. But the good news is that new technology presents a great opportunity to bundle TSO C-199 with UAVs to dramatically improve attractiveness and acceptance for gliders.


I look forward to joining with the FAA to get this solved, which I believe demands that we all step back and work together to seek clever compromises as I have suggested here. So please extend the study period, engage the best available contributors from the soaring community & other factions of aviation, collaborate as I have suggested, and embark on a mutual education phase before developing solid proposals. Together we can solve this.

Jim Herd

 




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