ADSB out in tow planes

[Charles Longley]

One of our Pawnees has an ADSB out transponder now. (Evergreen Soaring) We’ve had glider pilots we’re towing that have FLARM ask us to turn off our transponder. We’ve told the glider pilots to turn their FLARM down or off. My recommendation is to either have a switch for your FLARM or know you can turn the volume down to a suitable level.

The question I have is does FLARM show up on ADSB in?

[SoaringXCellence]

No! it's been discussed before, there is no relationship between the signals of the two systems. PowerFlarm does not do any output of ADS-B, it only receives.

[Darryl Ramm]

On Friday, June 1, 2018 at 6:01:43 PM UTC-7, Charles Longley wrote:
> One of our Pawnees has an ADSB out transponder now. (Evergreen Soaring) We’ve had glider pilots we’re towing that have FLARM ask us to turn off our transponder. We’ve told the glider pilots to turn their FLARM down or off. My recommendation is to either have a switch for your FLARM or know you can turn the volume down to a suitable level.
>
> The question I have is does FLARM show up on ADSB in?

As discussed here before the solution to spurious PowerFLARM alerts in the glider to the towplane ADS-B Out may be to put a PowerFLARM in the towplane so the PowerFLARM in the glider knows it's a towplane and more tolerant of it being close to the glider. There is unfortunately no way for an ADS-B out signal to contain any information to tell PowerFLARM it's a towplane. The FLARM signal does carry that information. it would be great if somebody could experiment with a PowerFLARM portable in the towplane to see if it indeed does solve the issue.

Be careful turning those transponders off, they provide visibility to other aircraft with ADS-B In, TCAS, ATC, all gliders with PowerFLARM with 1090ES In option etc. And if in controlled airspace its a violation of 14 CFR 91.215... and since the towplane is transmitting ADS-B data for all to see and the signal starts going of in flight that may well get noticed. The likely better option if necessary here is for the glider to turn off or turn down the volume on their PowerFLARM while on tow.

[George Haeh]

You might want to try putting the towplane ICAO ID on FlarmNet and, after the update is available, installing the updated FlarmNet file on the display devices.

Possibly the PowerFLARM will then process the ADS-B return as a towplane. No guarantees, but it may be worth a try and the rest of us would like to know.

[Dan Daly]

On Saturday, June 2, 2018 at 8:53:41 AM UTC-4, George Haeh wrote:
> You might want to try putting the towplane ICAO ID on FlarmNet and, after the update is available, installing the updated FlarmNet file on the display devices.
>
> Possibly the PowerFLARM will then process the ADS-B return as a towplane. No guarantees, but it may be worth a try and the rest of us would like to know.

Interesting idea. I see in FLARMnet there is a selection for "towplane" in the menu...

[son_of_flubber]

What is Flarm Inc guidance on Flarm-ADSB glider-towplane interoperability? Trying to determine the true repeatable behavior of Flarm and ADSB based on a few experiments is back-assward.

On Saturday, June 2, 2018 at 1:31:39 AM UTC-4, Darryl Ramm wrote:
>... it would be great if somebody could experiment with a PowerFLARM portable in the towplane to see if it indeed does solve the issue.

[Charles Longley]

Good info guys! I am doing more research. There’s an ADSB in option for PowerFLARM that must be what some of the glider pilots are seeing. So if someone put put a Power FLARM core with the ADSB in option into a tow plane what would be the best way to display it? I am thinking iPad mini so ForeFlight could be used for Aero retrieves.

[Darryl Ramm]

Again, this has all been discussed here in the past. It's FLARM's own comment to somebody experiencing this issue that a PowerFLARM in the towplane should prevent this. Doing a test to confirm you get the benefit that FLARM state seems a very good idea.

I don't expect t putting the towplane into FLARMnet will make a difference for this problem. FLARMnet is about displaying labels for targets, I don't believe that information is used to suppress an alert... but that gets into the behavior of the third party FLARM display, so who knows for sure. So yes, given all the combinations of displays etc. I absolutely would be doing some quick experiments here. And having the towplane in FLARMnet listing it's ICAO ID even if it does not have a PowerFLARM so that other aircraft with a PowerFLARM see a better label for it is nice idea.

[Dave Nadler]

To clarify Darryl's comment: FLARMnet data is used by display devices only.
FLARMnet is not used by FLARM or PowerFLARM and has nothing to do with alerts.

Please register your ICAO (FLARM) ID in FLARMnet so everyone using a
FLARMnet-compatible display device (and who has downloaded FLARMnet DB into it)
will see your ID.
Not registering is anti-social!
Thanks!

[Darryl Ramm]

On Saturday, June 2, 2018 at 8:34:12 AM UTC-7, Charles Longley wrote:
> Good info guys! I am doing more research. There’s an ADSB in option for PowerFLARM that must be what some of the glider pilots are seeing. So if someone put put a Power FLARM core with the ADSB in option into a tow plane what would be the best way to display it? I am thinking iPad mini so ForeFlight could be used for Aero retrieves.

You really should look through some old threads on r.a.s. on this stuff.

You don't need a PowerFLARM core, you could use a portable. I would start with trying to borrow somebody's PowerFLARM Portable for an easier quick test. Sure a core could be more nicely installed.

Almost all PowerFLARM in the USA have the "ADS-B" Option. Which is 1090ES In Only. About half a dozen out of many hundred units sold in the USA don't have this option, and some of those owners I've talked to really regret not getting the ADS-B Option. PowerFLARM has some restrictions with ADS-B In, basically bemuse of it's European centric development, they are not being dual-link In (so it cant' see UAT Out equipped targets) and not supporting TIS-B and ADS-R... all that makes it not great for an ADS-B In option in GA/power aircraft.

PowerFLARM is aimed at the glider not GA community, PowerFLARM talks FLARM serial protocol and you can display that ADS-B traffic on any devices that supports that protocol (e.g. LXNav FLARMView displays, Air Avionics traffic displays, LXNav flight computers, ClearNav flight computers, Naviter Oudie, PDA/PNAs running soaring software, etc.)

PowerFLARM does *NOT* talk GDL90 or Garmin display protocol and so cannot display on ForeFlight or similar GA EFB applications.

I would hope the main benefit of having a PowerFLARM in a towplane would be increased safety from better awareness of FLARM equipped gliders and other towplanes while airborne, with hopefully the secondary benefit of helping PowerFLARM equipped gliders on tow not get these annoying alerts about the towplane with ADS-B Out. That all seems much more intersting than finding glider for retrieves. And there practically you need (1) line of sight to the glider on the ground, (actually it's transponder antenna, which might be obscured by the fumerslage... but it's got a lot of power so hopefully will work... but best case you are likely to get a few tens of miles of range, and (2) the glider pilot to leave the transponder on transmitting ADS-B Out and (3) I suspect rely on the glider on the ground *not* transmitting surface mode ADS-B Ou messages which the PowerFLARM will likely ignore... and the glider is required to do that for a 2020 Compliant/SIL-3 ADS-B Out installs. Options like Garmin inReach and Spot and good old VHF radio seem more useful for retrieves, but it's a great thing to think about and something to maybe play with (yes more tests).

[Charles Longley]

I was actually talking about using ForeFlight for navigation on an aero retrieve. Not to find the glider. Generally we only do aero retrieves to airports. If a glider lands in a farmers field they generally have to go get it with their trailer. So my question is what app can I display FLARM on in an iPad? I picture using the FLARM display app for towing and Foreflight for navigation.

I’ll get the one tow plane we have ADSB out in registered on the FLARM net.

[Charles Longley]

And you guys need to relax about the fact that’s this has been discussed before. More and more tow planes are getting ADSB out. As discussed most of the glider FLARM units in the US have ADSB in. This is something glider pilots and tow plane operators need to be aware of and resolve.

I just got back from Ephrata and was reading the latest issue of Soaring. I noticed a letter from our friends over at PSSA. Their Chief Tow Pilot wrote on this exact issue.

[Darryl Ramm]

On Saturday, June 2, 2018 at 11:15:50 AM UTC-7, Charles Longley wrote:
> I was actually talking about using ForeFlight for navigation on an aero retrieve. Not to find the glider. Generally we only do aero retrieves to airports. If a glider lands in a farmers field they generally have to go get it with their trailer. So my question is what app can I display FLARM on in an iPad? I picture using the FLARM display app for towing and Foreflight for navigation.
>
> I’ll get the one tow plane we have ADSB out in registered on the FLARM net.

This is probably the wrong way to think about providing traffic data/warnings from FLARM in a towplane. You want a dedicated FLARM traffic display mounted high up on the panel (or just a PowerFLARM portable) in the towplane and audio wired though your radio/audio panel. Tow pilots are not going to want to fart around with complicated soaring software on an iPad just to see traffic.

And again FLARMnet is not likely to help the glider on tow getting false alerts from towplanes ADS-B Out.

If you want to use a iPad with Foreflight in the towplane for other purposes, for all the reasons I mentioned before, and more, I would get a portable Stratus or Stratux receiver.

[Charles Longley]

I am not that worried about the glider on tow. They can turn their FLARM down or off.

The ideal installation on a tow plane would be a PowerFLARM brick with external antennas. It doesn’t look like there’s any way to display FLARM on an iPad so there would need to be a simple to use display mounted on the glare shield. I was just looking at the FLARM website and didn’t see a lot of options. How is FLARM normally displayed in a glider. (My glider doesn’t have it)

[Darryl Ramm]

On Saturday, June 2, 2018 at 12:00:23 PM UTC-7, Charles Longley wrote:
> I am not that worried about the glider on tow. They can turn their FLARM down or off.
>
> The ideal installation on a tow plane would be a PowerFLARM brick with external antennas. It doesn’t look like there’s any way to display FLARM on an iPad so there would need to be a simple to use display mounted on the glare shield. I was just looking at the FLARM website and didn’t see a lot of options. How is FLARM normally displayed in a glider. (My glider doesn’t have it)

Uh oh. You have to read past posts on r.a.s. to find that out. Like the ones immediately above where I describe those -)

[Charles Longley]

Are you talking about this statement?
“PowerFLARM is aimed at the glider not GA community, PowerFLARM talks FLARM serial protocol and you can display that ADS-B traffic on any devices that supports that protocol (e.g. LXNav FLARMView displays, Air Avionics traffic displays, LXNav flight computers, ClearNav flight computers, Naviter Oudie, PDA/PNAs running soaring software, etc.) ”

So will all of those options display FLARM targets?

Look I am a power guy that’s transitioning to gliders for retirement. So I have questions. I just got my first glider specific computer an Oudie a couple of weeks ago.

[Darryl Ramm]

On Saturday, June 2, 2018 at 11:25:11 AM UTC-7, Charles Longley wrote:
> And you guys need to relax about the fact that’s this has been discussed before. More and more tow planes are getting ADSB out. As discussed most of the glider FLARM units in the US have ADSB in. This is something glider pilots and tow plane operators need to be aware of and resolve.
>
> I just got back from Ephrata and was reading the latest issue of Soaring. I noticed a letter from our friends over at PSSA. Their Chief Tow Pilot wrote on this exact issue.

Yes the issue is important to let folks know about, but it would be better to do that in way not to add yet more confusion. The letter in Soaring Magazine unfortunately missed that this a known issue and FLARM have already commented on a way to resolve this. It may not be a way that people like, but knowing that is a lot better than not.

And to avoid confusion there, PowerFLARM does not "interrogate ADS-B". And I'm not sure what contacting the FAA will help here, or what they are expected to do about an unregulated ADS-B receiver.

I would hope some of the more technology geeky glider pilots in the broad Seattle/Pacific North West area already know about this issue, or know folks to ask (e.g. FLARM dealers, or Dave, or me). And if not PSSA then SGC folk likely do (hi Craig, Kelvyn).

[MNLou]

> Look I am a power guy that’s transitioning to gliders for retirement. So I have questions. I just got my first glider specific computer an Oudie a couple of weeks ago.

Hi Charles -

Welcome to gliding! I have a PowerFlarm - S8 - Oudie set up. I don't have the option of turning off the PowerFlarm.

As part of my "get in the glider" checklist, I turn the Oudie volume down to 20% when I adjust the Oudie's altitude. On tow, I just ignore the written warning messages and the audibles are easy to ignore. Once off tow, the warnings go away and I turn my Oudie volume up to 80% for the rest of the flight.

I hope that helps.

Lou

[Darryl Ramm]

Yes. And they also show ADS-B (1090ES Out only) targets *when received by a PowerFLARM*.

This whole area is unfortunately a quagmire of confusing stuff. The soaring/FLARM related stuff is very specialized and the European vendors largely do an poor job explaining how their stuff will or won't work in the more complex USA ADS-B environment. Be careful their reading product specs/claims and assuming too much from that before talking to folks who know what actually works.

And you are going in multiple directions here. I would encourage you to start by talking with local glider pilots who have PowerFLARM installs and have them show you/demo what they have. You may be able to borrow a Portable unit to fly with in your glider or towplane or at least play with on the ground.

Your Naviter Oudie will display FLARM traffic data (FLARM and ADS-B/1090ES In traffic data from a connected PowerFLARM). You can find out more in the Oudie/SeeYou documentation look for "FLARM Radar", they mean FLARM traffic display by that... I wish Naviter would just call it "FLARM traffic".

Some folks (like me) would prefer a more dedicated FLARM traffic display on their panel even if they also have that data going to something like an Oudie.

The PowerFLARM might simply drive a Oudie over hard wired serial connection and providing basic GPS as well as traffic data to the Oudie, more sophisticated installs will combine data from a soaring vario/flight computer and traffic data from the PowerFLARM. The moment you start scratching this it likely gets complex. And you are missing a decade or so of experience folks here have with this stuff, so again your local PowerFLARM users are likely the best place to start. And once you get a better idea of all the possible options and what you want to do then one of the USA PowerFLARM dealers is the place to go. They should know what works with what, all the bits you need, and how to configure stuff or how to get questions answered if they don't know.

[Dan Marotta]

XCSoar will display FLARM targets, but it may only work on Android devices.

On 6/2/2018 12:15 PM, Charles Longley wrote:
> I was actually talking about using ForeFlight for navigation on an aero retrieve. Not to find the glider. Generally we only do aero retrieves to airports. If a glider lands in a farmers field they generally have to go get it with their trailer. So my question is what app can I display FLARM on in an iPad? I picture using the FLARM display app for towing and Foreflight for navigation.
>
> I’ll get the one tow plane we have ADSB out in registered on the FLARM net.

--
Dan, 5J

[Charles Longley]

Hi Lou,

Thanks for the info!

I am really enjoying my new found sport. I finally got out on a couple of decent cross country flights last week. Looking forward to some more.

Power FLARM is certainly in the works for next season along with hooking up the Oudie to my Cambridge vario.

Charlie

[Charles Longley]

I’ve heard from a lot of glider pilots and seen the comment that the FLARM can’t be turned off. I was reading through the PowerFLARM core installation manual and it says-“Connect PowerFLARM CORE via a dedicated pilot-operated 2 ampere CB. ”

How long would it take the FLARM to boot up and find itself if you didn’t push the CB in until after you release from tow?

[Darryl Ramm]

On Saturday, June 2, 2018 at 2:06:24 PM UTC-7, Charles Longley wrote:
> I’ve heard from a lot of glider pilots and seen the comment that the FLARM can’t be turned off. I was reading through the PowerFLARM core installation manual and it says-“Connect PowerFLARM CORE via a dedicated pilot-operated 2 ampere CB. ”
>
> How long would it take the FLARM to boot up and find itself if you didn’t push the CB in until after you release from tow?

< minute. But it's not that simple. As somebody else already mentioned many pilots will be relying on the PowerFLARM as a flight recorder. Or even if relying on it to to drive a PDA you may have problems getting the soaring software set up correctly, pressure altitude set correctly etc. without a GPS driving stuff.

Pilots are unlikely going to won't want to risk problems, especially in contests or badge flights. And adding to the pilot workload and distractions to do stuff and then check things are working in a thermal off tow or maybe a pre-start gaggle is a bad idea. Turning down the volume seems a much better idea. Or even better put that PowerFLARM in the towplane and hopefully the issue just goes away.

[Charles Longley]

Those are all excellent points! Glad I asked the question.

[jfitch]

On Saturday, June 2, 2018 at 2:18:17 PM UTC-7, Charles Longley wrote:
> Those are all excellent points! Glad I asked the question.

You CAN display Flarm targets on an iPad, but it requires a specific installation. You will need an Air Connect interface and the iGlide software from Air Avionics. The Air Connect uses the RS-232 stream from the Flarm and sends it via WiFi to the iPad. On the iPad, iGlide will display all the targets that PowerFlarm can see, which will be Flarm equipped gliders and ADS-B traffic. You can also use iGlide for navigation as it is a full tactical computer with GPS moving map, airspace, etc. There is a variation of it called iPilot for GA aircraft, but I don't think it will connect to the Flarm.

Another app that will display Flarm on an iPad is Winpilot Live (still requires the Air Connect). Both apps are on the Apple app store. The Air Connect can be had from Craggy Aero, installation is simple on a PowerFlarm, one plug for power and data.

[jfitch]

On Saturday, June 2, 2018 at 2:06:24 PM UTC-7, Charles Longley wrote:
> I’ve heard from a lot of glider pilots and seen the comment that the FLARM can’t be turned off. I was reading through the PowerFLARM core installation manual and it says-“Connect PowerFLARM CORE via a dedicated pilot-operated 2 ampere CB. ”
>
> How long would it take the FLARM to boot up and find itself if you didn’t push the CB in until after you release from tow?

Many glider pilots will not want to turn off Flarm until after release, because they are using the Flarm IGC logger to document their flight. Leaving it off until release is not an option as it will leave the takeoff, field elevation, etc. undocumented making the flight likely invalid for competition, OLC, or other uses.

To answer your question, it will only take 30 seconds or less to boot and find position. But the damage to the log file is already done.

[markde...@gmail.com]

Rather than turn off the powerflarm core, simply turn off the FlarmView that is connected to the Flarm. Intercepting the power lead in the cable going to the Flarmview and routing that to a panel mounted switch will keep the Flarm running (good for your flight log and keeps you visible to other Flarm traffic) and you won’t get annoying beeping while on tow. Once off tow, you can power up the Flameview and be on your way.

[Darryl Ramm]

Yes, but to be clear, that can't display on Foreflight (a just *wonderful* GA app), which was the original question. And since he already has an Oudie and C302 I know what I'd be doing... adding a PowerFLARM and K6 Mux and possibly a Flarmview display.

Now if only SeeYou Mobile ran on an iPhone I'd care more using those (OK I said that just to annoy Jon). :-)

[Dan Marotta]

So...  Will the glider pilot complaining that his PF alerts on the tug's
ADS-B be willing to foot the bill to put a PF portable into the tug?

--
Dan, 5J

[jfitch]

SeeYou mobil runs on an iPhone just about as usefully as it runs on an Oudie or an Android phone. :)

[waremark]

Does Foreflight run on Android? In Europe we don't have Foreflight. Instead we have SkyDemon, an outstanding app for GA which I believe is comparable to Foreflight. SkyDemon runs equally well on Android or iOs devices, and can accept an input from Powerflarm. The SkyDemon folk market the use of PF for traffic awareness to GA pilots.

It is rather cheaper and simpler to use an Android tablet with the free to use XC App and PF than to go down the iOs route. But if Foreflight does not run on Android I suppose you afe stuck with an iPad cor GA flight planning and nav. If so, i am grateful to SkyDemon for giving us the option of Android.

BTW, I rate the Oudie very highly. It is extremely flexible- which is a strength for power users and which is difficult for those who want a turnkey solution.

[Darryl Ramm]

ForeFlight is iOS only and they seem proud of that and how being focused on a single platform helps them. And it may, it's very impressive software. What is most impressive is how much damage they have done to Garmin in the GA EFB/portable device market. Now coming to Europe. https://foreflight.com/europe

[jfitch]

How does SkyDemon get Flarm information into an iOS device?

I am a power user, but I would rather spend that power doing useful things, than making SYM work. :)

On Saturday, June 2, 2018 at 6:01:36 PM UTC-7, waremark wrote:

[2G]

On Friday, June 1, 2018 at 10:31:39 PM UTC-7, Darryl Ramm wrote:
> On Friday, June 1, 2018 at 6:01:43 PM UTC-7, Charles Longley wrote:
> > One of our Pawnees has an ADSB out transponder now. (Evergreen Soaring) We’ve had glider pilots we’re towing that have FLARM ask us to turn off our transponder. We’ve told the glider pilots to turn their FLARM down or off. My recommendation is to either have a switch for your FLARM or know you can turn the volume down to a suitable level.
> >
> > The question I have is does FLARM show up on ADSB in?
>
> As discussed here before the solution to spurious PowerFLARM alerts in the glider to the towplane ADS-B Out may be to put a PowerFLARM in the towplane so the PowerFLARM in the glider knows it's a towplane and more tolerant of it being close to the glider. There is unfortunately no way for an ADS-B out signal to contain any information to tell PowerFLARM it's a towplane. The FLARM signal does carry that information. it would be great if somebody could experiment with a PowerFLARM portable in the towplane to see if it indeed does solve the issue.
>
> Be careful turning those transponders off, they provide visibility to other aircraft with ADS-B In, TCAS, ATC, all gliders with PowerFLARM with 1090ES In option etc. And if in controlled airspace its a violation of 14 CFR 91.215... and since the towplane is transmitting ADS-B data for all to see and the signal starts going of in flight that may well get noticed. The likely better option if necessary here is for the glider to turn off or turn down the volume on their PowerFLARM while on tow.

If you have a transponder installed, you are required to operate it at all times unless otherwise directed by ATC (i.e. Oshkosh).

Tom

[Darryl Ramm]

That's not quite accurate, you are required to operate an installed transponder at all times in *controlled airspace*. 14 CFR § 91.215 (c). So they can be turned off in Class G airspace. Maybe a good aviation quiz night question, or BFR question. But to the point, yes turning them off is a bad idea.

[Dan Marotta]

Foreflight does not run on Android though Garmin Pilot runs on both. 
Having run Garmin Pilot on both platforms, I can say that it has more
features in the iOS version than the Android version.  It also crashed
quite often on the Android and never (yet, 3 months) on iOS.

--
Dan, 5J

[2G]

Wrong: 91.215 states where you MUST operate your transponder - it says nothing about allowing a pilot to turn it off. The matter is addressed in section 4−1−20 of the AIM (https://www.faa.gov/air_traffic/publications/media/AIM_Basic_dtd_10-12-17.pdf), "Transponder Operation:"

4. Transponder and ADS-B Operations in
the Air. EACH PILOT OPERATING AN AIRCRAFT EQUIPPED WITH AN OPERABLE ATC TRANSPONDER, MAINTAINED IN ACCORDANCE WITH 14 CFR SECTION 91.413 OR ADS-B TRANSMITTER, MUST OPERATE THE TRANSPONDER/TRANSMITTER, INCLUDING MODE C/S IF INSTALLED, ON THE APPROPRIATE MODE 3/A CODE OR AS ASSIGNED BY ATC. EACH PERSON OPERATING AN AIRCRAFT EQUIPPED WITH ADS-B OUT MUST OPERATE THIS EQUIPMENT IN HE TRANSMIT MODE AT ALL TIMES WHILE AIRBORNE UNLESS OTHERWISE REQUESTED BY ATC.

Notice the use of ALL CAPS: the FAA is shouting this requirement out at us. Furthermore, the glider involved in the Minden mid-air collision with the Hawker jet was faulted for not operating his transponder (https://www.ntsb.gov/_layouts/ntsb.aviation/brief2.aspx?ev_id=20060906X01297&ntsbno=LAX06FA277A&akey=1) even though they were not in controlled airspace at the time.

Tom

[waremark]

Your hatred of the superb Oudie continues to mystify me.

For anyone unclear about this, SeeYou Mobile is excellent soaring software. Its makers sell several versions of a hardware device which runs it, the Oudie, and it also runs on third party Window CE devices - all now old and obsolete. The makers have presumably chosen not to port it to Android because there are at least three versions of soaring software for Android which are free to use. Whether or not SYM is better than the free software, I don't expect pilots would choose it over the free options.

iGlide which Jon prefers probably has the easiest interface to learn at the expense of reduced flexibility.

[jfitch]

And yet, the regulation does not say that. The relevant section 91.215 (c) is quoted here in it's entirety:

"(c) Transponder-on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an air- craft equipped with an operable ATC transponder maintained in accordance with §91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC."

The airspace specified in paragraph (b) is controlled airspace. The AIM can say whatever it likes, the regulation is clearly worded and is the law. I'd agree that keeping it on at all times is a good idea, and do myself. But it is not required outside of controlled airspace.

[2G]

The AIM clearly states that it must be on in no uncertain terms (did you not read that?), so there is no wiggle room as far as the FAA is concerned. There are times when ATC will direct pilots to turn off their transponders, such as the EAA fly-in at Oshkosh, but they must be on otherwise. 91.215 nowhere gives the pilot the discretion of turning off the transponder in uncontrolled airspace. And the glider pilot was, indeed, found liable in the Minden mid-air.

Tom

[Darryl Ramm]

On Sunday, June 3, 2018 at 11:15:00 AM UTC-7, 2G wrote:

(With apologies to John Adams) We are a nation of laws not Aeronautical Information Manuals.

AIM is not a regulation. The 14 CFR § 91.215 regulation is *very* clear. And those regulations, and case law, is what determines what is legally required.

And being told where you are required to do something, also implies where you are not required to. The regulation does not need to discuss the transition between those states that are bleeding obvious. Nobody should be confused that the meaning here is going from required to be on to not required to be on might mean the pilot might... wait for it... ta.. da.. turn it off. And specially since the regulation does not say you cant' turn it off in that transition then you bloody well can.

And secondarily the section of the AIM you are referring to is discussing the provision of ATC services, which relies on transponders and ADS-B out, and if you are receiving those service than what you are quoting above is kind obvious, and fully consistent with 14 CFR § 91.215. Even if it was inconsistent with a regulation FAR/AIM cannot change that regulation or how you are required to comply with it.

I think this is the second time on r.a.s. recently where you quoted stuff claiming it proves some point of yours and instead had you dug a bit deeper you would have seen it was consistent with what others are saying.

----

And for those playing along at home...

Of course, in practice turning off transponders and ADS-B Out systems is a bad idea.

Turning off a transponder (unless directed by ATC) in controlled airspace ((everything except Class G) is also a violation of 14 CFR § 91.215.

Turning off an ADS-B Out system (unless directed by ATC) in *any* airspace is a violation of 14 CFR § 91.225(f) "Each person operating an aircraft equipped with ADS-B Out must operate this equipment in the transmit mode at all times." Well that's great given the goals of ADS-B and how it differs from ATC surveillance radar and meaning of controlled airspace.

So if your transponder is also doing 2020 Complaint 1090ES Out then now you can't turn it off in any airspace because doing so would turn off the ADS-B Out.

Ah but now what about TABS ADS-B Out systems? Does 14 CFR 91.225(f) cover that as well? I would say no as 14 CFR § 91.225 is all about regulations applying to "2020 Compliant" ADS-B out systems specified in 14 CFR § 91.227. And if 14 CFR § 91.225 and/or § 92.227 applied to TABS then we have all sorts if other issues. An illogical rat hole that nobody including the FAA likely would want to go down.

Not that any of this actually matters (just leave stuff tuned on) but if it did then a letter to the FAA Office of the Chief Counsel would help clarify this question about TABS. And they tend to take a pretty clear and supportive view of stuff that if it's not really explicit then its allowed (transponder carriage exemptions for gliders come to mind, glider pilots (including me in the past) assumed they might imply more restrictive regulations than they do, the Office of the Chief Counsel on multiple occasions clarified they don't).

See now, hopefully we are pretty well armed for a boozy Aviation quiz night questions about turning off transponders and ADS-B Out. ...

[Darryl Ramm]

You seem confused about how regulatory law in the Unites States works. Stuff in the AIM might as well be in a children's coloring book as far as determining regulatory compliance.

---

And what the hell does the Minden midair collision have to do with this? That was not uncontrolled airspace to start with, 16,000' over the Pine Nut range is Class E == *controlled* airspace. The NTSB report addresses *nothing* to do turning off transponders outside of uncontrolled airspace.

NTSB LAX06FA277A final reports: "Probable cause: The failure of the glider pilot to utilize his transponder and the high closure rate of the two aircraft, which limited each pilot's opportunity to see and avoid the other aircraft."

That's a statement of probable cause. I'd be careful not to call that a finding of "liability", and the glider pilot has stated reasons why they believed they should not operate the recently installed but not 14 CFR 43, Appendix E & F checked transponder. I hope I would have made a different decision.

[2G]

The AIM is subtitled "Official Guide to Basic Flight Information and ATC Procedures." What part of "Official" don't you understand? The section I quoted is in no way qualified by other paragraphs - it stands on its own. The AIM is an excellent resource in regards to how the FAA interprets FARs - your interpretation and five bucks will buy you a cup of coffee at Starbucks.

And, did you not read the NTSB findings on the Minden glider-jet mid-air? They ALSO agree with me.

If you think you can legally turn off your transponder anytime you want in uncontrolled airspace, you are skating on thin ice. You can deviate from regs if it is a flight safety issue, however.

And I believe I corrected your false claim that all ADS-B Out installations are a minor modification.

Tom

[2G]

Fault was determined by the NTSB - liability was determined by the insurance companies.

Tom

[2G]

I view that statement as being a dangerous, elitist disregard of how us pilots should operate in a safety-centric, collaborative setting with the FAA. You have sunk to a new low for bloviating.

Tom

[jfitch]

You certainly did no such thing. Regarding ADS-B out being a major or minor, Darryl said 'it depends' but often is a minor change. You confirmed EXACTLY THAT with your FSDO. Go back and read the thread, this time for comprehension.

The AIM is a low level bureaucrat's interpretation of the regulations. It cannot be enforced unless a judge agrees with that interpretation. There are literally millions of court cases where the judge has not agreed. In this particular case the wording is completely clear and unambiguous.

[Darryl Ramm]

I never said that. I was correcting you claim that all ADS-B Out installs (in type certified aircraft) are major modifications. You seemed to made the common mistake that because FAA policy asks for a 337 they are therefore major changes. I said they do require a "notification only" 337s but are not necessarily a major modifications, only if they are for the usual reasons. You then went and got an FAA FSDO person who agreed with what I had been trying to tell you. You seem to have really confounding problems following simple logic/reasoning and keep inverting stuff, or finding contradictions where they don't exist.

I'd already made the comment in this thread about what is allowed by regulations and you commented later saying something different. I don't care what you personally think about anything, but when you keep stating stuff on r.a.s. again and again that is simply just wrong I am going to correct you.

[JS]

Wonder if Las Vegas bookies have odds on this?
Jim

[Mike Schumann]

For all practical purposes, if you have a transponder equipped aircraft you need to leave it on at all times. While technically you can turn it off in Class G airspace (unless that also disables your ADS-B OUT installation), in the continental US, we are almost always flying in or transitioning thru Class E airspace, so this distinction is really moot.

[Darryl Ramm]

Yes absolutely, leave the damn thing on (and it there is a reason you think you can't then fix it).

I was hoping to make that clear. It is also great that this regulatory weirdness about controlled airspace applies to Transponders but not ADS-B Out. And folks need to remember how easy for anybody watching to notice an ADS-B targets just going off the air.

The original question here came from glider pilots asking a tow pilot to turn off the towplanes' ADS-B Out. We got sidetracked calling that a "transponder". If I was the tow pilot I know what my response would have been.... :-)

[Charles Longley]

What’s an informational 337? Never heard of one until now.

Charlie
A&P/IA

[Darryl Ramm]

Don't worry, you are not alone, this has caused a reasonable amount of confusion and not just with gliders. Have a read of FAA 8900.362 - Policy for Installation of ADS-B OUT Systems. https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.information/documentID/1029526 (no that policy really has not expired).

An "information only" 337 is what the FAA wants you to complete and send to FAA HQ in Oklahoma for an ADS-B out install. It's so they can track what is being installed. It's not the normal use of an 337 sent to the FSFDO for field approval for a major alteration. This has been discussed here in detail before in the thread linked in previous posts. There are multiple other FAA reference docs giving the same guidance listed in that other thread. The FAA may not formally refer to these as "information only" 377 but thats a term used by others, and by FAA folks when you talk to them.

The misconception that an ADS-B out install is by necessity a major alteration and requires a 337 (to the FSDO) has seemed to cause some glider owners unnecessary pain. Folks get confused and send the 337 to the FSDO and then the FSDO assumes they are seeking field approval for a major alteration, and you end up with folks trying to jump through hoops and find STC etc. and other items for install in a glider that are likely not required in the first place. And the pain starts with: there are no STCs for any transponder install in any glider. None, nada, zilch. And if you read the above policy, you'll see the STC mentioned, but it explains that is also a special case for an ADS-B Out install--the STC there is only required to establish the pairing of a particular transponder and GPS source, not the basis for a design approval for a major modification.

Since this confusion has created issues for some owners my effort to explain it here was is to avoid others suffering. Of course if an A&P IA has good reason to determine if any install actually is a major modification then that's a different discussion. Most installs of avionics in gliders are not considered major modifications, and the FAA has been supportive of that position, and there is no regulation that makes ADS-B Out installs special cases where they are automatically major alterations. The other thing I've suggested people do is let their A&P IA seek any clarifications about these from the FAA instead of trying to contact FSDO staff themselves.

There is no FAA notification required for ADS-B Out installs in experimental aircraft and none required for TABS/TSO-C199 (read that TSO for more info) install in any aircraft since 14 CFR 91.225/91.227 (the only thing that policy above applies to) don't apply to TABS... that's another whole point of potential confusion with owners or A&P contacting the FSDO and asking about "ADS-B Out" installs where they mean TABS and the FSDO will likely assume 2020 Complaint systems not TABS, and staff there may just not know what TABS is at all. And now we have at least one glider owners who has got an ADS-B Out non-compliance letter from the FAA for their TABS systems because the FAA ADS-B Out compliance reporting does not understand TABS. I'm helping respond to that letters (and can provide a draft of the response letter to anybody who wants one) and I hope this is a great opportunity to help educate more FAA folks on TABS and gliders in general.

[Dan Marotta]

Free beer in my hangar if you guys will come and have this discussion
face to face.  Maybe it could be settled once and for all.

--
Dan, 5J

[Charles Longley]

I don’t know if I agree with you. If an ADSB out can be installed in any type certified aircraft without a 337 why do the manufacturers bother with a STC? I’ve installed a Stratus transponder in a Pawnee using the policy you quoted. I didn’t consider it an informational 337 when I did it. The FAA gets information on which airplanes have ADSB when they’re flown in the national airspace system.

Experimental aircraft are a whole different subject.

[Darryl Ramm]

On Monday, June 4, 2018 at 7:38:18 AM UTC-7, Charles Longley wrote:
> I don’t know if I agree with you. If an ADSB out can be installed in any type certified aircraft without a 337 why do the manufacturers bother with a STC? I’ve installed a Stratus transponder in a Pawnee using the policy you quoted. I didn’t consider it an informational 337 when I did it. The FAA gets information on which airplanes have ADSB when they’re flown in the national airspace system.
>
> Experimental aircraft are a whole different subject.

This has been flogged to death on r.a.s. in the recent past, and the person who was then confused about it went to his FSDO, which confirmed what I was saying. But I'll spare your the pain of wading though that tangled ball.

I did try to addressed exactly the reason an STC is usually needed in the post before. The STC is needed (as the easiest way) to establish a valid pairing between a ADS-B Out tranmitter (e.g. transponder) and a GPS source. You are expected (by that FAA policy) to follow that STC for the configuration related to that device pairing (or if a single box, presumably the setup in that box related to the GPS source). This stuff is in pretty clear English (especially section (6)) of the FAA policy doc I gave you the link to.

You are not required to treat the install as a major alteration and to use that STC for an approval basis just because this is an ADS-B install (if you think you are please explain exactly what establishes that). If you otherwise determine the install is a major alteration then an STC specific to the install in that aircraft is going to provide the basis for a field approval, and you would file a 337 with the FSDO. If it's not a major alteration then you just need an STC that establishes the pairing of those devices, and it does not need to be specific to that aircraft.

Manufactures here clearly need STCs for the pairing basis. Manufacturers also need some STCs for installs as a major alteration approval basis because well those installs are really major alterations, manufactures also like to have STCs to cover stuff where they may not really raise to the level of major alterations but some A&Ps (and FSDO staff) might be nervous about doing stuff without an STC. Many of the existing install STCs were also developed in the past where the installs process was more complex.

The FAA cannot get information they want from the equipment installed in aircraft from direct monitoring of the ADS-B Out signal. There is no data transmitted over ADS-B Out that describes the transmitter or GPS source manufacturer or model (I wish there was), and no way to collect from that the magic info of which A&P signed off on the install. Which given how many ADS-B Out install fail from basic setup/software configurations I suspect they want to know and track down those responsible--to help avoid more, the FAA seems to be being very supportive/helpful with installs but there are so many problems with installs for them to track down. Since an ADS-B Out install is not necessarily a major alteration a 337s would not necessarily be filed with the FSDO so the FAA is seeking a way here to collect all this information and using a 337 form in an unusual way to do that. They would never have bothered with creating that extra process if all installs were major modifications with 337s going to the FSDOs.

I hope you did followed the process the FAA expects for the ADS-B Out equipment you installed in the Pawnee. If you also decided that install required a major alteration approval for other reasons then that that was your decision. I hope you submitted the "notification only" 337 to Oklahoma, if not you may want to go ahead and do that. Not doing that might eventually get the club a "please explain" letter.

[Charles Longley]

Did you not read my post? I said I sent a 337 in per the FAA’s guidance. I disagree with you that it was a “notification” 337. But everyone is entitled to their opinion.

[Darryl Ramm]

On Monday, June 4, 2018 at 7:07:57 PM UTC-7, Charles Longley wrote:
> Did you not read my post? I said I sent a 337 in per the FAA’s guidance. I disagree with you that it was a “notification” 337. But everyone is entitled to their opinion.

I read your post, very carefully, and its not clear what you have done. Did you send a 337 to Oklahoma or the FSDO? Did you treat the installation was a major modification, and if so would you mind explaining why? Did you get the FSDO to approve Block 3 before sending it to Oklahoma? Did Oklahoma send you back the 337 with Block 3 approved? I appreciate your help here explaining exactly what you did, I suspect we may be talking at crossed purposes.

I again want to reiterate that ADS-B Out installations in gliders (I know you did a towplane) should normally be minor modifications, and therefore do not need major modification approval, but do require a "notification only" 337 filed with FAA HQ.

[Charles Longley]

I followed FAA guidance and installed a Stratus transponder with its associated GPS antenna in accordance with the STC. The STC only has a few models in it not including the Pawnee. I filled out the 337 per FAA guidance and sent it off to OK City. It wasn’t a field approval but was a Major Alteration so no need to send it to the local FSDO. Again per FAA guidance. I don’t expect to get the 337 back. I expect it to just be filed with the aircrafts records as usual.

To reiterate there is no such thing as a “notification” 337.

I haven’t been asked to or researched putting an ADS-B out transponder into a glider so I can’t really speak to that. When I install the PowerFLARM brick into my glider in the fall I’ll get the ADSB out option and do the appropriate research/ paperwork.