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Proposed ADS-B Out Exemption

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jimrice

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Someone has taken the time and effort to draft a proposed exemption to the ADS-B Out requirement per the January 2020 mandate from the FAA. It would encompass aircraft with engine driven electrical which may operate under a 30nm Mode C veil to continue to fly without equipping with ADS-B Out. Since I know several members have other aircraft besides their Cub or some have Cubs with engine driven electrical systems, I thought his might be of interest to you.

This is an individual's suggestion and petition, but is on an offical government site addressed to the FAA. While signing on my prove pointless, it might not be if enough folks actually take the time to respond.

Here is the link: http://www.regulations.gov/#!docketDetail;D=FAA-2014-1061

Here was my input.

I support this proposed exemption. I live under the KMEM Class B veil, yet very rarely fly in the Class B airspace. I fly strictly VFR in my antique airplanes; one with engine driven electrical system and one without. I rarely fly into the KOLV Class D which underlies the KMEM Class B. The vast majority of my flying is outside the Class B veil or under the 4000' floor ring.

The cost for equipping older airplanes for VFR only flight outside the actual Class B, although it is within the veil, is significant. I see the solution as VFR only aircraft which do not operate in the actual Class B, but simply under the veil should be exempt, along with non-electrical aircraft. For VFR, the return on a $5-7,000 investment is virtual nil. Additionally, adding additional complexity and instrumentation places the VFR pilots attention inside the plane when it needs to be more outside. I have no needs for the additional features of weather and such with ADS-B In which further reduces the little added benefit. I'm already flying at the altitude with other non-electric/non-equipped GA community where few will realize a benefit.

Surely there is some compromise for day VFR only aircraft which never fly into actual Class B airspace. Keep the Mode C requirement and restrict entry into the Class B positive control to aircraft equipped with ADS-B out. This exemption along the lines of a non-engine driven electrical system for Mode C would be a great plan for light planes which never fly in Class B and day VFR only. Again, keep the Mode C requirement if you must since we are already equipped inside the 30 nm veil...and the approach radars will continue online for the foreseeable future.
 

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