ADS-B solution?

[Capt. Geoffrey Thorpe]

From another thread...

91.215 B (3). But, I think 91.215 D (3) also applies:

"For operation of an aircraft that is not equipped with a transponder, the request must be made at least one hour before the proposed operation."

That only applies to aircraft with inop transponders.
Does not apply to aircraft with no engine driven electrical system, they are exempt under 91.215(b)(3).

91.215(d)(3) is asking for a deviation from the reg, it's not a deviation if you are already exempt under 91.215(b)(3)

Given that the ADS-B rules read the same as the above transponder rules, I think I have found my solution for ADS-B: an aircraft with no engine driven electrial system.

I'm not seeing a down side.

91.225
(e) The requirements of paragraph (b) of this section do not apply to any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed, including balloons and gliders. These aircraft may conduct operations without ADS-B Out in the airspace specified in paragraphs (d)(2) and (d)(4) of this section. Operations authorized by this section must be conducted—
(1) Outside any Class B or Class C airspace area; and
(2) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport, or 10,000 feet MSL, whichever is lower.