So what do think will happen???

If I buy an airplane that was "originally certified without an electrical system", but had one added post-certification, can I just yank the transponder out and keep the rest of the electrons? My other option is to remove the electrical system and Velcro an iPad to the panel . . .
Nope and nope.

"or that has not subsequently been certified with such a system installed,"
 
Pay some $$ and make themselves exempt?


Honestly I wish I had the contacts, for only 5 to 10k, and it’s a write off I’d love to “invest” to change some BS laws.
 
Transponders: 91 215 (3) Notwithstanding paragraph (b)(2) of this section, any aircraft which was not originally certificated with an engine-driven electrical system...
ADS-B: 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...

The "engine driven" got removed from the ADS-B rule. So even without an engine driven generator/alternator, if you have a starter, radio, whatever, you get to install ADS-B if you want to penetrate the 30nm ring of death.

Au contraire. The FAA Office of the Chief Counsel has already opined the change in verbiage doesn't change it. It still must be an engine driven system. See attached below.
 

Attachments

  • Schober - (2017) Legal Interpretation.pdf
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219,000 is just the total number of US registered aircraft. I don't know how many of these do not have electrical systems, or even if the FAA has that data. At any rate, the total number of registered aircraft is sufficient to give a rough idea of where we are at. There is of course no way of determining from FAA data how many owners with electrical systems are not intending to equip their aircraft. But if the number of aircraft required or intending to comply were 50% of registered aircraft, it would still not be possible to meet the mandate deadline unless the rate of installation increases dramatically.

Oh I agree that to meet the deadline even just for those that really need it, install rates need to increase. However, it is not as bad as your numbers make it out to be. I do expect the install rate to pick up the closer January 2020 gets. I would venture to guess if you subtract the aircraft that do not have electrical systems, the aircraft that hardly if ever fly into subject airspace, and the ones that might have an occasional need to fly into such airspace but with not enough regularity to make the install worthwhile that the numbers are probably much better than anyone thinks. That is what I'm trying to get at. You also have the folks who might only need ADS-B occasionally who might be planning on waiting until after 2020 when the smoke clears, hoping prices will drop more. I can see that making sense for a lot of people.
 
Au contraire. The FAA Office of the Chief Counsel has already opined the change in verbiage doesn't change it. It still must be an engine driven system. See attached below.
That's a relief - I wanted a starter. . .maybe the electron fairies will install an alternator for me, but forget to log it. I suspect I won't be inside airspace where it'll be a consideration. . .
 
About a year ago, when I was working at an airline on our ADS-B equipage project it amazed me how little options there were. If I remember correctly, there were three manufacturers that were "viable" options. One was already committed to supplying all of their units to new end of line aircraft until something like 2021, the other did not have a product in production yet, and the third was basically the only option we had. I think the airlines don't want to do it for money reasons obviously, but for us, there weren't many options available to actually accomplish the mandate. Wouldn't be surprised if the deadline did get extended, but I think a lot of that blame should be placed on the manufacturers and not the airlines... but this is all info from over a year ago, so the product offerings could have drastically changed.
 
I don't know the numbers, but a significant portion of the 737s that I fly are ADS-B equipped.
 
I see a LOT of airliners via direct Mode-S ADS-B messages on my OTA receiver here and not from rebroadcast on UAT from the tower.

Are they really that far behind, or is that more myth than reality right now?
 
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