Originally published at: FAA Reopens Part 108 Comment Period on BVLOS Rule
FAA seeks additional input on electronic conspicuity and right-of-way issues.
ADS-B needs a third party arbitration system. If the FAA says you violated ADS-B rules, there is no real defense that you can mount. They’ve made the penalties real extreme, and you have no effective recourse.
“Portable electronic conspicuity devices were raised as a potential option for aircraft not equipped with installed ADS-B Out, particularly for low-altitude operations.” There it is. The first hint of forced participation through liability. Like telling us all we had a choice over taking the covid shot, but we may not be able to shop, worship or be employed util we bend.
ADS-B was supposed to replace the transponder, then they took away the option of turning it off. I foresee them making it your responsibility to evade drones unless you buy a portable choice.
A means of mediation for perceived infractions must be included in any expansion of rules or participation. There are already reports of passing aircraft reported as landing by ADS-B and hit with landing fees. A means of mediation must be in the rewrite of the application.
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