I am listing my response here and soliciting ALL to submit a comment on the FAA website.
The National Transportation Safety Board issued a Safety Alert Nov. 15, 2016, to pilots with suggestions on what they can do to reduce their chances of being involved in a midair collision.
SEE and AVOID ONLY GOES SO FAR.
Two recent mid-air collisions exemplify this point. On July 7, 2015, a Cessna 150 and an F-16 Air Force fighter jet on a training mission collided. An air traffic controller advised the F-16 pilot that the Cessna was a potential traffic conflict. The F-16 pilot was not able to visually acquire the Cessna until it was too late to avoid the collision. The two occupants of the Cessna were KILLED; the F-16 pilot ejected and survived. On Aug. 16, 2015, a North American Rockwell Sabreliner inbound for landing a Cessna 172 that was practicing landings at the same airport collided. The four occupants of the Sabreliner and the sole occupant of the Cessna were KILLED.
The Safety Alert highlights the value of traffic avoidance technologies to pilots as an aid to detecting and avoiding other airplanes in flight.
The proposed AD is clearly CONTRARY to this NTSB recommendation. AND is contrary to the desires of the FAA to equip most if not all with ADS-B out. AND is contrary to the NSTB 2017-2018 MOST WANTED LIST. The first listed HERE is to INCREASE IMPLEMENTATION OF COLLISION AVIODANCE TECHNOOGY.
Many have purchased the Navworx ADS-B transceiver because it was listed by the FAA as a unit approved and eligible for the rebate. The proposed AD mandating removal, months after, makes many VERY unhappy. In addition, the cost to the Navworx owner as listed in the proposed AD is in error. The cost to the owner should not only include a reasonable estimate of the A&P removal cost (4 hours at $80/hour) but should also include the cost of a new ADS-B transceiver and its installation costs.
I fly with the Navworx ADS-B transceiver installed. After flying with this equipment for 9 months, it clearly provides me with a very much desired safety margin. I fly in VFR conditions and my experimental aircraft is NOT IFR equipped. FAA?s concern appears to be with the accuracy of the Navworx reported GPS position. I DO NOT, nor do I believe many others need an accuracy of inches or a foot. This is clearly a case where engineers developed a set of specifications and did not use any engineering judgement whatsoever, nor did they consider the multitude variations where the ADS-B out units could be installed. (Certified vs. Experimental, VFR vs. IFR, etc., Light planes vs. those that utilize Class A airspace.)
The FAA must reconsider the ramifications of the proposed AD and either cancel it or revise it. If I am forced to disable and remove the Navworx equipment, the probability of me being involved in a mid-air collision has increased many-fold.