OK. Just sat through a buncha forums at Sun n Fun about the new "drone" NPRM and about why I should spend 1/3 the price of my 25yr old aircraft, about the cost of an engine overhaul, to put in ADS-B out. Left the event early to let my brain cool off. And my temper.
Presenter after presenter on the ADS-B systems emphasized that they would allow us to see traffic threats and the more we spend, the more threats they'll show us. Aircraft lacking ADS-B will be excluded from A, B, and C and the 30-mile veil because that's where the traffic is concentrated. BS. Those systems don't and won't see all the threats because they weren't designed to. They present the BOXES not the body. Thousands of aircraft won't have boxes under the rule, thus will not show up any better than the 10 to 20 thousand birds which are struck and reported each year. ADS-B is, as one presenter said when questioned about pricing and alternatives, "an expensive system because it has to be totally reliable on a dark and stormy night." Yup, but most of us want an affordable system for a bright and sunny morning. This ain't that.
Couple that info with the sUAS NPRM forums. sUAS will be allowed to fly in B, C, and veil airspace without ADS-B out! Why? Because it's too expensive, too heavy, too complicated, and wouldn't be reliable. I'm not making that up, that's what presenters said about why the rule allows it.
So. Think sun angle, aspect ratio, size, etc. The most likely aircraft to be involved in a midair is the one that isn't looking and that the other pilot can't see and avoid. Which describes the aircraft which WON'T be required to carry the ONLY piece of gear designed to self-announce position to other participating aircraft without reliance on ATC voice transmissions! Oh, and the guy who DOES have the mandated ADS-B out? Might not have paid enough for his unit to have ADS-B in, so even if the sUAS had ADS-B out, it wouldn't make a difference.
As to the "concentrated traffic" argument. Read the Sun n Fun or the AirVenture NOTAMs. When traffic gets heavy, we are required to turn our transponders off because the system can't handle them all. Is that why sUAS won't have ADS-B? Naw, couldn't be, nope. The new system will be bug-free!
The emperor isn't just nekkid, he's nuts.
EAA has lost the bubble on these, too. In their (our) nprm submission which Sean Elliot signed they discriminated between private and public airports and claim "an operating ceiling of 400 feet AGL would create 100 foot safety buffer for both manned aircraft and sUAS."
(http://www.eaa.org/~/media/files/new...20comments.pdf)
First, aircraft at private airports can't collide with sUAS so ignore those aircraft? Second; EMS helicopters, law enforcement aircraft, aerial applicators, powerline and pipeline patrol, etc etc routinely operate below 500' AGL, often WELL below 500'.
I thought EAA would support safety for ALL manned aircraft and the people underneath them without discriminating. Lest we forget, "First they came for..." by Martin Niemöller.
Oh, well. The NPRM is a basic and timely compromise. We're probably ready to start using it so the lawyers can get a supply of blood and guts and litigate the problems out of it. Oh, yeah, remember - LOOK OUT THE WINDOW.