May 14, 2021

Twenty aviation organizations, including NBAA, avionics manufacturers, aircraft manufacturers and other groups, recently sent a letter to the Federal Communications Commission (FCC) to dispute inaccurate information presented in CTIA comments about an RTCA 5G radar altimeter report, the “Assessment of C-Band Mobile Telecommunications Interference on Low Range Radar Altimeter Operations” (the MSG Report).

The response is in support of a petition for reconsideration of the commission’s March 3, 2020, report and order in a docket filed by radio altimeter manufacturers, aerospace organizations, aviation organizations, and others asking the commission to consider the potential impacts on aviation safety from flexible use operations in the 3.7-3.98 GHz band (“3.7 GHz operations”) and take appropriate steps to mitigate against them and ensure continued safety of flight.

Specifically, the aviation organizations found several shortcomings in CTIA’s comments, saying its statements are overly broad and lack detailed analysis, it limited its involvement with aviation subject matter experts and relied upon inappropriate comparisons with unrelated studies and services, and finally, CTIA’s critique is plagued by “unsound analysis, conjecture, and erroneous statements.”

“Without rigorous independent analysis, CTIA discounts the only thorough safety study supported by aviation subject matter expertise – the MSG Report – and advocates that the commission ignore its finding that there is a clear threat to public and aviation safety risking the lives of passengers and crews,” the letter states.

“The Organizations Supporting Aviation Safety urge the commission to grant the petition to ensure aviation safety and engage with the FAA, the aviation safety regulator, to further assess the risks to public and aviation safety demonstrated by the MSG Report and develop reasonable and appropriate mitigations,” according to the letter.

In addition to NBAA, the letter was signed by: Aerospace Industries Association; Aerospace Vehicle Systems Institute; Airline Pilots Association International; Airborne Public Safety Association; Airbus; Aircraft Electronics Association; Aircraft Owners and Pilots Association; Airlines for America; Aviation Spectrum Resources, Inc.; Collins Aerospace; Experimental Aircraft Association; Garmin International, Inc.; General Aviation Manufacturers Association; Helicopter Association International; Honeywell International Inc.; International Air Transport Association; National Air Carrier Association; National Air Transportation Association and Regional Airline Association.

Read the full letter. (PDF)