April 11, 2013

NBAA on April 1 submitted comments to the Federal Communications Commission (FCC) opposing its latest proposal to ban the manufacture, sale, importation and use of 121.5 MHz emergency locator transmitters (ELTs).

A prime motivator for the proposed ban is the discontinued satellite monitoring of 121.5 MHz, which had relayed distress signals to search-and-rescue organizations. The Cospas-Sarsat constellation now monitors signals from 406 MHz emergency location devices.

NBAA agrees that there are many benefits to a 406 MHz ELT, which include digital reliability, optional GPS position reporting and aircraft-specific identification. Some NBAA Members have already upgraded to 406 MHz ELTs. Most of these operators fly in remote areas or internationally, the latter requires their compliance with International Civil Aviation Organization (ICAO) standards and recommended practices that require a 406 MHz ELT.

But, “a significant number of business aviation aircraft are operated solely within the United States, where there is good radar and communications coverage with air traffic control to provide timely notification of an emergency situation,” NBAA’s Vice President, Safety, Security, Operations & Regulation Doug Carr wrote in comments to the FCC. They are not subject to ICAO standards, and requiring the installation of a 406 MHz ELT would adversely affect them.

By the FCC’s own definition, many of these U.S.-only operators are “small entities.” They appreciate the benefits of the 406 MHz system, but “the upgrade costs are significant, while the benefits potentially very small with the reliability of aircraft in service today,” NBAA said.

Fully supporting its Members’ strong desire to install 406 MHz equipment when the cost-benefit analysis makes sense, NBAA recommends that the FCC grandfather the use of 121.5 MHz ELTs now installed until the end of their useful lives.

“This approach lets operators make the decision to upgrade the ELT on their aircraft when the benefits of having a 406 MHz ELT are greater than or in line with the cost of the upgrade,” according to NBAA’s comments. This would prevent “the unnecessary grounding of aircraft that would otherwise be airworthy in accordance with federal aviation regulations.”

Review NBAA’s comments to the FCC (134 KB, PDF)

View the FCC’s Proposed Rule (229 KB, PDF)