Safeguarding Business Aviation for Upper C-Band Deployment

NBAA is working across several fronts to protect business aircraft operators from unintended impacts created by the planned auctioning by the Federal Communications Commission (FCC) of wireless communications frequencies in the Upper C-band.

In March, NBAA joined with a coalition of aviation manufacturers, pilot groups and other stakeholders in submitting comments to the FAA on its notice of proposed rulemaking that would require installation of new radio altimeters on tens of thousands of airplanes and helicopters.

While some existing radio altimeters are equipped with filters against bandwidth interference from current 5G telecommunications networks, the planned auction of frequencies in the Upper C-band in 2027 will likely require installation of new radio altimeters (RAs) against those signals, said NBAA Vice President, Air Traffic Services and Infrastructure Heidi Williams.

“The business aviation sector has enthusiastically adopted new technologies that ensure flying remains the safest form of transportation,” Williams said. “At the same time, we recognize the need to address potential concerns over the cost and other impacts of new mandates for technology equipage.”

In the coalition’s comments, the stakeholders pointed to FAA estimates underscoring the planned requirement’s sweeping application to “nearly 40,900 aircraft that operate in the U.S. airspace with nearly 58,600 separate radio altimeter units across nearly 14,000 owners and operators,” including the commercial airlines, “with potentially more [costs] to be discovered in private ownership.”

The groups also questioned the FAA’s industrywide estimate of $4.49 billion in undiscounted retrofit costs, based on a per-unit replacement figure of $80,000. “Based on consultation with operators and aircraft and radio altimeter manufacturers, equipment and labor costs may reach $120,000 per RA unit,” the comments noted.

There is precedent to help ease at least some of those costs for operators. NBAA joined in February with the National Air Transportation Association in urging the FCC to ensure equitable cost allocation for Part 91 and Part 135 operators.

“Under the commission’s longstanding emerging technologies framework, incumbents compelled to modify equipment due to commission-initiated changes in spectrum use are entitled to reimbursement of reasonable and documented costs,” the associations noted.

Doug Carr, NBAA senior vice president of safety, security, sustainability and international operations, noted industry stakeholders are prepared to respond to these concerns and work together with the FAA and FCC to find common ground.

“We have a lot of work cut out for us to make sure aviation needs are protected as these new capabilities are introduced through the sale of this spectrum,” Carr said. “However, our experience in responding to the introduction of 5G telecommunications allows all stakeholders to work better together and own the parts of this equation for which they’re best equipped.”

Learn more about NBAA advocacy efforts at nbaa.org/advocacy.