NBAA 加入聯盟，就 FAA 建議的高度表規則提供業界意見

A radio altimeter (RA) provides real-time height-above-terrain altitude data that supports critical flight crew decisions and operations, while also feeding key data to numerous safety-critical aircraft systems.

The Federal Communications Commission (FCC) has proposed expanding wireless telecommunications into the Upper C-band (3.98-4.2 GHz), a portion of the frequency spectrum used by the altimeters for safety-data transmission. Specifically, the agency intends to auction portions of the frequency, potentially for millions of dollars.

The Federal Aviation Administration (FAA), in turn, has proposed a requirement for the aviation sector to install new RAs, hardened against interference from signals introduced into the Upper C-band by non-aviation entities.

In response, NBAA, along with a host of aircraft and avionics manufacturers, industry groups and other stakeholders, has formed the Joint Aviation Community coalition, which recently submitted comments outlining the group’s united views concerning  the FAA’s proposed RA-equipage mandate.

“The Joint Aviation Community is fully committed to preserving the highest levels of aviation safety, while also advancing the broader goals of the [FCC] for greater spectrum efficiency across multiple frequency ranges and systems,” the coalition noted in comments submitted March 9 responding to the FAA’s notice of proposed rulemaking (NPRM) on the new RA requirement.

At the same time, coalition stakeholders expressed alarm over the likely costs involved in completing those retrofits by the target date of 2034 for Part 91 and 135 aircraft. Many general aviation aircraft and rotorcraft are equipped with at least one radio altimeter, while turboprop and turbine jet business aircraft often have two.

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. “The FAA NPRM affects all of these units and their operators, with potentially more to be discovered in private ownership.”

Read the Comments

Furthermore, “[t]he FAA’s estimate of $4.49 billion in undiscounted retrofit costs is likely underestimated,” the coalition added. “Based on consultation with operators and aircraft and radio altimeter manufacturers, equipment and labor costs may reach $120,000 per RA unit,” significantly more than the $80,000 figure cited in the FAA’s NPRM.

Stakeholders urged the FAA to support financial incentives to offset out-of-pocket installation costs, which “could meaningfully accelerate the retrofit schedule, including for Part 91 and Part 135 operators who will face disproportionate per-aircraft costs and, in many cases, the inability to absorb or recover those costs.”

Such incentives are supported by the NPRM’s own regulatory analysis, they continued, noting the situation results from external forces beyond the aviation industry’s control.

“Any incentive or compensation mechanism should adequately reflect the full costs borne by the aviation sector, which the Joint Aviation Community currently estimates between $4.49 billion and slightly over $7 billion in total undiscounted costs,” the comments concluded.

“Over many decades, the business aviation sector has enthusiastically adopted new technologies that ensure flying remains the safest form of transportation,” said NBAA Vice President for Air Traffic Services Heidi Williams. “At the same time, we recognize the need to address potential concerns over the cost and other impacts of new mandates for technology equipage. We look forward to collaborating with the FAA to address the concerns involving its radio altimeter proposal, so that we can ensure all aircraft are equipped with the technology needed to protect essential safety systems from signal interference by non-aviation parties.”

In submitting the comments, NBAA joined with the Aerospace Industries Association, Airbus Helicopters, Aircraft Electronics Association, Aircraft Airlines for America, Allied Pilots Association, The Boeing Company, Embraer, FreeFlight Systems, General Aviation Manufacturers Association, Garmin International, Honeywell, MHI RJ Aviation, National Air Transportation Association, RTX, Thales Group and Vertical Aviation International.

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