kkoran
Pattern Altitude
Cross Post from the Red Board:
FCC to prohit the use of 121.5 for ELT's effective immediately?
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poadeleted20
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This issue arrived in Craig Fuller's email inbox about 15 minutes ago (at least, I know my note on it did). Let's give AOPA at least until Monday to dig into this before we go totally beserk. Right now, we don't even know if the FAA was consulted before the FCC went and did this, and if not, what Randy B's going to do when he hears it from Craig.
ScottM
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iBazinga!
I am encouraged by the use of the word "should" in this. That is a very important regulatory word. It means that something is not mandatory. As in we SHOULD all eat less, but in fact go berserk at buffets. If the word used was shall, then I would be really worried.
TMetzinger
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Yep. Should = NPRM, maybe.
Unbeliever
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RJM62
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Geek on the Hill
As a rule, most things the government does happen very slowly.
The most common exception occurs when the thing the government is doing is very, very dumb. Those things tend to fast-tracked and to happen very quickly, which I fear may be the case here.
-Rich
The most common exception occurs when the thing the government is doing is very, very dumb. Those things tend to fast-tracked and to happen very quickly, which I fear may be the case here.
-Rich
silver-eagle
En-Route
They seem to be saying NO NEW 121.5 ELTs. Wouldn't this affect only new aircraft? I can't imagine anyone replacing an old 121.5 with a new 121.5. That just doesn't make sense.FCC10-103 said:
Since 121.5 is no longer monitored, it's only been a matter of time. I'd hate to think this will be the impetus the FAA needs to mandate NEW 406 ELTs for the rest of us.
PS: My 406 is due to be installed in August.
catmandu
Pattern Altitude
The FCC does not have to make sense, and they don't seem to care because history is on their side. Footnote 77 of the document:
JOhnH
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I am trying to parse this sentence, and although my old sentence diagramming skills are lacking, when the sentence ends with "or use of 121.5 MHz ELTs", it sounds to me like we can no longer use 121.5 MHz.
ScottM
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iBazinga!
I agree with your assessment.
While tinfoil hat wears may want to believe in a vast conspiracy of none carrying bureaucrats out to get us I know from my work with the FCC that the truth is somewhat different. My experience suggests that this was written by people who have no contact with the FAA or aviation business and are making their decisions on what they know of 121.5 status of monitoring. When the aviation businesses start commenting on this I fully expect this to be delayed for implementation and a period of investigation followed by other processes to get the regulation updated.
The sky is not falling yet. But I think that the day when we will be upgrading to 406MHz EPRIBs is approaching. The manufacturers of those devices want to sell them and will be lobbying the FAA and FCC to make changes to force us to buy them, ahhh free market capitalism at its best !!
JeffDG
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The big problem is...the 406's also transmit on 121.5...so they'll all be in violation of this regulation as well....
ScottM
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iBazinga!
Exactly. So you know there is still to be work to be done on the regulation. The FCC is a fairly open, at least compared to other agencies like the FAA, group. Often times there are committees of industry people that are used to write rules and review orders such as this.
The bright side of this may be that there becomes and elimination of dual bad EPIRBs and that could bring cost down for 406MHz only units.
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Joe B
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No. The regulation prohibits the use of "121.5 ELT's", not "devices which transmit on 121.5". Somewhere outside this final rule there exists a formal definition of 121.5 MHz ELT's and 406MHz ELT's. I know one set of definitions exist in the applicable TSO's. What is prohibited (and allowed) are the devices described in those formal definitions.
RJM62
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Geek on the Hill
It's the FCC's contribution to the stimulus package.
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Bob Noel
hmmm, where are the new ELTs made?
1970s(?): "ALL of you rich b*d pilots WILL BUY THESE TRANSPONDER THINGS because a jet ran into a Cessna in visual conditions under positive radar control and these Mode C transponders wouldn't have made a difference but dammit WE'RE DOING SOMETHING ABOUT IT and don't you dare whine about it!"
1970s(?): "ALL of you rich b*d pilots WILL BUY THESE 121.5Mhz ELT THINGS because a plane carrying a congressman went down and it wasn't found for too long and these wouldn't have made a difference but dammit WE'RE DOING SOMETHING ABOUT IT and don't you dare whine about it!"
2010: "ALL of you rich b*d pilots WILL BUY THESE NEW ADS-B-OUT THINGS because the airliners you never get anywhere near want to be able to fly closer together and you need to replace the Mode C transponders all of you rich b*d pilots insist on having and don't you dare whine about it!"!"
2010: "ALL of you rich b*d pilots WILL BUY THESE NEW 206MHz ELT THINGS AND STOP USING THOSE 121.5Mhz THINGS ALL of you rich b*d pilots insist on having and don't you dare whine about it!"
I want an apology from Joe Barton.
Tom-D
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Tom-D
The bottom line here is, you are required to have equipment in FAR 91.207, which you are not allowed to use. IAW the new FCC rules.
Does that sound like your government at work again?
remember the FCC does not dictate airworthiness, but they can fine you for breaking their rules.
So, my best advice is to comply with 91.207, and turn off the ELT. 91.207 does not require the ELT be turned on, it only requires that it be in operable condition and installed.
The FCC has in the past declared the 360 channel radios unusable, but the FAA never made any changes to their regulations, I don't expect them to change any regulations on this issue.
This is typical of one department of the government not coordinating with the other over regulating our industry
The rest of my feelings over this issue can be seen on the AOPA forums
Does that sound like your government at work again?
remember the FCC does not dictate airworthiness, but they can fine you for breaking their rules.
So, my best advice is to comply with 91.207, and turn off the ELT. 91.207 does not require the ELT be turned on, it only requires that it be in operable condition and installed.
The FCC has in the past declared the 360 channel radios unusable, but the FAA never made any changes to their regulations, I don't expect them to change any regulations on this issue.
This is typical of one department of the government not coordinating with the other over regulating our industry
The rest of my feelings over this issue can be seen on the AOPA forums
Palmpilot
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This rulemaking started in 2001. That's hardly a fast track.
Considering the fact that none of them is on the list of commenters in Appendix A, looks to me like the alphabet groups fell asleep at the switch.
Graueradler
Pattern Altitude
Doesn't CAP use 121.5 for search and rescue.
If the ELT is switched on but is not activated, am I using it?
If the ELT is switched on but is not activated, am I using it?
Doggtyred
En-Route
All of the CAP planes should be equipped for 406 now as well.. which uses burst transmitters with your GPS coordinates embedded (and an aircraft ID too)..
rather than a generic homing signal.
Dr. O
Pattern Altitude
If you don't crash, you don't transmit, therefore you are not in violation of the proposed rule banning them...
If they do ban them they will also change the FAR paragraphs that require the 121.5, to be the ELT frequency... They will also change the rule saying you ought to monitor 121.5 at all times...
My 121.5 ELT is all of 6 months old... To say I am annoyed if this goes through in the next few months is an understatement...
denny-o
If they do ban them they will also change the FAR paragraphs that require the 121.5, to be the ELT frequency... They will also change the rule saying you ought to monitor 121.5 at all times...
My 121.5 ELT is all of 6 months old... To say I am annoyed if this goes through in the next few months is an understatement...
denny-o
Palmpilot
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Embedding of GPS coordinates is optional. My understanding is that CAP DFs the low power 121.5 beacon that is incorporated in the 406 units, since the short duration of the 406 MHz data bursts makes them hard to DF.
PilotAlan
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Negative. 406 is localized by the satellites, and can carry GPS location data.
DF is done on a 121.5 relatively low power transmitter.
twdeckard
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I'll step into the debate to put in a plug for the newer 406Mhz units. I wasn't able to persuade our club to get them but hopefully a Mexico/Canada vacation will oblidge us to upgrade.
Today average time from the last known position (LKP) to rescue is 31 hours.
Aside from the debates on Government or Aviation costs; the newer ELTs are a lifesaving technology. A small personal unit can be had for under $300 (but you have to ask yourself will I be able to activate it, will my passengers be able to dig it out of my pocket in the fire, will my six year old figure it out).
I don't understand the lack of a mandate to retire the 121.5 only units.
The nerds can chime in and talk about the advantages of 121.5 homing in the close in search. I don't understand why the units were built with the complementary transmitter and I wonder if it was practically for marketing/regulations. For my part if AFRCC at Langley has my lat/long I'll have a lot better faith hanging in the straps broken and bleeding ...
Todd
Today average time from the last known position (LKP) to rescue is 31 hours.
Aside from the debates on Government or Aviation costs; the newer ELTs are a lifesaving technology. A small personal unit can be had for under $300 (but you have to ask yourself will I be able to activate it, will my passengers be able to dig it out of my pocket in the fire, will my six year old figure it out).
I don't understand the lack of a mandate to retire the 121.5 only units.
The nerds can chime in and talk about the advantages of 121.5 homing in the close in search. I don't understand why the units were built with the complementary transmitter and I wonder if it was practically for marketing/regulations. For my part if AFRCC at Langley has my lat/long I'll have a lot better faith hanging in the straps broken and bleeding ...
Todd
gismo
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The 121.5 transmission has multiple advantages. One is that most aircraft can receive this frequency so an activation can be immediately recognized and reported (this is most likely the case when an aircraft under ATC control disappears). And virtually all SAR is already equipped for 121.5 DF so if the distress signal's location isn't known with enough accuracy to direct rescue to the exact location, short range DF tracking is needed and that works better with a continuous signal vs one that transmits periodically (as is the case with the 406 MHz signal). Keep in mind that most 406 ELTs do not transmit GPS determined location and even ones that can may not be able to provide the location of the exact crash site and in the case of personal beacons ground cover and/or local interference can easily preclude a GPS position solution. Without an accurate GPS position, the 406 MHz system is far more accurate than the older 121.5 simply because the specs for the transmitters are much tighter on the carrier frequency which allows a more precise determination of position by the roving satellites but that method still leaves a search area potentially as large as several square miles.
And as Joe B already stated, I think it's extremely unlikely that the FCC has any intention of prohibiting the use of 121.5 by ELTs and other rescue beacons, I'm pretty certain they only want to eliminate units that can only provide that and don't have 406 MHz capability.
So IMO the real issue here is whether or not the FCC can legally (or politically) prohibit the manufacture and sale of (and more importantly the use of) non-406 ELTs. Their motive and justification appears to be safety rather than spectrum and AFaIK the FAA carries that burden for aviation, not the FCC.
I believe that what we have here is a little political water-carrying, by a branch of government ill-equipped to evaluate or understand the impact of what they are doing, in favor of other interests whose efforts to effect policy in the proper arena has failed.
FCC is in charge of spectrum control. Last I checked, there was not a big problem with spectrum-hogging by ELTs. I monitor all the time when I am outside the terminal area, and in seven years, I have heard (maybe) four ELTs.
What is chilling about this is not just the aspect of the FCC stepping its meddlesome nose where it does not belong (read the reasoning cited in the Register for this remarkable decision), but the timing of it. Where is the careful and deliberative consideration of all impacted persons and entities?
Sixty days' notice. How much inventory will be written off, eaten, by manufacturers and retailers of avionics?
The 406 market is still getting going, so to speak, and a deadline like this one, if genuinely enforced, constitutes a license to steal for some unscrupulous dealers and shops.
Back to my other point, though: imagine BATF issuing a ban on broad classes of weapons, not for any core reason relating to the guns themselves, but simply citing (say) Department of Health and Human Services statistics on the bad effects of guns on the people who experience PFA (Penetration by Firearm Ammunition) injuries?
Think about it...
FCC is in charge of spectrum control. Last I checked, there was not a big problem with spectrum-hogging by ELTs. I monitor all the time when I am outside the terminal area, and in seven years, I have heard (maybe) four ELTs.
What is chilling about this is not just the aspect of the FCC stepping its meddlesome nose where it does not belong (read the reasoning cited in the Register for this remarkable decision), but the timing of it. Where is the careful and deliberative consideration of all impacted persons and entities?
Sixty days' notice. How much inventory will be written off, eaten, by manufacturers and retailers of avionics?
The 406 market is still getting going, so to speak, and a deadline like this one, if genuinely enforced, constitutes a license to steal for some unscrupulous dealers and shops.
Back to my other point, though: imagine BATF issuing a ban on broad classes of weapons, not for any core reason relating to the guns themselves, but simply citing (say) Department of Health and Human Services statistics on the bad effects of guns on the people who experience PFA (Penetration by Firearm Ammunition) injuries?
Think about it...
The 406 LBs have a unique serial number/ID that you are required to register with the NOAA, but AFAIK it's not the aircraft ID, unless they came up with revised rules for aircraft ELTs.
When you register a Personal Locator Beacon you indicate the IDs and colors of aircraft and vehicles where you might be carrying it, along with emergency contact information.
poadeleted20
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When someone gets a response from AOPA or the FAA on this, please let me know.
twdeckard
Pre-takeoff checklist
Hey there Lance! Sorry I missed you and Ron and Rick at Gastons. I was sure I was going to go but family vacation plans trumped it. It still involved grass runways and flying but alas not to Arkansas.
The geostationary part of the satellite network spots you immediately on 406 (however you are right, you need the GPS integrated unit to do you any good). A low orbit satellite might be 90 minutes away and their doppler derived fix is only good to 2 square miles or so according to google.
However my personal prejudice assumes I wouldn't buy a 406 unit unless it had the GPS component. With that, I cannot see why 121.5 has any value except for pure system redundancy. Unless hanging in the trees, the SAR guys offer that a very short range DF is really valuable I'd assume I'd be as easy to find as any geocache.
If there is a conspiracy do you think its a cost control/cost shift? Save $ by forcing the retirement of 121.5.
Todd
ScottM
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iBazinga!
Actually the FCC shares that duty with the DoD, but your point is valid. There has not been a spectrum issue associated with ELTS. The FCC also has additional authorities associated with protecting commercial interests in the radio spectrum. Since radio propagation know no national boundaries the FCC also is the PoC on international issues. It works with the UN agency the ITU to develop treaties on spectrum use.
Well it does belong there. It is there area to decide what communications devices are used in what services. What is not good is that it appears that the FAA and aviation interests where not consulted or perhaps did not participate. This activity has been on going since 2001 so it would seem that there was plenty of time.
None. This is a shot across the bow. People will wake up, petition the FCC and they will put it on the back burner for further action. This stuff sometimes happens when the FCC cannot get the commercial interests to pay attention. They make a decision that will result in those interests having to finally pay attention. The last one I can think off of the top of my head was hearing aid compatible cell phones.
Cellphone companies had no interested in adding the $.15 worth of components and extra shielding to make a cell phone hearing aid compatible. The cellphone companies would just sell an inductive loop to people who needed to get audio into their cellphones and promised to look into better solutions. 8 years later there was no advancement forth coming. So the FCC mandated hearing aid compatibility in Part 68 for all phone including cellular ones. That got the manufacturers attention. They petition for regulatory relief, then a delay, and finally got a reasonable time period to implement the feature. This could just be the same thing.
Another guess is that the 406MHZ ELT manufacturers are behind this using a back door approach to force us into upgrading thus increasing their sales.
BATF basically did this with rocket motors for model rockets after 9/11. You could not even buy a D-motor in one state and take it to another without a BATF license. It got sorted out. Helped a lot of lawyers, think of it as a legal stimulus plan!
Thankfully we are a nation of laws and can petition the government to fix these things.
RotorAndWing
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With you, cuz, and if they respond rationally to petitions relating to reasonable (and I mean legitimately reasonable, not "I don't wanna never change" reasonable) timing on the changeover, I think it's OK.
Still, sixty days, backed only by some mealy-mouthed babble about motivating pilots to change...
ScottM
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iBazinga!
Ya I hear ya. Did you see who the industry reps to this report and order were?
NOT ANY GA interests at all from what I could see. The "mealy-mouthed" stuff sounds encouraging but why leave in the word 'use' if the intent is to force transition? Also why not mention working with the FAA on coming up with a joint transition plan?
'Zackly.
The reason I still think this is a set-up is, while the jurisdiction of the FCC is legit, its interest here is nominal- this belongs to the FAA.
By doing it this way, it flew under the radar.
Would I be wrong in assuming that in the case of an emergency, PIC is authorized to do whatever is necessary, including 'using' an unauthorized ELT?
I like the way you're thinking, and I am all about civil disobedience but I guess that'd all hinge on what exactly constitutes "use," in the first place.
Is it "use" if you have it installed and ready to trigger?
"Paging Mr. Clinton, Mr. William Jefferson Clinton. Word parsing assistance on aisle nine..." :wink2:
