Airlines for America (A4A) on Thursday asked the Federal Communications Commission (FCC) to stop the wireless industry from turning on C-band spectrum for commercial deployment on January 5, saying the FCC never did provide a “reasoned analysis of why it has rejected the evidence submitted by the aviation interests.”
Last week, CTIA, A4A and the Aerospace Industries Association issued a joint statement saying they were working together to share available data to identify specific areas of concern for aviation. The best technical experts from across both industries were said to be on the case, working collectively to identify a “data-driven solution” that would allow for the deployment of 5G while preserving aviation safety.
But the A4A said the issue remained unresolved as of December 30, with only days remaining before 3.7 GHz license 5G operations are set to start. According to the A4A, the FCC failed – since the beginning of the C-band proceeding – to explain why it rejected evidence of the “detrimental impact of interference” from 3.7 GHz licenses on radio altimeters.
A4A said it’s not seeking a full stop to new 5G service, but “in fact only a stay of initiation of operations in certain designated airport locations.” It lists more than 135 airports where it wants deployments to remain idle, including locations in Detroit, Houston, New York, Chicago and Los Angeles.
“Aircraft will not be able to rely on radio altimeters for numerous flight procedures and thus will not be able to land at certain airports,” the A4A said in its filing (PDF).
If C-band deployments were allowed in these locations, A4A outlined a series of dire consequences: The need to reroute and/or cancel thousands of airline flights, dislocating millions of passengers and airline crews and delaying delivery of time-sensitive shipments like Covid-19 vaccines and tests. In addition, it pointed to potential economic losses estimated at more than $1 billion.
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“The disruptions to the 3.7 GHz licensees will not be to existing operations, but rather to the rollout of a new service,” A4A said. “Thus, any adverse impact will entail some delay in implementation of the new service, but will not impact ongoing operations. More importantly, members of the public are not likely to be affected at all by such delay. By contrast, virtually the entirety of the American public will be significantly and adversely affected if the January 5th date is not stayed.”
In a statement, CTIA SVP and Chief Communications Officer Nick Ludlum reiterated that the wireless industry expects to launch 5G on January 5, as planned, using the C-band spectrum.
In a December 31 filing, CTIA told the FCC that 5G is authorized today in numerous countries at power levels higher than what is permitted in the U.S.; that includes Denmark, Finland and Ireland, as well as New Zealand, Romania and Spain. “Millions of passengers travel every year in these countries, with no impacts to radio altimeter operations,” CTIA said.
“The RTCA Report—the sole study on which aviation stakeholders base their claims regarding coexistence in the United States – purports that 5G deployments in the U.S. would cause harmful interference to radio altimeters,” CTIA said. “This study has been fully debunked by CTIA, and rightly so: if the predictions in the RTCA Report were correct, 5G deployments in dozens of countries would be causing demonstrable harmful interference to thousands of aircraft every day. Yet no harmful interference has been documented to date in any of these countries, as the FAA has acknowledged, and targeted testing with radio altimeters in numerous countries has provided further support for the ability of these services to coexist.”
The A4A asked the FCC to act on its emergency petition no later than noon Eastern time on January 3, 2022, and if it doesn’t, A4A said it’s prepared to seek judicial “or other relief” to avoid “the immediate and unacceptable safety risks to its members’ operations from interference to radio altimeters by new 3.7 GHz 5G mobile services,” set to launch January 5.
Earlier this month, a bipartisan group of former chairs for the FCC sent a letter (PDF) to FCC Chairwoman Jessica Rosenworcel and Acting NTIA Administrator Evelyn Remaley expressing their concerns about the FAA’s efforts to revisit the FCC’s 2020 decision on C-band, which followed almost two years of review.
While the FAA should work with the FCC and NTIA to resolve the FAA’s concerns, the debate shouldn’t be fought publicly in a way that undermines consumer confidence in the process or require months of additional delays, they said. The letter was signed by former FCC chairs Ajti Pai, Tom Wheeler, Mignon Clyburn, Julius Genachowski, Michael Copps and Michael Powell.