AT&T and Verizon say no to FAA 5G rollout plan

Just like Remote ID the FAA have not managed to get any RF experts in the room when considering the implications of something new. Remote ID has a problem with the z-axis for the operator’s position, it’s not accurate enough for the FAA and cannot be unless your smartphone or tablet has a major GPS update.

Now the implications of 5G on really dated manned aircraft equipment is trying to be mitigated by asking two of the companies rolling out the service to please slow down.

Manned aviation is completely hamstrung by ancient equipment and politically connected vendors of that equipment.

The cell phone companies told the FAA they gave them a chance to sort it out already and now they really think aircraft not equipped with the right gear, should not use some airports, exclusion zones for them to be enforced.

The drone industry is no stranger to FAA foolery, let me pull the best bit out IMHO, it’s well down this page.

Nonetheless, the FCC encouraged the aviation community to use the nearly two years before C-Band deployment to upgrade any altimeters that might not be properly designed to filter out frequencies far removed from the 4.2-4.4 GHz altimeter band.

Inexplicably, the FAA and the aviation industry apparently did nothing following the February 2020 order or even after the C-Band auction closed in January 2021. In fact, it was not until November 2, 2021 that the FAA even issued a notice to begin collecting data about altimeters from the aviation industry.

Who would have thought the FAA would not have kept to a deadline!

Running the sky in 2022 like it was still 1982 no longer cuts the mustard.

What do we want, a digital sky, when do we want it, well as soon as the FAA enters this millennium.

The bit where the Government asked nicely.

December 31, 2021

John T. Stankey
Chief Executive Officer
AT&T

Hans Vestberg
Chief Executive Officer

Verizon

Dear Mssrs. Stankey and Vestberg:

Thank you for the ongoing dialogue and for your prior agreement to an initial 30-day delay as we work to find a solution that will provide confidence that 5G C-Band and aviation will safely coexist in the United States. We recognize the significant investment your companies made to launch 5G C-band service, and the importance of expanding 5G service for the American economy. At the same time, absent further action, the economic stakes for the aviation industry and the disruptions the travelling public would face from the commercial launch of C-Band service on January 5 are significant, particularly with the ongoing stress and uncertainty caused by the
coronavirus pandemic.

Accordingly, we seek to build on our productive discussions by offering the attached proposal as a near-term solution for advancing the co-existence of 5G deployment in
the C-Band and safe flight operations. Failure to reach a solution by January 5 will force the U.S. aviation sector to take steps to protect the safety of the traveling public, particularly during periods of low visibility or inclement weather. These steps will result in widespread and unacceptable disruption as airplanes divert to other cities or flights are canceled, causing ripple effects throughout the U.S. air transportation system.

This proposal minimizes and spreads the short-term economic and operational burden while permanent fixes are rapidly put into place. It will still involve significant disruptions for aviation operations in the U.S., but represents a much better way forward than the current trajectory.

Under this framework, commercial C-band service would begin as planned in January with certain exceptions around priority airports. The FAA and the aviation industry will identify priority airports where a buffer zone would permit aviation operations to continue safely while the FAA completes its assessments of the interference potential around those airports.

Our goal would then be to identify mitigations for all priority airports that will enable the majority of large commercial aircraft to operate safely in all conditions. This will allow for 5G C-band to deploy around these priority airports on a rolling basis, such that C-Band planned locations will be activated by the end of March 2022, barring unforeseen technical challenges or new safety concerns.

Meanwhile, the FAA will safely expedite the approvals of Alternate Means of Compliance (AMOCs) for operators with high-performing radio altimeters to operate at those airports.

We appreciate that this proposal offers a general framework and that further discussion will be needed to clarify important details. We commit to basing those discussions on the substantial technical information that has been shared and will be shared as part of this process, to ensure that decisions and outcomes are fact-based and data-driven.

As part of this proposal, we ask that your companies continue to pause introducing commercial C-Band service for an additional short period of no more than two weeks beyond the currently scheduled deployment date of January 5. During this time, the FAA will identify the priority airports, issue the required Notices to Air Missions (NOTAMs) and begin approving AMOCs.

During this time, the FAA will review information relating to the size of the buffer zone around critical airports and will seek to reduce the size when safely able based on data from aviation manufacturers. The FAA will make every effort to complete this work as expeditiously as possible.

From the beginning of our discussions, our overarching goal has been to protect flight safety, while ensuring that 5G deployment and aviation operations can co-exist. We believe this proposal advances this goal and avoids substantial disruptions to aviation operations – and to the flying public – in the short term.

The United States has the safest aviation system in the world. We achieve this every day by actively identifying risks and eliminating them. Passengers have confidence that when they board one of the daily 45,000 commercial flights they will safely reach their destination.

We are an aviation nation because flying is safe. Our safe aviation systems and thriving aviation industry are profoundly important to America’s economy and our way of life. We know you share the desire to keep aviation safe and efficient, and we urge you to seriously consider this solution as a common-sense way forward.

Sincerely,

Pete Buttigieg
Secretary of Transportation
Steve Dickson
FAA Administrator

The response….

Dear Secretary Buttigieg and Administrator Dickson:

We are writing in response to your letter sent to us the evening of December 31 regarding C-Band spectrum.

As you know, the U.S. Government’s auction of the C-band spectrum almost a year ago was heralded by this Administration as a major policy victory and one of the most successful auctions ever conducted in the United States. From a financial perspective, the auction raised more than $80 billion for the U.S. Treasury. Moreover, the U.S. Government had determined that the United States was “lagging behind China” and other countries in 5G deployment and that a major cause for this was “the lack of some carriers’ access to the radio frequencies best suited for 5G coverage.”

The C-Band spectrum auction was vital in addressing this national security vulnerability and was necessary to provide the connectivity for millions of American families and businesses to work, learn, and run their lives and businesses. With continued COVID crises, it has never been more important that our country’s critical communications infrastructure have the spectrum needed to handle escalating traffic demands from our customers.

The auction of the C-Band spectrum was the culmination of years of study by the Federal Communications Commission, which is the expert agency of the U.S. Government on spectrum.

Among other things, the FCC conducted an extensive public rulemaking process in which submissions from hundreds of parties, including from the aviation industry, were considered. At the end of that process in February 2020, the FCC adopted its lengthy and comprehensive CBand Order, which found, among other things, that its rules would fully “protect aeronautical services in the 4.2-4.4 GHz band.”

The FCC had compelling reasons for this conclusion. Spectrum interference disputes
typically involve simultaneous transmissions on the same frequencies. But radio altimeters do not operate on, or anywhere near, the C-Band frequencies. Rather, they operate in a frequency band (4.2-4.4 GHz) that is separated by at least 400 megahertz from the C-Band frequencies (3.7-3.8 MHz) that AT&T and Verizon will begin using in 2022 and at least 220 megahertz from any C-Band frequency authorized for use in the future. This helps explain why C-Band 5G service and aviation operations already coexist in nearly 40 other countries where C-Band
spectrum has been deployed without any negative impact on aviation.

We care deeply about the safety of our customers, employees, and families, all of whom fly domestically and internationally for business and pleasure. Our two companies are deeply committed to public safety and national security, and fortunately, the question of whether 5G operations can safely coexist with aviation has long been settled.


Relying on the FCC’s comprehensive rulemaking process and the C-Band Order, AT&T,
Verizon, and others bid more than $80 billion on C-Band spectrum. With the FCC’s
encouragement, we then paid billions of dollars more to accelerate the migration of the satellite companies that had been using these frequencies specifically so that we could begin using the spectrum in some geographic areas by December 5, 2021.

AT&T and Verizon spent most of 2021 preparing to put the C-Band spectrum into
service. In addition to the tens of billions of dollars we paid to the U.S. Government for the spectrum and the additional billions of dollars we paid to the satellite companies to enable the December 2021 availability of the spectrum, we have paid billions of dollars more to purchase the necessary equipment and lease space on towers. Thousands of our employees have worked non-stop for months to prepare our networks to utilize this spectrum. Thousands more have been trained to engage with customers as the new spectrum is put to use.

Amid all this activity, we were told for the first time late last year that the Federal
Aviation Administration (FAA) and parts of the aviation community had concerns about the timing of our use of C-Band under the FCC’s February 2020 order. The aviation community participated in the C-Band proceeding, and the FCC considered all their input and found that the use of the spectrum would cause no harmful interference to altimeters.

Nonetheless, the FCC encouraged the aviation community to use the nearly two years before C-Band deployment to upgrade any altimeters that might not be properly designed to filter out frequencies far removed from the 4.2-4.4 GHz altimeter band. Inexplicably, the FAA and the aviation industry apparently did nothing following the February 2020 order or even after the C-Band auction closed in January 2021. In fact, it was not until November 2, 2021 that the FAA even issued a notice to begin collecting data about altimeters from the aviation industry.

As a result of this inaction, the U.S. Government approached AT&T and Verizon in
November to ask us to delay using the C-Band spectrum in order to avoid potential disruption to the aviation industry, which had been in its own power to avoid. Despite the thousands of people who had been working for almost a year towards a December 5 C-Band deployment, despite the billions of dollars of capital we have invested in our networks in 2021 to prepare for C-Band, and despite the $80 billion that the wireless industry paid last year for use of the C-Band spectrum, AT&T and Verizon agreed to wait until January 5, 2022 to begin using the C-Band and to
implement additional restrictions on our use of the spectrum through July 5, 2022, over and above the operational restrictions the FCC already had found sufficient to protect radio altimeters.

Although there was no requirement for us to adopt these measures, we did so
voluntarily in the spirit of cooperation and good faith. Now, on the evening of New Year’s Eve, just five days before the C-Band spectrum will be deployed, we received your letter asking us to take still more voluntary steps – to the detriment of our millions of consumer, business and government customers – to once again assist
the aviation industry and the FAA after failing to resolve issues in that costly 30-day delay period, which we never considered to be an initial one.


As you know, the FCC is the expert agency designated by our government to make
decisions governing the use of our nation’s scarce spectrum resources. Its ability to set and administer policy has been rightfully respected and carefully followed by policymakers around the globe. Its task is a hard one – not to serve the interests of anyone industry or stakeholder, but to ensure that finite spectrum resources are deployed intelligently against a careful balance of industries (e.g., communication, satellite, aviation, automotive, consumer electronics, defense) and in consideration of innovation and economic development, public interest, and the protection
of the interests of the United States.

At its core, your proposed framework asks that we agree to transfer oversight of our
companies’ multi-billion dollar investment in 50 unnamed metropolitan areas representing the lion’s share of the U.S. population to the FAA for an undetermined number of months or years.

Even worse, the proposal is directed to only two companies, regardless of the terms of licenses auctioned and granted, and to the exception of every other company and industry within the purview of the FCC.

Agreeing to your proposal would not only be an unprecedented and unwarranted circumvention of the due process and checks and balances carefully crafted in the structure of our democracy, but an irresponsible abdication of the operating control required to deploy world-class and globally competitive communications networks that are every bit as essential to our country’s economic vitality, public safety and national interests as the airline industry. We are, however, committed to continue our cooperation with your Department and all interested parties, including the offer of further mitigations described below, on the condition that the FAA and the aviation industry are committed to doing the same without escalating their grievances, unfounded as they are, in other venues.

On December 31, we filed with the FCC again reiterating that we will abide by the
considerable mitigation measures we announced in November and that we are voluntarily implementing for six months as your Department and the aviation industry take whatever steps you think appropriate to ensure that all aircraft are properly equipped. These are voluntary steps we are taking, over and above what is required by our FCC licenses, in the spirit of cooperation.

For your convenience, we are attaching a copy of the December 31 filing to this letter.
In addition, despite the extraordinary and unprecedented nature of your further request, we will again volunteer, in the spirit of cooperation and good faith, to alter our use of the C-Band spectrum during the same six-month period (unless we and the FAA determine that these voluntary limits should be relaxed sooner).

Specifically, for six months, until July 5, 2022, we will adopt the same C-Band radio exclusion zones that are already in use in France, with slight adaptation to reflect the modest technical differences in how C-band is being deployed in the two countries. That approach – which is one of the most conservative in the world – would include extensive exclusion zones around the runways at certain airports. The effect would be to further reduce C-band signal levels by at least 10 times on the runway or during the last mile of final approach and the first mile after takeoff. This is over and above the protections we already committed to put in place around airports that were detailed in the letter to the FCC on November 24th, 2021 – protections that the FCC referred to as among “the most comprehensive efforts in the world to safeguard aviation technologies.” As you know, U.S. aircraft currently fly in and out of France every day with thousands of U.S. passengers and with the full approval of the FAA. As a result, France provides a real-world example of an operating environment where
5G and aviation safety already co-exist. The laws of physics are the same in the United States and France.

If U.S. airlines are permitted to operate flights every day in France, then the same
operating conditions should allow them to do so in the United States, as we propose in the technical details attached to this letter.

These additional voluntary measures will give the FAA and the aviation industry ample opportunity to conduct any further studies and remediate any altimeters that might not meet current standards, as was originally recommended by the FCC in February 2020. We trust they are sufficient to allay any remaining concerns expressed in your December 31 letter.

Sincerely,
/s/ John Stankey /s/ Hans Vestberg

Chief Executive Officer Chairman and Chief Executive Officer
AT&T, Inc. Verizon Communications, Inc

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