Comments on ICAO State letter E 3/5-08/69
The International Council of Aircraft Owner and Pilot Associations (IAOPA) appreciates the opportunity to comment on this important issue. Protection of the electromagnetic spectrum for aviation is essential to the continued viability of civil aviation, but more importantly, access to critical segments of the spectrum is an integral part aviation safety.
IAOPA represents the interests of more than 470,000 general aviation and aerial work pilots and owner/operators who are members of our 67 worldwide affiliate organizations.
Traditionally, the spectrum interests of personal transportation and small aircraft segments of general aviation have been relatively elementary, centered on basic voice communications and ground-based radio navigation systems. With the advent of satellite-based CNS and elementary data link our interests have widened to include those useful and safety-linked systems. Yet, our dilemma regarding new technology continues to center on cost vs. effectiveness/efficiency of emerging technology devices. While the full range of modern CNS devices may all contain some marginal benefit for general aviation, the costs associated with those systems are often prohibitive for the small aircraft owner/operator. What may be an ideal system for a large airliner is frequently an economic impossibility for aircraft owner/operators who pays for system upgrades out of their own personal funds.
Therefore, we must take a very selective approach when embracing new or significantly altered devices employing the electromagnetic spectrum. A good example of this is the Global Navigation Satellite System (GNSS). Early GPS receivers were largely unaffordable for general aviation but showed great promise. As receiver and integrated database technology progressed rapidly the devices became more affordable and useful. Significantly, the increased safety and utility aspects of an integrated GPS/database system became a prime driver in the near-universal embrace of GPS by the general aviation community. However, integrated GPS systems certified for IFR enroute and approach purposes are still beyond the reach of many general aviation aircraft owner/operators.
In general we support most of the positions stated in the state letter but must abstain from commenting on those positions that have little apparent applicability for our segment of aviation. With this as a background we would like to submit the following comments regarding the ICAO draft WRC positions:
Agenda Item 1.2 (Resolution 915) – Increase Regulatory Flexibility. This agenda item proposes that regulations and processes be reviewed and changes be proposed to make them more flexible and responsive without specifying what those items might be. While the spectrum demands of emerging technology may make this an attractive proposition, in general changes to spectrum assignments are not in the best interest to general aviation since they usually mean significant changes to avionics. There are exceptions, e.g. GPS and UAT, but making even positive changes to spectrum usually doesn’t require more rapid processes to satisfy the needs of general aviation. Additionally, regulatory flexibility may work against aviation interests if commercial spectrum users use this process to gain an advantage over our requirements. Therefore, the concept of flexibility should not be synonymous with speed of execution or a laissez faire approach to protection of the aviation spectrum.
Agenda Item 1.3 (Resolution 421) - Spectrum for Unmanned Aeronautical Systems (UAS). UAS demand for spectrum will like become significant and most likely compete with that of manned aircraft. The allocation of UAS spectrum also has the potential to accelerate the deployment of UAS operations in airspace utilized by general aviation. However, we are faced with the dilemma of not wishing to share the lower airspace structure with UAS but insist that they have adequate sense and avoid and air/ground communications capability to protect our members’ safety and utility. Therefore, we advocate allocation to UAS interests based strictly on need. Inherent in these assignments must be guarantees of communications and data link integrity and backups that will ensure the protection of piloted aircraft
Agenda Item 1.5(Resolution 954) – Harmonize spectrum used for news gathering. This item seeks to identify and harmonize spectrum that can be utilized for news gathering. It does not preclude allocation of aeronautical spectrum. We strongly support ICAO’s opposition to this proposition.
Agenda Item 1.14 (Resolution 611) – Consider new applications in the range 30-300 MHz range. This agenda item recommends review current allocations in the 30-300 MHz frequency range and the consideration of new radiolocation (non-aeronautical) services in that band. In general, we support this initiative with the caveat that any “creative use” of existing terrestrially-based communications or navigation spectrum be balanced against the continuing need to maintain traditional voice communications and navigation systems for general aviation requirements.
Agenda Item 1.23 - Consider an allocation of about 15 kHz in parts of the band 415 -526.5 kHz to the amateur service on a secondary basis, taking into account the need to protect existing services. We support the ICAO position with emphasis on ensuring that interference with non-directional beacons (NDB) be a primary consideration in granting amateur access to this spectrum. Aviation must protect this spectrum until last NDB has been decommissioned.
We look forward with interest to the many aspects of the WRC as it will significantly affect worldwide aviation. To this end we are alerting our affiliates to work closely with their State communications and aviation authorities to ensure that aviation interests are adequately protected.
Sincerely,
John Sheehan
IAOPA Secretary General
