Sunday, August 6, 2017

Comments Needed in FCC AeroMACS Proceeding

The Federal Communications Commission in Washington, D.C., has issued a Public Notice seeking comment on a petition filed by the WiMAX Forum proposing service rules for the Aeronautical Mobile Airport Communications System (AeroMACS). This WiMAX Forum Petition for Rulemaking to Adopt AeroMACS Service Rules was filed with the FCC on March 31, 2017.  See the text here   AeroMACS refers to a collection of high data rate wireless networks that are used in accordance with international aeronautical standards for airport surface operations to provide broadband communications between aircraft and other vehicles, as well as between critical fixed assets.  
The FCC notes that AeroMACS is designed to support a wide variety of services and applications, including Air Traffic Control/Air Traffic Management and infrastructure functions, as well as airline and airport operations.  For example, the FCC opines that AeroMACS frequencies might be used by pilots to receive weather and airfield information; by fire rescue, snow removal, and ground personnel to coordinate operations; and by airport security personnel to monitor live video feeds. The FCC has previously allocated frequencies for AeroMACS , which will operate in the 5000-5030 MHz and 5091-5150 MHz bands, and will be utilized by Federal and non-Federal users.  See Amendment of Parts 2, 15, 80, 90, 97, and 101 of the Commission’s Rules Regarding Implementation of the Final Acts of the World Radiocommunication Conference (Geneva, 2012)(WRC-12), Other Allocation Issues, and Related Rule Updates, Report and Order, 32 FCC Rcd 2703, 2717-18, paras. 39-40 (2017); 47 CFR § 2.106, Footnotes US115, US444B.

Proposed uses for Federal users (i.e., government entities, like the FAA) include air traffic management, including air traffic control; aeronautical operations communications; and communications related to airport operations, safety, and security.  Non-Federal users may include airport owners and operators, airline carriers, aeronautical communications network providers (ACNPs), and other entities that engage in airport communications relating to safety and regularity of flight.  

The FCC has taken  actions in support of aeronautical mobile (route) service (AM(R)S) surface applications at airports in the 5000-5030 MHz band and unmanned aircraft systems (UAS) in the 5030-5091 MHz band.   The aeronautical mobile (route) service is an aeronautical mobile service (i.e. a mobile service that supports communications between aeronautical stations and aircraft stations, or between aircraft stations) and is reserved for communications relating to the safety and regularity of flight.  See 47 CFR § 2.1.

The reason these allocations are important for sUAS is that the FCC has allocated the 5030-5091 MHz band to the AM(R)S on a primary basis for Federal and non-Federal use, while noting that the 5030-5091 MHz band would be appropriate to satisfy the terrestrial, line-of-sight, spectrum requirements for command and control of UAS in non‑segregated airspace. See U.S. Proposals for WRC-12, First Tranche, Agenda Item 1.3 (“given that there is minimum use in this band worldwide and because the lack of an existing or planned microwave landing system deployment in the United States at 5030-5091 MHz ensures availability of appropriate aeronautical spectrum for terrestrial line-of-sight UAS in the band”)( The U.S. Proposals for the WRC-12 consisted of three letters from the Commission and NTIA to the U.S. Department of State:  First Tranche (February 17, 2011); Second Tranche (RCS-2394/1, June 21, 2011); and Third Tranche (September 19, 2011) (together, U.S. Proposals for WRC-12, available at  

The Small UAV Coalition generally supported this allocation, noting that the allocation of this band should be flexible to accommodate future uses of the band by low‑altitude small UAS and uses beyond line-of-sight.  Boeing also supported this allocation, Boeing also supported the AM(R)S allocation, noting the expected substantial growth of UAS in the coming years, including flight operations outside of segregated airspace. Boeing also noted that the 5030-5091 MHz band was well suited for line-of-sight control links because it remains relatively unused.

So, while the allocations are established, the service rules for use of the spectrum at and around airports is not, and these rules are the subject of this Notice of Proposed Rulemaking.  Those readers with an interest in helping to shape the rules for the deployment of the AeroMACS frequencies for uses which will affect small UAS, particularly for uses beyond line-of-sight, are urged to file comments. 
Electronic Filers:  Comments may be filed electronically using the Internet by accessing the ECFS:  The File No. of this proceeding is RM-11793.  The Comment Date is August 18, 2017, and the Reply Date:  September 5, 2017.

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