After a couple of days, there doesn't seem to be much new information on
the supposed banning of 121.5 ELTs in August. The FCC, as far as I know
at this time, has not denied the alleged ban, but they have not admitted
it either. Either way, I really do not think it can be done quite as
quickly as the first reports indicated. Given the lack of comment by
the FCC, I feel that they are up to something. With that in mind, I
wrote the following letter to the FCC. I'm sure it isn't perfect but
feel free to use it as is or as food for thought to write your own.
Tommy
N93929
Chairman Julius Genachowski
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Sir:
Recent reports concerning the FCC's decision to prohibit use of
Emergency Locator Transmitters on 121.5 MHz are alarming. We all know
that these ELTs are not tremendously dependable or accurate and I do not
think anyone will argue that the potential of the 406 MHz Elts promises
to be far superior. However, the reports being circulated, and to my
knowledge not denied by your agency, are indicating a very short time
for the retirement of the 121.5 ELTs. Sir, this is not practical in
many aspects:
1. Production and delivery.
Can the manufacturers of the 406 ELTs produce 100,000 units in time to
meet the rumored retirement date of August?
2. Installation.
Given the down turn in general aviation maintenance facilities; can
100,000 units be installed by the retirement date?
3. Cost.
Currently an ELT operating on 121.5 MHz can be bought for as little as
$200.00. However, the cheapest 406 MHz ELT I have personally been able
to locate will cost approximately $800.00 by the time it is delivered
and another $200 for installation. This is a minimum cost of $1000.00
for each and every general aviation aircraft in the country. This will
mean an outlay of approximately $100000000.00 (One Hundred Million
Dollars) from a segment of our economy that is already struggling if not
dying. If so, to what or who's benefit?
4. Triple frequency units.
In recent years there have been many triple frequency units sold and
installed. These units operate on 121.5 MHz, 243.0 MHz, and 406 MHz.
Does this new regulation ban those new units because they transmit on
121.5?
5. Search equipment.
Who will be responsible for re-equipping all search aircraft and ground
teams with new radio signal direction finding equipment?
6. Reliability.
Even with all of its short comings and problems 121.5 or some other
ground based and ground searched signal must be maintained. As good as
the satellite systems are; there are times and places where the
satellites just cannot be "seen."
Even when the 121.5MHz ELT's were being monitored by satellite, many
signals were reported by other aircraft that were later or never heard
by the satellites.
On the subject of cost: Does the FCC plan on issuing vouchers for the
replacement units, similar to those issued for television converters
boxes? That is only logical since this change will apparently be
mandated without any concern for those it affects. Personally, I would
be willing to meet half way as my ELT is not new and I would eventually
have to replace it anyhow.
All things considered, from my perspective and probably that of about
600,000 others; this new proposal is extremely short-sighted and it is
clear your commission has not thought this new regulation completely
through. Please do not hesitate to contact me if you have any questions
concerning my comments.
Copies:
Hon. Henry Cuellar, U.S. House of Representatives
Mr. Craig Fuller, Aircraft Owners and Pilots Association
Mr. Tom Poberezny, Experimental Aircraft Association
Mr. Skip Carden, Ercoupe Owners Club
Commissioner Michael J. Copps
Commissioner Robert McDowell
Commissioner Mignon Clyburn
Commissioner Meredith Attwell Baker
