On April 1, the Aircraft Electronics Association submitted comments on the notice of proposed rulemaking published at 78 Fed. Reg. 6276 (January 30, 2013). Click here to view the comments or read below.
In general, the AEA supports the enhanced safety that C126 ELTs provide over C-91a. As such, the AEA supports shutting down the pipeline for future C91a ELTs. The association supports the Federal Communications Commission's proposal to no longer approve the importation or manufacturing of legacy C-91a ELTs.
The association DOES NOT support the FCC's proposal to prohibit the sale of existing TSO C-91a ELTs. Also, the AEA also DOES NOT support the retroactive decertification of existing TSO C-91/C91a ELTs.
The Federal Aviation Administration has been delegated the responsibility for aviation safety, including the requirement for emergency locator transmitters. Title 14 of the Code of Federal Regulations (CFR) requires that there is an approved automatic type emergency locator transmitter attached to the airplane (§ 91.207 Emergency locator transmitters). The regulation further states that if an article is required to be approved under the Federal Aviation Regulations, it may be approved under a TSO. (§ 21.8 Approval of articles) TSO C-91a ELTs are produced to a government standard (FAA-TSO) -- the association does not believe it is within the jurisdiction of the FCC to simply negate another agency's standard.
The AEA does not support the prohibition of sale of existing ELTs nor the prohibition of use of the existing C-91a ELTs. The association considers the prohibition to use existing C-91a-approved ELTs to be a retroactive decertification of an FAA-approved article.