Regulatory Alert: FAA to Release NOTAMs Identifying 5G-Related Restrictions
January 12, 2022
Today, the Federal Aviation Administration (FAA) notified AAAE that the agency plans to issue Notices to Air Missions (NOTAMs) this evening at 12 a.m. EST on Thursday, January 13, identifying the limitations that may be placed on low-visibility operations when a radio altimeter is required and where the 5G C-Band is deployed. While the NOTAMs will be issued tonight, they will not go into effect until January 19 when Verizon and AT&T activate their network. You will be able to view and search these NOTAMs on the agency's NOTAM Search website. 
In terms of next steps, operators and aircraft and altimeter manufacturers are working closely with FAA and the telecoms on technical solutions that would allow operators to obtain approval from FAA to conduct low-visibility operations at airports with instrument approach procedures (IAPs) that have been identified by the NOTAMs. According to our discussions with the agency, FAA is expected to issue a number of these approvals in the immediate future, which will help reduce the operational impacts from the NOTAMs.
AAAE has been in constant communication with senior leadership from FAA, lawmakers, and our airline partners, expressing our concerns over the rollout and working to minimize operational impacts to the greatest extent possible. The 5G issue has been extensively discussed at our 36th Annual Aviation Issues Conference this week, and we have been working to address questions that have been raised by our members given the complexity of the issue.
AIRPORT FAQs ON 5G IMPACTS
AAAE has received many questions regarding the status of potential 5G C-Band operational impacts and has been working with FAA and our industry partners to address your questions. Based on FAA publications and our discussions with the agency, we have developed the following FAQs and information to help you navigate the complexities of this 5G issue.
When will the 5G C-Band network be deployed? The 5G C-Band network will be deployed on January 19, 2022. Verizon and AT&T were originally expected to deploy their new C-Band network on December 5, 2021, but it was delayed until January 5 after concerns were raised about potential impacts of 5G signals on aircraft operations. On January 4, the U.S. Department of Transportation (DOT) and FAA reached an agreement with Verizon and AT&T whereby the telecoms agreed to delay the rollout by two weeks to January 19. 
Does AAAE expect any additional delays with the deployment? No, as part of the January 4 agreement between DOT/FAA and the telecoms, the federal government agreed not to seek any further delays in rolling out the 5G C-Band network. 
Where will the 5G C-Band network be deployed? Verizon and AT&T plan to deploy their new 5G C-Band network in 46 different markets across the country. The cities where deployment will occur on January 19 are known as Partial Economic Areas (PEA) 1-4, 6-10, 12-19, 21-41, and 43-50 from a list that the Federal Communications Commission (FCC) has published here. If the city does not fall within the PEAs identified, the 5G C-Band will not be rolled out in your area until late 2023. You can view a map of the PEAs here. 
What airports fall within the 46 markets where the 5G C-Band will be deployed? FAA has not provided a list of all the airports located within the 46 markets where the 5G C-Band network will be deployed. However, FAA plans to release NOTAMs this evening identifying the airports located within these markets, so a list can be developed following the release. 
What happens if my airport is located within the 46 markets where the 5G C-Band will be deployed? FAA plans to issue an aerodrome NOTAM this evening for any airport that is located within those 46 markets, or PEAs, where the 5G C-Band will be deployed. In addition, the agency will be issuing a series of IAP NOTAMs that will restrict the IAPs that may be used by operators at specific airports. 
What happens if FAA issues an aerodrome NOTAM for my airport? The operator will be prohibited from using autoland, heads-up display (HUD) to touch down, or enhanced flight vision systems (EFVS) to touchdown. These systems can be used if the operator obtains an alternative method of compliance (AMOC) approval from FAA, which is further discussed below. The NOTAM does not mean that the operator is prohibited from landing at the airport. For additional details on aerodrome NOTAMs, see FAA's NOTAM and AMOC Guide that they published in relation to the 5G issue. 
What happens if FAA issues an IAP NOTAM in relation to my airport? The operator can fly a visual or any IAP at your airport that does not have a NOTAM. The IAP NOTAM will restrict procedures that require radio altimeters and have visibility requirements less than a half mile. There is an exception: As further discussed below, if the operator has obtained an AMOC approval from FAA, the operator may be able to use IAPs restricted by the IAP NOTAM. For additional details on IAP NOTAMs, see FAA's NOTAM and AMOC Guide that they published in relation to the 5G issue. 
What is an FAA AMOC approval, especially in the context of this 5G issue? On December 9, FAA issued a determination that radio altimeters “cannot be relied upon to perform their intended function“ if they experience 5G interference. This led the agency to issue two airworthiness directives (2021-23-12 and 2021-23-13) for all transport and commuter category airplanes and helicopters equipped with radio altimeters, prohibiting these aircraft from conducting operations identified by NOTAMs (e.g., low-visibility operations when a radio altimeter is required). 
An AMOC approval from FAA is specific to an aircraft and means that an operator has demonstrated to the agency that their aircraft or altimeter models are not susceptible to 5G interference. If an AMOC approval has been secured, the operator will no longer be restricted by the airworthiness directives or any applicable NOTAMs, although the operator will be subject to any terms or conditions identified in the AMOC approval.
What is the likelihood of FAA issuing AMOC approvals in the context of this 5G issue? Has FAA issued AMOC approvals for any aircraft or altimeters to operate in the 5G C-Band environment? As part of the January 4 agreement between DOT/FAA and Verizon and AT&T, the telecoms are sharing 5G data with the federal government. FAA is working closely with aircraft and altimeter manufacturers to review the data, along with altimeter test results, to determine which aircraft can be granted AMOC approvals. According to our discussions with FAA, the agency plans to issue AMOC approvals for many aircraft and altimeter models that have demonstrated that they can be safely used in a 5G C-Band environment. These approvals are under review at the agency and are expected to be issued in the immediate future. 
How many aircraft are expected to receive AMOC approvals to operate in the 5G C-Band environment? AAAE has been requesting additional information on the scope of aircraft and altimeters that can or cannot be safely operated in the 5G C-Band environment. At this stage, FAA has not been able to approximate the scope of expected approvals. 
On January 7, FAA published a list of 50 airports where Verizon and AT&T will create “buffer zones.“ What is a “buffer zone“ and will they be permanent? As part of the January 4 agreement, Verizon and AT&T agreed to implement mitigation measures, called “buffer zones“ or “exclusion zones,“ at 50 airports for a period of six months, or through July 5, 2022. Prior to the agreement, the telecoms were planning to activate 5G antennae that were located within very close proximity to some airports within the 46 markets, or PEAs. Under the deal with DOT/FAA, the telecoms agreed to not activate these antennae around 50 airports, creating “buffer zones“ around the runways. These measures, which are similar to what has been adopted in France, are expected to 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. You can read additional details about these buffer zones in the telecoms' January 2 letter to DOT and FAA. 
What benefits do the telecoms' “buffer zones“ provide to the 50 airports that were included on the list? According to discussions with FAA, 5G C-Band interference depends on the distance between the aircraft and its altimeter and the 5G antenna and its power level. By reducing the strength of the 5G signals near runways at these airports, FAA can issue additional AMOC approvals for aircraft to operate at these airports, thereby further mitigating the operational impacts of 5G interference. 
How did FAA develop the list of 50 airports where the “buffer zones“ will be implemented by Verizon and AT&T? Why were some airports excluded? The January 4 agreement between FAA/DOT and the telecoms limited the mitigation measures to only 50 airports. In discussions with FAA, the agency has emphasized that not every airport has a 5G antenna in close proximity to its runways. As a result, in developing its list of 50 airports, FAA primarily focused on airports where a 5G antenna was scheduled to be activated near a runway for that airport. FAA believes this is where the telecoms' mitigation measures would be most effective. In addition, FAA considered traffic volume, the number of low-visibility days, and geographic location when selecting the 50 airports. 
Why are these restrictions necessary when the 5G C-Band network has been successfully deployed in other countries? This week FAA published a statement on why 5G C-Band deployment in the United States is different than in other countries: 
The U.S. airspace is the most complex in the world, and the FAA holds ourselves and our aviation sector to the highest safety standards. Deployments of 5G technology in other countries often involve different conditions than those proposed for the U.S., including: 
• Lower power levels
• Antennas tilted downward to reduce potential interference to flights 
• Different placement of antennas relative to airfields 
• Frequencies with a different proximity to frequencies used by aviation equipment 
• The early stages of the 5G deployment in the U.S. will include mitigations that are partly similar to those used to help protect air travel in France. However, even these proposals have some significant differences.
• Planned buffer zones for U.S. airports only protect the last 20 seconds of flight, compared to a greater range in the French environment.
• 5G power levels are lower in France. In the U.S., even the planned temporary nationwide lower power levels will be 2.5x higher than in France.
• In France, the government required that antenna must be tilted downward to limit harmful interference. Similar restrictions do not apply to the U.S. deployment.
Has FAA published any resources on the 5G C-Band issue? Yes, FAA has a dedicated webpage to the 5G issue that you can find here. AAAE also recommends reviewing the following resources: 
• FAA Safety Alert for Operators (SAFO) 21007, “Risk of Potential Adverse Effects on Radio Altimeters when Operating in the Presence of 5G C-Band Interference“ (Dec. 23, 2021) 
• FAA's List of 50 Airports with Buffer Zones 
• FAA's NOTAM and AMOC Guide on 5G 
• FCC PEA Nos. 1-4, 6-10, 12-19, 21-41, and 43-50 
• Verizon and AT&T's January 2 Letter to DOT/FAA 
• AAAE's December 30 Regulatory Alert on FAA's 5G Impacts Update 
• AAAE's January 4 Regulatory Alert on DOT/FAA Agreement with the Telecoms 
• AAAE's January 8 Regulatory Alert on List of 50 Airports with Buffer Zones  
Today, the Federal Aviation Administration (FAA) notified AAAE that the agency plans to issue Notices to Air Missions (NOTAMs) this evening at 12 a.m. EST on Thursday, January 13, identifying the limitations that may be placed on low-visibility operations when a radio altimeter is required and where the 5G C-Band is deployed. While the NOTAMs will be issued tonight, they will not go into effect until January 19 when Verizon and AT&T activate their network. You will be able to view and search these NOTAMs on the agency's NOTAM Search website. 
In terms of next steps, operators and aircraft and altimeter manufacturers are working closely with FAA and the telecoms on technical solutions that would allow operators to obtain approval from FAA to conduct low-visibility operations at airports with instrument approach procedures (IAPs) that have been identified by the NOTAMs. According to our discussions with the agency, FAA is expected to issue a number of these approvals in the immediate future, which will help reduce the operational impacts from the NOTAMs.
AAAE has been in constant communication with senior leadership from FAA, lawmakers, and our airline partners, expressing our concerns over the rollout and working to minimize operational impacts to the greatest extent possible. The 5G issue has been extensively discussed at our 36th Annual Aviation Issues Conference this week, and we have been working to address questions that have been raised by our members given the complexity of the issue.
AIRPORT FAQs ON 5G IMPACTS
AAAE has received many questions regarding the status of potential 5G C-Band operational impacts and has been working with FAA and our industry partners to address your questions. Based on FAA publications and our discussions with the agency, we have developed the following FAQs and information to help you navigate the complexities of this 5G issue.
When will the 5G C-Band network be deployed? The 5G C-Band network will be deployed on January 19, 2022. Verizon and AT&T were originally expected to deploy their new C-Band network on December 5, 2021, but it was delayed until January 5 after concerns were raised about potential impacts of 5G signals on aircraft operations. On January 4, the U.S. Department of Transportation (DOT) and FAA reached an agreement with Verizon and AT&T whereby the telecoms agreed to delay the rollout by two weeks to January 19. 
Does AAAE expect any additional delays with the deployment? No, as part of the January 4 agreement between DOT/FAA and the telecoms, the federal government agreed not to seek any further delays in rolling out the 5G C-Band network. 
Where will the 5G C-Band network be deployed? Verizon and AT&T plan to deploy their new 5G C-Band network in 46 different markets across the country. The cities where deployment will occur on January 19 are known as Partial Economic Areas (PEA) 1-4, 6-10, 12-19, 21-41, and 43-50 from a list that the Federal Communications Commission (FCC) has published here. If the city does not fall within the PEAs identified, the 5G C-Band will not be rolled out in your area until late 2023. You can view a map of the PEAs here. 
What airports fall within the 46 markets where the 5G C-Band will be deployed? FAA has not provided a list of all the airports located within the 46 markets where the 5G C-Band network will be deployed. However, FAA plans to release NOTAMs this evening identifying the airports located within these markets, so a list can be developed following the release. 
What happens if my airport is located within the 46 markets where the 5G C-Band will be deployed? FAA plans to issue an aerodrome NOTAM this evening for any airport that is located within those 46 markets, or PEAs, where the 5G C-Band will be deployed. In addition, the agency will be issuing a series of IAP NOTAMs that will restrict the IAPs that may be used by operators at specific airports. 
What happens if FAA issues an aerodrome NOTAM for my airport? The operator will be prohibited from using autoland, heads-up display (HUD) to touch down, or enhanced flight vision systems (EFVS) to touchdown. These systems can be used if the operator obtains an alternative method of compliance (AMOC) approval from FAA, which is further discussed below. The NOTAM does not mean that the operator is prohibited from landing at the airport. For additional details on aerodrome NOTAMs, see FAA's NOTAM and AMOC Guide that they published in relation to the 5G issue. 
What happens if FAA issues an IAP NOTAM in relation to my airport? The operator can fly a visual or any IAP at your airport that does not have a NOTAM. The IAP NOTAM will restrict procedures that require radio altimeters and have visibility requirements less than a half mile. There is an exception: As further discussed below, if the operator has obtained an AMOC approval from FAA, the operator may be able to use IAPs restricted by the IAP NOTAM. For additional details on IAP NOTAMs, see FAA's NOTAM and AMOC Guide that they published in relation to the 5G issue. 
What is an FAA AMOC approval, especially in the context of this 5G issue? On December 9, FAA issued a determination that radio altimeters “cannot be relied upon to perform their intended function“ if they experience 5G interference. This led the agency to issue two airworthiness directives (2021-23-12 and 2021-23-13) for all transport and commuter category airplanes and helicopters equipped with radio altimeters, prohibiting these aircraft from conducting operations identified by NOTAMs (e.g., low-visibility operations when a radio altimeter is required). 
An AMOC approval from FAA is specific to an aircraft and means that an operator has demonstrated to the agency that their aircraft or altimeter models are not susceptible to 5G interference. If an AMOC approval has been secured, the operator will no longer be restricted by the airworthiness directives or any applicable NOTAMs, although the operator will be subject to any terms or conditions identified in the AMOC approval.
What is the likelihood of FAA issuing AMOC approvals in the context of this 5G issue? Has FAA issued AMOC approvals for any aircraft or altimeters to operate in the 5G C-Band environment? As part of the January 4 agreement between DOT/FAA and Verizon and AT&T, the telecoms are sharing 5G data with the federal government. FAA is working closely with aircraft and altimeter manufacturers to review the data, along with altimeter test results, to determine which aircraft can be granted AMOC approvals. According to our discussions with FAA, the agency plans to issue AMOC approvals for many aircraft and altimeter models that have demonstrated that they can be safely used in a 5G C-Band environment. These approvals are under review at the agency and are expected to be issued in the immediate future. 
How many aircraft are expected to receive AMOC approvals to operate in the 5G C-Band environment? AAAE has been requesting additional information on the scope of aircraft and altimeters that can or cannot be safely operated in the 5G C-Band environment. At this stage, FAA has not been able to approximate the scope of expected approvals. 
On January 7, FAA published a list of 50 airports where Verizon and AT&T will create “buffer zones.“ What is a “buffer zone“ and will they be permanent? As part of the January 4 agreement, Verizon and AT&T agreed to implement mitigation measures, called “buffer zones“ or “exclusion zones,“ at 50 airports for a period of six months, or through July 5, 2022. Prior to the agreement, the telecoms were planning to activate 5G antennae that were located within very close proximity to some airports within the 46 markets, or PEAs. Under the deal with DOT/FAA, the telecoms agreed to not activate these antennae around 50 airports, creating “buffer zones“ around the runways. These measures, which are similar to what has been adopted in France, are expected to 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. You can read additional details about these buffer zones in the telecoms' January 2 letter to DOT and FAA. 
What benefits do the telecoms' “buffer zones“ provide to the 50 airports that were included on the list? According to discussions with FAA, 5G C-Band interference depends on the distance between the aircraft and its altimeter and the 5G antenna and its power level. By reducing the strength of the 5G signals near runways at these airports, FAA can issue additional AMOC approvals for aircraft to operate at these airports, thereby further mitigating the operational impacts of 5G interference. 
How did FAA develop the list of 50 airports where the “buffer zones“ will be implemented by Verizon and AT&T? Why were some airports excluded? The January 4 agreement between FAA/DOT and the telecoms limited the mitigation measures to only 50 airports. In discussions with FAA, the agency has emphasized that not every airport has a 5G antenna in close proximity to its runways. As a result, in developing its list of 50 airports, FAA primarily focused on airports where a 5G antenna was scheduled to be activated near a runway for that airport. FAA believes this is where the telecoms' mitigation measures would be most effective. In addition, FAA considered traffic volume, the number of low-visibility days, and geographic location when selecting the 50 airports. 
Why are these restrictions necessary when the 5G C-Band network has been successfully deployed in other countries? This week FAA published a statement on why 5G C-Band deployment in the United States is different than in other countries: 
The U.S. airspace is the most complex in the world, and the FAA holds ourselves and our aviation sector to the highest safety standards. Deployments of 5G technology in other countries often involve different conditions than those proposed for the U.S., including: 
• Lower power levels
• Antennas tilted downward to reduce potential interference to flights 
• Different placement of antennas relative to airfields 
• Frequencies with a different proximity to frequencies used by aviation equipment 
• The early stages of the 5G deployment in the U.S. will include mitigations that are partly similar to those used to help protect air travel in France. However, even these proposals have some significant differences.
• Planned buffer zones for U.S. airports only protect the last 20 seconds of flight, compared to a greater range in the French environment.
• 5G power levels are lower in France. In the U.S., even the planned temporary nationwide lower power levels will be 2.5x higher than in France.
• In France, the government required that antenna must be tilted downward to limit harmful interference. Similar restrictions do not apply to the U.S. deployment.
Has FAA published any resources on the 5G C-Band issue? Yes, FAA has a dedicated webpage to the 5G issue that you can find here. AAAE also recommends reviewing the following resources: 
• FAA Safety Alert for Operators (SAFO) 21007, “Risk of Potential Adverse Effects on Radio Altimeters when Operating in the Presence of 5G C-Band Interference“ (Dec. 23, 2021) 
• FAA's List of 50 Airports with Buffer Zones 
• FAA's NOTAM and AMOC Guide on 5G 
• FCC PEA Nos. 1-4, 6-10, 12-19, 21-41, and 43-50 
• Verizon and AT&T's January 2 Letter to DOT/FAA 
• AAAE's December 30 Regulatory Alert on FAA's 5G Impacts Update 
• AAAE's January 4 Regulatory Alert on DOT/FAA Agreement with the Telecoms 
• AAAE's January 8 Regulatory Alert on List of 50 Airports with Buffer Zones  
