industry. Currently, the rotorcraft AMOC procedures have not been formally released by the FAA; the process is still being worked on and fine-tuned. It is critical that the FAA continue the same level of urgency and commitment it has had for commercial aviation to mitigate operational impacts upon helicop- ter operations and the rest of general aviation and the essential ser- vices they provide to save lives, protect com- munities, and support jobs. The effects of 5G
deployment are not limited to the nation’s busiest airports, and mitigations by wire- less carriers should not be limited to those locations either. As we evaluate AMOCs for rotorcraft, we must recognize that the air- lines’ operational environment is vastly dif- ferent from that for rotorcraft. An airliner is only in the zone of potential 5G interfer- ence for a short time, generally during the critical periods of takeoff and landing. The vast majority of its flight occurs at high alti- tudes, out of the range of 5G interference. Conversely, helicopter operations, which
take place at much lower altitudes than air- line flights, could very well conduct their entire flight within the zones of interfer- ence. In addition, while airplanes must take off and land from airports, rotorcraft can uti- lize a much wider variety of sites, including heliports and unimproved locations such as streets, parking lots, or fields. The voluntary measures proposed by the wireless carri- ers would provide modest 5G limitations at the surface of public-use heliports, of which there are only 55 in the country. That number is dwarfed by the estimated 6,533 to 8,533 helicopter air ambulance (HAA) landing sites in the United States, with more than 4,000 being private-use heli- ports colocated at hospitals.
HAI has partnered with the FAA to maxi-
mize the efficiency the AMOC process. Knowing that the FAA would be under immense pressure to approve a large amount of AMOCs, HAI took steps to ensure that critical helicopter operations could be prioritized. In cooperation with the
My members ask why they should be financially responsible for installing new equipment to mitigate the safety risk imposed by another corporation’s decision to deploy 5G wireless systems.
FAA, HAI developed a 5G AMOC Portal (
rotor.org/5g-amoc), where operators can report how their operations are being impacted by 5G interference. These reports are shared with the FAA, providing it with additional intelligence on 5G impacts.
Exemptions The other avenue to reduce the operational impact of 5G interference is the exemption process. HAI is pleased that the FAA par- tially approved a petition for exemption that HAI had submitted in anticipation of 5G C band deployment, seeking relief from regulations that require a normally function- ing radio altimeter for certain operations. This exemption allows Part 119 certifi- cate holders authorized to conduct HAA operations under Part 135, Subpart L, to continue Part 135 helicopter operations while employing radar altimeters that may not function normally due to 5G interfer- ence. The relief also allows the use of night-vision goggles (NVG) in HAA operations. These exemptions are contingent on
certain conditions and limitations. All pilots conducting operations under the exemp- tion are required to receive and maintain a record of proper training. Additional
conditions for NVG operations include the installation of a movable searchlight and a requirement for pilots or crew members to establish radio contact with ground person- nel at a landing site so they can receive and confirm a description of the landing site. To date, 40 HAA operators have submit- ted letters of intent to use the HAI exemption. This accounts for 1,206 helicopters in opera- tion, or 97% of the approximately 1,250 helicopters used in HAA operations. This exemption pro-
vides a significant path for moving forward, not only for HAA operators but also for the countless communities and hospital net- works that would otherwise have been deprived of the critical lifesaving support that can only be offered by helicopter oper- ations. This exemption will allow HAA oper- ators to continue to do what they do best—save lives.
The Path Forward I want to be very clear: HAI and our mem- bers are not against 5G. However, due to our mission profiles and operational param- eters, 5G interference is of particular con- cern to the vertical flight sector. The deployment of 5G must be done so that it can safely coexist with aviation operations. Under the exemption and with the proper mitigations in place, HAA missions can move forward. However, other rotor- craft industry sectors do not have similar exemptions that enable them to continue operations. Critical public-service missions, including firefighting, utility work, and law enforcement, and economically important ones, such as transportation and flight training, are severely constrained if operat- ing in areas for which a 5G-related NOTAM has been issued. Additionally, emerging
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