The Association For Maximum Service Television has joined NAB in opposing the portion of the FAA Notice of Proposed Rulemaking that would require spectrum users who may potentially impact FAA communications and navigation facilities to notify the FAA before making changes to their operations. The frequencies used by VHF broadcasters (both TV and FM radio) are included in the spectrum affected by the NPRM.
In its comments, MSTV said that the proposed modifications to Part 77 of the FAA's Rules, "particularly as they apply to users of the VHF television spectrum... would provide no benefit to air safety, while unnecessarily imposing dramatic costs on broadcasters and other users of the radio spectrum..." It also said the proposal interferes with the FCC's "ability to discharge its responsibility to regulate the use of the broadcast spectrum in the public interest."
MSTV argues that the existing partnership between the FAA and the FCC has worked well, as evidenced by its review of air crash data published by the National Transportation Safety Board showing that not even one incident was attributable to radio frequency interference. It also notes that VHF TV broadcasters require FCC licenses and that every broadcast application is "open to comment from any member of the public, including the FAA, and such comments are routinely considered when the FCC acts on pending applications." MSTV added that since the applications and their technical data are available in the FCC's databases, the FAA could easily coordinate with the FCC to obtain the information it needs without the need for a rule change.
