Federal Communications Commission
Washington, D.C. 20554
June 22, 2009
DA 09-1380
Mr. Robert Scoble
General Manager Aircraft Inspection and Regulatory Control
United Airlines
San Francisco International Airport
MOC – SFOIQ, Building 15
San Francisco, CA  94128
Re:  “Request for an interim variance to FCC Rule 47 CFR 87.199(f) requirement for a 
clearly discernable permanent plate or label”
Dear Mr. Scoble,
We have before us your letter, dated September 24, 2008, requesting a temporary waiver 
of Section 87.199(f) of the Commission's Rules, 47 C.F.R. 87.199(f), regarding the plan of 
United Airlines (United) to install labels on its 406 MHz emergency locator transmitters (ELTs).  
For the reasons that follow, we grant the waiver request to the extent indicated below.
By way of background, 406 MHz ELTs are radio beacons that are activated either 
manually or automatically, and used as alerting and locating aids in aviation distress situations.  
See 47 C.F.R. § 87.5.  Each 406 MHz ELT is programmed with a unique identification code, and 
must be registered with the National Oceanographic and Atmospheric Administration (NOAA).  
See 47 C.F.R. § 87.199(e), (f).  Up-to-date registration information enables rescue personnel to 
quickly verify that a received alert involves an actual distress situation, and aids in ascertaining
the identity and location of the parties in distress.  Because of the importance of this information, 
Section 87.199(f) specifically requires that every 406 MHz ELT, in addition to bearing the label 
required by the Commission’s equipment certification rules, 47 C.F.R. §§ 2.925, 2.926, “be 
provided on the outside with a clearly discernable permanent plate or label” containing the unit’s 
identification code and reminding the user that it must be registered with NOAA.  See 47 C.F.R. 
§ 87.199(f).  
You indicate that United learned during a quality assurance audit that some of its 406 
MHz ELTs did not have the label required by Section 87.199(f). You state that these 406 MHz 
ELTs are in fact properly registered with NOAA.  You also report that United is working with its 
supplier to obtain labels for the 406 MHz ELTs, and you seek a waiver of Section 87.199(f), to 
the extent necessary, to permit United to install the missing labels at each beacon’s next 
maintenance visit or removal from service, or prior to any transfer to another owner. You state 
that this plan could take up to five years to complete. You propose to attach the labels in this 
manner in order to avoid the possibility that the identification code might otherwise be recorded 
on the label incorrectly by maintenance personnel unfamiliar with the equipment.
Mr. Robert Scoble Page 2
Under the circumstances presented, we find your proposal for bringing the beacons into 
compliance with Section 87.199(f) to be acceptable. Within five years, United will install the 
missing labels, either at each beacon’s next maintenance visit or removal from service, or prior 
to any transfer to another owner. Because United’s 406 MHz ELTs already are properly 
registered with NOAA, the primary purpose of the rule is being served.  We do not believe that it 
is necessary to require that the 406 MHz ELTs be brought into immediate compliance with the 
labeling requirement if doing so carries a risk of mislabeling the beacons.  We reserve discretion 
to seek further information regarding United’s progress in bringing the beacons into compliance, 
and to make further inquiry (and to pursue any appropriate action) regarding the manufacturer's 
compliance with the Commission's Rules.
Accordingly, pursuant to the authority contained in Sections 0.131 and 0.331 of the 
Commission's Rules, 47 C.F.R. §§ 0.131, 0.331, the request for waiver of Section 87.199(f) of 
the Commission's Rules, 47 C.F.R. 87.199(f), IS GRANTED to the extent indicated above, for a 
period of five years from the date of this letter.
FEDERAL COMMUNICATIONS COMMISSION
Scot Stone
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau