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Thank you for the link – however this appears to be really outdated advisory (6/23/83) in some areas.
25-a. Communications with Air Traffic Control. In all radio communications with air traffic control, ultralight operators should state the word "ultralight" followed by the call letters assigned by the F.C.C. on your radio license, i.e., "Ultralight 12593U." Use of the following radio communication practices will result in the controller having a better understanding of your request and enhance the safety of your flight.
FCC Form 605 - On October 25, 1996, the FCC released a Report and Order in WT Docket No. 96-82 (text) eliminating the individual licensing requirement for all aircraft, including scheduled air carriers, air taxis and general aviation aircraft operating domestically. This means that you do not need a license to operate a two-way VHF radio, radar, or emergency locator transmitter (ELT) aboard aircraft operating domestically.
Now there could be some discussion as to the definition of an “aircraft”. As we know the FAA does not use the word "aircraft" in Part 103. However, this is as the FAA has stated to resolve the issue of the FAA having to regulate ultralights or keep the regulation to an absolute minimum. Note there's nothing in Part 103 that says ultralights are not aircraft. With that, the FAA identifies ultralights as vehicles. However, looking into 14 CFR 1.1 (Federal Register :: Request Access) it's in the FAA's very own definition that an ultralight is considered an aircraft just like a balloon, glider, Para-motor...etc. In 14 CFR 1.1 it states - "Aircraft means a device that is used or intended to be used for flight in the air.”
The common radio use for ultralights is to identify themselves as ultralight and intentions. This is as an identifier just as an N tail number is, with one exception – the announcement of “ultralight” does notify LSA/GA pilots that a slow moving aircraft is in the area – that's certainly not a bad thing. After all most ultralights can take off and land in the same space an LSA/GA aircraft parks in
, that is as long as the pilot is not too overweight! However, being a licensed Amateur Radio operator since the 90's, the main use of a license call sign (and in this case tail numbers for aircraft) is for identification and ease of communication. I can see starting the call with “ultralight” as being important. Such as Ultralight Echo Bravo Charlie 001 is no different of an identifier from Cessna or Skyhawk November Bravo1 6 niner. Both would typically go to the normal shortened version after the initial ID to say, Bravo Charlie 001 or even Charlie 001 and Bravo 1 6 niner.Along with this I would argue that the FCC sees ultralights as aircraft, therefore the FAA's advisory does not apply in the way it once did. I haven't dug into this, so I may be incorrect. At best, it means the use of a call sign using a radio license has not been applicable since October of 1996. At worst is leaves vagueness in how the FAA can/will interpret the requirement/regulation – and we know how much fun that is when dealing with the FAA and with any of their regulations.
25-b. (2) Covers the communications in uncontrolled airspace, and it's pretty much identical to that of what an LSA/GA aircraft would do. Much of this falls back to the tried and true of of any aircraft - aviate, navigate, communicate.
25-c. States the outdated issue mentioned above – there are no call letters assigned by the FCC. I do love 25-c. (3) Speak slowly and distinctly. Uh, maybe LSA/GA pilots need to be reminded of this. I hear pilots coming into Rockwall Muni (F46) all the time speaking as if they were communicating with ATC at Chicago or LAX. It's both funny and sad. Funny in that they don't realize that they are difficult to understand and sad in that they don't realize that they are difficult to understand! It's a muni - slow down, speak clearly, and use some voice as your cockpit noise is overpowering what you're trying to say. I would much rather they speak with authority and me understanding what their intentions are than "what did he/she say?" popping into my head.
This advisory is way out of date, there is no question about that, but it still contains good radio practice and information that is certainly usable by not only ultralight pilots but also by LSA/GA pilots.
What does this all cumulate to? Is it OK to use the EAA registration in an ADS-b out? I would say yes based on current regulations. It's obvious this is a changing area and the regulations haven't caught up yet - which is typical. I'm sure it will all flush out someday. There is an ADS-b out being developed which may resolve most of if not all of this problem. Check it here and see the additional articles about it on the right menu bar.
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