[unav_all] Public Comment Period on FCC's Proposed LightSquared Actions

Frederick Blume blume at unavco.org
Tue Feb 21 16:42:09 MST 2012

Dear Colleagues,
The Federal Communications Commission (FCC) is accepting public comments their proposed actions to vacate the conditional waiver granted in January, 2011 to LightSquared allowing use of the Mobile Satellite Services (MSS) spectrum adjacent to GPS for terrestrial broadband internet transmissions.  

UNAVCO has filed this comment in favor of the proposed actions, and we urge each of you to make your voices heard on this issue.  You may file comments on behalf of your institution, as a private citizen, or both, on or before March 1, 2012.  The FCC's decision is not yet final, and public input will be weighed before the actions are taken.

Public comments can be found and submitted from this page:


Comments may either be in the form of documents uploaded using the "Submit a Filing" link on then right, or simple text using the "Submit a Filing (Express)" form (proceeding number is 11-109).  It may be helpful to identify yourself as a member of the scientific community who relies on GPS infrastructure to support research.

Following extensive testing of LightSquared's initial proposal last summer that showed widespread interference on all classes of GPS receivers, LightSquared modified their plan to mitigate these issues.  Additional tests conducted last fall by the National Space-Based PNT Systems Engineering Forum (NPEF) using then modified plan conclusively showed that LightSquared's transmissions result in harmful interference.  The NPEF informed the National Telecommunications and Information Agency (NTIA) of their findings, and last week the head of the NTIA sent a letter to the FCC detailing its technical findings w.r.t. LightSquared's proposed deployment.  The conclusion is clearly stated:

"Federal agencies and LightSquared have invested significant time and resources to identify and analyze proposed solutions to adders the impact of LightSquared's planned network implementations.  Based on the testing and analyses conducted to date, as well as numerous discussions with LightSquared, it is clear that LightSquared's proposed implementation plans, including operations in the lower 10 MHz would impact both general/personal navigation and certified aviation GPS receivers.  We conclude at this time that there are no mitigation strategies that both solve the interference issues and provide LightSquared with an adequate commercial network deployment."

On February 15 the FCC posted this Public Notice, which proposes the following actions and calling for public comments:

"The NTIA, the federal agency that coordinates spectrum uses for the military and other federal government entities, has now concluded that there is no practical way to mitigate potential interference at this time. Consequently, the Commission will not lift the prohibition on LightSquared. The International Bureau of the Commission is proposing to 
(1) vacate the Conditional Waiver Order, and 
(2) suspend indefinitely LightSquared’s Ancillary Terrestrial Component authority to an extent consistent with the NTIA letter."

It is important to realize that while the short-term threat to GPS from LightSquared will disappear if the proposed FCC actions are implemented, there will be an ongoing need for spectrum that will drive the expansion of terrestrial broadband into the MSS at some point in the future.  It is likely that there will be a "10-year plan" to get which will involve the drafting of new receiver/antenna standards by the FCC/NTIA, development of new hardware, and a turnover period to allow the hardware to find its place in the field while older hardware is retired.  This time around we were perhaps able to skate through on the backs of the military, aviation, and other big entities, so we'll need to make sure we're engaged and our interests are represented as the process moves forward. 

The last paragraph of this letter from the DoD and DoC representatives of NPT EXCOM to the NTIA detailing the results of last fall's "Lower 10" testing on receivers (that did not include our class of High Precision devices) is particularly relevant:

"The EXCOM Agencies continue to strongly support the President's June 28, 2010 Memorandum to make available a total of 500 MHz of spectrum over the next 10 years, suitable for broadband use. We propose to draft new GPS Spectrum interference standards that will help inform future proposals for non-space, commercial uses in the bands adjacent to the GPS signals and ensure that any such proposals are implemented without affecting existing and evolving uses of space-based PNT services vital to economic, public safety, scientific, and national security needs."

Please contact me if you'd like more information or advice on the comment process.
Best regards,
Freddy Blume

Dr. Frederick Blume
Sr. Project Manager
6350 Nautilus Dr.
Boulder, CO  80301-5553
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