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Threat to GPS Use: Coalition to Save Our GPS

Type:  Featured News  

Threat to GPS use:  www.SaveOurGPS.org

Background: 

MALSCE, ACSM and representatives of a wide variety of industries and companies have joined the Coalition to Save Our GPS to resolve a serious threat to the reliability and viability of the Global Positioning System (GPS).  The Federal Communications Commission (FCC) recently granted a waiver to a company called LightSquared that allows them to repurpose the satellite spectrum immediately neighboring that of the GPS.

 

According to the Coalition to Save Our GPS, LightSquared plans to transmit ground-based radio signals that would be one billion or more times more powerful as received on earth than GPS's low-powered satellite-based signals, potentially causing severe interference impacting millions of GPS receivers - including those used by the federal agencies, state and local governments, first responders, airlines, mariners, civil engineering, construction and surveying, agriculture, and consumers.

 

In January 2011, the Federal Communications Commission (FCC) conditionally allowed a company called LightSquared to offer wireless broadband services in radio frequency bands adjacent to those used by GPS receivers. Based on feedback from public and private sector GPS users, the FCC told LightSquared that it could not launch service until testing could be completed to determine the extent of the problems that LightSquared would cause. The report on that testing was submitted to the FCC on June 30, 2011.  It showed there would be massive interference to GPS from LightSquared's proposed operations. The FCC is now seeking feedback from the public by July 30, 2011, especially from the surveying community, on the report.
 

Latest news -- scroll down for background and past news, with latest news first.

 

Studies and Reports page:  http://saveourgps.org/studies-reports.aspx#studiesreports 

 

May 30, 2012:  Apparently LightSquared has laid off nearly half of its workforce and filed for bankruptcy, but has not let go of any lobbyists. 

 

April 30, 2012:  (From the April 2012 ACSM/NSPS Government Affairs Update):
There is very little happening with our LightSquared issue these days. However, that does not mean we can take our eyes off the issue. The FCC is currently reviewing the thousands of comments submitted by various stakeholder groups and their members, and should issue a final ruling on LightSquared soon.
The Federal government put a lot of the LightSquared news on this very useful website: http://www.gps.gov/spectrum/lightsquared/. We will continue to monitor the issue and will keep MALSCE members informed as the issue progresses.
 

February 29, 2012:  The FCC extended the comment period deadline, previously March 1, to March 16.  On February 15, the Federal Communications Commission (FCC) issued a Public Notice proposing that it:
1) Withdraw the January 2011 waiver that allowed LightSquared to proceed with its planned wireless network; and
2) Modify LightSquared’s satellite license to prohibit LightSquared from building any ground-based wireless network.  
This FCC decision was brought about, in large part, by two additional interference studies released by the Federal government on February 14.  These reports (http://www.gps.gov/news/2012/02/lightsquared/) demonstrate that LightSquared’s network interferes with GPS and that there are no practical fixes to solve that interference. 

 

This is a great step forward for protecting GPS from interference. But, it is not the final step.
The FCC is now seeking public comment on its two proposals, and we need your help. 

 

We ask that you write the FCC applauding it for making the two proposals contained in the Public Notice, which if adopted would prohibit LightSquared from buildings its wireless network, and strongly urging the FCC to adopt both proposals.  The FCC has asked for public comments by March 16.  Although comments can be submitted up until the time that the FCC makes a formal decision on the matter, we urge you to write as soon as possible.

 

What can I do?

Everyone who cares about GPS should let the FCC know that the facts are now clear -- LightSquared cannot be allowed to move forward.   In writing to the FCC, we encourage you to cover the following points in your own words:

How you use GPS technology in your business and/or personal life.


What would happen to your business/personal life if GPS became unavailable or unreliable.
While more capacity for wireless broadband services is important, it should not come at the expense of GPS, which is critical to our country’s economy.


All of the engineering studies conducted, including those recently released by the government agency in charge of federal radio spectrum management, clearly show that LightSquared’s proposed network causes interference and that there are no remedies to fix this interference.


The FCC should formally adopt its proposed recommendations and deny LightSquared the authority to offer any ground-based wireless network.

 

How do I tell the FCC to save GPS?
The FCC has an easy-to-use portal on its website to submit feedback on the Public Notice:

(1)  Click on this link for the FCC’s Electronic Comments Filing System (ECFS):  http://apps.fcc.gov/ecfs/upload/display?z=3qvwi.
(2)  In the box which says “Proceeding Number,” type:  11-109.  It is important to include this docket number with your comments.
(3)  In the designated boxes, enter (a) your name or your company’s name, and (b) your mailing address/city/state/zip.
(4)  In the box which says “Type in or paste your brief comments,” do so.  Click “Continue”.
(5)  A review page will load listing all of the information entered.  If correct, click “Confirm.” (6)  If you have trouble, contact the FCC ECFS Helpdesk at 202-418-0193 or e-mail at ecfshelp@fcc.gov.

 

February 15, 2012:  It appears that the FCC has indefinitely suspended LightSquared's license.  More:   http://saveourgps.org/related-articles.aspx

 

January 31, 2012: 

Lightsquared petition to the FCC for declaratory relief (December 22, 2011) - (Link)

FCC Public Notice for Comments on the LightSquared's Petition for Declaratory Ruling - (Link)

 

It is more important than ever for our voices to be heard regarding the LightSquared issue. The FCC has asked for comments related to LightSquared’s claim that "Commercial GPS receivers are not licensed, do not operate under any service rules, and thus are not entitled to any interference protection whatsoever”, requesting  that the FCC “not grant interference protection to global positioning systems.” Comments are due by February 27

 

January 24, 2012: 

From Coalition to Save Our GPS Clips (not full report)
Senator Chuck Grassley issued a press release on a letter he sent to Philip Falcone of Harbinger Capital Partners, asking him to explain “questionable contact” with Grassley’s office by Falcone and another man who claimed to be working for LightSquared. 

 

Bloomberg, Broadcasting & Cable, Hot Air,  The New York Post, Farm Futures, TR Daily, DealBook, NextGov and Communications Daily  all reported on the Grassley letter, which said statements by the men “implied an invitation to pull punches in [Grassley’s ] investigation.” 

 

Harbinger issued a statement once the story was reported, which was added to several articles:

• “Mr. Ruelle does not, nor has he ever worked for Mr. Falcone, Harbinger or LightSquared as an employee or a consultant,” Harbinger said in a statement on Monday, in response to Mr. Grassley’s letter. “No one at Harbinger or LightSquared has had any discussions or negotiations with Mr. Ruelle with respect to approaching or contacting Senator Grassley’s office regarding an alleged quid pro quo, or a call center in Iowa, which in any event would be inconsistent with the LightSquared wholesale business model. If such conversations occurred, Mr. Ruelle was acting entirely on his own and without the knowledge, authority, or endorsement of Mr. Falcone, Harbinger or LightSquared.”

Communications Daily has an article on 4th quarter lobbying expenditures for 2011, highlighting a boost in spending by LightSquared, Trimble and John Deere. 

 

TV Technology reports that LightSquared filed full Alcatel Lucent test results with the FCC Friday, after having submitted a preliminary report about four weeks ago.

 

An op-ed for The Hill by Grover Norquist and William Cobb argues that spectrum crunch is a problem the FCC has been slow to resolve.  The piece uses LightSquared as an example, saying that the FCC “quickly quieted, cowered, and slowed the company’s plans” when GPS interference concerns were raised. 

 

An Investors Business Daily editorial about tonight’s State of the Union address argues that the President has “miserably failed even by his own definition of fairness.”  It lists LightSquared as an example of the President creating two sets of rules — “one for well-connected Democrats and one for the rest of the country.”

 

LightSquared issued a press release announcing a wholesale agreement with Telecom Ventures, which is comprised of two entities, Assist Wireless and New-Talk.

 

Fierce Wireless and Rethink Wireless report that Simplexity has reached a wholesale agreement with Clearwire that is similar to a deal it reached with LightSquared in September. 
 

Early January 2012:

Congress put legislation in the Defense Authorization Act that was just passed preventing the FCC from lifting restrictions and granting further permissions to Lightsquared until the interference issue has been resolved to the satisfaction to a number of congressional committees and the DOD.  
In addition, Sprint gave Lightsquared a 30 day extension to get the FCC approval needed. http://www.businessweek.com/news/2012-01-06/sprint-puts-investment-in-lightsquared-on-hold-hesse-says.html 

 

Action Alert on January 4:  The issue of LightSquared’s interference with GPS reception (as has been verified in testing) continues to be a major concern for us and those we serve as Professionals. LightSquared is pressuring the FCC to allow it to move ahead with its plans and disregard the recent independent test results.

 

We need your help to urge the FCC not to allow this happen. The information attached (LINK) provides details regarding how to submit your comments to the FCC. Please contact NSPS Government Affairs Consultant Laurence Socci (laurence@theclagroup.com) if you have questions. 

 

December 2011 from ACSM Government Affairs Report

Recent test results show that LightSquared’s signals will cause harmful interference with 75% of GPS receivers.
Additionally, separate analysis by the FAA found that LightSquared’s signals will interfere with a flight safety system designed to warn pilots of approaching terrain. The findings were presented to the technical steering group which represents nine federal agencies that make up the National Executive Committee for Space-Based Positioning, Navigation and Timing. The recent report is still being analyzed and more information should be made available soon.


On the legislative side, there are several bills working through Congress with language specifically relating to LightSquared interference. The National Defense Authorization Act for FY 2012 (H.R. 1540, S. 1253 and S. 1867) forbids the FCC from approving operations of the LightSquared terrestrial wireless network until the FCC has resolved concerns of widespread harmful interference to military GPS devices. The Financial Services and General Government Appropriations Act of 2012 prohibits the FCC from using FY 2012 funds to remove the conditions in LightSquared’s January 2011 authorization, or to otherwise permit commercial LightSquared operations until the FCC has resolved GPS interference concerns. Other appropriations bills reference potential GPS interference and state that federal funds will not be released until those interference issues are resolved, but do not specifically mention LightSquared. Congress has told us in various meetings, that it is the FCC that ultimately controls the direction of the LightSquared issue. A copy of the recent ACSM/NSPS Government Affairs Semi-Annual Report is in the update. In the section of the report related to LightSquared, there are step by step instructions on how to contact the FCC to voice your concerns. The FCC is encouraging feedback from high-precision GPS users on the LightSquared issue. Please take a moment to let the FCC know how this issue affects you.

 

November 30, 2011 from NSPS News & Views:

Several outlets — including The Washington Post, Bloomberg, The Des Moines Resister and Inside GNSS — reported on Sen. Grassley blasting the FCC about the release of documents related to LightSquared through Freedom of Information Act requests. Many noted that the FCC established a new website to post documents related to LightSquared. That website, available here, is described as a "public Web portal to provide ready access to publicly available documents and other responsive documents not otherwise exempt from release under the FOIA." The site also says the FCC is still in the process of releasing documents in response to FOIA requests.

 

October 11, 2011:

C-SPAN’s  The Communicators focused on LightSquared this week, with interviews with Rep. Paul Broun of the House Science, Space and Technology Subcommittee; Jim Kirkland, founding member of the Coalition to Save our GPS; and Fred Schulte, senior reporter of iWatch News.

A video clip of the show is available on CSPAN’s website here.

 

News from Capitol Hill…

The House Small Business Committee will hold a hearing on “LightSquared: The Impact to Small Business GPS Users” on Wednesday, October 12 at 1 pm Eastern.   Scheduled witnesses include:

  • Dennis B. Boykin IV, Chairman, Leesburg Executive Airport Commission, Leesburg, VA, Testifying on behalf of the Aircraft Owners and Pilots Association
  • Rick Greene, Precision Agronomy Manager, MFA Incorporated, Columbia, MO, Testifying on behalf of the Agriculture Retailers Association
  • Jeff Carlisle, Executive Vice President, LightSquared, Reston, VA
  • Tim Taylor, President & CEO, FreeFlight Systems, Irving, TX, Testifying on behalf of the Aircraft Electronics Association

In a letter dated September 29, 2011, Sen. Charles Grassley questioned whether the FCC’s initial approval of the LightSquared network could lead to billions of dollars of costs for taxpayers. “At no point has the FCC addressed who will pay to retrofit every single federal, state, and local government GPS receiver, which will require a filter as a result of interference” caused by LightSquared’s network, wrote Grassley.

 

On October 5, 2011, Sen. Grassley sent letters to the top investor in and the chief executive of LightSquared requesting the company’s communications with the White House and government agencies.  Grassley said in the letters (available here and here), "if LightSquared has nothing to hide and would like to put questions of improper influence at the FCC, Department of Commerce and White House to rest, the public release of these communications would allow Congress and the American people to fully examine the facts and decide for themselves."

 

The House Committee on Science, Space, and Technology issued a press release on October 6, 2011 reiterating its request that agencies provide the Committee with their assessments of the potential impacts of the LightSquared network on operations.  In addition, the Committee also released several LightSquared impact assessments by a number of federal agencies, including the Department of Transportation, the Department of Interior and NASA.  The agency assessments can be found here.

 

Trimble Responds to Misleading LightSquared Letter…

Trimble Vice President and General Counsel Jim Kirkland has submitted a letter to the Strategic Forces Subcommittee of the House Armed Services Committee responding to a letter to the committee from LightSquared Executive Vice President Jeffrey Carlisle that repeated many of the inaccurate claims LightSquared has made in the past.  The Trimble letter, dated October 6, 2011, is available here: http://www.saveourgps.org/pdf/Trimble_Response_-_HASC.pdf.  We thought you might be interested in reading the letter because it reflects the most current positions of the Coalition to Save Our GPS.  Some of those positions include those below.

  • General Shelton is correct that LightSquared has proposed a new and fundamentally different use of the MSS band adjacent to GPS.  LightSquared is the newcomer and approval of its plans would represent a major policy change as well as a major change in spectrum use.  As recently as March 2010, the FCC reiterated that MSS licensees were only authorized to use terrestrial operations to “fill-in” the footprint of a satellite service.  Because LightSquared is proposing fundamentally different operations in the MSS band than those previously authorized, it is responsible for bearing all costs of eliminating interference, including costs of replacing or retrofitting any existing equipment that will suffer interference after its mitigation proposals have been implemented.  
  • LightSquared’s selective discussion of the technical terms of its ATC authorization is beside the point. LightSquared’s suggestion that GPS manufacturers were required, starting in 2005, to start designing their equipment to accommodate eventual nationwide terrestrial operations in the MSS band has the order of priority precisely backwards.  In fact, MSS licensees have always operated under various direct and indirect obligations to limit terrestrial operations and to protect GPS. But it doesn’t matter, because even the January 2011 International Bureau waiver decision makes clear that LightSquared will not be permitted to operate until interference concerns are resolved.
  • GPS receivers do not “encroach” on LightSquared’s spectrum and are designed appropriately.  LightSquared’s contention that GPS receivers should have been designed differently over the last several years to avoid interference depends entirely on its inaccurate claim that the FCC authorized nationwide terrestrial service and terrestrial-only services in the MSS band in 2005.  Revisionist history aside, GPS receivers were designed in expectation that the “quiet neighborhood” in which MSS service was originally authorized would be maintained.
  • LightSquared’s revisionist history is clearly calculated either to hide or justify a multi-billion dollar spectrum windfall for its owners. The mobile satellite spectrum that Harbinger Capital acquired when it bought out LightSquared’s predecessor in March 2010 was originally awarded for free. LightSquared’s own consultants estimate that its value is currently $2 billion if limited to satellite use, but $12 billion if it can be used for unrestricted terrestrial mobile broadband services. So, if LightSquared is allowed to move forward, it will pocket an unjustified windfall at the expense of U.S. taxpayers. 
  • More tests are necessary. Both the NTIA and FCC have said that more testing of GPS devices in the presence of signals from LightSquared’s lower 10 MHz of spectrum is required.
  • The cost impact of interference to GPS is substantial.  GPS is essential to economic activity between $68 billion and $122 billion per year, and “an estimated $3 trillion worth of commerce relies on GPS for tracking, timing and navigation” worldwide.
  • LightSquared will have adverse effect on our nation’s military forces. GPS is vital to national security and is relied upon by our service men and women for a wide array of capabilities. Even if an effective filter could be developed and even if it were itself an inexpensive item, DOD would still have to conduct exhaustive tests.

September 22, 2011:  Rallies to Save GPS are being held around the country on September 22.   To organize your own local, civil rally  on this issue, here are some basic guidelines:  Organizing a Protect GPS Rally

 

September 10, 2011 GPS interference puts wireless startup in jeopardy with lawmakers, regulators (Blog:  The Hill):  http://thehill.com/blogs/hillicon-valley/technology/180725-gps-interference-put-wireless-startup-in-jeopardy

 

Interference Study Released:  http://www.saveourgps.org/interference-studies.aspx

 

Update for August 5, 2011:  MALSCE Member Action Alert

Action Alert from ACSM/NSPS Government Affairs
Contact Your Members of Congress Again This Month

 

Notify your US Senators and your US Representative this month during their August Recess about your concern, before LightSquared’s plan is allowed to move ahead, regarding the interference with GPS from LightSquared’s broadcast of signals. Many of members of Congress are back in Massachusetts this month; it’s a great time to contact them.

 

Contacting members of Congress for Massachusetts
2 US Senators (Kerry and Brown) represent the whole state and you have 1 US Representative for your district, based on where you live and vote.
Who is my US Representative? Find out:  http://www.wheredoivotema.com/bal/myelectioninfo.php

Contact info. for members of Congress for MA, including email contact forms:  http://www.contactingthecongress.org/cgi-bin/newseek.cgi?site=ctc2011&state=ma


Many of them will have public events near you this month – seek them out there too.  Or request a meeting in their district offices….Cordially, of course.

 

Key points for your message and/or if you have an opportunity to meet with any of our delegation while they are in the state this month:

  • How you use GPS technology in your business and/or personal life 
  • What would happen to your business/personal life if GPS became unavailable or unreliable 
  • While more capacity for wireless broadband services is important, it should not come at the expense of GPS, which is critical to our country’s economy  
  • The results of the testing that were performed at the FCC’s request are conclusive – they show that GPS reception would be wiped out by LightSquared’s proposed service. 
  • Now that the test results have shown interference to GPS, the FCC shouldn’t allow LightSquared to keep trying out modified versions of its plan to use the spectrum near the GPS band.  LightSquared’s operations and GPS are fundamentally incompatible and the FCC should order LightSquared out of that band.
  • Ask him/her to join with you in demanding that the FCC order LightSquared out of the spectrum band that is near the GPS band, because GPS reliability is critical for your work.

Background on the GPS issue:   on this web page


Link to article:  GPS Interference Test Results May Not Slow FCC Decision on LightSquared Deals
http://www.insidegnss.com/node/2721

 

FOR IMMEDIATE RELEASE --- August 4, 2011
CONTACT: CURT SUMNER – csumner@acsm.net

If you love your Garmin or your Tom Tom, you better learn how to read a map!
LightSquared’s “Solution” to a Problem THEY Caused Will Wipe Out GPS

 

GPS, as we know it, will end soon --- thanks to the FCC and a company called LightSquared. Earlier this year, LightSquared, a Reston, VA satellite-terrestrial broadband network company, was granted a temporary waiver by the FCC to deploy 40,000 ground stations as part of their wireless 4G broadband network ---- there is only one problem, the LightSquared 4G broadband network will wipe out nationwide GPS; and they know it!

 

Tests have shown that if LightSquared is allowed to precede with its plan, virtually all GPS units across the country, at all levels, will be rendered useless. LightSquared offered three “solutions” to the problems its plan will cause, but they all come up short. The only real solution is for LightSquared to move far away from the GPS spectrum, which is something it blatantly refuses to do.

 

GPS users have one last opportunity to save GPS as we know it. Call your Member of Congress --- or better yet, visit them in person (and bring your GPS) --- tell them you want them to take action to prevent LightSquared and the FCC from destroying GPS, and you want them to do it now. Tomorrow may be too late. If LightSquared is allowed to proceed --- YOU WILL LOSE YOUR GPS!!

 

ACT NOW AND CALL YOUR MEMBER OF CONGRESS TODAY!

ACSM Radio Hour:  Monday August 8, 2011, 11:00 AM EDT
LightSquared!    Future of GPS/GNSS!     Solar Activity!

You can’t afford to miss this important conversation with host Curt Sumner and his guest, GPS User Community Advocate Eric Gakstatter.  Join Curt and Eric on America’s Web Radio at www.americaswebradio.com to hear the latest on these three critical topics for the surveying and broader geospatial community.

 

Eric Gakstatter is the contributing editor on matters related to Survey and GPS for the GPS World e-newsletter. He has been involved in the GPS and spatial industries for more than 20 years, and recently participated in the LightSquared Panel discussion during the Survey Summit/ACSM Annual Conference.

 

Update for August 2, 2011:

Dear Coalition Member:

 

To the many of you who have filed comments with the FCC to express your concerns about LightSquared’s planned deployment, thanks very much.To those of you who have not yet had a chance to file a comment, there’s still time. While the original comment filing period is ending, during the “reply period” – which ends August 15 – the FCC is still accepting comments.

 

After that, the FCC will be deliberating about next steps for LightSquared, and we can’t stress enough how important it is that you lend your voice to push back against the devastating effects LightSquared’s plans would have on GPS.

The process of filing a comment, explained below, is straightforward and relatively quick.

 

While the below explanation suggests various points you could cover in your comment, what’s key here is that – regardless of the exact details – you make a comment.  In fact, your comment could be, literally, the same sentiments you expressed when responding to this prompt when you joined the Coalition: “Why your organization is concerned about the threat to GPS.”

 

You felt strongly enough about the threat posed by LightSquared’s plans to join the Coalition, and we hope you’ll invest just a few more minutes of your time to tell the FCC about your concerns. 

 

The deadline is August 15, but sooner is better.

 

Suggested Comment Points:

Everyone who cares about GPS should let the FCC know about the threat that LightSquared poses.  In writing to the FCC, we encourage you to cover the following points in your own words:

  • How you use GPS technology in your business and/or personal life
  • What would happen to your business/personal life if GPS became unavailable or unreliable
  • While more capacity for wireless broadband services is important, it should not come at the expense of GPS, which is critical to our country’s economy 
  • The results of the testing that were performed at the FCC’s request are conclusive – they show that GPS reception would be wiped out by LightSquared’s proposed service.
  • Now that the test results have shown interference to GPS, the FCC shouldn’t allow LightSquared to keep trying out modified versions of its plan to use the spectrum near the GPS band.  LightSquared’s operations and GPS are fundamentally incompatible and the FCC should order LightSquared out of that band.

How to File a Comment with the FCC:
The FCC has an easy-to-use portal on its website to submit feedback on the testing results:

(1)  Click on this link for the FCC’s Electronic Comments Filing System (ECFS):  http://fjallfoss.fcc.gov/ecfs/upload/begin?procName=&filedFrom=X  [In the case that URLs change, please make sure you are in the EXPRESS filings page]
(2)  In the box which says “Proceeding Number,” type:  11-109. It is VERY important to include this docket number with your comments.
(3)  In the designated boxes, enter (a) your name or your company’s name, and (b) your mailing address/city/state/zip.
(4)  In the box which says “Type in or paste your brief comments,” do so.  Click “Continue.”
(5)  A review page will load listing all of the information entered.  If correct, click “Confirm.” (6)  If you have trouble, contact the FCC ECFS Helpdesk at 202-418-0193 or e-mail it at ecfshelp@fcc.gov.
 

Link to the FCC website with the Technical Working Group on June 30 Lightsquared Report, which is in 7 parts. Comments were due by July 30, 2011:  http://fjallfoss.fcc.gov/ecfs/comment/view?id=6016826095

Update for July 1, 2011 From the Coalition to Save Our GPS

CONTACT: Prism Public Affairs
Dale Leibach: 202-207-3630 or dleibach@prismpublicaffairs.com

 

LightSquared’s “Recommendation” Document: A Review
 

On June 30, 2011, the Federal Communications Commission (FCC)-mandated Technical Working Group filed a 1,000-plus page report analyzing interference from LightSquared’s proposed deployment plans in the Mobile Satellite Service (MSS) band adjacent to the Global Positioning System (GPS).
 

The report was based on LightSquared’s February 2011, description of its planned three phases for deployment: Phase 0, Phase 1 and Phase 2.  All three phases identified by LightSquared for study used a portion of the MSS band directly adjacent to GPS, 1545.2-1555.2 MHz (the “Upper MSS band”).  The working group test results showed that use of this portion of the MSS band caused overwhelming interference to every category of the 500 million GPS receivers in use in the United States, from those used by airplanes, police vehicles and ambulances to everyday consumer cell phones and personal navigational devices. 


Up to the point of the June 30 report filing, LightSquared had for months repeatedly said that its proposed operations would not interfere with GPS. Faced with the report’s overwhelming evidence of massive interference – and no doubt in order to preempt these highly negative results -- LightSquared simultaneously released a 37 page “Recommendation” document (RD) that it developed totally outside of the Technical Working Group established to collaboratively study the problem.


In that document, LightSquared proposed an entirely new deployment scenario, not included in the initial scope of the working group analysis, which would not use the Upper MSS band at all, and a series of mitigation measures – many of which were never disclosed or discussed during the four month working group study process.  Further, the document tries to blame the “commercial GPS industry” for any interference caused by its operations, and also claims, without citation to the working group study or any other supporting data, that its proposal will solve interference for 99 percent of GPS receivers.  
 

The utter failure of LightSquared’s initial deployment plans to pass interference tests raises fundamental questions about the representations LightSquared made to the FCC prior to its January 2011 decision that convinced the FCC to grant the waiver and convene the interference study process in the first place, and raises significant questions about the credibility of LightSquared’s various claims and whether they hold up to scrutiny.
 

The current strong indication is that whatever LightSquared told the FCC prior to January 2011 was highly inaccurate, to a degree that verges on negligence. These questions logically follow from the failure of the original deployment plan: Was LightSquared transparent in its dealings with the FCC? In other words, what did LightSquared know, and when did it know it? 

 

  • In all of its documents and public statements, LightSquared claims a long history of familiarity with the technical rules of the MSS band and a wealth of technical expertise on interference issues.  LightSquared is clearly the most knowledgeable about its own network technology, and also claims to be intimately familiar with prior proceedings relating to MSS interference and GPS.  And it appears to claim that it has been working on these plans for years.  Yet, in February 2011 it proposed only deployment scenarios which used the upper MSS bands, which overwhelming technical evidence shows will cause massive interference to every GPS receiver studied.
  • This raises a variety of questions: Did LightSquared not know that its proposed upper MSS band operations would cause interference? If it didn’t know, that places its technical competence in severe doubt.  Did LightSquared know, or have very strong reason to believe, before January 2011 that massive interference would result? If so, why did it not disclose this to the FCC?
  • There certainly was ample available evidence that harmful interference would result. The US GPS Council knew, and presented testing results and analysis demonstrating this interference to the FCC in both December 2010 and January 2011.  So did major U.S. government departments and agencies, which communicated serious concerns to the FCC in a formal letter in January 2011.  LightSquared’s reaction? It dismissed these findings out of hand. 

Since LightSquared was completely wrong in formulating its initial deployment plans and claiming that they would not cause interference, why should the company’s reassuring technical claims about its “new” deployment plan be given credibility?  LightSquared’s “recommendation” document makes a host of other inaccurate or misleading statements, and a number of its major misstatements are discussed below. The bottom line is that, just as LightSquared was wrong in 2010 and the first six months of 2011, it is wrong now.  


Statement 1:  The Recommendation Document mischaracterizes the GPS industry’s position, claiming that the industry is trying to force LightSquared to buy other spectrum or go out of business:
 

“[T]he commercial GPS device industry now argues that LightSquared should not be permitted to operate its L-band terrestrial network on its authorized frequencies but, rather, should have to find or buy new frequencies. . . .This choice would doom an innovative American start-up company that has devoted more than 10 years of effort and billions of dollars in reliance on explicit regulations and authorizations permitting it to proceed as planned with a vital new wireless network.” RD p. 3
 

“LightSquared must begin to deploy its network immediately or it may not survive.”  RD p. 24
 

The Facts: The Coalition to Save Our GPS has simply said that until it can be conclusively shown that there will be no interference to critical GPS uses, LightSquared should not be allowed to deploy in the upper or lower MSS band.  Unless and until that is demonstrated, LightSquared already has other spectrum and should use it.  LightSquared’s website states that:
 

LightSquared already owns valuable high quality spectrum assets, including 59 MHz of nationwide ubiquitous spectrum in an advantageous frequency position. Viewable at: http://www.lightsquared.com/about-us/our-investor
 

The Upper and Lower MSS band together account for 20 MHz of spectrum.  This leaves 39 MHz of “high quality spectrum assets,” to which LightSquared asserts it has access, available to be used for initial deployment.  Since the RD clearly indicates that only 20 MHz of spectrum is needed for initial deployment,  (see endnote 1 below)  LightSquared already has ample spectrum to support deployment without using any of the MSS Upper or Lower band. In any case, to allow for a clear understanding of the impact of the present proceeding on its plans, LightSquared should provide a full and detailed accounting of its spectrum holdings instead of painting baseless “doom and gloom” scenarios.  
 

Statement 2:  The Recommendation Document falsely implies that this is a fight between LightSquared and the “commercial GPS industry,” and that only the “commercial GPS industry” has raised interference objections to LightSquared’s plans:
 

“[T]he commercial GPS device industry wants the Commission to shut down an unprecedented effort to establish a nationwide wireless broadband network built with private funding.” RD p. 4
 

The Facts:  The Coalition to Save Our GPS was founded initially by leading GPS manufacturers, but it has grown to include includes companies and trade associations cutting across virtually every sector of the US economy.   Its members include: the Aeronautical Repair Station Association (ARSA), AGCO, Agricultural Retailers Association (ARA), Air Transport Association (ATA), Aircraft Electronics Association (AEA), Aircraft Owners and Pilots Association (AOPA), Air Line Pilots Association, International (ALPA), American Association of State Highway and Transportation Officials (AASHTO), American Petroleum Institute (API), American Car Rental Association (ACRA), American Congress on Surveying and Mapping (ACSM), American Council of Engineering Companies/Council of Professional Surveyors (ACEC/COPS), American Rental Association (ARA), Associated Equipment Distributors (AED), Associated General Contractors of America to the Coalition, Association for Unmanned Vehicle Systems International (AUVSI), Association of American Geographers (AAG), Association of American Railroads (AAR), Association of Equipment Manufacturers (AEM), ATX Group, Avidyne Corporation, BoatU.S. - The Boat Owners Association of The United States, California Land Surveyors Association, California Space Authority (CSA), Canadian Owners and Pilots Association (COPA), Case New Holland, Caterpillar, Deere & Company, Delta Air Lines, Edison Electric Institute (EEI), Equipped to Survive Foundation, Inc. (ETSFI), Esri, Experimental Aircraft Association (EAA), Farm Equipment Manufacturers Association (FEMA), FedEx, Fire Department of New York (FDNY), Garmin, General Aviation Manufacturers Association (GAMA), GROWMARK, Inc., Hemisphere GPS, Inside GNSS, International Air Transport Association (IATA), Intelligent Transportation Society of America (ITS America), Leica Geosystems, MACHINE CONTROL Online, Magellan GPS, Mid-Atlantic Aviation Coalition-New Jersey (MAAC-NJ), National Agricultural Aviation Association (NAAA), National Association of Manufacturers (NAM), National Business Aviation Association (NBAA), National Cotton Council of America (NCCA), National Rural Electric Cooperative Association (NRECA), Networkfleet, New World Systems, North American Equipment Dealers Association (NAEDA), OmniSTAR, Orienteering USA, Payment Assurance Technology Association (PATA), PeopleNet, PocketGPSWorld.com Ltd, Regional Airline Association (RAA), Reinke Mfg. Co. Inc., TomTom, Topcon Positioning Systems, Trimble, UNAVCO, UPS, and the USA Rice Federation.


More importantly, LightSquared ignores the fact that the GPS constellation is a U.S. government-owned asset representing historical investment of over $35 billion of taxpayer money and annual investment of $1.7 billion to maintain the constellation.  The U.S. government, including practically every major federal department and agency, is the biggest single user of GPS equipment and services, and has invested many more billions of dollars in GPS-based equipment and systems, such as the NextGen aviation guidance system.


These government agencies lodged strong objections to LightSquared’s deployment plans in multiple letters to the FCC in January and March 2011.  Recently, a study was prepared on behalf of the federal government users which concluded that LightSquared’s initial deployment plans (phases 0, 1 and 2) created unacceptable interference to all classes of GPS receivers in use by the federal government, and that use of Lower MSS band only by LightSquared had not been proven to solve these interference issues. 


Statement 3:  The Recommendation Document suggests that interference is the result of design decisions made by the “commercial GPS industry” that resulted in GPS receivers that wrongfully “listen” to LightSquared’s frequencies.
“GPS devices, such as wideband precision measurement receivers, deliberately use LightSquared’s L-band frequencies. Their receivers employ wideband front-ends in order to increase precision and in order to receive satellite augmentation signals throughout the 1525-1559 MHz L-Band.  By failing to build receivers resistant to lawful transmissions in an adjacent band, GPS manufacturers have effectively appropriated LightSquared’s L-band spectrum.”  RD p. 18


“[I]t is inescapable that it is [the GPS manufacturers’] disregard for the Commission’s policies regarding the immunity of receivers to transmissions in nearby frequency bands that is the source of the technical problem.”  RD p. 2


The Facts:  Many high precision GPS are in fact intentionally designed to receive signals in the MSS band, but not because GPS manufacturers intentionally “fail[ed] to build receivers resistant to lawful transmissions” in this band.  Rather, many high precision receivers are designed this way to take advantage of services that LightSquared itself provides, as does Inmarsat – so as LightSquared knows well, but elects not to explain, LightSquared itself earns revenue by selling satellite capacity for the very same GPS augmentation services that high precision receivers are designed to receive.   LightSquared also fails to disclose that its own contracts with satellite customers reserve the right to transmit signals anywhere in the entire MSS band upon notice, so GPS receivers which use LightSquared MSS services had to be designed to receive signals in the entire MSS band.  In other words, the ”design decision” to make high precision GPS receivers that were vulnerable to interference from  high power terrestrial interference in the MSS band was imposed by LightSquared itself.  


The fact is that LightSquared’s original plans, as well as its new “recommended” plan, create massive interference to customers from which LightSquared has been happily collecting revenue for years.  And LightSquared adds insult to injury by blaming GPS manufacturers for designing high precision GPS receivers in a way that allowed their customers to pay money to LightSquared.   


The proven potential for interference to high precision GPS receivers that use MSS based augmentation services, interference which LightSquared acknowledges, also raises fundamental questions about LightSquared’s business practices: If it knew since 2001 that it was planning a service that was incompatible with GPS augmentation services, what did it do to disclose this fact to customers?  Has it disclosed this fact to customers recently based on its current plans?  Based on all reports from the affected users, the answers are “nothing” and “no.”  


The suggestion that design decisions by commercial GPS manufacturers created the interference problem through “bad” design decisions is also belied by the fact that many GPS receivers that LightSquared will interfere with are designed according to the demanding specifications of the Department of Defense or in accordance with the exacting standards applicable to national and international aviation navigation imposed by the Federal Aviation Administration, the International Civil Aviation Organization, International Telecommunication Union and other industry standards bodies. Further, integrated L-band MSS-GPS equipment has for many years been built to International Maritime Organization standards for Global Maritime Distress and Safety Systems (GMDSS). Such equipment was shown to suffer devastating interference during government tests at White Sands Missile Range.

 

Either LightSquared failed to do the most minimal due diligence on GPS receiver standards, or it has conveniently ignored them.  Either way, LightSquared’s current opinions on what is “good” GPS design are entirely self-serving and baseless. 


Statement 4:   The Recommendation Document states that the “commercial GPS industry” knew of LightSquared’s plans and acquiesced in them.


“Since 2003, the commercial GPS device industry has not only known about plans to develop a terrestrial wireless network in L-band spectrum, it actually approved those plans.”  RD, pgs. 6-7


The Facts:  This claim merely recycles a simplistic view, endlessly repeated in LightSquared sound bites, about the history of the FCC’s “ancillary terrestrial component” rules, and also glosses over the inconvenient fact that LightSquared required a waiver of the FCC’s rules, which was granted in January 2011, to proceed with its plans.   Simple repetition does not make the claim any more accurate. 


But the claim is lacking even in basic logic. If LightSquared knew beginning in 2001 that it was going to build the nationwide network it is now proposing, and was so intimately involved in FCC proceedings defining interference standards for MSS and GPS, how is it that between 2001 and the present, the “commercial GPS industry” built and sold 500 million GPS receivers that did not meet purported FCC standards, and that were incompatible with its carefully conceived plans, without LightSquared ever noticing this “fact”?  Hundreds of millions of these same receivers had been sold to the public by the time Harbinger bought LightSquared in 2010.  Did Harbinger know when it invested further “billions” in its satellite and network that there were so many non-compliant GPS receivers in the hands of customers and businesses, and elect to move forward anyway, without addressing this proactively with the FCC?  And if it didn’t know, why not?  As a sophisticated New York hedge fund with billions of dollars of investors capital at its command, it should be expected to do basic due diligence. Or was the massive detrimental effect on GPS users from LightSquared’s initial plans simply “someone else’s problem” that could be safely ignored?


In short, even if LightSquared’s account of history were true, if anyone “slept on their rights” it was LightSquared, and not the “commercial GPS industry.” The GPS industry has done what real innovators do – build great products that tens of millions of people and businesses want to buy and put to an incredible variety of cutting edge uses.  LightSquared, on the other hand, has not yet provided broadband services to a single customer. 


But the more basic truth is that LightSquared’s version of history is simply groundless.  The Coalition to save Our GPS has already debunked this revisionist history in detail.  Viewable at: http://www.saveourgps.org/studies-reports.aspx#letters


One final point deserves emphasis.  There is simply no escaping the fact that it is and was the FCC’s responsibility to identify and proactively address GPS interference issues to protect the substantial investment the federal government has in GPS.  The FCC expressly committed to do this in 2005, in a passage that bears quotation at length: 


While we agree with the GPS Industry Council, NTIA, and other government agencies that it is essential to ensure that GPS does not suffer harmful interference, it is also important to ensure that new technologies are not unnecessarily constrained. In this regard, we recognize that the President's new national policy for space-based positioning, navigation, and timing (PNT) directs the Secretary of Commerce to protect the radio frequency spectrum used by GPS and its augmentations through appropriate domestic and international spectrum management regulatory practices…  Furthermore, the President's PNT policy calls for the establishment of an inter-agency Executive Committee, on which the Chairman of the FCC will be invited to participate as a liaison, and a National Space-Based PNT Coordination Office. It is our intention to establish discussions with other agencies, through the PNT Executive Committee and Coordination Office as appropriate, to better understand what protection levels for GPS are warranted. The results of those discussions may lead to future rulemaking proposals in order to ensure that all FCC services provide adequate protection to GPS, and produce a more complete record upon which to establish final GPS protection limits for MSS ATC licensees. (see endnote 2 below)


Ironically, this is this same PNT that has objected strenuously to LightSquared’s plans after reviewing the results of government interference tests.  It does not appear that the FCC has taken steps to implement this commitment, nor has LightSquared supported the FCC by submitting complete and accurate disclosures of interference potential from its proposed operations at any point during this process.  If, for whatever reason, the FCC has failed to fulfill this responsibility to date, LightSquared should not be allowed to make the “commercial GPS industry” the scapegoat.
Statement 5: LightSquared claims that by limiting its operations to the Lower MSS band, it will eliminate interference to more than 99 percent of GPS receivers.  


[T]ransmissions in the 10 MHz band at the bottom of LightSquared downlink frequencies 3 — the band farthest away from the GPS frequencies — will not adversely affect the performance of over 99 percent of GPS receivers. Exceptions are mostly limited to those precision measurement devices used largely in agriculture, mining and construction. . .  RD p. 2


The Facts:  LightSquared has cited absolutely no data from the working group study or elsewhere to support this claim and the 99 percent figure is found nowhere in the Technical Working Group’s final report. The available data show that this claim is blatantly false. As best one can tell from LightSquared’s public statements, the claim appears to be based on the assertion that Lower band operations will not affect mass market GPS devices such as personal navigation devices or cell phones. But this is not at all what the working group data show. 


The technical working group report of the General Navigation sub-group, which studied mass market personal navigation devices, stated that “lab testing revealed that many devices suffered from harmful interference from the lower 10 MHz channel; specifically, 20 out of 29 devices experienced harmful interference.” TWG Final Report at pgs. 16, 177.  Similarly, data from the cellular sub-group report clearly shows that 6 out of the 39, or 15 percent, of cellphone GPS receivers tested failed the defined interference tests.  TWG Final Report Figure 3.2.2.   


Simply counting a percentage of affected devices also ignores the true costs and benefits of interference from LightSquared’s new plan. While precision receivers account for a relatively small percentage of GPS receivers, they account for enormous economic benefits.  A recently released economic study demonstrated that high precision receivers used in construction, agriculture and survey and mapping accounted for $10 billion in private investment in GPS equipment over the last five years, and produced $30 billion in economic benefits per year. It’s highly irresponsible for LightSquared to so lightly dismiss tens of billions of dollars of potential damage to the economy.


Statement 6: LightSquared claims that the use of inexpensive filters would prevent GPS receivers from “listening” to LightSquared’s frequencies and would solve the interference problem.


“Despite the commercial GPS device industry’s best efforts to rewrite the record and obfuscate the nature of the problem, the simple fact remains that GPS receivers do not adequately reject base station transmissions in the adjacent band.’” RD p. 17 


“[B]y failing to deploy receivers with sufficient filters, the GPS industry essentially uses LightSquared’s L-Band spectrum even though it is beyond the spectrum allocated to GPS.”   RD p.19


The Facts:  Aside from integrated MSS-GPS equipment designed to use L-band satellite communications, the idea that GPS receivers are “using” LightSquared’s spectrum is nothing more than a sound bite, with no basis in any established or generally accepted concepts of spectrum usage or radio frequency engineering. To be able to receive faint satellite signals, GPS receivers must be designed to be highly sensitive.  GPS receivers incorporate filters that reject transmissions in adjacent bands that are hundreds of millions times more powerful than the signals that are transmitted within the band they are designed to receive.


LightSquared, however, is proposing to transmit signals in the band adjacent to GPS that are billions of times more powerful than GPS satellite signals. In fact, the highest recorded power levels at the Las Vegas tests conducted in the study were a staggering 800 billion times the power of GPS signals. There has never been, nor will there ever be, a filter that can block out signals in an immediately adjacent frequency band that are so much more powerful, nor has LightSquared put forward any credible, independent expert opinion or other evidence that this is possible. 


The FCC mandated that the technical working group consider possible ways to “mitigate” interference.  As the technical working group report confirms – its sound bites about filters notwithstanding – the only device LightSquared produced for testing was an antenna with filters so extreme that they would filter out more than 95 percent of the GPS signals as well, with an extremely severe penalty to receiver performance. Other than that, LightSquared did not produce a single filter for testing, only PowerPoint presentations and conceptual vendor proposals.  Even these theoretical filters did not address the insurmountable technical problem presented by extremely high powered signals immediately adjacent to GPS. 


If LightSquared’s theoretical filters ever made it off of the drawing board, they would force GPS receivers to retreat into only a tiny portion of the legitimate GPS band and would render useless millions of GPS devices and billions of dollars of investment by government, industry and consumers.


And even real filters are not a solution for the 500 million receivers in use in the United States.  The entire population of GPS users would require a minimum of 15 years to prepare for such a change. For example, factory GPS systems installed in automobiles are typically not replaced for the 10-15 years life of the vehicle and the same can be said for aircraft, trucks, ambulances, agricultural and construction machinery to name but a few. The idea of effecting such a transition in a matter of months is absurd.


While the nation needs more wireless broadband services, there are many places in the radio spectrum already identified or allocated to 4G cellular uses, where interference to adjacent space based communications such as GPS would not occur. The satellite component of LightSquared’s network – serving rural and public safety users outside of cellular coverage – is fully compatible with the adjacent uses and is already in use. To allow a new unproven use for fewer users to diminish a long-established, highly productive spectrum use for the majority is not in the public interest and must not be allowed.

 

Endnotes:

 

   Under LightSquared’s new proposal, it will initially deploy using the 10 MHz in the lower MSS band.  The need for 20 MHz is derived from the need in wireless networks to have equal amounts of paired uplink and downlink spectrum.  The 10 MHz lower band presents 10MHz of downlink spectrum.

 

2   Flexibility for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz
Band, the L-Band, and the 1.6/2.4 GHz Bands, Memorandum Opinion and Order and Second Order on
Reconsideration, 20 FCC Rcd 4616, ¶ 70 (2005).

 

#  #  #
 

 

 

Update for June 29, 2011: 

LightSquared requested and received a last minute extension from the FCC to file a Technical Working Group (TWG) report on interference caused by its planned network.  Then, LightSquared announced its proposed solution to GPS interference.  The Coalition issued a rebuttal (http://www.saveourgps.org/pdf/Rebuttal_to_LightSquared_Solution.pdf), explaining in detail why LightSquared’s proposal is a nonstarter. The TWG report is now due July 1, 2011, but could be filed any day now.  Once the TWG report is filed, a public comment period will begin.  We will be sure to let you know when that begins.

 

Several recent developments: 

On June 9, 2011:  The National Space-Based PNT Advisory Board held a meeting to discuss results of two separate tests of LightSquared’s impact on the GPS signal. The results were devastating.  In 46 tests “all the GPS receivers” were affected by LightSquared’s signals, according to Federal Aviation Administration official Deane Bunce. Trimble’s Jim Kirkland represented the Coalition at the meeting.  Peter Marquez, vice president at Orbital Sciences Corp said “Time travel is more likely ... than mitigating this issue.”

 

On June 22, 2011, an economic study by Dr. Nam D. Pham of the Washington, D.C.-based NDP Consulting Group found that more than 3.3 million U.S. jobs in agriculture and industries rely heavily on GPS technology and the disruption of interference with GPS posed by LightSquared’s planned deployment of 40,000 ground stations threatens direct economic costs of up to $96 billion to U.S. commercial GPS users and manufacturers.  The Coalition issued a press release quoting three members:  http://www.saveourgps.org/pdf/Rebuttal_to_LightSquared_Solution.pdf

 

  • Ken Golden, director of global public relations at John Deere: “The use of GPS technology is vital to thousands of people who make their living with agricultural and construction equipment. It is simply not acceptable to allow this new network to interfere with these important industries when all indications are that there is no practical solution to mitigate this interference. In agriculture, the loss of a stable GPS system could have an impact of anywhere from $14 to $30 billion each year. That could significantly erode the strong competitive global position of U.S. farmers in the world agricultural economy. Serious impacts to the productivity of those in the construction business also will be apparent.”
  • Siamak Mirhakimi, general manager, Caterpillar Electronics & Systems Integration: “High precision GPS continues to be widely adopted technology in heavy construction and civil engineering due to the benefits of increased productivity, improved job site safety, faster completion times for projects and reduced fuel and rework costs. The test results clearly show substantial interference to high precision GPS which in turn will impact our products and customers. Allowing any company to cause interference to the GPS band would be a major step backward and significantly impact this domestic industry, which has invested billions of dollars in GPS enabled products and which employs over a million people in the U.S.”
  • Jim Kirkland, vice president and general counsel of Trimble: “This analysis highlights the massive economic benefits of GPS technology to the U.S. economy and adds a critical perspective to the current debate over LightSquared’s plans. This study also highlights how LightSquared’s recently announced ‘solution’ to the interference problem, which LightSquared admits will not reduce interference for high precision GPS uses, is no solution at all. High precision GPS uses represent nearly $ 10 billion in historical investment by GPS users over the last five years and $30 billion in annual economic benefits.

On June 23, 2011, at a hearing for the House Transportation and Infrastructure Subcommittee on Aviation and the Subcommittee on the Coast Guard and Maritime Transportation, representatives of three members of the Coalition to Save Our GPS called on Congress to put a stop to deployment of LightSquared’s planned broadband network in spectrum that threatens to disrupt GPS signals.  Top officials from the Departments of Defense and Transportation also expressed strong concerns. Coalition press release on the hearing:   http://www.saveourgps.org/pdf/Hearing_Release_06232011.pdf

 

Also on June 23, 2011, the House Appropriations Committee approved the Financial Services and General Government Appropriations bill for fiscal year 2012, which includes an amendment introduced by U.S. Rep. Steve Austria (R-Ohio) that prohibits funding for the FCC to remove conditions on or permit certain commercial broadband operations until the FCC has resolved concerns of harmful interference by these operations on GPS devices.  The amendment was adopted on a voice vote. Press releases from Rep. Austria (http://austria.house.gov/index.cfm?sectionid=44&sectiontree=23,24,44&itemid=383  and the Coalition (http://www.saveourgps.org/pdf/Appropriations_Amendment_June23.pdf)  

 

On June 23, 2011 the Transportation Construction Coalition (TCC), representing 29 national construction industry groups, sent a letter to Department of Transportation Secretary Ray LaHood requesting his “active engagement to block the Federal Communication Commission from considering this unusual waiver.”  Letter link:  http://www.saveourgps.org/pdf/TCC_GPS_Letter_%2006232011.pdf

  

Update for June 13, 2011:  article from Space News:  http://www.spacenews.com/satellite_telecom/110610-lightsquared-risk-gps.html

 

Update for June 9, 2011

FOR IMMEDIATE RELEASE: June 9, 2011    
CONTACT: Prism Public Affairs
Dale Leibach: 202-207-3630 or dleibach@prismpublicaffairs.com
Anne Tyrrell: 202-207-3632 or atyrrell@prismpublicaffairs.com    


FCC Should Focus Its Efforts on Finding a Practical Way for LightSquared to Proceed
Tests Confirm Planned Network Will Cause Substantial Interference


WASHINGTON, D.C., June 9, 2011 – Speaking today at an event sponsored by the National Space-Based PNT Advisory Board, Trimble Vice President and General Counsel and founding member of the “Coalition to Save Our GPS” sent a strong message to the Federal Communications Commission (FCC):

 

“The test data discussed today makes clear that there is substantial interference to GPS if LightSquared turns on high-powered terrestrial facilities in the spectrum next door to GPS,” Kirkland said.  “The data confirm what the industry told the FCC before it granted the waiver, and also confirms that there is no viable technical fix.  It’s time for the FCC to stop squandering resources trying to find a solution to an unfixable problem.  Instead, it should focus its efforts on finding spectrum that LightSquared can operate in –where LightSquared won’t interfere with GPS.

 

“When it comes to broadband and GPS, it’s not an either/or situation – the United States can, and should have both.  LightSquared says it has other spectrum and it should use it,” Kirkland said.

 

At issue is an unusual waiver granted to LightSquared in January by the FCC’s International Bureau allowing the dramatic expansion of terrestrial use of the mobile satellite spectrum (MSS) immediately neighboring that of the GPS - utilizing extremely high-powered ground-based transmissions that tests have shown will cause interference to hundreds of millions of GPS receivers across the United States.  

 

At the event, Kirkland and government representatives discussed testing conducted to measure interference to GPS receivers used in aviation and other critical government applications.  In at least one test, LightSquared failed to deliver test equipment that matches its proposed operations, thus causing optimistic results – and even those optimistic results showed interference. 

 

“It’s clearly a good thing that LightSquared is trying to do,” Kirkland said. “No one in the GPS industry opposes its goals of increasing wireless data capacity and competition, but the available data has shown overwhelming interference, and LightSquared should not be allowed to launch in the spectrum adjacent to GPS.”

 

A joint industry report is due to the FCC on June 15th, when the FCC will begin a public comment period before making its final decision. 

 
www.SaveOurGPS.org
# # #
 

Background:

A recent FCC action would allow a company called LightSquared to expand its use of terrestrial broadband, potentially interfering with the portion of the spectrum reserve for GPS.  We all rely on GPS and need to protect this technology.  MALSCE and ACSM are seeking your help with letters to members of Congress about this issue.

 

ACSM and MALSCE Have Joined the Save Our GPS Coalition: http://www.saveourgps.org/
The Save Our GPS website will brief you on this complicated issue that could have a major negative impact on survey grade GPS.

An article from the other side on this issue:  http://thehill.com/blogs/congress-blog/technology/160207-why-we-can-have-both-reliable-gps-and-more-broadband
There appears to be distinction between the effects, technical issues and solutions for consumer grade GPS and survey grade GPS.  MALSCE members need to understand these issue better and make sure our specific industry needs continue to be addressed. 

 

ACSM has been very active in this debate, filing a statement with FCC and participating in the Save Our GPS Coalition.

 

Below are some points to use in a letter to your US Representative (in the US House of Representatives) and both of our US Senators from Massachusetts:  Senator John Kerry and Senator Scott Brown.   Write the letter in your own words and include your contact information. You can fax the letters to Congressional Offices, or use an online form.  Please don't mail paper letters; due to security issues, mailed letters take a month or more to arrive in Congress.  

 

Contact ACSM Government Affairs Chairman John Matonich (jmatonich@rowepsc.com), ACSM Government Affairs Consultant Laurence Socci (laurence@theclagroup.com) , or Curtis Sumner (Curtis.Sumner@acsm.net)  with any questions about this issue.   Please email a copy of the text of any letter or message you send to malsce@engineers.org

 

Key links:  

 

 

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