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LightSquared Has No Boundaries?  I think otherwise.

 

LightSquared Goes Global; GLONASS, Galileo May Be at Risk, Too

June 29, 2011By: Alan Cameron 


Recent events, some of them summarized here, may appear to have dealt setbacks to LightSquared, the boundless opportunist of wireless broadband that just happens to interfere with GPS. But the company has not run out of moves yet. Would you, if you had $20 billion at stake? The latest gambit, led by lawyers and cloaked in jargon, appears to be an end-run around the U.S. government to appeal to the International Telecommunications Union, which has ultimate and international authority over spectrum. Watch out, GLONASS and Galileo — and U.S. troops operating in foreign theaters.

GPS World has received copies of three “fact sheets” authored by two lawyers and a strategic consultant. The documents are addressed to ITU-R WP 4C, the International Telecommunications Union Working Party that handles mobile satellite services (MSS) and radio determination satellite service (RDSS spectrum) and orbits. One document is titled “ Compatibility between Complimentary Ground Componenet in the 1525–1559 Mhz and 1626.5–1660.5 Mhz Bands and Other Service.” All three documents appear to be cover sheets for longer treatises, and their language and citations are not entirely clear to me, as my legal and regulatory background leaves something to be desired.

However, they announce their purpose as “to modify and refine the example methodology to calculate aeronautical mobile satellite (route) service spectrum requirements,” and “to address ongoing Integrated Mobile Satellite Service Complimentary Ground Component compatibility matters,” and finally “to update the Integrated Mobile Satellite Service Complimentary Ground Component technical characteristics based upon the most recent information regarding CGC deployment plans in this frequency band.”

One source familiar with the documents, who did not wish to be named, commented that “One should interpret what LightSquared is doing with ITU as a bellwether indication of intent to use the whole band at the full authorized power, no matter how they spin ‘protect GPS’ in their press releases. 



“At first blush, the filings look innocuous; let me assure you, they are not. This is the first salvo. Watch what they do, much more than what they say.



“These are fact sheets intended to inform the U.S. government that LightSquared intends to develop papers with the intent to get the U.S. government to approve the papers to be sent to the ITU WP-4C, the Working Party that handles MSS and RDSS spectrum & orbits. The ultimate goal is to work internationally to allow LightSquared to allow ancillary terrestrial component (ATC) broadcast globally.”

The three so-called fact sheets are appended here.

In other developments, going now in reverse chronological order, from most recent to early June:

Congressional Activity

On June 23, the U.S. House of RepresentativesAppropriations Committee approved the fiscal year 2012 Financial Services and General Government Appropriations bill. One amendment to the bill prohibits funding for the Federal Communications Commission (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. More details here.

Previously, on May 27, the U.S. House of Representatives passed a bill stating that the FCC shall not provide final authorization for LightSquared operations until Defense Department concerns about GPS interference have been resolved. The bill then went to the U.S. Senate for its action.

The House actions and a letter to the FCC signed by 32 U.S. senators may presage a showdown over the issue between Congress and the president, who has promised increased broadband access. A 4G wireless network providing this access could be facilitated by LightSquared sales of service via its tower transmitters to wireless carriers. LightSquared has already signed a $20 billion, 15-year deal with Sprint.

Money Talks

A report on “The Economic Benefits of Commercial GPS Use in the United States and the Costs of Potential Disruption” was presented by during a June 21 webinar sponsored by the Coalition to Save Our GPS.  The report estimates that “the direct economic benefits of GPS technology on commercial GPS users are . . .  over $67.6 billion per year in the United States,” but also that ““the direct economic costs of full GPS disruption to commercial GPS users and GPS manufacturers are estimated to be $96 billion per year in the United States.”

Final Report Withheld

At the last minute of a June 15 deadline for the final Working Group report on interference, LightSquared asked for a two-week extension. Federal regulators granted the request, and the final report is now due on July 1.

A spokesperson for the Coalition to Save Our GPS revealed that “The Working Group results show devastating interference to GPS and no proven method of mitigation. Delay will not change these results. These results are the same results the FCC had had before it granted the waiver.”

Some Solution. Three days after requesting the delay, LightSquared announced it had solved the problem, by proposing to broadcast only from the lower end of its permitted spectrum band. GPS experts countered that this would still disable the functioning of high-precision receivers.

“This comes out of the blue, without the knowledge, agreement or consensus of the industry group studying the problem,” riposted the Coalition to Save Our GPS. “That may well be because virtually nothing has actually changed in this “new” proposal relative to what LIghtSquared pledged at the outset of testing. The power levels don’t change. Nor do the frequencies. In fact, the only thing that has changed is the order in which the channels within the band adjacent to GPS would be deployed.

“LightSquared’s announced “solution” has two components:

“1. LightSquared acknowledges that “[e]arly test results indicated that one of LightSquared’s 10MHz blocks of frequencies poses interference to many GPS receivers.” LightSquared states that for “the next several years” it would not operate in this band – which is directly adjacent to GPS spectrum and is referred to as the “upper MSS band.” During this period, LightSquared would commence operations in a second 10 MHz block of the MSS band , referred to as the “lower MSS band,” slightly further away from GPS. 

“2. According to the proposal ‘LightSquared will modify its FCC license to reduce the maximum authorized power of its base-station transmitters by over 50 percent. This action will limit LightSquared to the power it was authorized to use in 2005.’ 

“This so-called solution is not a solution in any shape, form or fashion,” continues the Coalition. “This is not a move to an alternative frequency band. Nor is it a reduction in power relative to what has been tested from the beginning. The “solution” would cause massive disruption to many critical U.S. economic sectors, initially including public sector users of high precision GPS, later followed – after “the next several years” — by other GPS users. The only real solution to the LightSquared interference problem is to move out of the MSS band altogether."

Click here for the full document, “New ‘Solution’ Is a Non-Starter.”

Air Transport Opposes Waiver

The Air Transport Association and the Aircraft Owners & Pilots Association told Congress that the only acceptable mitigation is for LightSquared’s operations to be moved outside of the L-band and away from GPS. “With so much of the early evidence showing that LightSquared’s proposed network would potentially endanger nearly every flight operating in U.S. airspace, it seems evident that no further development of this system can be allowed.”

Military Report Calls for FCC Retreat

The National PNT Engineering Forum concluded after testing classified and GPS receivers under LightSquared terrestrial transmission conditions: “Significant concerns remain that operation of an ATC integrated service as originally envisioned by the FCC cannot successfully coexist with GPS.”

The NPEF report calls for rescinding the FCC waiver for LightSquared terrestrial transmissions, conducting more thorough studies on impacts, and revisiting the 2003–2010 authorizations. The group tested a variety of military receivers under classified categorization, also known as “government receivers.”

Rebuttals Distort Record

Claims by LightSquared’s Carlisle and FCC chair Julius Genachowski, that the GPS industry knew long ago about LightSquared’s plan for powerful terrestrial transmitters, contradict the truth. Examination of FCC filings show that the GPS industry knew about and agreed to a plan by a previous ownership of the company, for a different purpose, with a different business concept, and employing a completely different technological approach, one that would not have harmed GPS transmissions and disabled GPS users the way the current LightSquared plan does.

The terrestrial broadband operations first unveiled in November 2010 cannot be described as ancillary to the purpose for which Lightsquared predecessors Motient, MSV, and SkyTerra received their spectrum and licenses — that is, to provide a service that was primarily a mobile satellite service. The November letter to the FCC described a new business model that turns the original concept on its head. LightSquared for the first time revealed plans to build a “nationwide network of 40,000 terrestrial base stations,” and stated that “the capacity of its fully deployed terrestrial network across all base stations will be tens of thousands of times the capacity of either of [its] satellites.”

The deviations from established policy required to accommodate LightSquared’s new business model are not technicalities. They represent a fundamental change to a complex and interrelated set of rules that were carefully designed to protect GPS users from interference.

The predecessor companies had to protect their own primary satellite operations from interference. The protection that their own satellite operations required was also sufficient — at that time — to protect GPS receivers. The terrestrial network and powerful signal LightSquared now proposes bear no resemblance to the operations the FCC authorized in 2003.

For further commentary in this vein, see LightSquared, FCC Rebuttals Distort Record.

PNT Advisory Board: Move ATC

At its June 9–10 meeting, the National Space-Based Positioning, Navigation and Timing (PNT) Advisory Board found that GPS services cannot be assured if the LightSquared plan is approved, and that the only viable option for continued availability of GPS as well as new wireless broadband is to find another spectrum for LightSquared not adjacent to the GPS frequency.

The formal recommendation reads: “The provision of GPS services cannot be assured if the LightSquared proposal for satellite and terrestrial broadband provision using the MSS L-Band receives final approval.

“The only reasonable and viable option to continue ubiquitous availability of GPS and the provision of a new 4G wireless broadband capability would be for the FCC to assign an alternate frequency spectrum to LightSquared that has little or no probability of affecting the delivery or utilization of GPS/GNSS services.”

During its meeting, the Advisory Board heard directly from one representative of LightSquared, the company's executive vice president, regulatory affairs and public policy, Jeff Carlisle, and from Jim Kirkland, vice president and general counsel, Trimble Navigation, speaking on behalf of the Save Our GPS Coalition.  
"Without knowing otherwise," commented one observer, "one might have thought they were talking about two different sets of FCC actions. Their interpretations of FCC actions were completely orthogonal to each other."

During the discussion, one Advisory Board member, a former governor of the state of Wyoming, told presenter Jeff Carlisle of LightSquared, “Your definition of mitigation seems more tied to a legal argument than a common-sense argument.”


Other speakers on the LightSquared/GPS panel included Dean Bunce, co-chair of the National PNT Engineering Forum (NPEF), which has had responsibility for testing various classified GPS receivers under LightSquared conditions; and Robert Frazier of the Federal Aviation Administration (FAA) Spectrum Planning and International Office. 


Most of the presentations from the meeting are now posted online.

Another observer at the Advisory Board meeting opined of the LightSquared presentation and subsequent replies to questions from board members, “I’ve seen weasels before, but not like this. Misinformation, mis-statements, reversals and take-backs, outright lies.”

Tests Slam Hi-Precision Receivers

Data from Las Vegas field tests show that wide-bandwidth, high-precision GPS receivers started feeling the effects of the LightSquared transmission about 1,800 meters from the tower. Medium-bandwidth high-precision GPS receivers started feeling the effects of the LightSquared transmission at about 1,200 meters from the tower. In each case, there was about a 200-meter buffer from when the GPS receivers started to feel the effects of the LightSquared transmission to the GPS receiver being jammed, at 1,600 meters and 1,000 meters respectively. For further details, seethis article.

GPS World has received further details of the tests but not an authorization to publish them yet.

Deere & Company, a major provider of precision agriculture equipment and services, notified the FCC on May 26 of substantial interference with its GPS receivers by the LightSquared signal. Deere receivers registered impact of and interference by the LightSquared signal as far away as 22 miles from a transmitter. Further, the company has found no practicable technical solution to the problem.

-From GPSWORLD.COM

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