By Randall Luthi, President, National Ocean Industries Association
To: Mr. Julius Genachowski,
Chairman, Federal Communications Commission
Ref: LightSquared, Inc.,
L-Band allocations impacting GPS FCC File No. SAT-MOD-20101 1 IS-00239
Dear Chairman Genachowski:
The National Ocean Industries Association (NOIA), which represents approximately 270 member companies involved in outer continental shelf (OCS) energy production throughout the United States, is gravely concerned over the pending allocation of Mobile Satellite Services (MSS) spectrum to LightSquared, Inc. for terrestrial high-powered transmissions. LightSquared’s proposed transmission structure will adversely impact GPS and Inmarsat signals along our coastlines, both of which are critical to marine operations. Specifically, NOIA is concerned that:
1. Coastal and near shore GPS operations will be impacted even at (promised) reduced LightSquared power levels. While NOIA understands that LightSquared will be required to reduce its tower transmission power along the coastline, their reduced power transmissions will still be many orders of magnitude greater than GPS signals, virtually guaranteeing interference for users in coastal and near-shore areas.
2. GPS receiver types used by NOIA members will be impacted substantially. NOIA members primarily use high-precision GPS receivers for their high-accuracy coastal and near shore work. High-accuracy GPS receivers require a wide-band front end, which will be seriously impacted by LightSquared transmissions.
3. Inmarsat-linked DGPS corrections will have interference. Virtually all of the high-accuracy GPS work requires the use of differential GPS corrections transmitted by Inmarsat in “L” band. These corrections will be jammed by the LightSquared signal. Implications are, for example, dredging or excavation work in areas near buried high-pressure natural gas pipelines. This work will become much more dangerous due to inaccurate, intermittent, or unreliable GPS readings.
4. Offshore oil and gas operations will be impacted because of interference on land. LightSquared interference from their 40,000 proposed transmission sites across the nation will interfere with dozens of high-accuracy DGPS reference stations used to generate differential corrections for offshore use and high-accuracy operations on shore. Because of this land-based interference with high-accuracy GPS reference stations, hundreds and possibly thousands of coastal users will be impacted. High-accuracy differential GPS corrections are used by a wide cross-section of marine users including dynamically positioned drilling rigs, pipeline construction vessels, rig supply vessels and others. Loss of GPS corrections or erroneous differential GPS corrections due to shore-based interference can cause a floating drilling rig to deviate from station resulting in catastrophic blowouts, environmental damage, and fatalities.
5. LightSquared will cause interference with Inmarsat. NOIA understands that LightSquared has paid Inmarsat, and will continue to pay Inmarsat a fee, to “endure the pain” caused by the interference. However, Inmarsat’s customers, including virtually all NOIA members, will still be required to endure the pain. Isotropic Inmarsat antennas will be impacted the most. NOIA understands that Inmarsat plans to move user frequencies at their cost. However, NOIA cannot be assured that this solution is viable given the financial drivers LightSquared is offering Inmarsat; it is not reasonable to assume that Inmarsat can compensate thousands of users for the costs of making the changes, even if the equivalent frequencies and powers are available.
6. NOIA is concerned that the FCC was premature in its decision to issue a waiver to LightSquared. Unlike the FCC’s historic test-then-approve, NOIA is concerned that the FCC has fast-tracked the effort and has improperly and unnecessarily implemented an approve-then-test procedure for this applicant. NOIA is concerned that the FCC may have directed findings of the professional staff in its decision making.
7. NOIA believes that millions of land and airborne GPS and DGPS user groups will be severely impacted by LightSquared transmissions. In conclusion, NOIA and its 270 member companies are extremely concerned that high-end GPS, DGPS, and the associated GPS reference stations will be interfered by LightSquared transmissions in the band previously protected for the very low power signals typical of satellite communications. The real-time GPS positioning needs of NOIA member companies are critical to the safety and success of their operations, and although these operations are at-sea they are totally dependent on shore-based GPS reference receivers, therefore LightSquared’s land-based operations will affect the offshore regions as well. With the marine industry’s giant assets including very specialized 2 vessels of all types completely dependent on GPS, the safety and environmental implications of GPS interference is astronomical. NOIA is concerned that other specialized Inmarsat installation members will also be disrupted.
Finally, NOIA believes that the FCC is moving too quickly and needs to step back and make its decisions based on sound science, understanding that national wireless coverage is being pursued with all deliberate speed by several knowledgeable industrial groups that have paid for the value received from their frequency allocations. It does not need this asymmetric and competition-reducing spectrum grab by a group without the years of experience and trust of those who are building the infrastructure to accomplish the very laudable outcome that is ostensibly LightSquared’s motivation.