At stake is the high-precision GPS industry as we know it. If LightSquared’s current proposal is approved by the FCC, it will render tens of thousands, and possibly hundreds of thousands of GPS receivers obsolete starting as early as next year. The FCC is accepting public comments until July 30 and replies to those comments until August 15. After the public comment period is closed, the FCC can render a decision at any time. Last weekend, I spoke alongside LightSquared and the Coalition to Save Our GPS in a two-hour panel discussion at the Esri Survey Summit in San Diego. Here’s my report.
Last weekend, I attended the Esri Survey Summit in San Diego. This year was different in that it was combined with the ACSM (American Congress on Surveying and Mapping) annual conference. Part of the conference Plenary on Saturday were 30-minute presentations by LightSquared and the Coalition to Save Our GPS. The following morning (Sunday), there was a two-hour discussion panel on the LightSquared/GPS interference issue, in which I participated.
At stake is the high-precision GPS industry as we know it. If LightSquared’s current proposal is approved by the FCC, it will render tens of thousands, and possibly hundreds of thousands of GPS receivers obsolete starting as early as next year. The FCC is accepting public comments until July 30 (see also instructions at the bottom of this column) and replies to those comments until August 15, 2011. After the public comment period is closed, the FCC can render a decision at any time.
The FCC is clearly biased on the LightSquared/GPS issue favoring LightSquared. There’s a lot of pressure to push the U.S. National Broadband Plan, which includes improving Americans’ accessibility to high-speed wireless connectivity to the Internet. After only 2 ½ weeks on the job, FCC Wireless Telecommunications Bureau Chief Rick Kaplan stated earlier this month that “We need to make sure we aren’t locking out valuable spectrum because of inefficient transmission,” obviously referring to the LightSquared/GPS interference issue.
The LightSquared propaganda machine has been effective in bending the ear of technically-challenged policymakers into believing GPS receivers are using LightSquared’s spectrum without permission, and that GPS receiver designers have known this issue was coming since as early as 1995. Both statements, of course, are not true as I’ve written before, as has GPS World editor Alan Cameron (see LightSquared, FCC Rebuttals Distort Record), and as published on the Coalition to Save Our GPS website.
Last weekend’s Survey Summit was perhaps the best opportunity to date for land surveyors and other high-precision GPS users to speak out and let LightSquared and our policymakers know how crucial high-precision GPS/GNSS receivers are to their operations. The discussion content was very good and our industry clearly made its points, but it was all for naught.
Esri got LightSquared Executive Vice President Jeffrey Carlisle to fly in from Washington D.C. to speak at the plenary and then participate in the discussion panel along with myself, moderator John Matonich (NSPS), Dr. Javad Ashjaee (JAVAD GNSS), Dr. Joe Paiva (consultant), Curt Sumner (ACSM), and Peter Large (Coalition to Save Our GPS). However, it was a lost opportunity. Only fifty or so people attended the discussion panel, and I’m sure Mr. Carlisle flew back to Washington D.C. to report that the high-precision GPS users just rolled over, and they are not nearly the roadblock that might have been anticipated.
LightSquared: 1, High-Precision GPS Users: 0
A few key points from the discussion panel I think are worth noting:
It’s a joke, but LightSquared is probably going to win the argument that the “GPS industry knew this was coming.” It is going to win not because it is correct, but because Jeff Carlisle was an FCC employee for several years and knows which buttons to push at the FCC, where to find documents that are publicly available — but not reasonably accessible to the general public, in my opinion — and how to misrepresent them.
Who is the “GPS industry” that LightSquared and the FCC refer to?
When LightSquared and the FCC refer to the “GPS industry,” they certainly are not referring to the GPS user community (you and I), which is expected to bear a huge financial burden (you and I will need to buy new GPS equipment) if the LightSquared proposal is approved.
In nearly all of its documents, LightSquared refers to discussions and agreements with the U.S. GPS Industry Council (USGIC). I have a problem with this, and so should you. The USGIC is a sort of chamber of commerce for GPS manufacturers. If you perform a Google search for the U.S. GPS Industry Council, you won’t find a website, you won’t find a listing of council members, nor will you find much other information about it.
The USGIC, in other words, does not maintain a high public profile. To be fair, it is an industry council, not a user council.
To be further fair, the Industry Council did negotiate an agreement several years ago with a former version of LightSquared (under different ownership then) and with the FCC, along certain business terms and technical parameters. That agreement did not harm GPS users in any way; in fact, it contained some inherent protections for GPS users. The current version of LightSquared has completely changed both its business plan and those technical parameters — turned them on their heads, as a matter of fact — but blithely continues to claim that this was all worked out and agreed to previously.
Nevertheless, how has it come about that the USGIC was the negotiator with LightSquared and its predecessors for you and I regarding your GPS equipment when you’ve never met a USGIC representative, and never had a chance to provide comments before negotiations with LightSquared and its predecessors on such a critical issue?
When I made a statement about this during our discussion panel, Jeff Carlisle called me a “fear-monger,” if I recall correctly, and he referred to my assertion that the USGIC is a chamber of commerce as “ridiculous.” I think he needs a little education.
The analogy I used was that when Walmart wants to build a store in your town, it does not negotiate with the Chamber of Commerce, because the Chamber of Commerce does not represent the citizens. Walmart negotiates with the City Planning Department and City Planning Commission, which is comprised of citizens of the community, who are directly impacted and must bear the consequence of the development.
The reason LightSquared is in this controversial and expensive predicament today is because it chose the incorrect organization to negotiate with. Perhaps on purpose, so it could maintain later that it had negotiated with someone.
This is not virgin territory. There is a clear precedent on this subject. Do you remember back in 2008 when the U.S. Air Force (GPS stewards) wanted to discontinue supporting the semicodeless technique that is used by virtually every civilian dual frequency GPS receiver in existence? It was the first time in GPS history that an action would render several hundred thousand high-precision GPS receivers obsolete, a scale which is very similar to the effect that the LightSquared system would have on high-precision GPS receivers today.
Do you recall an industry coalition being formed to fight it? Do you recall an industry outcry? Do you recall a technical working group being formed to test the effects on receivers if semicodeless was not supported?
The answer is no.
Why is that
The answer is very simple. The U.S. Air Force, to its credit, did a fantastic job of communicating with the GPS user community along with the Department of Commerce. It issued public statements describing the impact the action would have on GPS receivers. It held a public comment period. The following statement from its website succinctly summarizes its approach:
“The Office of Space Commercialization worked hard to raise awareness of the size and significance of the high-end GPS user community, which was poorly understood within the government. The Office collected industry information to quantify the installed base of codeless/semi-codeless GPS equipment, estimate its economic value, and determine an acceptable time frame for its replacement. The Office also issued a request for public comments to receive broad stakeholder feedback.”
In other words, it did its homework. At the end of the day, the U.S. Air Force set a date of December 31, 2020 to discontinue supporting the semicodeless technique. It correctly determined that 12 years is about the correct amount of time that would allow a smooth transition with a manageable financial impact to the GPS user community. Users would naturally upgrade their equipment during that period.
Imagine if the U.S. Air Force had set a period of one year to transition away from using the semicodeless technique. That action would have destroyed the high-precision GPS user community, and the continued adoption of high-precision GPS technology would have been set back for years. Fortunately, it did its homework.
LightSquared, on the other hand, either didn’t do its homework or intentionally kept quiet in order to fly under the radar and push its initiative through before the GPS user community (and others) knew what was happening.
During the discussion panel, I wanted to (and I think I did) make three points very clear:
- The high-precision GPS user community did not know this was coming, period.
- There was a precedent already set that clearly illustrated how to successfully communicate to the high-precision GPS user community when an action is proposed that would effectively render hundreds of thousands of high-precision GPS receivers obsolete.
- The high-precision GPS user community should not bear any cost related to LightSquared implementing its system.
That said, I’m not saying “no” to LightSquared.
I get the 4G wireless broadband argument that LightSquared and the U.S. National Broadband Plan make. I want high-speed internet on my smartphone too. I want my phone to work in elevators and elevator-like environments that LightSquared promises. I think this might be a boost to the economy.
While I’m not saying “no” to LightSquared, I’m saying “no” to LightSquared’s proposal at this moment. There are still waaaaay too many unknown issues to be understood and resolved.
A few of them are:
- Even using the lower frequency spectrum in its new proposal (1526-1536MHz), at least tens (maybe hundreds) of thousands of your high-precision receivers will need to be replaced. Who will bear that cost?
- More testing is needed to understand exactly what the effect of using only the lower frequency spectrum will have on all types of GPS receivers. That was not LightSquared’s original roll-out plan and therefore wasn’t tested extensively to determine its affect on GPS receivers.
- The idea of using the upper frequency (1545-1555MHz) for high-powered terrestrial broadcast needs to be permanently abandoned.
- The effect on GLONASS L1, Galileo L1, Compass L1, and GPS L1C need to be extensively tested to understand the effect on GNSS receivers of today and of the future. Galileo L1, Compass L1 and GPS L1C all use wider bandwidth than today’s GPS L1 C/A, which makes them even more susceptible to interference from LightSquared’s system.
- A serious effort needs to be made to understand the effect of LightSquared’s mobile devices on GPS/GNSS receivers. LightSquared’s mobile devices will operate in the 1626.5-1660.5MHz frequency spectrum, above the GPS L1 spectrum and GLONASS L1 (~1597-1605MHz). It’s been reported that Inmarsat devices (using LightSquared’s 1626.5-1660.5MHz mobile device spectrum) do not fare well around Iridium phones (1616-1626.5MHz), which is very close to GLONASS L1.
We have to be very careful and test these scenarios because once the plug is pulled, you can’t suck the water back out of the drain. There’s no turning back. Also, the FCC doesn’t have a solid history of making good decisions in the wireless arena. In the words of noted wireless industry guru Andrew Seybold (BlackBerry, HP, AT&T, Motorola):
“The history of wireless is littered with examples where the FCC acted on a request by a vendor, approved the deployment of a system, and later learned that the new system created interference to other services.”
In fact, Mr. Seybold writes that LightSquared shouldn’t be permitted to move forward at all. On July 6, 2011, he published the following:
“Okay, I admit it. I don’t believe LightSquared should be permitted to use what was supposed to be satellite spectrum for a terrestrial broadband network. Not only that, I don’t believe LightSquared has a sound business plan. Building more than 40,000 cell sites, maintaining them, and reselling the bandwidth to others who want to sell it to its customers, does not pencil out in my book. The margins will be too slim, especially given the fact that prices for both voice and broadband services keep falling in the United States so margins will continue to be squeezed. But apart from a faulty business plan, the main reason I am opposed to LightSquared’s plan to build this network is that if there is the slightest chance it will interfere with GPS receivers, it simply should not be permitted to be built.”
To file comments with the FCC: Comments may be filed electronically using the Internet by accessing the ECFS: http://fjallfoss.fcc.gov/ecfs2/. Filers should follow the instructions provided on the website for submitting comments. In completing the transmittal screen, ECFS filers should include their full name, U.S. Postal Service mailing address, and IB Docket No. 11-109.