LightSquared: The Ball is in the FCC’s Court

August 18, 2011  - By 0 Comments

The FCC’s public comment period regarding the LightSquared/GPS interference issue has ended and the reply comment period is over as well. To date, more than 3,300 comments (not including the 15,000+ that were submitted by the Boat Owners Association of the United States) were entered that the FCC must sift through and arrive at some sort of conclusion. Following are my last comments filed with the FCC as well as my best guess at where this is heading.

I decided to file a “reply comment” submission on August 15 to the FCC based on an August 11 filing by LightSquared where LightSquared Executive Vice President Jeffrey Carlisle stated “had the GPS industry complied with the DoD’s recommended filtering standards for GPS receivers, there would be no issue with LightSquared’s operations in the lower portion of its downlink band.” It’s a blatantly false statement, so I couldn’t let it pass without a rebuttal. Following is what I submitted to the FCC:

 


August 15, 2011

Eric Gakstatter
Editor – GPS World magazine Survey Scene enewsletter
Editor – Geospatial Solutions
High-precision GPS Consultant
PO Box 663
West Linn, OR 97068
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street SW
Washington, DC  20554
Re: IB Docket No. 11-109

 

Dear Ms. Dortch,

In addition to my comments posted on July 28, 2011, I’d like to reply to comments submitted by LightSquared in their letter dated August 11, 2011.

Again, by way of background, as a Contributing Editor to GPS World magazine, my specialty is high-precision GPS receivers of which I’ve been involved with for more than 20 years as a product developer, power user and consultant. I’m in touch with tens of thousands of high-precision GPS users from around the world through my newsletter articles (bi-weekly), webinars and my attendance at technical conferences. I consider myself and I’m considered by others to be an advocate for the high-precision GPS community.

In Jeffrey Carlisle’s (LightSquared Executive Vice President) comments to the FCC dated August 11, 2011, he stated that “had the GPS industry complied with the DoD’s recommended filtering standards for GPS receivers, there would be no issue with LightSquared’s operations in the lower portion of its downlink band.”

This is a false statement, and to make matters worse, he knows it’s a false statement. Here’s why…

LightSquared sells high-precision satellite data communications services to the GPS industry. Before LightSquared was formed in 2010, its predecessors (Skyterra, MSV) sold the same services to the GPS industry for many, many years.  In the course of business over many, many years, LightSquared and its predecessors have encouraged GPS receiver manufacturers to design receivers that look into the MSS band (1525-1559MHz) in order to access LightSquared’s satellite data communication services. This service has generated tens of millions of dollars in revenue for LightSquared and its predecessors over many years and continues to be a revenue source for LightSquared today.

If LightSquared chooses to stop supplying satellite data communications services to the GPS industry, that’s their choice, but they should not fabricate a statement claiming that only the reason for interference in the “lower portion of its downlink band” is due to filtering technology. It’s just not true. Tens of thousands, if not hundreds of thousands, of expensive high-precision GPS receivers were specifically designed to access LightSquared’s and Inmarsat’s satellite data communications services that they sell to the GPS industry.

LightSquared may state they will continue to offer these services to the GPS industry in the upper portion of its downlink band (1545-1559MHz) to create separation from the lower portion of the downlink band (1526-1536MHz). It’s too late for that. Billions of dollars of expensive, high-precision GPS receivers are already in the market that were designed to look in the entire MSS L-band (1525-1559MHz) for services provided by LightSquared and Inmarsat. Had the GPS user community been given sufficient notice, tens of thousands of high-precision GPS equipment owners could have planned for transitioning their GPS receivers over many years with a manageable financial impact. Unfortunately, that’s not the case. The GPS user community was blindsided by LightSquared’s application in November 2010 and the FCC’s waiver granted to LightSquared in January 2011.

LightSquared and the FCC failed to adequately notify the GPS user community of their intentions. As I’ve submitted before, the precedent has already been set on how to effectively notify the GPS user community about an action that would render several hundred thousand high-precision GPS receivers obsolete. In 2008, the U.S. Air Force proposed to discontinue supporting the semicodeless technique that is used by virtually every civilian L1/L2 high-precision GPS receiver in existence. It was the first time in history that an action would render several hundred thousand high-precision GPS receivers obsolete, a scale which is very similar to the impact of the LightSquared system.

There was no industry coalition formed to engage the Air Force. There was no industry outcry. A public/private technical working group was not formed to test the effects on receivers if semicodeless was not supported. Why is that?

The answer is very simple. The U.S. Air Force, to its credit, did a fantastic job of communicating directly with the GPS user community along with the Department of Commerce. It issued public statements describing the impact the action would have on high-precision GPS receivers.

The U.S. Air Force did its homework. At the end of the day, it set a sunset date of December 31, 2020 to discontinue supporting the semicodeless technique. It correctly determined that 12 years is about the amount of time that would allow a smooth transition with a manageable financial impact to the high-precision GPS user community.

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 resulting in billions of dollars in losses and widespread small business closure. Fortunately, they did their homework, understood the impact, and made the correct decision.

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. In either case, the GPS user community shouldn’t be held accountable in paying for the FCC’s and LightSquared’s lack of communication/notification.

LightSquared and the FCC incorrectly assumed that communicating/negotiating with the U.S. GPS Industry Council (USGIC) was the equivalent of communicating/negotiating with the GPS user community. That is a false assumption. The USGIC does not communicate directly with the GPS user community and never has. That’s not their role. I’ve been perso
nally involved in the high-precision GPS industry for 20+ years and writing a monthly newsletter on high-precision GPS technology for GPS World magazine for more than five years. I attend almost every major GPS conference and high-precision GPS market segment conference in the U.S. and some abroad. The first I’d heard about the LightSquared interference issue was November 2010.

Even if LightSquared only uses the lower portion of the downlink band (1526-1536MHz) as they’ve proposed, the number of high-precision receivers affected would be at least 200,000 at an estimated replacement cost of $10,000 per unit which equates to a total equipment replacement cost of $2 billion dollars. That does not include the cost of removal/installation, lost productivity, required software upgrades, and training. Do LightSquared and the FCC expect the GPS user community to bear that cost? Hopefully, you can see by the overwhelming number of public comments from small businesses and local government agencies, such an action would be devastating to the U.S. economy.

Lastly, please do not forget about the potential devastating impact of LightSquared mobile devices (uplink band 1626.5-1660.5MHz) on GPS and GNSS receivers. I’m afraid this is being lost in all the discussion about the downlink band.  The uplink band could have a worse affect on GPS and GNSS receivers than the downlink band.

LightSquared mobile devices are potentially portable GPS/GNSS jammers. The FCC needs to seriously investigate the interference impact of LightSquared mobile devices (1626.5-1660.5Mhz) on GPS receivers. It is already known that Inmarsat (1626.5-1660.5MHz) devices and Iridium (1616-1626.5MHz) devices interfere with each other, but Iridium devices are only used in remote areas so it’s not a widespread problem. It is also known that these devices interfere with the GLONASS L1 signal (1597-1605MHz). We don’t know the extent of the effect that LightSquared mobile devices will have on GLONASS L1, GPS L1, Galileo L1, or Compass L1 signals. The problem is that no LightSquared mobile devices are available to test. Yes, lab simulations can be performed, but LightSquared devices will be made in Asia, among other places, where the designers won’t care one bit about GPS/GLONASS interference. There is not an acceptable design margin, if any, to allow for sloppy LightSquared device designs.

Thank you for your attention. If you feel that further testimony is needed, I’m more than happy to oblige.

Sincerely,

/S/ Eric Gakstatter

Eric Gakstatter
Principal – Discovery Management Group LLC
Editor – GPS World Magazine Survey Scene enewsletter
Editor – Geospatial Solutions
PO Box 663
West Linn, OR 97068

I think that three things are batting against LightSquared at this point:

1. As much as they say they gave fair warning, LightSquared and the FCC didn’t communicate with the GPS user community at all on this issue. The U.S. GPS Industry Council (USGIC) doesn’t count. They don’t represent the GPS user community nor communicate with the GPS user community at all. So, the GPS user community was blindsided by this in Nov 2010.

This was either intentional or sloppy, but it doesn’t matter either way. The bottom line is that you can’t give nine months notice on obsoleting 200,000+ very expensive GPS receivers that are installed and used in critical infrastructure applications. It would take many years to transition to new equipment. The U.S. Air Force and Dept of Commerce have already been through this drill already and they determined that 12 years was about the right timeframe needed to transition high-precision civilian GPS equipment to new technology. If LightSquared and the FCC really understood this market, they would know it’s not a four-year exercise.

2. Even with LightSquared using only the lower spectrum (1526-1536Mhz), it still interferes with $2+ billion dollars worth of high-precision GPS receivers. Who’s going to pay that bill? The GPS user community that was given no advanced notice?

They can argue all they want about who’s fault it is, new filter technology, DoD standards, etc., but at the end of the day, obsoleting 200,000+ expensive high-precision GPS receivers valued at  $2+ billion dollars would be devastating to American small businesses and Fed/State/Local gov’t.

3. LightSquared sells high-precision satellite data communications services to the high-precision GPS industry. Before LightSquared was formed in 2010, its predecessors (Skyterra, MSV) sold the same services to the GPS industry for many, many years. In the course of business over many, many years, LightSquared and its predecessors have encouraged GPS receiver manufacturers to design receivers that look into the MSS band (1525-1559MHz) in order to access LightSquareds satellite data communication services. This service has generated tens of millions of dollars in revenue for LightSquared and its predecessors over many years and continues to be a revenue source for LightSquared today.

If LightSquared chooses to stop supplying satellite data communications services to the GPS industry, thats their choice, but they should not fabricate a statement claiming that only the reason for interference in the lower portion of its downlink band is due to filtering technology. Its just not true. Tens of thousands, if not hundreds of thousands, of expensive high-precision GPS receivers were specifically designed to access LightSquareds and Inmarsats satellite data communications services that they sell to the GPS industry.

LightSquared may state they will continue to offer these services to the GPS industry in the upper portion of its downlink band (1545-1559MHz) to create separation from the lower portion of the downlink band (1526-1536MHz). Its too late for that. Billions of dollars of expensive, high-precision GPS receivers are already in the market that were designed to look in the entire MSS L-band (1525-1559MHz) for services provided by LightSquared and Inmarsat. Had the GPS user community been given sufficient notice, tens of thousands of high-precision GPS equipment owners could have planned for transitioning their GPS receivers over many years with a manageable financial impact. Unfortunately, thats not the case. The GPS user community was blindsided by LightSquareds application in November 2010 and the FCCs waiver granted to LightSquared in January 2011.

Of course, I didn’t mention aviation, maritime, military and other safety-of-life applications of GPS. That’s a whole other story…

Does that mean the FCC is going to tell LightSquared to go home?

Maybe, but I doubt it.

In a letter dated August 10, 2011, the FCC Office of Engineering and Technology Chief Julius Knapp requested more data from LightSquared and the U.S. GPS Industry Council (USGIC). Following is an important excerpt from the letter:

“It is unclear to what extent the GPS receivers and devices tested are current production models, into what market  segments those receivers and devices are most commonly sold, what fraction of a given market segment those devices represent, and their design lifetimes and typical owner-use lifetimes.This information is important in assessing the likely impact, if any, of interference on various use cases over time. We therefore request production and U.S. sales information for each of the devices tested, including (1) the dates of production, (2) the market segment(s) to which the device is targeted or sold,  (3) total annual sales volume and annual sales volume by market segment or estimates thereof, (4) the date on which full support of the device by th
e manufacturer ceased (or will cease), (5) estimated time period after which the device owner would likely replace or discontinue use of the device”.

 

The letter also requests updated information from LightSquared based on their proposal to use only the lower spectrum (1526-1536MHz). The timeframe to provide the requested information is very aggressive, with all information to be supplied on or before August 22, 2011.

I think this is good news in general. It is the FCC’s first solid attempt to understand the GPS receiver markets in which the proposed LightSquared system will cause interference problems, including high-precision.

The bad news is that the FCC is only requesting market information on GPS receivers that were tested. If you recall in one of my earlier articles, I listed the GPS receivers being tested by the high-precision team. Obviously, if the FCC only used market data from these GPS receivers, the numbers will be underestimated by a large double-digit value and maybe orders of magnitude because many receiver models weren’t included in the test. Also, many CORS in operation are legacy GPS receivers that are out of production. Based on their questions, I have a feeling the FCC will discount those to little or no value, when they actually still provide economic benefit. However, the CORS owner can’t or aren’t in a position to replace them, resulting in a net loss.

No matter which way this goes, I’m pretty confident the FCC is going to use this opportunity to rattle the GPS industry’s cage. Spectrum is a finite resource and the FCC is going to look at ways to allocate spectrum as efficiently as possible, as they should. Is the MSS L-band (1525-1559MHz) being used in the most efficient manner? Probably not. I bet the FCC orders changes in that area, or at least the FCC sets the wheels in motion towards change. I’m ok with that as long as it doesn’t come at the unreasonable expense of the GPS user community, be it high-precision, aviation, military, etc.

All of this bruha is really about timing. Given enough time, GPS receiver manufacturers and component manufacturers have a chance to develop new technologies that use the MSS spectrum more efficiently, if at all. Actually, if the FCC pushes forward like they seem to want, it really isn’t MSS (Mobile Satellite Service) spectrum any longer, it would become a Mobile Terrestrial Service. But developing new technologies, designing/testing products and then allowing the GPS user community enough time to adopt the new technology with a reasonable financial impact takes years, a lot of years, not four or five. It takes more years than what LightSquared has to give no matter which part of the MSS spectrum (low or high) one is discussing.

I think in the short-term the FCC is going to order more testing in order to understand the impact on GPS receivers of LightSquared using only the lower end of the MSS spectrum (1526-1536MHz). We already know it’s going to hammer most high-precision GPS receivers valued collectively at $2+ billion dollars. I don’t have a good grip on how it will affect aviation, military and other receivers in critical apps. We’ll see.

Actually, I agree with what Jeff Kagan of E-commerce Times writes. LightSquared is playing the public relations game the wrong way and they’re getting their nose punched every time they turn around. They should be spending their energy on talking about how wireless communications will be enhanced by their service instead of scraping up obscure DoD specifications they claim that commercial GPS receivers are supposed to adhere to. I still don’t understand what they bring to the table that Sprint, Verizon, AT&T, etc. don’t. Yes, I get that they are a wholesaler and can bring 4G LTE to small service providers. I’m talking about technology. What technology do they bring to the table? If they are just a new distributor in the mix, there’s not much to talk about and maybe that’s why they are fighting the public relations game the way they are. Interesting enough, earlier this week LightSquared announced they hired a new Senior Vice President for Public Relations and Communications, presumably to attempt to resolve the GPS interference fiasco.

Dish Network Announces Plan for 4G LTE Network and Applies for FCC Waiver Similar to LightSquared

Dish Network is trying something eerily similar to LightSquared, but it will have no effect on GPS receivers since their spectrum is far away from GPS (2+ GHz). Dish bought two bankrupt companies last year, Terrestar and DBSD, and have 40MHz of spectrum to play with in 4G LTE. It will be interesting to watch how the FCC deals with this, especially if the Dish waiver is pushed through as LightSquared’s was. With no GPS interference concerns, Dish might be able to field a 4G LTE system before LightSquared can.

As Phil Goldstein from GPS World’s sister publication, Fierce Wireless, comments:

“One of they issues that has come to the fore in the wake of the FCC’s decision to grant a similar conditional waiver to LightSquared is that LightSquared’s L-Band spectrum sits adjacent to GPS spectrum, and that terrestrial transmissions from LightSquared’s proposed wholesale LTE network in the upper portion of its spectrum is causing GPS interference. Pointedly, in its filing, Dish said its 2 GHz S-Band spectrum “will not raise the technical issues that have hampered the use of the MSS L-Band, such as the interleaving of the operators’ assignments and the severe interference claimed by systems operating in adjacent spectrum.”
 
In return for the waiver, Dish said it will commit to a “substantial terrestrial network deployment” of a branded retail service intended to increase wireless broadband competition, including in rural areas, using LTE-Advanced network technology. Dish said it is prepared to work with the FCC “to develop a reasonable, attainable buildout schedule keyed to commercial availability of the LTE-Advanced standard,” and that it is committed to developing a buildout schedule “consistent with FCC precedent and based on the buildout principles established” in Sprint Nextel’s (NYSE:S) combination of its spectrum assets with Clearwire (NASDAQ:CLWR).

 

Read the full article by clicking here.

America’s Web Radio Guest Appearance

Last week, I was a guest on the American Congress on Surveying and Mapping’s (ACSM) weekly, one-hour America’s Web Radio program. Web radio is actually a very creative idea. You can listen to the live program on your internet-connected computer (11am U.S. Eastern time every Monday) or you can download the recorded program in MP3 format and listen to it using your iPod or other MP3 player. Click here if you’d like to listen to last week’s program when I was the guest.

Thanks, and see you next time.
Follow me on Twitter at http://twitter.com/GPSGIS_Eric

 

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