This week, I’m pleased to present to you an essay written by Gavin Schrock, a licensed land surveyor (Washington), technology writer and administrator of the Washington State Reference Network (WSRN), which operates 103 GNSS reference stations that comprise the statewide RTK Network. He has written about surveying, mapping, GNSS, civil engineering, GIS, and data management for industry and association publications. He is usually not as cynical as he is when facing potential forced upgrades/replacements/production losses for his profession and the GNSS community.
With plenty of announcements, posturing and news, expect another newsletter shortly from me recapping the LightSquared events of December and January.
Should GPS Users Accept New “Fees”?
“Eat your spinach, you no good’ infink [infant]’. Eat it. EAT IT. Eat it.!” – Poopdeck Pappy [from Popeye]
By Gavin Schrock, LS
GPS is free of charge; period. Apart from any costs you incur in securing your own equipment to utilize the signals from the GPS constellation, or to subscribe to some augmentation service, there are no direct user fees. This is codified in our nation’s laws; GPS is free of user fees and this policy has remained consistent throughout the history of the U.S. Global Positioning System. End users, industry, public safety, and some international agreements, are based on or rely upon this fundamental, ubiquitous, irrefutable, concept of free!
Not that a fee would not be a great revenue generator; it has often humorously commented on within the Position Navigation and Timing (PNT) circles of the government that if one penny could be charged every time a GPS-based position is generated that there would be no debt. But this is not a serious consideration, and for the very reason we have GPS in the first place: we’ve already paid for it. GPS is essentially a military program, a weapons system “friend with benefits”. Taxpayers own this system. It was funded for and is operated (in an exemplary manner) by the military for specific purposes, but is almost exclusively unique as a military program in that it provides almost unprecedented direct economic and public safety benefits to the civilian world as well. In other words; we really get our money’s worth out of this investment.
The military can keep it free because they reap enough internal benefits to justify the expenditures; like valuable encrypted services for their own national security purposes. Many fear that the military might lose a substantial portion of this justification if such things as P-Code encryption were turned off, as some have suggest (without the newer “M-Code” being fully deployed first) and that bean counters might start looking at fees. Fees are universally so unpopular for dual-use GNSS systems that no other constellation provider does, nor plans to do so, with the possible exception of the European Galileo system; and there is still great internal debate and dysfunction within the EU and the Galileo program on the design of a franchise model for user fees. Some have also tried to characterize expenditures for developing, deploying, operating and modernizing the GPS constellation as “subsidies” for GPS manufacturers and users. Many more view it as: we paid for it, we own it, and it ain’t a subsidy. Are lighthouses and highways considered subsidies?
You can freely look for and receive GPS signals anywhere they may roam, worldwide and in any band they may wander, not just the GPS Band. There are absolutely no restrictions on receiving GPS signals. The FCC regulates transmissions, not reception. You are not breaking any laws or “squatting” if you look for GPS signals in the next band or the one beyond that. You can try to look into an FM band with your VHF radio if you want. It may not make any sense, but there are no restrictions. What one does with received signals can run afoul of the law though (like eavesdropping on private conversations or decoding encrypted national security transmissions), but when it comes to GPS, there are no current restrictions on what you listen to.
That the FCC only regulates transmissions and not reception discounts calls by some (guess who), for the FCC to develop and enforce standards for GPS receivers. The FCC is generally only concerned with what things emit or transmit. A receiver does neither as it is transmissions and emissions that harm other users. There may be no legal standing for the FCC to regulate receivers. The same kind of selective indignation is heard the characterization of GPS units as being “unlicensed” (got a license for your FM car radio?). This is another attempt to deflect from the immediate issue at hand by implying that your GPS gear is somehow breaking some rules, is deficient, or that the manufacturers have been negligent. More storms in teacups?
No Steps Backward, Only Steps Forward
To this date, the gracious hosts of the GPS constellation (USAF) has not implemented any fundamental design changes that would force you to have to change your GPS uses, or incur any additional costs in doing so. Quite the opposite, there have been many improvements along the way which would make one consider a voluntary upgrade. An example of changes for the better include Selective Availability (deliberate degradation of GPS signal) being turned off in 2000. That action was made permanent in 2007 and such actions acknowledge the tremendous lateral benefits of civilian uses. It will not be until December of 2020 (at the earliest) that there will be any major change in the GPS signal (or spectrum) that will render any method or solution for utilizing the GPS solutions unusable or substantially compromised. The planned change is an option that the constellation provider may exercise at that time to no longer support selected elements of the GPS L1 P(Y) and L2 P(Y) signal characteristics. The U.S. Government acknowledges global use of GPS codeless and semi-codeless techniques is committed to maintaining as such for a whole decade for transition. That is an important distinction; a whole decade… there are no “gotchas” (nor should there be) when it comes to such a valuable amenity. This decade for transition primarily provides time for other constellation upgrades to reach fruition, providing alternatives and mitigating for the possible loss of codeless and semi-codeless functionality. That is another important distinction and concept; do no harm to one capability until there are alternatives completely in place to mitigate for the harm/loss.
Don’t Fee on Me…
If the U.S. government was to try to start charging some end users fees directly or via some other means like a surcharge on GPS gear, that would be met with such opposition as to drag the debate out in process and possibly the courts for far more than a decade. Such an action would also be breaching some hard wrought international agreements. Implementation of direct fees would be as improbable as being struck by a falling GPS satellite.
Now, if the constellation host (USAF, or if forced by another agency) were to make a design change that enabled a specific private entity or group of entities to be able to charge for use of the system (i.e. like an encryption, or spectral change that might cause you to have to buy some proprietary gear) then that would be a fee and that scenario would surely cause an even bigger storm!
But what if a U.S. government regulatory action rendered your current gear to become obsolete in some way? That you would have to incur expenditures to continue to use the very system you paid for, and through no fault or action of your own – would this in affect be a “fee”? (You probably know where I’m going with this). Some say this is moot, because (in their eyes and marketing dreams) your gear is already “obsolete”, and you should buy their gear right away.
One would not expect the definition of a word like “obsolete” to be highly debatable, but one would have never expected a word like “ancillary”, or Ancillary Terrestrial Component to be up for debate either.
From the FCC: (“We clarify that ‘integrated service’ as used in this proceeding and required by 47 C.F.R. § 25.149(b)(4) forbids MSS/ATC operators from offering ATC-only subscriptions. We reiterate our intention not to allow ATC to become a stand-alone system. . . . We will not permit MSS/ATC operators to offer ATC-only subscriptions, because ATC systems would then be terrestrial mobile systems separate from their MSS systems.”).
Sorry, got sidetracked there. Obsolete. Now look at your high precision GPS gear, the gear that you maybe even purchased within the past year. If you were to use that gear today, you would have a reasonable expectation of a certain level of precision and reliability from that gear. There are no planned constellation/signal changes before the end of 2020 that would otherwise negatively impact the expected precision and reliability of your gear. Barring events or conditions completely out of your control, or that of the constellation hosts (natural or manmade disasters, invasions of GPS eating zombies, etc) your gear will not be in any way “obsolete” (with regards to current functionality) before 2020 at the earliest (and may still function long after that).
Your smart phone might be deemed “obsolete” by some of your technophile buddies because a new one came out, but yours still works. On the other hand some have opined “just because a company builds an electric car does not mean we should shut down all gas stations”. Comparing consumer level devices to expensive and sophisticated high precision GNSS gear is like comparing grapes and watermelons. Folks do not take too kindly to others telling them their gear is obsolete, or poorly designed – quibble about the details, but they don’t take too kindly just the same.
But what could make your gear obsolete? Apart from the previous scenarios (and no insult to folks who believe in GPS eating zombies) there are things out there that could potentially compromise your ability to use your current gear, but none, other than things like space weather and malicious jammers (that deliberately set out to mess with current GPS capabilities), are not within your realm of control, or for the most part the control of the constellation providers. However, there is that controversial broadband plan under review that sets out to introduce a new source of interference (that does not currently exist in the specific form, strength, and coverage) being so heavily debated during this past year.
If this perpetually-revised broadband plan is to be given the go ahead, then a new source of interference will require an upgrade or replacement of many high precision and general navigation and aviation GPS units, and if the costs of upgrades and production interruptions fall on the end users, this will, in effect, be a “fee” (or at least smell like one). Likening these costs to a fee is not any crazier or out of line than the barrage of claims and counter-claims brought about by this recent GPS-Broadband “mad as a box of frogs” debate. There are all kinds of arguments, or rationalizations of unpopular positions, that run the gamut from specific technical considerations, politics, deflection, projection, test result rejection, lobbyist injection, to “we already have full rights to do this, GPS must accept the interference.” If that were the case, then why did there have to be a waiver? – and a waiver with strict conditions attached at that?
The broadband applicant and the GPS industry have sparred mightily. Have the conditions of the waiver been met? Who’s fault was it? Bad receiver designs or flawed and rushed broadband plan? [Insert your own favorite rhetoric or talking point here]. Leaving all that aside for a moment, a big overlooked question is, what about the innocent bystanders that will take the heat if it is approved? The end users subject to a new “fee” of sorts. While there is fleeting mention of the “who pays?” in the deliberations (that only seems to go as deep as “the other guys should pay”), no party has set forward a practical plan to cover those costs other than the end user eating them. The highest probability is that the end user will have to eat this “fee” and that will be quite a blow to many people.
Is the fix in, for the fix that is in?
There has been a lot of alchemy going on over the past year with regards to this matter; attempts to turn straw into gold; like the effort to turn low-cost satellite spectrum into golden terrestrial spectrum, and more recent efforts to try to spin what will amount involuntary upgrades (“fees”) as some kind of “gift”. Involuntary expenditures end users will have to incur, to continue to use their perfectly fine GPS gear and perfectly fine spectrum and perfectly fine constellation, as they were designed for and as they are accustomed to, are a defacto fee! To try to spin something so unsavory into a gift, gem, or blessing in disguise, is being viewed widely viewed as self serving and somewhat disingenuous. There is a reason why alchemy went out of style centuries ago by the way.
One way to help someone swallow something unsavory is to sugar coat it, convince someone that it does not taste too bad and won’t make them sick, or wrap it in something that appeals to them. It is very likely that all manufacturers will see fit (if the plan is indeed forced on us) to sweeten the deal to soften the blow, offer incentives, and throw in cool features. No matter how cool the deal is, and what amazing features “you’d be a fool to pass up” are, there is still an element of being forced to pay to be able to continue to use GPS as you are accustomed.
Setting aside this controversy for a moment, there are several schools of thought about upgrades. Like any product, developers (even sometimes with the purest of intentions) work very hard to develop new features and hope we see those as valuable enough to spark an upgrade or replacement purchase. This can be wonderful and with healthy competition we benefit from options for both “nice to have” new features to groundbreaking “must have” features. High precision GPS gear is not consumer GPS gear, and most folks do not buy every new unit that comes out. Do you buy a new car every year? Most need to get several years of use out of the gear to realize cost-benefit, but for others a constant upgrade can pencil out. The growing popularity among heavy users (especially construction) of leasing gear ensures all of newest features, configuration, and firmware (remember that every support call starts with “what firmware version are you on?”). This does not work for everyone and so far as there has not been a forced upgrade or other planned obsolescence, users have reasonably expected many years of reliable use out of their current gear.
Selling (and opposing) the controversial broadband plan that sparked this flurry of debate, has been a well-funded and ongoing effort. No one disagrees that more wireless would benefit a lot of people and even laterally the very end users that will have to pay the “fees” to make it a success. We’ve been told that this plan heralds a new chapter/era/breakthrough in wireless. But it is not like there is some amazing new technology in play that could not be served by other plans, existing or in the works, that do not hurt GPS, and then we find out that the plan might not be as ubiquitous as we might think.
We’ve been told that this is an epic battle between and “obstructionist GPS community and the very future of broadband!” Not quite; LTE is already here, growing, and there are quite a few other initiatives under way, including several hybrid satellite-terrestrial proposals that do not pose immediate threats to GPS. Opposition to this plan does not impact the entire future of all broadband. Plus there is a substantial amount of spectrum being “sat on”, and numerous tests show seriously underutilized spectrum. This has more to do with operational, marketing, and poorly functioning systems that just needs good management and policies. Of course more spectrum needs be sought over time, but why are some of the more recent (and vocal) advocates (even from within the GPS community) for this specific plan so hung up on the supposed “criticality” of this one specific plan. Wouldn’t it be better for both the expansion of broadband and the GPS community to advocate for better management of existing spectrum? Or is it better to zero in on one piece of spectrum that represents a hazard to current GNSS? How about working on underutilized spectrum and give sufficient time to work out solutions for the MSS/GPS bands? This haste and laser focus on this GPS-unfriendly option raises a lot of questions and hackles as we have seen.
We’ve been told variations over time how the interference can “all be fixed with a ten cent filter” to “some components only cost $6″, to $300, to $800, to $5,000, to a thousand bucks a year, to… (lets drop that for a moment). We’ve also been pitched that the plan will bring forth a new cut-rate nationwide RTK network (which may not be as practical or nationwide as some might think). Though there would be benefits of more wireless choices, and a great many investors would benefit as well; does one segment of the population have to take the bullet for this success?
New features added to sweeten the deal might be well worth the cost when separately considered as a voluntary purchase (or not), but if someone wants to eschew the sweeteners, can they get upgraded for free?
A spoon, or shovel full of sugar helps the medicine go down…
Manufacturers have always admirably striven to create new and amazing features, and then the sales and marketing folks have to turn those into “must have” features. This latest move with the “GPS upgrade fee sweeteners” is not an exception. Some sweeteners that will likely be added to the “GPS upgrade fee” might be “must have” to some, but might include features that are not quite ready for prime time in the view of some, or do not solve “make or break” issues for other end users. End users are savvy enough to decide what to buy and when, and if not forced to do so will buy based on business needs and cost benefits. Folks do not take too kindly to salesmen implying that they are “fools for not taking advantage of this deal”.
For example, a forced upgrade might be offered with modifications to get access to more constellations and signals (for the limited numbers of receivers that can take that kind of upgrade). A lot of folks already have with their current gear, L5, Galileo, and other signals capability (or at least placeholders and will be waiting years before those come to fruition). Others wait until a constellation or signal is fully deployed before making a big purchase or commitment. It was announced December 27th, 2011 that the Beidou/Compass constellation has been declared operational, but how many years before that will make any difference to you in the field? Trying to sell something that is not yet ready for prime time can have mixed results. Do you remember the dark times of the old Glonass constellation? Unlike today when it has been successfully modernized and is at full deployment, there were past precision issues reported when using Glonass. I asked a few manufacturers why a decade ago they did not heavily market their early Glonass capable gear, one response was “we did not want a customer to go out there and get [poor] results and then blame us for pushing Glonass on [them]”. Many users may be wise wait until these new constellations and signals have matured.
A noble ambition/feature is to solve the filtering for not only this pending issue but for all forms of interference, and this has been tacitly offered as up another sweetener. With the timeline too short to pull this off before approval of this broadband plan hanging over our heads aside, are end users currently really being crippled by existing sources of interference? Not to deny the potential harm of various types of interference, but is the timing of this “awareness heightening” by some supporters of the broadband plan a case of (to paraphrase L. Frank “Oz” Baum) “pay no attention to the [broadband plan] behind the curtain”?
The U.S. GPS Interference Detection and Mitigation Program (IDM) is a serious undertaking. There are reporting elements like the Patriot Watch portal (closed to the general public) and support/notification services (for not only interference but constellation updates and other alerts) from a “GPS Triad” formed by the USAF (military issues), the FAA (airspace issues), and U.S. Coast Guard (surface issues) already in place. I’ve queried these entities, as well as a number of RTK network operators and have not come up with a huge number of verified examples of interference that would significantly affect high precision users. I’m not saying that “the Orc we fear is worse than the Orc we hear”, but like any other element of risk assessment there should be serious analysis of incident data and testing before we rush off on a potentially costly course of action based in part on anecdotes and compound assumptions about interference.
There have been several (but few) well publicized cases of interference that do present cause for concern, in particular the accidental military source disruption in San Diego in 2007, and the cheap “trucker jammer” that affected an airport in New Jersey. But for non-jamming or military sources (that are not typically turned on in populated areas) the other more commonly suspected sources of interference are often recognized and avoided (e.g. certain types of power lines, some sat-phone handsets, and some high power distribution substations). There are also users successfully working in areas one would highly suspect for interference, but are not necessarily a hazard; like in and around airports, military installations, and even on hilltop antenna farms, without loss of precision.
That is not to say that interference is not a threat nor that jamming might not harm operations. Jammers are highly illegal and of course some folks will use them. You put the idea in a users head, and then the otherwise systematic debugging of field operations issues can take on a whole new element of paranoia. We’ve even fielded support calls this past year with frustrated field users asking “could this be interference from LightSquared?”, a system that has not even been turned on yet. Efforts to build affordable detection devices is a noble cause. There have been some great strides in analyzing this issue and developing new tools. The problem with serving up these things as a sweetener added to a forced upgrade, or as a tool to deflect attention away from the immediate broadband-plan issue, is that many view this in some way disingenuous. Right or wrong, the timing and nature of how this has been spun may serve to taint the otherwise worthy issue of a broader interference.
More at stake than your GPS unit
Sweetening the deal and softening the blow for one limited segment of GPS users, like the surveying profession, or other specific type of GPS equipment, completely ignores other issues that can be viewed as much more compelling than that of the individual.
Aviation: Can the same model of cheap, quickie upgrades (and sweeteners) be applied to aviation? Some of the most compelling concerns have come from the aviation community and FAA Advisory report. To assert that one could go up to a plane on the tarmac, crack open the GPS unit, put in a few cheap components and then send a hurtling can of people into the sky sounds more than reckless or insulting. Developing, acquiring, testing, certifying, installing and then testing again of aviation components is time consuming and expensive, and cannot be taken lightly.
Public safety rightly seems to trump all in this debate, it was no surprise that the December 2011 report of recent limited FCC ordered testing was met with such shock, and that mainly over the aviation element risks.
The same solutions for limiting interference in cell phones may not be applicable to other types of gear, and may be completely ludicrous for others. In the case of cell phones, these are narrow band (only using about 6%, or 2MHz of the 32MHz of GPS signal) as they are not concerned with precision, and many utilize Assisted GPS (AGPS); an augmentation to improve the slim pickings from such a narrow band view. High precision units, and most general navigation GPS, plus aviation, and most military are “wide band”. There is a huge difference between a cell phone being tested in a purely pass/fail mode; more for “conformance”, than for “performance” and a high precision unit that uses (perfectly legitimately) as much signal as possible to achieve such high precisions as many rely upon.
No one would disagree that there are engineers that have been rolling up their sleeves and working on new and improved filtering options, but at this point in time, there is a sort of “spectral gun” being aimed at the end users. The view is quite a bit different from down here at the business end of said gun than from the point of view of those who are so cavalier about this subject on the trigger end. In this charged atmosphere of the current controversy, we may really need a “hype filter”. Is it too much to ask that such grand filtering ideas be backed up with solutions that have been developed and tested for every type of GPS unit well in advance of anyone monkeying with the spectrum? Sure one can assume that anything can be fixed with enough time and money; seems to be no shortage of money, but how about time? Back down the throttle a little and let this plane come in for a safe landing.
Hold the Cheeseburger
Wrap up something unsavory in a double-patty-pickles-onions-cheese-on-a-sesame-seed-bun and we are still being forced to consume something unsavory or disgusting– and don’t expect us to think folks are heroes for selling us a toothbrush.
Opposition to the plan has not been limited to the GPS manufacturers or satellite communications providers who would stand to lose something in this matter. The U.S. military, aviation, agriculture, and public safety are among the others who have arguably had more say in the matter. There have been some accusations that all opposition is contrived, or based solely on conflicted interests – don’t insult us. Yes, the end user may be only looking at the costs of upgrade/replacement/production interruption but what of those who stand to gain either financially or in stature from this if approved?
Why would parties from even within the GPS industry and community (some call “turncoats”) advocate for introduction of this new specific form of interference and inflicted forced upgrades/replacements on their own industry and end user community, and then try to spin that as some kind of gift, or path to a “better world”? Some would suspect profit, or there may be pure intentions involved, though the latter might make one think about those old spy/action movies where some group is planning to disrupt the world so that they can rebuild a more perfect world according to their plans or beliefs. Good intentions, but…
If this broadband plan is given the green light (and even if it looks like it might not fly), or not, it may serve as a harbinger of things to come. If it fails, it is not the end of broadband or the world as we know it, and perhaps a good long term plan to manage spectrum and constellation could come of this. It would be a fantastic goal/role for joint PNT/FCC cooperation, but these things cannot and should not be rushed. Wow, managing something effectively, am I dreaming?
If approved though, all of the manufacturers will have to offer some kind of deals to soften the blow. The end user may have no choice but to upgrade or replace, but they will have a choice in how they do this and who they patronize. Some sweetener peddlers have jumped the gun and have touted cost-benefit computations of the upgrades (based in part on some aforementioned arguable assumptions) that (they say) may only cost you the price of a burger a day; couple of bucks a day (or 50 Rubles, or whatever currency equivalent as many might turn to cheap GPS gear from overseas if forced into this). Many have expressed how insulted they feel about this attempt to minimize their concerns.
People will not easily forget those who blatantly advocated for what many consider to be a rushed-reckless spectral disruption. Many end users have indicated that they will seek to pay (if forced to) these “fees” to other companies who did not support the potential harmful broadband plan, exercising what little choice or influence they have in this matter. Or at least if the GPS eating zombies do attack, they might be tempted to trip some of those turncoats.
Thanks, and see you next week.
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