Hey FCC – GPS Is Not A Toy!

Dear colleagues,

I would like to bring to your attention a potential hazard to one of the most valuable tools and resources for our industry and public safety – the L-band in which GPS signals reside may soon be “overcrowded” by commercial signals.

A recent application submitted to the FCC which, if granted as filed, has the strong potential for adverse impact on the reception of the GPS/GNSS L1 signal in affected urban areas in the U.S. This harmful interference could be created by a newly proposed high-capacity terrestrial wireless service operating adjacent to the GPS L1 band and planned for a demo launch in 2011. The FCC appears to be expediting regulatory treatment of this application. Please refer to the background below or to the issue paper which has been distributed to the U.S. GPS Industry Council (USGIC) members for similar action.

I believe it is completely appropriate for our associations to call for a more formal evaluation of the application before granting the access to the applicant for use of this critical bandwidth.

This is not in any way trying to restrict a business, but only to delay the action and ask for a more in depth study. If the L-band is adversely compromised it could potentially impede surveyor’s use of GPS, but also think of the public safety risks (FAA, Coast Guard, to name a few). GPS also enhances multi-billions in commerce, construction, agriculture, not to mention the consumer usage. Probably some low level FCC “rubber-stampers” view GPS as a toy. The GPS manufacturers, including those who produce our survey gear are united on this matter, and I have already received many copies of this call for action from other associations; surveyors need to add our voice.

Specifically, I respectfully request your help, please, to contact Industry Associations: Identify organizations and companies willing to be listed in the attached USGIC letter(s) to the FCC and to appropriate Administration officials having national responsibilities for GPS;

A one page 13KB PDF “issue” paper from USGIC can be found HERE. The paper provides Council representatives’ contact information. The Council is developing a media Q&A, with Trimble’s assistance, which will be provided to member companies. It will be important for the GPS industry to have a coordinated external message.

Timeframe: The FCC applicant filed their request on Nov 18; the Commission put it on public notice on Nov 19; and the FCC significantly abbreviated the public comment period. This extraordinary FCC regulatory approach to fast track this application, which effectively seeks a reallocation of spectrum from space to terrestrial use, is raising significant alarm among the majority of parties filing comments to date. According to the Administrative Procedures Act and its own rules, the FCC is required to place a request for spectrum reallocation on public comment under a Notice of Proposed Rule-Making (NPRM).

• The GPS/GNSS L1 signal operates in the radiofrequency band (1559-1610 MHz);
• The GPS L1 signal is bracketed by bands allocated to Mobile-satellite service operations (MSS) on a primary basis: (1525-1559 MHz; 1625.50-1660.50 MHz);
• The adjacent L-band MSS operator, LightSquared, has an FCC license granted in 2004 to operate Ancillary Terrestrial Component (ATC) base stations to augment and extend its primary MSS service in urban areas;
• On Nov 18, LightSquared filed a report on the implementation of its integrated MSS/ATC service advising the FCC that:
• LightSquared’s business model “has evolved” to a wholesale provider of network capacity to retailers who will take an integrated MSS/ATC service, but who can choose to offer cellular only to end-users;
• It propose to operate, effectively on a primary basis, a terrestrial wireless voice and data broadband service; and deploy a high-capacity, densely populated network of strong signal transmitters (1500 watts) blanketing select urban areas. We understand that six U.S. cities may be identified for initial roll-out.. We believe that Las Vegas and Phoenix are candidates.
• LightSquared is effectively seeking a reallocation of its band from a space service (MSS) to a terrestrial wireless service which represents a radical change in the operating environment of the adjacent GPS L1;

Status of the GPS industry response:
• The GPS Industry Council filed comments with the FCC in this application proceeding; and filed separate with the National Telecommunications and Information Administration (NTIA),as co-regulator with the FCC of the spectrum where GPS operates;
• The Council technical team held two technical discussions via conference calls with LightSquared to inform them directly of the different interference problem created for GPS that will potentially occur from its newly proposed terrestrial wireless service and of the additional mitigation measures that need to be taken to protect GPS operations;
• The Council technical team had a conference call today with the Chairman of the Interdepartmental Radio Advisory Committee (IRAC) to provide a draft technical presentation; during the first week of January 2011, the Council will follow-up with a final technical presentation to the FCC and NTIA/IRAC;
• Current launch of the GPS industry effort, as described in this e-mail, to reach out to industry associations and potentially affected end-users to build a broader coalition to inform the FCC of the potential for serious harmful interference to GPS use.

Please let me know if you have any questions. Also feel free to contact Mike Sweik – Executive Director of USGIC (202) 416-6282.