LightSquared’s Reaction to the GPS-Broadband Report: High Precision GPS to be Sacrificed? Can This New Proposal Be Stopped?

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The report is in–and it is fairly damning. Per the January 2011 conditional waiver from the FCC, LightSquared and the GPS industry were to test elements of the proposed system for potential interference hazards. After a two week extension requested by LightSquared, the ordered report arrived amid heated rhetoric on both sides.  While the report might put the skids on the original proposal, hastily prepared alternatives being promoted by LightSquared would still cripple high precision GPS uses, like surveying, machine control, science, and precision agriculture – these industry segments might represent a small percentage of receivers, but combined they represent the largest portion of the total economic benefit of GPS: []. With only a 30 day public comment period ending July 30th, our industry cannot afford to miss out on having our concerns heard.

To be effective in voicing concerns it is important to be versed in the details of the matter. It might be a good idea to spend a bit of time perusing the interesting and sometimes very telling submissions in the official FCC file [] on the LightSquared proposal; the cases from both sides are well represented, and in many cases revealing some of the misconceptions about the proposal and how the results of relentless lobbying have swayed some of the submitters. There are some glaring contradictions in the responses; for example there are public safety first responders who vehemently oppose the plan, and those who enthusiastically support it. One would expect that decisions about critical spectrum to be based more on science, the physics of radio transmissions, and hard numbers on economic impact, and not reactions to things like emotionally charged full page advertisements.

The full report is available, but a bit overwhelming and painful to sift through. You can read the full Report [ ] plus the four appendices 1 [ ] , 2 [] , 3 [ ] ,and 4 [ ] that detail the procedures for testing and results of the joint technical working group (TWG).  Or you can look at some of the detailed analyses, like the report summary [ ] from the Coalition to Save Our GPS [ ]. The spin from LightSquared is seemingly omnipresent and all too easy to find online; their reaction has been to float alternatives to keep the proposal alive because even LightSquared admits that the report shows the original proposal could not fly as-is.

Though not mentioned anywhere in the report, the prime alternative being floated over the past few weeks is for LightSquared to work at the lower end of the spectrum in question, even though this would still be devastating to high precision GPS. LightSquared’s answer to this is to work their way slowly up the spectrum over time on the presumption that technical solutions to the interference hazard to high precision GPS will materialize along the way. This new proposal provides a real Catch-22 to those who want to voice their concerns during the public comment period. On the one hand, the responders can only officially comment on the report as it relates to the original proposal; the whole band proposal that is now effectively dead. But the new proposal was not tested, so comments about that may or may not be ignored. That should not prevent folks who oppose the original and new proposals from commenting, filing directly with the FCC, and writing their elected officials (many of whom were gotten to early on with the über-lobby “blame-the-victim” campaign against GPS by LightSquared). While opponents can find a lot to cite in the report, it is what is not in the report that might have more a bearing on the outcome of this controversy and how it could devastate high precision uses…

A few key take-aways from the report:
• The results of the testing shows substantial interference in all segments of GPS end use. It is important to note that LightSquared’s initial assertion was that there would be little or no interference and that the GPS industry was exaggerating the risks.
• The new proposal is not mentioned in the report, and key elements of the new proposal (using initially only the lower half of the band) were not tested as such. Only a limited test of some lower-band transmissions was tested on a small sampling of cell phones; even that showed interference for over 12% of units tested. No lower-band testing was done for high precision GPS gear.
• Without lower band testing, there is no reason to believe that the new proposal would work. LightSquared was completely wrong on the original proposal, how can we trust their “experts” on this one?
• LightSquared has cited the 2003 FCC order on their proposal for a limited number of towers and lower power transmissions in the same band as a precedent authorizing this current proposal. LightSquared claims that the GPS industry bought off on the 2003 plan and therefore has relinquished it’s say in this matter. It is very important to note that the 2003 plan was for far less transmitters and dramatically lower power levels. This isn’t just an “apples-oranges” comparison; it is more like comparing an apple to an 80lb jackfruit (that would crush someone if it fell on them).
• The current proposal, not mentioned in the report, relies upon redesign and replacement of GPS receivers and infrastructure. Nothing of the sort was tested chiefly because such designs as proposed and such filtering does not exist yet, and some of the expectations for such technical solutions (that so far only exist in the fertile imaginations of proposal supporters) defy the laws of physics. Yes, it is currently possible to filter out transmission that are hundreds and even thousands time more powerful that what a GPS receiver is accustomed to, but the current proposal is in the order of billions of times more powerful; Star Trek-like shields do not exist yet…
• The latest proposal is supposed to reduce interference for all but 0.5% of GPS users (and only if all of the compound assumptions about technical fixes and filtering actually come to fruition). Even if solutions were to be eventually found, there would be a lengthy and costly transition. The process to adopt new technical solutions for the FAA alone takes upwards of seven years to test and certify. Per a separate report  [ ], that 0.5% equates to about 40% of all economic benefit of GPS, and a possible decade-long transition could do more harm to our economy than the even the optimistic estimates for what the enhanced broadband being touted might bring.

It is very likely that few of the decision makers will bother to read the report; their minds are all bu
t made up. Why? The argument for broadband-for-all is compelling. The notion that LightSquared was willing to invest so much private funding into what was being spun as the biggest potential economic driver since the industrial revolution and the potential to bring broadband to rural America is all that some folks (including the FCC) want to hear. The death of the current or latest LightSquared proposals will not kill the whole broadband dream. Conversely, it is possible that the FCC in its haste to try to fulfill that dream by backing a flawed proposal might hurt better planned proposals in the future. So how does someone oppose this particular flawed plan without sounding like they oppose broadband and all of its potential benefits? It is very important for surveyors to stick to the elements of this particular proposal; and a few more things to note:
• The original proposal and order set expectations that LightSquared will offer broadband services  for 260 million Americans; that leaves a substantial segment of the population where they are now; no broadband. So much for bringing broadband to rural America; instead the services will simply be competing with existing carriers in the most populated and lucrative markets.
• Some argue that our national broadband offerings are too slow and costly for us to compete with other economies. While there is some merit to this in considering that some countries like Korea and Japan have average speeds many times ours and at a fraction of the cost, we are on par with most booming economies and actually have a very high penetration rate. Sobering are the statistics revealing that streaming movie services like Netflix make up over 20% of all US internet use, YouTube alone accounts for 8%, Torrents are another 20% (i.e. downloads of movies and music, including the substantial amount that are less-than-legal), and standard HTTP is at 16% – this leaves less than 40% as the economic engine we hope it could be. Perhaps it is not so much what we have, as what we do with it?
• A proposed national broadband network for public safety is a separate initiative. The FCC is touting the “D-Block” of the 700MHz band for this other initiative. The LightSquared proposal(s) have absolutely nothing to do with this (unless there was a fallback contingency all along). GPS users are not trying to kill the national broadband network for public safety.
• The end of the LightSquared proposal will not kill the future for broadband. Where there is a will and a way (and especially a will and a way and a pile of money) then there will eventually be more high speed broadband than we can imagine. Just not with this particular rushed, flawed, and dangerous proposal.
• LightSquared will offer these services wholesale. Services will be offered through third parties like big-box electronics stores like Best Buy, or even discount department store giants like Wal-Mart. A reseller could have cheap devices manufactured overseas and provide direct competition for the big telecoms. If there is going to be a backlash over the proposal if authorized, LightSquared might not even feel it as they are not on the front lines. The typical consumer will be able to go ahead and stream movies cheaper than ever before without realizing it helped killed high precision GPS.
• It is important to highlight the other high precision uses, like precision agriculture, machine control, science (like earthquake, volcano, and tsunami studies), and how the proposal would effectively kill the high precision NextGen landing and anti-collision systems being developed for aviation. Surveying is a critical service that most folks do not even consider, but it seems a bit esoteric and disconnected from the experience of the average citizen or elected official, and these are the folks that need to be reached. Hit them with stuff they understand…
• Reach out to these other end use communities… wouldn’t  it be a great publicity stunt for the cause to have some agriculture tractors and surveyors with rovers parading about (sorry, dreaming out loud here).

It is hard not to get emotional (I constantly have to geek-check myself) but it appears that there is an objective and compelling case for the FCC to consider backing another horse as their champion for the cause of enhanced broadband.

Consider filing your concerns directly [ ] with the FCC, writing to your elected folks (especially those who had jumped to conclusions far before the testing was done), and maybe rallying your local associations…