The American Surveyor

The Coalition to Save Our GPS Issues Follow Up Comment in Reaction to the Friday, January 13, 2012 PNT Statement

The January 13, 2012 statement from the Department of Defense and the Department of Transportation, on behalf of the nine government departments and agencies that use and benefit from GPS in performing critical functions for the public, represents the culmination of a year of unprecedented technical effort to evaluate LightSquared’s proposal to repurpose satellite spectrum adjacent to GPS for a nationwide wireless network providing terrestrial-only services.

In January 2011, the FCC’s International Bureau granted LightSquared a conditional waiver removing legal barriers to this proposal, but imposed the absolute condition that LightSquared would not be permitted to move forward unless it could demonstrate that its proposed operations would not interfere with GPS. LightSquared fully accepted this condition. At the time, LightSquared made public representations that its operations would not interfere with GPS, and the FCC relied upon these representations.

Consistent with the FCC’s directives and in recognition of the benefits to the public of additional wireless competition and services, affected manufacturers, government agencies, and critical users of GPS have devoted unprecedented efforts to technical studies to evaluate LightSquared’s proposed operations. From the outset, these parties have expressed serious concerns that these operations would create widespread harmful interference to GPS, but undertook these efforts nonetheless.

Every set of independent technical studies has confirmed that LightSquared’s proposed operations would create widespread interference to critical GPS uses. The test results which were the subject of the January 13, 2011 government conclusions yet again confirm the interference problem. The results also confirm that interference will not only affect high-precision GPS receivers, but also millions of GPS devices used by consumers every day in their cars, trucks and boats. In addition, the most recent studies confirm interference to critical aviation safety systems.

LightSquared has been afforded every possible opportunity to make its technical case, and has failed to demonstrate that it can avoid interference to many critical GPS based activities. Over the last year, it has proposed numerous modifications to its proposals which it claimed would solve the interference problem. Each of these proposals has been extensively evaluated and none have been found adequate to eliminate widespread interference to GPS. No credible, independent expert or organization has come forward to support LightSquared’s claims of non-interference to millions of existing GPS devices.

We welcome the PNT Executive Committee’s unanimous conclusion on behalf of the nine government departments and agencies that ‘no practical solutions or mitigations’ exist that would allow LightSquared to operate without causing significant interference to GPS. At this point, there is no evidence that any further modifications to its proposal would yield a different conclusion. Because of this, the Committee’s conclusion that it is time to end technical studies and that the proposal is not viable is supported by overwhelming technical evidence.

Unfortunately, in apparent recognition that it cannot satisfy the FCC International Bureau’s condition of non-interference that it accepted in January 2011, LightSquared has pursued a concerted disinformation campaign to attack and impugn specific companies and individuals who have been part of the process of reviewing its proposals. These shrill, irresponsible attacks are reprehensible, and are obvious acts of desperation. The technical evidence speaks for itself, and no individual, company or government body can legitimately be blamed for the clear defects of LightSquared’s ill-conceived proposal or the failure of that proposal to pass an extensive, fact-based review process.

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