Speaking at the National Press Club on Nov. 3, Federal Communications Commission (FCC) Chair Jessica Rosenworcel announced a plan to reorganize the agency to include a Space Bureau and a standalone Office of International Affairs.
The rationale for these moves, as explained in a press release, is to “help ensure that the FCC’s resources are better aligned so that the agency can continue to fulfill its statutory obligations and keep pace with the rapidly changing realities of the satellite industry and global communications policy.”
While neither GPS nor Ligado were mentioned in the press release, some have taken establishment of a Space Bureau as a sign the FCC may be reconsidering its decision regarding Ligado Networks.
By creating a Space Bureau, the reasoning goes, the commission is acknowledging a need to better focus on space-based users. A report this summer from the National Academies of Science said that some GPS and Iridium users would be harmed if Ligado Networks is allowed to operate as planned.
Since the commission seems to be trying to prevent future Ligado-like controversies, it may also be ready to reconsider its Ligado decision. In February 2020 seven different petitions were filed by organizations and groups of organizations formally asking the FCC to reconsider. The commission has not yet responded to any of the petitions.
Few can disagree that aligning resources to more effective address constituent concerns is a good idea. At the same time reorganizations rarely, in and of themselves, prevent problems from recurring.
As one example, the FCC had been criticized for years for not including analyses of total costs and benefits to the nation of decisions it was considering. In January 2018, FCC Chairman Ajit Pai established the FCC’s Office of Economic Analysis to address those concerns.
Yet, despite Pai still being chair, the Office of Economic Analysis was not called upon to provide input to the commission’s deliberations on Ligado Network’s application. One of the pending petitions for reconsideration asserts that if the office had done a cost-benefit analysis, the commission’s decision would have been different. This is because the cost of even a small service degradation for potentially millions of GPS users would have very likely easily outweighed any benefit to the nation of granting Ligado Networks permission to operate.
Photo: Bill Oxford/iStock/Getty Images Plus/Getty Images
Last week, 27 members of the U.S. House Agriculture Committee sent a letter to Federal Communications Commission (FCC) Chairman Ajit Pai. In it, they urged him to reconsider the FCC’s decision to allow Ligado Networks to operate a terrestrial nationwide network that the executive branch says will cause harmful interference to GPS signals for many users.
This concern and opposition from a sector not traditionally engaged in GPS or positioning, navigation and timing (PNT) issues is just one example of how the FCC’s decision — rather than putting the issue to rest — has instead recruited a whole new set of actors from across multiple sectors for the opposition.
Many observers don’t see this as surprising.
According to one observer, previously it was easy for many to assume the FCC would reject Ligado’s proposal. The entire executive branch had been vehemently opposed for years. So had aviation groups, the weather community, geospatial interests and some satellite communications concerns. With such opposition from so many important quarters, it was reasonable for many to assume they need not become involved. Now that the FCC has acted to the contrary, these interests have become well energized.
The FCC decision also empowered opponents to educate and recruit others who don’t normally think or worry about GPS and PNT issues, folks like farmers and agricultural interests.
As one insider said, “The existing opposition can now go to just about anyone in any sector and say, ‘This is going to happen and it will harm your operation. There are no ifs, ands, or buts. The FCC has decided’.”
Photo: Avalon_Studio/E+/Getty Images
Agriculture’s reliance on GPS
Agriculture is a good example. While not the sector that first springs to mind when most people think about GPS, farming has become dependent on augmented GPS for precisely and automatically driving machinery, minimizing fertilizer and pesticide use, and a wide variety of other productivity gains over pre-GPS operations.
“GPS is critically important to the commercial agriculture, mining, forestry and rural manufacturing industries. In fact, GPS has become the single most significant technological advancement for American farm equipment in the past two decades… [A 2019 RTI study] found that during planting season, if GPS were interrupted, the economic impact to the agriculture sector could amount to losses of $15 billion due to lower crop yields. Moreover, an earlier study suggested GPS-enabled precision agriculture could save farmers an estimated 10 to 15 percent in operating costs and purchased inputs. This same study estimated the benefits of GPS to precision agriculture between $10 and $17 billion.”
Department of Transportation studies have shown that high-precision GPS receivers, such as those used in agriculture, could be impacted within 3,000 meters of a Ligado transmitters. With tens of thousands of transmitters deployed in a nationwide network, this could pose a real problem for American farming.
Other sectors have also become involved in the opposition. The recently formed Keep GPS Working Coalition has members representing aviation, surface transportation, maritime, agriculture and equipment manufacturing.
This formal and public coalition, though, seems to be just the tip of the opposition iceberg.
Almost 100 dissenting organizations
According to some involved with protesting the FCC’s decision, there are nearly a hundred organizations and companies that are working in some way to have it overturned. These include multiple aviation, delivery service, agriculture, surface transportation, geospatial, weather, maritime, space and technology interests.
One sign of the influence they are having is an increase in concerns being expressed by members of Congress.
In addition to the agriculture letter, some of the most powerful recent examples are statements made during meetings of the influential House Committee on Appropriations. Rep. Ken Calvert (R-CA), ranking member of the Defense Appropriations subcommittee, spoke at length in opposition to the FCC’s action. His comments were followed in a similar vein by the vice chair of the Appropriations Committee, Rep. Peter Aguilar (D-CA).
Many of the questions being asked by the public and members of Congress alike were reflected in the letter from the Agriculture Committee members:
How did the FCC know that “its” tests were representative and valid?
Why does the FCC find that some degradation of GPS reception is acceptable?
Why did the FCC reject the executive branch’s testing criteria?
Was there a cost/benefit analysis?
The letter also asked the question that is on almost everyone’s mind: If and when there are problems, who is going to fix them?
Signing the letter were Senators Mike Lee, Brian Schatz, Ron Johnson, Edward Markey, Ted Cruz, Mark Warner, John Thune and Chris Coons. All except for Senator Coons serve on the Senate Committee on Commerce, Science and Transportation, which oversees the FCC. Senator Coons serves on the appropriations subcommittee that funds the FCC each year.
The letter referred to the hearing held by the Senate Armed Services Committee on the issue, and stated that only parties opposed to the FCC’s action were heard. The senators were concerned that the public also hear from the FCC.
Thirteen specific questions covered topics including:
How long the proceeding was on the docket
What notice given federal agencies of the proposed final order
Which agencies were consulted and how input was considered
The adequacy of the guard band and how the FCC has used the 1-db interference standard in the past
The 13th question asked the FCC why it believed granting the application was in the public interest.
A copy of the letter is available on the Resilient Navigation and Timing Foundation website.
Alan Cameron Editor-in-Chief and Publisher, GPS World
“All the News that Fits” can sometimes be a hard motto to live up to, and it has turned out so this month. I want to get more material into our pages for your perusal, and it just could not be crammed into the System of System pages in this issue. Therefore, I cede my “Out in Front” editorial to the 27 gentlepeople, executives across the commercial, scientific and government agency spectrum, who wrote to U.S. Federal Communications Commission (FCC) chair Ajit Pai on July 18.
The core quotes from the letter appear here. However, there’s more meat on the bones and I want to present it here.
“The undersigned organizations, representing entities that provide and rely upon critical GPS, satellite communications (“SATCOM”) services, and essential weather and other environmental data, write to inform you that the threat of harmful interference from Ligado’s proposed ancillary terrestrial component (“ATC”) service continues to pose a significant risk of harmful interference despite Ligado’s May 31, 2018, amendments to its license modification applications in the above-referenced file numbers. The record, augmented by recent government reports, makes clear that the interference will be particularly impactful to the countless government and commercial entities that rely on GPS and SATCOM services for aviation safety and other critical services and the many groups that receive and depend upon real-time weather and related environmental information from National Oceanic and Atmospheric Administration (“NOAA”) satellites…
“We recognize the importance of ensuring that there is sufficient spectrum for mobile broadband, and the Commission has recently taken many steps to address that challenge. However, at a time in which the Administration has placed so much emphasis on the critical importance of space-based communications — through the revival of the National Space Council and other policy initiatives — the FCC should not undermine the nation’s critical space leadership.2 Granting Ligado’s request would harm the nation’s satellite industry and the broad sectors of the country that benefit from American space leadership every day in at least three ways. First, it would threaten the reliability of critical position, navigation and timing (“PNT”) services, including GPS and also an emerging satellite time and location (“STL”) capability augmenting GPS.
“Second, it would undermine the investment-backed expectations of those who operate commercial satellite systems by fundamentally altering the interference environment decades after licensing.
“And third, it would convert 40 MHz of increasingly rare satellite spectrum away from satellite use, rewarding a company for underutilizing its satellite spectrum rather than investing in new satellite technologies.”
In addition to several organizations, the letter is signed by the Aircraft Owners and Pilots Association, the American Geophysical Union, American Weather and Climate Industry Association and the National Emergency Number Association.
