Tag: FCC Ligado decision

The Ligado saga continues

Matteo Luccio

The LightSquared/Ligado Networks saga, now in its second decade, continues. On Sept. 9, the Committee to Review FCC Order 20-48 Authorizing Operation of a Terrestrial Radio Network Near the GPS Frequency Bands of the National Academies of Sciences, Engineering and Medicine (NASEM) released its consensus study. Both sides claim the report supports their position.

A summary of the report and reactions from various stakeholders can be found here.

According to Ligado, the report confirms the FCC’s finding that the company’s operations “can co-exist with GPS.” It cited the report’s conclusion that “the technology to enable compatibility has been in use for over a decade, and most consumer equipment, commercial general navigation, timing, cellular and aviation receivers will not experience harmful interference from Ligado’s operations.”

The NASEM report also confirmed, the company said, the FCC’s finding that “[a] small percentage of very old and poorly designed GPS devices may require upgrading.” Ligado reaffirmed its commitment to “upgrade or replace” federal equipment negatively impacted by its operations and expressed its hope that now the Department of Defense (DOD) and the National Telecommunications and Information Administration “will stop blocking Ligado’s license authority and focus instead on working with Ligado to resolve potential impacts relating to all DOD systems.”

By contrast, the GPS Innovation Alliance applauded the NASEM’s “reaffirmation that Ligado’s terrestrial operations would have a harmful, real-world impact on the millions of federal and commercial users that rely on GPS, satellite communications, and weather forecasting services every single day.” It further stated that the report “demonstrates that Ligado would pose an unacceptable risk to services critical to safety-of-life operations, our national security, and our economy” and urged “government action to address the imminent, but preventable, harm that would result from Ligado’s deployment.”

According to the DOD, the NASEM study “confirms that Ligado’s system will interfere with DOD GPS receivers, which include high-precision GPS receivers.” The study also concludes, DOD says, that the FCC’s proposed mitigation and replacement measures “are impractical, cost prohibitive, and possibly ineffective.”

The NASEM committee pointed out repeatedly in its report that matters are more nuanced than represented by either side and that test results and harmful interference depend on many factors — including the receiver’s signal processing architecture, the amount of SNR loss, the use case, and the relevant failure modes. “The determination of harmful interference is dependent on the particulars,” it said.

The committee also bemoaned “a lack of a quantifiable definition of harmful interference” and “the lack of common receiver assumptions” and called for “more definitive receiver standards.” It also pointed out that “many spectrum conflicts could be avoided if receivers were better designed and implemented.”

The GPS user base is in the billions. Therefore, even if “most” receivers will not be harmed by Ligado’s operations, as the committee reported, tens of millions of devices will be. I highly recommend reading the full report.

October 13, 2022
As launch looms, threat from Ligado returns

Luccio

“The new LightSquared business plan and the new FCC rules significantly expand the terrestrial transmission increasing the potential for interference to GPS receivers,” the U.S. departments of Defense and Transportation (DOD and DOT) wrote to the Federal Communications Commission in 2011 after the FCC granted the company permission to offer broadband via its satellite and base station networks to a wide variety of mobile broadband partners. The move — heralded by supporters as hastening the advent of 4G services across the country, especially in underserved communities — sent shockwaves across the GNSS/PNT community, which opposed the plan forcefully for the threat it posed to GPS.

Reborn in December 2015 as Ligado Networks, the company obtained the FCC’s unanimous approval in April 2020 for the use of spectrum near the L-bands used by GPS for its 5G network. It is scheduled to launch its first deployment at the end of September.

Nearly all the federal government, including DOD and DOT, as well as most manufacturers of GNSS receivers, are very strongly opposed. On September 9, the National Academies of Science, Engineering and Medicine’s Committee to Review FCC Order 20-48 will release its independent evaluation of the issue, as mandated by the 2021 National Defense Authorization Act.

The study, begun in May 2021, considered three issues:

1. Which of two prevailing proposed approaches for evaluating harmful interference is most effective to mitigate the risk of harm.

2. The potential for harmful interference from Ligado to mobile satellite services — such as Iridium.

3. The feasibility and practicality of the remedies proposed by the FCC.

A summary of the report can be found here.

Welcome Penny Axelrad

I am very pleased to announce that Prof. Penina “Penny” Axelrad has joined GPS World’s Editorial Advisory Board.
Penny is a University of Colorado (CU) Distinguished Professor in the Ann and HJ Smead Department of Aerospace Engineering Sciences. She received her B.S. and M.S. degrees in Aeronautical and Astronautical Engineering from MIT and her Ph.D. in Aeronautics and Astronautics from Stanford University. She has been a member of the faculty at CU since 1992, serving as primary advisor for 25 Ph.D. graduates and many M.S. and undergraduate research students.

Penny has been active in research on GPS and PNT technology and applications for aircraft, spacecraft and remote sensing, as well as estimation of satellite orbits and attitude, since 1985, co-authoring more than 60 journal papers and 130 conference papers. She has served as principal investigator or co-investigator on grants and contracts totaling $17 million. She is a Fellow of the Institute of Navigation and the American Institute of Aeronautics and Astronautics, and a member of the National Academy of Engineering. Since 2013 she has served as a member of the National Space-Based Positioning, Navigation and Timing (PNT) Advisory Board.

I overlapped with Penny at MIT in the mid-1980s. Now, nearly 40 years later, I look forward to her contributions to this magazine.

September 13, 2022
Ligado approaches Canada for spectrum permission, comments sought

News from CANSPACE Listserv

The Canadian Positioning, Navigation and Timing Office (PNTO) is warning stakeholders that Ligado has asked the Canadian government for access to spectrum that neighbors that of GNSS services. The request has long been a major issue in the United States because of the risk of radio frequency interference for GNSS users.

Image: da-kuk/E+/Getty Images

Innovation, Science and Economic Development’s (ISED) Spectrum Management and Telecommunications team announced on Aug. 19 a Notice of Application from Ligado Networks. The application seeks authority for providing terrestrial mobile services in the L-band (1526-1536 MHz in the MSS downlink, and 1627.5-1637.5 MHz and 1646.5-1656.5 MHz in the MSS uplink).

In its application, Ligado Canada is requesting that ISED adopt similar operational requirements and technical rules as those of the U.S. Federal Communications Commission. The rules are spelled out in 2020 FCC order 20-48, “FCC Ligado Amendment to License Modification Applications.” The operational requirements would allow Ligado Canada to provide ancillary terrestrial mobile services over specific portions of its licensed MSS spectrum.

Interested stakeholders can submit comments until Oct. 18 on ISED’s website. Respondents are requested to email their comments in Microsoft Word or Adobe PDF to [email protected].

CANSPACE Listserv is a service of Canadian Space Geodesy Forum and is administered by Dr. Richard Langley.

August 29, 2022
NSC director: GPS ‘Still a Single Point of Failure’

Photo: Caitlin Durkovich

The Global Positioning System (GPS) is “still a significant single point of failure in our country,” said Caitlin Durkovich, National Security Council director for Response and Resilience.

Her remarks were made at the Dec. 9 meeting of the president’s National Space-based Positioning, Navigation and Timing (PNT) Advisory Board.

The meeting was held shortly after Russia’s successful anti-satellite test and threat to “blind NATO and the U.S.” by shooting down all GPS satellites.

Durkovich’s remarks were made in the context of a larger national resilience message. She cited recent incidents such as Hurricane Ida, the Colonial Pipeline hack, the winter failure of the Texas electrical grid, and disrupted supply chains. She said everyone is responsible to ensure they, their systems and the nation are able to safely weather adverse events and bounce back better than before.

The interconnectedness of so many vital services such as electrical power and other vital systems like PNT make a holistic approach necessary. The administration is developing a set of resilience principles to support that, she said. It is also ensuring as funds go out to states and localities from the infrastructure bill that making American infrastructure more resilient to climate change and “all hazards” is a priority.

Because “positioning, navigation and timing is foundational to our life,” she said, “resilience is more important now than ever.” Disruptions could lead to “cascading effects.”

Durkovich cited the administration’s Space Priorities Framework as evidence of White House concern. Released this month, it says in part:

“Space systems are an essential component of U.S. critical infrastructure — by directly providing important services and by enabling other critical infrastructure sectors and industries. The United States will enhance the security and resilience of space systems that provide or support U.S. critical infrastructure from malicious activities and natural hazards.”

She also indicated that the Biden administration was following through on two Trump administration policies as important steps to resilience.

Executive Order 13905, “Strengthening National Resilience Through Responsible Use of Positioning, Navigation, and Timing Services,” among other things, calls on all users to avoid over-reliance on GPS. It also calls for the federal government to require PNT resilience to be considered when selecting contractors.

Space Policy Directive 7 “The United States Space-Based Positioning, Navigation, and Timing Policy” outlines a number of research and other efforts. It also says the nation will:

“Invest in domestic capabilities and support international activities to detect, mitigate, and increase resilience to harmful disruption or manipulation of GPS, and identify and implement, as appropriate, alternative sources of PNT for critical infrastructure, key resources, and mission-essential functions.”

Several board members asked about the Federal Communications Commission’s (FCC) order authorizing Ligado Networks to broadcast in frequencies adjacent to those used by GPS. She said the administration was concerned and both the National Economic Council and National Security Council were in discussion. Engagement with the FCC, though, may pend confirmation of a full board of commissioners.

One of the board members asking about the Ligado issue followed up with a comment that adjacent-band concerns pale in comparison to recent Russian threats to GPS satellites. Durkovich responded that there wasn’t much she could say on that topic in public except that it had the attention of the president and his senior advisors.

Durkovich was also asked about the administration’s commitment to execute the 2018 National Timing Resilience and Security Act. The law’s requirement to establish a terrestrial, wireless source of coordinated universal time to back up GPS signals by December 2020 was ignored by the Trump administration.

Her reply was to reaffirm her earlier statement that “assuring positioning, navigation and timing, and the economic and strategic benefits it brings to this nation, is a priority for this administration.”

Video of the entire advisory board meeting is available on YouTube. MS Durkovich’s remarks begin at approximately 1:37:00. A link to the video is also posted as part of the agenda on the board’s website.

January 4, 2022
GPS coalition asks White House to fix Ligado/5G chaos
The GPS Innovation Alliance (GPSIA) sent a letter on Feb. 16 to the White House National Economic Council, asking it solve the issues with Ligado interfering with GPS spectrum.

“Strong and unified leadership by the U.S. government is needed to preserve and advance GPS — leadership that recognizes the inherently unique functional and technical attributes of GPS,” wrote J. David Grossman, GPSIA executive director, in the letter.

Panel on risks to sat services

GPSIA’s J. David Grossman will be speaking Feb. 17 at 2 p.m. ET, in a panel discussion entitled “Satellite-Based Services at Risk?” Other speakers include former FCC Commissioner Robert McDowell; Capt. Steve Jangelis, representing the Air Line Pilots Association (ALPA); and Susan Avery, former president of the Woods Hole Oceanographic Institution. Register here.

The coalition, which counts Garmin, Apple and John Deere among its members, was ensnared in the dispute between Trump executive branch agencies and the Federal Communications Commission (FCC) over whether the commission’s Ligado approval decision in 2020 would affect GPS.

In the letter to NEC Director Brian Deese, the group argues that these squabbles “are not unique to GPS” and “reflect a continued pattern by which shared decision-making is replaced by the FCC acting with exclusive authority as the final arbiter.”

GPSIA recommends that the council
- update a memorandum of understanding between the FCC and Commerce Department to help ease decision-making;
- install a detailee from federal agencies managing GPS in the FCC’s engineering office; and
- have each FCC commissioner add a technical adviser to its staff.
The letter concludes, “GPSIA and its members stand ready to be a resource to the NEC and others in the Administration seeking to more efficiently allocate spectrum, while protecting critical incumbent systems and services.”
February 16, 2021
2021 Defense Act signals turning point for Congress and PNT
Photo: Toshe_O/iStock / Getty Images Plus/Getty Images

Senate joined House to override Trump’s veto, making bill into law

The U. S. Congress, especially the Armed Services Committees, have long been concerned about GPS and positioning, navigation and timing (PNT) issues. Over the past two decades, Congressional hearings, demands for reports and investigations have dealt with acquisition, contingency plans for when space is not available, deliberate interference, and a host of other issues.

While these all evidenced Congress’ interest and concern, they were relatively passive measures.

This began to change in 2018 with passage of the National Timing Resilience and Security Act. It requires the Department of Transportation to establish a terrestrial timing system to backup GPS signals.

Then in 2019, Congress appropriated money for a GPS Backup Technology Demonstration. And the National Defense Authorization Act (NDAA) for 2020 required the Air Force to develop a prototype multi-GNSS receiver as part of its resiliency efforts.

The NDAA for 2021 seems to finalize Congress’ transition from an interested observer, mostly on the sidelines, to an active player in national PNT issues and policy.

GPS Under Threat

Capitol Hill observers say this is the result of several factors that have come to a head over the last year. Taken together, they have convinced many legislators that GPS is under threat and PNT issues are not being taken seriously enough by the executive branch. These include increased jamming and spoofing (especially by China and Russia), full implementation of China’s BeiDou system and its marketing to other nations as a superior alternative to GPS, the Federal Communications Commission’s (FCC) decision on Ligado Networks, and the Pentagon’s failure to respond to combatant commanders’ Joint Urgent Operational Needs Statements for non-GPS PNT.

Here are some of the provisions of the 2021 NDAA of interest to the PNT community.

Military Multi-GNSS Prototype

The 2018 NDAA required the Defense Department to incorporate Europe’s Galileo and Japan’s QZSS satellite navigation signals into military user equipment. The idea was to make it more resilient to disruption. Also required was an investigation into using non-allied signals.

Apparently not satisfied with progress on this project, Congress mandated a project to develop a prototype multi-GNSS receiver as part of the 2020 NDAA.

The 2021 NDAA seems to indicate Congress is still not happy. It withholds 20% of the funding for the Office of the Secretary of the Air Force until the department certifies the prototype project is underway and provides briefings to the Senate and House Armed Services Committees.

Resilient, Survivable PNT

Language in the 2021 NDAA also seems to show Congress is impatient with the Pentagon’s lack of responsiveness to combatant commanders’ requests for non-GPS PNT systems.

Section 1611 of the act is entitled “Resilient and Survivable Positioning, Navigation, and Timing Capabilities.” It requires development, integration and deployment of these capabilities for combatant commanders within two years. This, it says, is “… consistent with the timescale applicable to joint urgent operational needs statements…”

The act says the new PNT capabilities shall “generate resilient and survivable alternative positioning, navigation, and timing signals” and “process resilient survivable data provided by signals of opportunity and on-board sensor systems…”

The act also addresses the Defense Department’s 2018 PNT Strategy’s plan for future systems to be classified and for military use only. It directs the department to work with the National Security Council, Departments of Transportation, Homeland Security and others “…to enable civilian and commercial adoption of technologies and capabilities for resilient and survivable alternative positioning, navigation, and timing capabilities to complement the global positioning system.”

To help ensure prompt action on this, the act requires a report to Congress within six months and authorizes the department to reprogram funds from other areas to finance the effort.

Responding to Ligado Decision

By far the most PNT-related text in the 2021 NDAA includes a host of measures responding to FCC Order 20-48 approving an application by Ligado Networks. An order that the executive branch is on record as strongly opposing, saying it will degrade GPS service for many.

Senator Jim Inhofe, chair of the Senate Armed Services Committee, has regularly expressed outrage at the FCC’s decision and has called for its reversal.

Among its provisions, the act:
- requires the Department of Defense to estimate and report to Congress the cost of damage to department systems as a result of the FCC order.
- prohibits using department funds to upgrade or modify military equipment to make it resilient to interference caused by broadcasts in the spectrum allocated (the FCC order requires this to be funded by Ligado).
- prohibits contracting with any entity using the frequency bands allocated to Ligado unless the Secretary of Defense certifies the use will not interfere with GPS services.
- requires the Secretary of Defense to contract with the National Academies of Sciences, Engineering, and Medicine for an independent technical review of the FCC order.
Dana Goward is president of the Resilient Navigation and Timing Foundation (rntfnd.org).
January 25, 2021
First Fix: New year, new opportunities for GNSS industry

J. David Grossman

By J. David Grossman
Executive Director
GPS Innovation Alliance

As we embark on a new year, 2021 ushers in a new administration and the start of the 117th Congress. With these changes comes a litany of opportunities, as well as challenges, for the nearly four-decade-old GPS industry.

Next month, the GPS Innovation Alliance (GPSIA) will mark its eighth anniversary as the voice of the GPS industry, educating policymakers and regulators about the GPS success story of innovation, economic growth and job creation. It is a uniquely American story made possible because of bipartisan support for protecting the spectrum used by GPS and maintaining funding to enable the modernization of the GPS constellation, ground control and military ground user equipment.

Congressional Support. This commitment was evident in the last Congress through broad support from both parties for two Congressional resolutions, H.Res.219 and S.Res.216, that affirmed the importance of continuous availability, accuracy, efficiency, robustness, reliability and resiliency of the GPS constellation.

Innovation and modernization of the GPS constellation are well underway. Last year, under the emerging leadership of the U.S. Space Force, two new Lockheed Martin-built GPS III satellites were launched into space. This new generation of GPS satellites offers three times greater accuracy, up to eight times improved anti-jamming capability for military users, and the addition of the L1C signal to enable interoperability with other navigation systems, such as Europe’s Galileo.

GPS modernization also has led to the introduction of M-code, an advanced, new signal designed to improve anti-jamming and anti-spoofing, as well as to increase secure access to military GPS signals for U.S. and allied armed forces. In GPS-denied environments, M-code reduces the jamming radius, giving military planners and targeteers options to minimize or avoid collateral strike damage.

With at least two additional GPS III satellites set to launch this year and a new ground control segment known as the Next Generation Operational Control System (OCX), the continued success of the GPS program remains bright.

Ligado Still Looms

As GPSIA continues to urge Congress to allocate the funding needed to support the modernization of GPS, we also are fighting to ensure uninterrupted operation of the estimated 900 million GPS devices in the United States ranging from precision agriculture to consumer gadgets.

Last year, we were deeply disappointed by the Federal Communications Commission’s (FCC) decision approving the applications of Ligado Networks, despite the well-documented objections of the expert agencies charged with preserving the integrity of GPS, specifically, on the critical issue of what constitutes harmful interference to users of GNSS.

Regrettably, the FCC chose to ignore the established “1-dB Standard,” which has a long history of protecting GPS operations from harmful interference in both international and domestic regulatory proceedings.

“All Americans benefit from a competitive 5G landscape.”

At the same time, Ligado and its supporters continue to argue that their proposal is the fastest way to bring 5G to all Americans. In actuality, millions of Americans already have access to 5G services and, thanks to the efforts of the FCC, hundreds of megahertz of 5G spectrum in low-, mid- and high-band frequencies have been or will soon be made available for commercial use. GPSIA believes all Americans benefit from a competitive 5G landscape.

5G without compromise. However, that goal can be achieved without undermining GPS receivers and devices that are foundational to wireless technology in general, including 5G. We remain hopeful that a new administration and congress will commit to protecting GPS receivers from harmful interference using the appropriate standard for determining such interference to ensure that the more than $1 billion per day in U.S. economic impact created by GPS continues to flourish.

2020 also brought the issue of GPS resiliency into the national forefront. In February, the president signed an Executive Order aimed at fostering greater resiliency for positioning, navigation and timing (PNT)-based systems, including GPS.

GPSIA supported this order and outlined in subsequent regulatory filings why GPS remains the gold standard for delivering PNT functions to our military as well as a wide range of other sectors, including transportation, agriculture, electricity and finance.

Complementing GPS. As the federal government considers alternative PNT solutions, it is critical that they be complementary to GPS, able to easily integrate into current or future devices, and based on a recognition that each PNT application has unique requirements driven by its intended function, environment and design factors. In sum, there is no one-size-fits-all solution.

Protecting Consumer Privacy. Looking ahead, GPSIA expects 2021 will bring a robust discussion around consumer privacy protections. While GPS satellite broadcasts are one-directional and cannot track a user’s location, we recognize that GPS is one of many data points that can contribute to application-specific location tracking. As such, GPSIA would urge Congress to ensure that geolocation data is appropriately addressed as part of any U.S. federal privacy legislation. In doing so, we believe protections for precise geolocation information will empower consumer choice, enhance transparency, and strengthen security.

On the surface, infrastructure modernization, protecting GPS spectrum, PNT resiliency, and consumer privacy may seem like distinctly different issues. What they have in common, though, is an ability to garner bipartisan support, deliver substantial consumer benefits, and strengthen our nation’s economy. GPSIA stands ready as a resource and looks forward to working with the Biden-Harris Administration and leaders in the House and Senate to promote, protect and enhance GPS.

January 7, 2021
Agriculture groups join Keep GPS Working Coalition to reverse FCC Ligado decision

Photo: artiemedvedev/iStock / Getty Images Plus/Getty Images

Several agriculture groups have been added to the Keep GPS Working Coalition, which was launched in June to protect GPS users from harmful interference resulting from the Federal Communications Commission’s (FCC) decision to permit Ligado Networks to operate a terrestrial wireless network in the band adjacent to GPS.

The groups added to the coalition include the Agricultural Retailers Association, American Soybean Association, Equipment Dealers Association, Iowa-Nebraska Equipment Dealers Association, National Corn Growers Association, National Cotton Council of America and USA Rice Federation.

The new members from the agriculture sector join the Association of Equipment Manufacturers, American Farm Bureau Federation, American Road & Transportation Builders Association, Aircraft Owners & Pilots Association and Boat Owners Association of The United States in urging the reversal of the FCC’s Ligado order.

“The FCC’s decision represents a sweeping governmental and regulatory assault on farmers who are already facing unprecedented challenges including severe weather, low commodity prices and supply chain vulnerability as a result of COVID-19,” said Dale Leibach, spokesperson for the Keep GPS Working Coalition. “The order must be stopped. The FCC’s decision must be reversed.”

According to the coalition, farmers are increasingly relying on precision agriculture applications that deliver centimeter-level accuracy that enables farmers to maximize crop yields while lowering costs and environmental impact. Precision farming also reduces costs for consumers, delivers economic benefits for rural economies and enables the efficient production of the foods required to meet a growing global demand for food, fiber and fuel, the coalition added.

“Ag retailers often fill a role as trusted advisor to their farmer customers, suggesting new and emergent technologies in the precision ag space,” said Daren Coppock, president and CEO of the Agricultural Retailers Association. “Without the GPS location services needed for proper planning and implementation of these resources, farmers may not have the tools they need to increase crop yields, lower input loads and decrease inefficacies. ARA stands behind the coalition’s work to protect GPS as a valuable resource to farmers.”

Agriculture industry leaders and a member of the House Committee on Agriculture will participate in a conversation discussing how the FCC’s decision to allow Ligado Networks to operate a terrestrial wireless network will threaten the reliability of GPS receivers used in precision agriculture at 11 a.m. EDT on Oct. 1. Details can be found here.

September 29, 2020