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.”
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).
Ligado application will bring harmful interference to critical technologies
U.S. Representatives Glenn “GT” Thompson (R-PA), Collin Peterson (D-MN) and James Comer (R-KY) sent a letter Nov. 24 to House Leadership and the Appropriations Committee requesting language delaying implementation of the April 2020 Federal Communications Commission (FCC) order granting Ligado’s application to deploy a terrestrial nationwide network to provide 5G services.
In July, the Congressmen expressed serious concerns surrounding the FCC’s decision, questioning the reliability of GPS for millions of Americans, especially the farmers and ranchers who rely on this technology each and every day for precision agriculture.
“Investments in 5G and GPS are critically important to the American economy, especially the agriculture industry,” said Rep. Thompson. “However, the Ligado decision will have negative impacts on GPS and satellite communications, hindering reliability and slowing progress on current and future innovation of this technology. I urge my colleagues in leadership and on the Appropriations Committee to delay this harmful implementation.”
“There is no room for error when discussing safety and reliability of service for GPS signals. Aviation, agriculture, and other vital industries rely on consistent signal quality,” said Rep. Peterson. “Safety and national security issues remain unresolved under the current order, which is why it is vital that we delay Ligado’s 5G deployment.”
“Our farmers are vitally important to providing the food supply for America and the world, and a reliable GPS network is critical to precision agriculture,” said Rep. Comer. “I understand the importance of improving telecommunications operations, especially for advancing rural economies. But critical tools like GPS technology must not be disrupted, as our farmers are essential workers who must have the tools they need to do their jobs. It is our responsibility as policymakers to fight to ensure that federal agency decisions do not negatively impact Americans’ livelihoods. It is my hope that this language to delay implementation of the Ligado order will be addressed in a year-end appropriations package.”
“The FCC’s ill-advised decision on the Ligado matter risks serious negative impacts to the communication of real-time environmental data from satellites that are a primary tool by the American Weather Enterprise in the creation and timely dissemination of accurate weather forecasts and severe weather warnings,” said Jonathan Porter, vice president and general manager, AccuWeather. “Any degradation in these communications will endanger critical economic and societal benefits for weather-sensitive businesses from family farms to large corporations and reduce the ability for people to stay safe during severe weather.”
“GPS is critical to precision agriculture applications that deliver centimeter level accuracy that enables farmers to maximize crop yields while lowering costs and environmental impact,” said Dale Leibach, spokesperson for the Keep GPS Working Coalition. “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. The order must be stopped, and Congressman Thompson and Chairman Peterson have been relentless champions for farmers in the effort to reverse the FCC’s decision.”
“GPS technology is a key component to precision agriculture, a sustainable practice that benefits both farmers and the environment,” said Dennis Slater, president of the Association of Equipment Manufacturers. “The recent Ligado decision will hinder these hard-working Americans from being able to properly utilize the tractors, combines, harvesters, and other modernized equipment we manufacture. We urge House leadership to include language to delay Ligado implementation. Farmers are already struggling due to the pandemic, natural disasters, and other factors. Let’s not add to their economic pain.”
“Protecting the public interest and our economic security requires defending and protecting critical GPS, satellite communications services, aviation navigation equipment and essential weather apparatus. But Ligado’s reckless venture puts that at risk,” said Jordan Hassin, director, Corporate Communications, Public Relations, and Industry Affairs for Iridium Communications. “As more users of services in the L-band discover the threat Ligado presents to their livelihoods, more of our policymakers are recognizing that they need to demand this threat be addressed either in the NDAA or in an end of year spending package. This is not just a defense issue. We are grateful to the leaders of the Agriculture Committee for adding their voices to the call for a change to the FCC’s misguided and destructive decision.”
The document covers a number of details regarding the Ligado Networks and the advancement of 5G.
According to the document, former NASA Administrator Daniel Goldin claims that FCC’s approval of the proposal by Ligado Networks to repurpose satellite spectrum in the L-Band for high-power terrestrial use should be upheld because it will help advance American leadership in 5G technologies.
“Winning the race to 5G — against China and other countries — is important, but Ligado’s proposed network is largely irrelevant to 5G,” the GPS Innovation Alliance said in response. “The availability of Ligado’s spectrum for terrestrial use will not contribute to the advancement of 5G but will instead undermine U.S. Global Positioning System receivers and devices that are foundational to wireless technology in general, including 5G.”
In addition, the GPS Innovation Alliance’s stated in its ex party that the use of L-Band spectrum is not critical for 5G services.
Other points mentioned in the document include that Ligado’s spectrum is not internationally harmonized, significantly diminishing its effectiveness as a 5G band, and that Ligado’s proposed network simply will not offer a 5G service. According to the GPS Innovation Alliance, Ligado merely proposes to offer limited internet of things services, primarily delivered over custom private networks to specific geographic areas for limited vehicular and utility operations. Not only is this not a 5G service offering, but similar services are already being provided by wireless service providers, the alliance added.
On Aug. 19, the U.S. Federal Communications Commission (FCC) granted a request for authorization from AT&T Services to use Galileo for emergency location purposes.
AT&T plans to use Galileo in conjunction with GPS to improve the accuracy of its E9-1-1 location services on mobile devices, and facilitate faster response from emergency services when wireless callers dial 9-1-1.
The request was approved by the FCC’s Public Safety and Homeland Security Bureau .
The FCC found that AT&T had satisfied the conditions for commercial mobile radio service (CMRS) providers to integrate foreign satellite signals into E9-1-1 services.
Under E9-1-1 requirements established in 2015, CMRS providers seeking to use foreign signals for E9-1-1 services must meet several conditions, including ensuring that integrating non-U.S. signals won’t cause interference with the E9-1-1 system.
Carriers also need to submit a signal integration plan including a mechanism to detect, mitigate and disable Galileo signals if they cause harmful interference.
The letter highlights what appears to be different characterizations of the engineering information in the FCC’s record, and suggests that these contrasting statements “support a careful re-examination of the bases of the Ligado Order and a stay of the decision while that occurs.”
“GPSIA appreciates your continued interest and efforts in this proceeding, and your willingness to consider whether a stay of the Ligado order may be appropriate,” the letter states. “As the record in this proceeding makes clear, sound technical analyses were conducted on Ligado’s network by DOT — a neutral third-party U.S. government expert on GPS. Further evaluation of those analyses should prompt the Commission to set aside the Ligado order so that its understanding of the DoT ABC Report can be better aligned with the authors of the report.”
Hold on Third FCC Chairmanship. In a related report, the chairman of the Senate Armed Services Committee Sen. Jim Inhofe (R-Okla.) on July 28 placed a hold on the nomination of O’Rielly to another five-year term chairing the commission.
Inhofe said he would block O’Rielly until the nominee “publicly commits to vote to overturn the current Ligado order,” according to a report from Space News.
“Over the past few months, I have sent letters, held hearings and called countless officials to highlight what we all know to be true: the FCC’s Ligado order is flawed and will lead to significant harm to our military and the thousands of individuals and businesses that rely on GPS,” Inhofe said.
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?
At first it was a flurry of letters and public statements from U.S. senators and members of the house. Then there was a senate hearing on the topic, and the issue was discussed in several other hearings.
The Federal Communications Commission’s (FCC) approval of a long-standing request by Ligado Networks continues to be controversial. The request was to make terrestrial broadcasts on a frequency near that used by GPS. Broadcasts which, according to analyses by the departments of Defense and Transportation, will interfere with GPS reception for many users.
Now it looks as though Congress is ready to move beyond talk and enact one or more pieces of legislation. These would require an independent technical review of the FCC’s decision and place limits on the ability of Ligado Networks to use the license it was granted.
Congressional interest has been fueled both by member concerns and a regular drumbeat of input from constituents. The recently formed Keep GPS Working Coalition is just one example. It was created from a larger group of more than 70 companies and organizations across a broad swath of industries that has gone on record against the decision and has been supporting congressional action.
National Defense Authorization Act
A primary vehicle for congressional action looks to be the National Defense Authorization Act (NDAA) for 2021. Unlike other “annual” legislation that often gets sidetracked or delayed during election years, Congress has passed an NDAA for each of the past 59 years. As such, it is a particularly powerful tool.
This is doubly so in this case, as the member of Congress that has been the most outspoken critic of the FCC’s decision is Senator Jim Inhofe (R-OK). He chairs the Senate Armed Services Committee that has direct responsibility for the NDAA.
Responding to conflicting claims about the findings of government and private tests, the bill requires the Defense department to contract with the National Academies of Science, Engineering and Medicine for an independent technical review.
Evaluating Potential Impact on GPS
Among other things, the review will compare the different methods of evaluating the potential impact on GPS services from Ligado’s transmissions, and determine which of those was the most effective in guarding against any harm.
The bill also prohibits the Defense Secretary from spending any money to comply with the FCC’s order until the Congress has been given an estimate of the total cost to the department of coping with Ligado’s transmissions.
While the FCC order requires Ligado to modify or replace any government receivers impacted by its operations, the Defense department and others have said this is only a small fraction of the overall costs they would incur.
The bill requires the Defense Department estimate to consider a much larger scope of costs including:
To upgrade, repair, or replace potentially affected receivers
To modify, repair, or replace equipment, pares, associated ancillary equipment, software, facilities, operating manuals, training, or compliance with regulations, including with regard to the underlying platform or system in which a capability of the Global Positioning System is embedded; and,
For personnel of the department to engineer, validate, and verify that any required remediation provides the Department with the same operational capability for the affected system prior to terrestrial operation in the 1525 to 1559 megahertz or 1626.5 to 1660.5 megahertz bands of electromagnetic spectrum.
The House version of the NDAA also provides that:
“The Secretary of Defense may not enter into a contract, or extend or renew a contract, with an entity that engages in commercial terrestrial operations using the 1525–1559 megahertz band or the 1626.5–1660.5 megahertz band unless the Secretary has certified to the congressional defense committees that such operations do not cause harmful interference to a Global Positioning System device of the Department of Defense.”
RETAIN GPS and Satellite Communications Act
Senator Inhofe has also announced he will introduce stand-alone legislation when Congress returns from summer recess. His “Recognizing and Ensuring Taxpayer Access to Infrastructure Necessary for GPS and Satellite Communications Act,” or “RETAIN GPS and Satellite Communications Act,” would require Ligado to modify or replace any receiver, including those used by private citizens, that would be impacted by Ligado’s operations.
This modification would be required before the FCC’s order allowing them to transmit could come into force. Most observers opine that the number of impacted civil receivers in the U.S. is so great that this would effectively deny Ligado use of the frequency.
Introduction of the RETAIN GPS and Satellite Communications Act was planned for before the summer recess. Its delay until after was likely to provide more time to recruit co-sponsors.
GPS Interference a ‘Niche’ Issue
One observer commented that “GPS and the FCC Ligado order are really niche issues. As time goes on, more and more members of Congress will hear about it from constituents and be appalled.”
The delay will also allow time for the mammoth NDAA bill to clear Congress. RETAIN GPS would then have more chance for the spotlight.
Many industry observers have opined that regardless of congressional action, Ligado will struggle to find a successful 5G or other business model that will generate a significant revenue stream from the spectrum.
As public concern continues to grow and Congress responds with legislation, it may turn out that Ligado finally won the battle at the FCC but ended up losing the war.
Not surprisingly, the primary topic at the July 1 meeting of the National Space-based Positioning, Navigation and Timing Advisory Board was the Federal Communications Commission (FCC) decision on Ligado Networks.
In it Captain Sullenberger cited many of the issues the board’s vice chair, Brad Parkinson, discussed later in the meeting. Sullenberger’s statement is available here.
In his presentation, Parkinson called the FCC decision “a grave error.” He outlined his rationale in 21 information-packed slides.
Parkinson summarized his presentation up front with three points:
Repurposing the Mobile Satellite Services (MSS) radio spectrum is very high risk and brings virtually no near-term benefit to the United States.
The risks affect much more than the Department of Defense: high-value civil applications are also in jeopardy.
Any such repurposing should have been subject to a formal rulemaking process.
At the end of the presentation, the board voted unanimously to adopt the presentation, with slight modifications, as a reference document for posting on the board’s website.
The group had previously made strong recommendations to the Departments of Defense and Transportation to oppose any such action by the FCC. Both departments have done that and are continuing to do.
Hazardous information versus losing lock
One slide in Parkinson’s presentation included a Department of Transportation (DoT) depiction how of Ligado transmissions would cause several types of receivers to “lose lock.” This graphic was used in a recent DoT presentation to the FCC.
DOT briefing to FCC: “Concerns Over Ligado Order & Authorization,” June 2020. (Slide: DOT)
Heretofore DoT has usually discussed the points at which Ligado transmissions would cause a 25% increase in the noise floor for receivers. This is an important metric as tests have shown that beyond that point many receiver types begin to give hazardously misleading information. DoT officials have used the example that the 1dB limit is like putting a load limit on vehicles crossing a bridge so that the bridge never reaches its breaking point. An important consideration with a safety-of-life application like GPS.
The National Space-Based PNT Advisory Board. (Board photo)
A receiver often gives inaccurate positioning and timing data, possibly hazardously misleading information, before it “loses lock” and stops providing any information at all. It is more difficult for a receiver to “acquire lock” than to track satellites and provide information, so equipment is rarely able to function again until it moves out of the area of interference.
When asked why DoT would bother to show such information to the FCC, one official suggested that loss of lock was more in line with the criteria the Commission used in making the Ligado decision. The hope was that, by showing that even this flawed standard had significant impacts which the FCC perhaps did not fully recognize, further technical discussions and reconsiderations could be realized.
Other Topics
While discussion of the FCC’s decision took the most time in the on-line meeting, several other issues were discussed as well.
Colonel Curtis Hernandez from the National Security Council briefly described development of a new space-based PNT policy to replace NSDP-39 which was put in place by President Bush in 2004.
He was not able to provide any specifics as it is a draft and still under consideration. Answering a question, he did say that the draft policy outlined the responsibilities of various departments, including for interference detection and monitoring.
Adam Balkcum from the Office of Science and Technology Policy discussed his office’s nascent efforts to investigate non-GNSS PNT as directed by the recent Executive Order on Responsible Use of PNT. The question of whether this includes possible PNT services from low earth orbit and geostationary satellites remains an open one.
Other presenters included:
Seth Jonas of the National Security Council staff on the recent Executive Order on Responsible Use of PNT,
Andrew Hansen of the Volpe Transportation Systems Center who spoke about efforts to monitor for GPS interference, especially in the post-FCC Ligado decision environment, and
NASA’s Chris Bonniksen discussed issues with operating and funding the agency’s Global Differential GPS system.
The agenda for the meeting and presentations are available here, as will be the meeting minutes once they have been finalized.
Coalition’s first action is to endorse Inhofe-Reed legislation forcing Ligado to provide financial relief to consumers, industries and other end users
Five organizations representing thousands of companies and millions of Americans have launched a new coalition to protect end users of GPS following the Federal Communications Commission’s (FCC’s) April 22 decision to permit Ligado Networks to operate a terrestrial wireless network using its satellite spectrum.
Ligado’s planned use of its L-band spectrum — adjacent to bands used by GPS — would threaten the reception capability of hundreds of millions of GPS devices, according to the coalition.
American Road & Transportation Builders Association (ARTBA)
Aircraft Owners & Pilots Association (AOPA)
Boat Owners Association of The United States (BoatU.S.)
As its first action, the Keep GPS Working Coalition will endorse the Recognizing and Ensuring Taxpayer Access to Infrastructure Necessary for GPS and Satellite Communications Act, which is expected to be formally introduced this week by Sens. Jim Inhofe (R-Okla.) and Jack Reed (D-R.I.).
GPS IIIF’s M-Code can be broadcast from a high-gain directional antenna in a concentrated, high-powered spot beam, in addition to a wide-angle, full-Earth antenna. (Artist rendering: Lockheed Martin)
The coalition explained in a press release,
The FCC’s decision threatens GPS reliability for countless consumers, farmers, ranchers, pilots, boat owners, surveyors, construction companies and other private GPS users who will be forced to suffer interference to their GPS devices or to pay to replace them.
The FCC admits in its order that there are cases where both government and private GPS receivers — including those that power aviation, agriculture and other key industries — will suffer harmful interference, but failed to provide a technically feasible and adequate remediation solution for consumer and business end users.
The FCC also failed to conduct an open and comprehensive rulemaking process before issuing the Ligado order, instead circulating a final decision only among FCC commissioners while major stakeholders grappled with the COVID-19 pandemic.
Notably, the FCC ignored established technical standards determining whether GPS devices would suffer harmful interference, instead relying on limited studies using vague and impractical criteria to assess interference with the GPS signal, while disregarding mountains of evidence on the topic under the established methodology.
“In issuing the Ligado order, the FCC threw millions of Americans who depend on GPS in their everyday lives under the bus with undue haste and inadequate consideration,” said Dale Leibach, spokesperson for the Keep GPS Working Coalition. “Alarmingly, the commission also ignored concerns raised by Congress and federal agencies — the experts that rely on GPS to protect our national and economic security — including the Departments of Defense, Transportation, Commerce, Interior, Justice and Homeland Security, as well as NASA, the National Science Foundation, the Coast Guard and the Federal Aviation Administration. DOD has even argued before Congress that the interference from Ligado’s network would put missions and troops at risk. It is a highly questionable decision that benefits a single company and its Wall Street investors at the expense of national and economic security.”
“The Keep GPS Working Coalition will ensure that the concerns of end users are represented in this critical public policy debate, joining the chorus of experts sounding the alarm over the Ligado order’s existential threat to GPS technology and urging the FCC to reverse its decision,” the press release stated.
“In the interest of the agriculture, construction, and other off-road equipment manufacturers, the Association of Equipment Manufacturers is taking a firm stance against the recent FCC Ligado decision,” said Kip Eideberg, Senior Vice President of Government and Industry Relations for AEM. “The FCC decision impacts millions of private GPS devices, many of which are used by farmers, contractors and consumers who depend on a reliable connection to plant, harvest, construct and move goods. We thank Senators Inhofe and Reed for their leadership and for introducing this legislation that will begin to address the wrongdoings the Ligado order will cause, and we urge the FCC to reconsider their imprudent decision.”
“America’s farmers and ranchers rely on precision agriculture technology and GPS so their farms and ranches can be more efficient, economical and environmentally responsible. Expanding broadband access is a top priority for Farm Bureau but not at the expense of losing the accuracy of GPS,” said Zippy Duvall, President of AFBF.
“The FCC’s actions threaten the profound improvements GPS has made possible in the construction industry, including increased efficiency, productivity and improved safety,” said Dave Bauer, President and CEO of the American Road & Transportation Builders Association. “ARTBA stands with our fellow Keep GPS Working Coalition members as we aim to reverse the FCC’s decision.”
“Reliable GPS is critical to aviation safety, a fact that was not adequately weighed by the FCC before reaching its decision. AOPA is grateful for the opportunity to represent aviation stakeholders as part of the Keep GPS Working Coalition,” said Jim Coon, Senior Vice President for Government Affairs for the Aircraft Owners & Pilots Association.
“The GPS technology that America’s boaters rely on every day is once again threatened by the FCC’s recent decision,” said David Kennedy, Government Affairs Manager of BoatU.S. “BoatU.S. is honored to be part of the Keep GPS Working Coalition and looks forward to working with the coalition’s other members to protect this critical technology.”
According to the coalition, in addition to requiring Ligado to satisfy additional conditions prior to the order becoming effective, the bipartisan Inhofe-Reed legislation would ensure the costs incurred by businesses and consumers as a result of the FCC’s decision would be covered by the licensee benefiting from the decision — in this case, Ligado.
“The Keep GPS Working Coalition thanks Senators Inhofe and Reed for introducing the Recognizing and Ensuring Taxpayer Access to Infrastructure Necessary for GPS and Satellite Communications Act, which acknowledges the potential harm to GPS end users caused by the Ligado order and ensures the burden of cost sits squarely where it belongs — on Ligado, rather than our farmers, pilots, boat owners, surveyors or construction companies,” said Leibach. “While we strongly urge the FCC to reconsider its position on this matter, we are deeply grateful to Senators Inhofe and Reed for recognizing the tremendous expense and burden the Ligado order places on American businesses and consumers and providing clear and immediate relief to critical stakeholders.”
For more information about the Keep GPS Working Coalition, visit www.keepgpsworking.com.
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.
U.S. Federal Communications Commission (FCC) Chairman Ajit V. Pai has responded to a congressional letter expressing objections to the April 20 FCC decision to allow Ligado to establish a broadband network.
In a May 27 email sent to GPS World, the FCC wrote, “Given your interest in the Ligado order that the Commission adopted unanimously last month, we wanted to share with you the text of the letter Chairman Pai recently sent to members of Congress on this topic.”
The five-member FCC voted unanimously in April to approve an order to allow Ligado Networks to deploy a low-power nationwide 5G network. Experts and policy makers have said the broadband network could — or likely would — interfere with reception of GPS signals.
On May 7, a bipartisan group of 23 members of the House Armed Services Committee (HASC) sent a letter to the FCC questioning the decision, and this is the letter the FCC is now responding to.
The letter from Committee Chairman Adam Smith (D-Wash.) and Ranking Member Mac Thornberry (R-Texas) says the FCC order did not comply with Section 1698 of the National Defense Authorization Act for Fiscal Year 2017. That act prevents the commission from approving commercial terrestrial operations in certain portions of the L-band spectrum until 90 days after the commission resolves concerns of harmful interference to GPS devices.
The Senate Armed Services Committee held a hearing on the topic on May 6 with Department of Defense officials, and on May 15, 32 senators asked the FCC to address their concerns and stay the Ligado approval order while doing so.
“GPS has no right to operate in the spectrum in question, so there is nothing for Ligado to share.” — FCC Chairman Pai
The letter insists that GPS will remain protected. “Although your letter references the shared use of spectrum, the Commission’s L-band decision does not authorize any spectrum sharing between Ligado and GPS. In fact, spectrum in this band has been licensed to Ligado and predecessor companies for over 30 years — with those companies authorized to deploy terrestrially since 2004. And as mentioned above, one of the FCC’s conditions require separation of Ligado’s operations from GPS spectrum by means of a 23-megahertz guard band. Thus, any implication that the Commission has authorized Ligado to “share” spectrum that is currently allocated to GPS is incorrect. GPS has no right to operate in the spectrum in question, so there is nothing for Ligado to share.”
Download the full letter to Rep. Smith here. Download HASC letter to the FCC here.
The email to GPS World included the following statement: “The FCC is required by law to make its decision based on the facts in the record, and federal agencies, including the Department of Defense, were provided with multiple opportunities to put whatever facts they believed to be relevant into the record, including classified information, which the Commission has a process in place to protect.
“The Commission based its decision on all of the information in the record. Moreover, we are not aware of the FCC refusing any request by the Department of Defense to provide a briefing related to this matter.
“To the extent any federal agency opposed to the Ligado application chose not to share information with the Commission, that was the agency’s decision and suggests that it did not believe that the information in question would bolster its case.”
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.
