A new letter has been sent to both President Biden and congressional leadership by 90 groups opposed to Ligado’s plans to launch a terrestrial network in the L-band used by GPS.
The letter, dated April 25, marked the two-year anniversary of a controversial decision by the U.S. Federal Communications Commission (FCC) to adopt the Ligado Order.
The 90 groups represent companies, organizations and associations united in their grave concerns over “imminent — but preventable — harm from Ligado’s proposed terrestrial network.” These groups have serious concerns about how Ligado’s plan threatens to interfere with services provided by the GNSS, aviation and real-time environmental satellite-data communities.
Staying the order is necessitated by the clear bipartisan will of Congress. After adoption of the order in 2020, Congress mandated an independent technical review to further assess the harmful interference that would be caused by Ligado’s proposed network and required the Department of Defense to brief federal representatives across the government “at the highest level of classification” on the potential for widespread harm from Ligado’s proposed terrestrial operations.
On this basis alone, the FCC should stay the order to adequately consider the material new information that will be uncovered as a result of these ongoing Congressionally mandated processes, according to the letter writers.
Their concern was made even more real following the announcement by Ligado that the company intends “to commence operations in the 1526-1536 MHz band on or after Sept. 30, 2022.”
To comply with Federal Communications Commission (FCC) E-911 regulations, Qualcomm Technologies has enhanced its Qualcomm Location Suite to provide improved horizontal and vertical positioning information. The upgrade will help first responders better determine the floor within a multi-story building from which an emergency call was placed.
The Qualcomm Location Suite is deeply integrated with Qualcomm’s Snapdragon Mobile Platforms and Snapdragon Modem-RF Systems that power millions of mobile devices in the U.S. The suite has supported emergency location services in the U.S. and globally for two decades.
The change will help mobile service providers comply with new E-911 regulations requiring that the horizontal and vertical position of each wireless caller be determined with a certain level of precision.
The Qualcomm Location Suite uses GNSS with network-based positioning and dead reckoning to deliver accurate location with speed and efficiency. GNSS assistance is delivered over cellular or Wi-Fi, LTE and 5G-NR terrestrial positioning; cellular/Wi-Fi-based location is also provided.
When an emergency call comes in, operators rely on a combination of triangulation of wireless signals and device positioning technologies, such as GPS, to provide the position of the caller. The use of technologies in the Qualcomm Location Suite is designed to result in highly accurate positioning information and the ability to share this reliable information with first responders, allowing them to reach the precise emergency site more quickly.
Guided by the leadership of the U.S. Air Force, and now the Space Force, for four decades GPS has supported all aspects of military operations, from precision guided munitions to search and rescue missions. GPS, however, is also ingrained in our economy, enabling a wide range of civil and consumer applications, including aviation, precision agriculture, construction, banking and public safety.
It’s easy to take GPS for granted, because we use it every day and it works so well. But what if someone interfered with the reliability and accuracy of GPS on which we depend? A 2019 study sponsored by the National Institute of Standards and Technology (NIST) estimated a $1 billion-a-day impact to our economy if GPS were lost.
Regrettably, the Federal Communications Commission (FCC) rolled the dice on this scenario in 2020, when it approved an application from Ligado Networks, a satellite communications company, to repurpose satellite spectrum in the L-band for high-power terrestrial use.*
Ignoring the warnings of a broad coalition of stakeholders, including U.S. federal agencies, congressional leaders and businesses, the FCC moved to open the traditionally “quiet neighborhood” used by satellite-based navigation services like GPS to ground-based signals that are billions of times more powerful.
The FCC itself was clear on the risks when it issued the order, and so it’s no surprise they explicitly required Ligado to “repair or replace as needed any U.S. government GPS devices that experience harmful interference from Ligado’s operations.” At the time, however, a key constituency was excluded from these protections: the millions of U.S. consumers and businesses who rely on accurate, reliable GPS signals.
In fact, 99% of the more than 900 million GPS devices found in the United States are used by the private sector, consumers, as well as state and local governments. Under the FCC’s order, first responders, pilots, municipal governments, farmers and countless other GPS users have been left on the hook for costs associated with Ligado’s disruptions.
On June 22, a bipartisan group of senators, led by Sen. Jim Inhofe (R-OK), took a critical step toward addressing this inequality by introducing the Recognizing and Ensuring Taxpayer Access to Infrastructure Necessary for GPS and Satellite Communications Act (RETAIN Act). A bipartisan House companion bill was subsequently introduced on July 22. This carefully balanced proposal ensures that Ligado, as the license holder and source of interference, is the one responsible for paying the costs to upgrade or replace affected GPS receivers used by consumers and businesses.
Across the country, GPS is woven into the fabric of the economy and people’s everyday lives. More than 100 million vehicles are equipped with a GPS receiver, and trains and aircraft use GPS to move people and goods. Our farms depend on GPS to increase crop yields and reduce waste. Similarly, with accurate and reliable GPS,
America’s bridges, and roads are being built more accurately, improving safety, and reducing construction times.
The RETAIN Act also protects municipal fire crews that depend on GPS for improved situational awareness and to speed response times to people in danger. In the critical moments between a 911 call and the arrival of firefighters, seconds matter. An unexpected loss of GPS could therefore be catastrophic. This is why GPSIA and more than 100 industry organizations and companies are supporting the RETAIN Act.
The RETAIN Act also considers the thousands of businesses that are showcasing their grit and ingenuity to bounce back from the COVID pandemic. Many of these companies are implementing GPS-enabled solutions, including app-based delivery and contact-tracing tools to increase efficiency and protect the safety of their employees.
The GPS Innovation Alliance, an organization committed to furthering GPS innovation, creativity and entrepreneurship, is grateful to these leaders in Congress who are standing up in support of GPS users.
Consistent with the terms of their litigation settlements with Ligado, Garmin International Inc. and Deere & Company do not affirmatively endorse or oppose the deployment of Ligado’s proposed mobile communications network. To the extent this op-ed discusses Ligado’s deployment of its proposed 5G mobile communications network (or any interference therefrom), GPSIA is not authorized, and does not purport, to speak for Garmin and Deere.
In letters sent today to the White House and U.S. Congress, more than 90 organizations representing a broad range of industries urged President Biden and members of Congress to set aside the Ligado Order approved during the previous administration.
The industries urged the president and lawmakers to work with the Federal Communications Commission (FCC) to “stay and ultimately set aside the Ligado Order,” saying that it “poses significant threats to the reliability of GPS for millions of Americans.”
“The risk to American lives and to the American economy are simply too great,” the group wrote in the letters.
“A year ago today, the FCC made the dangerous and misguided decision to allow Ligado Networks to operate a terrestrial network on frequencies adjacent to GPS despite threats to GPS reliability and the concerns of Congress and virtually all federal agencies that rely on GPS to protect our national and economic security,” said Dale Leibach, spokesman for the Keep GPS Working Coalition.
“We are hopeful that under the new administration, something can be done to stop Ligado from proceeding with its plan and we are extremely thankful to the many members of Congress and government officials who have rightly pointed to the very harmful impact this decision will have on countless consumers, farmers, ranchers, pilots, boat owners, surveyors, engineers and construction companies if it is not reversed,” Leibach said.
Vote would make mid-band spectrum available for 5G
The Keep GPS Working Coalition issued the following statement in support of an anticipated March 17 vote by U.S. Federal Communications Commission (FCC) commissioners that would make the 3.45–3.55 GHz band a contiguous block of “mid-band” spectrum, available for auction and deployment of high-speed wireless 5G networks.
“The Keep GPS Working Coalition applauds the FCC for its consideration of this matter, which holds promise as a crucial step in the race to 5G and presents an opportunity for advancement without threatening the availability and reliability of GPS. We encourage the FCC to use this as an opportunity to showcase a bipartisan commitment to moving expeditiously to make this mid-band spectrum available for auction by early October.
“The Department of Defense has also demonstrated its sustained commitment to advance the deployment of 5G services. We are grateful to the DoD for its leadership and cooperation with the FCC to make spectrum available for commercial use where it can while protecting national defense interests.
“The spectrum being considered for auction is internationally harmonized and can be used nearly everywhere in the continental United States to the benefit of the entire country, including Keep GPS Working Coalition members. Importantly, it will advance this critical priority without the risk of harmful interference to GPS currently posed by Ligado Networks, proving that 5G and GPS can coexist.”
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.
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.
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.
The five-member FCC voted unanimously in April to approve an order to allow Ligado Networks to deploy a low-power nationwide 5G network.
“The hurried nature of the circulation and consideration of the Order itself — during a national crisis, no less — was not conducive to addressing the many technical concerns raised by affected stakeholders,” wrote the senators.
The senators continued,
“With this specific docket item pending before the FCC for almost 10 years, we are concerned with the pace by the Commission to push through an Order first announced on April 16, the approval for which was declared two business days later. We believe this accelerated timeline was not adequate to address the significant stakeholder concerns for an Order of this magnitude….”
“We are concerned that the FCC has discounted testing and assessments conducted by nine federal agencies in the Interdepartment Radio Advisory Committee process — all expressing concerns that the Ligado plan would interfere with millions of GPS receivers and satellite services across the nation. Further, the FCC did not provide a technical forum to resolve the significant disconnects between this testing and Ligado’s privately funded testing…”
“For these reasons, we urge the Federal Communications Commission to immediately stay and reconsider their Order on this matter, more fully consider the technical concerns raised by numerous federal agencies and private sector stakeholders, and outline a path forward that adequately addresses these concerns.”
A Resilient PNT Foundation editorial on the organization’s website says the main problem seems to be misunderstanding about the differences between radionavigation and communication.
“We share the concerns with the FCC’s actions that are outlined in this letter:
After ten years of deliberations a draft order was processed to a final decision within a couple days during a national crisis
The FCC discounted the testing done by the executive branch and did not say why
No technical forum was held to resolve the differences between Ligado’s and DoD/DoT’s testing
There was no public discussion of these differences and how they might be resolved
“Undoubtedly, a lot of the differences between the FCC and the Executive Branch on this issue boil down to a lack of appreciation of the fundamental differences between wireless communication and radionavigation.” The Resilient PNT Foundation website provides a table outlining the differences.
“When two parties start from completely different places, they are likely to talk past each other and end up in completely different places.
“We think the Federal Communications Commission might not have fully appreciated the needs of radionavigation as a safety-of-life utility and wound up in the wrong place.
“But that’s just us. A lot of folks think differently.
“That’s why we are urging an independent technical review, with both communications and radionavigation experts, to inform public policy decisions on this before anything moves forward.
“This is too important to get wrong.”
Feature photos: Capitol building with flag/Andrea Izzotti/Shutterstock.com Capitol building at night/Brian Kinney/Shutterstock.com
Leaders in the GNSS/PNT community are reacting to the Federal Communications Commission (FCC) decision to approve an order to allow Ligado Networks to deploy a low-power nationwide 5G network. The departments of Defense and Transportation have criticized the decision, concerned about interference with GPS signals.
Below are statements we have received from our readers.
Logan Scott, LS Consulting
Logan Scott
Spectrum regulation is much like land use zoning in that certain services are kept separate so as to avoid disturbing the neighbors. The FCC has in effect allowed Ligado to build an outdoor concert venue next to a monastery and by way of compensation, they offer free earplugs. GPS / GNSS signals are extremely weak and the receivers are extremely sensitive. To give some perspective, by the time they get to the GPS receiver, GPS signals are about a factor of 20 less powerful than cosmic background noise. Ligado’s spectrum is/was licensed for mobile satellite services (MSS) and so was not likely to interfere with GPS.
With their new, and much more valuable license, Ligado now has a legal right to build a terrestrial cellular service. Exhaustive testing over the last 10 years has repeatedly demonstrated that such a system will interfere with high precision GPS/GNSS receivers used in surveying, timing, and earth observation. The DoD has also made strong claims that such a system will cause harm to their systems. In all cases, the effect is much like riding a bicycle at night. You can see fine until someone comes around the corner with the high beams on and blinds you.
The FCC has in effect allowed Ligado to build an outdoor concert venue next to a monastery and by way of compensation, they offer free earplugs.
In their earlier filings, Ligado had asked for permission to transmit at a power level of 1500 Watts. In an amazing piece of legerdemain, they convinced the FCC, but not the DoT or DoD, that by reducing transmit powers to 10 Watts, there would be no harm. This is a stunningly erroneous claim. As you lower the transmit power, you need many more cellular basestations to cover a given area. To use an analogy from my backyard, I can install one high flow sprinkler head to cover the entire yard or a bunch of low flow heads, each covering a small portion. Either way, the grass doesn’t care about anything other than inches of water and I’m gonna get wet if I run across the yard. Ligado’s core argument is equally wet. Nonetheless, it has great appeal to people who don’t understand how cellular systems work.
So, moving forward and assuming the license stands, interference events will become more prevalent and GPS will be deemed “less reliable”. Because interference sources are largely untraceable, blame will rarely attach to Ligado. I expect that GNSS receiver vendors will incorporate improved filters into receivers and pass the cost along to buyers. Ligado, or more likely whoever they sell the spectrum to, will quickly move to petition for increase transmit powers so as to lower capital costs; after all more basestations cost more. And so, the Visogoths have arrived, 4G in hand with a 5G label.
John Fischer, Orolia
John Fisher. (Photo: Orolia)
At Orolia, we support the position of the DOT, DHS and DOD and the measures they are taking to protect the GNSS band. However, interference is a fact of life in this band as the GNSS signals are very weak, so additional measures must be taken for resiliency, especially for critical infrastructure. Adversarial interference is much worse than this, so a range of solutions are possible: from the simple – for example, a horizon blocking antenna that shields energy from a nearby tower – to full multi-layer defenses that include RF filtering, advanced DSP filtering/detection, alternative PNT from STL signals, atomic clock and IMU backup, and CRPA antennas. No one solution covers every case, but the problem can be managed.
Mitch Narins, Strategic Synergies
Mitch Narins
It is quite concerning when a panel of lawyers makes a decision, despite the results of years and years of studies, and over the objections of our nation’s technical and operational Position, Navigation and Timing (PNT) experts. While I have championed the need for a complementary and resilient PNT system for many, many years, one cannot dispute the worldwide benefits that GPS and other GNSS have brought — from safety, security, and economic perspectives.
As noted in the FCC’s press release, “The order also requires Ligado to protect adjacent band incumbents by reporting its base station locations and technical operating parameters to potentially affected government and industry stakeholders prior to commencing operations, continuously monitoring the transmit power of its base station sites, and complying with procedures and actions for responding to credible reports of interference, including rapid shutdown of operations where warranted.” I believe that it is imperative that GPS users, both within the Government and in the private sector, understand:
How base station location information will be disseminated, what power levels and radiation patterns will be utilized, and what recourse GPS users will have to object to the proposed location and service;
How the service will be monitored for each base station location, what systems will be used to do the monitoring, and how the monitoring information will be publicly disseminated;
How reports of interference will be filed, how and by whom they will be determined to be “credible”, how and in what timeframe will a “rapid shutdown of operations” be accomplished, and how appropriate mitigations will be identified and implemented; and
Given the importance and concern associated with this action, what special oversight mechanisms, involving civilian and military participants, should be put in place to avert potential safety, security, and economic impacts to our nation’s critical infrastructure.
While one can model, and even test problems based on the location of facilities where aircraft would be expected to be operating close to the ground (e.g., airports and heliports), one can never be sure where a medevac or other first responder helicopter may have to set down in response to an accident or incident site. In keeping with the FCC’s own press release, it is unclear how a pilot experiencing problems with GPS (if, in fact the pilot could recognize such a problem) would be able to report the issue and have it mitigated in real time to support a safety or security mission — unless all areas around all ground transmitters were mapped and first responders could request specific ones to be turned off when operations were expected in a known area. Unfortunately, the limits of these operating areas are, many times, unknown or rapidly changing (e.g., forest fires) and any delay in reaction to unforeseen events could prove detrimental to safety, security, and economic wellbeing.
Mitre conducted a test wherein small Unmanned Aerial Systems (sUAS) could detect and avoid an aircraft based on receipt of its ADS-B squits. Perhaps these ground transmitters should include ADS-B receivers and automatically go off-air if a helicopter comes within a certain distance. I have no doubt that Ligado would not appreciate this solution …
I would hope that those who disagree with this decision will seek out a means to correct this through either the legislative or judicial branches or both. Personally, I cannot see how this either “promotes the general welfare” or “provides for the common defense” (I didn’t have to go to law school to come to those conclusions). I also believe that (1) the ever growing importance and criticality of PNT services should provoke the Congress to modify the makeup of the FCC to include PNT expertise at the very top; and (2) the FCC Office of Chief Engineer needs to become an independent point of expertise akin to the Office of Inspector General to preclude undue pressure and potential political “bending” of technical analyses.
Finally, regardless of whether one agrees or disagrees with the FCC’s order, no one can possibly believe that this decade-long tale of woe is an example of governmental “best practice.” As it took the energy and significant resources from so many more important PNT initiatives, I hope that a quality/leadership body (perhaps GAO and/or a group of IGs) take up the task to do an independent “lessons learned” assessment of this decade-long tale of woe needs to be carefully examined, as it took the energy and significant resources from so many more important PNT initiatives — we should never have to go through this ever again.
Mitch Narins is the principal consultant and owner of Strategic Synergies, LLC, a technical and management consulting firm that he formed after retiring following over four decades of U.S. government service with the FCC, US Navy/Marine Corps, and the Federal Aviation Administration.
Alison Brown
Allison Brown
GPS user equipment needs to be designed to be more resilient to interference. The threat to GPS has been well understood for many years but agencies and vendors have been slow to respond to improve national resiliency against jamming threats. The President signed into law the National GPS Timing Resilience and Security Act in 2018 and on 2/12/2020 signed an Executive Order on Strengthening National Resilience through Responsible Use of Positioning, Navigation, and Timing Services recognizing “the disruption or manipulation of these services has the potential to adversely affect the national and economic security of the United States.” The onus is now on vendors and agencies to develop resilient solutions that can operate in the presence of intentional and unintentional interference. These solutions would also mitigate any potential impact from the use of adjacent bands by operators such as Ligado to deploy 5G and Internet of Things services.
Ellen Hall
Ellen Hall
Overall, the GPS industry should be encouraged to do more to protect themselves from harmful interference. While it is too late for today’s receivers, the next generation needs to introduce more resilience. I agree with the House Armed Services Committee Chairman in saying, “While I strongly support development of the world’s most robust, safe and secure network, using L-band spectrum in such close proximity to critical GPS, as Ligado’s proposal requires, carries an unacceptable risk….”
The FCC said the approval order included stringent conditions aimed at ensuring that GPS would be vulnerable to harmful interference. It seems the only way to prevent harmful interference, would be to permanently fund an oversight commission to monitor Ligado’s system. I believe only Congress can appropriate funding for this effort, therefore the FCC’s decision should be a recommendation to Congress to implement. It is not enough to leave it to a five-person committee to “encourage” that “stringent conditions” are implemented. Enforcement is crucial. Critical infrastructure should be regulated to ensure that we can cope better with “noisy neighbors.”
The five-member Federal Communications Commission (FCC) voted unanimously to approve an order to allow Ligado Networks to deploy a low-power nationwide 5G network.
The approval comes despite objections from the U.S. Defense Department (DOD), other federal agencies and major U.S. airlines, all of whom are concerned about near-band interference with GPS.
The FCC said the approval order included stringent conditions aimed at ensuring GPS would not experience harmful interference.
“After many years of consideration, it is time for the FCC to make a decision and bring this proceeding to a close,” said FCC Chairman Ajit Pai in an April 16 news release. “We have compiled an extensive record, which confirms that it is in the public interest to grant Ligado’s application while imposing stringent conditions to prevent harmful interference.”
Ligado is seeking to repurpose a swath of L-band spectrum for a 5G network focused mainly on connecting smart devices and other internet-of-things services. According to the FCC, the order will “promote more efficient and effective use of our nation’s spectrum resources and ensure that adjacent band operations, including the Global Positioning System (GPS), are protected from harmful interference.”
In response, members of both the Senate and House Armed Services Committees and other defense advocates are considering legislative action to overturn the order.
Two areas that rely heavily on the integrity of GPS signals include defense and transportation. The DOD issued a joint statement with the Department of Transportation (DOT) criticizing the FCC ruling.
“Americans rely on our Global Positioning System (GPS) each day for many things: to locate citizens in need of emergency assistance through our E-911 system, to secure our financial system, to order and receive shipments, to travel by car for work and leisure, to facilitate commercial trucking and construction work, and even to make a simple cellphone call. Our departments rely on GPS each day for all those reasons as well to coordinate tactical national security operations, launch spacecraft, track threats, and facilitate travel by air and sea. The proposed Ligado decision by the Federal Communications Commission will put all these uses of GPS at risk.”
House Armed Services Committee Chairman Adam Smith (D-Wash.) released a letter he sent to Defense Secretary Mark Esper and FCC Chairman Ajit Pai raising concerns about Ligado’s 5G network.
“While the United States must be a leader in the implementation of 5G networks, our creation of these networks must not hamper our military’s operational capacity in any way. China’s aggressive, global promotion of its 5G companies presents a considerable security challenge that must be addressed. However, Ligado’s proposal, which seeks a portion of spectrum adjacent to that used for Global Positioning Systems, poses an even larger security risk.
“The Department of Defense has been clear and direct: providing this license to Ligado would cause unacceptable operational impacts and adversely affect the military’s use of GPS. The military’s seamless use of GPS is vital to our national security. Our service members rely on GPS satellites for critical precision timing and navigation, and thousands of weapons systems are embedded with GPS signals.
“While I strongly support development of the world’s most robust, safe and secure network, using L-band spectrum in such close proximity to critical GPS, as Ligado’s proposal requires, carries an unacceptable risk that far outweighs the possibility of a 5G network.”
‘Risk of crippling’ GPS
Defense Secretary Mark Esper said via Twitter on Friday that the “Ligado proposal would needlessly imperil GPS-dependent national security capabilities. The Department continues to support domestic 5G options, but not at the risk of crippling our GPS networks. Nearly a dozen other federal agencies have joined us in opposing this proposal.”
“Although I appreciate the concerns that have been raised by certain Executive Branch agencies, it is the Commission’s duty to make an independent determination based on sound engineering. And based on the painstaking technical analysis done by our expert staff, I am convinced that the conditions outlined in this draft order would permit Ligado to move forward without causing harmful interference. For example, the draft order would authorize downlink operations at a power level that represents a greater than 99% reduction from what Ligado proposed in its 2015 application.”
Image: A-Digit/DigitalVision Vectors/Getty Images
The release also provided this background about the Ligado proposal, and the “conditions” under which the FCC decided to approve it.
In recent years, Ligado has amended its application to significantly reduce the power levels of its base stations from 32 dBW to 9.8 dBW (a reduction of 99.3%). Ligado has also committed to providing a significant (23 megahertz) guard-band using its own licensed spectrum to further separate its terrestrial base station transmissions from neighboring operations in the Radionavigation-Satellite Service allocation. As such, Ligado is now only seeking terrestrial use of the 1526-1536 MHz, 1627.5-1637.5 MHz, and 1646.5-1656.5 MHz bands. The Order is conditioned to reflect these technical requirements. It also requires Ligado to protect adjacent band incumbents by reporting its base station locations and technical operating parameters to potentially affected government and industry stakeholders prior to commencing operations, continuously monitoring the transmit power of its base station sites, and complying with procedures and actions for responding to credible reports of interference, including rapid shutdown of operations where warranted.
However, The decision “appears to ignore the well-documented views of the expert agencies charged with preserving the integrity of GPS, specifically on the critical issue of what constitutes harmful interference to users of Global Navigation Satellite Systems (GNSS),” said J. David Grossman, executive director of the GPS Innovation Alliance (GPSIA). He continued,
J. David Grossman
“GPSIA has consistently advocated for adoption of the 1-dB Standard as the only reliable mechanism that provides the predictability and certainty to ensure the continuation of the GPS success story, with the support of the Department of Defense, the Department of Transportation and numerous other federal agencies. The 1-dB Standard for radiofrequency-based services is critical for GNSS. The FCC’s press release refers to conditions placed on Ligado’s application to prevent harmful interference, and GPSIA and its members intend to carefully review the details of today’s order while continuing to vigorously advocate for promoting, protecting and enhancing GPS.”
Ligado Networks President and CEO Doug Smith issued this statement in reaction to the approval.
“Ligado thanks the Commissioners for moving promptly to approve the order regarding our applications. We greatly appreciate their unanimous support as well as the expert engineering analysis determining that a terrestrial network can be deployed in the L-band to advance our country’s economic and security interests while fully protecting GPS. Our spectrum can be very instrumental in the transition to 5G, and we look forward to utilizing satellite and terrestrial services to deploy customized private networks and deliver innovative, next-generation IoT solutions for the industrial sector.”
Positive reactions to the decision
On April 20, the FCC released a compilation of responses to the decision, all of them in support.
Attorney General Bill Barr: “I applaud FCC Chairman Pai’s proposal to make available L-band spectrum, to be used together with C-band spectrum, for deployment of advanced wireless services, including 5G. As I said in my speech at the Center for Strategic and International Studies, swift FCC action on spectrum is imperative to allow for the deployment of 5G. This is essential if we are to keep our economic and technological leadership and avoid forfeiting it to Communist China.” (Statement, 4/16/2020)
Secretary of State Mike Pompeo: “I commend Federal Communications Commission (FCC) Chairman Pai’s draft order that would release the L-Band spectrum. Quick action on this order, in conjunction with the allocation of a portion of the C-Band for 5G, is vital to our national security and will help ensure that the United States is the global leader in advanced technologies such as AI, the Internet of Things, edge computing, and the next generation of telemedicine. Accelerating the deployment of 5G is essential to our country’s growth, and global economic security.” (Statement, 4/16/2020)
Sen. Ron Johnson (WI): “In a time when connectivity is and will continue to be more important than ever, it’s great to see @AjitPaiFCC move forward with freeing up critical spectrum resources for #5G.” (Tweet, 4/16/2020)
Sen. Mark Warner (VA): “As the U.S. works to lead the world in 5G innovation and promote wider high-speed internet coverage, it’s all the more important to put our valuable mid-band spectrum to use. I urge the @FCC to follow the Chairman’s lead and approve Virginia-based @LigadoInsights’s application.” (Tweet, 4/16/2020)
Rep. Billy Long (MO): “I applaud @AjitPaiFCC and the @FCC for taking action to unlock vital L-band spectrum that has been held hostage by bureaucratic slow-walking for far too long. Jobs and 5G is a win-win for the country.” (Tweet, 4/16/2020)
Rep. Doris Matsui (CA): “I called on the @FCC to move forward with new, innovative uses of L-band spectrum to advance 5G. Glad to see the Commission take action on this front today to encourage efficient use of our spectrum.” (Tweet, 4/16/2020)
Former Rep. Bob Barr (GA): “Federal Communications Commission Chairman Ajit Pai’s decision to circulate a draft FCC Order would at long last move forward the process of opening up a segment of mid-band satellite spectrum for commercial use in 5G technology deserves praise. … If adopted by the five-member Commission headed by Pai, the draft Order would tangibly signal to the country and the world that the United States is committed to seize the leadership in deployment of 5G technology, a role China openly covets.” (Statement, 4/16/2020)
American Action Forum: “More good news from the FCC! 5G is incredibly important and this is yet another example of actions that will enable innovation in 5G and support the growing number of connected devices.” (Tweet, 4/16/2020)
American Enterprise Institute Visiting Scholar Mark Jamison: “@FCC approval of Ligado petition should accelerate 5G, bring diversity to marketplace, and increase efficient spectrum use. … Good leadership and bipartisan effort!” (Tweet, 4/20/20)
American Enterprise Institute Visiting Scholar Roslyn Layton: “Kudos @AjitPaiFCC for unlocking more vital mid-band spectrum for #5G. Record of 10 years shows @LigadoNetworks took many steps with agencies and firms to address potential issues with GPS. We must move quickly on 5G!” (Tweet, 4/16/2020)
Citizens Against Government Waste: “The FCC has the engineering expertise to determine the best use of this spectrum and whether alternative uses would cause undue interference. The adoption of the Chairman’s draft order will promote 5G and IoT development, while providing the necessary safeguards for services using adjacent bands, including GPS positioning. … The L-band would not be used at all for the foreseeable future unless the FCC takes action. Freeing up the spectrum requested by Ligado will not only expand the use of 5G, it will also help to prevent other countries, particularly China, from getting ahead of the U.S. in 5G deployment.” (Blog, 4/17/2020)
Competitive Carriers Association: “[We] commend Chairman Pai for circulating a draft order to approve Ligado’s applications, which will make much-needed mid-band spectrum, specifically L-band spectrum, available for terrestrial use. This long-awaited, positive progress comes at a critical time for all Americans, particularly those in rural areas, who are relying on mobile connections and services more than ever before. Mid-band spectrum provides real opportunities for deploying next-generation technologies, and competitive carriers are eager to access this valuable resource to expand and enhance their networks.” (Statement, 4/16/20)
Competitive Enterprise Institute: “Access to spectrum is crucial for our modern economy, connecting everything from radios, to cellphones, to satellites. But for too long, turf-wars between federal regulatory agencies have left spectrum bands largely unavailable for valuable commercial applications. Today’s FCC decision wrests spectrum away from bureaucratic waste and delivers it into the hands of people who will aide our economic recovery and resiliency in the aftermath of the COVID-19 pandemic.” (Statement, 4/16/2020)
CTIA—The Wireless Association: “We’re pleased to see that the FCC has managed to cut through the red tape to make a decision on Ligado. This multi-year process reveals the challenges at play in our nation’s spectrum policy and the need for stronger support for new commercial wireless services. We need to all learn lessons from this process and ensure that decisions on key spectrum bands like lower 3 GHz occur in a more expedited and collaborative manner.” (Statement, 4/16/2020)
FreedomWorks: “Freeing up broadband spectrum will make America a global technological leader and will lead to innovations and developments that will improve quality of life across the country. Chairman Pai and the FCC should be applauded for their work resolving these matters[.]” (Blog, 4/15/2020)
Free State Foundation: “Chairman @AjitPaiFCC has made a commendable decision to act on @LigadoNetworks’ proposal to put L-band spectrum into use for next-gen wireless services. This move takes seriously the @FCC’s responsibility and the urgent need for more commercial spectrum.” (Tweet, 4/16/2020)
Georgetown Law Institute for Technology Law & Policy Distinguished Fellow Gigi Sohn: “This decision was a long time coming, but it’s the right one. … Kudos to @AjitPaiFCC for having the fortitude to move this forward.” (Tweet, 4/16/2020)
Information Technology & Innovation Foundation: “Great to see @FCC taking steps to finally approve @LigadoNetworks waiver for terrestrial use of their spectrum. This will be a boon to industrial IoT connectivity, bringing more productivity, safety, and resiliency for users of the network.” (Tweet, 4/16/2020)
International Center for Law & Economics: “Promoting deployment of 5G & next-gen IoT devices means finding new ways for incumbents to responsibly operate in ever-closer proximity. The @FCC’s Ligado order does that. Credit to @AjitPaiFCC for finding a way fwd that promotes innovation while limiting the risk of interference.” (Tweet, 4/16/2020)
Lincoln Network: “Access to spectrum is an essential feature in any working 5G plan. Frankly, one key barrier in opening up this vital resource is government’s stronghold on ‘beachfront’ spectrum whether they own it or not. … This proceeding has been in regulatory limbo for several years due in large part to government stakeholders’ speculative interference claims regarding GPS-applications. … The FCC’s draft order in this proceeding provides enough protection for incumbents in adjacent bands, adds more competition into the 5G-IoT space, and allows consumers to have more access to broadband. Everybody wins.” (Blog, 4/16/2020)
Mercatus Center Senior Fellow Brent Skorup: “Too often new tech is stalled by FCC regulation and incumbents. Chairman Pai pledged to breathe new life into Sec. 7. It’s great to see Chairman Pai and the FCC act on that pledge, liberalize spectrum, and expedite the deployment of new wireless services.” (Tweet, 4/16/2020)
National Security Institute: “Big move by @FCC Chairman @AjitPaiFCC today to support US 5G availability. This is a key nat sec issue w/ threat posed by China + econ benefits of broad 5G deployment in US.” (Tweet, 4/16/2020)
New America Foundation’s Open Technology Institute: “Kudos to @AjitPaiFCC @FCC for again standing up to Fed agencies trying to hoard spectrum they are not using – or, in this case, which is licensed to @LigadoNetworks! A big plus for #5G wireless ecosystem if it’s built out.” (Tweet, 4/16/2020)
R Street Institute: “If you can change your business model to be more productive and profitable, without hurting anyone else, then regulations shouldn’t stand in your way. Well done, @FCC!” (Tweet, 4/16/2020)
Progressive Policy Institute: “We applaud the FCC’s ongoing efforts to accelerate the deployment of 5G. Repurposing this commercial spectrum for a mobile broadband network is another step in the right direction.” (Tweet, 4/16/2020)
Public Knowledge: “The Chairman’s proposed Order reveals how the FCC has worked to both protect incumbent GPS users while allowing for pro-competitive commercial licensing of spectrum. … Congress has entrusted the FCC to strike the proper balance between the needs of incumbents and the potential benefits to new entrants or new users, and here, the FCC gets it right. In approving Ligado’s license, the FCC has taken an important step forward in its role as the sole arbiter of spectrum disputes and, in this instance, has correctly sided on behalf of the public interest to help deliver the potential of 5G to more Americans.” (Statement, 4/16/2020)
Technology Policy Institute: “Allowing the Ligado spectrum to lie fallow would represent a waste of valuable resources that could provide substantial benefits for consumers in the form of new Internet of Things and other uses. … Failure to approve the Ligado license modifications would have the opposite effect, transferring a large block of spectrum from the commercial sector back to the government. The Commission’s action today will avoid that outcome.” (Statement, 4/16/2020)
Wireless Infrastructure Association: “WIA applauds Chairman Pai for circulating a draft order to approve Ligado’s plans to deploy a nationwide network that would primarily support 5G and IoT services. After years of diligence, study, and discussion, today’s action is further evidence that the FCC bases its decisions on science and engineering. Freeing up more spectrum, especially mid-band spectrum, is vital to 5G deployment. Ligado’s proposal offers an enormous opportunity for infrastructure investment, deployment, and connectivity for Americans across the country right when we need it most.” (Statement, 4/16/2020)
Apple has applied for a license from the Federal Communications Commission (FCC) to install GPS testing equipment within Apple Park.
For the purposes of licensing, GPS transmitters are included in radio broadcasting legislation, and enforced jointly by the FCC and the U.S. National Telecommunications and Information Administration, which is part of the Department of Commerce.
In its application, Apple named two objectives. The first objective is the “illumination of the part of the the facility, located at 1 Apple Parkway, Cupertino, California, with a GPS signal to allow for the testing and experimentation indoors for continued exploration of utilizing GPS technologies within their devices to provide innovation applications and continue to provide safe products.” Its second objective is the “further design, development and enhancement of existing GPS applications to provide greater efficiency and more effective means of utilizing GPS derived information.”
According to Apple Insider, this would mean Apple would install a GPS transmitter or repeater within Apple Park in order to better control and test its own GPS devices. Apple plans to use a GPS repeater called Metro GNSS, Apple Insider added.
The application has not yet been granted, but Apple previously applied three times for licenses to conduct tests regarding cellular and consumer radios, with each application being approved, reported Apple Insider.
