A U.S. judge dismissed the bulk of two lawsuits by LightSquared and equity owner Harbinger Capital Partners, reports Reuters. The suits accused Trimble, Garmin and Deere & Co. of misleading them about interference concerns and hastening the company’s fall into bankruptcy.
In an opinion issued Feb. 5 in Manhattan federal court, Judge Richard Berman threw out Harbinger’s lawsuit, and denied nine of 11 claims by LightSquared.
LightSquared has been in bankruptcy since 2012, when the Federal Communications Commission revoked its license to build a planned wireless network over concerns it could interfere with GPS.
The lawsuits alleged that Deere, Garmin International , Trimble Navigation Ltd, and a GPS industry group led LightSquared to believe the planned network would not pose an interference risk. It wasn’t until LightSquared had pumped $4 billion into the project, the plaintiffs argued, that the GPS industry voiced their concerns.
Judge Berman dismissed many claims from both plaintiffs, including breach of contract and civil conspiracy, leaving alive only LightSquared’s claims for negligent misrepresentation and constructive fraud.
Because the judge did not dismiss all claims, LightSquared could still be able to probe the GPS companies’ books and records during discovery.
A new group, the GPS Innovation Alliance, has formed and announced itself as the voice of the U.S. GPS industry and community of users, to “support the ever-increasing importance of GPS” in the U.S. capital, Washington, D.C. The organization subsumes and replaces both the U.S. GPS Industry Council, an entity of longstanding, and the Coalition to Save Our GPS, which arose in March 2011 in response to a Federal Communications Commission (FCC) conditional waiver granted to LightSquared.
The alliance appears to reflect a desire on the part of some industry members to take a more aggressive approach inside the Washington Beltway, a sign, it would seem, of the political times. Some of those involved spoke informally of a desire to take advantage of contacts made on Capitol Hill and in the media during the highly visible LightSquared combat, fought in the glare of media attention heretofore unknown in industry circles.
Members of the Alliance are drawn from a variety of fields and businesses reliant on GPS, as well as leading manufacturers of GPS equipment. The former group includes, aviation, agriculture, construction, transportation, first responders, and surveying and mapping, and consumer organizations representing users of GPS for boating and other outdoor activities, and in automobiles, smartphones, and tablets.
Joining John Deere, Garmin, and Trimble — three lead drivers of the Coalition effort at the FCC — are NovAtel Inc. and Topcon Positioning Systems. All five were previously long-time members of the USGIC, and they appear as founding members of the alliance at www.gpsalliance.org.
Affiliate members listed on the website include the Association of Equipment Manufacturers, General Aviation Manufacturers Association, National Association of Manufacturers, Association for Unmanned Aerial Vehicles International, and Boat Owners Association of the United States.
The alliance plans to build on “the proud heritage and extensive expertise of the United States GPS Industry Council (USGIC), which was formed in 1991 to promote broader commercial applications of GPS and to expand global markets while assisting in safeguarding the technology’s military advantages. The council has a long history of highly effective advocacy on behalf of the GPS industry, as well as serving as a trusted source of objective information for policy makers, the media and the public both in the U.S. and around the world.” The alliance website gives a longer statement about the history and record of the USGIC, highlighting its role in international negotiations.
Michael Swiek, executive director of the USGIC, has transitioned to become the executive director, executive branch and international, of the Innovation Alliance. In addition to working closely with leading offices of executive branch departments of the U.S. government, he will continue well-established dialogs with governmental, private sector and academic entities in areas critical to GPS and satellite navigation among key players in Europe, Japan, Russia, Korea, China, and elsewhere.
Heather Hennessey, a principal of Innovative Federal Strategies LLC, a “comprehensive government relations firm,” has taken the position of executive director, legislative, at the alliance. Hennessey has seven years of service in the House of Representatives, including two years as chief of staff for Congressman Jack Kingston of Georgia.
An active voice in alliance representations on Capitol Hill will presumably be that of Jim Kirkland, vice president and general counsel for Trimble. Kirkland was the most prominent spokesperson for the coalition during the LightSquared battle, which appears to be either over or nearly so. “The alliance is committed to ensuring constructive, robust dialog between GPS users, manufacturers and policy makers on critical policy issues affecting GPS,” Kirkland said, “a commitment Trimble is pleased to be a part of as the industry continues to innovate and modernize.”
The alliance mission statement cites the importance of GPS to global economy and infrastructure; vows to aid further GPS innovation, creativity and entrepreneurship; and to protect, promote and enhance the use of GPS.
The GPS Innovation Alliance officially launched on February 13 with a reception on Capitol Hill, a traditional lobbying tactic that previous efforts had perhaps not envisioned. The organization has also hired a public relations firm, Prism Public Affairs, and commissioned a logo.
After a four-month sabbatical and the GPS World servers back in order, I’m back writing on a regular basis. I’ve been super busy on different GPS/GNSS-related products, conferences and various GPS/GNSS applications.
Let’s take a look at some of the technologies and events that were significant in 2012 and some that will be significant in 2013 for high-precision GNSS users.
LightSquared
House Representative Anna Eshoo, ranking member on the House Subcommittee on Communications and Technology, who in September 2011 wrote to the NTIA’s Larry Strickland asking Strickland to find a way for LightSquared and GPS to coexist, said it best a year later (November 2012):
“What happened to LightSquared is disappointing, but unfortunately that ship has sailed.”
Now all that’s left are negotiations regarding GNSS receiver standards and/or a frequency guard band around GPS L1, both of which are moving at a snail’s pace. Regardless, you can bet that GNSS receiver designers are taking this experience to heart and tightening up their filtering as much as possible. The more difficult problem to solve is the augmentation services offered in the MSS band (such as Trimble’s OmniSTAR, Deere’s Starfire and just-introduced Terrastar), all of which broadcast their correction signals in the MSS band at low-power satcom power levels (as opposed to high-power terrestrial power levels).
Hidden behind the LightSquared issue over the past two years has been the FCC narrow-banding ruling that took effect on January 1, 2013. Initially adopted in 1995, the narrowbanding ruling has been around for a number of years. In fact, equipment suppliers have been required to offer narrowbanded (12.5kHz vs. 25kHz spacing) radios since 1997. In 2004, the FCC set the January 1, 2013 deadline for users to comply.
The FCC’s webpage on the narrowbanding ruling shed some light on the rationale behind it, but narrowbanding doesn’t specifically target RTK users so there’s not any RTK-specific information contained in the FCC documents. The bottom line is that the FCC is trying to allow more users in the same spectrum, similar to trying to fit more cars on a highway by splitting lanes in two. The problem with this, from a user standpoint, is that some vehicles won’t fit in the new, narrower lanes and therefore aren’t legal to use any longer. That’s the case with most UHF/VHF RTK base stations.
To be clear, the narrowbanding ruling doesn’t affect UHF/VHF radios on your rover (receiving radio) GPS/GNSS receiver. I’m talking about the base station UHF/VHF radio. The ruling states that your UHF/VHF base station radio must be able to broadcast at 12.5kHz vs. 25kHz, essentially utilizing half the spectrum. Your UHF/VHF base radio can still broadcast at 25kHz if it broadcasts at 19,200 baud. Since January 1, 2013, it is illegal to broadcast at 4,800 or 9,600 using 25kHz spacing. The reality is that it becomes complicated when trying to broadcast at 19,200 baud at 25kHz spacing. Radio range is reduced and communication protocols (compatibility) become an issue. The reality is that you’ll likely need to replace your UHF/VHF base radio in order to stay compliant with the FCC rules.
Just a few weeks ago (January 7, 2013), I was a guest on the NSPS Radio Hour to discuss the FCC narrowbanding rule. I invited Charlie Branch from Pacific Crest Corporation, a major supplier of VHF/UHF radios for RTK users, and Mark Silver from IGAGE Corp, a Pacific Crest dealer, to discuss their thoughts on the FCC narrowbanding rule and their experience with equipment compatibility. It is a great discussion on the subject and well worth listening to if you’re interested in learning more about the narrowbanding rule and how it affects RTK users.
Lastly, you might also be interested in this presentation from Charlie Branch on the FCC narrowbanding rule.
Low-Cost RTK Receivers
At the GPS World dinner during the Institute of Navigation GNSS conference last September, Dr. Todd Humphreys predicted that RTK GNSS would be available in mobile phones by the year 2020. As I’ve written before, the challenge with this is not really the quality of the GPS receiver used in mobile phones (some of the key engineers at Broadcomm, who supply the GNSS chip to Apple, used to design RTK receivers at Ashtech), but rather the poor quality antennas that mobile phone designers choose to use. Instead of RTK inside the mobile phone, I think small RTK “pucks,” a few inches in diameter, are more practical and realistic and will become common and easily interfaced to mobile phones (or other mobile devices) via Bluetooth. I think you will start seeing these within the next three years.
Galileo
With four Galileo IOV (in-orbit validation) test satellites in orbit that will be converted to operational satellites, Europe’s Galileo is on its way to becoming a viable satellite navigation system for high-precision apps. Launch of production satellites is scheduled to begin later this year and scheduled to occur every three months, launching in pairs. With an aggressive launch schedule, 18 satellites are predicted to be in orbit by the end of 2015, a little more than two years from now.
I’m very bullish on Galileo because, like GPS, it supports the new L5 signal, which will lead to less expensive dual-frequency, dual-constellation receivers. It’s clear that the European Union is committed to Galileo, and it would be difficult for them to shut down the project after advancing as far as they have.
GPS Modernization
Modernizing GPS, on the other hand, is moving very slowly. Galileo already has more L5-capable satellites in orbit than GPS. My 2010 prediction that 18 Galileo satellites and 12 GPS satellites would provide the high-precision user community with a full 30-satellite constellation broadcasting L1/L5 signals by 2015 may not materialize. However, the weak link might end up being delays with the GPS program rather than a lack of commitment from the European Union with its Galileo program.
Last August at a CGSIC (Civil GPS Service Interface Committee) meeting, I heard rumblings of three GPS launches this year (2013). Sadly, I don’t think this is going to materialize. I think we’re on pace for a single launch this year, again. Budget, launch pad scheduling and a healthy GPS constellation continue to be the culprits.
There’s also a bit of second-guessing happening with respect to GPS signals. Earlier this month, Don Jewell wrote a piece entitled “2C or not 2C: An Important Signal Question.” While the delay in launching next-generation GPS satellites may have saved the U.S. government some money, I think it has put the L2C signal in peril. There were high hopes for L2C, as the second civil GPS signal, when it was conceived in the 1990s. But it’s been seven long years since the signal was deployed on the first GPS II-RM satellite in 2005, and there are only a total of 10 GPS satellites broadcasting L2C today. That’s not enough, and it’s hard for receiver manufacturers and the civilian user community to take L2C seriously when it appears the U.S. government is not taking it seriously.
Some sort of positive traction with L2C must happen soon, or it will risk being ignored as it is overtaken by the new L5 signal that is supported by up-and-coming GNSS like Galileo and Compass/BeiDou.
UAVs (Unmanned Aerial Vehicles)
The United States is the last major geographic region (that I’m aware of) where UAVs are illegal to use by commercial entities. Service companies in other countries are going crazy with UAVs in offering mapping services (for instance, in mining and agriculture). The Federal Aviation Administration (FAA) is working on establishing rules by 2015 that will allow commercial entities to utilize UAVs in the U.S. This will turn the market for digital mapping imagery upside down. It will become very easy and inexpensive for people to obtain quick-n-dirty imagery for mapping purposes with a very quick turnaround.
Thanks, and see you next month.
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Based upon lessons learned from the LightSquared situation, the author identifies important considerations for GPS spectrum interference standards, recommended by the PNT EXCOM for future commercial proposals in bands adjacent to the RNSS band to avoid interference to GNSS.
On January 13, 2012, the U.S. National Positioning, Navigation, and Timing Executive Committee (PNT EXCOM) met in Washington, D.C., to discuss the latest round of testing of the radiofrequency compatibility between GPS and a terrestrial mobile broadband network proposed by LightSquared. The proposed network included base stations transmitting in the 1525 – 1559 MHz band and handsets transmitting in the 1626.5 – 1660.5 MHz band. These bands are adjacent to the 1559 – 1610 MHz radionavigation satellite service (RNSS) band used by GPS and other satellite navigation systems. Based upon the test results, the EXCOM unanimously concluded that “both LightSquared’s original and modified plans for its proposed mobile network would cause harmful interference to many GPS receivers,” and that further “there appear to be no practical solutions or mitigations” to allow the network to operate in the near-term without resulting in significant interference.
The LightSquared outcome was a lose-lose in the sense that billions were spent by the investors in LightSquared and, as noted by the EXCOM, “substantial federal resources have been expended and diverted from other programs in testing and analyzing LightSquared’s proposals.” To avoid a similar situation in the future, the EXCOM proposed the development of “GPS Spectrum interference standards that will help inform future proposals for non-space, commercial uses in the bands adjacent to the GPS signals and ensure that any such proposals are implemented without affecting existing and evolving uses of space-based PNT services.”
This article identifies and describes several important considerations in the development of GPS spectrum interference standards towards achieving the stated EXCOM goals. These include the identification of characteristics of adjacent band systems and an assessment of the susceptibility of all GPS receiver types towards interference in adjacent bands. Also of vital importance to protecting GPS receivers is an understanding of the user base, applications, and where the receivers for each application may be located while in use. This information, along with the selection of proper propagation models, allows one to establish transmission limits on new adjacent-band systems that will protect currently fielded GPS receivers. The article further comments on the implications of the evolution of GPS and foreign satellite navigation systems upon the development of efficacious spectrum interference standards.
Adjacent Band Characteristics
The type of adjacent-band system for which there is currently the greatest level of interest is a nationwide wireless fourth-generation (4G) terrestrial network to support the rapidly growing throughput demands of personal mobile devices. Such a nationwide network would likely consist of tens of thousands of base stations distributed throughout the United States and millions of mobile devices. The prevalent standard at the present time is Long Term Evolution (LTE), which is being deployed by all of the major U.S. carriers. LTE and Advanced LTE provide an efficient physical layer for mobile wireless services. Worldwide Interoperability for Microwave Access (WiMAX) is a competing wireless communication standard for 4G wireless that is a far-distant second in popularity.
For the purposes of the discussion within this article, an LTE network is assumed with characteristics similar to that proposed by LightSquared but perhaps with base stations and mobile devices that transmit upon different center frequencies and bandwidths. The primary characteristics include:
Tens of thousands of base stations nationwide, reusing frequencies in a cellular architecture, with the density of base stations peaking in urban areas.
Base-station antennas at heights from sub-meter to 150 meters above ground level (AGL), with a typical height of 20–30 meters AGL. Each base station site has 1–3 sector antennas mounted on a tower such that peak power is transmitted at a downtilt of 2–6 degrees below the local horizon, with a 60–70 degree horizontal 3-dB beamwidth and 8–9 degree vertical 3-dB beamwidth.
Peak effective isotropic radiated power (EIRP) in the vicinity of 20–40 dBW (100–10,000 W) per sector.
Mobile devices transmit at a peak EIRP of around 23 dBm (0.2 W), but substantially lower most of the time when lower power levels suffice to achieve a desired quality of service as determined using real-time power control techniques.
As LTE uses efficient transmission protocols, emissions can be accurately modeled as brickwall, that is, confined to a finite bandwidth around the carrier.
Throughout this article it will be presumed that LTE emissions in the bands authorized for RNSS systems such as GPS will be kept sufficiently low through regulatory means.
The opening photo shows a typical base-station tower, with three sectors per cellular service provider and with multiple service providers sharing space on the tower, including non-cellular fixed point microwave providers. As a cellular network is being built out, coverage is at first most important, and many base-station sites will use minimum downtilt and peak EIRPs within the ranges described above. As the network matures, capacity becomes more important. High-traffic cells are split through the introduction of more base stations, and this is commonly accompanied by increased downtilts and lower EIRPs.
The assumed characteristics for adjacent band systems plays a paramount role in determining compatibility with GPS, and obviously lower-power adjacent-band systems would be more compatible. If compatibility with GPS precludes 4G network implementation on certain underutilized frequencies adjacent to RNSS bands, then it may be prudent to refocus attention for these bands on alternative lower-power systems.
GPS Receiver Susceptibility
Over the past two years, millions of dollars have been expended to measure or analyze the susceptibility of GPS receivers to adjacent band interference as part of U.S. regulatory proceedings for LightSquared. Measurements were conducted through both radiated (see photo) and conducted tests at multiple facilities, as well as in a live-sky demonstration in Las Vegas. This section summarizes the findings for seven categories of GPS receivers. These categories, which were originally identified in the Federal Communications Commission (FCC)-mandated GPS-LightSquared Technical Working Group (TWG) formed in February 2011, are: aviation, cellular, general location/navigation, high-precision, timing, networks, and space-based receivers.
Aviation. Certified aviation GPS receivers are one of the few receiver types for which interference requirements exist. These requirements take the form of an interference mask (see Figure 1) that is included in both domestic and international standards. Certified aviation GPS receivers must meet all applicable performance requirements in the presence of interference levels up to those indicated in the mask as a function of center frequency. In Figure 1 and throughout this article, all interference levels are referred to the output of the GPS receiver passive-antenna element. Although the mask only spans 1500–1640 MHz, within applicable domestic and international standards the curves are defined to extend over the much wider range of frequencies from 1315 to 2000 MHz.
A handful of aviation GPS receivers were tested against LightSquared emissions in both conducted and radiated campaigns. The results indicated that these receivers are compliant with the mask with potentially some margin. However, the Federal Aviation Administration (FAA) noted the following significant limitations of the testing:
Not all receiver performance requirements were tested.
Only a limited number of certified receivers were tested, and even those tested were not tested with every combination of approved equipment (for example, receiver/antenna pairings).
Tests were not conducted in the environmental conditions that the equipment was certified to tolerate (for example, across the wide range of temperatures that an airborne active antenna experiences, and the extreme vibration profile that is experienced by avionics upon some aircraft).
Due to these limitations, the FAA focused attention upon the standards rather than the test results for LightSquared compatibility analyses, and these standards are also recommended for use in the development of national GPS interference standards. One finding from the measurements of aviation receivers that may be useful, however, is that the devices tested exhibited susceptibilities to out-of-band interference that were nearly constant as a function of interference bandwidth. This fact is useful since the out-of-band interference mask within aviation standards is only defined for continuous-wave (pure tone) interference, whereas LightSquared and other potential adjacent-band systems use signals with bandwidths of 5 MHz or greater.
Cellular. The TWG tested 41 cellular devices supplied by four U.S. carriers (AT&T, Sprint, US Cellular, and Verizon) against LightSquared emissions in the late spring/early summer of 2011. At least one of the 41 devices failed industry standards in the presence of a 5- or 10-MHz LTE signal centered at 1550 MHz at levels as low as –55 dBm, and at least one failed for a 10-MHz LTE signal centered at 1531 MHz at levels as low as –45 dBm. The worst performing cellular devices were either not production models or very old devices, and if the results for these devices are excluded, then the most susceptible device could tolerate a 10-MHz LTE signal centered at 1531 MHz at power levels of up to –30 dBm. Careful retesting took place in the fall of 2011, yielding a lower maximum susceptibility value of –27 dBm under the same conditions.
General Location/Navigation. The TWG effort tested 29 general location/navigation devices. In the presence of a pair of 10-MHz LTE signals centered at 1531 MHz and 1550 MHz, the most susceptible device experienced a 1-dB signal-to-noise ratio (SNR) degradation when each LTE signal was received at –58.9 dBm. In the presence of a single 10-MHz LTE signal centered at 1531 MHz, the most susceptible device experienced a 1-dB SNR degradation when the interfering signal was received at –33 dBm.
Much more extensive testing of the effects of a single LTE signal centered at 1531 MHz on general location/ navigation devices was conducted in the fall of 2011, evaluating 92 devices. The final report on this campaign noted that 69 of the 92 devices experienced a 1-dB SNR decrease or greater when “at an equivalent distance of greater than 100 meters from the LightSquared simulated tower.” Since the tower was modeled as transmitting an EIRP of 62 dBm, the 100-meter separation is equivalent to a received power level of around –14 dBm. The two most susceptible devices experienced 1-dB SNR degradations at received power levels less than –45 dBm.
High Precision, Timing, Networks. The early 2011 TWG campaign tested 44 high-precision and 13 timing receivers. 10 percent of the high-precision (timing) devices experienced a 1-dB or more SNR degradation in the presence of a 10-MHz LTE signal centered at 1550 MHz at a received power level of –81 dBm (–72 dBm). With the 10-MHz LTE signal centered at 1531 MHz, this level increased to –67 dBm (–39 dBm).
The reason that some high-precision GPS receivers are so sensitive to interference in the 1525–1559 MHz band is that they were built with wideband radiofrequency front-ends to intentionally process both GPS and mobile satellite service (MSS) signals. The latter signals provide differential GPS corrections supplied by commercial service providers that lease MSS satellite transponders, from companies including LightSquared.
Space. Two space-based receivers were tested for the TWG study. The first was a current-generation receiver, and the second a next-generation receiver under development. The two receivers experienced 1-dB C/A-code SNR degradation with total interference power levels of –59 dBm and –82 dBm in the presence of two 5-MHz LTE signals centered at 1528.5 MHz and 1552.7 MHz. For a single 10-MHz LTE signal centered at 1531 MHz, the levels corresponding to a 1-dB C/A-code SNR degradation increased to –13 dBm and –63 dBm. The next-generation receiver was more susceptible to adjacent-band interference because it was developed to “be reprogrammed in flight to different frequencies over the full range of GNSS and augmentation signals.”
Discussion. Although extensive amounts of data were produced, the LightSquared studies are insufficient by themselves for the development of GPS interference standards, since they only assessed the susceptibility of GPS receivers to interference at the specific carrier frequencies and with the specific bandwidths proposed by LightSquared. If GPS interference standards are to be developed for additional bands, then much more comprehensive measurements will be necessary.
Interestingly, NTIA in 1998 initiated a GPS receiver interference susceptibility study, funded by the Department of Defense (DoD) and conducted by DoD’s Joint Spectrum Center. One set of curves produced by the study is shown in Figure 2. This format would be a useful output of a further measurement campaign. The curves depict the interference levels needed to produce a 1-dB SNR degradation to one GPS device as the bandwidth and center frequency of the interference is varied. The NTIA curves only extended from GPS L1 (1575.42 MHz) ± 20 MHz. A much wider range would be needed to develop GPS interference standards as envisioned by the PNT EXCOM. It may be possible, to minimize testing, to exclude certain ranges of frequencies corresponding to bands that stakeholders agree are unlikely to be repurposed for new (for example, mobile broadband) systems.
Figure 2. Example of NTIA-initiated receiver susceptibility measurements from 1998.
Receiver-Transmitter Proximity
The LightSquared studies, with the exception of those focused on aviation and space applications, spent far less attention to receiver-transmitter proximity. Minimum separation distances and the associated geometry are obviously very important towards determining the maximum interference level that might be expected for a given LTE network (or other adjacent band system) laydown.
Within the TWG, the assumption generally made for other (non-aviation, non-space) GPS receiver categories was that they could see power levels that were measured in Las Vegas a couple of meters above the ground from a live LightSquared tower. Figure 3 shows one set of received power measurements from Las Vegas. In the figure, the dots are measured received power levels made by a test van. The top curve is a prediction of received power based upon the free-space path-loss model. The bottom curve is a prediction based upon the Walfisch-Ikegami line-of-sight (WILOS) propagation model. The NPEF studies presumed that the user could be within the boresight of a sector antenna even within small distances of the antenna (where the user would need to be at a significant height above ground).
Figure 3 Measurements of received power levels from one experimental LightSquared base station sector in Las Vegas live-sky testing.
The difference between the above received LTE signal power assumptions has been hotly debated, especially after LightSquared proposed limiting received power levels from the aggregate of all transmitting base stations as measured a couple of meters above the ground in areas accessible to a test vehicle. After summarizing the aviation scenarios developed by the FAA, this section highlights scenarios where so-called terrestrial GPS receivers can be at above-ground heights well over 2 meters. The importance of accurately understanding transmitter-receiver proximity is illustrated by Figure 4. This shows predicted received power levels for one LTE base station sector transmitting with an EIRP of 30 dBW and with an antenna height of 20 meters (65.6 feet). The figure was produced assuming the free-space path-loss model and a typical GPS patch-antenna gain pattern for the user. Note that maximum received power levels are very sensitive to the victim GPS receiver antenna height.
Figure 4. Received power in dBm at the output of a GPS patch antenna from one 30 dBW EIRP LTE base station sector at 20 meters.
Aviation. The first LightSquared-GPS study conducted for civil aviation was completed by the Radio Technical Commission for Aeronautic (RTCA) upon a request from the FAA. Due to the extremely short requested turnaround time (3 months), RTCA consciously decided not to devote any of the available time developing operational scenarios, but rather re-used scenarios that it had developed for earlier interference studies. It was later realized that the combination of five re-used scenarios and assumed LightSquared network characteristics did not result in an accurate identification of the most stressing real-world scenarios. For instance, within the RTCA report, base stations’ towers were all assumed to be 30 meters in height. At this height, towers could not be close to runway thresholds where aircraft are flying very low to the ground, because this situation would be precluded by obstacle clearance surfaces. Later studies used actual base-station locations, from which the aviation community became aware that cellular service providers do place base stations close to airports by utilizing lower base-station heights as necessary to keep the antenna structure just below obstacle clearance surfaces.
The FAA completed an assessment of LightSquared-GPS compatibility in January 2012 that identified scenarios where certified aviation receivers could experience much higher levels of interference than was assessed in the RTCA report. The areas where fixed-wing and rotary-wing aircraft rely on GPS are depicted in Figures 5 and 6 (above the connected line segments), respectively.
Figure 5. Area where GPS use must be sssured for fixed-wing aircraft.Figure 6. Area where GPS use must be assured for rotary-wing aircraft.
Aircraft rely upon GPS for navigation and Terrain Awareness and Warning Systems (TAWS). Helicopter low-level en-route navigation and TAWS for fixed- and rotary-wing aircraft are perhaps the most challenging scenarios for ensuring GPS compatibility with adjacent-band cellular networks. In these scenarios, the aircraft can be within the boresight of cellular sector antennas and in very close proximity, resulting in very high received-power levels. The FAA attempted to provide some leeway for LightSquared while maintaining safe functionality of TAWS through the concept of exclusion zones (see Figure 7). The idea of an exclusion zone is that, at least for cellular base-station transmitters on towers that are included within TAWS databases, that it would be permitted for the GPS function to not be available for very small zones around the LTE base-station tower. This concept is currently notional only; the FAA plans to more carefully evaluate the feasibility of this concept and appropriate exclusion-zone size with the assistance of other aviation industry stakeholders.
Figure 7. Example exclusion area around base station to protect TAWS.
High-precision and Networks: Reference Stations. To gain insight into typical reference-station heights for differential GPS networks, the AGL heights of sites comprising the Continuously Operating Reference Station (CORS) network organized by the National Geodetic Survey (NGS) were determined. The assessment procedure is detailed in the Appendix.
Figure 8 portrays a histogram of estimated AGL heights for the 1543 operational sites within the continental United States (CONUS) as of February 2012. The accuracy of the estimated AGL heights is on the order of 16 meters, 90 percent, limited primarily by the quality of the terrain data that was utilized. The mean and median site heights are 5.7 and 5.2 meters, respectively.
Figure 8. Distribution of heights for CORS sites.
RALR, atop the Archdale Building in Raleigh, North Carolina, was the tallest identified site at 64.1 meters. This site, however, was decommissioned in January 2012 (although it was identified as operational in a February 2012 NGS listing of sites). The second tallest site identified is WVHU in Huntington, West Virginia at 39.6 meters, which is still operational atop of a Marshall University building. 223 of the 1543 CORS sites within CONUS have AGL heights greater than 10 meters, and furthermore the taller sites tend to be in urban areas where cellular networks tend to have the greatest base-station density.
High Precision and Networks: End Users. Many high-precision end users employ GPS receivers at considerable heights above ground. For instance, high-precision receivers are relied upon within modern construction methods. The adjacent photos show GPS receivers used for the construction of a 58-story skyscraper called The Bow in Calgary, Canada. For this project, a rooftop control network was established on top of neighboring buildings using both GPS receivers and other surveying equipment (for example, 360-degree prisms for total stations), and GPS receivers were moved up with each successive stage of the building to keep structural components plumb and properly aligned. Similar techniques are being used for the Freedom Tower, the new World Trade Center, in New York City, and many other current construction projects.
Other terrestrial applications that rely on high-precision GPS receivers at high altitudes include structural monitoring and control of mechanical equipment such as gantry cranes. At times, even ground-based survey receivers can be substantially elevated. Although a conventional surveying pole or tripod typically places the GPS antenna 1.5 – 2 meters above the ground, much longer poles are available and occasionally used in areas where obstructions are present. 4-meter GPS poles are often utilized, and poles of up to 40 ft (12.2 meters) are available from survey supply companies.
General Location/Navigation. Although controlling received power from a cellular network at 2 meters AGL may be suitable to protect many general navigation/location users, it is not adequate by itself. For example, GPS receivers are used for tracking trucks and for positive train control (the latter mandated in the United States per the Rail Safety Improvement Act of 2008). GPS antennas for trucks and trains are often situated on top of these vehicles. Large trucks in the United States for use on public roads can be up to 13 ft, 6 in (~4.1 meters), and a typical U.S. locomotive height is 15 ft, 5 in (~4.7 meters). Especially in a mature network that is using high downtilts, received power at these AGL heights can be substantially higher than at 2 meters.
Within the TWG and NPEF studies, the general location/navigation GPS receiver category is defined to include non-certified aviation receivers. One notable application is the use of GPS to navigate unmanned aerial vehicles. UAVs are increasingly being used for law enforcement, border control, and many other applications where the UAV can be expected to occasionally pass within the boresight of cellular antennas at short ranges.
Cellular. The majority of Americans own cell phones, and a growing number are using cell phones as a replacement for landlines within their home. Already, 70 percent of 911 calls are made on mobile phones. Although pedestrians and car passengers are often within 2 meters of the ground, this is not always the case. Figure 9 shows three cellular sector antennas situated atop a building filled with residential condominiums. The rooftop is accessible and frequently used by the building inhabitants. According to an online real estate advertisement, “The Garden Roof was voted the Best Green Roof in Town and provides amazing 360 degree views of downtown Nashville as well as four separate sitting areas and fabulous landscaping.” One of the sector antennas is pointing towards the opposite corner of the building. If the downtilt is in the vicinity of 2–6 degrees, then it is quite likely that a person making a 911 call from the rooftop could see a received power level of –10 dBm to 0 dBm, high enough to disrupt GPS within most cellular devices if the antennas were transmitting in the 1525–1559 MHz band.
Figure 9. Cellular antennas atop Westview Condominium Building in downtown Nashville.
This situation is not unusual. Many cellular base stations are situated on rooftops in urban areas, and many illuminate living areas in adjacent buildings. In recent years, New York City even considered legislation to protect citizens from potential harmful effects of the more than 2,600 cell sites in the city, since many sites are in very close proximity to residential areas.
Propagation Models
Within the LightSquared proceedings, there was a tremendous amount of debate regarding propagation models. Communication-system service providers typically use propagation models that are conservative in their estimates of received power levels in the sense that they overestimate propagation losses. This conservatism is necessary so that the service can be provided to end users with high availability. From the standpoint of potential victims of interference, however, it is seen as far more desirable to underestimate propagation losses so that interference can be kept below an acceptable level a very high percentage of time. As shown in Figure 3, some received power measurements from the Las Vegas live-sky test indicate values even greater than would be predicted using free-space propagation model. Statistical models that allow for this possible were used in the FAA Status Report. The general topic of propagation models is worthy of future additional study if GPS interference standards are to be developed.
Future Considerations
GPS is being modernized. Additionally, satellite navigation users now enjoy the fact that the Russian GLONASS system has recently returned to full strength with the repopulation of its constellation. In the next decade, satellite navigation users also eagerly anticipate the completion of two other global GNSS constellations: Europe’s Galileo and China’s Compass. Notably, between the GPS modernization program and the deployment of these other systems, satellite navigation users are expected to soon be relying upon equipment that is multi-frequency and that needs to process many more signals with varied characteristics. New equipment offers an opportunity to insert new technologies such as improved filtering, but of course the need to process additional signals and carrier frequencies may make GNSS equipment more susceptible to interference as well. Clearly, these developments will need to be carefully assessed to support the establishment of GPS spectrum interference standards.
Summary
This article has identified a number of considerations for the development of GPS interference standards, which have been proposed by the PNT EXCOM. If the United States proceeds with the development of such standards, it is hoped that the information within this article will prove useful to those involved.
Bow highrise under construction in Calgary, showing GPS receivers in use (photos courtesy Rocky Annett, MMM Group Ltd.)(Photo courtesy of Rocky Annett, MMM Group Ltd.)(Photo courtesy of Rocky Annett, MMM Group Ltd.)
Appendix: AGL Heights of CORS Network Sites
The National Geodetic Survey Continuously Operating Reference Station (CORS) website provides lists of CORS site locations in a number of different reference frames. To determine the height above ground level () for each site within this study, two of these files (igs08_xyz_comp.txt and igs08_xyz_htdp.txt) were used. These two files provide the (x,y,z) coordinates of the antenna reference point (ARP) for each site in the International GNSS Service 2008 (IGS08) reference frame, which is consistent with the International Terrestrial Reference Frame (ITRF) of 2008. These coordinates are divided into two files by NGS, since the site listings also provide site velocities and velocities are either computed (for sites that have produced data for at least 2.5 years) or estimated (for newer sites). The comp file includes sites with computed velocities and the htdp file includes sites with estimated velocities (using a NGS program known as HTDP).
The data files can be used to readily produce height above the ellipsoid, , for each site. This height can be found using well-known equations to convert from (x, y, z) to (latitude, longitude, height). Obtaining estimates of requires information on the geoid height and terrain data, per the relationship:
(A-1)
For the results presented in this article, terrain data was obtained from http://earthexplorer.usgs.gov in the Shuttle Radar Topography Mission (SRTM) Digital Terrain Elevation Data (DTED) Level 2 format. For this terrain data, the horizontal datum is the World Geodetic System (WGS 84). The vertical datum is Mean Sea Level (MSL) as determined by the Earth Gravitational Model (EGM) 1996. Each data file covers a 1º by 1º degree cell in latitude/longitude, and individual points are spaced 1 arcsec in both latitude and longitude. The SRTM DTED Level 2 has a system design 16 meter absolute vertical height accuracy, 10 meters relative vertical height accuracy, and 20 meter absolute horizontal circular accuracy. All accuracies are at the 90 percent level. Considering the accuracies of the DTED data, the differences between WGS-84 and IGS08 as well as between the ARP and antenna phase center were considered negligible. Geoid heights were interpolated from 15-arcmin data available in the MATLAB Mapping Toolbox using the egm96geoid function.
Lower AGL heights are preferred for CORS sites to minimize motion between the antenna and the Earth’s crust. However, many sites are at significant heights above the ground by necessity, particularly in urban areas due to the competing desire for good sky visibility.
Christopher J. Hegarty is the director for communications, navigation, and surveillance engineering and spectrum with The MITRE Corporation. He received a D.Sc. degree in electrical engineering from George Washington University. He is currently the chair of the Program Management Committee of the RTCA, Inc., and co-chairs RTCA Special Committee 159 (GNSS). He is the co-editor/co-author of the textbook Understanding GPS: Principles and Applications, 2nd Edition.
It had to happen sometime. I just thought or hoped it might take a few more years.
But I guess I should not be surprised since I experienced a wonderful 30-year U.S. Air Force (USAF) career and that has been over for more than a decade. I have been working GPS issues since 1978. So I guess it should not have come as a surprise when just a couple of weeks ago a wet-behind-the-ears USAF 2nd Lieutenant actually inquired of me, in a public GPS-related forum no less, “So, what did you do in the war, granddad?”
Several irreverent and potentially satisfying responses immediately came to mind:
I am not your granddad.
Where do you get off asking me a question in that tone of voice?
Frankly, it is none of your business.
Instead, I simply inquired, “Which one?” This obviously unexpected response necessitated a long pause while the offender, a now obviously-easily-confused 2nd Lieutenant, ruminated about which war(s) to inquire. For my part I was ready to hit him over the head with my cane if he responded with WWII. Of course I would probably have been accused of child abuse, so he saved the day and a possible court date when he replied in a questioning falsetto, “Vietnam?”
I won’t bore you with my response. However, since that unfortunate “age discrimination” incident (from both parties), it has occurred to me that many of us who were privileged to experience GPS in its infancy are certainly not spring chickens. Indeed, many (Dr. Ivan Getting for one) have passed on to their great reward. Remember, Professor (Colonel) USAF Ret. Bradford Parkinson, who created and ran the NAVSTAR GPS Joint Program Office from 1972 to 1978, was a full colonel in 1972. However, that says nothing about commitment or expertise. Most of us, Brad included, are still as engaged and passionate about the future of GPS as we ever were. Consider that the first satellite in the system, Navstar 1, was launched February 22, 1978. In just a few months the GPS operational constellation will be 35 years old, and Air Force Space Command is celebrating its 30th anniversary this year. My point being that few operational space systems, if any, engender this type of lifelong loyalty, passion and dedication. Plus, those of us who count ourselves among the original sojourners on this amazing journey, especially those who are graying and threatening to beat impertinent whippersnappers with canes, are actually very proud of the fact that we are still engaged, and even more amazed and heartened that there’s a generation of young USAF and other military personnel, engineers, scientists, inventors, and everyday believers to follow in our footsteps. I highlight the USAF personnel because they are the official stewards of GPS.
Indeed, at the recent ION GNSS Conference held it Nashville, Tennessee, it was apparent that many of the youngsters (many of whom are Ph.D.s) are just as engaged as we are. They see a future for GPS and PNT (position, navigation and timing) systems that we may never have imagined. As prescient as many of us “seniors” claim to be, I have no doubt, indeed I fervently hope, that the young men and women following in our footsteps will achieve feats with GPS and PNT systems of which we never dared dream.
ION GNSS 2012 – Nashville
I state here without equivocation or worry of being challenged that the plenary at this year’s event, which was titled “GNSS Revolution, the Catalyst of the New Information Age,” was the best I have ever encountered at any ION event in the past twenty years. Dr. Jade Morton from Miami University was an excellent moderator and kept the program moving along, but it was the presenters, their evident, extensible passion for their subjects and their excellent presentations (see list below) that made the night unforgettable:
1.
High Precision Agriculture: Tony Thelen, Director of Intelligent Solutions Group, John Deere
2.
Crime, Punishment, and the Global Positioning System: Professor David Last, Crime Consultant Engineer and Professor Emeritus, University of Bangor, UK
3.
Precision Navigation Sensors Based on Atom Interferometry: Professor Mark Kasevich, Applied Physics, Stanford Universit
GPS and Agriculture
Tony Thelen, the first presenter from John Deere — yes, the people who make green farm and lawn tractors among other things — actually made GPS and agriculture sound interesting. His presentation was top notch. It certainly kept my interest, and he left me wanting to know more about GPS and agriculture! Of course, I am being a bit disingenuous, since one of my most requested columns, titled “The Farmer in Finland,” concerns the unparalleled John Deere StarFire system, which probably deserves another column soon. Conversations with plenary attendees after his excellent presentation indicate that Tony managed to ignite that spark and interest again for many in the audience. The effect that GPS and companies like John Deere have had on agriculture is simply amazing, and the quantifiable benefits almost beyond belief. Plus, according to Tony Thelen, there is good reason to believe we will continue to be astounded at what the future holds for GPS and agriculture. I encourage you to visit the ION website and review not only Tony’s excellent presentation, but all the ION GNSS 2012 Plenary presentations.
GPS Forensics
When you have three excellent and inspiring speakers lined up for an evening of edification, you always face the conundrum of order. Should the featured or most entertaining speaker be in the middle, or should you risk losing some of your audience early and build toward a climax? With this audience Dr. Jade Morton made the wise decision, and put the most anticipated speaker in the middle of the lineup. There is always great expectation on my part, and I expect from most of the audience, when Professor David Last is scheduled to speak. At Nashville, he certainly did not disappoint. Only the infamous tonal chimes from “Law and Order” could have made his presentation any more dramatic.
For my part, I kept expecting to hear those infamous tones whenever David transitioned to a new slide. David’s presentation was a perfect combination of “Law and Order” combined with “The World of Stupid Criminals.” With material like that, how could it have not been a roaring success? Add the dulcet British Public School accent and perfect comic timing and delivery and you can’t fail. Indeed, anyone listening outside the auditorium that night would have thought they had stumbled upon a standup comic convention instead of a bunch of staid scientists and engineers listening to a presentation on GPS forensics.
David is always interesting, but that night he was competing for and in my book won the ION GNSS Emmy. If you ever have the chance to hear Professor David Last speak publicly, don’t miss it. And criminals in the UK should just surrender — they don’t stand a chance in court against a consulting engineer and expert witness like Professor Last. I dare say even Sherlock Holmes, the famous consulting detective, would be proud of Professor Last.
Cold Atom Interferometry
None of this lessens the impact or obvious passion for his subject displayed by Professor Mark Kasevich from Stanford University. It is not that I don’t have a passion for cold atom interferometry, it’s just that two weeks later I am still trying to figure out what he said and how it applies. I have no doubt that you can, excuse me, that Professor Mark Kasevich can, construct a cold atom interferometer that can be used to determine a position or a fix; I am just trying to figure out how that 10-cubic-foot rack is going to fit into anything remotely mobile. But, of course, even the optimistic Professor Kasevich admitted that mobile or handheld atom interferometers of this caliber are probably 10 years in the future.
So, at this years’ ION GNSS Plenary event, the audience was treated to a down-to-earth and yet exciting look at the future of GPS and agriculture: the comedic and yet brilliant GPS forensic expertise of a passionate John Cleese wannabee, a caped crusader who is feared by criminals everywhere, and the futuristic “Star Trek” look at cold atoms and interferometry. What more could you ask for? This was an evening that for me elucidates the best ION GNSS Plenary ever. My hat is off to ION Executive Director Lisa Beaty and Plenary Program Director Dr. Jade Morton for an excellent program, but mostly I applaud all three speakers for a wonderfully educational and entertaining evening. How often do you get to combine those adjectives?
GPS World Leadership Dinner and Annual Awards Ceremony
However, for myself and many others the highlight of the ION GNSS event for the past several years has been the annual GPS World Gala and Dinner, now known as the annual GPS World Leadership Dinner and Awards Ceremony. This wonderful and prestigious event is the brainchild of Alan Cameron, our beloved editor-in-chief and now publisher of GPS World. Every year the event just gets better and better. The venues are always palatial, and this year was no exception as we held the event at the beautiful Nashville Hermitage Hotel. The stained-glass ceiling in the lobby was astounding.
I won’t say much more since Alan wrote a complete review of the evenings events, except to caution you that invitations to this wonderful event are extremely hard to come by, and if you are nice to me, who knows? You might receive an invitation next year. It reminds me of the admonition from my daughter, a PsyD in Psychology and a practicing clinical psychologist, when she says: “You should always be nice to me Dad. Remember, I get to pick your nursing home!”
Kudos and Final Thoughts on ION GNSS 2012
I can’t complete my comments on ION GNSS this year without pointing out that the venue, Nashville or Music City, and the Renaissance Hotel by Marriott were both outstanding. The ambience of the entire event was professional yet also warm and friendly, and the ION staff as well as the staff at the Renaissance could not do enough to make my stay more memorable. The Renaissance staff was extremely professional and attentive, working hard to make the event a success. I am already looking forward to next year’s conference, which will be held at the same location September 16-20, 2013. Book early and arrive early for reasons I elucidate next.
Lest we forget, while the ION GNSS is the main performance, the center ring if you will, it is historically preceded by the Civil GPS Service Interface Committee (CGSIC) meeting, which is co-chaired by the United States Coast Guard (USCG) NAVCEN/CC. The CGSIC has been around for 52 years, and was outstanding this year. Yes, the title sounds incredibly dry and boring, but CGSIC meetings are actually very informative, down to earth, informal and even occasionally entertaining. The new USCG NAVCEN commander, Captain William Burns, and his NAVCEN team did an excellent job putting the event together. So, again, I highly recommend arriving a couple of days early for next year’s ION GNSS in Nashville, so you too can attend the CGSIC. You will find it worthwhile.
LightSquared
As much as I hate to close my column on a downer I must unfortunately inform you that the amnesiacs at LightSquared (LSQ) are at it again. Not exactly the same amnesiacs, of course, as their CEO resigned in February, and Philip Falcone from Harbinger, whose solipsistic behavior resulted in a federal security SEC indictment for fraud, joined the LightSquared board recently. The U.S. Securities and Exchange Commission recently filed securities fraud charges against Falcone and Harbinger Capital Partners. However, this has not slowed LSQ as it subsequently on Septembert 28 submitted two proposed spectrum sharing filings with the FCC, proposing to utilize the lower 5 MHz of LSQ’s non-existent broadband network in a form that was not initially sanctioned or envisioned and, according to the filings, will not interfere with GPS signals. LSQ did not submit any evidence or test data to prove the lack of interference, just conjecture. These filings, of course, are in addition to LSQ’s recent filing for Chapter 11, better known as a bankruptcy filing. Plus, Philip Falcone has publicly alerted the FCC that LightSquared will not go away!
Where have you heard this song and dance before? I have read both filings very carefully, and they are filled with the same flawed technology and total refusal to adhere to the laws of physics as their previous filings. LSQ fails to understand that you cannot abrogate the laws of physics merely because they are inconvenient and interfere with your grand scheme. Previous test results have determined that transmitters as powerful as the ones proposed by LSQ will interfere with GPS signals no matter what portion of the immediately adjacent spectrum bands are proposed.
The latest filings clearly seem to be a last-gasp effort of a dying company that is attempting to snatch victory from the jaws of defeat. LSQ must think the U.S. government has an incredibly short attention span. In my humble opinion, if the FCC were to approve either of the proposed filings, pilots, airlines and passengers at Ronald Reagan National Airport and other major airports on the East Coast would be unable to use GPS to fly out of or navigate to the airports. LSQ continues to think it is more important to be able to tweet, “I just saw Elvis” than it is to navigate safely to your destination. However, as improbable as the acceptance of these LSQ filings may be, in a recent memo I warned my GPS/PNT colleagues, via notable quotes you may recognize, “…unfortunately this is not over, ‘prepare for boarders’ and remember ‘we have not yet begun to fight’.”
GPS II-F 3
Fortunately, I won’t end on a down note after all. As I write this, the third GPS IIF satellite, designated SVN-65, is on orbit being checked out by the 19th SOPS (Space Operations Squadron) with LADO (Launch, Anomaly, and Disposal Operations) software developed by Braxton Technologies. My hat is off to AFSPC (Air Force Space Command), SMC (Space & Missile Systems Center), Boeing, ULA (United Launch Alliance), the 50th Space Wing, and Braxton Technologies for a successful launch and hopefully a quick and flawless checkout. It has been a long 15 months since the last IIF launch, and this is the only launch in calendar and FY12. Plus, technically the satellite on orbit is actually satellite vehicle (SV) four, as SV three is undergoing some necessary changes. Most experts expect a minimum 30-day checkout. However, my sources tell me it could be as long as 90 days. Wouldn’t it be great if it were sooner? We will just have to wait and see. Stay tuned to GPS World for the latest news on GPS IIF-3. The good news is we have another GPS IIF on orbit.
Until next time, happy navigating, and remember all of us at GPS World now have new email addresses in the following format. If you wish to email me please do so at [email protected]. I look forward to your comments.
JAVAD GNSS announces that it has improved its GNSS protection filters, not only to protect the L1 band against all interferences (including LightSquared 10L, 10H and 10R handset), but to protect against all other interferences which may come in any other GNSS band.
The company calls its improved filter the J-Shield, and states that it will “help make the bands near any GNSS band free for other usages like broadband wireless, which the United States desperately needs to catch up with other nations, as currently the United States is number 16 in the world [in broadband capacity], and to help to create competition to potentially reduce U.S. wireless broadband costs to 1/3 of what they are today.”
CEO and founder Javad Ashjaee will present details on the J-Shield on Thursday, September 20, at the ION-GNSS conference in Nashville, Tennessee, in a talk titled “All about GNSS Interferences and Jammers.”
The talk will cover:
Where does interference come from?
How to know, view, quantify and analyze interference.
How to protect against interferences.
Implementation of these features in JAVAD GNSS’s mass-produced commercial products.
Introduction of the J-Shied for all GNSS bands.
The company will also have an exhibit on the ION-GNSS show floor in the Nashville Convention Center, from Wednesday, September 19 to Friday, September 21.
Although the LightSquared issue seems to have waned, it’s like a virus in that it’s really difficult to erradicate it completely. However, Harbinger Capital Partners (LightSquared’s primary financial backer) and LightSquared are facing tougher problems than they have since they’ve started this adventure, not only from their technical foes but now from the U.S. Securities and Exchange Commission (SEC).
Earlier this week, the SEC filed fraud charges against Phil Falcone and Harbinger. In particular, the SEC alleges that:
Falcone fraudulently obtained $113.2 million from a hedge fund that he advised and misappropriated the proceeds to pay his personal taxes;
Falcone and two Harbinger investment managers through which Falcone operated manipulated the price and availability of a series of distressed high-yield bonds by engaging in an illegal “short squeeze;”
Falcone and Harbinger secretly offered and granted favorable redemption and liquidity rights to certain strategically-important investors in exchange for those investors’ consent to restrict redemption rights of other fund investors, and concealed the arrangement from the fund’s directors and investors; and
Harbinger engaged in illegal trades in connection with the purchase of common stock in three public offerings after having sold the same securities short during a restricted period.
“Not only are hedge fund managers expected to be savvy investors, they are supposed to serve the interests of their clients. Here, in addition to raiding a fund for personal benefit and cutting secret deals with favored investors, Falcone then lied to investors about what he had done,” said Bruce Karpati, Chief of the Asset Management Unit in the SEC’s Division of Enforcement.
Yes, it’s getting ugly. However, they aren’t giving up. I wouldn’t expect so after spending ~$4 billion on this project.
LightSquared’s latest proposal to the Federal Communications Commission (FCC) is a spectrum swap. Read the details of their proposal here. In fact, LightSquared was able to convince a group of your legislators to lobby the FCC in support of the spectrum swap.
“In the absence of a viable technical solution that would allow LightSquared to use its own licensed spectrum, we believe a spectrum swap is the most resourceful and efficient way to quickly expand broadband access nationwide,” wrote Reps. Jim Moran (D-Va.), Maurice Hinchey (D-N.Y.), Steve Rothman (D-N.J.), Rodney Alexander (R-La.) and Ander Crenshaw (R-Fla.), who all serve on the Appropriations Committee.
Seriously? Our own U.S. legislators want to trade for spectrum worth almost nothing for spectrum worth billions of dollars? Who’s side are these people on? Clearly, not the taxpayer. However, there’s little or no chance a spectrum swap is going to happen. It’s a dream that they ran up the flagpole so see who would salute it. I doubt anyone did, at least anyone of significant influence, and now the legislators can say they fulfilled their obligations (in exchange for ??) and no harm done.
Serious Technical Issues Still Exist
Aside from the serious financial, legal, and political challenges LightSquared faces, they are no closer to solving the GPS interference problems disclosed a year ago.
If you recall, the National Telcommunications and Information Administration (NTIA), a U.S. government agency tasked by the FCC to study the LightSquared/GPS interference issue, concluded:
“The federal agencies and LightSquared have invested significant time and resources to identify and analyze proposed solutions to address the impact of LightSquared’s planmned network implementations. Based on the testing and analyses conducted to date, as well as numerous discussions with LightSquared, it is clear that LightSquared’s proposed implementation plans, including operations in the lower 10MHz would impact both general/personal navigation and certified aviation GPS receivers. We conclude at this time that there are no mitigation strategies that both solve the interference issues and provide LightSquared with an adequate commercial network deployment.”
That pretty much says it all. While the “lower 10” the NTIA is likely a technically solvable problem, the cost of redesigning and redeploying GPS receivers across commercial, military, aviation, etc. markets to accomodate the lower 10 MHz is huge. It’s likely in the high tens of billions or even into the hundreds of billions.
The upper 10 MHz of LightSquared’s spectrum, there is no practical technical solution that exists. If there was one, even one that was close, LightSquared would be talking about it all day long. You can bet that many engineers from many different companies and agencies have been working to solve this technical problem since early last year, but no one has come up with any reasonable solution yet. Also, remember that the upper 10 MHz hammered the vast majority of all GPS receivers in existence, not just high-precision receivers.
The Way Forward
Without a technical solution to their GPS interference problem, LightSquared is stuck trying to convince regulators that it deserves to be gifted alternative spectrum since they couldn’t make theirs work. As I wrote earlier, I think the possibility of a spectrum swap is low, but the conversation may linger.
From now on, it’s clear that the technical discussion has disappeared. It’s turning into a pure political discussion. Even though the FCC received the NTIA’s recommendation to not allow LightSquared to proceed back in February, the FCC still hasn’t declared a ruling on anything regarding this matter. Some speculate that they won’t make a ruling before the U.S. presidential election this coming November in order to fly under the radar. For this reason, it would not be surprising to me if this issue hung in limbo for the rest of the year; dormant, but it’s still lurking, like a virus.
Last Monday, June 25, 2012, I was a guest on America’s Web Radio’s ACSM Radio Hour discussing the current LightSquared situation. It’s a good discussion (60 minutes). The podcast is a standard audio recording you can play on your MP3 player or listen to on your computer. You can download it here.
FCC Narrowbanding Rule
While we’re on the subject of the FCC, you might have heard about the Narrowbanding rule the FCC established some years ago. It’s going to kick in January 1, 2013. If you’re an RTK user who uses UHF or VHF radios, you’re likely going to be affected and should be aware of it. Following is a summary statement from the FCC:
“On January 1, 2013, all public safety and business industrial land mobile radio systems operating in the 150-512 MHz radio bands must cease operating using 25 kHz efficiency technology, and begin operating using at least 12.5 kHz efficiency technology. This deadline is the result of an FCC effort that began almost two decades ago to ensure more efficient use of the spectrum and greater spectrum access for public safety and non-public safety users. Migration to 12.5 kHz efficiency technology (once referred to as Refarming, but now referred to as Narrowbanding) will allow the creation of additional channel capacity within the same radio spectrum, and support more users.
After January 1, 2013, licensees not operating at 12.5 KHz efficiency will be in violation of the Commission’s rules and could be subject to FCC enforcement action, which may include admonishment, monetary fines, or loss of license.”
Essentially, the FCC is trying to increase the efficiency of the UHF and VHF radio spectrum so it can accomodate more users.
If you use UHF or VHF radios for RTK, you’ll likely need to upgrade or replace your UHF/VHF radio hardware. Be aware that this could be quite expensive.
Following are some relevant FCC documents on the matter:
On June 27, 2012, the Securities and Exchange Commission filed fraud charges against New York-based hedge fund adviser Philip A. Falcone and his advisory firm, Harbinger Capital Partners LLC for illicit conduct that included misappropriation of client assets, market manipulation, and betraying clients. The SEC also charged Peter A. Jenson, Harbinger’s former Chief Operating Officer, for aiding and abetting the misappropriation scheme. Additionally, the SEC reached a settlement with Harbinger for unlawful trading.
In a separate, settled action, the SEC charged Harbert Management Corporation, whose affiliates served as the managing members of two Harbinger-related entities, as a controlling person in the market manipulation.
The SEC alleges that Falcone used fund assets to pay his taxes, conducted an illegal “short squeeze” to manipulate bond prices, secretly favored certain customers at the expense of others, and that Harbinger unlawfully bought equity securities in a public offering, after having sold short the same security during a restricted period.
“Today’s charges read like the final exam in a graduate school course in how to operate a hedge fund unlawfully,” said Robert Khuzami, Director of the SEC’s Division of Enforcement. “Clients and market participants alike were victimized as Falcone unscrupulously used fund assets to pay his personal taxes, manipulated the market for certain bonds, favored some clients at the expense of others, and violated trading rules intended to prohibit manipulative short sales.”
The SEC filed actions in U.S. District Court for the Southern District of New York against Falcone, Jenson, and Harbinger, and, in connection with the illegal trading scheme, separately instituted and settled administrative and cease-and-desist proceedings against Harbinger.
In particular, the SEC alleges that:
Falcone fraudulently obtained $113.2 million from a hedge fund that he advised and misappropriated the proceeds to pay his personal taxes;
Falcone and two Harbinger investment managers through which Falcone operated manipulated the price and availability of a series of distressed high-yield bonds by engaging in an illegal “short squeeze;”
Falcone and Harbinger secretly offered and granted favorable redemption and liquidity rights to certain strategically-important investors in exchange for those investors’ consent to restrict redemption rights of other fund investors, and concealed the arrangement from the fund’s directors and investors; and
Harbinger engaged in illegal trades in connection with the purchase of common stock in three public offerings after having sold the same securities short during a restricted period.
“Not only are hedge fund managers expected to be savvy investors, they are supposed to serve the interests of their clients. Here, in addition to raiding a fund for personal benefit and cutting secret deals with favored investors, Falcone then lied to investors about what he had done,” said Bruce Karpati, Chief of the Asset Management Unit in the SEC’s Division of Enforcement.
Describing the illegal short squeeze, Gerald W. Hodgkins, Associate Director of the SEC’s Division of Enforcement said, “After he took control of an entire issue of high-yield bonds, Falcone kept buying with an eye toward rigging the market and punishing short sellers to settle a score. In the process, Falcone hijacked the market for the bonds and illegally manipulated their price and availability. The Division will continue to police the bond market to make sure it operates as an efficient market, free of the corrosive effects of manipulators such as Falcone.”
Misappropriation Scheme
In the misappropriation scheme, the SEC alleges that Falcone unlawfully used fund assets to pay his personal taxes. In 2009 Falcone owed federal and state authorities $113.2 million in taxes. Declining to pursue other financing options, such as pledging his personal assets as collateral for a bank loan, Falcone elected instead to take a $113.2 million loan from the Harbinger Capital Partners Special Situations Fund, L.P. – the same fund from which Harbinger had earlier suspended investors from redeeming.
Falcone authorized the transfer of fund assets to himself in a transaction that Jenson helped structure. Falcone and Harbinger never sought or obtained consent from investors prior to using the fund's assets to benefit Falcone.
As part of the misappropriation scheme, the SEC alleges that Falcone and Harbinger, aided by Jenson, made several material misrepresentations and omissions in seeking legal advice regarding the loan and in subsequent communications with investors, including, among other things:
the financing alternatives available to Falcone;
the circumstances that led to Falcone’s need for the loan;
the ability of the Special Situations Fund to furnish the loan, without disadvantaging investors;
the terms and conditions of the loan, including the interest rate charged and the amount of collateral posted by Falcone; and
the role of Harbinger’s outside legal counsel in vetting the transaction.
The SEC also alleges that Falcone and Harbinger delayed disclosing the loan for approximately five months because of their concern that disclosure of Falcone’s financial condition might have a negative impact on investor withdrawals and on Falcone’s ability to attract more investments for other Harbinger funds. Falcone repaid the loan in 2011, after the Commission commenced its investigation.
Market Manipulation / Illegal Short Squeeze
In a separate civil action, the SEC alleges that from 2006 through early 2008 Falcone and two Harbinger investment management entities manipulated the market in a series of distressed high-yield bonds issued by MAAX Holdings Inc. In this fraudulent scheme, Falcone and the Harbinger entities allegedly orchestrated an illegal “short squeeze” – a market manipulation scheme in which an investor constricts the supply of a security, through large purchases or other means, with the intent of forcing settlement from short sellers at arbitrary and inflated prices.
The SEC’s complaint alleges that at Falcone’s direction, Harbinger purchased a large position in the MAAX bonds during April and June of 2006. After hearing rumors that a Wall Street financial services firm was shorting the MAAX bonds and also encouraging its customers to do the same, Falcone decided to seek revenge. In September 2006, Falcone directed the Harbinger-managed funds to buy every available bond in the market, often purchasing the bonds from short sellers. Ultimately, Falcone raised the funds’ stake to approximately 13 percent more than the available supply of the MAAX bonds.
At one point, Harbinger had purchased 22 million more bonds than MAAX had ever issued. Contemporaneously with these purchases, Falcone locked up the MAAX bonds the Harbinger funds had purchased in a custodial account at a bank in Georgia to prevent his brokers from lending out the bonds to sellers seeking to deliver the bonds to purchasers after short sales.
Having seized control of the supply of the MAAX bonds, Falcone then demanded that the Wall Street firm and its customers settle their outstanding MAAX short sales, not disclosing that it would be virtually impossible to find bonds available for delivery. The Wall Street firm bid daily for the bonds, which quickly doubled in price. Then, Falcone engaged in a series of transactions with certain short sellers at arbitrary, inflated prices, while at the same time valuing the funds’ holdings on his books at a small fraction of the prices he charged the covering short sellers.
Preferential Redemption Scheme
In its action alleging misappropriation, the SEC also alleges that in a further breach of Falcone and Harbinger’s fiduciary duties to their clients, Falcone and Harbinger engaged in unlawful preferential redemptions for the benefit of certain favored investors.
In 2009, while soliciting required investor approval to restrict withdrawals from another Harbinger fund, Falcone and Harbinger secretly exempted certain large investors that Falcone deemed to be strategically important from soon-to-be imposed liquidity restrictions – provided those investors voted to approve restrictions that would temporarily stabilize the decline in Harbinger’s assets under management.
Ultimately, pursuant to these ‘vote buying’ agreements, Falcone and Harbinger allegedly permitted these investors who were connected to certain favored institutional investors to withdraw a total of approximately $169 million. Harbinger concealed these quid pro quo arrangements from the independent directors and from fund investors.
Other Illegal Trading by Harbinger
In a separate administrative and cease-and-desist proceeding, the SEC found that between April and June 2009, Harbinger violated Rule 105 of Regulation M of the Securities Exchange Act of 1934 (Exchange Act). Rule 105 is an anti-manipulation rule that prohibits short selling securities during a restricted period and then purchasing the same securities in a public offering.
The Commission’s Order censures Harbinger and requires the firm to cease and desist from committing or causing any violations of Rule 105 now or in the future. Harbinger will pay disgorgement in the amount of $857,950, prejudgment interest in the amount of $91,838, and a civil monetary penalty in the amount of $428,975. Harbinger consented to the issuance of the Order without admitting or denying any of the Commission’s findings.
Settlement with Harbert Management Company
In a separate complaint also filed in U.S. District Court for the Southern District of New York, the SEC filed a settled civil action against Harbert and two related investment entities – HMC-New York Inc. and HMC Investors, LLC – for their role in the illegal short squeeze described above.
The SEC alleges in its complaint against Harbert that during the entire period of the short squeeze, Defendants Harbert, HMC-NY and HMC Investors, directly or indirectly, possessed the power to control Falcone and the investment managers through which he operated. HMC-NY and HMC Investors, two entities controlled by Harbert, served as the managing members of two limited liability companies that acted as the general partners of the funds advised by Falcone.
Harbert and its affiliates also provided hedge fund administrative, legal, compliance, risk assessment and other services to the funds. In these capacities, Harbert, HMC-NY and HMC Investors knew of Falcone’s trades in the MAAX bonds, but failed to take appropriate steps to address Falcone’s manipulative conduct. The SEC charged the Harbert defendants as controlling persons pursuant to Section 20(a) of the Exchange Act, alleging that they are jointly and severally liable for Falcone’s and the Harbinger investment managers’ violations of the antifraud provisions of the Exchange Act.
Without admitting or denying the allegations of the complaint, Defendants Harbert, HMC-NY and HMC Investors have agreed to pay a civil penalty in the amount of $1 million. The Harbert defendants also have consented to the entry of a judgment enjoining them from violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder. The proposed settlement with Harbert is subject to approval by the court.
In the pending federal court actions concerning the first three fraudulent schemes described above, the Commission seeks a variety of sanctions and relief including injunctions against Falcone and Harbinger from violations of the anti-fraud provisions of the Securities Act of 1933, the Exchange Act, and the Investment Advisers Act of 1940.
In addition, the Commission seeks to enjoin Harbinger and Falcone from controlling any person who violates the anti-fraud provisions of the Exchange Act. As for monetary relief, the Commission seeks disgorgement of ill-gotten gains, prejudgment interest, and civil money penalties from Falcone and Harbinger. The Commission further seeks to prohibit Falcone from serving as an officer and director of any public company. Against Jenson, the Commission seeks to enjoin Jenson from aiding and abetting future violations of the anti-fraud provisions of the Exchange Act and Advisers Act and seeks to obtain monetary penalties.
The SEC’s investigation was a coordinated effort between teams from the SEC’s headquarters and the New York Regional Office, including Conway T. Dodge, Jr., Robert C. Besse, Ken C. Joseph, Mark Salzberg, Brian Fitzpatrick, and David Stoelting. Messrs. Joseph, Salzberg, and Fitzpatrick are members of the Enforcement Division’s Asset Management Unit. Mr. Stoelting and David Gottesman will lead the SEC’s litigation team.
LightSquared, the company that mounted a powerful threat to GPS signals, declared bankruptcy on May 14, after losing a lengthy struggle in the court of the Federal Communications Commission (FCC) with the GPS industry, the U.S. military (behind the scenes), the Federal Aviation Administration, and many other GPS users. However, the vacuum into which Lightsquared sought to step — a dearth of spectrum for exploding mobile data use, up 123 percent last year — remains a gaping hole that will likely attract other entrants.
The Lightsquared bankruptcy move followed collapse of negotiations with lenders to the company, and will likely give CEO Philip Falcone several further months of control. It is not known whether his efforts will seek to salvage the business plan to provide wholesale broadband capacity to wireless carriers, who need more capacity to feed a ravenous market. In her May Wireless Pulse column, GPS World contributing editor Janice Partyka writes, “Carriers [at the CTIA industry show] sounded alarms about running out of spectrum to support ballooning mobile data consumption.”
As a result of the February FCC decision to revoke LightSquared’s conditional waiver to broadcast a powerful terrestrial signal immediately adjacent to a band reserved for satellite services, the company’s main asset, its spectrum license, lost most of its potential value, unless significantly repackaged and redirected, or traded for another spectrum band..
In late 2010, when the LightSquared threat first surfaced, Falcone maintained that LightSquared’s interference issues were not his to solve, because GPS users were encroaching on his spectrum. “People who are in adjacent bands have to understand that there is now a new driver in town driving on that highway,” he said. “And they can’t be weaving in and out of that highway.”
Falcone now has to deal with creditors who include Carl Icahn, the near-legendary corporate raider. Icahn and other investors have bought about $300 million of LightSquared debt. “Icahn is a take-control, alpha-male investor,” said Brad Balter, head of Balter Capital Management, as quoted in a May 3 Business Week story. “Falcone is both desperate and naive if he thinks of Icahn as anything other than an adversary who would wrest control of the spectrum if LightSquared went into bankruptcy.” What Icahn might venture if he gained control of LightSquared spectrum represents another unknown on the GPS horizon.
Spectrum Shortage. Meanwhile, writes GPS World editor Partyka, “Verizon Wireless and T-Mobile executives complained that the future of data use is at risk if more spectrum isn’t put to use. FCC Chairman Julius Genachowski defended the agency’s decision to block the AT&T T-Mobile deal with a rejoinder about spectrum shortage. ‘Some have argued that transactions — let’s be frank, one transaction — is somehow causing a shortage,’ said Genachowski. ‘But the overall amount of spectrum hasn’t changed.’ While this is true, spectrum is a concern. CTIA reports that U.S mobile data traffic surged 123 percent in 2011.”
In a statement regarding the company’s bankruptcy filing, Marc Montagner, interim co-chief operating officer and chief financial officer, stated “All LightSquared distribution partners and customers, including public safety, emergency response, government, and military users of LightSquared’s satellite-based communications services can continue to rely on LightSquared to provide them with mission critical communications services. The filing was necessary to preserve the value of our business and to ensure continued operations. The voluntary Chapter 11 filing is intended to give LightSquared sufficient breathing room to continue working through the regulatory process that will allow us to build our 4G wireless network.”
In your March editorial, “The Fire Next Time,” you ask for suggestions to protect against another LightSquared encroachment. The solution is remarkably simple. Just let the same bandwidth be used for space downlink as it was originally intended. That would be both innocuous to GPS receivers and, more importantly, stake the ground against future challenges like LightSquared.
Following is a guest editorial by GPS World’s contributing editor for Defense, Don Jewell.
Advanced low-frequency (LF) signals are back on the air in North America, with live testing of a wide-area precise-timing solution. Initial tests include a comprehensive pallet of signals, including eLoran, that are being evaluated for their ability to provide a robust, wide-area, wireless precise-timing alternative that can operate cooperatively with GPS, or during periods of GPS unavailability.
The high-power, virtually jam-proof and spoof-proof LF signals operate independently of GPS and GNSS, and provide a Universal Coordinated Time reference, critical to many aspects of U.S. national infrastructure, on the order of tens of nanoseconds.
Not only is this an independent timing backup, but the LF signals can also be used as pseudoranges mixed with GPS, or if enough transmitters are available, as a fully independent PNT network — in other words, a true backup PNT capability for safety-of-life navigation, for dispatching first responders, and for supporting critical national infrastructures.
This is an extremely positive development, especially in light of the LightSquared debacle and the now better-understood vulnerabilities of the very low-power GPS signals.
I hoped I would never have to type that word again, as a noun or a verb, but LightSquared did serve to point out a dire need and shortcoming in the U.S. PNT infrastructure. Fortunately, the proposed eLoran system appears to be on track to fill that need perfectly.
For the first 32 years that GPS signals were broadcast, Loran-C served as a timing backup and a less accurate but viable navigation alternative. In 2010, the current U.S. administration unplugged Loran-C, against the recommendations of the Department of Transportation’s Positioning and Navigation (PosNav) Committee, the Department of Homeland Security Geospatial Committee, the DOT Undersecretary for Policy, and the DHS Deputy Undersecretary for Preparedness and National Protection.
Long story short: non-technical people forced ill-advised technical decisions.
At that time, Loran-C was 80 percent of the way through a critical metamorphosis into a new digital version known as enhanced Loran or eLoran, with better, more reliable transmitters, smaller receivers, and a virtually jam-proof signal structure. Many likened eLoran to a strong ground-based GPS with coded signals for security.
Since then, the government has spent more money dismantling the legacy Loran-C infrastructure than it would have taken to complete the remaining 20 percent upgrade to eLoran.
Let’s hope the eLoran demonstrations continue successfully, and that a contract is forthcoming quickly before anyone forgets the LightSquared lessons learned — like we would ever let that happen.
The LightSquared machine continues to implode as CEO Sanjiv Ahuja and Executive Vice President Martin Harriman resigned last week in the wake of the NTIA recommendations against LightSquared rolling out their system. This week, Bloomberg reported that Sprint will end its infrastructure sharing deal with LightSquared. Meanwhile, the FCC is accepting public comments on the NTIA’s recommendations.
On February 28, 2012, LightSquared announced that CEO Sanjiv Ahuja and Executive VP Martin Harriman resigned. Forbes reported that Ahuja will remain as LightSquared board chairman. LightSquared announced that Harbinger Capital Partners CEO Phil Falcone was appointed to the LightSquared board of directors. Chief Network Officer Doug Smith and Chief Financial Officer Marc Montagner will serve as interim co-chief operating officers while the search for a new CEO is underway. Amid the announcement, Falcone remained steadfast that LightSquared is focused on finding a solution.
“We are, furthermore, committed to working with the appropriate entities to find a solution to the recent regulatory issues. We, of course, agree that it is critical to ensure that national security, aviation and the GPS communities are protected. I am confident that working together, we can solve this problem…,” said Falcone.
In the week prior, on February 20, Reuters reported that LightSquared missed a $56.25M payment due to satellite partner Inmarsat. While LightSquared stated that Imarsat hadn’t completed it’s obligations, Inmarsat said it was negotiating with LightSquared but didn’t know if or when a payment would be made. Inmarsat issued a notice of default, starting the 60-day clock in which LightSquared has to resolve the issue. Inmarsat is a vital partner as LightSquared needs rights to certain MSS spectrum that Inmarsat has rights to. LightSquared has paid Inmarsat a total of $420M under their agreement, of which $260M was paid in 2011.
Inmarsat isn’t the only vital partner not happy with LightSquared. Yesterday (March 6), Bloomberg reported that Sprint will opt out of its infrastructure sharing agreement with LightSquared. LightSquared had planned to use 31,000 Sprint towers, in addition to contributing 3,400 of its own towers, to roll out their system. Building its own towers from scratch would be prohibitively expensive and would not allow LightSquared to meet the roll out schedule detailed in the January 26, 2011, FCC order.
The LightSquared-Sprint agreement is contingent on LightSquared gaining FCC approval. The original agreement expired December 31, 2011. Sprint agreed to grant a 30-day extension, some speculating for ~$20M. At the end of January, Sprint granted another extension, this time for 45 days, to March 15. Rumors are circulating that Sprint is done granting extensions. To date, LightSquared has paid Sprint $310M in prepayment for work. Sprint’s SEC filing last month stated that if LightSquared doesn’t achieve FCC approval by the agreed date (now March 15), Sprint is allowed to keep all but $74M of LightSquared’s deposit. MSS industry expert Tim Farrar called the $236M “the most expensive press release in the world” stating that Sprint had done “basically nothing in terms of deployment apart from some initial network planning.”
If Sprint pulls out, LightSquared is in a really tough spot. Although LightSquared owns its satellites for satellite-to-earth communications services, they are relying heavily on Sprint’s infrastructure for its terrestrial service.
Investor Lawsuit
Obviously, LightSquared investors aren’t happy about how their money was squandered. On February 17, 2012, a LightSquared investor filed a lawsuit against Harbinger Capital Partners and Phil Falcone. Investor Lili Schad, daughter of the inventor of the snowmobile and noted film director, says she invested $4M in Harbinger and that they “implemented a very different investment strategy, which bore little or no resemblance to the investment strategy described in the Offering Materials.”
Furthmore, the lawsuit states “By going all in on LightSquared, Defendents materially deviated from the Offering Material’s representations that the Fund would seek to achieve attractive returns by investing in distressing debt, special situation equities, and private loans and notes. The risks, rewards and time horizon implicit in the LightSquared investment were not those attendant upon an investment in a hedge fund with the objectives and investment strategy described in Harbinger’s Offering Materials.”
FCC Seeking Comments on NTIA Recommendations
The more than year-long battle between wireless start-up LightSquared and the GPS industry peaked on February 14, 2012 when the National Telecommunications and Information Administration (NTIA), tasked by the Federal Communications Commission (FCC) to study the potential interference problem between LightSquared’s mobile wireless proposal and GPS receivers, issued a statement and report with the following conclusion:
“The federal agencies and LightSquared have invested significant time and resources to identify and analyze proposed solutions to address the impact of LightSquared’s planned network implementations. Based on the testing and analyses conducted to date, as well as numerous discussions with LightSquared, it is clear that LightSquared’s proposed implementation plans, including operations in the lower 10MHz would impact both general/personal navigation and certified aviation GPS receivers. We conclude at this time that there are no mitigation strategies that both solve the interference issues and provide LightSquared with an adequate commercial network deployment.”
The FCC subsequently issued a statement including the following paragraph:
“NTIA, the federal agency that coordinates spectrum uses for the military and other federal government entities, has now concluded that there is no practical way to mitigate potential interference at this time. Consequently, the Commission will not lift the prohibition on LightSquared. The International Bureau of the Commission is proposing to (1) vacate the Conditional Waiver Order, and (2) suspend indefinitely LightSquared’s Ancillary Terrestrial Component authority to an extent consistent with the NTIA letter. A Public Notice seeking comment on NTIA’s conclusions and on these proposals will be released tomorrow.”
As promised, the FCC subsequently opened a Public Notice seeking comments based on NTIA’s report and conclusions. View the Public Notice here. Public comments close on March 16, 2012. If you have invested in GPS technology, you should enter your comments to protect your investment.
Submitting your comments to the FCC only takes five minutes. You don’t need to write an essay. Just state that you support the NTIA’s conclusion.
You can compose your comments in a text editor like Notepad, then save the file and attach it. Once you go to the FCC comment submission website, it will make sense. If you have any problems, email me.
Go to the FCC comment submission website by clicking here.
Type in the following information:
Proceeding Number: 11-109
Name of Filer: Enter your name
Address Line 1: Enter your address
City: Enter your city
State: Enter your state
Zip: Enter your zipe code
Attach your comments
That’s it. Five minutes and you’re done.
You might have heard about another Public Notice that the FCC issued regarding LightSquared. It is in response to LightSquared’s petition to rule that GPS receivers are not entitled to interference protection. I wrote about it last week. You can read my article here. At that time, I was planning to submit my comments, but that was before the NTIA released its report and conclusions this week. I wouldn’t suggest you not enter a comment to the earlier Public Notice, but certainly I’d focus on entering comments on the latest Public Notice in support of NTIA’s report and recommendations.
March 15 Webinar: “Everything Else but GPS: How GLONASS, Galileo, and Compass Will Affect High-Precision Users”
In a rapidly changing world — which is the world of GPS and GNSS — those who invest significant amounts of their operating capital in hardware must plan carefully for the future,” said Gakstatter, who serves as moderator of the webinar. “Will your survey receiver remain relevant and up to date long enough for you to recoup your investment? How could taking advantage of newly operational constellations improve your efficiency and competitiveness? GLONASS is operational now. Compass has put forward a very aggressive schedule for regional and then global operations. Galileo is moving steadily forward.
The webinar will be held at 10 a.m. Pacific (1 p.m. ET/6 p.m. GMT); registration is free.
