Join GPS World’s Survey and GIS Editor Eric Gakstatter March 15 for the webinar, “Everything Else but GPS: How GLONASS, Galileo, and Compass Will Affect High-Precision Users.” The webinar will be held at 10 a.m. Pacific (1 p.m. ET/6 pm. GMT); registration is free.
“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.”
Gakstatter closely follows all these systems, and can relate their capabilities — current and future — directly to surveyors’ needs. His guest speakers will add to the insight. This webinar is required listening for anyone planning to stay on survey’s leading edge.
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.
In my 20-plus years of involvement in the GPS/GNSS industry, nothing has come close to the LightSquared debate for technical and political complexity, nor for potential effects on nearly every high-precision GPS/GNSS user in the United States. The industry’s destiny is somewhat controlled by a federal agency that is not very knowledgeable about how, when, and where GPS is used — although I’m sure they’ve learned a lot in the last 14 months.
While receiver manufacturers have a firm grip on the technical complications of what LightSquared proposed, they have jockeyed for market position, as information released to the public is filtered through their marketing heads. Finally, media coverage is all over the place, from “LightSquared is doomed” to “this will happen.”
On January 13, as we all know, the U.S. deputy secretaries for defense and transportation wrote, on letterhead of the Space-Based Positioning Navigation & Timing National Executive Committee (PNT EXCOM), to the head of the National Telecommunications Information Administration (NTIA), declaring that “there appear to be no practical solutions or mitigations that would permit the LightSquared broadband service, as proposed, to operate in the next few months or years without significantly interfering with GPS.”
On February 14, the NTIA director wrote to the Federal Communications Commission (FCC) chairman in a similar vein with nearly the same language. That same day, the FCC stated its intent to “not lift the prohibition on LightSquared,” and to “vacate the Conditional Waiver Order, and suspend indefinitely LighSquared’s Ancillary Terrestrial Component authority.”
It just so happens that LightSquared cannot accomodate military GPS users nor aviation GPS users. Those of you who use high-precision GPS can thank your lucky stars that the military and aviation folks are standing in your corner. Otherwise, as I warned back in May of last year, high-precision users would have been thrown under the onrushing bus of national broadband.
In testimony to a House of Respresentatives subcommittee meeting on GPS and aviation in early February, the Transportation deputy secretary revealed that the Federal Aviation Administration (FAA) spent more than $2 million of taxpayer dollars with two different independent labs to conclude that LightSquared proposals were not compatible with several GPS-dependent air safety-of-flight systems.
Don’t expect the Department of Defense (DoD) ever to provide similar testimony. The Pentagon played its veto card off-air and out of the public eye.
LightSquared has continued to complain about GPS receivers “looking into our spectrum” as the reason for the interference GPS receivers are suffering. If you missed Richard Keegan’s December 2011 article in GPS World, you should take a look. He succinctly addresses this issue, as I did in my November 2011 Survey Scene column.
As LightSquared has clearly lost the engineering argument, it has taken a very creative approach in an attempt to convince the FCC that this isn’t an engineering problem, but rather all about the FCC rules. LightSquared petitioned the FCC to confirm that “GPS devices are not entitled to protection from interference.”
Crazy statement? If you think so, see if you recall reading this statement on equipment such as GPS receivers. It is on almost every electronic device that relies on radio signals.
“This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions:
“(1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.”
What if LightSquared can convince the FCC that GPS receivers do, indeed, fall within the confines of Part 15 of the FCC rules and aren’t entitled to interference protection? That’s what the company is trying to do, and that’s why this fight ain’t quite done.
Don’t underestimate the power of the White House pushing the National Broadband Plan, or of commercial interests — of which there are myriad — seeking to turn a buck on the hunger, whether real or only perceived, for limitless broadband. Even the transportation depsec allowed in his testimony as how “in the Obama administration, we believe deeply in what LightSquared is attempting to do, which is to make the Internet more accessible to more people all across the country. This is an urgent national priority.”
Communications for My RTK
Some people in the GPS industry who believe that the LightSquared service will do wonders for RTK operations, somehow replacing the communications methods we currently use (UHF/VHF, 900MHz, GSM/GPRS, CDMA, Wifi/Mifi, etc.). I disagree.
LightSquared was relying on Sprint’s infrastructure (~31,000 towers) for its terrestrial operations, supplementing them with ~3,400 LightSquared towers at some point. I’ve used Sprint’s mobile phone service for about 12 years and I used Sprint’s data card service for several years (not any longer). I pretty much know that Sprint is good for metro areas and poor for rural areas. Like other wireless providers (AT&T, Verizon, T-Mobile, etc.), Sprint is strong in some geographic areas, and weak in others. Since LightSquared is focused on serving people (densely populated areas) rather than geographic areas (e.g., farmlands), their terrestrial service is not going to be even close to being nationwide. LightSquared’s solution for areas not covered by their terrestrial service is to use satellite communications for Internet connectivity.
If you think you would enjoy ubiquitous coverage with satellite communications for your RTK operations, consider OmniSTAR’s service, which is in the same spectrum as what LightSquared proposed. OmniSTAR works great when there’s a clear view of the sky to one of OmniSTAR’s satellites (ironically, operated by LightSquared) such as in the agriculture industry. But I’ve used it a bit and — just like GPS — it doesn’t work in buildings, in vehicles, under trees, or in other obstructed-sky locations.
Can you imagine using a LightSquared mobile phone that doesn’t work in buildings, in cars, or under trees? You wouldn’t. Anyone who’s ever used RTK knows that spotty base/rover communications is the quickest way to spoil an RTK party. With GPS/GLONASS receivers allowing us to use RTK in places where we’ve rarely ventured before, the limitation wouldn’t be the number of navigation satellites in view, but rather if the LightSquared satellite was in view.
For those of you who heard that LightSquared might have been a good idea in order to make wireless mobile Internet access more affordable, I seriously doubt that statement as well. Documents in a huge Freedom of Information Act release by the FCC reveal what LightSquared was planning to charge its wholesale customers (not retail) when they were out of range of the terrestrial system and forced to use LightSquared’s satellite for wireless broadband. The wholesale cost of their satellite broadband service was to be $10 per megabyte (not gigabyte), an astonishingly high price for a company that’s been touting affordable, nationwide wireless broadband Internet service.
Upgrade Costs
A cool $2.4 billion was the official estimate given for aviation industry upgrades, should LightSquared have gone forward. I think that’s conservative because I doubt it covers the infrastructure upgrade cost (WAAS, GBAS, and so on) or the cost of NextGen program delays.
How about something closer to home? I queried the administrator of a statewide RTK network of 103 GNSS reference stations, and used his estimates to extrapolate national costs in that regard: 7,000 CORS receivers across the United States. They look like this: optimistic scenario, $64 million; likely,$92 million; worst-case scenario, $120 million.
Keep in mind that this is only the high-precision GPS/GNSS infrastructure in the United States. There are still hundreds of thousands of high-precision GPS/GNSS receivers owned by users across the country that would have to be upgraded. For many GPS receivers (think handheld), there will be no upgrade solution, so the manufacturer might offer trade-in credit for a new GPS receiver.
After spending time to understand the actual costs of accomodating LightSquared, one state legislator who initially voiced his support for LightSquared said “we can’t afford it.”
New Beginnings
Included in the NTIA report was a recommendation that, with time, GPS receivers could be redesigned in order to accomodate LightSquared’s 10L signal.
NTIA also reported that during the January 13 EXCOM meeting, it was agreed that “federal agencies will move forward this year to develop and establish new 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 vital to economic, public safety, scientific, and national security needs.”
In summary, GPS/GNSS receiver designs will change in the coming years and move towards more efficient use of spectrum. To me, a critical statement in the NTIA letter to the FCC is “without affecting existing and evolving” — meaning that not only should GPS be considered, but also GPS-like systems from other countries such as Russia’s GLONASS, Europe’s Galileo, and other developing satellite navigation systems and applications.
ERIC GAKSTATTER is contributing editor for survey of GPS World, and editor of Geospatial Solutions.
This week, I’m pleased to present to you an essay written by Gavin Schrock, a licensed land surveyor (Washington), technology writer and administrator of the Washington State Reference Network (WSRN), which operates 103 GNSS reference stations that comprise the statewide RTK Network. He has written about surveying, mapping, GNSS, civil engineering, GIS, and data management for industry and association publications. He is usually not as cynical as he is when facing potential forced upgrades/replacements/production losses for his profession and the GNSS community.
With plenty of announcements, posturing and news, expect another newsletter shortly from me recapping the LightSquared events of December and January.
Eric Gakstatter
Should GPS Users Accept New “Fees”?
“Eat your spinach, you no good’ infink [infant]’. Eat it. EAT IT. Eat it.!” – Poopdeck Pappy [from Popeye]
By Gavin Schrock, LS
GPS is free of charge; period. Apart from any costs you incur in securing your own equipment to utilize the signals from the GPS constellation, or to subscribe to some augmentation service, there are no direct user fees. This is codified in our nation’s laws; GPS is free of user fees and this policy has remained consistent throughout the history of the U.S. Global Positioning System. End users, industry, public safety, and some international agreements, are based on or rely upon this fundamental, ubiquitous, irrefutable, concept of free!
Not that a fee would not be a great revenue generator; it has often humorously commented on within the Position Navigation and Timing (PNT) circles of the government that if one penny could be charged every time a GPS-based position is generated that there would be no debt. But this is not a serious consideration, and for the very reason we have GPS in the first place: we’ve already paid for it. GPS is essentially a military program, a weapons system “friend with benefits”. Taxpayers own this system. It was funded for and is operated (in an exemplary manner) by the military for specific purposes, but is almost exclusively unique as a military program in that it provides almost unprecedented direct economic and public safety benefits to the civilian world as well. In other words; we really get our money’s worth out of this investment.
The military can keep it free because they reap enough internal benefits to justify the expenditures; like valuable encrypted services for their own national security purposes. Many fear that the military might lose a substantial portion of this justification if such things as P-Code encryption were turned off, as some have suggest (without the newer “M-Code” being fully deployed first) and that bean counters might start looking at fees. Fees are universally so unpopular for dual-use GNSS systems that no other constellation provider does, nor plans to do so, with the possible exception of the European Galileo system; and there is still great internal debate and dysfunction within the EU and the Galileo program on the design of a franchise model for user fees. Some have also tried to characterize expenditures for developing, deploying, operating and modernizing the GPS constellation as “subsidies” for GPS manufacturers and users. Many more view it as: we paid for it, we own it, and it ain’t a subsidy. Are lighthouses and highways considered subsidies?
You can freely look for and receive GPS signals anywhere they may roam, worldwide and in any band they may wander, not just the GPS Band. There are absolutely no restrictions on receiving GPS signals. The FCC regulates transmissions, not reception. You are not breaking any laws or “squatting” if you look for GPS signals in the next band or the one beyond that. You can try to look into an FM band with your VHF radio if you want. It may not make any sense, but there are no restrictions. What one does with received signals can run afoul of the law though (like eavesdropping on private conversations or decoding encrypted national security transmissions), but when it comes to GPS, there are no current restrictions on what you listen to.
That the FCC only regulates transmissions and not reception discounts calls by some (guess who), for the FCC to develop and enforce standards for GPS receivers. The FCC is generally only concerned with what things emit or transmit. A receiver does neither as it is transmissions and emissions that harm other users. There may be no legal standing for the FCC to regulate receivers. The same kind of selective indignation is heard the characterization of GPS units as being “unlicensed” (got a license for your FM car radio?). This is another attempt to deflect from the immediate issue at hand by implying that your GPS gear is somehow breaking some rules, is deficient, or that the manufacturers have been negligent. More storms in teacups?
No Steps Backward, Only Steps Forward
To this date, the gracious hosts of the GPS constellation (USAF) has not implemented any fundamental design changes that would force you to have to change your GPS uses, or incur any additional costs in doing so. Quite the opposite, there have been many improvements along the way which would make one consider a voluntary upgrade. An example of changes for the better include Selective Availability (deliberate degradation of GPS signal) being turned off in 2000. That action was made permanent in 2007 and such actions acknowledge the tremendous lateral benefits of civilian uses. It will not be until December of 2020 (at the earliest) that there will be any major change in the GPS signal (or spectrum) that will render any method or solution for utilizing the GPS solutions unusable or substantially compromised. The planned change is an option that the constellation provider may exercise at that time to no longer support selected elements of the GPS L1 P(Y) and L2 P(Y) signal characteristics. The U.S. Government acknowledges global use of GPS codeless and semi-codeless techniques is committed to maintaining as such for a whole decade for transition. That is an important distinction; a whole decade… there are no “gotchas” (nor should there be) when it comes to such a valuable amenity. This decade for transition primarily provides time for other constellation upgrades to reach fruition, providing alternatives and mitigating for the possible loss of codeless and semi-codeless functionality. That is another important distinction and concept; do no harm to one capability until there are alternatives completely in place to mitigate for the harm/loss.
Don’t Fee on Me…
If the U.S. government was to try to start charging some end users fees directly or via some other means like a surcharge on GPS gear, that would be met with such opposition as to drag the debate out in process and possibly the courts for far more than a decade. Such an action would also be breaching some hard wrought international agreements. Implementation of direct fees would be as improbable as being struck by a falling GPS satellite.
Now, if the constellation host (USAF, or if forced by another agency) were to make a design change that enabled a specific private entity or group of entities to be able to charge for use of the system (i.e. like an encryption, or spectral change that might cause you to have to buy some proprietary gear) then that would be a fee and that scenario would surely cause an even bigger storm!
But what if a U.S. government regulatory action rendered your current gear to become obsolete in some way? That you would have to incur expenditures to continue to use the very system you paid for, and through no fault or action of your own – would this in affect be a “fee”? (You probably know where I’m going with this). Some say this is moot, because (in their eyes and marketing dreams) your gear is already “obsolete”, and you should buy their gear right away.
Obsolete?
One would not expect the definition of a word like “obsolete” to be highly debatable, but one would have never expected a word like “ancillary”, or Ancillary Terrestrial Component to be up for debate either.
From the FCC: (“We clarify that ‘integrated service’ as used in this proceeding and required by 47 C.F.R. § 25.149(b)(4) forbids MSS/ATC operators from offering ATC-only subscriptions. We reiterate our intention not to allow ATC to become a stand-alone system. . . . We will not permit MSS/ATC operators to offer ATC-only subscriptions, because ATC systems would then be terrestrial mobile systems separate from their MSS systems.”).
Sorry, got sidetracked there. Obsolete. Now look at your high precision GPS gear, the gear that you maybe even purchased within the past year. If you were to use that gear today, you would have a reasonable expectation of a certain level of precision and reliability from that gear. There are no planned constellation/signal changes before the end of 2020 that would otherwise negatively impact the expected precision and reliability of your gear. Barring events or conditions completely out of your control, or that of the constellation hosts (natural or manmade disasters, invasions of GPS eating zombies, etc) your gear will not be in any way “obsolete” (with regards to current functionality) before 2020 at the earliest (and may still function long after that).
Your smart phone might be deemed “obsolete” by some of your technophile buddies because a new one came out, but yours still works. On the other hand some have opined “just because a company builds an electric car does not mean we should shut down all gas stations”. Comparing consumer level devices to expensive and sophisticated high precision GNSS gear is like comparing grapes and watermelons. Folks do not take too kindly to others telling them their gear is obsolete, or poorly designed – quibble about the details, but they don’t take too kindly just the same.
But what could make your gear obsolete? Apart from the previous scenarios (and no insult to folks who believe in GPS eating zombies) there are things out there that could potentially compromise your ability to use your current gear, but none, other than things like space weather and malicious jammers (that deliberately set out to mess with current GPS capabilities), are not within your realm of control, or for the most part the control of the constellation providers. However, there is that controversial broadband plan under review that sets out to introduce a new source of interference (that does not currently exist in the specific form, strength, and coverage) being so heavily debated during this past year.
If this perpetually-revised broadband plan is to be given the go ahead, then a new source of interference will require an upgrade or replacement of many high precision and general navigation and aviation GPS units, and if the costs of upgrades and production interruptions fall on the end users, this will, in effect, be a “fee” (or at least smell like one). Likening these costs to a fee is not any crazier or out of line than the barrage of claims and counter-claims brought about by this recent GPS-Broadband “mad as a box of frogs” debate. There are all kinds of arguments, or rationalizations of unpopular positions, that run the gamut from specific technical considerations, politics, deflection, projection, test result rejection, lobbyist injection, to “we already have full rights to do this, GPS must accept the interference.” If that were the case, then why did there have to be a waiver? – and a waiver with strict conditions attached at that?
The broadband applicant and the GPS industry have sparred mightily. Have the conditions of the waiver been met? Who’s fault was it? Bad receiver designs or flawed and rushed broadband plan? [Insert your own favorite rhetoric or talking point here]. Leaving all that aside for a moment, a big overlooked question is, what about the innocent bystanders that will take the heat if it is approved? The end users subject to a new “fee” of sorts. While there is fleeting mention of the “who pays?” in the deliberations (that only seems to go as deep as “the other guys should pay”), no party has set forward a practical plan to cover those costs other than the end user eating them. The highest probability is that the end user will have to eat this “fee” and that will be quite a blow to many people.
Is the fix in, for the fix that is in?
There has been a lot of alchemy going on over the past year with regards to this matter; attempts to turn straw into gold; like the effort to turn low-cost satellite spectrum into golden terrestrial spectrum, and more recent efforts to try to spin what will amount involuntary upgrades (“fees”) as some kind of “gift”. Involuntary expenditures end users will have to incur, to continue to use their perfectly fine GPS gear and perfectly fine spectrum and perfectly fine constellation, as they were designed for and as they are accustomed to, are a defacto fee! To try to spin something so unsavory into a gift, gem, or blessing in disguise, is being viewed widely viewed as self serving and somewhat disingenuous. There is a reason why alchemy went out of style centuries ago by the way.
One way to help someone swallow something unsavory is to sugar coat it, convince someone that it does not taste too bad and won’t make them sick, or wrap it in something that appeals to them. It is very likely that all manufacturers will see fit (if the plan is indeed forced on us) to sweeten the deal to soften the blow, offer incentives, and throw in cool features. No matter how cool the deal is, and what amazing features “you’d be a fool to pass up” are, there is still an element of being forced to pay to be able to continue to use GPS as you are accustomed.
Setting aside this controversy for a moment, there are several schools of thought about upgrades. Like any product, developers (even sometimes with the purest of intentions) work very hard to develop new features and hope we see those as valuable enough to spark an upgrade or replacement purchase. This can be wonderful and with healthy competition we benefit from options for both “nice to have” new features to groundbreaking “must have” features. High precision GPS gear is not consumer GPS gear, and most folks do not buy every new unit that comes out. Do you buy a new car every year? Most need to get several years of use out of the gear to realize cost-benefit, but for others a constant upgrade can pencil out. The growing popularity among heavy users (especially construction) of leasing gear ensures all of newest features, configuration, and firmware (remember that every support call starts with “what firmware version are you on?”). This does not work for everyone and so far as there has not been a forced upgrade or other planned obsolescence, users have reasonably expected many years of reliable use out of their current gear.
Selling (and opposing) the controversial broadband plan that sparked this flurry of debate, has been a well-funded and ongoing effort. No one disagrees that more wireless would benefit a lot of people and even laterally the very end users that will have to pay the “fees” to make it a success. We’ve been told that this plan heralds a new chapter/era/breakthrough in wireless. But it is not like there is some amazing new technology in play that could not be served by other plans, existing or in the works, that do not hurt GPS, and then we find out that the plan might not be as ubiquitous as we might think.
We’ve been told that this is an epic battle between and “obstructionist GPS community and the very future of broadband!” Not quite; LTE is already here, growing, and there are quite a few other initiatives under way, including several hybrid satellite-terrestrial proposals that do not pose immediate threats to GPS. Opposition to this plan does not impact the entire future of all broadband. Plus there is a substantial amount of spectrum being “sat on”, and numerous tests show seriously underutilized spectrum. This has more to do with operational, marketing, and poorly functioning systems that just needs good management and policies. Of course more spectrum needs be sought over time, but why are some of the more recent (and vocal) advocates (even from within the GPS community) for this specific plan so hung up on the supposed “criticality” of this one specific plan. Wouldn’t it be better for both the expansion of broadband and the GPS community to advocate for better management of existing spectrum? Or is it better to zero in on one piece of spectrum that represents a hazard to current GNSS? How about working on underutilized spectrum and give sufficient time to work out solutions for the MSS/GPS bands? This haste and laser focus on this GPS-unfriendly option raises a lot of questions and hackles as we have seen.
We’ve been told variations over time how the interference can “all be fixed with a ten cent filter” to “some components only cost $6″, to $300, to $800, to $5,000, to a thousand bucks a year, to… (lets drop that for a moment). We’ve also been pitched that the plan will bring forth a new cut-rate nationwide RTK network (which may not be as practical or nationwide as some might think). Though there would be benefits of more wireless choices, and a great many investors would benefit as well; does one segment of the population have to take the bullet for this success?
New features added to sweeten the deal might be well worth the cost when separately considered as a voluntary purchase (or not), but if someone wants to eschew the sweeteners, can they get upgraded for free?
A spoon, or shovel full of sugar helps the medicine go down…
Manufacturers have always admirably striven to create new and amazing features, and then the sales and marketing folks have to turn those into “must have” features. This latest move with the “GPS upgrade fee sweeteners” is not an exception. Some sweeteners that will likely be added to the “GPS upgrade fee” might be “must have” to some, but might include features that are not quite ready for prime time in the view of some, or do not solve “make or break” issues for other end users. End users are savvy enough to decide what to buy and when, and if not forced to do so will buy based on business needs and cost benefits. Folks do not take too kindly to salesmen implying that they are “fools for not taking advantage of this deal”.
For example, a forced upgrade might be offered with modifications to get access to more constellations and signals (for the limited numbers of receivers that can take that kind of upgrade). A lot of folks already have with their current gear, L5, Galileo, and other signals capability (or at least placeholders and will be waiting years before those come to fruition). Others wait until a constellation or signal is fully deployed before making a big purchase or commitment. It was announced December 27th, 2011 that the Beidou/Compass constellation has been declared operational, but how many years before that will make any difference to you in the field? Trying to sell something that is not yet ready for prime time can have mixed results. Do you remember the dark times of the old Glonass constellation? Unlike today when it has been successfully modernized and is at full deployment, there were past precision issues reported when using Glonass. I asked a few manufacturers why a decade ago they did not heavily market their early Glonass capable gear, one response was “we did not want a customer to go out there and get [poor] results and then blame us for pushing Glonass on [them]”. Many users may be wise wait until these new constellations and signals have matured.
A noble ambition/feature is to solve the filtering for not only this pending issue but for all forms of interference, and this has been tacitly offered as up another sweetener. With the timeline too short to pull this off before approval of this broadband plan hanging over our heads aside, are end users currently really being crippled by existing sources of interference? Not to deny the potential harm of various types of interference, but is the timing of this “awareness heightening” by some supporters of the broadband plan a case of (to paraphrase L. Frank “Oz” Baum) “pay no attention to the [broadband plan] behind the curtain”?
The U.S. GPS Interference Detection and Mitigation Program (IDM) is a serious undertaking. There are reporting elements like the Patriot Watch portal (closed to the general public) and support/notification services (for not only interference but constellation updates and other alerts) from a “GPS Triad” formed by the USAF (military issues), the FAA (airspace issues), and U.S. Coast Guard (surface issues) already in place. I’ve queried these entities, as well as a number of RTK network operators and have not come up with a huge number of verified examples of interference that would significantly affect high precision users. I’m not saying that “the Orc we fear is worse than the Orc we hear”, but like any other element of risk assessment there should be serious analysis of incident data and testing before we rush off on a potentially costly course of action based in part on anecdotes and compound assumptions about interference.
There have been several (but few) well publicized cases of interference that do present cause for concern, in particular the accidental military source disruption in San Diego in 2007, and the cheap “trucker jammer” that affected an airport in New Jersey. But for non-jamming or military sources (that are not typically turned on in populated areas) the other more commonly suspected sources of interference are often recognized and avoided (e.g. certain types of power lines, some sat-phone handsets, and some high power distribution substations). There are also users successfully working in areas one would highly suspect for interference, but are not necessarily a hazard; like in and around airports, military installations, and even on hilltop antenna farms, without loss of precision.
That is not to say that interference is not a threat nor that jamming might not harm operations. Jammers are highly illegal and of course some folks will use them. You put the idea in a users head, and then the otherwise systematic debugging of field operations issues can take on a whole new element of paranoia. We’ve even fielded support calls this past year with frustrated field users asking “could this be interference from LightSquared?”, a system that has not even been turned on yet. Efforts to build affordable detection devices is a noble cause. There have been some great strides in analyzing this issue and developing new tools. The problem with serving up these things as a sweetener added to a forced upgrade, or as a tool to deflect attention away from the immediate broadband-plan issue, is that many view this in some way disingenuous. Right or wrong, the timing and nature of how this has been spun may serve to taint the otherwise worthy issue of a broader interference.
More at stake than your GPS unit
Sweetening the deal and softening the blow for one limited segment of GPS users, like the surveying profession, or other specific type of GPS equipment, completely ignores other issues that can be viewed as much more compelling than that of the individual.
Aviation: Can the same model of cheap, quickie upgrades (and sweeteners) be applied to aviation? Some of the most compelling concerns have come from the aviation community and FAA Advisory report. To assert that one could go up to a plane on the tarmac, crack open the GPS unit, put in a few cheap components and then send a hurtling can of people into the sky sounds more than reckless or insulting. Developing, acquiring, testing, certifying, installing and then testing again of aviation components is time consuming and expensive, and cannot be taken lightly.
The same solutions for limiting interference in cell phones may not be applicable to other types of gear, and may be completely ludicrous for others. In the case of cell phones, these are narrow band (only using about 6%, or 2MHz of the 32MHz of GPS signal) as they are not concerned with precision, and many utilize Assisted GPS (AGPS); an augmentation to improve the slim pickings from such a narrow band view. High precision units, and most general navigation GPS, plus aviation, and most military are “wide band”. There is a huge difference between a cell phone being tested in a purely pass/fail mode; more for “conformance”, than for “performance” and a high precision unit that uses (perfectly legitimately) as much signal as possible to achieve such high precisions as many rely upon.
No one would disagree that there are engineers that have been rolling up their sleeves and working on new and improved filtering options, but at this point in time, there is a sort of “spectral gun” being aimed at the end users. The view is quite a bit different from down here at the business end of said gun than from the point of view of those who are so cavalier about this subject on the trigger end. In this charged atmosphere of the current controversy, we may really need a “hype filter”. Is it too much to ask that such grand filtering ideas be backed up with solutions that have been developed and tested for every type of GPS unit well in advance of anyone monkeying with the spectrum? Sure one can assume that anything can be fixed with enough time and money; seems to be no shortage of money, but how about time? Back down the throttle a little and let this plane come in for a safe landing.
Hold the Cheeseburger
Wrap up something unsavory in a double-patty-pickles-onions-cheese-on-a-sesame-seed-bun and we are still being forced to consume something unsavory or disgusting– and don’t expect us to think folks are heroes for selling us a toothbrush.
Opposition to the plan has not been limited to the GPS manufacturers or satellite communications providers who would stand to lose something in this matter. The U.S. military, aviation, agriculture, and public safety are among the others who have arguably had more say in the matter. There have been some accusations that all opposition is contrived, or based solely on conflicted interests – don’t insult us. Yes, the end user may be only looking at the costs of upgrade/replacement/production interruption but what of those who stand to gain either financially or in stature from this if approved?
Why would parties from even within the GPS industry and community (some call “turncoats”) advocate for introduction of this new specific form of interference and inflicted forced upgrades/replacements on their own industry and end user community, and then try to spin that as some kind of gift, or path to a “better world”? Some would suspect profit, or there may be pure intentions involved, though the latter might make one think about those old spy/action movies where some group is planning to disrupt the world so that they can rebuild a more perfect world according to their plans or beliefs. Good intentions, but…
If this broadband plan is given the green light (and even if it looks like it might not fly), or not, it may serve as a harbinger of things to come. If it fails, it is not the end of broadband or the world as we know it, and perhaps a good long term plan to manage spectrum and constellation could come of this. It would be a fantastic goal/role for joint PNT/FCC cooperation, but these things cannot and should not be rushed. Wow, managing something effectively, am I dreaming?
If approved though, all of the manufacturers will have to offer some kind of deals to soften the blow. The end user may have no choice but to upgrade or replace, but they will have a choice in how they do this and who they patronize. Some sweetener peddlers have jumped the gun and have touted cost-benefit computations of the upgrades (based in part on some aforementioned arguable assumptions) that (they say) may only cost you the price of a burger a day; couple of bucks a day (or 50 Rubles, or whatever currency equivalent as many might turn to cheap GPS gear from overseas if forced into this). Many have expressed how insulted they feel about this attempt to minimize their concerns.
People will not easily forget those who blatantly advocated for what many consider to be a rushed-reckless spectral disruption. Many end users have indicated that they will seek to pay (if forced to) these “fees” to other companies who did not support the potential harmful broadband plan, exercising what little choice or influence they have in this matter. Or at least if the GPS eating zombies do attack, they might be tempted to trip some of those turncoats.
Gavin Schrock, LS, is a licensed surveyor, technology writer, and administrator of the Washington State Reference Network, a regional cooperative GPS network (RTN) in the Pacific Northwest. He has worked in surveying, mapping, data management, and GIS for over three decades in the civil, utility, and mapping disciplines. He has published in these fields and has taught these subjects at local, state, national, and international conferences.
Some folks are proposing that a nationwide RTK Network (RTN) be piggy-backed on the controversial LightSquared communications network. That could be cool, if it can be done. No one is saying that it can’t be done, but there are reservations on whether it would be worth the massive investments needed to pull it off, and that there might be little gain at all over the existing presence of RTN in the U.S.
RTN are arrays of continuously operating GNSS reference stations that can provide correctors for high precision positioning. Centimeter positions instantaneously; imagine what could be done with a capability like that. People have not only imagined such things, but have implemented over 100 of these in the U.S. and over 350 worldwide serving industries such as surveying, mapping, construction, precision agriculture, science, machine control, public safety, precise navigation. If you feel you have heard all of this before, you probably have, and chances are you might have heard this from an RTN junkie like me.
I am a strong supporter, even a rabid supporter and promoter of the expansion of RTN and the many benefits that can be realized where RTN exist. I have bored many people to tears with my idealistic ramblings about RTN, and have seized opportunities to jump on any bandwagon that promotes more widespread or even nationwide RTN (e.g. On-Grid Goal, GPS World 2006). There are many countries that already have nationwide RTN like Japan, Germany, Denmark, Greece, and many others; but under completely different circumstances, and none piggybacked on communication network towers. So why haven’t we seen a nationwide RTN in the U.S.? There are a lot of good practical reasons why this has not happened, and likely won’t. It is not a matter of a single design or business model issue standing in the way, and likewise the solving of a single issue will not bring the entire dream to reality. There are far too many moving parts to an RTN; hurdles that would have to be overcome to realize a nationwide RTN. Examining those hurdles might bring us closer to visualizing the dream, but perhaps instead we should focus on what is realistically possible and provide the best possible amalgam of many well run RTN to provide the same utility.
The Nationwide RTN Carrot. In the course of the past year, and the LightSquared broadband plan interference controversy, RTN have been mentioned in the context of both a reason to oppose the broadband plan in question, and by others as a reason to support the broadband plan. Some have suggested that the LightSquared plan in question would be the catalyst for a nationwide RTN, as it could possible fulfill the crucial communications element of an RTN, and have touted this as a carrot for approval of the entire broadband plan. The idea of piggybacking an RTN on a communications network towers is not a new idea, and it has been studied seriously by many folks, including myself. There have been GNSS manufacturers and mobile phone service providers who have looked at this idea; but none that have acted on the idea; for good reasons.
I would really like to see a nationwide RTN, but this particular carrot is not backed up yet by a credible plan that has been formally proposed and presented for scrutiny, it does look mighty tasty at first glance. Are there too many compound assumptions being made with regards to this particular carrot? Or is there real potential for a grand RTN? The controversial broadband plan asks a lot of people to sacrifice a lot in direct costs and lost productivity during transition; so the various carrots being touted should be scrutinized very carefully. The first glance look at the assertion that a nationwide RTN could be piggybacked on the proposed LightSquared LTE build-out does appear to provide two key RTN elements: secure station sites (perhaps as many as 40,000 to choose from) with power and low-latency communications for both stations and rovers. But are tower sites really suitable? And can it be done with the tower sites alone? Can it be done in a manner that would greatly improve the coverage of RTN and at a dramatically lower cost? Let’s takes a closer look at what it would take to stake a nationwide RTN on an array of wireless communication towers before we jump to any conclusions.
Secure sites with power. Yes, the proposed tower sites are essentially cellular tower sites with fences and reliable AC power. But the assumption that one can simply rely on tower sites only applies to the limited area of the country that will be covered by the terrestrial component, the rest would need new stand-alone CORS sites to be presumably served by the satellite component of the plan (not a good idea and adds more infrastructure costs).
Tower mounts. A communications tower is subject to movement, and therefore not a good candidate for mounting a high-precision GNSS CORS antenna. Even as little as one centimeter of incidental movement (and much more in high winds) is not only not a good practice for an RTN station, it would compromise the relative integrity between RTN stations and the resultant real-time solutions. If you expect your rovers to achieve centimeter positions, the RTN stations must be stable to a few millimeters. But don’t cell towers already have GPS antennas on them? Yes, but these are typically tiny little single frequency units used to time the communications systems where positional precision is not a consideration.
Co-Location at Tower Sites. You will not find very many RTN stations co-located at wireless communications tower sites, and those that are have been placed on stable ground mount far from tower (south side preferred for maximum constellation) to mitigate as much multipath from the tower as possible. Most tower sites are not big enough to accommodate this. It may take a separate lease of a fenced area far away from the tower. This greatly reduces the number of potential sites.
Leases. Wireless communications tower sites are mostly leased from local land owners, and the towers themselves are often owned by third parties from whom communications companies lease space on the towers. The LightSquared plan is not calling for wholly-owned and leased sites; other parties and leases will be required. For instance, Sprint has been proposed as a LightSquared partner for providing tower infrastructure. Site and tower owners want to make money from their property. Towers = more ongoing costs.
Site Geology. Potential RTN station sites are carefully vetted for sources of incidental geological movement. For example, alluvial fans or slumping slopes are not good candidate sites. An RTN serves as the active control component of a geodetic reference framework; and strict criteria are followed. Tower sites are not necessarily vetted on the same criteria. The potential site list becomes even more narrow.
Interference. While sources of interference from other radio frequency appurtenances on the towers might not be an issue, then there is the question (ironically) of the possible LightSquared interference as these stations would be at ground zero. Assuming that there are solutions for what is referred to as the lower 10MHz plan interference, what of the upper 10Mhz plan? Recent lower 10MHz filtering tests aside, the upper 10 MHz band plan has still not been taken off the table. No one has demonstrated any credible filtering plan (even LightSquared admits this is still theoretical or at least years away) for the upper 10MHz. Would the RTN stations be immune to such interference? Depending on how the upper band issue plays out, this idea (and viability of every other every other RTN, not to mention all high precision GPS in the U.S.) might be dead in the water.
Geometry and Coverage. RTN stations are spaced as close as 30km or as far apart as 100km depending on what type of solution is being sought, terrain and elevation differences, tropospheric trends, redundancy considerations, and site suitability/availability as outlined above. With the LightSquared plan proposing as many as 40,000 possible tower sites it would otherwise be possible to find enough in densely populated areas of the country to have decent geometry and coverage, but only if all of the other design criteria can be met. The point may be moot as tower sites overall are not good candidate sites and won’t cover the majority of the country without adding satellite communication-served sites.
Geodesy. If the relative positional integrity of an RTN is not maintained, and elements like plate tectonics and ocean tide loading are not taken into account, the resultant solutions suffer. Poor geodesy renders an RTN useless for high precision positioning. There are amazing tools for monitoring, maintaining, and updating the geodesy of an RTN available in some of the commercial RTN operations software suites, but this proposal would be taking on an unprecedented huge and expensive geodetic burden – even if a fraction of the 40,000 sites are included. The National Geodetic Survey maintains system of 1,800 CORS maintained by over 200 different partnering organizations. Even with the most advanced tools and some of the finest geodetic minds in the world, maintaining the geodesy of these sites is straining the NGS resources. The threshold for update on NGS CORS is when its network integrity exceeds two centimeter horizontal by for centimeter vertical; completely unacceptable for the relative integrity that RTN requires. RTN operators maintain registration to the National Spatial Reference System via constraining to a minimum number of CORS, but then have to maintain a further level of relative integrity locally for the RTN to run. A nationwide RTN would need to be run as an array of sub-networks for independent geodetic regions; some RTN have to do this even within a single state to accommodate regions of varied tectonic velocity. A small army of geodesists would be needed to oversee a nationwide RTN resulting in another significant cost.
Ubiquitous Communications. The term “ubiquitous” gets thrown around a lot with regards to the current plan. Go online and look at a population density map and then look at any of your favorite cellular coverage maps. Now look at a terrestrial component deployment map (Source: TMF Associates) for the proposed network from October 2010. It does not cover huge areas of the country; instead the satellite component of the proposed plan would need to be used. RTN CORS do not need a lot of bandwidth, but they do need low latency communications. Satellite communications links are rarely used for RTN. An RTN might get away with a few isolated high-latency satcomm served sites, but too many clustered together in a network solution do not work. Also notice the population map and the coverage map of some common cell/broadband providers look very similar; the profitable areas are targeted. Many companies are steadily deploying LTE broadband (LTE was not invented in the past year). While the plan calls for providing services to an admirable goal of 260 million potential subscribers, the remaining 50 million plus in rural areas will be left out as they have been by other carriers, or simply served by slower satellite communications.
Nationwide does not really mean nationwide in the commercial communications business, and that would be the same for RTN. Communications networks get built where the potential subscriber base can support the investments. The same can be said for RTN. You will find RTN covering the same densely populated areas, or over areas where precision agriculture is being implemented. There are actually RTN and arrays of single-base RTK stations in places that are not covered well by broadband and would not likely be covered by this plan or the others. In these areas radio and satellite-based augmentation systems are the cost effective alternative. Even though the communications component of the plan (that might arguably be more bandwidth and possibly faster or cheaper) will not be much more ubiquitous in terms of RTN functionality than what is available now, there would still be big holes in a “nationwide” RTN.
Wholesale. LightSquared plans to offer wholesale bandwidth. This might equate to any number of retail providers offering the bandwidth through proprietary or open source communications devices. LightSquared is promoting this as “the dumbest of pipes”; essentially a great big pipe of bandwidth, which is a cool idea and prime for a wholesale model. More options for communications through these retailers might arguably be a good thing for RTN users, but not necessarily for any entity trying to put together a nationwide RTN unless there was some kind of exclusive deal attached. Competition can lead to lower costs overall, but subscriptions are typically what the market can bear and that might not be stupendously lower than what we pay now because everyone in between needs to take a cut. One strong point of the model was supposed to be unified communications for RTN, but instead we may be looking at a fractured element. The potential RTN operator would have to deal with as many, if not more, wireless communications providers than currently exist.
But in another potential model, if the RTN provider were also a LightSquared broadband retail “reseller”, that might be a key to streamlining the model. However, if every end user was to buy the same units or brand with built in broadband receivers from one of the preferred retailers (wishful thinking), that would streamline the model even more. There are too many existing RTN (some free or at nominal cost), and too much legacy equipment out there to expect users to accept and rapidly execute dramatic upgrades, replacements, or carrier changes unless the full LightSquared plan is approved and they are forced to upgrade.
The Elastic and the Brittle. I hate to rain on anyone’s parade, but RTN are not the dramatic cash cow one might imagine. The worldwide experience of RTN is very similar in that there is a limited market for network corrections. Even if one was to count on signing up all of the current RTN users in the U.S., plus all of the precision agriculture market (and a mighty hard sell that would be as they have made some huge investments in their own systems), it is still unlikely that there would be enough revenue to fund the initial and ongoing infrastructure investments, and to sustain the ongoing costs of operations, geodesy, leasing, maintenance contracts, and account management. If anyone is entertaining thoughts of consumers paying extra for higher precision on their cell phones and car navigation devices they might be greatly mistaken. The consumer seems quite happy with accuracy on the order of a few meters, and multiple constellations and modernization will be providing higher fidelity to them soon enough. One wireless service provider even experimented with delivering corrections to mobile phone users from the national RTN where they are based and found consumers in their test group to be indifferent and even thinking it was a silly idea.
Private RTN have spread across areas of the U.S., somewhat organically as opportunities arise, partners are secured, and where the market can support them. Public and cooperative RTN have spread in areas where the sponsoring entities can realize cost-benefits from their investments like a state department of transportation for their own projects. Public RTN have often filled regions where a private network may not have otherwise been cost effective. Together public and private RTN have covered a substantial area of the U.S. The nature of RTN in the U.S. is a healthy elasticity which fits the market and needs. With RTN being narrow-margin enterprises, this is a good thing. Developing a huge single entity RTN on narrow margins leaves the entire enterprise quite brittle. Investors might view areas that have a low or negative return as not worth retaining or even building out in the first place. The cards are really stacked against a ubiquitous nationwide RTN, unless as some assert there were elements of overriding public interest to justify some level of public investment or partnering.
RTN Coverage of the U.S. as a percentage of Total Area
Infrastructure Investment. Typical RTN stations have cost between $10,000 and $50,000 each to establish and sites requiring satellite communications start at a minimum of $20,000. Let’s say for arguments sake that only 10,000 of the tower sites were utilized, with perhaps just as many in satellite communications-served sites also needed. That might not even exceed the coverage of existing RTN. Even so, at $10,000 each, that is $100,000,000 up front; not to mention the satellite communications-served sites on top of that. Some may question those costs, so let’s break them down. A RTN receiver has to be dual-frequency, multi-constellation, geodetic-grade, enable remote operations, and be paired with a geodetic-grade antenna. Sure, used receiver/antenna pairs can be had for as little as $2,000-$6,000. Let’s say for arguments sake a manufacturer was able to build and sell (or essentially give away) a new unit for the unlikely price of $2,000, there is still the cost of a stable ground mount, conduit, enclosures, labor, site selection, engineering, fuel, logistics, and contract management. These would very likely add up to $10,000. But let’s say for arguments sake this could be done for $8,000. It would still cost $80,000,000 up front, and maybe triple that to add enough satellite communications-served sites. One would have to question the robustness and viability of an RTN built so cheaply. Realistically, it would be more like $100,000,000 to $360,000,000 to build out.
Ongoing Costs. Break even operations costs for an RTN average around $1,000-$4,000 per station annually. This includes hardware replacement, software contracts, operations staff, geodesy, training, support, billing, leases, power, communications, data processing, and more. Again, for arguments sake let’s say on a grand scale that cost could be brought down to $1,000 per station per year, that sill represents $8,000,000 to $10,000,000 per year, but more realistically like $15,000,000 to $20,000,000 annually with double or triple to that cost for satellite communications-served sites.
Pricing Model. The carrot has been touted with assertions that the services would be provided at dramatically reduced costs for both communications and corrections. No one involved would be expected to give anything away. A fair price for all elements would be exacted like it would for any other enterprise. For existing RTN, price is not typically what holds back potential customers. The RTN’s in the U.S. charge very reasonable prices, and much lower than some RTN in other countries. The limitation is the existing and potential pool of users as a function of geographic area. To operate an RTN at greatly reduced prices does not work because many public RTN that initially offered free services are exploring at least nominal fees for the future. It does cost money to run an RTN. Even if a new cut-rate nationwide RTN were to assume it could assimilate all current RTN users, plus a substantial segment of agriculture users, it is likely that the revenues would not be able to justify covering more area of the country than existing RTN already do.
What do we make of this carrot?
I completely welcome this idea for consideration, but it needs to be examined seriously before any speculative cost benefits can be added to the value equations folks are presenting as rationale for approving the LightSquared plan. There are a lot of unknowns about what folks have in mind when they tout this piggyback-on-LightSquared-nationwide-RTN carrot.
Too many unknowns encircle this carrot. If a credible plan were offered up for scrutiny and proposed coverage were shown, all of the design and business model issues I’ve outlined were addressed, the FCC approves the LightSquared LTE plan and there were investors who were willing to see modest returns at best, then I would be among the first to jump on the bandwagon, sing praises, and actively promote the idea.
However, in light of the tremendous uncertainty we face not only in considering this carrot, but the fate of the broadband proposal it serves to sweeten, touting of this particular nationwide RTN proposal must be viewed at best with a not insignificant amount of skepticism and perhaps at worst be viewed as somewhat disingenuous. The seed for this carrot has not yet even been sown.
At the end of every year, I title this column Directions, in which I discuss significant developments, trends, technologies, companies, etc. in the GNSS industry. This year, two entities have captured my attention and I think have the potential to significantly transform the GNSS industry.
What conversation about GNSS today can we have without LightSquared being at its center? LightSquared, or rather the FCC’s looming decision about LightSquared’s proposal, has the potential to bring significant changes to the high-precision GNSS industry in 2012 and beyond.
An FCC decision in favor of LightSquared can cause a paradigm shift in the GNSS competitive landscape in the North American market. By that, I mean significant market-share changes. The high-precision GNSS market is currently dominated by three key players: Trimble, Leica, Topcon. What if the FCC approves LightSquared’s plan, and thousands upon thousands of users need to upgrade their equipment? Will they purchase the same brand they currently own?
The answer, in my opinion, really depends on how much of an upgrade is required. Since each GPS receiver model is designed differently, the extent of the upgrade can vary greatly among GPS receiver models. Some receivers may not require anything; some may require a new antenna design; and still others may require a new antenna design and new GPS receiver circuitry design.
Since LightSquared’s plan has changed considerably over the past few months, and testing based on its latest plan isn’t complete (or even started in some cases) yet, it’s too early to say how particular receivers are going to be affected. I’m sure each manufacturer has a good idea about each of their receiver models, but they aren’t talking yet.
The current focus of testing is on the effects of the 10L (low) spectrum (10Mhz of spectrum at 1526-1536MHz), which is furthest from GPS L1 (centered at 1575.42MHz). If you recall, LightSquared’s initial plan was to roll out their service using the 10H (high) spectrum (1545-1555MHz), but that idea was abandoned in June 2011 when the Technical Working Group (TWG) testing clearly showed that GPS receivers, of all kinds, were jammed due to the 10H frequency being so close to GPS L1 and the signal being so strong compared to GPS, more than a billion times stronger.
Since the original TWG testing was focused on 10H (with some 10L testing), the affect of rolling out LightSquared’s system on 10L is not fully known. Therefore, in September 2011 the FCC (via NTIA) ordered new testing focused solely on 10L. The testing for consumer-grade GPS (mobile phones, general navigation) was to be completed and analyzed by November 30, 2011. The NTIA has not released any information regarding the test results. My guess is that the testing will show that mobile phones and general navigation devices will be free of interference since those GPS receivers don’t need to use the entire GPS band (only 2MHz) like high-precision GPS receivers do (20+MHz), and aren’t designed to use GPS correction services broadcast in the MSS spectrum (such as OmniSTAR and Starfire).
Separately, the DoD (Department of Defense) is conducting their own classified tests to understand the affect of 10L on military GPS receivers. We may hear bits and pieces of the results, but I’m guessing the DoD test results will largely remain classified and therefore not be made known to the general public. Interestingly enough, the DoD holds the most powerful LightSquared trump card, although we’ll likely never know if it was played.
Besides the national security trump card the DoD could play, the Federal Aviation Adminstration (FAA) holds the slightly less powerful safety-of-life card that could trump LightSquared. The FAA is super-conservative (no one wants to be responsible for crashing an airliner) and their processes/procedures can take forever. A few weeks ago, I saw an FAA presentation with the following information:
Next Steps:
Preparing of NPEF Test report for NCO, EXCOM and NTIA/FCC
Scope Next LightSquared Test Phase(s)
– High Precision and Timing Receivers (different timelines)
Awaiting LSQ-provided High Precision and Timing Filters (November and March 2012 respectively), antennas and handsets.
-Schedule
Tentatively, Spring of 2012
Test Test Types – Lab; Chamber; Live Sky; Aggregate Effects
Another time crunch problem it has is its deal with Sprint. LightSquared isn’t “building towers,” at least for the bulk of their infrastructure. It is relying on an agreement with Sprint in which it will pay Sprint $9 billion over an 11-year period to use Sprint’s infrastructure, paying some $290 million up front.
Sprint CFO Joseph Euteneuer, during Sprint’s 2Q 2011 Earnings Call, said “we’ve gotten the $290 million.” Furthermore, Euteneuer stated “…we will be getting pre-funding of any work that we would be doing for LightSquared.”
Regarding the GPS-jamming problem, Euteneuer said “…we need clear GPS spectrum before we go forward. So we can get started with a lot of the planning and those things, but we need to get clearance on the spectrum before we start any heavy construction.”
Sprint has the right to terminate the deal with LightSquared if LightSquared doesn’t receive FCC approval on the 20MHz (10L and 10H) of MSS spectrum by the end of this month. Clearly, that isn’t going to happen. Maybe Sprint will grant an extension to LightSquared, but it has to know the only thing LightSquared might bring to the table at this point is 10L sometime next year, and even that is a crap shoot given the huge cost that the Fed/state/local government agencies would incur in addition to private corporations, not to mention the DoD and FAA discussion above. Finally, Sprint has to know that there’s no chance for the 10H spectrum to be approved in the foreseeable future. The June 2011 Technical Working Group (TWG) test report clearly showed that 10H jams virtually all GPS receivers.
That leaves LightSquared in a really tough spot, and is the reason its public relations campaign machine has really cranked up these past few months.
Today (Wednesday, Dec. 7), LightSquared announced that “testing conducted by an independent laboratory has confirmed that several major high-precision receivers, including those developed by GPS pioneer, Javad GNSS, are 100 percent compatible with LightSquared’s network. These results show that LightSquared is well on its way to demonstrating that GPS interference issues have been resolved.” The message lacks specifics, and there has as yet been no verification of the unnamed independent lab’s results.
LightSquared is taking the message this week to Capitol Hill trying to convince uninformed legislators and other public officials that the end is in sight. The problem is…it’s not true.
Here’s why:
LightSquared’s preliminary “independent testing” indicates that some receivers are tested to be 50 percent compatible with LightSquared’s network. Remember, we are only talking about 10L at this point, which is only half of LightSquared’s spectrum. Since LightSquared has not abandoned the 10H spectrum, it’s not true to say “100 percent compatible with LightSquared’s network.”
These are newly-developed receivers, which means hundreds of thousands of high-precision receivers would be obsolete. Who will pay for replacing/upgrading them?
LightSquared’s “independent testing” doesn’t include FAA (aviation) or DoD (military) testing.
LightSquared’s “independent testing” doesn’t include LightSquared mobile devices (they don’t exist yet). As I’ve written before, they are potential portable GPS jammers.
LightSquared’s “independent testing” announcement provides no details on GPS performance. A performance hit of 2 or 3 db of signal strength can make a significant difference when tracking in marginal GPS conditions.
For more than a decade, Galileo has been discussed and debated, to the point that few believed it would ever come to fruition. Even today, some folks still don’t believe Galileo is real. Given the history and the current state of the European economy, I don’t blame them.
However, the chips are down, and the stack is high. Europe is “all in.” As the Galileo folks head further down the road, it becomes much more difficult to pull back. The next launch of two Galileo sats is slated for next summer. The four are dedicated for In-Orbit Validation (IOV), but unlike the two Galileo test satellites that have been in orbit for several years (GIOVE-A, GIOVE-B), the latest IOV satellites will become part of the operational Galileo constellation of 30.
Whereas I’m bullish on Galileo, the schedule is a bit more unpredictable. The European GNSS Agency (GSA) estimates that the first 18 Galileo satellites will be in orbit in the 2014/2015 timeframe. If they stick to it, it would have a profound effect on the GNSS industry fairly soon. As I’ve written before, Galileo supports the new L5 signal along with GPS; this means that L1/L5 dual-frequency, dual-constellation GNSS receivers will be low-cost and very accurate. Regardless if Galileo sticks to its schedule or not (not to mention GPS sticking to its own schedule), when Galileo does finally have 18 satellites operating in orbit, it will change GNSS positioning forever.
Webinar – December 8, 2011
I’m pleased to participate in a webinar featuring Dr. Javad Ashjaee who is presenting his solution for the LightSquared interference problem. If you’re unable to attend, please register anyway and you will be emailed instructions on how to view the webinar at your convenience. It will be available for download within a few days of the live presentation.
In true Wall Street lawyer fashion, LightSquared Executive VP Jeff Carlisle thinks he’s entitled to receive answers with regards to LightSquared’s GPS-jamming problem instead of providing answers. He seems to forget that LightSquared is the one applying for approval to proceed, and needs to provide the answers and solutions.
Interestingly enough, LightSquared’s questions really point out how ignorant the company continues to be about the GPS industry, which is surprising since it’s been about a year since it submitted its application to the FCC. By now, you’d think that the company would have performed enough due diligence to become familiar with the GPS industry. From the questions for which it demands answers, apparently not.
First of all — I’ve written before and I’ll write it again — the GPS user community is in its own corner on this issue. No one is looking out for your interest unless you are able to persuade your congressperson to act on your behalf.
Incidentally, I spoke to a state legislator last week who reached out to me about the LightSquared GPS-jamming issue. He was one of those legislators who had submitted a letter of support for LightSquared to the FCC during the public comment period. He said that LightSquared lobbyists were reaching out again last week to state legislators looking for letters of support. He said he didn’t know anything about the technology but believed LightSquared’s claims of 15,000 jobs being created. What he didn’t understand was the chaos it would cause to the economy with respect to small business (agriculture, engineering, construction), fed/state/local government, aviation, and military. Of course, once he understood the full impact, he made it clear that he would not approve of a system that would have a negative impact on GPS. When I informed him that there’s a solution being floated by LightSquared (the “fix”), but that it is yet to be vetted and that the upgrade cost would run into the billions, he concluded “we can’t afford it.”
I think this is a typical situation among legislators and other public officials who have voiced their support for LightSquared. They just don’t understand the issue and take what LightSquared lobbyists say at face value. Once it’s explained to them, they quickly understand that America can’t afford LightSquared’s current proposal.
Speaking of lobbyists, if you didn’t watch “60 Minutes” on November 6, take a look the following video on the corruption taking place in the U.S. Congress. It’s disgusting.
Now, back to the subject at hand.
Yes, Trimble, Deere/Navcom, Garmin, and other GPS manufacturers are putting up a good fight via the Coalition to Save Our GPS. They’ve invested tens of millions, if not more than $100 million, in this debate over the last year, largely on behalf of and in support of the GPS user community. But make no bones about it, if LightSquared is granted approval to proceed, and that action requires your equipment to be upgraded (if an upgrade is even possible), this will be a huge windfall for the GPS manufacturers. They will make a ton of money. Salespeople will sit back and take orders. There’s no easier business than a forced upgrade (do you remember the Y2K problem?).
That brings us to LightSquared’s first question to which it demands an answer.
LightSquared Question #1:Isn’t it true that the so-called “non-biased” PNT Advisory Board, which advises the Pentagon, is represented by board members of GPS companies who have a financial stake in LightSquared not getting approval to proceed?
They are referring primarily to Dr. Brad Parkinson, who has been a Trimble board member for many years, and who even acted as Trimble CEO for a period of time, more than a decade ago, after Charlie Trimble’s departure.
Dr. Parkinson is an aeronautical engineer. He’s retired from the U.S. Air Force (at the rank of colonel) and is a professor emeritus at Stanford University. He was the first GPS Program Manager for the U.S. Air Force, and is largely responsible for the GPS getting on the road to being what it is today.
LightSquared’s question implies that Dr. Parkinson, a Trimble shareholder and board member who has voiced his opposition to the LightSquared initiative, will somehow profit if LightSquared’s application is rejected by the FCC.
If LightSquared personnel put some thought into it, they’d understand that Trimble (and its shareholders) stand to make a lot more money if LightSquared is allowed to proceed than if it isn’t. In other words, if LightSquared is allowed to proceed, Trimble makes a ton of money in forced upgrades from GPS users who hadn’t planned on it. If LightSquared isn’t allowed to proceed, Trimble has just spent a year and ~$25 million (my estimate) in direct and indirect costs participating in this fire drill, not to mention the opportunity cost of the distraction of high-level engineers and executives.
For example, the company/entity/individual who just bought the latest and greatest Belchfire XYZ GNSS receiver six months ago would face an upgrade charge of thousands because it needs a new circuit board and a new antenna or antenna element. This would be gravy for Trimble because it’s revenue they thought they’d never see for a long time from a customer who just bought the receiver six months ago.
Again, this assumes a technical fix is possible. That hasn’t been proven yet. Far from it.
LightSquared Question #2:Numerous annual reports and SEC filings from GPS manufacturers going back to 2001 acknowledge material harm to their business due to interference with neighboring spectrum. Why did you not prepare your devices with filters if you’ve known for ten years there would be interference problems caused by your devices looking into adjacent spectrum?
Ok, for how long does LightSquared want to continue ignoring the fact that LightSquared and its predecessors (Skyterra, MSV) encouraged GPS receiver manufacturers to design GPS receivers that “look” into the MSS spectrum?
Why would LightSquared and its predecessors encourage this?
The answer? Because LightSquared and its predecessors sell satellite data communications services to the GPS industry using the MSS spectrum (via OmniSTAR), generating tens of millions of dollars in revenue from LightSquared and its predecessors.
Now, if LightSquared chooses not to sell those satellite data communication services to the GPS industry any longer, that’s the company’s choice, but don’t blame the receiver because it was designed to receive LightSquared’s satellite data communication service it was promoting. That sort of logic is, well, illogical.
LightSquared Question #3:True or false? Did the GPS industry manufacture devices knowing there would be interference with neighboring spectrum because this enhanced their performance?
False. LightSquared promoted GPS receivers be designed to access the MSS spectrum in order to access its satellite data communication services that it sells to the GPS industry. Furthermore, LightSquared profited from it.
LightSquared Question #4:Who funds the Coalition to Save Our GPS?
I don’t know. Who cares? Certainly not Friends of LightSquared. Can you really not figure that out?
LightSquared Question #5:Did the GPS industry falsely claim that it would take billions of dollars and more than a decade to find a solution to this problem?
I don’t know who made this statement, but it wasn’t me.
I do believe that LightSquared has no clue as to the extent of the negative economic impact its proposed system will cause — and it doesn’t care. The $50 million the company has pledged to repair damage it creates to federal government GPS users constitutes a sliver of what it will actually take.
But all of this is moot until any sort of proposed “fix” is fully understood and vetted across all product lines and markets. Clearly, LightSquared does not understand the extent of the problem its system causes; otherwise it would have never predicted an FCC decision by the end of this year.
My Questions
I was offered the opportunity to interview LightSquared a few months ago. I declined. It’s senseless to speak to a lawyer or marketing guy about this technology. They don’t know what they are talking about. They just regurgitate the same senseless spin.
But, given that they keep ignoring the fact that they sell satellite data communications services to the GPS industry utilizing the MSS spectrum, I’d pose these questions:
Question #1 to LightSquared:True or false, does LightSquared sell satellite data communication data services to the GPS industry via frequencies in the MSS spectrum (1525-1559MHz)?
Question #2 to LightSquared:True or false, did LightSquared’s predecessors, Skyterra and MSV, sell satellite data communications services to the GPS industry via frequencies in the MSS spectrum (1525-1559MHz)?
Question #3 to LightSquared:When did LightSquared and its predecessors (Skyterra/MSV) first begin selling satellite data communication services to the GPS industry via frequencies in the MSS spectrum (1525-1559MHz)?
Question #4 to LightSquared:How much gross revenue, in total, has LightSquared and its predecessors (Skyterra and MSV) generated from the GPS industry since they began selling said services to the GPS industry via frequencies in the MSS spectrum (1525-1559MHz)?
Question #5 to LightSquared:List all of the frequencies in the MSS spectrum that LightSquared and its predecessors (Skyterra and MSV) have utilized in delivering satellite data communication services to the GPS industry since LightSquared/Skyterra/MSV began selling said services?
Let’s see if LightSquared is as bold in answering questions as they are in asking.
Like a bad week on the stock exchange, LightSquared hit speed bump after speed bump this week. After Monday when the company boldly claimed there would “be a resolution within a month” to the GPS interference problem, the FCC spanked them Tuesday by ordering more testing. The rest of the week turned even more sour.
The issue really isn’t about blame, which is how LightSquared is trying to frame it with the “the GPS industry knew about it” argument. The fact is that hundreds of thousands (LightSquared estimates 750,000 to 1 million) of high-precision GPS receivers would be affected. These are high-end receivers valued at thousands and tens of thousands of dollars each.
This week (September 12-16), things turned sour for LightSquared. Most alarming is that it really demonstrated how flakey LightSquared’s thought process is, thus substantially reducing the company’s credibility.
Monday
On Monday, it was reported that LightSquared said it was confident the FCC would make a decision in the next month. LightSquared Executive VP Martin Harriman said Monday at the Mobile Future Conference “We are at the end of the process and we expect the FCC to make a decision. We have made some big concessions… Sprint wouldn’t sign this big deal if it didn’t expect it to be resolved. I expect there to be a resolution in the next month.”
Does he really think people are that stupid? Obviously, Sprint would love to have $9 billion of LightSquared’s money, but I guarantee the contract is contingent upon LightSquared gaining approval from the FCC. If I was Sprint, I’d sign it, too. There’s no downside for Sprint to sign the deal!
After LightSquared’s statement on Monday, the week started going downhill in a hurry for the company.
Tuesday
On Tuesday, a day after LightSquared applied pressure and said it “expects the FCC to make a decision,” the FCC threw LightSquared a right jab by issuing a Public Notice stating that further testing is needed to understand the impact of LightSquared’s latest proposal. Following is from the FCC’s Public Notice:
“This Public Notice is issued pursuant to the provision of LightSquared Subsidiary LLC’s (LightSquared) conditional Ancillary Terrestrial Component (ATC) authorization that LightSquared may not commence ATC operations until the Commission, in consultation with the National Telecommunications and Information Administration (NTIA), finds that Global Positioning System (GPS) interference concerns have been satisfactorily resolved. Following extensive comments received as a result of the technical working group process required by the International Bureau’s Order and Authorization dated January 26, 2011, the Federal Communications Commission, in consultation with NTIA, has determined that additional targeted testing is needed to ensure that any potential commercial terrestrial services offered by LightSquared will not cause harmful interference to GPS operations.”
Furthermore, the FCC Public Notice stated:
“LightSquared submitted proposed mitigation techniques to remedy the interference to GPS simultaneously with the technical working group final report. Notably, LightSquared proposed to revise its planned deployment to operate terrestrial transmitters only in the lower 10 MHz of its spectrum. The results thus far from the testing using the lower 10 MHz showed significant improvement compared to tests of the upper 10 MHz, although there continue to be interference concerns, e.g., with certain types of high precision GPS receivers, including devices used in national security and aviation applications.Additional tests are therefore necessary.”
It was a no-brainer that the FCC would take this route. It really makes one wonder what these LightSquared guys are thinking. Maybe they think if they behave arrogantly enough, they can “will it” to happen?
Wednesday
This story got even better on Wednesday.
On Wednesday, LightSquared representatives announced that they miraculously “found the solution” to the GPS interference problem with Jeff Carlisle stating, “We have a proof of concept that uses current technology and equipment that is available today and is affordable.” Riiiiight. Obviously, this guy never ran a product development project. He has nothing but a conceptual idea of how the problem might be solved. He further stated that LightSquared’s solution can be placed into production within several months.
Implementing in the field is a lot different than proving a concept in a lab. Several months? Are you kidding me? Dude, you can’t even get your testing done on all the different GPS makes/models in “several months.” You can’t responsibly test your design concept in “several months,” and you’re already talking about going into mass production in “several months”? Honestly, I’ve lost a lot of respect for LightSquared this week.
The Technical Working Group (TWG) didn’t test all makes/models of receivers that would be affected, only a sample set. In fact, just like LightSquared’s lack of due diligence in researching the GPS markets to begin with, the company’s doing enough now just to slide by, taking the shortest cut possible. I guarantee you it will be a disaster for the high-precision GPS markets if the LightSquared guys are granted permission to move forward, given their attitude and behavior. Responsible design engineers don’t behave this way. In fact, I’m guessing the design engineer(s) behind the scenes at LightSquared cringe whenever LightSquared executives (e.g., lawyers) make these kinds of flakey statements.
OK, let’s think about LightSquared’s “fix” for a minute. For sure, it’s going to be a hardware accessory and/or a new antenna, or both. Think about all the high-performance GPS handhelds on the market (Trimble GeoXT/XH, Ashtech ProMark, Mobile Mapper, etc.). Are they really going to suggest a LightSquared “clip-on” accessory for those handheld units? Seriously? How about replacing antennas on CORS? New antennas would need to be characterized by NGS. That’s just the tip of the iceberg. All of this in “several months”?
I’ve been pretty open-minded about LightSquared proposing a solution, but this really insults our intelligence. But as we’ve seen previously with LightSquared, it’s not about finding a practical solution for the GPS user community; it’s all about selling an idea to the FCC. The problem is that the FCC doesn’t have to live with LightSquared’s half-baked “solution,” we do.
Ok, that’s about enough news on LightSquared for the week, right?
Not a chance.
Thursday
On Thursday, The Daily Beast reported that General William Shelton, commander of the U.S. Space Command, said in a classified briefing that the White House tried to pressure him to change his testimony to make it more favorable to LightSquared.
The Daily Beast reported that Shelton’s prepared testimony was leaked in advance to LightSquared. Reports the website, “The White House asked the general to alter the testimony to add two points
: that the general supported the White House policy to add more broadband for commercial use; and that the Pentagon would try to resolve the questions around LightSquared with testing in just 90 days. Shelton chafed at the intervention, which seemed to soften the Pentagon’s position and might be viewed as helping the company as it tries to get the project launched, the officials said.”
The White House confirmed Wednesday that its Office of Management and Budget suggested changes to the general’s testimony but insisted such reviews are routine and not influenced by politics. And it said Shelton will be permitted to give the testimony he wants, without any pressure.
Kudos to General Shelton for speaking out. His career will likely take a hit for this, especially if this turns into a major political scandal.
“In my capacity as a member of the House Committee on Government Reform and Oversight, I will be asking Chairman Issa [Rep. Darrell Issa, R-Calif.] and Ranking Member Towns [Rep. Edolphus Towns, D-N.Y.] to promptly investigate this matter.”
Also on Thursday, Congressman Tom Petri (R-WI) spanked LightSquared for its advertisement in the Wall Street Journal. In response to LightSquared’s claim that the GPS industry is to blame, Petri wrote:
“This ignores the fact that GPS was located on this part of the spectrum long before LightSquared devised its plan to employ a terrestrial network within the Satellite band of radio spectrum.
“In fact, your spectrum was purchased at bargain prices because it was not intended for terrestrial operations,” Petri continued. “If it were always intended for such use, it would have been of much higher value. It became high-value spectrum when it became clear that LightSquared’s business plan was to abuse the ancillary terrestrial authorization and use the spectrum for terrestrial based operations — a radical change to the intended use of spectrum.
“I would suggest that it is LightSquared using a part of the spectrum for inappropriate purposes that has led to this dilemma,” Petri wrote. “Don’t blame GPS, a service that is vital to our national security, aviation safety and efficiency, serves billions of users and the overall public good.”
Friday
Rounding out the week, on Friday one of Fox News’ lead stories was titled “General Reported He Was Pressured on Testimony About White House-backed Project, Sources Say.” This is a good thing. There’s no way LightSquared is going to fly under the radar at this point.
Rally Organized to Protest Potential GPS Band Interference by LightSquared
Gavin Schrock, administrator of the Washington State RTK Network (WSRN) consisting of nearly 100 GNSS reference stations, is helping organize a rally to be held on September 22 at 8:30 a.m. in front of the Jackson Federal Building in Seattle. The rally is intended to support GPS and express concerns over a controversial application by LightSquared being considered by the FCC that would cause substantial interference for GPS users.
He says similar rallies for the same day are being organized in other cities. “These rallies are in support of GPS as a critical public resource, and to voice end user concerns over the proposal being considered by the FCC that could cause damaging interference for high-precision GPS for end users like surveyors, aviation, construction, science, industry, and public safety (a.k.a. the “LightSquared” issue),” Schrock said.
“The rallies are being spearheaded by surveyors and surveying associations, but other end-user segments are pitching in, like precision agriculture, academia, aviation, and public safety. This is purely grassroots about this specific issue with no other agenda,” he said.
When I mentioned to him the rally is taking place during the week of the Institute of Navigation (ION) GNSS technical conference in Portland, OR, he said it was planned that way. Good idea. In fact, on Wednesday evening during the ION conference, there’s a LightSquared Discussion Panel taking place (see below).
LightSquared Discussion Panel Next Week at the Institute of Navigation (ION) GNSS Conference
The discussion panel will be held during the ION-GNSS conference at the Oregon Convention Center, 5:30 p.m.-7:00 p.m. Titled “Can LightSquared and GPS Coexist?”, the session will be moderated by GPS industry veteran Tom Stansell with the panel including:
Michael Swiek – U.S. GPS Industry Council
Bruce Peetz – Vice President Advanced Technology and Systems, Trimble Navigation Ltd
Scott Burgett – Software Engineering Manger – Garmin Ltd
Patrick Fenton – Chief Technology Officer – NovAtel Inc
Dr. Paul Galyean – Director of Precise Positioning Systems – Deere & Co./NavCom
Doug Smith – Chief Network Officer – LightSquared
Greg Turetzky – Marketing Director for New Technology and IP – CSR/SiRF
According to Tom, “this ION meeting will be fairly technical in nature, with panelists talking about the test results and their implications”.
I will be present at the event and possibly assisting Tom in facilitating the discussions (e.g., microphone runner). Follow my Twitter account if you want to follow the event closely.
It’s a good mix of very knowledgeable people who can intimately discuss many applications of GPS/GNSS technology, from agriculture and surveying/mapping to consumer applications.
Each panel member will be allotted ten minutes or less, followed by a Q&A session.
Getting the latest GPS/GNSS (not just LightSquared) news
If you haven’t signed up for Twitter, please consider it. It’s become a very popular method of getting relevant news quickly. I’ve been using it a lot to blog about conferences and events I’ve been attending. I’m able to attached photos to my Twitter messages to bring you closer to what I’m experiencing. Earlier this week, I was at the Field Technology Conference which I helped organize and sent quite a few Twitter messages with photos about the technical presentations. If your travel budget has been hit hard and you can’t attend conferences you’d like, this is a great way to stay connected to leading edge subjects being discussed at conferences.
U.S House Committee Committee on Science, Space, Technology “Full Committee Hearing – Impacts of the LightSquared Network” – September 8, 2011
If you have a chance, listen to all or parts of this hearing:
Testimony is given by:
Mr. Anthony Russo, Director, The National Coordination Office for Space-Based Positioning, Navigation, and Timing
Ms. Mary Glackin, Deputy Under Secretary, National Oceanic and Atmosph
eric Administration
Dr. Victor Sparrow, Director, Spectrum Policy, Space Communications and Navigation, Space Operations Mission Directorate, National Aeronautics and Space Administration
Mr. Peter Appel, Administrator, Research and Innovative Technology Administration, Department of Transportation
Dr. David Applegate, Associate Director, Natural Hazards, U.S. Geological Survey
Jeffrey J. Carlisle, Executive Vice President, Regulatory Affairs and Public Policy, LightSquared
Dr. Scott Pace, Director, Space Policy Institute, George Washington University
U.S. House Armed Services Committee Hearing on “Sustaining GPS for National Security – September 15, 2011
If you have a chance, listen to all or parts of this hearing:
Testimony is given by:
General William L. Shelton, Commander, U.S. Air Force Space Command
Ms. Teresa M. Takai, Chief Information Officer, U.S. Department of Defense
Mr. Karl Nebbia, Associate Administrator, Office of Spectrum Management, National Telecommunications and Information Administration, U.S. Department of Commerce
Mr. Anthony J. Russo, National Coordination Office, Space-Based Positioning, Navigation and Training, National Oceanic and Atmospheric Administration
Mr. Julius Knapp, Chief of the Office of Engineering Technology, Federal Communications Commission
The FCC’s public comment period regarding the LightSquared/GPS interference issue has ended and the reply comment period is over as well. To date, more than 3,300 comments (not including the 15,000+ that were submitted by the Boat Owners Association of the United States) were entered that the FCC must sift through and arrive at some sort of conclusion. Following are my last comments filed with the FCC as well as my best guess at where this is heading.
I decided to file a “reply comment” submission on August 15 to the FCC based on an August 11 filing by LightSquared where LightSquared Executive Vice President Jeffrey Carlisle stated “had the GPS industry complied with the DoD’s recommended filtering standards for GPS receivers, there would be no issue with LightSquared’s operations in the lower portion of its downlink band.” It’s a blatantly false statement, so I couldn’t let it pass without a rebuttal. Following is what I submitted to the FCC:
August 15, 2011
Eric Gakstatter
Editor – GPS World magazine Survey Scene enewsletter
Again, by way of background, as a Contributing Editor to GPS World magazine, my specialty is high-precision GPS receivers of which I’ve been involved with for more than 20 years as a product developer, power user and consultant. I’m in touch with tens of thousands of high-precision GPS users from around the world through my newsletter articles (bi-weekly), webinars and my attendance at technical conferences. I consider myself and I’m considered by others to be an advocate for the high-precision GPS community.
In Jeffrey Carlisle’s (LightSquared Executive Vice President) comments to the FCC dated August 11, 2011, he stated that “had the GPS industry complied with the DoD’s recommended filtering standards for GPS receivers, there would be no issue with LightSquared’s operations in the lower portion of its downlink band.”
This is a false statement, and to make matters worse, he knows it’s a false statement. Here’s why…
LightSquared sells high-precision satellite data communications services to the GPS industry. Before LightSquared was formed in 2010, its predecessors (Skyterra, MSV) sold the same services to the GPS industry for many, many years. In the course of business over many, many years, LightSquared and its predecessors have encouraged GPS receiver manufacturers to design receivers that look into the MSS band (1525-1559MHz) in order to access LightSquared’s satellite data communication services. This service has generated tens of millions of dollars in revenue for LightSquared and its predecessors over many years and continues to be a revenue source for LightSquared today.
If LightSquared chooses to stop supplying satellite data communications services to the GPS industry, that’s their choice, but they should not fabricate a statement claiming that only the reason for interference in the “lower portion of its downlink band” is due to filtering technology. It’s just not true. Tens of thousands, if not hundreds of thousands, of expensive high-precision GPS receivers were specifically designed to access LightSquared’s and Inmarsat’s satellite data communications services that they sell to the GPS industry.
LightSquared may state they will continue to offer these services to the GPS industry in the upper portion of its downlink band (1545-1559MHz) to create separation from the lower portion of the downlink band (1526-1536MHz). It’s too late for that. Billions of dollars of expensive, high-precision GPS receivers are already in the market that were designed to look in the entire MSS L-band (1525-1559MHz) for services provided by LightSquared and Inmarsat. Had the GPS user community been given sufficient notice, tens of thousands of high-precision GPS equipment owners could have planned for transitioning their GPS receivers over many years with a manageable financial impact. Unfortunately, that’s not the case. The GPS user community was blindsided by LightSquared’s application in November 2010 and the FCC’s waiver granted to LightSquared in January 2011.
LightSquared and the FCC failed to adequately notify the GPS user community of their intentions. As I’ve submitted before, the precedent has already been set on how to effectively notify the GPS user community about an action that would render several hundred thousand high-precision GPS receivers obsolete. In 2008, the U.S. Air Force proposed to discontinue supporting the semicodeless technique that is used by virtually every civilian L1/L2 high-precision GPS receiver in existence. It was the first time in history that an action would render several hundred thousand high-precision GPS receivers obsolete, a scale which is very similar to the impact of the LightSquared system.
There was no industry coalition formed to engage the Air Force. There was no industry outcry. A public/private technical working group was not formed to test the effects on receivers if semicodeless was not supported. Why is that?
The answer is very simple. The U.S. Air Force, to its credit, did a fantastic job of communicating directly with the GPS user community along with the Department of Commerce. It issued public statements describing the impact the action would have on high-precision GPS receivers.
The U.S. Air Force did its homework. At the end of the day, it set a sunset date of December 31, 2020 to discontinue supporting the semicodeless technique. It correctly determined that 12 years is about the amount of time that would allow a smooth transition with a manageable financial impact to the high-precision GPS user community.
Imagine if the U.S. Air Force had set a period of one year to transition away from using the semicodeless technique. That action would have destroyed the high-precision GPS user community resulting in billions of dollars in losses and widespread small business closure. Fortunately, they did their homework, understood the impact, and made the correct decision.
LightSquared, on the other hand, either didn’t do its homework or intentionally kept quiet in order to fly under the radar and push its initiative through before the GPS user community (and others) knew what was happening. In either case, the GPS user community shouldn’t be held accountable in paying for the FCC’s and LightSquared’s lack of communication/notification.
LightSquared and the FCC incorrectly assumed that communicating/negotiating with the U.S. GPS Industry Council (USGIC) was the equivalent of communicating/negotiating with the GPS user community. That is a false assumption. The USGIC does not communicate directly with the GPS user community and never has. That’s not their role. I’ve been perso
nally involved in the high-precision GPS industry for 20+ years and writing a monthly newsletter on high-precision GPS technology for GPS World magazine for more than five years. I attend almost every major GPS conference and high-precision GPS market segment conference in the U.S. and some abroad. The first I’d heard about the LightSquared interference issue was November 2010.
Even if LightSquared only uses the lower portion of the downlink band (1526-1536MHz) as they’ve proposed, the number of high-precision receivers affected would be at least 200,000 at an estimated replacement cost of $10,000 per unit which equates to a total equipment replacement cost of $2 billion dollars. That does not include the cost of removal/installation, lost productivity, required software upgrades, and training. Do LightSquared and the FCC expect the GPS user community to bear that cost? Hopefully, you can see by the overwhelming number of public comments from small businesses and local government agencies, such an action would be devastating to the U.S. economy.
Lastly, please do not forget about the potential devastating impact of LightSquared mobile devices (uplink band 1626.5-1660.5MHz) on GPS and GNSS receivers. I’m afraid this is being lost in all the discussion about the downlink band. The uplink band could have a worse affect on GPS and GNSS receivers than the downlink band.
LightSquared mobile devices are potentially portable GPS/GNSS jammers. The FCC needs to seriously investigate the interference impact of LightSquared mobile devices (1626.5-1660.5Mhz) on GPS receivers. It is already known that Inmarsat (1626.5-1660.5MHz) devices and Iridium (1616-1626.5MHz) devices interfere with each other, but Iridium devices are only used in remote areas so it’s not a widespread problem. It is also known that these devices interfere with the GLONASS L1 signal (1597-1605MHz). We don’t know the extent of the effect that LightSquared mobile devices will have on GLONASS L1, GPS L1, Galileo L1, or Compass L1 signals. The problem is that no LightSquared mobile devices are available to test. Yes, lab simulations can be performed, but LightSquared devices will be made in Asia, among other places, where the designers won’t care one bit about GPS/GLONASS interference. There is not an acceptable design margin, if any, to allow for sloppy LightSquared device designs.
Thank you for your attention. If you feel that further testimony is needed, I’m more than happy to oblige.
Sincerely,
/S/ Eric Gakstatter
Eric Gakstatter
Principal – Discovery Management Group LLC
Editor – GPS World Magazine Survey Scene enewsletter
Editor – Geospatial Solutions
PO Box 663
West Linn, OR 97068
I think that three things are batting against LightSquared at this point:
1. As much as they say they gave fair warning, LightSquared and the FCC didn’t communicate with the GPS user community at all on this issue. The U.S. GPS Industry Council (USGIC) doesn’t count. They don’t represent the GPS user community nor communicate with the GPS user community at all. So, the GPS user community was blindsided by this in Nov 2010.
This was either intentional or sloppy, but it doesn’t matter either way. The bottom line is that you can’t give nine months notice on obsoleting 200,000+ very expensive GPS receivers that are installed and used in critical infrastructure applications. It would take many years to transition to new equipment. The U.S. Air Force and Dept of Commerce have already been through this drill already and they determined that 12 years was about the right timeframe needed to transition high-precision civilian GPS equipment to new technology. If LightSquared and the FCC really understood this market, they would know it’s not a four-year exercise.
2. Even with LightSquared using only the lower spectrum (1526-1536Mhz), it still interferes with $2+ billion dollars worth of high-precision GPS receivers. Who’s going to pay that bill? The GPS user community that was given no advanced notice?
They can argue all they want about who’s fault it is, new filter technology, DoD standards, etc., but at the end of the day, obsoleting 200,000+ expensive high-precision GPS receivers valued at $2+ billion dollars would be devastating to American small businesses and Fed/State/Local gov’t.
3. LightSquared sells high-precision satellite data communications services to the high-precision GPS industry. Before LightSquared was formed in 2010, its predecessors (Skyterra, MSV) sold the same services to the GPS industry for many, many years. In the course of business over many, many years, LightSquared and its predecessors have encouraged GPS receiver manufacturers to design receivers that look into the MSS band (1525-1559MHz) in order to access LightSquareds satellite data communication services. This service has generated tens of millions of dollars in revenue for LightSquared and its predecessors over many years and continues to be a revenue source for LightSquared today.
If LightSquared chooses to stop supplying satellite data communications services to the GPS industry, thats their choice, but they should not fabricate a statement claiming that only the reason for interference in the lower portion of its downlink band is due to filtering technology. Its just not true. Tens of thousands, if not hundreds of thousands, of expensive high-precision GPS receivers were specifically designed to access LightSquareds and Inmarsats satellite data communications services that they sell to the GPS industry.
LightSquared may state they will continue to offer these services to the GPS industry in the upper portion of its downlink band (1545-1559MHz) to create separation from the lower portion of the downlink band (1526-1536MHz). Its too late for that. Billions of dollars of expensive, high-precision GPS receivers are already in the market that were designed to look in the entire MSS L-band (1525-1559MHz) for services provided by LightSquared and Inmarsat. Had the GPS user community been given sufficient notice, tens of thousands of high-precision GPS equipment owners could have planned for transitioning their GPS receivers over many years with a manageable financial impact. Unfortunately, thats not the case. The GPS user community was blindsided by LightSquareds application in November 2010 and the FCCs waiver granted to LightSquared in January 2011.
Of course, I didn’t mention aviation, maritime, military and other safety-of-life applications of GPS. That’s a whole other story…
Does that mean the FCC is going to tell LightSquared to go home?
“It is unclear to what extent the GPS receivers and devices tested are current production models, into what market segments those receivers and devices are most commonly sold, what fraction of a given market segment those devices represent, and their design lifetimes and typical owner-use lifetimes.This information is important in assessing the likely impact, if any, of interference on various use cases over time. We therefore request production and U.S. sales information for each of the devices tested, including (1) the dates of production, (2) the market segment(s) to which the device is targeted or sold, (3) total annual sales volume and annual sales volume by market segment or estimates thereof, (4) the date on which full support of the device by th
e manufacturer ceased (or will cease), (5) estimated time period after which the device owner would likely replace or discontinue use of the device”.
The letter also requests updated information from LightSquared based on their proposal to use only the lower spectrum (1526-1536MHz). The timeframe to provide the requested information is very aggressive, with all information to be supplied on or before August 22, 2011.
I think this is good news in general. It is the FCC’s first solid attempt to understand the GPS receiver markets in which the proposed LightSquared system will cause interference problems, including high-precision.
The bad news is that the FCC is only requesting market information on GPS receivers that were tested. If you recall in one of my earlier articles, I listed the GPS receivers being tested by the high-precision team. Obviously, if the FCC only used market data from these GPS receivers, the numbers will be underestimated by a large double-digit value and maybe orders of magnitude because many receiver models weren’t included in the test. Also, many CORS in operation are legacy GPS receivers that are out of production. Based on their questions, I have a feeling the FCC will discount those to little or no value, when they actually still provide economic benefit. However, the CORS owner can’t or aren’t in a position to replace them, resulting in a net loss.
No matter which way this goes, I’m pretty confident the FCC is going to use this opportunity to rattle the GPS industry’s cage. Spectrum is a finite resource and the FCC is going to look at ways to allocate spectrum as efficiently as possible, as they should. Is the MSS L-band (1525-1559MHz) being used in the most efficient manner? Probably not. I bet the FCC orders changes in that area, or at least the FCC sets the wheels in motion towards change. I’m ok with that as long as it doesn’t come at the unreasonable expense of the GPS user community, be it high-precision, aviation, military, etc.
All of this bruha is really about timing. Given enough time, GPS receiver manufacturers and component manufacturers have a chance to develop new technologies that use the MSS spectrum more efficiently, if at all. Actually, if the FCC pushes forward like they seem to want, it really isn’t MSS (Mobile Satellite Service) spectrum any longer, it would become a Mobile Terrestrial Service. But developing new technologies, designing/testing products and then allowing the GPS user community enough time to adopt the new technology with a reasonable financial impact takes years, a lot of years, not four or five. It takes more years than what LightSquared has to give no matter which part of the MSS spectrum (low or high) one is discussing.
I think in the short-term the FCC is going to order more testing in order to understand the impact on GPS receivers of LightSquared using only the lower end of the MSS spectrum (1526-1536MHz). We already know it’s going to hammer most high-precision GPS receivers valued collectively at $2+ billion dollars. I don’t have a good grip on how it will affect aviation, military and other receivers in critical apps. We’ll see.
Actually, I agree with what Jeff Kagan of E-commerce Times writes. LightSquared is playing the public relations game the wrong way and they’re getting their nose punched every time they turn around. They should be spending their energy on talking about how wireless communications will be enhanced by their service instead of scraping up obscure DoD specifications they claim that commercial GPS receivers are supposed to adhere to. I still don’t understand what they bring to the table that Sprint, Verizon, AT&T, etc. don’t. Yes, I get that they are a wholesaler and can bring 4G LTE to small service providers. I’m talking about technology. What technology do they bring to the table? If they are just a new distributor in the mix, there’s not much to talk about and maybe that’s why they are fighting the public relations game the way they are. Interesting enough, earlier this week LightSquared announced they hired a new Senior Vice President for Public Relations and Communications, presumably to attempt to resolve the GPS interference fiasco.
Dish Network Announces Plan for 4G LTE Network and Applies for FCC Waiver Similar to LightSquared
Dish Network is trying something eerily similar to LightSquared, but it will have no effect on GPS receivers since their spectrum is far away from GPS (2+ GHz). Dish bought two bankrupt companies last year, Terrestar and DBSD, and have 40MHz of spectrum to play with in 4G LTE. It will be interesting to watch how the FCC deals with this, especially if the Dish waiver is pushed through as LightSquared’s was. With no GPS interference concerns, Dish might be able to field a 4G LTE system before LightSquared can.
As Phil Goldstein from GPS World’s sister publication, Fierce Wireless, comments:
“One of they issues that has come to the fore in the wake of the FCC’s decision to grant a similar conditional waiver to LightSquared is that LightSquared’s L-Band spectrum sits adjacent to GPS spectrum, and that terrestrial transmissions from LightSquared’s proposed wholesale LTE network in the upper portion of its spectrum is causing GPS interference. Pointedly, in its filing, Dish said its 2 GHz S-Band spectrum “will not raise the technical issues that have hampered the use of the MSS L-Band, such as the interleaving of the operators’ assignments and the severe interference claimed by systems operating in adjacent spectrum.”
In return for the waiver, Dish said it will commit to a “substantial terrestrial network deployment” of a branded retail service intended to increase wireless broadband competition, including in rural areas, using LTE-Advanced network technology. Dish said it is prepared to work with the FCC “to develop a reasonable, attainable buildout schedule keyed to commercial availability of the LTE-Advanced standard,” and that it is committed to developing a buildout schedule “consistent with FCC precedent and based on the buildout principles established” in Sprint Nextel’s (NYSE:S) combination of its spectrum assets with Clearwire (NASDAQ:CLWR).
Last week, I was a guest on the American Congress on Surveying and Mapping’s (ACSM) weekly, one-hour America’s Web Radio program. Web radio is actually a very creative idea. You can listen to the live program on your internet-connected computer (11am U.S. Eastern time every Monday) or you can download the recorded program in MP3 format and listen to it using your iPod or other MP3 player. Click here if you’d like to listen to last week’s program when I was the guest.
You may not have noticed it, but last Friday we experienced the first serious geomagnetic storm in this solar cycle (Solar Cycle 24), which began in 2009. Not all types of solar activity (sun spots, solar flares, solar burst, and solar radiation) affect GPS receiver operations. Geomagnetic storms are the ones that can cause problems for GPS receivers if those storms are powerful enough.
Last Thursday, I received e-mail from Joe Kunches at NOAA (National Oceanic and Atmospheric Administration).
“The Sun has been erupting and looks like a storm — say G3 level — could be on for Friday, August 5.”
Joe was right, it hit about a day later, on Friday, August 5, as he predicted.
The good news is that Joe says we generally have at least a 24-hour warning before a geomagnetic storm starts disturbing the ionosphere.
That’s what it comes down to, the ionosphere.
GPS signals being delayed as they pass through the ionosphere end up being the largest source of error in GPS positioning. The signals must pass through the ionosphere, which is full of free electrons. The density of these electrons in the ionosphere affects the speed at which GPS signals travel. If the density of the electrons in the ionosphere was consistent, then it would be straight-forward to create a model and largely mitigate its effects. However, that’s not always the case. The ionosphere has been relatively benign since the last solar cycle, and that’s one of the reasons that GPS accuracy has been so good, especially GPS L1 SBAS systems like WAAS/EGNOS/MSAS, which rely on modeling the ionosphere.
The problem is geomagnetic storms. They wreak havoc on the free electrons in the ionosphere, making it difficult to accurately determine how much the GPS signals have been delayed.
The NOAA Space Weather Prediction Center (SWPC) is one of the foremost agencies that monitors the Total Electron Count (TEC) in the ionosphere. With Joe’s help, I was able to obtain dynamic plots of the TEC from last Friday so I could illustrate to you what happened. I was also able to obtain plots from Gavin Schrock at the Washington State Reference Network (WSRN) showing how it impacted the WSRN. I compiled the plots, added some text, and produced the following Youtube video.
As I wrote in the Youtube video, to get the most updated solar activity information that’s related to high-precision GPS users, you should follow me on Twitter at GPSGIS_Eric.
If you’re looking for a good backgrounder on how the ionosphere affects GPS, you might want to read this April 1991 GPS World column. Although it’s dated in some respects, the fundamental concepts are solid.
Last Push on LightSquared
There’s been some confusion on the FCC comment period regarding the LightSquared/GPS interference issue. The comment period was not extended. The public comment period was July 1 to July 30, 2011. The reply comment period is from August 1 to August 15, 2011. However, it appears the FCC is still logging new comments even after the July 30 cut-off date. Either way, do not hesitate to submit your comments before August 15; just mark it (dropdown menu) as a reply to comments.
This is your last chance to speak out and let your government know how important GPS is to your orgnization.
To date, there have been more than 2,900 individual comments electronically filed as well as more than 15,000 submitted in writing to the FCC (15,000 alone from the Boat Owners Association of the United States). The vast majority of the comments support GPS.
Okay, folks, this is where the rubber meets the road. The FCC public comment period ends this Saturday (July 30). If you use GPS at all, it would be very wise to submit your comments today. Don’t expect the FCC to make a rational decision. There’s a lot of money and political influence in LightSquared’s camp and those can dwarf engineering/technical arguments even if they are overwhleming. The best weapon the GPS user community has is sheer numbers, but we aren’t showing up!
To date (July 27), only 1,896 comments have been submitted. That’s not even close to being enough to get the FCC’s attention, and many of those are aviation and geocaching. Also, you see the politically connected comments (chiefs of police, mayors, state legislators, etc.) are largely in support of LightSquared. That’s because LightSquared is mobilizing its political influence machine.
Submitting your comments to the FCC only takes five minutes. You don’t need to write an essay. Here’s what you need to make the FCC aware of:
What you (or the organization you work for) use GPS for.
How much (approximately) your organization has invested in GPS equipment/software.
How much your organization (business or public entity) depends on GPS.
How it would affect your organization (business or public entity) if GPS was interfered with.
If you are worried about not getting approval in time from your department, etc, just keep your comments generic and don’t mention your organization name. The value is the story you tell about how important GPS is to you and your organization, not the specific names.
I suggest composing your comments in a word processor (Word, WordPad, Notepad, etc.) first, then copy/paste to the FCC form so you don’t lose your work in case something goes sideways with the FCC website while you are typing.
Here are simple instructions to submit your comments:
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 street address
City: Enter your city
State: Enter your state
Zip: Enter your zip code
Type in or paste your brief comments: Copy/paste your comments
That’s it. Five minutes and you’re done.
DO NOT assume the Department of Defense, Department of Transportation, the National Telecommunications and Information Administration (NITA) or other organizations that have submitted comments will save the day. They are interested in only protecting their own turf, not yours. I still hear people saying, “The FCC will never let this happen because the Department of Defense or DOT will stop them.” If that was the case, this would have stopped months ago. The further along this goes, the more the following statement rings true (that I wrote back in May):
“The military is going to be accommodated in the name of national security. The aviation industry is going to be accommodated in the name of safety-of-life. The auto navigation industry is going to be accommodated because they are high-profile. The high-precision user is going to be thrown under the bus because we are the most difficult to accommodate (technically) and don’t have a high profile nor are perceived as significant enough to accommodate.”
LightSquared’s latest proposal is to begin using its lower frequency spectrum (1526-1536MHz) first. The departments of Defense, Transportation, and NTIA may bite on this as a compromise for LightSquared’s “good faith effort.” LightSquared says this new plan will accomodate all but 0.5% of GPS receivers. To the FCC, it appears like LightSquared is bending over backwards because they’ve accommodated 99.5% of all GPS receivers. If you didn’t know any better, you’d be impressed, too! The problem for you is that the remaining 0.5% of the GPS receivers are your RTK and high-precision GPS receivers that you’ve spent tens of thousands of your money to purchase! LightSquared’s solution is to have you purchase new equipment.
If you’re interested in reading my comments to the FCC, the following is what I’m submitting to the FCC today. Feel free to copy/paste parts you agree with and incorporate them into your comments if you choose.
July 27, 2011
Eric Gakstatter
Editor – GPS World magazine Survey Scene enewsletter
Editor – Geospatial Solutions
High-precision GPS Consultant
PO Box 663
West Linn, OR 97068
Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Re: IB Docket No. 11-109
Dear Ms. Dortch,
I have serious concerns about LightSquared’s proposal for a nationwide 4G LTE system. I’m afraid that neither LightSquared nor the FCC fully understand the impact of LightSquared’s proposed system on GPS receivers, America’s small businesses, and America’s economy.
As a Contributing Editor to GPS World magazine, my specialty is high-precision GPS receivers, of which I’ve been involved with for more than 20 years as a product developer, power user, and consultant. I’m in touch with tens of thousands of high-precision GPS users from around the world through my newsletter articles (bi-weekly), webinars, and my attendance at technical conferences. I consider myself and I’m considered by others to be an advocate for the high-precision GPS community.
Hundreds of thousands of high-precision GPS receivers in the U.S. are used across many market segments including civil/environmental engineering, construction, land surveying, Geographic Information Systems (GIS), agriculture, forestry, road/rail/airport, hydrography, environmental, water/gas/electric/oil/telecom utilities, mining, bridge/dam monitoring, emergency management, defense & intelligence, higher education, and all levels of Fed/State/Local government.
To illustrate, allow me to describe some examples of how high-precision GPS is being used.
In road construction, high-precision GPS offers a 5-to-1 efficiency advantage over legacy construction equipment. Can you imagine the delays if road construction projects took five times longer to complete? California’s Department of Transportation (CALTRANS) currently has 846 construction projects ongoing with construction costs of ~$10.5 billion. High-precision GPS receivers are a critical component of these projects. Projects such as the widening project pictured below, are completed way ahead of schedule. For this reason, CALTRANS has invested in 250 high-precision GPS receivers valued at ~$5 million (~$20,000 per receiver).
CALTRANS Highway 101 project widened the route from four to six lanes to extend the carpool lane for two and a half miles and upgrade a congested interchange in Santa Rosa, six months ahead of schedule
It’s not just large, high-precision GPS receiver deployments that matter. GPS also keeps the public safe.
In Florida, the 5.5 mile Sunshine Skyway Bridge spanning Tampa Bay has five high-precision GPS
receivers permanently mounted on it so engineers can monitor the health of the structure. On an annual basis, more than 18 million vehicles travel over the bridge. High-precision GPS is a core technology that ensures the safety of those 18 million vehicles.
The structural integrity of the Sunshine Skyway Bridge over Tampa Bay is continuously monitored by high-precision GPS receivers, ensuring the safety of more than 18 million vehicles per year
It’s not just thousands of public entities that are invested in high-precision GPS technology. Tens of thousands of U.S. small businesses rely on high-precision GPS technology in their daily operations.
A small land surveying firm owner in Virginia says:
“I have relied on GPS for survey grade data for at least 15 years. We use GPS every day for all projects. If GPS becomes unavailable or unreliable it will just about put us out of business. Our $500,000 investment would become worthless.”
A four-person agricultural drainage firm owner states:
“I am president of a small business that relies solely on high accuracy GPS. We do GPS Ag drainage (I and three other employees) we set a base on site all over the state because close proximity RTK correction is the only way to get the vertical accuracy required to do what we do. Any GPS interference immediately closes my business and puts four people out of work.”
Another small land surveying firm says:
“High-precision GPS allows us to obtain measurements between monuments which are miles apart to control land boundaries … in a couple of hours that 20 years ago would required 20 to 30 hours of field crew time. The change in technology comes with our investment of approximately $100,000 which is very significant for a small firm like ours. If we are to wake up here in the next year and find our equipment useless for high-precision GPS, the effects would be devastating to us and our clients in both private development and public infrastructure.”
Finally, high-precision GPS users rely on a complex infrastructure of 7,000+ high-precision, fixed-mount GPS base stations deployed nationwide. The infrastructure began with a few receivers in the early 1990s and has been built upon over the past 18 years by the GPS user community volunteering time, money, equipment, and expertise. It would be impossible to replace all of these receivers since the ownership is so disparate. Many are publicly owned and the rest are commercially owned by businesses and used by people in all the market segments I listed above. To illustrate, one such network consisting of more than 875 high-precision GPS receivers is located in the western United States managed by UNAVCO, a university-governed consortium which is sponsored by the National Science Foundation (NSF), National Aeronautics and Space Administration (NASA), U.S. Geological Survey (USGS), and National Oceanographic and Atmospheric Administration (NOAA).
UNAVCO uses this massive network of high-precision GPS receivers to, among other things, monitor the earth’s crustal plate movement (think earthquake montoring).
Each dot represents a permanently-mounted high-precision GPS receiver that continuously monitors the Earth’s crustal plate movement
Another type of high-precision GPS network is called an RTK network. It delivers real-time, high-precision corrections to engineers, surveyors, Geographic Information Systems (GIS) specialists, construction specialists, and others. This particular network, owned by Keystone Precision Instruments, consists of 178 fixed-mount, high-precision GPS receivers and delivers high-precision GPS corrections to users in New York, Pennsylvania, Maryland, Virginia, Delaware, New Jersey, Connecticut, Vermont, Massachusetts, Rhode Island, New Hampshire, and Maine.
Like the UNAVCO network, the Keystone Precision Instrument RTK Network is a multi-million dollar investment in high-precision GPS infrastructure.
Keystone Precision Instruments’ RTK Network diagram showing 178 fixed-mount, high-precision GPS receivers that provide high-precision GPS corrections to high-precision GPS users in the northeastern U.S.
Recommendations
I’m grateful for this 30-day public comment period as I think it will give the FCC and LightSquared a new perspective on the impact that disrupting high-precision GPS receivers would have on the GPS user community and America’s economy.
Although I’m in favor of a nationwide 4G LTE system, I’m opposed to LightSquared’s proposed plan for the following reasons:
1. The GPS user community knew this was coming and chose to do nothing. This is false. Contrary to what LightSquared asserts, the GPS user community did not know anything about this potential interference until November 2010. LightSquared and the FCC incorrectly assumed that communicating/negotiating with the U.S. GPS Industry Council (USGIC) was the equivalent of communicating/negotiating with the GPS user community. That is a false assumption. The USGIC does not communicate directly with the GPS user community and never has. That’s not its role. I’ve been personally involved in the high-precision GPS industry for 20+ years and writing a monthly newsletter on high-precision GPS technology for GPS World magazine for the past five years. I attend almost every major GPS conference and high-precision GPS market segment conference in the U.S. and some abroad. The first I’d heard about the LightSquared interference issue was November 2010.
Furthermore, there is a clear precedent already set that demonstrates how to handle a case very similar to the current LightSquared situation. In 2008, the U.S. Air Force proposed to discontinue supporting the semicodeless technique that is used by virtually every civilian L1/L2 high-precision GPS receiver in existence. It was the first time in history that an action would render several hundred thousand high-precision GPS receivers obsolete, a scale which is very similar to the impact of the LightSquared system.
There was no industry coalition formed to engage the Air Force. There was no industry outcry. A public/private technical working group was not formed to test the effects on receivers if semicodeless was not supported. Why is that?
The answer is very simple. The U.S. Air Force, to its credit, did a fantastic job of communicating directly with the GPS user community along with the Department of Commerce. It issued public statements describing the impact the action would have on high-precision GPS receivers.
The U.S. Air Force did its homework. At the end of the day, it set a sunset date of December 31, 2020, to discontinue supporting the semicodeless technique. It correctly determined that 12 years is about the amount of time that would allow a smooth transition with a manageable financial impact to the high-precision GPS user community.
Imagine if the U.S. Air Force had set a period of one year to transition away from using the semicodeless technique. That action would have destroyed the high-precision GPS user community resulting in billions of dollars in losses and widespread small business closure
. Fortunately, they did their homework, understood the impact, and made the correct decision.
LightSquared, on the other hand, either didn’t do its homework or intentionally kept quiet in order to fly under the radar and push its initiative through before the GPS user community (and others) knew what was happening. In either case, the GPS user community shouldn’t be held accountable in paying for the FCC’s and LightSquared’s lack of communication/notification.
2. The FCC needs to consider future GPS signals as well as satellite signals from other satellite navigation systems. The FCC needs to investigate the effect of the LightSquared system on the future GPS L1C signal as well as GLONASS L1 (Russia), Galileo L1 (Europe), and Compass L1 (Chinese) to understand the effect on receivers of today and of the future. GPS L1C, Galileo L1, and Compass L1 all use wider bandwidth than today’s GPS L1, which makes them even more susceptible to interference from LightSquared’s system.
L1 and L5 are the GPS, GLONASS, Galileo, and Compass signals of the future. Those signals will drive hundreds of billions of dollars in revenue because they will bring high-precision accuracy to our everyday lives, which is something only available on very expensive GPS receivers today.
Again, precedence has been set. Look at what happened to GPS navigation after Selective Availability (SA) was turned off in May 2000. Overnight, GPS accuracy improved from 100 meters to 10 meters, and subsequently the multi-billion dollar market for GPS automobile navigation devices was launched. Companies like TomTom grew from zero revenue to multi-billion dollar corporations.
The same is expected to happen again when mainstream GPS accuracy improves from 10 meters to well under a meter using the L1 and L5 signals, but that will only occur if the GPS L1, GLONASS L1, Galileo L1, and Compass L1 signals are protected. Some say that L2 can be used instead of L1 in the future. While that’s true for GPS, L1 and L5 have become the international standard while L2 is not supported by the international community.
3. LightSquared mobile devices are potentially portable GPS jammers. The FCC needs to seriously investigate the interference impact of LightSquared mobile handsets (1626.5-1660.5 Mhz) on GPS receivers. It is already known that Inmarsat (1626.5-1660.5 MHz) devices and Iridium (1616-1626.5 MHz) devices interfere with each other, but Iridium devices are only used in remote areas so it’s not a widespread problem. It is also known that these devices interfere with the GLONASS L1 signal (1597-1605 MHz). We don’t know the extent of the effect that LightSquared mobile devices will have on GLONASS L1, GPS L1, Galileo L1, or Compass L1 signals. The problem is that no LightSquared mobile phones are available to test. Yes, lab simulations can be performed, but LightSquared devices will be made in Asia, among other places, where the designers won’t care one bit about GPS interference. There is not an acceptable design margin, if any, to allow for sloppy LightSquared device designs.
The consequence of LightSquared mobile devices interfering with GPS L1, GLONASS L1, Galileo L1, and Compass L1 is hard to imagine and might be worse than interference from the 40,000 LightSquared towers. Although the LightSquared mobile devices are much lower power (2-3 watts vs. 1,500 watts), LightSquared has announced they intend to deploy more than 250 million mobile devices, which could behave like portable GPS jammers.
Please pay attention this important technical issue that many have chose to ignore.
4. LightSquared needs to permanently abandon using the upper frequency spectrum (1545-1555 MHz) for terrestrial broadcasting. The idea of LightSquared using its licensed upper frequency spectrum (1545-1555 MHz) for terrestrial purpose needs to be permanently abandoned. It’s clear from the test results that this causes widespread GPS interference no matter which class of GPS is used.
Finally, I would like to emphasize that the GPS user community should bear no cost as a result of any interference from LightSquared’s system. The GPS user community was blindsided in November 2010. While you can debate whether about the communication between the FCC, MSV/Skyterra/LightSquared, and the U.S. GPS Industry Council, no case can be made that the GPS user community knew of MSV/Skyterra/LightSquared’s intentions earlier than late last year, yet the FCC and LightSquared expect the GPS user community to bear the cost of interference caused by LightSquared’s system?
Furthermore, far too little testing has been completed in order to fully understand the impact of LightSquared’s system on GPS receivers. Yes, we have a rough idea of the scale of interference from the test reports submitted in June 2011, but the devil is in the details.
Even if LightSquared only uses the licensed lower spectrum (1526-1536 MHz), as it has proposed as an alternative, the number of high-precision receivers affected would be at least 200,000 at an estimated replacement cost of $10,000 per unit which equates to a total equipment replacement cost of $2 billion dollars. That does not include the cost of removal/installation, lost productivity, required software upgrades, and training. Does the FCC expect the GPS user community to bear that cost?
For the above reasons, I recommend that the FCC deny LightSquared’s request to proceed and encourage them to use spectrum outside of the MSS band. The resources expended by federal/state/local governments and private corporations to vet LightSquared’s proposal to use the MSS band has run into the tens of millions of dollars, if not more than a one hundred million dollars. I’m afraid the cost of further vetting will double or triple the expenditure as well as result in tremendous opportunity cost as significant resources are expended by public and commercial entities to continue this debate.
Thank you for your attention. If you feel that further testimony is needed, I’m more than happy to oblige.
Sincerely,
/S/ Eric Gakstatter
Eric Gakstatter
Principal – Discovery Management Group LLC
Editor – GPS World Magazine Survey Scene enewsletter
At stake is the high-precision GPS industry as we know it. If LightSquared’s current proposal is approved by the FCC, it will render tens of thousands, and possibly hundreds of thousands of GPS receivers obsolete starting as early as next year. The FCC is accepting public comments until July 30 and replies to those comments until August 15. After the public comment period is closed, the FCC can render a decision at any time. Last weekend, I spoke alongside LightSquared and the Coalition to Save Our GPS in a two-hour panel discussion at the Esri Survey Summit in San Diego. Here’s my report.
Last weekend, I attended the Esri Survey Summit in San Diego. This year was different in that it was combined with the ACSM (American Congress on Surveying and Mapping) annual conference. Part of the conference Plenary on Saturday were 30-minute presentations by LightSquared and the Coalition to Save Our GPS. The following morning (Sunday), there was a two-hour discussion panel on the LightSquared/GPS interference issue, in which I participated.
At stake is the high-precision GPS industry as we know it. If LightSquared’s current proposal is approved by the FCC, it will render tens of thousands, and possibly hundreds of thousands of GPS receivers obsolete starting as early as next year. The FCC is accepting public comments until July 30 (see also instructions at the bottom of this column) and replies to those comments until August 15, 2011. After the public comment period is closed, the FCC can render a decision at any time.
The FCC is clearly biased on the LightSquared/GPS issue favoring LightSquared. There’s a lot of pressure to push the U.S. National Broadband Plan, which includes improving Americans’ accessibility to high-speed wireless connectivity to the Internet. After only 2 ½ weeks on the job, FCC Wireless Telecommunications Bureau Chief Rick Kaplan stated earlier this month that “We need to make sure we aren’t locking out valuable spectrum because of inefficient transmission,” obviously referring to the LightSquared/GPS interference issue.
The LightSquared propaganda machine has been effective in bending the ear of technically-challenged policymakers into believing GPS receivers are using LightSquared’s spectrum without permission, and that GPS receiver designers have known this issue was coming since as early as 1995. Both statements, of course, are not true as I’ve written before, as has GPS World editor Alan Cameron (see LightSquared, FCC Rebuttals Distort Record), and as published on the Coalition to Save Our GPS website.
Last weekend’s Survey Summit was perhaps the best opportunity to date for land surveyors and other high-precision GPS users to speak out and let LightSquared and our policymakers know how crucial high-precision GPS/GNSS receivers are to their operations. The discussion content was very good and our industry clearly made its points, but it was all for naught.
Esri got LightSquared Executive Vice President Jeffrey Carlisle to fly in from Washington D.C. to speak at the plenary and then participate in the discussion panel along with myself, moderator John Matonich (NSPS), Dr. Javad Ashjaee (JAVAD GNSS), Dr. Joe Paiva (consultant), Curt Sumner (ACSM), and Peter Large (Coalition to Save Our GPS). However, it was a lost opportunity. Only fifty or so people attended the discussion panel, and I’m sure Mr. Carlisle flew back to Washington D.C. to report that the high-precision GPS users just rolled over, and they are not nearly the roadblock that might have been anticipated.
LightSquared: 1, High-Precision GPS Users: 0
A few key points from the discussion panel I think are worth noting:
It’s a joke, but LightSquared is probably going to win the argument that the “GPS industry knew this was coming.” It is going to win not because it is correct, but because Jeff Carlisle was an FCC employee for several years and knows which buttons to push at the FCC, where to find documents that are publicly available — but not reasonably accessible to the general public, in my opinion — and how to misrepresent them.
Who is the “GPS industry” that LightSquared and the FCC refer to?
When LightSquared and the FCC refer to the “GPS industry,” they certainly are not referring to the GPS user community (you and I), which is expected to bear a huge financial burden (you and I will need to buy new GPS equipment) if the LightSquared proposal is approved.
In nearly all of its documents, LightSquared refers to discussions and agreements with the U.S. GPS Industry Council (USGIC). I have a problem with this, and so should you. The USGIC is a sort of chamber of commerce for GPS manufacturers. If you perform a Google search for the U.S. GPS Industry Council, you won’t find a website, you won’t find a listing of council members, nor will you find much other information about it.
The USGIC, in other words, does not maintain a high public profile. To be fair, it is an industry council, not a user council.
To be further fair, the Industry Council did negotiate an agreement several years ago with a former version of LightSquared (under different ownership then) and with the FCC, along certain business terms and technical parameters. That agreement did not harm GPS users in any way; in fact, it contained some inherent protections for GPS users. The current version of LightSquared has completely changed both its business plan and those technical parameters — turned them on their heads, as a matter of fact — but blithely continues to claim that this was all worked out and agreed to previously.
Nevertheless, how has it come about that the USGIC was the negotiator with LightSquared and its predecessors for you and I regarding your GPS equipment when you’ve never met a USGIC representative, and never had a chance to provide comments before negotiations with LightSquared and its predecessors on such a critical issue?
When I made a statement about this during our discussion panel, Jeff Carlisle called me a “fear-monger,” if I recall correctly, and he referred to my assertion that the USGIC is a chamber of commerce as “ridiculous.” I think he needs a little education.
The analogy I used was that when Walmart wants to build a store in your town, it does not negotiate with the Chamber of Commerce, because the Chamber of Commerce does not represent the citizens. Walmart negotiates with the City Planning Department and City Planning Commission, which is comprised of citizens of the community, who are directly impacted and must bear the consequence of the development.
The reason LightSquared is in this controversial and expensive predicament today is because it chose the incorrect organization to negotiate with. Perhaps on purpose, so it could maintain later that it had negotiated with someone.
This is not virgin territory. There is a clear precedent on this subject. Do you remember back in 2008 when the U.S. Air Force (GPS stewards) wanted to discontinue supporting the semicodeless technique that is used by virtually every civilian dual frequency GPS receiver in existence? It was the first time in GPS history that an action would render several hundred thousand high-precision GPS receivers obsolete, a scale which is very similar to the effect that the LightSquared system would have on high-precision GPS receivers today.
Do you recall an industry coalition being formed to fight it? Do you recall an industry outcry? Do you recall a technical working group being formed to test the effects on receivers if semicodeless was not supported?
The answer is no.
Why is that
?
The answer is very simple. The U.S. Air Force, to its credit, did a fantastic job of communicating with the GPS user community along with the Department of Commerce. It issued public statements describing the impact the action would have on GPS receivers. It held a public comment period. The following statement from its website succinctly summarizes its approach:
“The Office of Space Commercialization worked hard to raise awareness of the size and significance of the high-end GPS user community, which was poorly understood within the government. The Office collected industry information to quantify the installed base of codeless/semi-codeless GPS equipment, estimate its economic value, and determine an acceptable time frame for its replacement. The Office also issued a request for public comments to receive broad stakeholder feedback.”
In other words, it did its homework. At the end of the day, the U.S. Air Force set a date of December 31, 2020 to discontinue supporting the semicodeless technique. It correctly determined that 12 years is about the correct amount of time that would allow a smooth transition with a manageable financial impact to the GPS user community. Users would naturally upgrade their equipment during that period.
Imagine if the U.S. Air Force had set a period of one year to transition away from using the semicodeless technique. That action would have destroyed the high-precision GPS user community, and the continued adoption of high-precision GPS technology would have been set back for years. Fortunately, it did its homework.
LightSquared, on the other hand, either didn’t do its homework or intentionally kept quiet in order to fly under the radar and push its initiative through before the GPS user community (and others) knew what was happening.
During the discussion panel, I wanted to (and I think I did) make three points very clear:
The high-precision GPS user community did not know this was coming, period.
There was a precedent already set that clearly illustrated how to successfully communicate to the high-precision GPS user community when an action is proposed that would effectively render hundreds of thousands of high-precision GPS receivers obsolete.
The high-precision GPS user community should not bear any cost related to LightSquared implementing its system.
That said, I’m not saying “no” to LightSquared.
I get the 4G wireless broadband argument that LightSquared and the U.S. National Broadband Plan make. I want high-speed internet on my smartphone too. I want my phone to work in elevators and elevator-like environments that LightSquared promises. I think this might be a boost to the economy.
While I’m not saying “no” to LightSquared, I’m saying “no” to LightSquared’s proposal at this moment. There are still waaaaay too many unknown issues to be understood and resolved.
A few of them are:
Even using the lower frequency spectrum in its new proposal (1526-1536MHz), at least tens (maybe hundreds) of thousands of your high-precision receivers will need to be replaced. Who will bear that cost?
More testing is needed to understand exactly what the effect of using only the lower frequency spectrum will have on all types of GPS receivers. That was not LightSquared’s original roll-out plan and therefore wasn’t tested extensively to determine its affect on GPS receivers.
The idea of using the upper frequency (1545-1555MHz) for high-powered terrestrial broadcast needs to be permanently abandoned.
The effect on GLONASS L1, Galileo L1, Compass L1, and GPS L1C need to be extensively tested to understand the effect on GNSS receivers of today and of the future. Galileo L1, Compass L1 and GPS L1C all use wider bandwidth than today’s GPS L1 C/A, which makes them even more susceptible to interference from LightSquared’s system.
A serious effort needs to be made to understand the effect of LightSquared’s mobile devices on GPS/GNSS receivers. LightSquared’s mobile devices will operate in the 1626.5-1660.5MHz frequency spectrum, above the GPS L1 spectrum and GLONASS L1 (~1597-1605MHz). It’s been reported that Inmarsat devices (using LightSquared’s 1626.5-1660.5MHz mobile device spectrum) do not fare well around Iridium phones (1616-1626.5MHz), which is very close to GLONASS L1.
We have to be very careful and test these scenarios because once the plug is pulled, you can’t suck the water back out of the drain. There’s no turning back. Also, the FCC doesn’t have a solid history of making good decisions in the wireless arena. In the words of noted wireless industry guru Andrew Seybold (BlackBerry, HP, AT&T, Motorola):
“The history of wireless is littered with examples where the FCC acted on a request by a vendor, approved the deployment of a system, and later learned that the new system created interference to other services.”
In fact, Mr. Seybold writes that LightSquared shouldn’t be permitted to move forward at all. On July 6, 2011, he published the following:
“Okay, I admit it. I don’t believe LightSquared should be permitted to use what was supposed to be satellite spectrum for a terrestrial broadband network. Not only that, I don’t believe LightSquared has a sound business plan. Building more than 40,000 cell sites, maintaining them, and reselling the bandwidth to others who want to sell it to its customers, does not pencil out in my book. The margins will be too slim, especially given the fact that prices for both voice and broadband services keep falling in the United States so margins will continue to be squeezed. But apart from a faulty business plan, the main reason I am opposed to LightSquared’s plan to build this network is that if there is the slightest chance it will interfere with GPS receivers, it simply should not be permitted to be built.”
To file comments with the FCC: Comments may be filed electronically using the Internet by accessing the ECFS: http://fjallfoss.fcc.gov/ecfs2/. Filers should follow the instructions provided on the website for submitting comments. In completing the transmittal screen, ECFS filers should include their full name, U.S. Postal Service mailing address, and IB Docket No. 11-109.
Join GPS World’s Survey and GIS Editor Eric Gakstatter March 15 for the webinar, “Everything Else but GPS: How GLONASS, Galileo, and Compass Will Affect High-Precision Users.” The webinar will be held at 10 a.m. Pacific (1 p.m. ET/6 pm. GMT); registration is free.
