Two Among 2,692 and Counting — Voices Raised in LightSquared Conflict

> Two Among 2,692 and Counting — Voices Raised in LightSquared Conflict
> August 2, 2011

http://www.gpsworld.com/gnss-system/...conflict-11947

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> Two notable filings have appeared among the many to the Federal Communications Commission (FCC) in the Matter of LightSquared Subsidiary LLC, IB Docket No. 11-109, Request for Modification of its Authority for an Ancillary Terrestrial Component. One comes from Tom Stansell, a longtime expert and consultant in the GNSS community, and the other from the U.S. GPS Industry Council.
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> As of midnight, August 1, the FCC comment site had logged 2,692 submissions, and more are being uploaded as the FCC processes them. The Boat Owners Association of the United States delivered 15,000 letters in support of GPS to the FCC.
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> GPS World survey editor Eric Gakstatter is at work on an interactive online map of FCC comment submitters regarding the LightSquared debate. Instead of searching through the FCC comment database one-by-one, this would enable viewers to zoom in and click on specific icons: for or against, public/private/legislator, and industry (surveying, aviation, consumer, and so on). More as we know it.
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> The Stansell response focuses on five key points:
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> the significant difference between bandwidth requirements for communication as compared with navigation

> the fact that LightSquared handsets are likely to interfere more with GPS than the ATC transmitters,

> the wideband M-code signal development,

> the U.S. treaty obligation to protect the European Union (EU) Galileo signals, and

> the need for extensive new testing not only of the recent LightSquared proposal to transmit only a low-10 LTE signal but also of the significant potential for interference due to out-of-band-emissions (OOBE) from LightSquared handsets and protection of Galileo signals.

> A PDF containing the complete Stansell Consulting comments appears here.
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> All the recent postings on this issue can be downloaded from this site. Alternately, go to this site and search for Proceeding 11-109.
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> The U.S. GPS Industry Council comments, in rough outline, consist of the following. For a PDF of the Council’s full document, click here.
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> The TWG Final Report Confirms:

> That the interference and compatibility problem the USGIC identified prior to the January 2011 LightSquared Order exists.

> That there are no “appropriate and feasible” mitigation techniques that will enable LightSquared to operate its proposed 4G LTE terrestrial broadband service as planned in the 1525-1559 MHz band.

> That increasing filtering on future GPS receivers and devices is at best a theoretical option; no suitable filters exist today or were available for testing by the TWG.

> That filtering does nothing to protect the hundreds of millions of direct GPS users in the installed base, and the many more who benefit inndirectly from GPS.

> That LightSquared 4G LTE terrestrial broadband operations using only the lower 10 MHz channel at 1526-1536 MHz would cause harmful interference to GPS receivers and GPS-dependent applications.

> That the harmful interference concerns raised with respect to LightSquared’s proposed 4G LTE terrestrial broadband operations in the 1525-1559 MHz band have not been resolved.

> The TWG Final Report clearly reflects the expectation that increases in filtering would negatively impact GPS receiver performance, and would degrade the accuracy of GPS receivers.

> GPS innovation in positioning, navigation, and timing is proceeding in the direction of wideband GPS signals and wider band use of the GPS allocation.

> The commission must reject’s attempt to reduce the number of affected GPS receivers and GPS-dependent applications by introducing new, unsupported harmful interference criteria.

> The TWG final report results, endorsed by all parties other than LightSquared, are consistent with findings made in other contemporaneous studies of potential.LightSquared harmful interference to GPS receivers and GPS-dependent applications.

> LightSquared’s attempts to distance itself from the TWG final report’s conclusions by accusing GPS manufacturers of producing deficient products are fallacious.

> LightSquared’s assertion that GPS manufacturers should have anticipated “adjacent band terrestrial transmissions” is wrong.

> The commission should reject outright the extraneous and incorrect non-technical factors LightSquared includes in its response.

> Contrary to LightSquared’s claim, GPS receivers are extremely efficient users of the spectrum resource.

> LightSquared wrongly tries to portray the interference issue as a battle between GPS and terrestrial broadband services.

> LightSquared’s “proposed solution” is no solution at all.

> The only conclusion to draw from the TWG final report and the LightSquared response is that LightSquared’s 4g LTE terrestrial broadband service needs to be provided in a different frequency band.
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See:
http://www.gpsworld.com/gnss-system/...conflict-11947