Attachment LightSquared - Instr

This document pretains to SAT-MOD-20101118-00239 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010111800239_866372

                                  Instrument Overhaul Service of San Diego, Inc.
                                              1981 N. Marshall Ave. * El Cajon, CA 92020
                                                PH. (619) 449—5565 FAX (619) 449—0687
                                                    FAA Repair Station CB3R417L
                                                                                           Received & Inspected
January, 17 2011                                                                              JAN 26 20"


The Honorable Julius Genachowski                                                                  i
Chairman, Federal Communication Commission                                                 FCC Mall ROOITI
Room 8—B201
445 12th Street, SW
Washington, DC 20554

Subject: FCC File No. SAT—Mod—20101118—00239, LightSquared Subsidiary LLC Request for Modification of Its
         Authority for an Ancillary Terrestrial Component

Dear Mr. Genachowski:


We are deeply concerned that the proposal by LightSquared referenced above will interfere with GPS
receiver operation. It is imperative that the GPS national utility remain free of impediments to operation for
more than 75 million North American GPS users.

This is not simply a "turf war" over spectrum allocattion. It is a public safety issue that would threaten the
national transportation grid, national financial system, national security, and virtually everyone in the United
States.

The LightSquared proposal will result in an unreliable GPS signal reception with the following effects:

          e   Inability of emergency responders to effectively answer calls

          e   Loss of pilots‘ primary means of navigation during a final approach

          e   Disruption of training exercises for military service members who routinely use commercial GPS
              systems

          e   Loss of the precise timing provided by GPS which is essential for operation of the financial system,
              power grid network synchronization, and cellular telephone system synchronization and cost
              accounting

Furthermore, the U.S. GPS constellation is currently undergoing an $8 hbillion upgrade. Approval of the
LightSquared proposal without adequate testing will result in a poor return on this huge taxpayer
investment.

We urge the FCC to conduct technical interference analysis BEFORE granting a waiver to effectively allow
a reallocation of spectrum use from mobile satellite space service to terrestrial wireless service that is
adjacent to the band where GPS operates. Further, we urge the FCC to consider this request from
LightSquared under the Notice of Proposed Rule—Making process initiated in ET Docket No. 10—142 to ensure
adequate opportunity for public comment.

Very fruly yOobprs,
           e   ie
          * Nb


 seneral Manager
      £



&c:           Commissioner Michael J. Copps
              Commissioner Robert M. McDowell
              Commissioner Mignon L. Clyburn
              Commissioner Meredith A. Baker



Document Created: 2019-04-21 06:26:21
Document Modified: 2019-04-21 06:26:21

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