Attachment LightSquared - Spada

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

IBFS_SATMOD2010111800239_867563

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    January 13, 2011
                                                                                            Received & Inspected
    The Honorable Julius Genachowski
    Chairman, Federal Communication Commission
    Room 8—B201                                                                                 JAN 2 O 20“
    445 12th Street, SW                                                                       FCC Ma" Room
    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 allocation. 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,

    ;he 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 billion 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.



Mw""“ /       & 3’9 &   L       "¥a
    Tom Spadafora
    GPS Product Owner




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



Document Created: 2019-04-17 23:36:42
Document Modified: 2019-04-17 23:36:42

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