Attachment LightSquared - Eclip

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

IBFS_SATMOD2010111800239_867565

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January 14, 2011                                                                       Received & mspected
The Honorable Julius Genachowski —
Chairman, Federal Communication Commission                                                   JAN 4 g 2011
Room 8—B201
445 12th Street, SW                                    ,                                 FCGC Mail 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.

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 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.




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Senior Vice President    C   (=   >jo3% 01 19              S           To d p o okie     0
Eclipse Aerospace Inc.
2503 Clark Carr Loop SE
Albuquerque,NM 87106
505—724—1843‘




co:        Commissioner Michael J. Copps
           Commissioner Robert M. McDowel!
           Commissioner Mignon L. Clyburn
           Commissioner Meredith A. Baker



Document Created: 2019-04-18 08:24:49
Document Modified: 2019-04-18 08:24:49

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