Attachment LightSquared - Garmi

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

IBFS_SATMOD2010111800239_870656

DOWLOhneS M. Anne Swanson z): D 202.776.2534 E aswanson@dowlohnes.com EX PARTE OR LATE FILED February 7, 2011 FILED/ACCEPTED VIA HAND DELIVERY . FEB —7 7011 Marlene H. Dortch, Esquire Federal Communications Commission Secretary Office of the Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Notification of Ex Parte Presentation in LightSquared Subsidiary LLC Application for Modification of Authority for Ancillary Terrestrial Component, File No. SAT—MOD—20101118—00239 Dear Ms. Dortch: On February 4, 2011, on behalf of Garmin International, Inc. ("Garmin"), I met with Paul de Sa, Chief of the Office of Strategic Planning and Policy Analysis, to discuss the results of empirical experimentation conducted by Garmin to assess the impact on GPS receivers operating in the 1559—1610 MHz band of fixed, high—power terrestrial broadband transmitters of the new, non—ancillary type LightSquared Subsidiary LLC ("LightSquared") first proposed in its above— referenced November 2010 application. The LightSquared application proceeding has been designated to have permit—but—disclosure status for purposes of the Commission‘s ex parte rules. I provided Dr. de Sa with a copy of the ex parte report filed by the GPS Industry Council on January 20, 2011 in connection with the application as well as the attached press reports. By this letter, and in accordance with Section 1.1206 of the Commission‘s Rules, 47 C.EFR. § 1.1206, two copies of this letter and its Appendices are provided for inclusion in the Commission‘s files. Please let me know if you have any questions. . Anne Swanson Counsel for Garmin International, Inc. Attachments ce w/attach. (by email): Dr. Paul de Sa Dow Lohnes PLLC WasHincton, DC | Atianta, GA 1200 New Hampshire Avenue, NW, Suite 800 Washington, DC 20036—6802 Attorneys at Law T 202.776.2000 F 202.776.2222 www.dowlohnes.com

FILED/ACCEPTED FEB —7 7201 Federal Communications Commissi on Office of the Secretary WASHINGTON, DC STEPHEN D. BARUCH 202.416.6782 SBARUCKH@LERMANSENTER.COM January 20, 2011 By Hand Delivery Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, D.C. 20554 Re: Notice of Ex Parte Presentation in LightSquared Subsidiary LLC Application for Modification of Authority for Ancillary Terrestrial Component, Kile No. SAT—MOD—20101118—00239 Dear Ms. Dortch: On January 19, 2011, representatives of the United States GPS Industry Council and several member companies held a teleconference with officials from the Commission‘s Office of Engineering and Technology, International Bureau, Public Safety and Homeland Security Bureau, and Wireless Telecommunications Bureau to discuss the results of empirical experimentation conducted by Garmin International ("Garmin") to assess the impact on GPS receivers operating in the 1559—1610 MHz band of fixed, high—power terrestrial broadband transmitters of the new, non—ancillary type LightSquared Subsidiary LLC ("LightSquared") first proposed in its above—referenced November 2010 application. The LightSquared application proceeding has been designated to have permit—but—disclose status for purposes of the Commission‘s ex parte rules. The participants (listed on Appendix 1 to this letter) discussed in detail the methodology, parameters, and findings presented in the Garmin report, entitled Experimental Evidence of Wide Area GPS Jamming That Will Resultfrom LightSquared‘s Proposal to Convert Portions ofL Band 1 to High Power Terrestrial Broadband, that is included as Appendix 2 to this letter. 2000 K STREET NW. SUITE 600 | WasHINGTON, DC 20006—1809 TEL 202.429.8970 | FAx 202.293.7783 | WWW.LERMANSENTERCOM

E.. c Marlene H. Dortch (; ] January 20, 2011 oi Page 2 By this letter, and in accordance with Section 1.1206 of the Commission‘s Rules, 47 C.F.R. § 1.1206, two copies this letter and its Appendices are provided for inclusion in the Commission‘s files. Please direct any questions to me. Respectfully submitted, Counsel for the United States GPS In ustry Council Enclosures co: (w/Enclosures): List of Persons in Appendix 1 (by e—mail)

APPENDIX 1 LIST OF PARTICIPANTS IN JANUARY 19, 2011 TELECONFERENCE FCC PARTICIPANTS: U.S. GPS Industry Council Participants Office of Engineering and Technology: U.S. GPS Industry Council: Julius Knapp, Chief F. Michael Swiek, Executive Director Ronald Repasi A.J. von Dierendonck Michael Ha Stephen D. Baruch (Lerman Senter PLLC) Mark Settle Robert Weller Garmin International: International Bureau Andrew Etkind Scott Burgett Robert Nelson Bronson Hokuf Sankar Persaud Doug Kealy Brian Poindexter Public Safety and Homeland Security Van Ruggles Bureau: Micheal C. Simmons M. Anne Swanson (Dow Lohnes PLLC]) Pat Amodio Trimble Navigation, Ltd.: Wireless Telecommunications Bureau: Ann Ciganer Paul Murray Bruce Peetz Tom Peters Russell Fox (Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.]

APPENDIX

Experimental Evidence of Wide Area GPS Jamming That Will Result from LightSquared‘s Proposal to Convert Portions of L Band 1 to High Power Terrestrial Broadband January 16, 2011 Scott Burgett, Bronson Hokuf Garmin International, Olathe, Kansas Executive Summary On November 18, 2010 LightSquared Subsidiary LLC filed an application requesting modification of its authority for Ancillary Terrestrial Component (FCC File No. SAT—MOD—20101118—00239) of L Band 1 MSS (Mobile Satellite Service}. This application proposes to fundamentally change the usage of the L Band 1 spectrum {(1525 MHz— 1559 MHz) from MSS (very low power, space to earth signals) to fixed, high power, terrestrial broadband service. The L Band 1 is adjacent to the GPS band (1559 MHz — 1610 MHz) where the GPS and other satellite based radio navigation systems operate. If this modification is approved, widespread, severe GPS jamming will occur. in careful, experimental testing at Garmin using the technical details {power, frequency, modulation bandwidth) of the proposed LightSquared system, two common state—of—the—art Garmin GPS receivers experienced significant jamming within a radius of several miles from a simulated LightSquared transmitter. The niivi 265W, a very common portable consumer automotive navigation device, began to be jammed at a power level that represents a distance of 3.6 miles {5.8 kilometers) from the transmitter. The nuvi 265W lost a fix at a distance of 0.66 miles (1.1 kilometers) from the transmitter. A GNS 430W, a common FAA certified General Aviation receiver that supports the FAA‘s NextGen RNAV and RNP operations, began to be jammed at a distance of 13.8 miles {22.1 kilometers) from the LightSquared transmitter. Total loss of fix occurred at a distance of 5.6 miles (9.0 kilometers) from the LightSquared transmitter. This GPS receiver is certified for LPV (Localizer Performance with Vertical guidance} approach operations to 200 feet decision height, yet will be completely fammed by LightSquared transmitters over 5.6 miles (9.0 kilometers) away. Further, due to the special FAA requirements that this receiver is designed to meet, it takes on the order of 90 seconds to regain a fix once lost. Background As discussed in the Executive Summary, LightSquared wants to fundamentally change the nature of L band 1 (1525 MHz— 1559 MHz) from a mobile, space to earth band containing very weak signals to a very noisy terrestrial broadband band full of extremely powerful signals. This will have a severe impact on the adjacent GPS band (1559 MHz — 1610 MHz) where GPS and other satellite navigation and 1

augmentation systems operate (Glonass, Galileo, WAAS, etc). LightSquared‘s published plans (ref LightSquared Letter to Marlene Dortch, November 18, 2010) entail the installation of up to 40,000 high power transmitters. These transmitters are authorized for up to 42 dBW {over 15,000 watts). The operation of so many high powered transmitters so close in frequency to the GPS operating frequency (1575.42 MHz) will create a disastrous interference problem for GPS receiver operation to the point where GPS receivers will cease to operate (complete loss of fix) when in the vicinity of these transmitters. Garmin products represent over 90% of the installed navigation equipment in the General Aviation segment in the United States. Garmin also represents over 50% of the portable consumer automotive and handheld GPS devices sold in the United States. When faced with this potentially catastrophic interference threat, Garmin set out to quantify the jamming threat by carefully simulating the jamming scenario in the lab using high fidelity simulation equipment. Garmin tested two of our most popular devices. From the consumer automotive segment, testing was performed using a niuvi 265W, which is a popular member of a best—selling family of consumer automotive navigation devices. From the aviation segment, testing was performed using a GNS 430W, a receiver designed to meet the FAA TSO—C146a minimum performance specifications and which presently supports FAA‘s NextGen RNAV and RNP operations and is expected to be approved as a position source for FAA‘s NextGen ADS—B Out mandate. DOue to the accelerated schedule with which the FCC is processing LightSquared‘s request for waiver, only these two devices were tested in the interest of time. These devices are very representative of the installed user base of Garmin products in the United States. Experimental Setup The goal of these experiments was to use Garmin‘s engineering test lab to faithfully replicate the real— world scenario of LightSquared‘s proposed transmissions in the MSS band adjacent to GPS signals in the RNSS band. in general, care was taken to err in LightSquared‘s favor whenever assumptions were made about its transmissions. For example, Order and Authorization (SAT—MOD—20090429—00047, et. al.) released March 265, 2010 authorizes transmissions of 42 dBW EIRP (15.85 kW) with power allowed all the way to the band edge of 1559 MHz (paragraph 46); however, this test setup was based on LightSquared‘s verbal guidance {conference call between LightSquared and the USGPSIC (US GPS Industry Councif), December 17", 2010) that they would not transmit in excess of 32 dBW EIRP at 1555 MHz. Furthermore, the simulated GPS scenario used was comprised of strong signals and a stationary DUT (device under test) {no dynamics, fading, etc.}.

LightSquared Transmitter Setup Table 1 shows the constraints that were used to replicate LightSquared‘s transmissions in the MSS band. These were based on information that LightSquared provided to the USGPSIC on December 17, 2010. Once again, it is important to note that the upper band edge used for this experiment is only 1555 MHz, not 1559 MHz, which is the upper band edge of L Band 1 and would represent the worst case interference scenario. TX Power (P3y) 62 dBm Center Frequency 1552.5 MHz Modulation aPSK Bandwidth 5 MHz Transmit Antenna . 0 dBi Gain (GAT) Table 1: LightSquared Transmitter Specifications In order to calculate the power incident upon one of the millions of deployed GPS navigation devices in the field at a given distance from the transmit tower, standard link budget and path loss equations for free space propagation were used. The power incident on the DUT (Ppyz) is equal to the transmit power {P1x) plus the transmit antenna gain (Ga;) plus the path loss (Gp,, a negative quantity). Pour = Prx + Gar + Gpr Likewise, the free space path loss with respect to distance d and wavelength A {in meters) is given by: 4nd GPL == —20Log (T) The resultant Ppy; is shown with respect to distance in Figure 1.

Poy; Versus Distance from Transmitter 0.0 —10.0 — —20.0 & io f“."_; ~30.0 s iz m3 —40.0 h% 1. S —50.0 Thmmeeks_ —60.0 100 1000 10000 Distance from Transmitter {m) Figure 1: Poy; Versus Distance from Transmitter Experimental Setup in the Anechoic Chamber As stated earlier, the goal of these tests was to emulate LightSquared‘s transmitter in a controlled laboratory environment. Consequently, the test setup was designed to allow the DUT to experience the same power levels seen in Figure 1 while simultaneously receiving ideal simulated GPS signals. An RF shielded room / anechoic chamber was used to create a test environment free from reflections and outside interference. in addition, calibrated antennas and state of the art test equipment were used to create the best possible test with the information available to date. LightSquared Transmitter Simulation Setup LightSquared‘s signal was simulated according to the parameters described above in Table 1 using a Rhode and Schwartz SMIQ—O35 signal generator with digital modulation. This signal was then amplified with an Amplifier Research linear SW amplifier (Model #551G4) to achieve the signal strengths needed to run the test, The output of the amplifier was padded by 10 dB and then run through a notch filter centered at 1575.42 MHz to reject any in—band spurious emissions from the RF signal generator. A detailed list of test equipment is available upon request. An Agilent NS020A spectrum analyzer was used to measure the coutput power (P1y) of the LightSquared Transmitter Simulator as illustrated in Figure 2.

Light Squared Transmitter Simulator Agilent N9020A RE&ssmia—03s AmplifierResearch 10d8 GPSNatch cable loss =0.5dB Signal Analyzer Pad Filter Figure 2: Transmitter Simulator Setup Next, the output of the transmitter simulator was connected to a vertically polarized transmitting antenna located inside an RF anechoic chamber at exactly 3 meters from the DUT, as iflustrated in Figure 3. RF AnecholcChamber . d > 3 meter GPS Simulstor \/ d= 3 meters | Light Squared Transmitter Simulator (Prd — Figure 3: RF Anechoic Chamber Test Setup Hence, the power incident upon the DUT (Ppyr] was controlled according to the following equation. Poutr = Prx + Geasir + Gar + Gp1(3m) The free space path loss at 3 meters follows the path loss equation stated earlier such that Gp; (3m) = —45.8dB. Furthermore the Cable Loss (Gcame) was measured with a Network Analyzer as Geagps = —2.56dB at 1552.5 MHz. Finally, the vertically polarized test antenna had a gain of G4; = 6.8dBi at 1550 MHz. These numbers were used to calculate the power incident upon the DUT and then a simulated path 10SS (GpLsimulatea) was derived based on a LightSquared‘s stated transmit power of 62d8m {32dBW) and assumed antenna gain of 0dBi. This simulated path loss was then used to calculate the simulated distance from the LightSquared transmitter by the following equation. A _(GPL-Simulated) d = —10 20 41t

The test results shown henceforth throughout this document are based upon this setup. The actual jJamming levels were measured during the experiment and then used to calculate the apparent distance from LightSquared‘s transmitter. GPS simulation setup The GPS signals were simulated by a Spirent GSS 6560 GPS Simulator. A stationary scenario at location N39.0000 and W95.0000 was used. The GPS constellation simulated contained 31 GPS satellites, which is the number of GPS satellites currently active. The time was set to the current wall clock time and was allowed to run freely over the duration of the test to facilitate the acquisition of GPS signals by the devices under test. An external LNA (Mini—Circuits PN Z2HL—1217HLN) was used in series with a right—hand circularly polarized (RHCP) conical antenna in an RF anechoic chamber. The output signal of the Spirent was adjusted so that each DUT reported a signal strength of approximately 40 dB—Hz C/No. This scenario is considered to be rather benign in that there is no acceleration or signal obscuration being simulated. A reported signal strength of 40 dB—Hz is considered to be a strong signal. Units Tested Due to the accelerated nature with which the FCC is considering LightSquared‘s request for modification of its ATC authorization, there was not an abundance of time with which to test. In the interest of time, Garmin selected two common units, a nlvi 265W and a GNS 430W—— one from the Consumer Automotive business segment and one from the Certified Aviation segment. The nivi 265W is representative of Garmin‘s family of PNDs (Portable Navigation Devices). Tens of millions of devices similar to the nlivi 265W have been sold in the past few years in North America. It is also representative of the technology used by other manufactures of PND‘s, SmartPhones, and other portable GPS units. It is designed using a state of the art antenna, preselect filter, LNA, post—LNA filter and GPS demodulator. It is a high sensitivity, multi—channel design. The GNS 430W is one of a number of FAA—certified navigation devices produced by Garmin that utilize a common GPS/SBAS receiver designed to meet the FAA TSO—C146a and TSO—C145a minimum performance specifications documented in RTCA DO—229C. As of December 31, 2010, Garmin has produced and shipped 57,812 FAA—certified products that utilize this GPS/SBAS receiver design. These products are installed in an estimated 43,321 aircraft worldwide. Garmin estimates that 70% of these products and aircraft are in the United States.

Test Results Ndvi 265W Jamming Table 2 describes the effect of jamming on the n{ivi 265W. "Jamming is Detected" refers to the point at which the receiver experiences 1 dB of de—sensitization. "Loss of Fix in the Urban Canyon" refers to the point at which the receiver experiences 10 dB of de—sensitization. In Garmin‘s judgment, this much loss of signal in a challenging urban canyon environment would typically result in a loss of GPS service. "Loss of Fix in the Open Sky" refers to the point at which the GPS receiver lost its fix completely. Jamming is detected 3.57 miles (5756 meters } Loss of Service in the Urban Canyon 1.79 miles (2884 meters } Loss of Fix in the Open Sky .56 miles (1059 meters} Table 2: niivi 265W Results GNS 430W Jamming Table 3 describes the effect of jamming on the GNS 430W. "Jamming is Detected" refers to the point at which the receiver experiences 1 dB of de—sensitization. "10 dB Loss of Sensitivity" refers to the point at which the receiver experiences 10 dB of de—sensitization. "Loss of Fix in the Open Sky" refers to the point at which the GPS receiver lost its fix completely. Jamming is detected 13.76 miles {22137 meters ) 10 dB Loss of Sensitivity 9.85 miles {(15853 meters) Loss of Fix in Open Sky 5.60 miles {9018 meters } Table 3: GNS 430W Results

Conclusion As shown by the Garmin testing described in this document, the proposed LightSquared plan to add 40,000 high—powered transmitters in the band adjacent to GPS will result in widespread, severe GPS jamming. This will deny GPS service over vast areas of the United States.

Data Shows Disastrous GPS Jamming from FCC—Approved Broadcaster | GPS World Page 1 of 2 E The Business and Technology of Slobal Ravigation and Positioning GNSS System D\’a’;' Shows Disastrous GPS Jamming from FCC—Approved Broadcaster 14, 2011 —power irans mio broadcast i tiook into our ben ast pr xperimental Evidence of Wide s Area GPS J autemotive navig ice and on a co it n 9Cever ) fromthe simu ed transmitte er device lost Jomming detected 3.97 miles (§756 maters } Loss of Service in the Urban Canyon 1.79 mifes (2884 meters ] Loss ofFix in the Open Sky . O.6§ miles {1059 moters} Table 2: niivi 2ISSW Results distence of 1 Jamming is detected 14.76 miles (22137 maters} 10 dB Loss: of Seesitivity ©.85 miles {15853 meters} Lossof Fix in Oper: 5.60 miles {1018 meters } Table 3: Results nited pas "GPS AND OTHER INTERFERENCE CONCERNS A. GPS—Relatedinterferance Concems http://www.gpsworld.com/gnss—system/news/data—shows—disastrous—gps—jamming—fec—approved—bro... 2/7/2011

Data Shows Disastrous GPS Jamming from FCC—Approved Broadcaster | GPS World Page 2 of 2 ol to exc rady to work v nSquar rgarding GPS and, fur mmences of .Band MSSft ssion, NTIA and es, and the GPS communily to I y the GPS : sends a For fu . see GPS Communi Urged to Contact {8] Bootmark in digg .' del.icio.us yahoo @:’2‘ facebook Add Comment Take the | http://www.gpsworld.com/gnss—system/news/data—shows—disastrous—gps—jamming—fec—approved—bro... 2/7/2011

GNSS Community Feels New Telecom Interference Threat from LightSquared | Inside G... Page 1 of 4 GIONAL/AYVGMENTATION— #4 i _ Home GNS News lndus gazrine Aubscriptic Advertise SEARCH WEERTE INSIDE GNSS NEWS GNSS Community Feels New Telecom Interference Threat from LightSquared Latest News Share via: Tectnorati ary Twitter MiSFacebook In his State of the Union address on January 25, President Obama held up the Global Positioning System as a prime example of government providing "cutting—edge scientists and inventors with the support that they need" to create world—leading, job— creating innovation. The following day, the Federal Communications Commission (FCC) unanimously approved a conditional waiver allowing LightSquared Subsidiary LLC to build tens of thousands ofterrestrial transmitters for wireless communications in frequencies on either side of the GPS L1 band. Reportedly, the transmitters are authorized to operate at 42 dBW (15 kilowatts) of power. In a response similar to that of the ultrawideband controversy nearly 10 years ago, the GNSS community has expressed dire concern that, if implemented, the Lightsquared initiative could cause serious problems for millions of users in the United States. Letters to the FCC calling for a more substantive technical evaluation before allowing LightSquared to proceed came from the U.S. GPS Industry Council (USGIC) and the National Telecommunication & Information Administration (NTIA), a U.S. Department of Commerce agency that serves as the President‘s principal adviser on telecommunications and information policy. The Air Force has asked the Aerospace Corporation, a federally funded research and development organization that works closely with the GPS Directorate, to assess whether the LightSquared plan would create problems for GPS receivers. INSISEGNSS Of & & Al prion A December 23 USGIC issue paper characterized the LightSquared proposal as "a radical Browse or download: change in the spectrum environmentfor GPS" that "has the strong potential to cause Novemberiiecember 2018 interference. .. ." Digital Edifion Archive In a January 16 report, GARMIN International described a recent test evaluating the effects of proposed LightSquared broadcasts on two of its most popular receivers: a GNS 430W FAA— certified general aviation receiver and a niivi 265W portable navigation device. Both lost open i —sky positioning capability at a distance 5.6 to 0.66 miles, respectively. Media Kit (pdf) Current Issue http://www.insidegnss.com/node/2471 1/31/2011

< GNSS Community Feels New Telecom Interference Threat from LightSquared | Inside G... Page 2 of 4 Contact Past Issues The company‘s conclusion: "If this [FCC—LightSquared] modification is approved, Subscontions GNSS Industry widespread, severe GPS jamming will occur." Subscription Services Events Technically, the FCC action grants LightSquared a waiver to its ancillary terrestrial Free Subscription New Products component (ATC) "integrated service" rule, which requires mobile satellite services (MSS) Change Industry News that have a ground transmission infrastructure to provide only combined satellite/terrestrial Questions Columns & Edkorials user equipment. Cancel GNSS Hotspots According to the FCC order, "Although LightSquared does not, itself, intend to offer ATC—only E—newsletter subscription GNSS Solutions subscriptions to its wholesale customers, it contemplates thatits customers may well offer C« y Informat: GNSS World ATC—only subscriptions to consumers." About Us Human Engineering Contact Us Thinking Aloud In effect, LightSquared‘s application "proposes to fundamentally change the usage of the L Band 1 spectrum (1525 MHz—1559 Mhz) from MSS (very low power, space to earth signals) to Staff Profiles Working Papers fixed, high power terrestrial broadband service," Garmin argued. Contributing Editors Contributing Writers Digital Edition LightSquared is working to gain access to 20 megahertz or more of L—band spectrum Editorial Advisory Council SIGNALS newsletter allocation, including a $ $337.5 million purchase from Inmarsat. With that resource, it would offer the first—ever wholesale nationwide 4G—LTE wireless broadband network integrated with ftogs E—Library satellite coverage for its customers to offer terrestrial—only, satellite—only, or integrated Director‘s Cut—Glen Gibbons Web Seminars satellite—terrestrial services to end users. The FCC ruling does acknowledge "the need to address the potentialinterference concerns regarding GPS," and requires "As a condition of granting this waiver, the [interference review] process . . . must be completed to the Commission‘s satisfaction before LightSquared commences offering commercial service pursuantto this waiver on its L—band MSS Download NovAtel SPAN®* frequencies." Astlal Photogrammetry white paper However, the ruling also requires LightSquared to begin implementing its system and assuring the availability of user equipment within a matter of months. Moreover, concern exists among that the solution to any interference problem could be placed on the backs of GNSS receiver manufacturers who would need to incorporate expensive design changes in for Free user equipment. LightSquared told the FCC that it is investing more than $50 million to underwrite the costs of developing a Qualcomm dual—mode chipset, related components, and an associated satellite ground station infrastructure. In a January 21 filing with the FCC, Qualcommy,a large—scale manufacturer of integrated GPS and wireless communications chips, described how it has protected its assisted—GPS (AGPS) solution against self—interference from the phone‘s cellular uplink transmitter at 1710 MHz, 135 megahertz away from the GPS L1 band. The company admitted that it didn‘t know if the receiver filter it used to prevent the uplink interference would also serve for an L—band downlink. "Qualcomm is now in the process of evaluating the extentof interference from LightSquared L Band LTE base stations (%.e., downlink) into the GPS receivers of cell phones using Qualcomm‘s AGPS solution, particularly legacy phones already in the market today, given the close proximity of the L and GPS L1 bands," wrote Dean R. Brenner, Qualcomm‘s vice— presidentfor governmentaffairs. Moving Quickly Backed by billions of dollars from principal investor Harbinger Capital Partners, LightSquared — which was only formed last July — is on the fast track to implementingits MSS system. The company has assembled a cast of luminaries from the wireless telecom community, including Chairman and CEO Sanjiv Ahuja, former CEO of UK wireless giant, Orange; Chief Marketing Officer, Frank Boulben, formerlyn global director of commercial strategy for the Vodafone Group; and Chief Network Officer Douglas Smith, who left a position as senior vice— president, engineering and operations, for Clearwire, a nationwide mobile broadband WiMAX network with majority ownership by Sprint. In September 2010, LightSquared disclosed an eight—year, $7—billion agreementfor Nokia Siemens Networks to deploy, install, operate and maintain the LightSquared nationwide network. The company‘seffort is aided by Goldberg Godles Wiener & Wright, a Washington, D.C.— based telecommunications law firm whose senior policy advisoris Thomas Tycz, who joined the firm in 2005 from his position as head of the ECC International Bureau‘s Satellite Division. Tycz‘s experience at the FCC presumably would have aided LightSquared in moving its waiver request — which coincided with the busy Thanksgiving/Christmas holiday season —— quickly through the agency‘s procedural channels. Ironically, given Obama‘s State of the Union shout—out for GPS, the LightSquared situation is driven in part by the president‘s own initiative, Unleashing the Wireless Broadband Revolution,issued in June 2010. In it, Obama committed to make available 500 megahertz of Federal and nonfederal spectrum over the next 10 years. http://www.insidegnss.com/node/2471 1/31/2011

*GNSS Community Feels New Telecom Interference Threat from LightSquared | Inside G... Page 3 of 4 The Garmin Tests The rapid emergence and evolution of the LightSquared initiative clearly caught the GNSS community off guard, and the accelerated FCC process has allowed little time for a technical evaluation ofits side effects before the fact. Consequently, the Garmin testing effort provides a key data point — especially considering that Garmin claims to have provided more than go percentof the current general aviation GPS receivers and 50 percentofthe automotive and handheld equipment now operating in the United States. Using a Spirent GSS6560 GPS simulator, a Rohde & Schwartz SMIQ—03$ signal generator, and an Agilent N9020A spectrum analyzer to measure output powerof the simulated LightSquared transmitter, Garmin engineers set up a test scenario with the receivers in an RF shielded, anechoic chamber to measure the likely real—world effects of the LightSquared terrestrial network. In their report, the Garmin engineers said they took care "to err in LightSquared‘s favor whenever assumptions were made aboutits transmissions." For example, although an FCC order allows a transmitter antenna to emit 42 dBW EIRP (effective isotropic radiated power) up to the 1559 MHz band bordering GPS L1, the test setup used a LightSquared "verbal guidance" that they would not transmit in excess of 32 dBW EIRP at 1555 megahertz. The simulated scenario also assumed GPS satellite signals (40 db—Hz carrier/noise ratio) and a stationary receiver, which would eliminate dynamiceffects, fading, and so forth. Under these conditions, the niivi receiver detected simulated LightSquared jamming at 3.57 miles and would have lost service in an urban canyon environmentif the transmitter was 1.79 miles away or closer, according to Garmin. For the aviation receiver, effects were even more marked: it detected the jamming at 13.76 miles and experienced a 10—decibel loss of sensitivity at 9.85 miles. FCC Conditions With its conditional waiver for LightSquared, the FCC is ostensibly taking its responsibility seriously to ensure non—interference with existing services. Agency staff will be directed to "work with NTIA, LightSquared, and the GPS community, including appropriate Federal agencies, to establish a working group to fully study the potentialfor overload interference to GPS devices and to identify any measures necessary to prevent harmful interference to GPS." In fact, the Institute of Navigation, which has long hosted the leading GNSS conferences, wrote to the agency on January 26, offering to help identify "technical experts who might best assist the FCC in evaluating risks and impacts of LightSquared‘s proposal." However, the phrasing in the conditions set by the FCC seems to suggest an assumption that LightSquared will be accommodated, directing that the working group provide "recommendations on steps that can be taken going forward to permit broadband witeless services to be provided in the L—Band MSS frequencies and coexist with GPS devices." Moreover, the burden of proof appears to rest on the GPS community. "Because the GPS interference concerns stem from LightSquared‘s transmissionsin its authorized spectrum rather than transmissions in the GPS band," the FCC order reads, "the Commission expects full participation by the GPS industry in the working group and expects the GPS industry to work expeditiously and in good faith with LightSquared to ameliorate the interference concerns." In addition, LightSquared is charged with preparing the information for the agency; no other organization or group And the compressed timeline for dealing with the issue continues: An initial report and workplan by February 25 and a final report by June 15, 2011, "thatincludes the working group‘s analyses of the potential for overload interference to GPS devices from LightSquared‘s terrestrial network of base stations, technical and operational steps to avoid such interference, | and specific recommendations going forward to mitigate potential interference to GPS devices." Copyright © 2011 Gibbons Media & Research LLC, all rights reserved. http://www.insidegnss.com/node/2471 1/31/2011

* GNSS Community Feels New Telecom Interference Threat from LightSquared | Inside G... Page 4 of 4 %‘2 1574 Coburg Road No. 233 + Eugene, Oregon 97401—4802 + United States SAF. Telephone 408—216—7561 + Fax 408—216—7525 Problems viewing this page? Contact our webmaster, http://www.insidegnss.com/node/2471 1/31/2011


Document Created: 2019-04-22 14:36:41
Document Modified: 2019-04-22 14:36:41
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC