Attachment OSD 03393-11.pdf

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

IBFS_SATMOD2010111800239_879503

                                                                                MAR 25 2011
Mr. Julius Genachowski
Chairman
Federal Communications Commission (FCC)
445 12"" Street SW
Washington, DC 20554

Dear Mr. Chairman:

The Department of Defense (DoD) and the Department of Transportation (DOT) recognize the
importance of implementing a thorough and equitable operational process for the LightSquared
Working Group (WG). In that regard, DoD and DOT have reviewed the Commission‘s
expectations for the LightSquared WG process as stated in the February 25, 2011, letter
(DA 11—367) to LightSquared, and have several concerns with its stipulations, which we believe
require your personal attention.

First, DoD and DOT were not sufficiently included in the development of the LightSquared initial
work plan and its key milestones. We are concerned with this lack of inclusiveness regarding input
from federal stakeholders. In particular, active engagement with DoD and DOT, the national
stewards and global providers of the Global Positioning Satellite (GPS) service, is essential to
protect this ubiquitous defense, transportation and economic utility as the WG process proceeds.

Second, the Commission‘s determination that consensus on the WG recommendations is not
required does not provide guidance regarding how differing technical viewpoints from federal and
private sector manufacturers and users will be reconciled. DoD and DOT need to understand how
differing conclusions and recommendations developed during the WG process that could affect
national security and transportation safety will be addressed.

Finally, DoD and DOT strongly advise that a comprehensive study of all the potential interference
to GPS is needed. The new LightSquared business plan and the new FCC rules significantly expand
the terrestrial transmission environment, increasing the potential for interference to GPS receivers.
An exchange ofall pertinent technical and operational information is also crucial to ensure the
effectiveness of interference mitigation solutions.

In light of these concerns, and the importance of GPS for civil, military, and commercial users, we
request clarification on these matters at your earliest opportunity.

                                              Sincerely,




                   ohh D. Porcari                              William J. Ly
               eputy Secretary of Transportation           Deputy Secretary of Defense


€C:
The Honorable Lawrence E. Strickling
 Assistant Secretary for National Telecommunications & Information
 Telecommunications & Information
 Administration, Department of Commerce



Document Created: 2011-03-29 17:15:21
Document Modified: 2011-03-29 17:15:21

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