Attachment Letter to Federal Co

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

IBFS_SATMOD2010111800239_900180

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 Ref:       AN 7/5 — CNS41541                                                                   13 June 2011



 Mr. Julius Genachowski
 Chairman
 Federal Communications Commission (FCC)
 445 12th Street, SW
 Washington, DC 20554
 United States


 Dear Mr. Genachowski,

               We are writing to you about an issue of grave concern to the international civil aviation
 community, in connection with Federal Communications Commission (FCC) Order and Authorization
 DA 11—133, adopted on 26 January 2011.

                          As you are aware, the Order granted LightSquared Subsidiary LLC a conditional waiver
 of FCC rules, enabling the company to use terrestrial—only devices in a band adjacent to that in which the
 global positioning system (GPS) operates.

                Subsequent to the Order being issued, studies have shown that LightSquared
 transmissions would have a dramatic impact on aviation GPS receivers. Specifically, the conclusion
 reached by an authoritative aviation industry body (RTCA, Inc.), after an exhaustive technical
 investigation, is that the proposed LightSquared operation would be incompatible with the current
 aviation use of GPS.

                          The safety and efficiency of aviation operations today are already, to a substantial extent,
 reliant on the invaluable position, navigation and timing service provided by GPS. Ongoing aviation
 developments, such as those being undertaken in the framework of United States NextGen programme
 and the European SESAR programme, will place even more emphasis on the central role of GPS and
 other satellite navigation systems in aviation operations.

                Therefore, the potential disruption to aviation use of GPS caused by the LightSquared
 system would have a far—reaching impact on current and future aviation operations. The impact would not
 only be limited to the United States. The international aircraft fleet flying into the United States would be
 directly affected and also similar developments could arise elsewhere and propagate the disruption
 beyond their borders.




  999 University Street     Tel.: +1 514—954—8219     E—mail: icaohq@icao.int
  Montréal, Quebec          Fax: +1 514—954—6077      www.icao.int
  Canada H3C 5H7


                                                    —2 .

               In September 2007, the United States Government reaffirmed its commitment to provide
the GPS Standard Positioning Service (SPS) for aviation throughout the world.

                This commitment, first expressed in 1994, was the foundation for the development of key
GPS aircraft navigation applications, based on ICAO international standards and procedures, which today
support safer and more efficient aviation operations worldwide.

               We urge you to ensure that this vital commitment is not unintentionally jeopardized by
the introduction of the LightSquared system and the ensuing impact on GPS use by aviation.


                                                               Yours sincerely,


                 >
                        Roberto Kobeh Gonzalez
                        President of the Council                SKretary General




ce:     Mr. Raymond H. LaHood
        United States Secretary of Transportation
        U.S. Department of Transportation

        Mr. J. Randolph Babbitt
        Administrator
        Federal Aviation Administration (FAA)

        Representative of the United States
         on the Council of ICAO



Document Created: 2011-06-28 15:02:33
Document Modified: 2011-06-28 15:02:33

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