Attachment StopInterference.pdf

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

IBFS_SATMOD2010111800239_915719

151 Black Bear Ln
State College, PA 16803

August 26, 2011

Federal Communication Commission
Washington, DC


Dear Mr. Chairman:

As a working member of the Land Surveying profession, and as a licensed amateur radio
operator, I have grave concerns with regard to recent actions taken by the commission
regarding potential interference to radio spectrum allocations that have been and continue
to be used by weak signal space based systems, namely Global Navigation Satellite
Systems, GNSS.

The FCC must make clear, and the NTIA must ensure, that LightSquared's license
modification is contingent on the outcome of the mandated study unequivocally
demonstrating that there is no interference to GPS. The study must be comprehensive,
objective, and based on correct assumptions about existing GPS uses rather than
theoretical possibilities. Given the substantial pre-existing investment in GPS systems
and infrastructure, and the critical nature of GPS applications, the results of studies must
conclusively demonstrate that there is no risk of interference. If there is conflicting
evidence, doubts must be resolved against the LightSquared terrestrial system. The views
of LightSquared, as an interested party, are entitled to no special weight in this process.

The FCC should make clear that LightSquared and its investors are proceeding at their
own risk in advance of the FCC's assessment of the working group's analysis. While this
is the FCC's established policy, the Commission's International Bureau failed to make
this explicit in its order.

Resolution of interference has to be the obligation of LightSquared, not the extensive
GPS user community of millions of citizens. LightSquared must bear the costs of
preventing interference emanating from their devices, and if there is no way to prevent
interference, it should not be permitted to operate. GPS users or providers should not
have to bear any of the consequences of LightSquared's actions.

Thank you for your prompt and diligent attention to this matter.

Sincerely,


Robert P Stenerson, SIT
KR3ORY





Document Created: 2011-08-26 12:24:09
Document Modified: 2011-08-26 12:24:09

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