Attachment LightSquared - B Wen

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

IBFS_SATMOD2010111800239_931566

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                            WENDELL‘S IRRIGATION
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                                                                Received & Inspecteq
     The Honorable Julius Genachowski                               JUN —
     Chairman                                                               6 20 11
     Federal Communications Commission                          FCC         f
     445 12"" Stroet, SW                                               Mail Room
     Washington, DC 20554

      Dear Mr. Chairman:

      We write to express concern about a conditional waiver that was granted by the International
      Bureau in January 2011 after an abbreviated public—notice process.

     The exclusive waiver, for a company named LightSquared Subsidiary LLC, would waive the
     integrated service rule for its L—Band Mobile Satellite Service license. As a result, LightSquared
     would be allowed to dramatically expand the terrestrial use of satellite spectrum that neighbors
     Global Positioning System (GPS) spectrum. This action has serious implications for all GPS
     technologies, and could negatively impact millions of Americans. Unfortunately, the FCC has
     recklessly fast—tracked the waiver processwithout undertaking appropriate transparent
     procedures, The Commission has called on a working group to investigate and report onthe
     potential for GPS interference by June 15. Accordingly, we request that the Commussion only
     approve LightSquared‘s waiver ifit can be indisputably proven that there will be no GPS
     interference.                                                                       :

     LightSquared intends to build 40,000 high—powered ground transmission stations, which would
     transmit radio signals one billion times more powerful than GPS signals. Since the intended
     spectrum usage is immediately adjacent to GPS spectrum, it could lead to severe interference
     that effectively renders the technology useless. Such interference would have devastating effects
     on the United States military, emergency responders, aviation, agricultural producers, cellular
     telecommunications companies, homeland security, transportation, forestry, engineering and
     construction, land management, disaster management, natural resources, utilities, and individual
     consumers who rely on GPS for everyday needs.

     General William Shelton, the head ofthe U.S. Air Force Space Command, recently said, "Within
     three to five miles on the ground and within twelve miles in the air, GPS is jammed by those
     towers. .. If we allow that system to be fielded and it does indeed jam GPS, think about the
     impact. We‘re hopeful we can find a solution, but physies being physics we don‘t see a solution
     right now. LightSquared has got to prove that they can operate with GPS and we‘re hoping the
      FCC does the right thing."

      With such significant potential consequences, the FCC should have conducted in—depth studies
     on the consequences of reallocating the spectrumprior to issuing the conditional waiver. Such

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                                                                         SAt— mop—20101118—00239
                                                            e
                                                            LightSqua red Subsidiary LLC


an approach would have allowed for significant public comment by all stakeholders.. Instead, the
FCC granted the waiver with the intention of subsequently testing the effects of repurposing the
spectrum. We are concerned that the brief study period arranged by the FCC following the
issuance ofthe conditional waiver does not allow for nearly the consideration necessary for such
a far—reaching decision.

Final approval should only be granted if LightSquared can indisputably demonstrate non—
interference on GPS usage. We urge the full Commission to weigh in onthis matter and allow
for additional public comment moving forward. It is incumbent upon LightSquared to
unequivocally prove that the proposal will not interfere with GPS spectrum.

We look forward to your prompt response on this matter.


                                             Sincerely,

                                             bubua lilerfet

C€2:           The Honorable Robert Gates, Secretary, Department of Defense
               The Honorable Janet Napolitano, Secretary, Department of Homeland Security
               The Honorable Gary Locke, Secretary, Department of Commerce
               The Honorable Tom Vilsack, Secretary, Department of Agriculture
               The Honorable Ken Salazar, Secretary, Department of Interior
               The Honorable Ray LaHood, Secretary, Department of Transportation



Document Created: 2011-12-30 14:52:58
Document Modified: 2011-12-30 14:52:58

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