Attachment LightSquared - DeBoe

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

IBFS_SATMOD2010111800239_932084

Oofcers # . Received & %fispef’:"‘f-‘ ~Chapter Representatives Mafk W. Powell, P.S. i David L. Clifford, P.S. President Msps ‘ JUN * 7 20“ John F(.;%‘Itxri?lle, P.S. Patrick G. Bentley, P.S. Mid—Michigan First Vice President MB W ECC Mail RGOM cartKiiskila, P.sS. Northeast Timothy A Platz, P.S. Bill Sikkema, P.S. Second Vice President Northern MICHIGAN SOCIETY OF PROFESSIONAL SURVEYORS Mark L. Vah Raemdonck, P.S. James E. Evans, P.S. Saginaw Valley Secretary 220 South Museum Drive Kelly M. Fedele, P.S., P.E. Lansing, Michigan 48933—1905 Southeast Zachary J. Stevens, P.S. Brian Reynolds, P.S. Treasurer (517) 484—2413 Southwestern FAX (517) 484—3711 Zachary J. Stevens, P.S. Paul N. Brown, P.S. E—Mail: centraloffice@misps.org Upper Peninsula Past President Web Address: www.misps.org Paul J. Privacky, P.S. West Central Directors 5 Ronald C. Brand, P.S. Julie R. DeBoer Ex Officio Brian K. Fullford, P.S. Executive Director Craig P. Amey, P.S. Karol L. Grove, P.S. NSPS Governor James Hollandsworth, P.S., P.E. mw \ l_l O Timothy L. Lapham, P.S., P.E. Patrick N. Johnson, P.S. NCEES POLC Representative Christopher L. Lester, P.S. $2358 SAT—MOD—20101118—00239 1B2010003539 LightSquared Subsidiary LLC June 2, 2011 The Honorable Julius Genachowski Chairman Federal Communications Commission 445 12"" Street, SW Washington, D.C. 20554 Dear Mr. Chairman: l am writing on behalf of the board and membership of the Michigan Society of Professional Surveyors 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, including surveyors in Michigan. Unfortunately, the FCC has recklessly fast— tracked the waiver process without undertaking appropriate transparent procedures. The Commission has called on a working group to investigate and report on the potential for GPS interference by June 15. Accordingly, we request that the Commission only approve LightSquared‘s waiver if it 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, Affiliate of the American Congress on Surveying and Mapping, National Society of Professional Surveyors, and the National Council of Examiners for Engineers and Surveyors

LETTER PAGE 2 Genachowski aviation, agricultural producers, cellular telecommunications companies, homeland security, transportation, forestry, engineering and construction, land management, surveyors, disaster management, natural resources, utilities, and individual consumers who rely on GPS for everyday needs. General William Shelton, the head of the 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 jJammed 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 physics 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 spectrum prior to issuing the conditional waiver. Such an approach would have allowed for significant public comment by all stake holders. 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 issuance of the 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 on this 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 thank you for your time and consideration of this matter of importance to the over 900 Professional Licensed Surveyors in the State of Michigan. Sincerely, t &4}\ é%lie DeBoe% Executive Director Co: Senator Carl Levin Representative Dale Kildee Senator Debbie Stabenow Representative Sander Levin Representative Justin Amash Representative Thaddeus McGotter Representative Dan Benishek Representative Candice Miller Representative Dave Camp Representative Gary Peters Representative Hansen Clarke Representative Mike Rogers Representative John Conyers, Jr. Representative Fred Upton Representative John Dingel! Representative Tim Walberg Representative Bill Huizenga Affiliate of the American Congress on Surveying and Mapping, National Society of Professional Surveyors, and the National Council of Examiners for Engineers and Surveyors


Document Created: 2012-01-03 15:47:00
Document Modified: 2012-01-03 15:47:00
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