Attachment LightSquared Ex Part

This document pretains to SAT-MOD-20120928-00160 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012092800160_1101052

Via Electronic Filing                                              August 18, 2015

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554


       Re:     IB Docket No. 12-340; IBFS File Nos. SAT-MOD-
               20101118-00239; SAT-MOD-20120928-00160; SAT-MOD-
               20120928-00161; SES-MOD-20121001-00872

Dear Ms. Dortch:

        LightSquared is filing this letter in response to an August 14, 2015, letter from the GPS
Innovation Alliance (GPSIA) regarding testing of GPS devices being conducted by
Roberson & Associates (Roberson). GPSIA has now made clear that despite ample opportunity
to do so, it does not wish to provide useful input or help to the Roberson testing. While input
from GPSIA and its members was solicited in the spirit of openness and transparency, Roberson
is proceeding with testing devices that are most representative of each category of GPS devices,
and thus the most significant portions of the market for such devices, as planned.

        LightSquared hopes that the Department of Transportation’s testing if done right can
contribute to the understanding that will be promoted by the Roberson study. We would note,
however, as GPSIA does, that the initial DOT testing plan was released in December 2012, and
so far not a single device has yet been tested, nor has any end date of testing been identified.
The Roberson testing needs to proceed in a timely way in order to provide relevant input into
the Commission’s process, and will do so notwithstanding GPSIA’s failure to contribute.

        LightSquared would note that GPSIA’s characterization of the Roberson testing as using
standards “of questionable relevance” is wholly incorrect. GPSIA provides no specific criticisms
of any of the standards proposed by Roberson that would allow substantiation of such a claim.
For example, GPSIA does not explain how anyone would consider a measure such as position
error to be of “questionable relevance” to the performance of a GPS device, the primary purpose
of which is to report position to a user. GPSIA apparently prefers “internationally agreed”
standards, but provides no detail at all as to what standards it means. Assuming GPSIA is again
referring to a standard based on an increase in the noise floor, GPSIA fails to address the
detailed explanation already provided by the undersigned that this measurement is wholly


Marlene H. Dortch
August 18, 2015
Page 2


inappropriate as a measure of harmful interference and is not, in fact, used by any standards
body as a measure of harmful interference for bands adjacent to GPS.1

        LightSquared looks forward to the completion of the Roberson testing and the provision
of useful information to the Commission that shows how GPS and terrestrial broadband can
coexist.

                                                    Respectfully submitted,




                                                    Gerard J. Waldron
                                                    Counsel to LightSquared




1See Letter from Gerard J. Waldron to Marlene H. Dortch, Secretary, FCC, IB Docket No. 12-
340; IBFS File Nos. SAT-MOD-20101118-00239; SAT-MOD-20120928· 00160; SAT-MOD-
20120928-00161; SES-MOD-20121001- 00872 (filed July 2, 2015) at 5-6.



Document Created: 2019-04-14 17:44:01
Document Modified: 2019-04-14 17:44:01

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