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IMPACTS OF THE LIGHTSQUARED NETWORK ON 

FEDERAL SCIENCE ACTIVITIES 

HEARING 

BEFORE THE

COMMITTEE ON SCIENCE, SPACE, AND 

TECHNOLOGY 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED TWELFTH CONGRESS 

FIRST SESSION 

THURSDAY, SEPTEMBER 8, 2011 

Serial No. 112–33 

Printed for the use of the Committee on Science, Space, and Technology 

( 

Available via the World Wide Web: http://science.house.gov 
(II) 

COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY 

HON. RALPH M. HALL, Texas, Chair 

F. JAMES SENSENBRENNER, JR., 

Wisconsin 

LAMAR S. SMITH, Texas 

DANA ROHRABACHER, California 

ROSCOE G. BARTLETT, Maryland 

FRANK D. LUCAS, Oklahoma 

JUDY BIGGERT, Illinois 

W. TODD AKIN, Missouri 

RANDY NEUGEBAUER, Texas 

MICHAEL T. MCCAUL, Texas 

PAUL C. BROUN, Georgia 

SANDY ADAMS, Florida 

BENJAMIN QUAYLE, Arizona 

CHARLES J. ‘‘CHUCK’’ FLEISCHMANN, 

Tennessee 

E. SCOTT RIGELL, Virginia 

STEVEN M. PALAZZO, Mississippi 

MO BROOKS, Alabama 

ANDY HARRIS, Maryland 

RANDY HULTGREN, Illinois 

CHIP CRAVAACK, Minnesota 

LARRY BUCSHON, Indiana 

DAN BENISHEK, Michigan 

VACANCY 

EDDIE BERNICE JOHNSON, Texas 

JERRY F. COSTELLO, Illinois 

LYNN C. WOOLSEY, California 

ZOE LOFGREN, California 

BRAD MILLER, North Carolina 

DANIEL LIPINSKI, Illinois 

GABRIELLE GIFFORDS, Arizona 

DONNA F. EDWARDS, Maryland 

MARCIA L. FUDGE, Ohio 

BEN R. LUJA ́ N, New Mexico 

PAUL D. TONKO, New York 

JERRY MCNERNEY, California 

JOHN P. SARBANES, Maryland 

TERRI A. SEWELL, Alabama 

FREDERICA S. WILSON, Florida 

HANSEN CLARKE, Michigan 

VACANCY 
(III) 

C O N T E N T S 

Thursday, September 8, 2011 

Page 

Witness List ............................................................................................................. 2 

Hearing Charter ...................................................................................................... 3 

Opening Statements 

Statement by Representative Ralph M. Hall, Chairman, Committee on 

Science, Space, and Technology, U.S. House of Representatives ..................... 12 

Written Statement ............................................................................................ 13 

Statement by Representative Eddie Bernice Johnson, Ranking Minority Member, Committee on Science, Space, and Technology, U.S. House of Representatives ........................................................................................................... 14 

Written Statement ............................................................................................ 15 

Witnesses: 

Mr. Anthony Russo, Director, the National Coordination Office for SpaceBased Positioning, Navigation, and Timing 

Oral Statement ................................................................................................. 17 

Written Statement ............................................................................................ 19 

Ms. Mary Glackin, Deputy Under Secretary, National Oceanic and Atmospheric Administration 

Oral Statement ................................................................................................. 29 

Written Statement ............................................................................................ 30 

Mr. Victor Sparrow, Director, Spectrum Policy, Space Communications and 

Navigation, Space Operations Mission Directorate, National Aeronautics 

and Space Administration 

Oral Statement ................................................................................................. 34 

Written Statement ............................................................................................ 36 

Hon. Peter H. Appel, Administrator, Research and Innovative Technology 

Administration, Department of Transportation 

Oral Statement ................................................................................................. 39 

Written Statement ............................................................................................ 40 

Dr. David Applegate, Associate Director, Natural Hazards, U.S. Geological 

Survey 

Oral Statement ................................................................................................. 43 

Written Statement ............................................................................................ 44 

Mr. Jeffrey J. Carlisle, Executive Vice President, Regulatory Affairs and 

Public Policy, LightSquared 

Oral Statement ................................................................................................. 46 

Written Statement ............................................................................................ 48 

Dr. Scott Pace, Director, Space Policy Institute, George Washington University 

Oral Statement ................................................................................................. 75 

Written Statement ............................................................................................ 77 

Discussion ................................................................................................................. 88 
Page

IV 

Appendix 1: Answers to Post-Hearing Questions 

Mr. Anthony Russo, Director, the National Coordination Office for SpaceBased Positioning, Navigation, and Timing ....................................................... 106 

Ms. Mary Glackin, Deputy Under Secretary, National Oceanic and Atmospheric Administration .......................................................................................... 115 

Mr. Victor Sparrow, Director, Spectrum Policy, Space Communications and 

Navigation, Space Operations Mission Directorate, National Aeronautics 

and Space Administration ................................................................................... 132 

Hon. Peter H. Appel, Administrator, Research and Innovative Technology 

Administration, Department of Transportation ................................................ 141 

Dr. David Applegate, Associate Director, Natural Hazards, U.S. Geological 

Survey ................................................................................................................... 147 

Mr. Jeffrey J. Carlisle, Executive Vice President, Regulatory Affairs and 

Public Policy, LightSquared ................................................................................ 151 

Dr. Scott Pace, Director, Space Policy Institute, George Washington University ......................................................................................................................... 164 

Appendix 2: Additional Material for the Record 

Prepared Statement of Mr. Randy Neugebauer, U.S. House Committee on 

Science, Space, and Technology .......................................................................... 172 

Letter from Members of Congress to Hon. Julius Genachowski, Chairman, 

Federal Communications Commission, Washington, DC ................................. 173 

Response to Hon. Randy Neugebauer from Hon. Julius Genachowski, Chairman, Federal Communications Commission, Washington, DC ........................ 178 

Written Statement of the Coalition to Save Our GPS, Presented to the House 

Committee on Science, Space, and Technology .................................................. 179 

Letter to Hon. Ralph M. Hall, Chairman, U.S. House Committee on Science, 

Space, and Technology from Mr. Malcolm D. Jackson, Assistant Administrator and Chief Information Officer, U.S. Environmental Protection Agency ........................................................................................................................... 196 

Letter to Hon. Ralph M. Hall, Chairman, U.S. House Committee on Science, 

Space, and Technology from Mr. Michael W. Locatis III, Chief Information 

Officer, U.S. Department of Energy ................................................................... 197 

Letter to Hon. Ralph M. Hall, Chairman, U.S. House Committee on Science, 

Space, and Technology from Mr. Subra Suresh, Director, National Science 

Foundation ............................................................................................................ 198 

Letter to Mr. Larry Strickling, Assistant Secretary of Commerce, U.S. Department of Commerce from NASA ........................................................................... 199 

Federal Aviation Administration: LightSquared Impact to Aviation: FAA Perspective: PowerPoint Presentation to U.S. House Committee on Science, 

Space, and Technology ......................................................................................... 204 

Letter to Mr. Karl B. Nebbia, Associate Administrator, National Telecommunications and Information Administration from Mr. Joel Szabat, 

Deputy Assistant Secretary for Transportation Policy, U.S. Department 

of Transportation ................................................................................................. 219 

Memorandum for Mr. Karl Nebbia, Associate Administrator, National Telecommunications and Information Administration from Deanna Archuleta, 

Senior Advisor to the Secretary, Department of the Interior ........................... 252 
(1) 

IMPACTS OF THE LIGHTSQUARED NETWORK 

ON FEDERAL SCIENCE ACTIVITIES 

THURSDAY, SEPTEMBER 8, 2011 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY, 

Washington, DC. 

The Committee met, pursuant to call, at 2:19 p.m., in Room 2318 

of the Rayburn House Office Building, Hon. Ralph Hall [Chairman 

of the Committee] presiding. 
2 
3 

1 FCC DA 11–133, January 26, 2011. 2 FCC 03–15, February 10, 2003. 

HEARING CHARTER

COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY 

U.S. HOUSE OF REPRESENTATIVES 

Impacts of the LightSquared Network on Federal 

Science Activities 

WEDNESDAY, SEPTEMBER 8, 2011

2:00 P.M.—4:00 P.M. 

2318 RAYBURN HOUSE OFFICE BUILDING

Hearing Purpose 

The purpose of this hearing is to examine the concerns and issues associated with 

interference on the Global Positioning System (GPS) signal from the proposed 

LightSquared LLC terrestrial broadband network related to federal scientific activities. 

The committee will review the results of recent testing on the impact of the 

LightSquared network on the GPS signal. Potential interference could disable the 

GPS signal used for critical U.S. Government services and science missions such as 

the Next Generation Air Transportation System, Earth and space science missions, 

communications and navigation, space mission operations, weather predication and 

climate observation, search and rescue, disaster response and public safety, navigation, geodesy, and marine research platforms and services. In addition, the Committee will examine measures and costs necessary to implement and prioritize mitigation strategies at federal departments and agencies. 

Background 

LightSquared is a Mobile Satellite Service (MSS) telecommunication company 

owned by Harbinger Capital Partners Funds that was formed in 2010 with plans 

to provide a wholesale, nationwide 4G wireless broadband network through their existing mobile satellite communications services and a ground-based wireless communications network that uses the same L-band radio spectrum as their satellites. 

LightSquared’s predecessor companies include SkyTerra Communications, Inc. 

(SkyTerra), Mobile Satellite Ventures (MSV), Motient Services Inc. and American 

Mobile Satellite Company (AMSC). 1

LightSquared operates its satellite service using two geostationary satellites that 

cover North America and is also authorized to operate a ‘‘next-generation’’ satellite 

called SkyTerra–1, launched on November 14, 2010. 

The new LightSquared terrestrial network will be located in the same frequency 

band as their satellite service, which is adjacent to existing GPS spectrum, and 

transmitted through approximately 40,000 base stations located primarily in major 

city markets. A number of GPS stakeholders have raised concerns with the Federal 

Communications Commission (FCC) that the proposed LightSquared business plan 

will interfere with existing GPS-based services. 

In 2003, the FCC adopted initial rules allowing commercial satellite service providers to operate a ground network integrated with their satellite service. These integrated ground networks are referred to as an Ancillary Terrestrial Component 

(ATC) of a Mobile Satellite Service (MSS) and were intended to ‘‘fill in’’ gaps and 

boost the penetration of the original satellite signal within dense urban environments. The integrated ATC network would simply augment the satellite signal. 

The initial ATC ruling permitted MSS providers to enhance their satellite service 

but was not intended to become an independent terrestrial network. The FCC stated 

in the 2003 ruling: 

The purpose of our grant of ATC authority is to provide satellite licensees flexibility 

in providing satellite services that will benefit consumers, not to allow licensees to 

profit by selling access to their spectrum for a terrestrial-only service. 2

In 2004, the FCC granted LightSquared (then known as MSV) conditional approval to build its integrated ATC ground-based wireless network using its satellite 
4 

3 FCC DA 04–3553, November 8, 2004. 4 ‘‘Notice to Noteholders—Name Change,’’ SkyTerra Press Release, December 8, 2008. 5 FCC DA 10–535, March 26, 2010. 6 FCC DA 11–133, January 26, 2010. 7 Ibid. 8 Hearing titled ‘‘GPS Reliability: A Review of Aviation Industry Performance, Safety Issues, 

and Avoiding Potential New and Costly Government Burdens,’’ Committee on Transportation 

and Infrastructure, U.S. House of Representatives, June 23, 2011. 9 FCC Proceeding filing 11–109, June 30, 2011. 10 Final Report of the Technical Working Grouup, June 30, 2011. 

spectrum near the GPS signal. 3 At that time, the GPS industry concluded that interference with GPS signal would be manageable as the ATC would simply augment 

the satellite signal. 

MSV changed its name to SkyTerra in 2008. 4 In 2010, Harbinger Capital Partners Funds became the principal owner of SkyTerra, 5 and subsequently renamed 

the company LightSquared. The newly formed company also developed a new business plan to provide a wholesale, nationwide 4G wireless broadband network 

through their existing mobile satellite communications services and an integrated 

ground-based wireless communications network that uses the same L-band radio 

spectrum as their satellites. 

On January 26, 2011, the FCC granted LightSquared a conditional waiver of its 

ATC authority ‘‘integrated service rule’’ meaning its customers could offer terrestrial 

only services. 6 LightSquared maintains that its network will continue to offer both 

satellite and terrestrial services bundled together but that its wholesale customers 

could sell smartphones and similar devices that are only capable of transmitting and 

receiving with the terrestrial base stations. 7 The approval also required 

LightSquared to form a Technical Working Group (TWG) and issue a GPS interference assessment report, due to the FCC on June 15, 2011. 

In March 2011, LightSquared formed the TWG with industry representatives and 

government officials to conduct testing and report the results of impacts on the GPS 

signal. Comments and responses on the TWG report were due on August 15th. Recent congressional testimony on the report’s findings indicate significant interference between the LightSquared signal and the GPS signal. 8

Independent of the FCC-ordered study, the U.S. Government’s National SpaceBased Positioning, Navigation, and Timing Systems Engineering Forum (NPEF) 

conducted its own testing of the potential interference to military and civilian GPS 

users from LightSquared’s terrestrial network. The NPEF completed its report on 

June 1, 2011, and concluded that harmful interference to the GPS signal would result from the LightSquared network. The NPEF report recommended that the FCC 

withhold authorization for LightSquared to commence commercial operations and 

stated: 

The U.S. Government should conduct more thorough studies on the operational, 

economic and safety impacts of operating the LightSquared Network. 

In light of the test results from the TWG and the NPEF reports, LightSquared 

has proposed a new plan to initiate commercial operations utilizing the lower 10 

MHz of its L-band spectrum that the company believes will minimize interference 

with the GPS signal. 9 While LightSquared maintains its new proposal will significantly reduce interference to a large percentage of the GPS user community, its impact on aviation, space-based, and high precision users, such as the FAA NextGen, 

NASA Earth Science missions, GPS meteorology, seismology, and NOAA weather 

satellites and marine surveyors remains uncertain. While these users represent a 

small percentage of the overall GPS community, their services are critical to U.S. 

government operations and science missions. 

The latest LightSquared proposal would first utilize the lower 10 MHz of its Lband spectrum allocation that is the farthest away from the GPS signal at reduced 

power. Over time, provided interference concerns with the GPS signal could be sufficiently mitigated, LightSquared would then start operations across its entire upper 

and lower spectrum allocation. Although not specifically tested, the TWG report contains numerous recommendations (see Appendix 1) to conduct additional testing on 

the impact on the GPS signal if the FCC were to authorize LightSquared’s latest 

commercial operations proposal. 10

On July 6, 2011, the National Telecommunications and Information Administration (NTIA) sent a letter to the FCC stating that, based on the government testing 

and analysis, earlier concerns about GPS interference remain unresolved and additional testing is necessary. NTIA recommended that the FCC continue to withhold 

authorization for LightSquared to commence commercial operations, stating: 
5 

11 NTIA Letter to FCC, July 6, 2011. 12 Letter from Chairman Genachowski, FCC, to Senator Grassley, May 31, 2011. 13 FCC filing, Recommendation of LightSquared LLC, June 30, 2011. 14 http://www.saveourgps.org/ pdf/TWGlFinallReportl2lPagel Summary.pdf. 15 FCC filing, Recommendation of LightSquared LLC, June 30, 2011. 

NTIA supports the [National Executive Committee for Space-Based Positioning, 

Navigation, and Timing] EXCOM’s recommendation that additional tests be performed and recommends that the FCC continue to withhold authorization for 

LightSquared to commence commercial operations until all the available test data 

can be analyzed and all valid concerns have been resolved. 11

On May 11, 2011, the National Executive Committee for Space-Based Positioning, 

Navigation, and Timing requested Departments and agencies assess the impacts of 

LightSquared’s concept for operations. The PNT-NCO asked Departments and agencies to answer the following questions: 

• Summarize and quantify current and future benefits provided by use of GPSbased application and any cost-benefit analyses. 

• Summarize and quantify total sunk costs in GPS-based infrastructure (prior 

years to date) and planned investments going forward. 

• To the extent possible, qualify, quantify, and describe risks to your agency’s 

GPS-based mission capability, including ‘‘lost benefits’’ if GPS performance were 

degraded (or lost) due to LightSquared’s signals including the costs to modify 

(or replace) GPS receiver infrastructure and the time frame required to replace 

that infrastructure. 

As stated previously, comments on the TWG report were due on July 29, 2011, 

and responses to comments were due on August 15, 2011. At this point, the FCC 

can rule on whether to approve LightSquared’s proposal at any time. While it is possible that the FCC could approve LightSquared’s proposal, the Commission has stated that it ‘‘will not permit LightSquared to begin commercial service without first 

resolving the Commission’s concerns about potential widespread harmful interference to GPS devices. The FCC International Bureau’s Order of January 26, 2011 

(Order), outlines our interference concerns and unambiguously conditions 

LightSquared’s commercial operation on first resolving those challenges to our satisfaction. Under no circumstances would I put at risk our nation’s national defense 

or public safety.’’ 12

Issues 

Mitigation 

While LightSquared announced that their new proposal (which offers to delay the 

use of the upper band of their spectrum) mitigates interference with 99 percent of 

GPS receivers, the GPS industry has challenged these claims.13,14 There would still 

be interference, however, with high precision ers—the primary users of GPS that the 

Committee is concerned with. Recent statements by LightSquared indicate that the 

remaining interference can be minimized by the use of filters. Questions remain as 

to whether this is actually possible, whether such a plan would require additional 

testing, how much this would cost, who would bear the costs of developing these filters, and who would be responsible for retrofitting impacted receivers. 

Spectrum Use 

LightSquared’s new proposal also states that they will, ‘‘delay incorporating into 

its terrestrial network the upper 10 MHz of its frequencies in which transmissions 

may jeopardize legacy GPS usage,’’ but will ‘‘work with the FCC, NTIA, and other 

government agencies to explore all options for using a full complement of terrestrial 

frequencies.’’ 15 Assuming LightSquared’s proposal is allowed by the FCC, it is uncertain whether the FCC will prevent LightSquared from operating in the upper 10 

MHz, or if this prohibition will be self-imposed. Issues also exist relative to how to 

determine an acceptable level of interference, who makes this determination, and 

when this determination can be made. 

Spectrum Encroachment 

High precision GPS receivers utilize a technique that receives augmentation signals over a wide swath of Global Navigation Satellite System (GNSS) spectrum in 
6 

16 FCC Filing SAT-MOD-20101118–00239, Feb. 25, 2011. 17 Letter to the Office of Spectrum Management, NTIA, from Mobile Satellite Ventures L.P. 

and the U.S. GPS Industry Council, July 25, 2002. 

order to achieve sub-centimeter accuracy. 16 These receivers also ‘‘look’’ across the 

spectrum allocated to LightSquared. While regulations exist to restrict broadcasts 

to certain portions of the spectrum, no regulations exist related to receivers. Therefore, LightSquared argues that interference ‘‘is not caused by emissions from 

LightSquared’s base stations into the GPS band, but from the failure of these legacy 

GPS receivers to reject transmissions from LightSquared’s licensed frequencies, 

which are adjacent to the spectrum allocated for use by GPS.’’ Conversely, the GPS 

industry argues that the LightSquared spectrum was originally planned to be for 

a Mobile Satellite Service (MSS), which, by design, can coexist with the GPS signal 

since it is of a similar strength. Furthermore, the GPS industry claims that the outof-band spectrum that high precision GPS receivers use in LightSquared’s spectrum 

can coexist without interference as long as the signal strength used by 

LightSquared in its spectrum remains predominately satellite based as originally 

planned. Although FCC waivers have allowed satellite providers to operate ancillary 

terrestrial components (ATC) to augment satellite signals, agreements were made 

to prevent interference with not only other bands, but also interference with a provider’s own satellite signal. 17 With LightSquared’s proposal to operate a predominately terrestrial network, bundled with a satellite service, adjacent to a low-level 

GPS signal, these interference issues have now become problematic. 

Witnesses 

• Mr. Anthony Russo, Director, National Coordination Office for Positioning, 

Navigation and Timing 

• Ms. Mary Glackin, Deputy Under Secretary, National Oceanic and Atmospheric 

Administration 

• Mr. Victor Sparrow, Director, Spectrum Policy, Space Communications and 

Navigation, Space Operations Mission Directorate, National Aeronautics and 

Space Administration 

• The Honorable Peter Appel, Administrator, Research and Innovation Technology Administration, Department of Transportation 

• Dr. David Applegate, Associate Director, Natural Hazards, U.S. Geological Survey 

• Mr. Jeffrey J. Carlisle, Executive Vice President, Regulatory Affairs and Public 

Policy, LightSquared 

• Dr. Scott Pace, Director, Space Policy Institute, George Washington University 
7 

APPENDIX 1 

GPS Technical Working Group (TWG) Final Report—6/30/2011 (Excerpts) 

2.7.5 Space-based Receivers 

• In NASA‘s view, the interference to space-based GPS receivers used for [radio 

occultation (RO)] RO would be severely disruptive to NASA‘s science missions 

based on the test and analysis conducted in the TWG. Space-based GPS receivers used for navigation and precise orbit determination would receive a lesser 

amount of interference, though interference would occur. 

• NASA is of the view that, although the TWG members worked diligently and 

in good faith throughout the period prescribed by the FCC, it was impossible 

to adequately evaluate and thoroughly investigate potential interference mitigation options for space-based and high precision science receivers. 

3.1 Aviation Sub-Team 

• Compatibility of aviation GPS operations with a single lower 10 MHz channel 

could not be determined definitively without additional study. 

3.4 High Precision, Timing, and Networks Sub-Team 

• 1.1 GPS Community Positions 

• (5) In the lower 10 MHz channel configuration, 31 of 33 High Precision and 

Network GPS receivers tested experienced harmful interference within the 

range of power levels that would be seen inside the network. High precision 

receivers fielded today would experience harmful interference at up to 5 km 

from a single LightSquared base station. 

• With respect to possible mitigations: 

• (4) We believe more study is required on the feasibility of building future 

wideband High Precision, Network, and Timing receivers and augmentation 

systems that would be compatible with LightSquared terrestrial signals and 

which would provide the same performance as today‘s receivers and systems. 

We do not foresee any possibility that LightSquared signals near the GPS 

band could ever be compatible with wideband receivers. 

• (6) The viability of proposed future concepts to accommodate high precision 

GPS and MSS augmentations in the presence of interference from 

LightSquared terrestrial operations only in the lower 10MHz band has not 

been tested or validated as part of this study. 
8 

APPENDIX 2—LEGISLATION

HR 2596. Commerce, Justice, Science Appropriations Act 

• Committee Report 112–169: Spectrum interference issues.—The Committee is 

aware that NTIA and the Federal Communications Commission (FCC) are in 

the midst of a regulatory process with respect to the Global Positioning System 

and that a technical working group is reviewing potential interference issues. 

NTIA is directed to report to the Committee following completion of the technical working group activities, but no later than August 1, 2011, regarding the 

discoveries of this technical working group and the scientific steps necessary to 

address any potential interference concerns. 

HR 2434. Financial Service Appropriations Act 

• Section 633: None of the funds made available in this Act may be used by the 

Federal Communications Commission to remove the conditions imposed on commercial terrestrial operations in the Order and Authorization adopted by the 

Commission on January 26, 2011 (DA 11–133), or otherwise permit such operations, until the Commission has resolved concerns of potential widespread 

harmful interference by such commercial terrestrial operations to commercially 

available Global Positioning System devices. 

• Committee Report 112–136: The Committee is aware of concerns related to possible interference to Global Positioning System (GPS) devices due to terrestrial 

broadband service. The Committee remains engaged on this issue and awaits 

the final report by the Technical Working Group. 

HR 1540. National Defense Authorization Act, 2012 

• Committee Report 112–78: The committee is aware that the Federal Communications Commission (FCC) issued a conditional order to a commercial communications company on January 26, 2011, authorizing it to provide broadband 

voice and data communications services that potentially interfere with GPS. 

The committee recognizes that the Armed Forces are highly dependent on GPS 

capabilities and services. The committee believes that any space-based or terrestrial-based commercial communications service that has the potential to 

interfere with GPS should not receive final authorization to provide service 

within the United States by the FCC unless and until the potential interference 

with GPS is resolved. Such commercial services are planned to be transmitted 

from 40,000 land-based towers across the United States. The committee understands, based on information received from the Air Force, that the signal 

strength of such service is estimated to be one billion times more powerful than 

the GPS signal. Though the commercial service would broadcast on a frequency 

adjacent to GPS, it may still overwhelm GPS receivers, potentially causing a 

denial of service for millions of users in the United States relying on GPS navigation and timing services. Such users included the military, emergency responders, maritime and aeronautical emergency communication systems, banking transactions, air traffic and ground transportation systems, and myriad 

commercial applications. The committee understands that the Deputy Secretary 

of Defense sent a letter to the Chairman of the Federal Communications Commission on January 12, 2011, highlighting the ‘‘strong potential for interference 

to . . . critical national security systems,’’ and ‘‘strongly recommend[ing] deferral 

of final action on [the FCC order and authorization] until the proper interference analysis and mitigation studies can be conducted.’’ 

HR 2112. Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2012 

• Committee Report 112–101: GPS Interference.—The Committee recognizes that 

the use of the Global Positioning System (GPS) is critical to USDA’s mission, 

including natural resource monitoring, forest firefighting, law enforcement, and 

research. In addition, precision agriculture would not be possible without GPS. 

It is estimated that U.S. farmers and ranchers have invested more than $3 billion in GPS technologies. 

• The Committee is aware of a decision by the Federal Communications Commission that may disrupt the use of GPS, causing significant problems for USDA 

and our Nation’s farmers and ranchers. The Committee directs USDA to ensure 

the FCC is aware of these concerns and to work with other Federal agencies, 
9 

such as the Department of Defense and the Department of Transportation, to 

address them. 
10 

APPENDIX 3—INTERNATIONAL PERSPECTIVE

European Commission 

On July 19, 2011, the head of the European Commission’s Directorate General for 

Enterprise and Industry, Heinz Zourek, the agency that oversees all operations of 

the Galileo program, has filed an official comment with the FCC regarding the proposed LightSquared network. The Commission expressed grave concern over interference with GPS and the future European Galileo satellite navigation system. The 

filing states: 

• ‘‘I am writing to express our deep concerns about the LightSquared system that 

is proposed for operation in frequencies immediately below the radionavigationsatellite service (RNSS) allocation at 1559–161O MHz. This band is the core 

band used by global satellite navigation systems including GPS and you are no 

doubt aware that Europe is at the advanced planning stage for its own system, 

Galileo, which will be operational by 2014/15, and that will also use this RNSS 

allocation. The LightSquared proposal for a terrestrial network deployment in 

MSS spectrum would completely change the nature of radio transmissions in 

the band.’’ 

EUMETSAT 

The European Organisation for the Exploitation of Meteorological Satellites 

(EUMETSAT) is an intergovernmental organization to establish, maintain and exploit European systems of operational meteorological satellites. 

On July 26, 2011, EUMETSAT filed a comment with the FCC in response to the 

LightSquared proposal. The filing stated: 

• ‘‘In reviewing the results and conclusions of the Technical Working Group Report regarding space-based GPS receivers in section 3.5 of the report, 

EUMETSAT shares the concerns expressed by NASA, that interference to 

space-based GPS receivers used for Radio Occultation (RO) would be severely 

disruptive also to the GRAS instrument on Metop.’’ 

• ‘‘Furthermore, the initial assessment of interference mitigation options have 

shown that even a restriction of the LightSquared operations to the lower 10 

MHz channel would not mitigate the amount of interference to an acceptable 

level. Thus, EUMETSAT supports the view of NASA that the only mitigation 

technique which would resolve interference to space-based GPS receivers used 

for Radio Occultation is to relocate high power terrestrial operations to a different frequency band.’’ 
11 

APPENDIX 4—ILLUSTRATION OF CONCERNS WITH LIGHTSQUARED
12 

Chairman HALL. I’d like to welcome you to today’s hearing entitled ‘‘Impacts of the LightSquared Network on Federal Science Activities,’’ and in front of you are the packets containing the written 

testimony, biography, and truth in testimony disclosures for today’s 

witnesses. We have two, four, six, seven. 

I recognize myself for five minutes for an opening statement. 

The United States is the clear leader in precision, navigation, 

and timing because of its consistent investment in the global positioning system. This investment has been protected and reaffirmed 

by successive Administrations’ support, which has led to the—one 

of the greatest technological achievements I guess this Nation has 

ever created. It is one that both government and industry can be 

proud of, and it is the gold standard for billions of people around 

the world. 

While it is nearly impossible to quantify the exact impact GPS 

has on society, it has certainly had an enormous impact on economic productivity, furthered scientific understanding, and modernized our national defense. Some recent reports estimate GPS enables over three trillion in direct and indirect economic activity and 

has created over three million jobs, a fact that should not be overlooked with the President preparing to speak before Congress in a 

few short hours on the state of our economy. 

In addition to the economic significance, the Global Positioning 

System is also an important aspect of many federal operations and 

scientific activities. Aerial and satellite imagery, weather forecasting, climate observation, search and rescue, air traffic management, rail transportation, traffic management, vessel navigation, 

emergency response and mapping, time distribution, seismic monitoring, land surveys, resource management, agriculture, engineering, and scientific observations all depend on GPS. Any potential 

disruption to GPS and the science activities that it supports is of 

utmost concern to this committee. 

LightSquared has proposed a network to support the President’s 

challenge to identify 500 megahertz of new spectrum for broadband 

service. While the President’s goal is certainly commendable, it 

should not be accomplished by destroying existing systems and applications. As the President’s own National Space Policy states, the 

United States must, ‘‘maintain its leadership in the service, provision, and use of global navigation satellite systems,’’ and ‘‘invest in 

domestic capabilities and support international activities to detect, 

mitigate, and increase resiliency to harmful interference for GPS.’’ 

The purpose of this hearing is to examine the potential impact 

of the LightSquared Network on federal science activities. In doing 

so we hope to ensure that all the affected agencies are aware of the 

potential issues, have communicated those concerns effectively, are 

identifying potential mitigation strategies, and are calculating the 

costs associated with those mitigation strategies. In preparing for 

this hearing we have seen varying degrees of preparation by agencies. Some have done the expected due diligence, and some clearly 

have not. 

Although the FCC has stated that it will not allow LightSquared 

to begin commercial service without first resolving the interference 

issue, nothing actually prevents the FCC from moving forward at 

this point. Since the testing that was conducted this spring and 
13 

summer, LightSquared has put forth a modified plan. Unfortunately, no testing has been done on this modified plan. I agree with 

the agencies before us today that additional testing should be required before the FCC allows LightSquared to begin commercial 

service. 

Ensuring that GPS is protected is a vital national interest. Its 

economic impact is clear, and its utility to science is unquestionable, but what is also important is the real impact on lives. Last 

month the FAA announced that LightSquared’s previous proposal 

would result in billions of dollars of investment loss, a decade of 

delays to ongoing projects, a cost impact of roughly 72 billion, and 

almost 800 additional fatalities, and that is just one Administration. Compromising the GPS would also benefit foreign systems 

and threaten U.S. leadership. As we have recently seen dependence 

on Russia for access to International Space Station has already 

compromised U.S. interests. Reliance on Russia’s GLONASS System, China’s COMPASS System, of Europe’s GALILEO System for 

the precision, navigation, and timing would be just as costly. 

We have to find a way to open up more spectrum for broadband 

but not at the expense of GPS. This is, however, a two-way street. 

GPS users and agencies also have to be mindful that developing 

applications outside of their spectrum is dangerous and ripe for 

conflict, even though previously there were no problems. 

[The prepared statement of Mr. Hall follows:] 

PREPARED STATEMENT OF CHAIRMAN RALPH M. HALL

Good afternoon. Welcome to today’s hearing titled ‘‘Impacts of the LightSquared 

Network on Federal Science Activities.’’ The United States is the clear leader in precision, navigation, and timing because of its consistent investment in the Global Positioning System. This investment has been protected and reaffirmed by successive 

Administrations’ support, which has led to one of the greatest technological achievements this nation has ever created. It is one that both government and industry can 

be proud of and is the gold standard for billions of people around the world. While 

it is nearly impossible to quantify the exact impact GPS has had on society, it has 

certainly had an enormous impact on economic productivity, furthered scientific understanding, and modernized our national defense. Some recent reports estimate 

GPS enables over $3 trillion in direct and indirect economic activity and has created 

over three million jobs—a fact that should not be overlooked with the President preparing to speak before Congress in a few short hours on the state of our economy. 

In addition to its economic significance, the Global Positioning System is also an 

important aspect of many federal operations and scientific activities. Aerial and satellite imagery, weather forecasting, climate observation, search and rescue, air traffic management, rail transportation, traffic management, vessel navigation, emergency response and mapping, time distribution, seismic monitoring, land surveys, 

resource management, agriculture, engineering and scientific observations all depend upon GPS. Any potential disruption to GPS, and the science activities that it 

supports, is of utmost concern to this Committee. 

LightSquared has proposed a network to support the President’s challenge to 

identify 500 megahertz of new spectrum for broadband service. While the President’s goal is certainly commendable, it should not be accomplished by destroying 

existing systems and applications. As the President’s own National Space Policy 

states, the United States must ‘‘maintain its leadership in the service, provision, 

and use of global navigation satellite systems (GNSS),’’ and ‘‘[i]nvest in domestic capabilities and support international activities to detect, mitigate, and increase resiliency to harmful interference to GPS.’’ 

The purpose of this hearing is to examine the potential impact of the 

LightSquared network on federal science activities. In doing so, we hope to ensure 

that all of the affected agencies are aware of the potential issues, have communicated those concerns effectively, are identifying potential mitigation strategies, 

and are calculating the costs associated with those mitigation strategies. In pre-
14 

paring for this hearing, we have seen varying degrees of preparation by agencies. 

Some have done the expected due diligence and some clearly have not. 

Although the FCC has stated that it will not allow LightSquared to begin commercial service without first resolving the interference issue, nothing actually prevents the FCC from moving forward at this point. Since the testing that was conducted this spring and summer, LightSquared has put forth a modified plan. Unfortunately, no testing has been done on this modified plan. I agree with the agencies 

before us today that additional testing should be required before the FCC allows 

LightSquared to begin commercial service. 

Ensuring that GPS is protected is a vital national interest. Its economic impact 

is clear, and its utility to science is unquestionable, but what is also important is 

the real impact on lives. Last month the FAA announced that LightSquared’s previous proposal would result in billions of dollars of investment lost, a decade of 

delays to ongoing projects, a cost impact of roughly $72 billion, and almost 800 additional fatalities—and that is just one Administration. Compromises to GPS would 

also benefit foreign systems and threaten U.S. leadership. As we have recently seen, 

dependence on Russia for access to the International Space Station has already compromised U.S. interests. Reliance on Russia’s GLONASS system, China’s COMPASS 

system, or Europe’s GALILEO system for precision, navigation, and timing would 

be just as costly. 

We have to find a way to open up more spectrum for broadband, but not at the 

expense of GPS. This is, however, a two-way street. GPS users and agencies also 

have to be mindful that developing applications outside of their spectrum is dangerous and ripe for conflict, even though previously there were no problems. 

With that, I yield to the Ranking Member from Texas, Ms. Johnson. 

Chairman HALL. I now recognize Ms. Johnson for her opening 

statement. 

Ms. JOHNSON. Thank you very much, Mr. Chairman. Good afternoon, and I would like to join you in welcoming our witnesses for 

today’s hearing. 

There is no question that the Global Positioning System has 

transformed our economy and our society in many ways. It has 

been an amazing accomplishment, and some here may be surprised 

to learn that this very successful program is a government initiative. The Global Positioning System was established by the Department of Defense to support their national security mission needs. 

But civilian agencies also rely on GPS to provide greater services 

for the American public. There is no doubt that GPS plays an essential role in public safety. This hearing will allow Members to 

better appreciate how agencies use GPS as well as what would be 

lost without a GPS. GPS satellite signals have also spawned an entire area of innovation in private industry with new hardware and 

applications that allow the average citizen unprecedented tools for 

location and navigation. All of this has been a free benefit to the 

Nation’s economy that is a product of sound management of the 

radio spectrum and direct government investment. 

The LightSquared proposal to build a nationwide broadband network into frequencies that sit next to GPS has provoked enormous 

controversy. I believe that if there is no way for LightSquared to 

move forward without damaging GPS, then the FCC should not approve the company’s proposal. 

However, I do not believe that FCC would make a decision that 

compromises GPS services. The question the commission has to settle and the question that this hearing will not allow us to make 

much headway on is whether GPS can thrive side by side with a 

ground-based broadband network. 

I sincerely hope that they can coexist. Some of those supporting 

the GPS industry claim such coexistence is impossible. This sug-
15 

gests the physics of cell towers sending out powerful transmissions 

will overwhelm the sensitive GPS receivers. 

However, others are feeling this is not a physics problem but an 

engineering challenge. With filters for GPS units and with reasonable beam shaping at cell towers, smart engineering can solve 

these problems. I do not know whether we are dealing with a physics problem or an engineering challenge, but I am not convinced 

that any of the witnesses can today provide an answer to that 

question with absolute certainty. 

The agencies before us are testifying based on testing of GPS 

equipment under the original LightSquared proposal, in which the 

company would first build cell towers that broadcast in the portion 

of the spectrum immediately adjacent to that of GPS. That testing 

was not based on the new proposal from the company to use the 

portion of the spectrum that is most remote from GPS-assigned frequencies. 

I fully believe that the FCC will make its decision based on technical assessments and not the political pressure that may come 

from private parties or even from committees of Congress or the 

Executive. I hope to learn as much as I can today about what additional testing may be needed to inform the FCC’s processes. 

The core question for policymakers is this. Can we use the Lband, or some portion of it, of the radio spectrum for an earthbased broadband network without damaging GPS? I hope the answer is yes, and everyone here should hope the answer is yes, because we need more broadband just as we need GPS. 

LightSquared is saying that they intend to invest $14 billion over 

the next eight years to build out the network, employing 14,000 

people in the process. In building more information technology infrastructure, consumers would have more choice in their telecommunications and data services with lower costs and expanding 

access. 

We should also see accelerating innovation of data-intensive cellular applications that take advantage of the greater capacities of 

this new network, creating more jobs, more profits, and more 

growth in high-tech industries. And we are desperately in need of 

jobs, profits, and growth right now. 

And while I am skeptical that today we will get definitive answers to the most important policy questions, I look forward to listening to the testimony, and I thank all of our witnesses for their 

participation. 

Thank you, and I yield back, Mr. Chairman. 

[The prepared statement of Ms. Johnson follows:] 

PREPARED STATEMENT OF RANKING MEMBER EDDIE BERNICE JOHNSON

The Global Positioning Satellite system has been a complete success. It is, for 

those who don’t know, a government program. The GPS system was established by 

the Department of Defense to help assist their security mission needs, but civilian 

agencies also use the GPS system to provide greater services to the American public. There is no doubt that GPS plays an essential role in public safety. 

But that is not all that has come from this public investment. GPS satellite signals have spawned an entire area of innovation in private industry with new hardware and applications that allow the average citizen unprecedented tools for location 

and navigation. All ofthis has been a free benefit to the economy from this government investment and sound management of the radio spectrum. 
16 

The LightSquared proposal to build a nationwide broadband network in the frequencies that sit next to GPS has provoked enormous controversy. On the one hand, 

GPS is too important to lose and so if there is no way for LightSquared to move 

forward without damaging GPS. On the other hand, the promise of enhanced infrastructure and the jobs that this might create is worthy of further study. This hearing will allow Members to better appreciate how OUI agencies use GPS as well as 

what would be lost should GPS suddenly go away. However, I do not believe that 

the FCC would make a decision that compromises GPS services. The question they 

have to settle, and the question that this hearing will not allow us to make much 

headway on, is whether GPS can thrive side-by≥side with a ground-based broadband 

network. 

Some of those lobbying for the GPS industry claim such coexistence is impossible. 

They suggest the physics of cell towers sending out powerful transmissions would 

overwhelm sensitive GPS receivers. However, others argue that this is not a physics 

problem, but an engineering challenge. With filters for GPS units and with reasonable beam shaping at cell towers, smart engineering could solve these problems. It 

is unclear whether we are dealing with a physics problem or an engineering challenge, and I do not believe any of the witnesses before us today can provide an answer to that question with absolute certainty. 

The agencies before us today are testitying based on testing of GPS equipment 

under the original LightSquared proposal in which the company would first build 

cell towers designed to use the portion of the spectrum immediately adjacent to that 

of GPS. Their testing is not based on the new proposal from the company to use 

their spectrum that is most remote from GPS’s assigned frequencies. The FCC will 

have to make its decisions based on technical assessments and not the political pressure that may come from private parties or even from Committees of Congress. 

Today, I want to learn about what additional testing may be needed to inform the 

FCC’s processes. 

The core question for policy-makers is this: can we use the L-band, or some portion of it, of the radio spectrum for terrestrial broadband applications without damaging GPS? I hope that the answer is yes, and everyone here should hope the answer is yes, because we need more broadband just as we need GPS. LightSquarcd 

is proposing to invest $14 billion over the next eight years to build out their network 

and projects it will employ 14,000 people in the process. In building more information technology infrastructure, we would see consumers have more choice in their 

telecommunications and data services, lowering their costs and expanding access. 

We should also see accelerating innovation of data-intensive cellular applications 

that take advantage ofthe greater capacities of this new network—creating more 

jobs, more profits, more growth. And we desperately need jobs, profits and growth 

right now. 

While I am skeptical that we will get definitive answers to the most important 

policy questions here today, I am happy to listen to the testimony from all of our 

panel members. 

Chairman HALL. Thank you, Ms. Johnson. If there are Members 

who wish to submit additional opening statements, your statements will be added to the record at this point. 

At this time I would like to introduce our witnesses and to thank 

our witnesses because I know they are valuable, their time is valuable. It took time to prepare for this. It took time for you to arrive 

here, it will take time for you to give your testimony, take time for 

you to go home. And your time is valuable, and we are going to try 

to be as helpful with you. As long as you give us the answers we 

are looking for, we won’t even use up all of our time. 

Mr. Anthony Russo is the Director of National Coordination Office for Positioning, Navigation, and Timing, Mrs. Mary Glackin is 

the Deputy Under Secretary at the National Oceanic and Atmospheric Administration, Mr. Victor Sparrow is the Director of Spectrum Policy at the National Aeronautics and Space Administration. 

The Honorable Peter Appel is the Administrator of the Research 

and Innovation Technology Administration at the Department of 

Transportation, Dr. David Applegate is the Associate Director for 

National—Natural Hazards at the U.S. Geological Survey, Mr. Jef-
17 

frey J. Carlisle is the Executive Vice President for Regulatory Affairs and Public Policy at LightSquared LLC, and Dr. Scott Pace 

is the Director of the Space Policy Institute at George Washington 

University. And I want to welcome all of you. 

As our witnesses probably know, spoken testimony is limited to 

five minutes, after which the Members of the Committee will have 

five minutes each to ask questions. We hope you can stay as close 

to that five minutes as you can because—and don’t let these empty 

seats here indicate a lack of interest in what you are saying because we are just back from a month when we were all gone and 

nobody was getting heard up here, and we came back, and everybody has a lot to do, and they have other committees, but all this 

testimony is being taken down and will be of record for everybody, 

not just the Members of this Committee but for everybody to read. 

So Mr. Russo, you may proceed if you would like, sir. 

STATEMENT OF MR. ANTHONY RUSSO, 

DIRECTOR, THE NATIONAL COORDINATION OFFICE FOR 

SPACE-BASED POSITIONING, NAVIGATION, AND TIMING 

Mr. RUSSO. Chairman Hall, Ranking Member Johnson, and 

Members of the Committee, I am deeply honored to be here for you 

today. 

Like the Internet, GPS is an essential element of the global information infrastructure. The free, open, and dependable nature of 

GPS has led to the development of thousands of applications affecting every aspect of modern life, and innovation has not stopped. 

New applications are being developed daily. 

GPS saves lives by preventing transportation accidents, aiding 

search and rescue efforts, assisting law enforcement, and speeding 

delivery of emergency services and disaster relief. It is vital to 

weather forecasting, earthquake monitoring, and environmental 

protection. 

GPS’s role as part of our civil infrastructure traces its roots to 

a tragic incident in 1983. A Korean airliner took off from Alaska 

and ended up straying way off course in Soviet airspace. The airliner was shot down, and all 269 passengers were killed, including 

a sitting Member of Congress. As part of the response, President 

Reagan announced we would make GPS signals available to the 

world, and that marked the beginning of a multi-use policy approach to GPS that each successive Administration has strengthened. 

An Executive Committee consisting of the Department Deputy 

Secretaries was established in 2004, to advise and coordinate on 

GPS-related issues to include spectrum protection and interference. 

To execute the staff functions of the Executive Committee, a National Coordination Office or NCO was also established. The NCO 

is staffed with representatives from every department or agency 

with major equities in GPS. I am speaking to you today in my capacity as director of that office. 

Earlier this year, the FCC approved a conditional waiver for 

LightSquared’s high-powered network, and with the permission of 

the Executive Committee, a tasked interagency group of technical 

experts called the National Space-Based Position Navigation and 

Timing Systems Engineering Forum or NPEF for short, to evaluate 
18 

the LightSquared proposal, assess impacts, and look at the mitigation of any harmful effects. 

And although they were not required to do so, LightSquared actively supported these efforts. They provided their actual hardware 

including a custom filter for their transmitter, technical specifications, they answered numerous questions, and they even sent personnel to government test sites to review the test set-up. So I 

would like to take the opportunity to publicly thank LightSquared 

for their cooperation, which greatly improved the fidelity of the results. 

The NPEF testing was done under numerous limitations, especially an extremely compressed time frame, but despite these limitations the NPEF reached a definitive answer. LightSquared’s proposed system would create harmful interference throughout all 

three phases of its planned deployment. Although not every individual receiver failed to perform, there were unacceptable levels of 

harmful interference in every class of receiver tested and at significant distances. 

I had asked the NPEF to investigate not only things that we 

might reasonably ask LightSquared to do, but also to look at 

changes the GPS community could do that would mitigate harmful 

interference and still allow LightSquared to execute their business 

plan. The NPEF spent many hours considering the full range of options but could not identify any feasible option that would both 

mitigate harmful interference for all or even most GPS users and 

still allow LightSquared to meet their system requirements. 

Now, to meet one of the conditions of their conditional waiver, 

LightSquared created a Technical Working Group or TWG with significant industry, government representation to conduct interference testing. LightSquared chose to break their testing into 

seven separate subgroups based on GPS application type. All seven 

subgroups reported significant harmful interference with respect to 

all three phases of LightSquared’s planned deployment. However, 

there was no consensus on feasible mitigation options. 

On June 29, LightSquared submitted their TWG report acknowledging the harmful interference, and simultaneously they submitted a report outlining a potential solution. LightSquared’s new 

recommendation paper suggests three distinct changes, and this 

was a series in constructive proposal, and the FCC is currently 

evaluating this recommendation, but the NPEF testing did not include the configuration LightSquared is now proposing. And it 

wasn’t in the TWG test plans either. 

Now, in the final days of their testing TWG did manage to collect 

some of the data relevant to this configuration, but the report itself 

is inconclusive as to whether data still shows harmful interference 

to many GPS receivers. The limited data collected is highly disputed among the members of TWG. Therefore, the federal agencies 

are recommending further testing once the FCC defines the final 

LightSquared end-state configuration. 

What we do know is enough data was collected that—by all parties in terms of whether or not high-precision receivers would be 

impacted. LightSquared’s report indicates 31 of 33 receivers tested 

in this subgroup still failed, even in the lower configuration, and 

this class of receivers involves many of those used in advanced sci-
19 

entific research applications. Most federal science systems were not 

directly tested by either the NPEF or the TWG, so we do not know 

for sure if they would be impacted. But the tests did indicate increased susceptibility interference for the higher end, more sophisticated systems, many of which are used in research and science 

applications. 

In summary, the extensive testing done by LightSquared, the 

government, and the GPS industry conclusively demonstrate harmful interference from LightSquared’s intended deployment, and 

they should not be allowed to commence commercial operations 

until the identified problems are resolved. Further study is needed 

on alternative concepts that were not comprehensively tested, including the most recent LightSquared proposal. The National Coordination Office will assist as directed by the Executive Committee in any follow-on efforts. 

I thank you for this opportunity to speak on this very significant 

issue impacting federal science activities and over a billion worldwide users. I look forward to your questions. 

[The prepared statement of Mr. Russo follows: 

PREPARED STATEMENT OF MR. ANTHONY RUSSO, 

DIRECTOR, THE NATIONAL COORDINATION OFFICE FOR

SPACE-BASED POSITIONING, NAVIGATION, AND TIMING

Chairman Hall, Ranking Member Johnson, and Members of the Committee, I am 

deeply honored for this opportunity to appear before you today. Like the Internet, 

Global Positioning System (GPS) is an essential element of the global information 

infrastructure. The free, open, and dependable nature of GPS has led to the development of thousands of applications affecting every aspect of modern life and new applications are developed daily. GPS technology is now in everything from cell phones 

and wristwatches to bulldozers and shipping containers. When you swipe your card 

at an Automatic Teller Machine (ATM) or your credit card at a gas pump, you are 

using GPS. GPS boosts productivity across a wide swath of the economy, to include 

farming, construction, mining, surveying, package delivery, and logistical supply 

chain management. Major communications networks, banking systems, financial 

markets, and power grids depend heavily on GPS for precise time synchronization. 

Some wireless services cannot operate without it. 

GPS saves lives by preventing transportation accidents, aiding search and rescue 

efforts, assisting law enforcement and speeding the delivery of emergency services 

and disaster relief. GPS is vital to the Next Generation Air Transportation System 

(NextGen) that will enhance flight safety while increasing airspace capacity. GPS 

also advances scientific aims such as weather forecasting, earthquake monitoring, 

and environmental protection. 

The Role of the Space-Based Positioning, Navigation 

and Timing Executive Committee 

On September 1, 1983, a Korean civilian airliner took off from Alaska and ended 

up straying way off course into Soviet airspace. The airliner was shot down as it 

attempted to leave the airspace and all 269 passengers were killed. As part of the 

response to that tragedy, President Reagan announced the United States would 

make its GPS signals available to the world to avoid any navigation errors of that 

type. That announcement marked the beginning of a multi-use policy approach to 

GPS and each successive administration has strengthened that concept. In 2004, 

President Bush issued a National Space-Based Positioning, Navigation, and Timing 

(PNT) Policy establishing a Deputy Secretary-level Executive Committee to advise 

and coordinate on policies, programs, requirements, schedules, architectures and 

budgets to sustain and modernize GPS, systems that augment or enhance GPS, and 

any backup systems. The Policy includes an explicit instruction to continue to operate and modernize GPS to meet growing scientific and commercial demands. Last 

year, President Obama signed out his comprehensive National Space Policy which 

left the existing PNT policy in place, but added emphasis and additional guidance 
20 

in four key areas related to GPS. One of these new emphasis areas dealt specifically 

with the issue of harmful interference. We are also responsible in this policy to identify impacts to government space systems prior to any reallocation of spectrum for 

commercial, federal, or shared use. 

To execute the staff functions of the Executive Committee, and to assist them in 

ensuring implementation of the President’s policy objectives, a National Coordination Office (NCO) was established. The NCO is staffed with representatives from 

every department or agency with major equities in GPS. I am speaking to you today 

in my capacity as the Director of that office. 

The National Space-Based Positioning, Navigation, 

and Timing Systems Engineering Forum (NPEF) 

The NPEF is an interagency working group that supports the Executive Committee on major technical issues that cross agency boundaries. Their reports help 

form the basis for recommendations made to the Executive Committee. The NPEF 

is co-chaired by the Air Force’s Chief Engineer from the GPS Program Office and 

the FAA’s Ground Segment Lead for Global Navigation Satellite Systems and 

Space-Based Augmentation Systems. They are assisted by technical representatives 

and other staff from across the interagency. 

On the January 26 this year, the Federal Communications Commission (FCC) approved a Conditional Waiver for LightSquared’s high-power broadband network the 

Executive Committee had warned might cause significant interference to governmentwide GPS applications. With the permission of the Executive Committee’s 

Steering Group, the NPEF was tasked to evaluate the LightSquared proposal, assess impacts, and look at potential mitigation of any harmful effects. I’ve included 

the NPEF Task Statement as part of this testimony. 

Their test methodology involved modeling, simulation, analysis, bench testing, radiated testing inside an anechoic chamber, and what we call ‘‘live sky’’ testing where 

they set up a tower outdoors and broadcast a signal as close as they could to what 

they expected the actual configuration to be. Each of these methods has advantages 

and limitations and using multiple methods enhances confidence in the results. 

LightSquared actively supported these efforts. They provided their actual hardware 

including a custom filter on their transmitters, technical specifications and answered numerous questions from NPEF engineers, and sent personnel to government test sites to review and comment on the test set-up. I would like to take this 

opportunity to publicly thank LightSquared for their cooperation. It greatly enhanced the fidelity of the results. 

I do want to identify some limitations of our testing effort. The most significant 

is that there was only one LightSquared transmit antenna. Since interference effects can be additive, this is a serious limitation in a planned environment where 

the LightSquared base stations are densely enough packed that a given user will 

likely see effects from multiple towers simultaneously. This also greatly complicates 

some of the potential mitigation options. A second limiting factor was there were 

no LightSquared handsets available to test. The handsets operate at a different frequency than their base stations and are much less powerful. However, the NPEF 

anticipates they will be much more numerous and since they are mobile they could 

be anywhere, and may even be frequently co-located with GPS receivers. Several 

technical experts on the team consider this to be a very significant problem, but 

they were not able to explicitly address this issue. A third limiting factor is the inability to fully represent the diversity of the GPS user community. There are more 

GPS applications than we can count, and at the NCO we learn of new applications 

at the rate of about three per week. Each application is different. Some require extreme position accuracy; others do not use position at all, but need very precise timing. Some applications require less precision, but need extremely high integrity— 

in other words they need high confidence the signal they receive is accurate. Still 

others do not even read the signal’s message content; they only care about the phase 

relationship between the military and civil GPS signals. It was therefore difficult 

to construct tests that covered all of our diverse users in the time we had to work 

with. And a final limiting factor was the extremely compressed time frame. 

But despite these limitations, the NPEF completed the job they were asked to do. 

They were able to look at a wide range of representative receivers against all three 

phases of LightSquared’s proposed deployment plan. In all, 24 different organizations participated in testing more than 75 different receivers in over 50 separate 

test events. The answer is definitive: LightSquared’s proposed system would create 

harmful interference throughout all three phases of its planned deployment. I have 

attached an Executive Summary of the publicly releasable results to this testimony. 

The tests showed no evidence of out-of-band emissions. In other words, the NPEF 
21 

was able to confirm LightSquared’s claim they correctly filter their transmission so 

it is not leaking into the GPS band. However, the tests also confirm the presence 

of other serious and harmful interference effects. Although not every individual receiver failed to perform, there were unacceptable levels of harmful interference in 

every class of receiver tested and at significant distances. 

In the NPEF task statement, the engineering team was asked to consider possible 

mitigations to any problems they discovered. They were asked to investigate not 

only things that we might reasonably ask LightSquared to do, but also to look at 

changes the GPS community could do that would mitigate harmful interference and 

still allow LightSquared to execute their business plan. The NPEF spent many 

hours considering the full range of options such as: reducing power on 

LightSquared’s transmission, increasing GPS’s transmitted power, building better 

GPS filters, or asking for exclusion zones around certain sensitive installations that 

use GPS. Unfortunately the NPEF could not identify any feasible option that would 

mitigate harmful interference for all or even most GPS users, and still allow 

LightSquared to meet their system requirements. The only suggested option that 

might work would be moving LightSquared to a different part of the spectrum, and 

that involves a host of other issues outside the PNT community. I’ve included an 

Executive Summary of the results of the NPEF testing, including a discussion of the 

potential mitigation options, as part of this testimony. 

LightSquared’s Technical Working Group (TWG) 

When the FCC granted the Conditional Waiver, one of the conditions was for the 

company to fund testing efforts to resolve the interference concerns the Executive 

Committee and GPS Industry had raised. The FCC Order further directed the creation of a LightSquared-led working group and highly encouraged participation from 

the U.S. Government and representation from across the diverse GPS industry. Altogether the TWG contained 39 full-time members and 61 part-time technical advisors, split between GPS Industry, LightSquared, and the Government. Like the 

NPEF, the TWG used an assortment of different techniques culminating in two 

weeks of ‘‘Live-Sky’’ testing in Las Vegas. There was healthy crossflow of expertise 

and data sharing between the NPEF and TWG. 

LightSquared chose to break the effort into seven separate subgroups based on 

GPS application type. The results were completely consistent with what the NPEF 

found. All seven subgroups reported significant harmful interference with respect to 

all three phases of LightSquared’s planned deployment. There was no consensus on 

feasible mitigation options although most of the subgroups did advocate for moving 

LightSquared’s service to a different frequency band. 

LightSquared’s New Plan 

On June 29, 2011 LightSquared submitted their TWG report acknowledging the 

harmful interference their proposed system would create. Simultaneously they submitted a report outlining a proposed potential solution. This solution was completely 

separate from the TWG and not evaluated by them. LightSquared’s new ‘‘Recommendation Paper’’ suggests three distinct changes. (1) A re-phasing of their plan 

where the first of their two transmissions is the one lower in their frequency band 

and therefore further from GPS; (2) a reduction in authorized power to the level 

they told us they originally planned to operate at; and (3) a ‘‘standstill’’ on transmitting their second channel (closer to the GPS band) for some undefined period of 

time. 

The FCC is currently evaluating this recommendation as well as considering all 

the comments received in the public comment period. The Government testing did 

not consider the configuration LightSquared is now proposing, although NPEF testing was done at the power level they indicate. The TWG did not plan to test this 

configuration either, but in the final days of their testing did collect some data. The 

TWG report is inconclusive as to whether this lower channel transmission does or 

does not cause harmful interference to most GPS receivers. The limited data collected is highly disputed and all seven of LightSquared’s subgroups recommended 

further study of this planned change to the phasing. The federal departments and 

agencies are recommending retesting once the FCC defines the final configuration. 

High-Precision Receivers 

However all parties concur the class considered ‘‘High-Precision’’ would still be impacted even under the first phase of LightSquared’s new proposal. LightSquared’s 

TWG report indicates 31 of 33 receivers tested in this subgroup failed in an environment where LightSquared was not transmitting in the upper half of their band. 
22 

This class of receivers involves many of those used in advanced scientific and research applications. For example, the receivers used in EarthScope’s Plate Boundary 

Observatory can measure movements due to tidal forces less than a one millimeter. 

Receivers like these would fit into the ‘‘High-Precision’’ category and will eventually 

be in every county in the country. This National Science Foundation project is critical to our understanding of the interior of the Earth and supports research on 

earthquakes, tsunamis and global climate change. 

Another example of a service which may be affected would be the National Institute of Standards and Technology (NIST) Time and Frequency Measurement and 

Analysis Service (TMAS) and (FMAS). LightSquared implementation, even under 

their new configuration, may impact NIST’s ability to provide high-precision calibration services to national laboratories and private sector customers nationwide. Even 

non-GPS related research may depend on accurate time and frequency calibration 

received from NIST. 

High-Precision GPS is also used by the Environmental Protection Agency for numerous research applications and is an integral part of their Field EnvironmentaL 

Decision Support system, or FIELDS. This impacts areas such as hazard waste site 

clean-up, response to oil spills, emergency preparedness, revitalization and development. Another NSF-funded environmental research project involves spatial variability in plant nitrogen and forage quality related to grassland fires. This directly 

affects grazing habits of herbivores. 

A final example would be potential impacts to efficient power distribution. The future ‘‘Smart Grid’’ incorporates geographically diverse Phasor Measurement Units 

(PMUs) to ensure alternating current is phase synchronized across the network. 

There are numerous economic and environmental benefits to this including reduced 

overall energy consumption, increased efficiency in demand response/load management programs, better utilization of equipment, reduction in carbon emissions, and 

the ability to more easily substitute renewable forms of energy. With the aid of precise GPS timing, the Department of Energy will be able to decrease the likelihood 

and the severity of major blackouts. 

None of these systems I’ve mentioned above were directly tested by either the 

NPEF or the TWG, so we do not know if they would be impacted. But both sets 

of tests did indicate increased susceptibility to interference for those higher-end, 

more sophisticated systems. Both the NPEF and the TWG subgroups recommended 

further testing, especially on the 10 MHz low configuration and on any proposed 

measures to mitigate harmful effects. 

Summary 

The extensive and comprehensive testing done by LightSquared, the NPEF, and 

the GPS Industry conclusively demonstrates harmful interference from 

LightSquared’s intended deployment of their high-power terrestrial broadband system and should not be allowed to commence commercial operations until the identified problems are resolved. 

The Administration believes that we must protect existing GPS users from disruption of the services they depend on today and ensure that innovative new 

GPS applications can be developed in the future. At the same time, recognizing 

the President’s instruction to identify 500 MHz of new spectrum for innovative 

new mobile broadband services, we will continue our efforts at more efficient 

use of spectrum. Therefore, in the short run, we will participate in the further 

testing required to establish whether there are any mitigation strategies that 

can enable LSQ operation in the lower 10MHz of the band. We also encourage 

commercial entities with interests to work with Lightsquared toward a possible 

resolution, though any proposed mitigation must be subjected to full testing. 

The challenge of meeting the President’s goal also depends on long-term actions 

by Federal agencies in the area of research and development, procurement practices that encourage spectrally efficient applications, and new policy development. 

Further study is needed on alternative concepts, including the most recent 

LightSquared proposal. The National Coordination Office will assist as directed by 

the Space-Based PNT Executive Committee in any follow-on efforts. I thank you for 

this opportunity to speak on an issue with a very significant impact to federal 

science activities and to over a billion world-wide users. I look forward to your questions. 
23 
24 
25 
26 
27 
28 
29 

Chairman HALL. Thank you very much. 

Dr. Applegate, you may proceed. 

I am sorry. I am told Ms. Glackin is next in line. 

STATEMENT OF MS. MARY GLACKIN, 

DEPUTY UNDER SECRETARY, NATIONAL OCEANIC AND 

ATMOSPHERIC ADMINISTRATION 

Ms. GLACKIN. Thank you. Mr. Chairman, Ranking Member Johnson, and Members of the Committee, thank you for the opportunity 

to speak today about the importance of GPS to NOAA and the 

operational impacts we could face as a result of GPS interference 

from the LightSquared network. 

GPS technology is a key enabler for nearly all of NOAA’s mission 

activities, and for this reason we are very interested and involved 

in the activities surrounding LightSquared and GPS. NOAA contributed equipment and experts to the two major testing efforts 

just described. My testimony will address the potential effects of 

the original and the modified LightSquared Spectrum Plans based 

on our analysis of the data. 

Based on our work to date, GPS interference under 

LightSquared’s original plan would cause serious degradation for a 

wide range of NOAA systems, resulting in the loss of critical services and potentially loss of life and property. These include satellite, airborne, sea-based, and terrestrial systems used for weather 

warnings, forecasting, climate observation, search and rescue, 

among others. 

First and foremost, our entire fleet of meteorological satellites 

would be put at risk. Without GPS, the ground systems that control the NOAA spacecraft would fail to keep proper time, causing 

widespread errors, leading to inaccurate warnings of tornadoes, 

hurricanes, and other severe weather events and eventually our 

ability to command and control the satellites would be compromised. 

Likewise, without precise GPS times, NOAA’s search and rescue 

satellite ground stations would produce less accurate and less timely distress alerts, leading to longer response time, greater risk to 

human life, and increased costs. 

We are concerned that LightSquared’s original broadcast would 

interfere with onboard GPS for newer satellites, including our NPP 

satellite in low-earth orbit and even GOES–R in GS geostationary 

orbit. 

My written testimony also highlights other critical NOAA systems put at risk at the LightSquared’s original proposal, including 

23,000 environmental sensor platforms that depend on GPS for accurate geo-referencing, time stamping, and communication of data 

that enable timely storm and flood warnings, use in weather balloons and hurricane dropsondes that measure wind speeds. 

LightSquared’s proposed solution involves voluntary power limits 

and postponement of one of its two planned channels, the upper 10 

megahertz next to GPS. Unfortunately, LightSquared’s own report 

to the FCC demonstrates that the new spectrum plan involves— 

would still raise issues for high-precision GPS receivers featuring 

a wideband design. 
30 

We have identified at least five major NOAA functions that require wideband GPS equipment. These include the COSMIC System of satellites to improve global and weather climate models, 

monitoring sea level trends to protect natural and human communities, the ground-based GPS meteorology project to improve shortterm forecasts, the issuance of the U.S. Total Electron Count product to inform the public of space weather conditions and space 

storms, and maintaining the National Spatial Reference System to 

ensure the compatibility among U.S. maps and surveys. 

Three of these five activities depend on NOAA’s nationwide network of Continuously Operating Reference Stations, or CORS, 

which collect and share precise data about GPS satellite orbits. 

CORS provides a consistent positioning technology, accurate to an 

inch, used by millions to anchor nautical charts, build roads and 

railways, and respond to disasters. 

CORS alone includes 1,800 wideband receivers owned by NOAA 

and 190 partner stakeholder organizations, and without a suitable 

mitigation for the lower channel LightSquared interference, major 

portions of CORS could cease functioning, forcing NOAA to revert 

to less accurate and much more costly methods to define the National Spatial Reference System. 

LightSquared has stated its belief that filtering can mitigate interference for wideband GPS users. We are concerned that a filter 

capable of blocking out the powerful LightSquared signal at a lower 

channel may also block the GPS signal, rendering our equipment 

useless. This is something that must be tested and, in any event, 

would not be feasible to apply to satellites that are already in 

space. 

Mr. Chairman, we must protect existing GPS users from disruption of services on which they depend. At the same time we recognize the need to use spectrum more efficiently to improve 

broadband access. We recommend further testing of LightSquared’s 

proposal to assess GPS interference in the lower 10 megahertz and 

to establish whether there is any feasible mitigation strategies. 

We appreciate LightSquared’s offer to not transmit in the upper 

10 megahertz and strongly support efforts to identify alternative 

means of achieving the purpose of the signal that was planned 

there. 

Thank you for your attention, and I look forward to any questions. 

[The prepared statement of Ms. Glackin follows:] 

PREPARED STATEMENT OF MS. MARY M. GLACKIN, 

DEPUTY UNDER SECRETARY FOR OPERATIONS, 

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

Mr. Chairman, Ranking Member Johnson, and Members of the Committee, thank 

you for the opportunity to speak today on the importance of the Global Positioning 

System (GPS) to the National Oceanic and Atmospheric Administration (NOAA) and 

the operational impacts we could face as a result of GPS interference from the proposed LightSquared communications network. 

My name is Mary Glackin, and I am the Deputy Under Secretary for Operations 

at NOAA. 

From daily weather forecasts, severe storm warnings, and climate monitoring to 

fisheries management, coastal restoration, and supporting marine commerce, 

NOAA’s products and services support economic vitality and affect more than onethird of America’s gross domestic product. GPS technology is a key enabler for all 
31 

of these activities, integrated into our operational systems and functions across all 

of the line offices at NOAA. 

For this reason, NOAA has been very interested and involved in the recent activities surrounding LightSquared Subsidiary LLC and its conditional authorization to 

broadcast in the 1525–1559 MHz band next to the GPS signal. NOAA contributed 

GPS equipment and experts to both of the major interference testing efforts that 

took place this spring—namely, the Technical Working Group led by LightSquared, 

and the government’s National Space-Based Positioning, Navigation, and Timing 

Systems Engineering Forum. 

Those testing efforts focused primarily on the original LightSquared broadcasting 

plan involving two channels, referred to as the upper 10 MHz and lower 10 MHz 

channels. But both groups also performed initial testing of LightSquared’s modified 

spectrum plan involving only the lower 10 MHz channel. My testimony today will 

address potential effects of both the original and modified LightSquared spectrum 

plans, based on our analysis of the empirical test data collected to date. 

Potential NOAA Impacts of LightSquared’s Original Spectrum Plan 

In response to tasking from the National Space-Based Positioning, Navigation, 

and Timing Executive Committee, we recently conducted an extensive review of 

GPS usage across NOAA, including the National Weather Service, the National 

Ocean Service, the Office of Oceanic and Atmospheric Research, the National Marine Fisheries Service, and the National Environmental Satellite, Data, and Information Service. 

Our review concluded that interference to GPS under LightSquared’s original 

spectrum plan would cause serious performance degradation or a total loss of mission for a wide range of our operational systems, resulting in the loss of critical 

services and potential loss of life and property. These include major satellite, airborne, sea-based, and terrestrial systems used for weather forecasting, climate observation, search and rescue, vessel navigation, nautical charting, emergency response, and geodesy. 

Our entire fleet of meteorological satellites would be put at risk. All of the ground 

stations that control the current GOES (Geostationary Operational Environmental 

Satellite) and POES (Polar-orbiting Operational Environmental Satellite) spacecraft 

depend on GPS for accurate system timing. Without GPS, these ground systems 

would eventually fail to keep proper time, causing widespread errors that degrade 

the quality of satellite-based weather and climate measurements. The result would 

be less accurate warnings of tornadoes, hurricanes, and other severe weather directly affecting U.S. public safety, property, and businesses. Eventually, if the timing errors reach the order of a few microseconds, spacecraft could become unstable 

and we could completely lose the ability to command and control them. 

Likewise, NOAA’s satellite-based search and rescue system, SARSAT, uses multiple GPS receivers at its ground stations to determine and maintain precise time. 

Since 1982, SARSAT has contributed to over 28,000 worldwide rescues—including 

last year’s rescue of Abby Sunderland, the 16-year-old who capsized in the Indian 

Ocean while sailing around the world. SARSAT ground stations use GPS time maintain the clocks on the satellite instruments that relay distress alerts. Without precise GPS time, the accuracy and timeliness of distress alert position calculations are 

significantly impacted. This leads to larger search areas, increased rescue personnel 

and fuel costs, longer response times, and ultimately, greater risk to rescuers and 

persons in distress. 

Our future satellites, including the NPOESS Preparatory Project (NPP) and 

GOES–R, will use on-board GPS receivers for timing and orbit determination. The 

testing to date has shown that LightSquared’s original broadcast could cause interference to GPS equipment in low Earth orbit, where NPP will fly. Our own engineering analysis suggests that it could even affect GOES–R at geostationary orbit, 

since GPS reception is already weak at that long distance. NPP and GOES–R are 

essential to continuing our weather and climate observations; without reliable GPS, 

their data will become almost useless. 

Aside from our satellites, NOAA has deployed over 23,000 environmental sensor 

platforms across the planet that depend critically on GPS for accurate 

georeferencing and time stamping of data. All of the sensor data must be tightly 

bound to the same geospatial and time scales, or it cannot be combined and ingested 

into our weather and climate models. The sensor platforms also require GPS time 

to synchronize their radio transmitters, so they can share limited radio spectrum 

as they relay data via the GOES and POES Data Collection Systems. Prolonged, 

continuous GPS interference at sensor platforms would cause their radios to start 

transmitting at the wrong times, and eventually cease operation. This would cause 
32 

data corruption and gaps, degrading our modeling, forecasting, and disaster warning 

capabilities. Redesigning the radio system and redeploying it to over 23,000 remote 

locations would require new technology whose cost cannot be estimated at this time. 

Similarly, NOAA’s network of NEXRAD weather radars and sea surface radar altimeters require GPS-based time synchronization to enable the sharing of radio frequencies among dozens of radars. The NEXRAD system is critical to issuing timely 

severe storm and flood warnings, and local weather forecasts. The oceanographic 

radar systems measure conditions at the ocean surface and ocean currents to improve weather and climate models, as well as models used to inform search and rescue operations at sea. NOAA used these radars to predict the growth of the Deepwater Horizon oil spill last year. Loss of GPS timing would require either greater 

use of spectrum, which is very unlikely, or loss of current NOAA capabilities. 

NOAA’s radiosondes and dropsondes—instruments we attach to weather balloons 

and drop from aircraft into hurricanes—are entirely dependent on GPS for accurate 

position and velocity measurements. These measurements provide wind speed data 

used for aviation forecasts and as input to global numerical weather prediction models. Widespread interference to GPS would force us to re-engineer these critical systems using alternative methods. These methods would be less accurate and take 

many years to develop and implement. Meanwhile, we would be left with major data 

gaps for numerical weather prediction models, support to air traffic, and hurricane 

forecasts. 

NOAA’s fleet of 19 ships employs a variety of GPS and differential GPS receivers 

for navigation and scientific use. These vessels support oceanographic, atmospheric, 

fisheries and coral reef research, nautical charting, environmental monitoring, and 

ocean exploration. In addition, NOAA has numerous fleets of smaller vessels used 

for research, education, damage assessment, law enforcement, environmental observation, and buoy maintenance. If GPS service becomes unavailable or unreliable 

along U.S. coasts and waterways, NOAA vessels will be unable to perform many operations and missions. 

I have described just a few of the myriad NOAA systems that depend on GPS and 

that would be impacted by GPS interference under LightSquared’s original spectrum plan. 

Potential NOAA Impacts from LightSquared’s Modified Spectrum Plan 

LightSquared’s proposed solution to the problem involves voluntary power limits 

and the postponement of one of its two planned broadcast channels—the upper 10 

MHz bordering the GPS signal. 

Unfortunately, the existing data from the interference testing groups, including 

LightSquared’s own report to the FCC, demonstrates that the new spectrum plan, 

involving the lower 10 MHz channel, still raises issues for high-precision GPS receivers that feature a wideband design. As I mentioned, NOAA participated in this 

testing. Specifically, we provided five different wideband receivers that are representative of the equipment in use at NOAA for high-precision positioning. During 

the tests, four out of the five models failed when subjected to only the lower 10 MHz 

LightSquared channel. Since many critical NOAA operations require high-precision, 

wideband GPS equipment, we support further testing of LightSquared’s proposal 

and continued investigations into mitigation options for wideband applications. 

We have identified at least five major NOAA systems or functions that require 

wideband GPS equipment. These include: 

• (1) the six-satellite COSMIC system that observes the Earth’s atmosphere to 

improve global weather and climate models; 

• (2) the monitoring of sea level trends to protect natural and human communities; 

• (3) the Ground-Based GPS Meteorology (GPS–Met) project, which measures atmospheric moisture to improve short-term weather forecasts; 

• (4) the issuance of the U.S. Total Electron Content (US-TEC) product to inform 

surveyors and other customers about space weather conditions affecting GPS 

accuracy; and 

• (5) the maintenance of the National Spatial Reference System to ensure compatibility among U.S. maps, surveys, and other geospatial products. 

Three of these five activities depend on NOAA’s management of a nationwide network of Continuously Operating Reference Stations, or CORS, which collect and 

share precise data about GPS satellite orbits. CORS provides a consistent positioning technology, accurate to an inch, that is used by millions of people throughout 

the United States, from surveyors to farmers to the FAA. This network is critical 
33 

1 Leveson, Irving. 2009. Socio-Economic Benefits Study: Scoping the Value of CORS and 

GRAV-D. NOAA’s National Geodetic Survey, Washington, D.C. 

to anchoring nautical charts, building roads and railways, surveying airports, and 

responding to natural disasters and other emergencies, such as Hurricane Katrina 

and the Deepwater Horizon oil spill. For example, it allows FEMA flood maps to 

be seamlessly overlaid with levee surveys from the Army Corps of Engineers. 

Unlike consumer GPS devices used for basic positioning, high-precision GPS 

equipment costs thousands of dollars per unit, and the economic value it provides 

to society is similarly high. In the case of CORS alone, there are over 1,800 reference stations, many of which have multiple GPS receivers. This multimillion dollar investment has been made not only by NOAA, but over 190 stakeholder organizations, including states, local communities, universities and other federal agencies. 

They all have a shared interest in maintaining a common standard for geospatial 

positioning in the United States, so the construction and maintenance of roads, 

bridges, railways, inland waterways, and other projects that cross jurisdictional 

boundaries all use the same coordinate system. 

If testing confirms that high-precision GPS receivers are significantly degraded by 

LightSquared’s lower channel, and a suitable mitigation is not developed, major portions of the CORS network could cease functioning. Depending on the geographic 

distribution of the remaining sites, the entire network could fail to serve its intended purpose, forcing NOAA to use less accurate, more labor-intensive, and more 

costly methods such as line-of-sight triangulation to define the National Spatial Reference System. 

For example, the cost to update the International Great Lakes Datum—a water 

level reference system of enormous economic importance to the United States and 

Canada for maritime navigation and shipping—could increase from under $30 million using GPS to $160 million using older methods. In addition, the widespread socioeconomic benefits of CORS use, estimated at $758 million annually, could be lost 

due to interference at CORS sites. 1

Similarly, we must find a way to preserve the high-precision GPS receivers used 

to measure sea level rise, which are subject to the same interference risk as the 

CORS equipment. Monitoring of ecological observations within an accurate and consistent geospatial framework requires high-precision GPS. Losing the availability or 

reliability of this technology would have a profound effect on our ability to monitor 

the impacts of sea level changes and inundation from storms and coastal flooding 

on coastal communities and ecosystems. This would undermine the ability of communities to identify their risk to sea level change and episodic storm events. 

Finally, we have concerns about the COSMIC satellite system that uses the ‘‘GPS 

radio occultation’’ technique to probe the Earth’s atmosphere. We use COSMIC data 

operationally to significantly increase the accuracy of hurricane forecasts and other 

weather models. COSMIC flies in low Earth orbit and would have been impacted 

by LightSquared’s original broadcast plan. The next round of testing needs to assess 

whether wideband receivers in low Earth orbit, including those on COSMIC, are affected by LightSquared’s new plan involving only the lower channel with proposed 

maximum power levels. If they are affected, the mitigation options will be limited, 

as the COSMIC satellites are already in space and cannot be modified.For the wideband GPS receivers that are on the ground, LightSquared has stated its belief that 

new radio signal filtering techniques and/or exclusion zones can mitigate the interference concern for GPS users. Our engineers are concerned that a filter capable of 

blocking out the powerful LightSquared signal at the lower channel may also prevent the receiver from detecting the GPS signal, rendering it useless. This is something that must be investigated thoroughly in the next round of testing, so that 

NOAA does not lose important operational capabilities. If a filter-based solution is 

identified, it must preserve the receiver’s high-precision functionality and it must 

not impose an unreasonable cost burden on NOAA and its partners. Establishing 

exclusion zones to keep LightSquared base stations away from major GPS users 

such as CORS sites may be more feasible, although this creates its own set of problems. 

Conclusion 

Mr. Chairman, the Administration believes that we must protect existing GPS 

users from disruption of the services they depend on today and ensure that innovative new GPS applications can be developed in the future. At the same time, recognizing the President’s instruction to identify 500 MHz of new spectrum for innovative new mobile broadband services, we will continue our efforts at more efficient 

use of spectrum. Therefore, in the short run, we recommend further testing in order 
34 

2 Letter from Lawrence E. Strickling, Assistant Secretary for Communications and Information, U.S. Department of Commerce, to Julius Genachowski, Chairman, Federal Communications Commission, (January 12, 2011). See also, Letter from Lawrence E. Strickling, Assistant 

Secretary for Communications and Information, U.S. Department of Commerce, to Julius 

Genachowski, Chairman, Federal Communications Commission, (July 6, 2011). 

to assess the GPS interference concerns in the lower 10 MHz of the band and to 

establish whether there are any feasible mitigation strategies. We also encourage 

commercial entities with interests to work with LightSquared toward a possible resolution, though any proposed mitigation must be subjected to full testing. The Administration appreciates LightSquared’s offer to not transmit in the upper 10 MHz 

of its band, right next to GPS, and strongly supports efforts to identify alternative 

means of achieving the intended purpose of the signal that was planned there. The 

challenge of meeting the President’s goal also depends on long-term actions by federal agencies in the area of research and development, procurement practices that 

encourage spectrally efficient applications, and new policy development. 

NOAA has communicated our concerns to the National Telecommunications and 

Information Administration (NTIA), the agency that is responsible for managing 

federal agencies’ use of spectrum, and with which the FCC has stated it will consult 

in determining whether the interference concerns raised by this matter have been 

resolved. 

NTIA, on behalf of impacted federal agencies, has previously informed the FCC, 

on two occasions, that the LightSquared proposal ‘‘raises significant interference 

concerns’’ with respect to GPS and GNSS receivers and has urged the FCC to ensure these concerns are resolved before permitting LightSquared to become operational. 2

This concludes my prepared statement. I thank you for your attention and look 

forward to your questions. 

Chairman HALL. And thank you for staying within the five minutes. 

Mr. Sparrow, you may proceed, sir. 

STATEMENT OF MR. VICTOR SPARROW, 

DIRECTOR, SPECTRUM POLICY, 

SPACE COMMUNICATIONS AND NAVIGATION, 

SPACE OPERATIONS MISSION DIRECTORATE, 

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION 

Mr. SPARROW. Okay. Good morning Chairman Hall, Ranking 

Member Johnson, and distinguished Members of the Committee. 

Thank you for inviting NASA to testify on the potential impacts of 

the proposed LightSquared Network on NASA’s scientific and exploration activities. My name is Victor Sparrow, and as you have 

mentioned, I am the Director of Spectrum Policy and Planning for 

NASA. 

My testimony today will focus on some of NASA’s GPS-dependent 

applications and their vulnerability to interference from the proposed network. I have gone into more detail in my written testimony and would be pleased to provide more information on any of 

these applications if needed. 

NASA relies on GPS technology and capabilities to monitor and 

improve our scientific understanding of the Earth, including climate studies and solid earth hazards, such as earthquakes and volcanic activity. This knowledge of our dynamic environment enhances resource management and protection, as well as environmental impact mitigation efforts. 

NASA also uses GPS data for ground-truth calibration, often supported by field measurements. Precise knowledge of their location 

is critical to enable accurate calibration of instruments aboard 

many of NASA’s orbiting earth science spacecraft. 
35 

NASA also collects data used in Unmanned Aerial Vehicles and 

crewed aircraft. For example, NASA recently flew sophisticated 

radar to study the oil disaster in the Gulf of Mexico and the impact 

of the Mississippi River floods on levees and farmlands. These 

UAVs and other aircraft conducting airborne science flights rely 

heavily on GPS data for accurate navigation and critical science 

measurements. 

Spacecraft also use GPS for highly precise navigation. This may 

involve obtaining signals from very low angles, including those 

from just over the horizon. Based on testing and analysis, NASA 

is concerned that powerful signals from a ground-based terrestrial 

network may cause disruption of these signals, degrading the precision of the spacecraft’s orientation. 

The worldwide search and rescue community uses the proposed 

band for downlink messages. There is a new system, the Distress 

Alerting Satellite System, developed by NASA’s Goddard Space 

Flight Center, which is intended to integrate future GPS satellites 

to replace the existing search and rescue system that will be decommissioned in 2016. 

As far as testing is concerned, NASA has participated in several 

efforts to analyze the potential impacts from the proposed network. 

NASA was part of the industry-led TWG and led the work of the 

Space-Based subgroup. NASA also participated in the High Precision Receiver sub-group. 

NASA is also a member of the federal agency National SpaceBased Positioning, Navigation, and Timing or PNT Systems Engineering Forum or NPEF, conducting tests and analysis work to interference to GPS receivers. 

Finally, NASA was involved in the test and analysis efforts conducted by RTCA, an advisory board to the FAA. 

Results of the TWG and NPEF test and analysis efforts indicate 

that significant and harmful interference would occur to terrestrial 

and space-based GPS receivers from the proposed network. NASA’s 

test results firmly support the conclusion at this point that deployment of the LightSquared network would jeopardize NASA’s lowearth orbit and terrestrial-based science missions that are dependent and reliable on GPS reception. Similarly, analysis conducted on 

aviation-based scenarios in the RTCA efforts demonstrated that the 

deployment and operation of the propose network would not be 

compatible with aviation GPS operations. The significant disruption of GPS-based aviation systems would adversely impact NASA’s 

aviation research missions. 

The Technical Working Group considered several mitigation options, none which of yet have been demonstrated to be effective in 

mitigating potential interference to GPS. 

In conclusion, Mr. Chairman, NASA has participated in federal 

agency and industry-led test and analysis efforts related to the deployment of the LightSquared Network and its potential impact to 

GPS. At this time it is clear to NASA that the FCC-imposed condition requiring resolution of GPS interference issues prior to commencing commercial operations has not been satisfied, including 

LightSquared’s modified plan of June 30. Impacts to NASA’s GPSdependent systems from interference created by the network would 

be substantial. It is important to reiterate that NASA fully sup-
36 

ports the Nation’s efforts to increase broadband wireless access, but 

such efforts should be compatible with our critical GPS assets. The 

critical science and engineering applications that GPS makes possible, benefiting Americans in many ways, should not be jeopardized. 

I would like to thank the Committee for its continued support of 

NASA and its programs, and I look forward to answering your 

questions you may have. Thank you. 

[The prepared statement of Mr. Sparrow follows:] 

PREPARED STATEMENT OF MR. VICTOR D. SPARROW, 

DIRECTOR, SPECTRUM POLICY AND PLANNING DIVISION, 

HUMAN EXPLORATION AND OPERATIONS MISSION DIRECTORATE, 

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Good morning Chairman Hall, Ranking Member Johnson, and Members of the 

Committee. Thank you for inviting the National Aeronautics and Space Administration (NASA) to testify today on this very important issue concerning the potential 

impacts of the proposed LightSquared network on NASA’s activities. My name is 

Victor Sparrow, and I am Director of the Spectrum Policy and Planning Division at 

NASA. 

NASA recognizes the importance of maximizing the utility of the radio spectrum, 

and fully supports the President’s Wireless Innovation Initiative and the Executive 

Memo setting a goal of 500 MHz for mobile broadband to achieve this end. This effort is needed to enable the continued growth of, and innovation in, wireless 

broadband capabilities and services. It is important to ensure, though, that projects 

being undertaken to pursue this initiative are compatible with the many Global-Positioning-System-dependent (GPS-dependent) systems that are also critical to the 

Nation. The capabilities, benefits, and innovation of the GPS utility should not be 

degraded or disrupted in the pursuit of increased wireless broadband access. 

My testimony today will focus on some of NASA’s GPS-dependent applications, 

and their significant vulnerability to interference from the network proposed by 

LightSquared and under consideration by the Federal Communications Commission 

(FCC). Impacted systems would include ground-based, airborne, and space-based receivers used to support activities such as: Earth Science research, weather forecasting, disaster monitoring, ground-truth calibration of instruments on orbit, precision navigation for aircraft and spacecraft, and search and rescue efforts. Research 

into the development of future aeronautical applications might be affected, as well. 

The Administration believes that we must protect existing GPS users from disruption of the services they depend on today and ensure that innovative new GPS applications can be developed in the future. At the same time, recognizing the President’s instruction to identify 500 MHz of new spectrum for innovative new mobile 

broadband services, we will continue our efforts at more efficient use of spectrum. 

Therefore, in the short run, we recommend further testing in order to assess the 

GPS interference concerns in the lower 10 MHz of the band and to establish whether there are any feasible mitigation strategies. We also encourage commercial entities with interests to work with LightSquared toward a possible resolution, though 

any proposed mitigation must be subjected to full testing. The Administration appreciates LightSquared’s offer to not transmit in the upper 10 MHz of its band, 

right next to GPS, and strongly supports efforts to identify alternative means of 

achieving the intended purpose of the signal that was planned there. The challenge 

of meeting the President’s goal also depends on long-term actions by Federal agencies in the area of research and development, procurement practices that encourage 

spectrally-efficient applications, and new policy development. 

NASA Science-Related Uses of GPS Technology 

In addition to depending upon GPS to provide robust navigation services, NASA 

relies on GPS technology and capabilities to monitor and improve our understanding 

of Earth science, including climate change and solid Earth hazards, such as earthquakes and volcanic activity. This knowledge of our dynamic environment enhances 

resource management and protection, and environmental impact mitigation efforts. 

Some examples of the use of GPS-dependent space-based applications to improve 

our knowledge of the Earth include: determining the atmosphere’s water content; 

improving the accuracy of weather forecasts; and enabling (as part of a multi-instru-
37 

1 COSPAS-SARSAT is the international satellite search-and-rescue network. COSPAS is an 

acronym for the Russian words 11Cosmicheskaya Sistyema Poiska Avariynich Sudov’’ (‘‘Space 

System for the Search of Vessels in Distress’’), and SARSAT for ‘‘Search And Rescue Satellite 

Aided Tracking.’’ 

ment suite) ocean topography measurements to determine currents and long-term 

changes in sea height. Ground-based GPS networks are also playing an increasingly 

prominent role in monitoring ground movement in order to identify potential conditions that may precede earthquakes and volcanic activity. 

NASA also uses GPS data for ground-truth calibration measurements, often supported by field measurements. Precise knowledge of the location of these measurements is critical to enabling accurate calibration of instruments aboard orbiting 

spacecraft. This important procedure is completely dependent on the availability of 

the in situ GPS location data. Without ground-truth measurements, the resulting 

observations from spacecraft instruments, and interpretations of the data they collect, would be suspect. This application of the GPS system impacts many Earth 

Science missions. 

In addition to data collected from satellites or in situ measurements on the 

ground, data are also collected using Unmanned Aerial Vehicles (UAVs) and crewed 

aircraft. For example, NASA’s highly successful UAV Synthetic Aperture Radar 

project recently flew a sophisticated radar to study the Gulf of Mexico oil disaster 

and the impact of the Mississippi River floods on levees and farmland. These UAVs 

and other aircraft use GPS for navigation. Airborne science flights carrying lidars 

or altimeters rely on GPS data for all the science measurements they obtained. 

Spacecraft also use GPS for highly precise navigation, using as many GPS satellites’ signals as their receivers are able to acquire at one time. This may involve 

obtaining signals from very low angles, including those from just over the receiving 

spacecraft’s ‘‘horizon.’’ Based on testing and analysis of receivers used for a similar 

low look angle scenario (‘‘radio occultation’’ measurements), NASA is concerned that 

powerful signals from a ground-based terrestrial network may cause disruption of 

those signals, degrading the precision of the spacecraft’s orientation. 

NASA uses GPS for weather sensing applications with a technique known as GPS 

radio occultation. This relies on the bending of GPS radio signals by the atmosphere 

as they travel from the GPS satellites in medium Earth orbit to a spacecraft in low 

Earth orbit (LEO). Specifically, this technique is used to estimate the temperature 

and water vapor content of the atmosphere by evaluating the minute changes in the 

GPS signal. These measurements define a vertical profile within the atmosphere. 

This technique, developed by NASA, is now being used operationally by the National 

Oceanic and Atmospheric Administration (NOAA) to improve its long-range weather 

forecasts. 

NASA Support for GPS-Based Search and Rescue (SAR) Efforts 

The worldwide Search and Rescue (SAR) community uses the 1544 MHz band for 

downlink messages. The effects of the LightSquared network on the global SAR capability have not yet been determined. It is critical to test the compatibility of these 

systems before a final regulatory decision is made which might affect future federal 

and international infrastructure plans. NASA is supporting the integration of a 

next-generation SAR capability onto the GPS satellites. The new system, the Distress Alerting Satellite System (DASS), is intended to succeed the existing COSPASSARSAT1 system as it is decommissioned around 2016. DASS is expected to significantly enhance current SAR operations by providing near-instantaneous detection 

and location of emergency beacons (NASA’s Goddard Space Flight Center currently 

hosts a prototype ground station for such applications). 

NASA Aeronautical Research and GPS 

NASA’s aeronautics research supports the development of the FAA’s NextGen air 

traffic system. NASA’s work in this area may or may not be impacted, depending 

on the resolution of the GPS signals interference issue. If the spectrum is not protected for aviation uses, certain GPS-enabled capabilities would not be possible. 

These include advanced Flight Management Systems which would allow for precision positioning and navigation (e.g., area navigation and required navigation performance). Substantial operational efficiencies would be lost (such as improvements 

enabled by Automatic Dependent Surveillance-Broadcast, or ADS–B technologies), 

and the benefits of NASA’s aeronautics research into NextGen applications that assume GPS-enabled precision would not be realized. 
38 

Test and Analysis of LightSquared’s Impacts 

NASA has participated in several efforts to analyze the potential impacts of the 

LightSquared proposal. The Agency was part of the industry-led Technical Working 

Group (TWG), which analyzed and tested GPS receiver performance in the presence 

of interfering signals representing LightSquared terrestrial broadcasts. Specifically, 

NASA led the work of the Space-Based Receiver (SBR) subgroup of the TWG, and 

participated in the work of the High Precision Receiver (HPR) subgroup. 

NASA is also a member of the National Space-based Positioning, Navigation, and 

Timing (PNT) Systems Engineering Forum (NPEF), a federal agency group that performed test and analysis work related to interference to GPS receivers. 

Finally, NASA was involved in the test and analysis effort conducted by the RTCA 

(formerly the Radio Technical Commission for Aeronautics), an advisory body to the 

Federal Aviation Administration. The FAA chartered an RTCA committee to investigate the impact to aviation and NextGen of the LightSquared implementation 

plan. This team concluded that all three phases of the currently proposed 

LightSquared deployment plan are incompatible with aviation GPS operations. 

RTCA concluded that use of the upper 10 MHz band segment should not be allowed 

from an aviation perspective and that use of the Lower 10 MHz channel as a possible mitigation technique would require additional study. 

Results of the TWG and NPEF test and analysis efforts indicate significant and 

harmful interference to terrestrial and space-based GPS receivers from the 

LightSquared network, were it to be deployed as originally intended. NASA’s test 

results support the conclusion at this point that if the LightSquared network were 

to be deployed as originally intended, NASA’s LEO and terrestrial-based science 

missions that are dependent on reliable GPS reception would be jeopardized. Similarly, analysis conducted on aviation-based scenarios in the RTCA effort showed significant disruption of GPS-based aviation systems, thereby impacting NASA aviation research missions. 

Mitigation Options 

Mitigation options for preventing the disruption of GPS by the deployment and 

operation of the LightSquared network, including a proposal to only use the lower 

10 Megahertz (MHz) channel of the planned two-channel deployment, were identified in the TWG and NPEF Reports. However, none of these options have yet been 

demonstrated to be effective in mitigating potential interference to GPS. Although 

limited testing was conducted by the TWG on the susceptibility of some GPS devices 

to the use of only the lower 10 MHz LightSquared channel, limitations— such as 

filters that have yet to be designed or are theoretical or speculative in nature—prevented adequate testing of this mitigation approach. NASA believes it would be premature to allow the use of only the lower 10 MHz channel as a solution, until testing has been completed and it is established that there is no negative impact on 

GPS users. 

Conclusion 

Mr. Chairman, NASA has participated in the federal agency and industry-led test 

and analysis efforts related to deployment of the LightSquared network and its potential impacts to GPS. At the conclusion of these efforts, it is clear to NASA that 

the FCC-imposed condition requiring resolution of GPS interference issues prior to 

commencing commercial operations has not been satisfied, including by 

LightSquared’s modified plan of June 30, 2011. Impacts to NASA’s GPS-dependent 

systems from interference created by the network would be substantial, impacting 

airborne and spaceborne science, as well as certain space operations. It is important 

to reiterate that NASA fully supports the Nation’s efforts to increase wireless access, but those efforts should be implemented in such a way that our critical GPS 

assets, and the many worthwhile, innovative science and engineering applications 

they make possible, are not jeopardized. 

I would like to thank this Committee for its continuing support of NASA and its 

programs. I would be pleased to respond to any questions you may have at this 

time. 

Chairman HALL. Thank you, Mr. Sparrow. 

The Chair now recognizes Mr. Appel. 
39 

STATEMENT OF HON. PETER H. APPEL, 

ADMINISTRATOR, RESEARCH AND 

INNOVATIVE TECHNOLOGY ADMINISTRATION, 

DEPARTMENT OF TRANSPORTATION 

Mr. APPEL. Chairman Hall, Ranking Member Johnson, and distinguished Members of the Committee, thank you for the opportunity to appear before you today. 

The Global Positioning System is vital to multimodal transportation safety and efficiency now and in the future. The Next Generation Air Transportation System or NextGen will use GPS to 

shorten routes, save time and fuel, reduce traffic delays, increase 

capacity, and permit controllers to monitor and manage aircraft 

with greater safety margins. Positive Train Control will increasingly depend on GPS to prevent train collisions and derailments 

and accidents caused by railroad switches left in an incorrect position. 

The Intelligent Transportation System Program for surface 

transportation relies on GPS for vehicle collision-warning and 

crash-avoidance systems. 

To provide the accuracy necessary for precision navigation, GPS 

receivers are designed with a wide front end so precision receivers 

also pick up signals from the adjacent Mobile Satellite Service 

band, the MSS band. 

Until the recent FCC action on LightSquared, this did not create 

a potential conflict. The GPS and MSS bands were both designed 

to be ‘‘quiet,’’ limited to weak satellite signals. GPS receivers easily 

filtered out the MSS signals. 

The Department of Transportation assessed the impact of test results from LightSquared’s original operating plan and concluded 

that the planned use of GPS for NextGen, Positive Train Control, 

and Intelligent Transportation System research and applications 

would not be feasible under this scenario. 

Based on the test results of using both the upper and lower portion of the LightSquared band, aviation use of GPS would be significantly compromised due to the aggregate effect of 40,000 

LightSquared transmitters. This would impact GPS receivers onboard over 60,000 aircraft, resulting in substantial retrofit costs 

and delay. Safety benefits of using GPS for approach and landing 

in all weather conditions and addressing controlled flight into terrain and runway incursions would not be fully realized. 

As a mitigation technique, there would be heavy reliance on 

aging legacy ground-based systems which do not meet the performance requirements for NextGen. The aviation industry also could 

have a demand for a non-U.S. satellite navigation system, such as 

Russia’s GLONASS system, which operates farther away in frequency from LightSquared than does GPS. 

For Positive Train Control, GPS is the least costly method for 

transmitting location information. If GPS were deemed unreliable, 

most railroads would have to switch to transponder-based technology identifying alternative approaches, would significantly delay 

PCT implementation and increase costs. 

The Intelligent Transportation Systems Program and their industry partners have invested many years and millions of dollars 

in safety-based research that leverages GPS to make significant 
40 

improvements in surface transportation crash avoidance. A degradation or loss of GPS will affect the operation of connected vehicle safety applications that will assist drivers in preventing crashes. 

Recently, LightSquared proposed to initially broadcast only on 

the lower 10 megahertz portion of the band in an attempt to avoid 

many of the interference issues. It is important to realize that any 

future use of the upper portion of the band would introduce all of 

the impacts uncovered by the test results previously discussed. Any 

future examinations of LightSquared should be made under the 

paradigm that only the lower 10 megahertz portion of the band will 

be utilized. 

While this scenario may lessen the impacts on aviation and other 

modes of transportation, it is important that the new scenario be 

thoroughly analyzed and tested. High-precision GPS receivers used 

for airfield and flight procedure surveys, flight test tracking, space 

weather monitoring, and timing applications might be impacted. 

The DOT would like to work towards a win-win, if one exists, 

that allows for increased broadband access without disrupting existing and planned GPS-based services. The DOT is also responsible for representing the Space-Based Positioning, Navigation, and 

Timing or PNT interested partner civilian federal agencies, as well 

as our own. Applications which may require access to both GPS 

and MSS signals such as precision agriculture and many scientific 

and surveying systems may be most difficult to resolve. 

We are concerned that if terrestrial broadband transmissions are 

allowed anywhere in the MSS band, they may disrupt existing 

high-precision GPS uses. The Department of Transportation has 

communicated its concerns to the National Telecommunications 

and Information Administration, NTIA, which has expressed concerns to the FCC and has urged that they be resolved before permitting LightSquared to operate. 

Going forward, the Transportation Deputy Secretary, John 

Porcari, has committed the Department to working with NTIA and 

the other federal agencies to ensure that we will have a plan in 

place such that the GPS systems in development now will not be 

compromised by interference in the years to come. 

Thank you very much, and I look forward to answering your 

questions. 

[The prepared statement of Mr. Appel follows:] 

PREPARED STATEMENT OF HON. PETER H. APPEL, 

ADMINISTRATOR, RESEARCH AND

INNOVATIVE TECHNOLOGY ADMINISTRATION, 

U.S. DEPARTMENT OF TRANSPORTATION

Chairman Hall, Ranking Member Johnson, and Members of the Committee: 

Thank you for the opportunity to appear before you today to discuss such an important topic. 

The Global Positioning System (GPS) is one of the greatest success stories of government and private sector innovation. Today, the use of GPS is ubiquitous. No one 

knows exactly how many commercial uses are built around GPS. Worldwide sales 

of GPS navigation devices exceed $20 billion, annually, and an estimated $3 trillion 

worth of commerce relies on GPS for tracking, timing and navigation. 

The United States clearly is the leader in space-based positioning, navigation, and 

timing (PNT) and we must continue to maintain and improve GPS, its augmentations, and backup capabilities. 
41 

GPS is vital to multimodal applications of transportation safety and efficiency. 

The Next Generation Air Transportation System (NextGen) will transform America’s air traffic control system from an aging ground-based system of today to a satellite-based system of the future. NextGen GPS technology will be used to shorten 

routes, save time and fuel, reduce traffic delays, increase capacity, and permit controllers to monitor and manage aircraft with greater safety margins. Positive Train 

Control (PTC) will increasingly depend on GPS to prevent train-to-train collisions, 

train derailments, and accidents caused by railroad switches left in an incorrect position. 

The Intelligent Transportation System (ITS) program will rely on GPS as a key 

technology for vehicle collision-warning and crash-avoidance systems. GPS-based location is also a crucial element of the Next Generation-911 public safety response 

systems currently in development. 

Per U.S. National Space-based PNT policy, the Department of Transportation also 

is responsible for representing the space-based PNT interests of partner civilian federal agencies, as well as our own. These applications include millions of GPS receivers used for precision agriculture and scientific and surveying systems such as those 

that NASA, NOAA, Department of the Interior, and others rely on. 

To provide the accuracy necessary for precision navigation, GPS receivers have 

been designed with a ‘‘wide front end’’ that pick up signals greater than the band 

authorized for GPS. In order to pick up this wide range of signals, precision receivers also pick up signals from the adjacent band, reserved for Mobile Satellite Service 

(MSS). 

Until recently, this did not create a conflict. The GPS and MSS bands were both 

designed to be ‘‘quiet,’’ limited to weak satellite signals, a tiny fraction of a watt 

when they reached the Earth. GPS receivers easily filtered out the MSS signals. 

In January 2011, the Federal Communications Commission (FCC) approved the 

application of LightSquared to broadcast broadband signals in the MSS band, contingent on LightSquared resolving potential interference to GPS. The LightSquaredled Technical Working Group (TWG) performed measurements and submitted its results and findings to the FCC on June 30th. 

Technical staff from the Federal Aviation Administration (FAA) participated in 

the TWG testing. In addition, the FAA commissioned RTCA, Inc. to study the impact of LightSquared’s proposed operations on aviation. The Department of Transportation also participated in a joint federal study—the National Space-Based PNT 

Engineering Forum (NPEF)—to assess the impact on a broad range of common government and commercial GPS receivers. 

The tests, based on the original operating plan that LightSquared had submitted 

to the FCC, focused on ‘‘overload interference’’—interference with the GPS receivers 

that ‘‘listened in’’ to the adjacent MSS band. The powerful broadband signal overwhelmed filters and effectively blocked GPS signals in almost all of the devices tested. 

The Department of Transportation assessed the impact of these test results from 

LightSquared’s original operating plan and concluded that the planned use of GPS 

for NextGen, Positive Train Control, and Intelligent Transportation System research 

and applications would not be feasible under this scenario. 

Based on the test results of using both the upper and lower portion of the 

LightSquared band— the original LightSquared operating plan—aviation use of 

GPS would be significantly compromised due to the aggregate effect of 40,000 highpower LightSquared transmitters. This would impact GPS receivers onboard over 

60,000 aircraft, resulting in substantial retrofit costs. Benefits of providing more direct routes and improving capacity, as well as safety benefits of using GPS for approach and landing in all weather conditions, and addressing controlled flight into 

terrain and runway incursions, would not be fully realized. 

As a mitigation technique, there would be heavy reliance on aging legacy groundbased systems which do not meet the performance requirements for NextGen. The 

aviation industry also could have a demand for a non-U.S. satellite navigation system, such as Russia’s GLONASS system, which operates farther away in frequency 

from LightSquared than does GPS. 

The FAA has initiated an Alternative Positioning, Navigation, and Timing (APNT) 

research program to identify technologies that meet the requirements of NextGen 

in the event that GPS is disrupted. 

Other transportation applications that rely on GPS also would be affected. For 

Positive Train Control, use of GPS is the least costly method for transmitting location information. If GPS were deemed to be unreliable, most railroads would have 

to switch to the transponder-based technology such as that used for the Advanced 

Civil Speed Enforcement System (ACSES) currently in place on the Northeast Corridor. 
42 

1 Letter from Lawrence E. Strickling, Assistant Secretary for Communications and Information, U.S. Department of Commerce, to Julius Genachowski, Chairman, Federal Communications Commission, (January 12, 2011). See also, Letter from Lawrence E. Strickling, Assistant 

Secretary for Communications and Information, U.S. Department of Commerce, to Julius 

Genachowski, Chairman, Federal Communications Commission, (July 6, 2011). 

A need to identify alternate and complementary sources for positioning, navigation, and timing would result in significant increases in PTC implementation time 

and costs. 

The Intelligent Transportation Systems Joint Program Office and their industry 

partners have invested many years and millions of dollars in safety-based research 

that leverages GPS to make significant improvements in surface transportation 

crash avoidance. A degradation or loss of GPS will affect the operation of Vehicleto-Vehicle and Vehicle-to-Infrastructure applications that provide the location and 

speed of other vehicles assisting drivers in preventing crashes, thereby reducing the 

substantial number of fatalities and injuries that occur each year. 

On June 30th, LightSquared submitted a Recommendation Paper to the FCC proposing to initially broadcast only on the lower 10 MHz portion of the band in an 

attempt to avoid many of the interference issues. LightSquared plans to ‘‘standstill’’ 

on use of the upper portion of the band. It is important to realize that any future 

use of the upper portion of the band would introduce all of the impacts uncovered 

by the test results previously discussed. As a result, any future examinations of 

LightSquared should be made under the paradigm that only the lower 10 MHz portion of the band would ever be utilized for the proposed high-power terrestrial transmitters. 

While this scenario may lessen the impacts on aviation and other modes of transportation, it is important that the new scenario—at which LightSquared only operates at the lower 10 MHz portion of its spectrum—be thoroughly analyzed and tested to determine any impact to GPS performance. 

The FAA is concerned that high-precision GPS receivers used for airfield and 

flight procedure surveys, flight test tracking, space weather monitoring, and timing 

applications might be impacted. Also, applications which require access to both GPS 

and MSS signals such as precision agriculture may be the most difficult to resolve. 

The Department of Transportation would like to work towards a ‘‘win-win’’—if one 

exists— that allows for increased broadband access, without disrupting existing and 

planned GPS-based services, such as NextGen. 

However, we are concerned that if terrestrial broadband transmissions are allowed anywhere in the MSS-band, they will disrupt existing GPS uses including 

precision agriculture and many scientific and surveying systems such as those that 

NASA, NOAA, Department of the Interior, and others rely on. 

The Department of Transportation has communicated its concerns to the National 

Telecommunications and Information Administration (NTIA), the agency that is responsible for managing federal agencies’ use of spectrum, and with which the FCC 

has stated it will consult in determining whether the interference concerns raised 

by this matter have been resolved. NTIA has advised the FCC that the 

LightSquared proposal ‘‘raises significant interference concerns’’ and has urged the 

FCC to ensure these concerns are resolved before permitting LightSquared to become operational. 1

The Department of Transportation will look for solutions to the challenges of our 

partner agencies, as well as our own, in interagency discussions. Going forward, 

Deputy Secretary John Porcari has committed the Department to work with NTIA 

and the other federal agencies to ensure that we have a plan in place such that the 

GPS systems in development now will not be compromised by interference in the 

years to come. 

The Administration believes that we must protect existing GPS users from disruption of the services they depend on today and ensure that innovative new GPS applications can be developed in the future. At the same time, recognizing the President’s instruction to identify 500 MHz of new spectrum for innovative new mobile 

broadband services, we will continue our efforts at more efficient use of spectrum. 

Therefore, in the short run, we will participate in any further testing or analysis 

required to establish whether there are any mitigation strategies that can enable 

LightSquared operation in the lower 10 MHz of the band. We also encourage commercial entities with interests to work with Lightsquared toward a possible resolution, though any proposed mitigation must be subjected to full testing. The challenge of meeting the President’s goal also depends on long-term actions by federal 

agencies in the area of research and development, procurement practices that encourage spectrally efficient applications, and new policy development. 

Thank you and I look forward to answering your questions. 
43 

Chairman HALL. I thank you very much, and our next—who is 

next up? Dr. Applegate for five minutes. Thank you, sir. 

Mr. APPLEGATE. Thank you. 

STATEMENT OF DR. DAVID APPLEGATE, 

ASSOCIATE DIRECTOR, NATURAL HAZARDS, 

U.S. GEOLOGICAL SURVEY, U.S. DEPARTMENT 

OF THE INTERIOR 

Dr. APPLEGATE. Well, Chairman Hall, Ranking Member Johnson, 

and Members of the Committee, I want to thank you for the invitation to testify at this hearing. I am the Associate Director for Natural Hazards at the U.S. Geological Survey, and we are the science 

agency for the Department of the Interior. 

The Department has significant concerns about the proposed 

LightSquared system, which could have negative impacts on the reception of Global Positioning System signals. The USGS and our 

colleagues across Interior make extensive use of GPS technology. 

Testing performed this year on LightSquared’s original deployment 

plan has failed to demonstrate the satisfactory effectiveness of mitigation techniques. Proposed alternatives, meanwhile, require further testing to be fairly judged. The Department feels that the proposal should not be approved at this time. 

The USGS and our sister bureaus at Interior face a wide range 

of potential impacts from GPS interference. Many Interior bureaus 

have law enforcement and public safety missions, for example, Interior Department police officers and fire crews use GPS for navigation in both remote back country and urban settings. 

At the USGS GPS is an essential tool for many of our mission 

responsibilities, including streamgaging, mapping and surveying, 

and in my area of responsibility, natural hazards monitoring and 

research. 

Streamgages and water quality monitors operated by the USGS 

and our partners provide data used to manage water resources, to 

forecast floods and droughts, and for many other purposes. GPS 

signals are used to calibrate these streamgages. In addition, modern streamgages have radios that use the GPS timing signal to 

make near real-time transmission of data possible. There are about 

9,000 of these radios in use, and without them the quality of data 

from the streamgages would be diminished. Losing those capabilities would reduce the accuracy of National Weather Service flood 

forecasts and would likely diminish the ability of the Army Corps 

of Engineers to minimize flood damage. 

With respect to our mapping mission, nearly all of the mapping 

data collected today involves the use of GPS. All modern airborne 

or satellite-based systems are dependent on GPS for navigation, position, and geolocation of the data. LiDAR technology can determine elevation to within centimeters but requires equally precise 

GPS positioning data to validate it. 

Nowhere is our stake in this issue more significant than in our 

natural hazards mission. Under the Stafford Act, the USGS issues 

warnings and forecasts for earthquakes, volcanoes, and landslides, 

and we support other agencies, especially NOAA, for a host of other 

threats. All of these responsibilities depend on reliable, redundant 

monitoring infrastructures. 
44 

For rapid reporting of earthquakes and their impacts, the USGS 

relies on our Advanced National Seismic System here in the U.S. 

and the Global Seismographic Network worldwide, which we maintain in cooperation with the National Science Foundation and the 

IRIS Consortium. The 2,500 seismic sensors in these networks use 

GPS for precise timing, and a small change in the timing signal, 

even just a few stations, can degrade the accuracy of our response 

products. 

Our ability to monitor deformation of the earth’s crust requires 

the most precise, accurate, and reliable GPS signals. With our university cooperators, along with the National Science Foundation 

and the UNAVCO Consortium, we maintain and use over 1,000 

permanent continuously operated GPS stations to monitor ground 

deformations along faults like the San Andreas. Dense networks of 

these high-data rate, high-precision GPS stations are particularly 

important for earthquake monitoring in at-risk urban areas in 

Southern California, the San Francisco Bay Area, and the Pacific 

Northwest. 

Our network of volcano observatories relies on real-time data 

from 220 continuously reporting GPS stations in order to forecast 

and detect eruptions for volcanically active areas across the Western U.S. These GPS instruments provide unique information, 

which are not often available from other monitoring methods and 

almost never with the near real time availability provided by GPS. 

Losing our GPS monitoring capabilities would result in a severely 

decreased ability to provide early as possible warning of volcanic 

unrest. This would be a significant public safety concern for communities near volcanoes, such as those in the Pacific Northwest 

and Alaska. It is also a concern for air traffic to the hazard of volcanic ash. 

GPS has become so pervasive that it risks being taken for granted. Many of these applications are critical, even fundamental, to 

the missions of the USGS and the Department of the Interior. The 

Department is committed to the development of solutions that ensure no loss of critical national security capabilities, including GPS. 

We look forward to working with our federal partners as well as 

Congress to address long-term solutions regarding a balance between federal spectrum requirements and the expanding demand 

for mobile broadband services. 

Thank you again for your attention to this important matter, and 

I would be happy to answer your questions. 

[The prepared statement of Dr. Applegate follows:] 

PREPARED STATEMENT OF DR. DAVID APPLEGATE, 

ASSOCIATE DIRECTOR FOR NATURAL HAZARDS, 

U.S. GEOLOGICAL SURVEY, U.S. DEPARTMENT OF THE INTERIOR

Chairman Hall, Congresswoman Johnson, thank you for inviting me to this hearing. My name is Dave Applegate. I am the Associate Director for Natural Hazards 

at the U.S. Geological Survey (USGS). The USGS is the science agency for the Department of the Interior (DOI). 

As you already know, the Department has significant concerns about the proposal 

for a satellite communications system being developed by the firm LightSquared. 

The proposed system could have negative impacts on the reception of Global Positioning System signals, or GPS. The USGS and our colleagues across DOI make extensive use of GPS technology—some of our work is entirely dependent upon it. 

Testing performed this year on LightSquared’s original deployment plan has failed 
45 

to demonstrate the satisfactory effectiveness of mitigation techniques. Proposed alternatives, meanwhile, require further testing to be fairly judged. The Department 

of the Interior feels that the proposal should not be approved at this time and has 

expressed this position to the National Telecommunications and Information Administration, which represents the spectrum interests of the Federal agencies before the 

Federal Communications Commission. 

I am, of course, most familiar with the uses of high-precision GPS technology in 

the fields related to my charge of natural hazards research and monitoring. However, DOI, the USGS, and our sister bureaus have identified a wide range of impacts of potential GPS interference to capabilities used for mapping, navigation, and 

timing. Many Interior bureaus have law enforcement and public safety missions, including a significant role in wildfire response nationwide. Law enforcement officers 

and fire crews use GPS for navigation in both remote backcountry and urban areas. 

Any degradation of GPS signal could make it more difficult for personnel to navigate. They would have to revert to navigating by ‘‘pencil-and-map.’’ 

Miscommunication and delays also would be a life-safety risk for personnel and the 

public. It is even possible that investigations by Department law-enforcement agents 

could be called into doubt due to the greater inaccuracy of manual geolocation techniques. 

For our part at the USGS, GPS technology is an essential tool for many of our 

mission responsibilities. Some examples include streamgaging, mapping and surveying, and in my area of expertise, geologic hazards. 

Streamgages and water quality monitors operated by the USGS and its partners 

provide data used to manage water resources, forecast floods and droughts, inform 

the design and operation of dams, levees, water—and wastewater treatment plants, 

and irrigation systems, and the regulation and monitoring of water pollution and 

its impacts. GPS signals in mobile applications are used to accurately position flowmeasuring equipment and obtain data needed to calibrate streamgages. In addition, 

modern streamgages have radios that use the GPS timing signal to make near realtime transmission of data possible. There are about 9,000 of these radios in use and 

without them the quality of data from the streamgages would be diminished. The 

impact of losing the capabilities of these radios is varied and significant. For example, it would reduce the accuracy of National Weather Service flood forecasts and 

would likely diminish the ability of flood-fighting agencies such as the Corps of Engineers to minimize flood damage. The confidence and timeliness of water-management decisions made by states, the Bureau of Reclamation, and the Army Corps of 

Engineers could also be impacted. Since 2009, the USGS has invested $11.5 million 

in GPS-based satellite radios and 91 acoustic doppler current profilers. Without the 

GPS-driven streamgage satellite radios, the increase in costs will approach $6.6 million per year based on the expense of periodically resetting physical clocks at each 

streamgage. 

As with our work to better understand water resources, the USGS relies on strong 

partnerships to fulfill our mapping missions. The science and craft of mapping have 

come a long way since this USGS mission began in the late 19th Century. Today, 

nearly all of the data collected involves the use of GPS. All modern airborne or satellite-based systems are dependent on GPS for navigation, positioning and 

geolocation of the data. Ortho-rectified imagery needs GPS to reliably determine the 

location of each image. LiDAR technology, meanwhile, can determine elevation to 

within centimeters, but requires equally precise GPS positioning data to validate it. 

High-precision LiDAR data are also useful in my field because the technology can 

reveal hidden faults, map out ancient landslides, and determine the shape of volcanoes in unprecedented detail. Since 2008, USGS has made between $18 million and 

$20 million in lidar acquisition purchases per year. The 2010 total was over $40 million, including a substantial investment of Recovery Act funds. 

Nowhere is our stake in this issue more significant than in our mission responsibilities for natural hazards. Under the Stafford Act, the USGS issues warnings 

and forecasts for a variety of geologic hazards, and we support other agencies for 

a host of other threats. All of these responsibilities depend on reliable, redundant 

monitoring infrastructures, like networks of seismometers or streamgages. 

For rapid reporting of earthquakes and their impacts, the USGS relies on our Advanced National Seismic System (ANSS) here in the U.S. and the Global Seismographic Network (GSN) worldwide, in cooperation with the National Science 

Foundation and IRIS Consortium of universities. The 2,500 seismic sensors in these 

networks use GPS for precise timing, and a small change in the timing signal at 

even just a few seismic stations can degrade the accuracy of earthquake’s location, 

and hence all downstream response products. 

Our ability to monitor deformation of the Earth’s crust requires the most precise, 

accurate, and reliable GPS signals. We and our university cooperators, along with 
46 

the National Science Foundation and UNAVCO consortium, maintain and use over 

1,000 permanent continuously operating GPS stations to track plate motions and 

monitor ground deformation due to earthquakes along faults like the San Andreas 

and hundreds of others nationwide. Dense networks of high data rate, high-precision GPS stations are particularly important for earthquake monitoring for at-risk 

urban areas in southern California, the San Francisco Bay Area, and the Pacific 

Northwest. The estimated capital cost of the USGS investment in these geodetic 

networks is $26 million, including $6 million in Recovery Act funds used to upgrade 

existing networks. For the NSF Earthscope project alone, GPS network capital costs 

are about $100 million and current operation and maintenance costs are $11 million 

yearly. UNAVCO expert analysis shows that this NSF investment would be put in 

jeopardy if the LightSquared Network is given approval to proceed. 

Our network of volcano observatories relies on real-time data from 220 continuously reporting GPS stations in order to forecast and detect eruptions for 

volcanically active areas around the western United States. These GPS instruments 

provide unique information on the location of magma and the size of an impending 

eruption, which seismic or other types of data do not. The impact of interference 

of GPS signals on the monitoring of U.S. volcanoes would be substantial. The threedimensional deformation data gathered from continuously recording GPS stations 

are often not available from any other monitoring method, and almost never with 

the near-real-time availability provided by the GPS networks. We now rely on our 

GPS monitoring capabilities, and losing these would result in a severely decreased 

ability to perform our duties in providing earliest possible warning of volcanic unrest. This would be a significant public safety concern for communities near volcanoes, such as those in the Pacific Northwest and Alaska. It is also a concern for 

air traffic in the northern Pacific Ocean due to the hazard of volcanic ash, a hazard 

that was recently demonstrated by the eruption of Icelandic volcanoes. Similar technology is used to monitor 16 potential landslide sites. The USGS capital investment 

in GPS receivers currently used for volcano monitoring is $3.5 million of which $1.5 

million came from Recovery Act funds. 

Recent testing has demonstrated that reception of the L1 signal, the civilian-use 

band of frequencies, by high-precision receivers used by DOI is significantly degraded when exposed to the proposed LightSquared signals tested thus far (recently 

proposed alternatives will require further testing to be sufficiently understood and 

fairly judged). Given the wide use of such receivers and the uncertainty of technical 

fixes, it is impossible to predict exactly how much it would cost to replace these receivers. The Department estimates that it has invested about $100 million in the 

technology and it could cost as much as $500 million to replace it. Also, there could 

be a cost in lost situational awareness and ongoing scientific research. 

GPS is vitally important in acquiring virtually every type of spatially referenced 

data in use today. It has become so pervasive that it is taken for granted. Many 

of these applications are critical-even fundamental-to the missions of the USGS and 

the Department of the Interior. A short-term requirement for replacement or modification would be chaotic and expensive; a gradual upgrade would require adequate 

funding, careful planning, and several years. 

The Department fully supports the national economic and security goals of the 

President’s 500 MHz initiative and is committed to the implementation of more effective and efficient use of the finite radio frequency spectrum and the development 

of solutions that ensure no loss of critical National Security capabilities, to include 

GPS. The Department will continue to work with its Administration partners and 

NTIA, as well as with Congress, to address long-term solutions regarding a balance 

between federal spectrum requirements and the expanding demand for mobile 

broadband services.Thank you again for inviting me today and for your attention 

to this important matter. I would be happy to answer any questions you may have. 

Chairman HALL. I thank you, sir, and Mr. Carlisle, you may proceed, sir. 

STATEMENT OF MR. JEFFREY J. CARLISLE, 

EXECUTIVE VICE PRESIDENT, REGULATORY AFFAIRS 

AND PUBLIC POLICY, LIGHTSQUARED 

Mr. CARLISLE. Chairman Hall, Ranking Member Johnson, Members of the Committee, thank you very much for giving me the opportunity to speak with you today about this issue. 
47 

We are going to make a major investment in U.S. infrastructure, 

and let me be extremely clear about this. We are not going to implement that investment in a way that will degrade or destroy 

GPS. Nor do we believe that the FCC would ever allow us to do 

so. This is not a zero sum game. Americans do not have to choose 

between a robust GPS and a competitive broadband wireless network. They can have both, because this is an issue of responsible 

receiver design and coordination of the network. It is a technical 

issue that can be solved just as it is solved every time anybody deploys a wireless network in the United States. As was mentioned earlier, we are investing $14 billion over the 

next eight years in deploying this network. This investment also includes support of our satellite, which was launched last November, 

which in and of itself was a $1 billion investment in American 

technology leadership. Part of that investment was $250 million in 

space technology that have never been invented yet, and as a result 

we have the largest commercial dish ever launched into space anywhere. 

Now, why did we make this investment, and why are we committing to invest more? Because the certainty of the FCC regulatory 

regime allowing us to deployment a ground-based network and this 

was not developed within the last few months as it is sometimes 

portrayed. This was actually the result of a four-year process that 

the FCC conducted from 2001, to 2005, and I have detailed this 

process in my testimony, but I will just emphasize a few points 

here. 

This process resulted—there was the—there were the original 

rules, there was out authorization under the rules in—the original 

rules were written in 2003, we were authorized in 2004, and the 

rules were reconsidered in 2005. That reconsideration is relevant 

for a very specific point. In that reconsideration in 2005, the FCC 

did two things. It removed any limit on the number of base stations 

or cell towers we could deploy in our network. It also established 

a power level of 1.6 kilowatts for those base stations. That is what 

we tested, that is what we are using, and that is what we have 

committed to use going forward. 

Also as part of this process it included the GPS manufacturers, 

and it included review at every one of these steps; 2003, 2004, 

2005, by NTIA’s interdepartmental committee that review—interagency committee that reviews all decisions by the FCC that have 

a potential impact on federal spectrum. The agencies here today 

can have—can and have made their concerns known through that 

committee on any number of spectrum issues, including this one. 

So why was that last issue relevant? Well, during the process 

from 2001 to 2005, the GPS industry said that the only issue that 

we were supposed to be worried about was our signal going into 

GPS, that it was powerful, it was going to taper off into GPS and 

overwhelm the GPS signal. We reached an agreement in 2002 to 

prevent that. Our signal is filtered so it doesn’t taper off into GPS. 

The issue of receiver sensitivity where the receivers or receiver 

overload where the receivers look into our band, so it doesn’t matter what kind of filtering we put in, they can still be overloaded 

by our transmitters, that was never raised during this four-year period. It was first raised by the GPS Industry Council in September 
48 

of last year after we had already committed $4 billion of investment to this project on the basis of the rules that had been written 

six years previously. 

So where are we today? We are moving forward with the proposal that has been discussed. We are moving to the other end of 

the GPS spectrum at a cost of $100 million to the company. We are 

reducing our power by 90 percent, not 50 percent. Ninety percent 

to the levels established in 2005, and this week we also discussed 

limiting the power that will reach the ground so that we will not 

interfere with the vast majority of devices. We will also fund research into resilient precision devices and coordinate the deployment of our network to avoid interference with them. 

We are committed to solving this issue, because if we get it 

wrong, Americans won’t have access to another competitive 

broadband network. They will basically have two, and that is a 

pretty big stake right now, particularly for jobs, education, and scientific progress in the United States. 

Thank you very much for you time, and I look forward to answering your questions. 

[The prepared statement of Mr. Carlisle follows:] 

PREPARED STATEMENT OF MR. JEFFREY J. CARLISLE, 

EXECUTIVE VICE PRESIDENT, 

REGULATORY AFFAIRS AND PUBLIC POLICY, LIGHTSQUARED 

My testimony today will explain the network that LightSquared is building, extensive interference testing, and steps that LightSquared plans to take to mitigate 

interference. LightSquared is investing billions of dollars in American infrastructure, in order to bring competitive wireless broadband service across the country. 

We will do so in a way that protects the GPS-related work of the agencies under 

this Committee’s jurisdiction. Indeed, LightSquared is in very much the same position as the agencies testifying before you today. We find long-planned and long-authorized operations threatened because the manufacturers of GPS devices have been 

building and selling receivers that ignored rules the FCC established in 2003 and 

2005 with their knowledge, and without their opposition. Nevertheless, 

LightSquared is committed to working with the Committee and the agencies to do 

our part in addressing a problem we did not create, and we have already made substantial and real proposals. The interference issue is a question of technology choice, 

and can be addressed through proper design. 

I. Lightsquared Is Building Critical Infrastructure for the 21st Century 

LightSquared is investing $14 billion over the next eight years to build a nationwide wireless broadband network. This investment will support over 15,000 jobs a 

year for each of the five years that it will take to construct this network. When completed, our ground network will provide over 260 million people with wireless 

broadband service at expected speeds of 5 to 10 megabits per second. The ground 

network will provide the scale needed to make our new high-power satellite system 

viable over the long term, which will provide disaster-resistant service to a new generation of user devices that are the same size, weight, and cost as today’s terrestrial 

mobile devices. LightSquared’s network promises to increase competition in the 

marketplace, give consumers new choices, broaden access to broadband, increase 

public safety and emergency response, and, ultimately, lower prices. 

This network is the culmination of years of hard work and billions of dollars of 

investment. LightSquared has been authorized to use spectrum for mobile satellite 

services (MSS) since 1989, and launch its first satellite in 1996. For the last 15 

years, it has provided voice and data services over its satellites to federal, state and 

local governments, transportation and maritime industries, and others who need reliable communications when a ground network is unavailable. 

In 2003, the FCC first issued rules authorizing the use of satellite spectrum for 

ground networks. The FCC issued an authorization to LightSquared’s predecessor 

in 2004, and finalized the spectrum rules in 2005 on reconsideration. Since then 
49 

LightSquared has worked hard to bring its network to market. It coordinated spectrum and developed technology to support an integrated satellite and ground network. 

Now we are ready to move forward, and this investment is coming at a particularly crucial time. The U.S. ranks 15th in the world when it comes to broadband, 

according to a recent Cisco survey. Congestion in urban markets is leading to an 

unacceptable level of dropped calls and ‘‘no service’’ displays. At the same time, 

many consumers in rural America don’t even have a wireless broadband option: 28 

percent of people who live in rural America still have no access to broadband. This 

puts rural communities at a disadvantage when it comes to attracting new businesses, creating jobs and gaining access to education. 

Wireless infrastructure in the U.S. is manifestly unready to meet the challenges 

of the 21st century. The U.S. is seeing the beginning of almost vertical growth in 

data usage. Data usage in the will jump from under 2 million terabytes per year 

to almost 14 million terabytes in 2015. Spectrum is needed to carry that data, and 

spectrum is severely limited. 

The FCC has already identified a need for at least 500 MHz of additional spectrum to be freed for broadband use over the next 10 years. We are bringing 40 MHz 

of spectrum to be used for broadband services—a significant down payment on the 

FCC’s 10-year goal. No other company has such a significant slice of airwaves that 

is ready to deliver network capacity to our spectrum-starved nation, and no other 

company could conceivably offer this broad coverage in the same time frame. 

It is important to understand that LightSquared will do this in a way that is completely different from other wireless companies in two ways. 

First, LightSquared will be the only wireless broadband network with an integrated satellite. Our first satellite was launched in November 2010, with the largest 

dish ever placed on a commercial spacecraft—seven stories tall. This represented a 

$1 billion investment in U.S. space technology. Our satellite allows a smartphone, 

tablet, data stick, or other device to link to the satellite when the ground network 

is not available, either because the device is out of range, or when ground networks 

have been destroyed by natural disasters. LightSquared already has a history of 

providing satellite communications in the places they are needed most: in Mississippi after Hurricane Katrina; in Kentucky after widespread and destructive ice 

storms; in Joplin, Missouri after its tornado; and in Maryland, Delaware, and Virginia after Hurricane Irene. The size and cost of satellite-enabled devices, assuming 

we can take advantage of the scale offered by the ground network, will be the same 

as that of regular cellular devices. This is why the deployment of the ground network is so critical. A sustainable, reliable satellite function promises substantial 

long-term benefit to government, public safety, and individual consumers. 

Second, LightSquared will be the first wholesale-only network. We will sell capacity to wireless companies, retailers and other companies that want to provide 

broadband services, and they can then provide the integrated network to their consumers. Thus, when we build our network, we’re not just enabling LightSquared as 

a competitor, we’re enabling dozens of competitors in the marketplace. 

In sum, then, what LightSquared is doing is making a massive private investment 

in critical U.S. infrastructure, making better and more efficient use of spectrum, 

and enabling wireless competition, all to the benefit of American consumers, public 

safety, and the nation as a whole. 

II. GPS Interference Has Been Studied Comprehensively 

Part of LightSquared’s spectrum is directly adjacent to the spectrum used by GPS. 

This is not a new development. When LightSquared’s predecessor first proposed 

using satellite spectrum for a ground network over 10 years ago, the GPS community, represented by the US GPS Industry Council (USGIC), asked us to voluntarily 

limit our energy that could bleed over into the GPS band. If we did nothing, comparatively powerful base stations used in cell sites would drown out faint GPS signals. We agreed to limits on emissions out of our band into GPS that were 1,000 

times stricter than what the FCC required, and designed our network around this 

agreement. Moreover, the power levels we are using today in our base stations are 

the same as what the FCC authorized in 2005, and we have committed to stay at 

those levels. I have attached a chronology, with citations to the public record, as Attachment 1 to my testimony. 

The current concerns about interference do not stem from a concern about emissions into the GOPS band. Instead, in September 2010, the USGIC raised a new 

and different issue arising out of the fact that certain GPS receivers are designed 

to not only capture GPS signals, but also capture signals from our band and could 

be desensitized, or overloaded. Accordingly, no matter how strictly we limited our 
50 

out of band emissions, we could still cause overload of some GPS receivers. I have 

provided illustrations showing this effect as Attachment 2 to my testimony. 

Much of the advocacy by the GPS manufacturers over the last nine months has 

tried to portray this issue as having arisen only this year because LightSquared 

somehow changed the ‘‘nature’’ of its network. This narrative has been stated and 

restated with a purpose: to distract lawmakers from the fact that GPS manufacturers failed to raise this issue at the FCC when it was developing its rules and could 

have addressed this issue in the design of their receivers years ago. In 2005, they 

knew that the FCC rules allowed LightSquared to deploy tens of thousands of base 

stations in our band, all broadcasting at a power of 1.5 kw. Thus, if LightSquared’s 

predecessor had had the resources to build its network at that time, it could have 

built exactly the same network as is planned today. Indeed, in 2003, the USGIC 

stated to the FCC that the effect of their rules was to allow us to use tens of thousands of base stations. (See Attachment 1 for citation.) 

The GPS community’s convenient story that we caused the problem because we 

asked for a modification to the types of end user devices that could be brought to 

our network is easily demonstrated to be false. End user devices have nothing to 

do with the overload effect the GPS community identified—it is entirely a function 

of the number and power of our base stations, which as I stated above was established in 2005. Moreover, as I stated above, the GPS community raised this issue 

in September 2010, two months before we asked for any modification for end user 

devices. Finally, the USGIC did acknowledge, eight years ago, that we would operate tens of thousands of base stations in our band. The possible scale and scope of 

our use of the network was well known by, or at least obvious to, any of the large 

companies that manufacture GPS receivers, all with presences in Washington, and 

yet they did nothing. This, despite the fact that the Department of Defense’s standards for use of the GPS constellation specify that manufacturers should use a receiver that filters out signals from adjacent bands if they expect to have full performance. 

Notably, the original rules in 2003, our authorization in 2004, and the reconsideration of those rules in 2005 were all subject to full review by the NTIA’s Interdepartment Radio Advisory Committee process, which includes input from all impacted federal agencies. Thus, when the FCC issued decisions allowing us to deploy 

tens of thousands of base stations, all transmitting at the powers we will use today, 

federal agencies had extensive and repeated opportunities for comment and input. 

Of course, as users of GPS devices, it is extremely difficult, if not impossible, for 

federal agencies to study this issue fully without the support and involvement of the 

GPS receiver manufacturers. The manufacturers’ failure to identify the overload 

issue until a year ago may well explain why Federal Government users did not raise 

this issue earlier. 

In the end, the GPS manufacturers either failed to understand the vulnerability 

of their own receivers or took the calculated risk that LightSquared would not be 

able to complete its network. Either way, they did nothing to prepare their receivers 

or their users for the changed spectrum environment. 

Despite the history of this issue, the fact remains that many receivers were placed 

into the stream of commerce that were not going to be compatible with the uses established by the FCC in 2003 and 2005. If LightSquared was going to be able to 

move forward with its network within any reasonable period of time, the responsible 

thing to do would be to test to determine the scope of the issue and possible mitigation. This is exactly what the FCC did when, in January of this year, it ordered 

us to work with the GPS community and federal agencies on joint testing. 

What followed is perhaps the most extensive study of interference ever conducted. 

The Technical Working Group (TWG), co-chaired by LightSquared and the USGIC, 

comprised 37 individuals with strong technical expertise representing a full range 

of GPS receiver categories, installed user groups, and other interested parties. The 

TWG included representatives of all the major GPS manufacturers, the four major 

wireless companies, two public safety organizations, the Department of Defense, 

FAA, NASA, Boeing, Rockwell, and Lockheed Martin. The TWG also relied on advisors representing a full range of stakeholders including manufacturers, user groups 

and individual experts in the GPS field. Over a three-and-a-half month period, the 

TWG tested over 130 devices across seven GPS receiver categories—aviation, cellular, general location and navigation, high-precision, networks, space-based receivers, and timing receivers. The Final TWG Report was filed June 30. 

Separately, the Department of Defense, RTCA (the aviation safety standards organization) and the Jet Propulsion Laboratory conducted their own analysis and tests 

of dozens of GPS receivers. LightSquared provided equipment and engineering expertise for each of these tests. Several reports or summaries have already been 

made public including reports from RTCA and the NPEF Report of government re-
51 

ceivers derived from the DoD tests. Accordingly, over the past nine months, there 

has been more than adequate opportunity in numerous venues to fully test receiver 

vulnerability. 

III. Lightsquared and GPS Can Coexist 

Key to understanding mitigation options is understanding that the vast majority 

of GPS receivers look only at LightSquared’s spectrum that is immediately adjacent 

to GPS. LightSquared’s original plan, before USGIC advised of the overload issue 

in September 2010, was to use this spectrum first, and then bring additional spectrum online later, when it needed further spectrum to serve capacity needs. This 

additional spectrum is on the other end of LightSquared’s band, as far away as possible from the border with GPS. Indeed, the frequencies LightSquared planned to 

use far away from GPS are a full 23 MHz removed from the bottom of the GPS frequency. 

Unsurprisingly, then, testing shows that LightSquared’s planned deployment 

would cause interference with a broad range of different types of GPS receivers, because the planned deployment would have started close to GPS. They also show, 

however, that use of the spectrum far away from GPS does not cause interference 

for the vast majority of GPS receivers. Among the recommendations of the NPEF 

report was a recommendation to conduct further testing of the 10 MHz furthest 

away from GPS, as the testing conducted by the Federal Government agencies on 

receivers so far has shown minimal or no interference. Similarly, the RTCA report 

stated that the 5 MHz furthest away from GPS does not cause a problem for aviation receivers under worst- case analyses, and that further analysis is needed to 

confirm that the next 5 MHz is similarly clear. Notably, the RTCA also noted that 

aviation receivers tested performed significantly better than the minimum performance standards. LightSquared is optimistic that this further analysis will not 

change the report’s conclusion. 

LightSquared has developed its position in response to the actual testing data, 

and has made the following proposal to resolve GPS interference issues: 

• First, LightSquared will operate at lower power than permitted by its existing 

FCC authorization, staying at the power level authorized in 2005. 

• Second, LightSquared will agree to a standstill in the terrestrial use of its 

upper 10 MHz of its frequencies immediately adjacent to the GPS band. 

• Third, LightSquared will commence terrestrial commercial operations only on 

those portions of its spectrum that pose no risk to the vast majority of GPS 

users and will coordinate and share the cost of underwriting a workable solution for the relatively small number of legacy precision measurement devices 

that may be at risk. 

• Fourth, just this week, LightSquared has made a proposal to the FCC to limit 

the power reaching the ground to levels that would, based on actual testing 

data, definitely eliminate interference issues for the vast majority of receivers. 

More detail on this proposal was provided to the FCC earlier this week, and 

is attached as Attachment 3 hereto. 

Initially, it should be noted that, though they are employed for a variety of important uses, legacy precision GPS receivers represent a small fraction of the overall 

installed base of GPS receivers. As compared to the 400 to 500 million cellular, personal navigation and aviation receivers that will be covered by our move to spectrum far away from GPS, precision receivers amount to approximately 500,000, used 

primarily in agriculture, surveying and construction. Precision receivers are also 

used in some of the scientific work undertaken by the agencies before the Committee. Some, but not all, precision receivers may still be impacted by operations 

on the other side of our band from GPS if they are specifically designed to look all 

the way across the band. These receivers use satellite signals from our band to augment the precision of their receivers. Notably, however, testing showed that not all 

precision receivers are so impacted. Ten out of 38 tested receivers were resilient to 

our operations in the spectrum farthest from GPS. The interference issue, then, is 

not a physics issue. It is a technology design issue and can be addressed through 

proper design. 

Contrary to the claims of some of the GPS manufacturers, there are technical and 

operational solutions that will allow us to deploy our network while retaining the 

benefits provided by using these devices. LightSquared can coordinate its rollout so 

agricultural receivers and many other receivers in remote locations will not be near 

LightSquared base stations for several years. LightSquared will underwrite the development of filtering technology for new receivers that can then be used consist-
52 

ently with the placement of our network. LightSquared will also work with 

Inmarsat to find a place in our band where precision manufacturers can be placed 

over the long term, isolated from terrestrial operations and where they can have a 

much higher certainty for their ongoing operations than they do today. 

IV. Conclusion 

LightSquared has never dismissed or made light of the sincere concerns expressed 

by the GPS community over the interference issues raised by the design of GPS receivers. Nor has LightSquared ever said that, because it is a receiver issue, it is 

the job of the manufacturers to solve alone. LightSquared has an obligation to be 

a good neighbor, however or whenever this issue arose. By taking the steps I’ve outlined in my testimony, LightSquared will address this issue for over 99% of the receivers currently used. These steps are not inexpensive to us, and they are not easy, 

but they can and must be done. We are stepping up to this commitment so that 

Americans can get the benefit of our significant investment in critical infrastructure, and continue to have all the benefits of a robust GPS system. 

LIGHTSQUARED AND GPS—THE FACTS 

For the last decade, LightSquared has planned to deploy a terrestrial network, 

and worked with the GPS community to make sure its network would not interfere 

with GPS. 

Lightsquared’s Service Has Been Expected for Almost 10 Years 

• In 2001, LightSquared proposed using satellite spectrum for a fully-capable 

ground network. In 2002, after discussions with the GPS industry representatives, LightSquared agreed (http://fjallfoss.fcc.gov/ecfs/document/ 

view?id=6513283601) to curtail any portion of its signal that crossed into GPS 

frequencies. This agreement imposed restrictions that were 1,000 times stricter 

than what the FCC rules eventually required. http://edocket.access.gpo.gov/ 

cfr¥2010/octqtr/pdf/47cfr25.253.pdf. 

• In 2003, the FCC adopted initial rules allowing LightSquared’s ground network 

to operate near GPS. http://hraunfoss.fcc.gov/edocs¥public/attachmatch/FCC03-15A1.pdf. These rules were adopted after a full review by DoD, FAA and all 

other interested government agencies. As the FCC said recently, ‘‘extensive terrestrial operations have been anticipated in [LightSquared’s spectrum band] for 

at least 8 years.’’ FCC MSS Flexibility Order, § 27 (Apr. 6, 2011). http:// 

hraunfoss.fcc.gov/edocs¥public/attachmatch/FCC-11-57A1.pdf. 

The GPS Industry Understood the Scope of Lightsquared’s Network 

• When the rules were first written in 2003, the FCC had an explicit limit in the 

technical characteristics as to the number of base stations LightSquared could 

build—1,750 per 200 KHz channel, which, when applied to the company’s network, would equal a little over 10,000 base stations. ATC Report and Order, 

FCC 03–15, at §§ 144–47 (February 10, 2003). http://hraunfoss.fcc.gov/ 

edocs¥public/attachmatch/FCC-03-15A1.pdf. 

• In 2003, the U.S. GPS Industry Council (‘‘USGIC’’) stated that the restrictions 

of the 2002 agreement were necessary to protect GPS against ‘‘[t]he increased 

user density from potentially millions of MSS mobile terminals operating in 

ATC mode . . . [and] potentially tens of thousands of ATC wireless base stations.’’ 

Reply Comments of USGIC, IB Docket No. 01–185, at 2 (Sept. 4, 2003) (emphasis added). http://fjallfoss.fcc.gov/ecfs/document/view?id=6515082621. 

• In 2004, the USGIC supported the LightSquared application for authority to operate a ground network under the 2003 rules, stating that the 2002 agreement 

was ‘‘intended to protect GPS receivers and at the same time allow 

[LightSquared] to maximize the utility of its ATC [ground network] service to 

its users.’’ Letter from USGIC to FCC (Mar. 24, 2004). http://licensing.fcc.gov/ 

myibfs/download.do?attachment¥key=366878. 

• In 2005, the FCC removed all limits on the number of base stations 

LightSquared could build and increased their permissible power to 1.6 kw, the 

level at which LightSquared now plans to operate. ATC Order on Reconsideration, FCC 05–30, at §§ 48–50, 53 (February 25, 2005). http:// 

hraunfoss.fcc.gov/edocs¥public/attachmatch/FCC-05-30A1.pdf Again, this decision was reviewed by all interested government agencies and was not challenged by USGIC. 
53 

• Beginning in 2006 and continuing to 2010, LightSquared disclosed its intent to 

build a wireless network using tens of thousands of base stations in its annual 

filings with the SEC http://www.sec.gov/Archives/edgar/data/756502/ 

000119312506067030/d10k.htm and http://www.sec.gov/Archives/edgar/data/ 

756502/000119312510041110/d10k.htm. 

The GPS Industry Knew About Lightsquared’s 

Planned Power Levels and Did Not Object 

• In 2009, LightSquared asked the FCC to increase the power levels of its base 

stations by approximately 10 times to 15 kw, to match the power levels at 

which other wireless networks are permitted to operate. http://licensing.fcc.gov/myibfs/download.do?attachment¥key=-164606. 

• USGIC did not object to even those higher power levels. It objected only to the 

possibility of interference into the GPS band from low-power indoor femtocells, 

an objection it withdrew (http://licensing.fcc.gov/myibfs/ 

download.do?attachment¥key=738501) in August 2009 after reaching agreement 

with LightSquared. http://licensing.fcc.gov/myibfs/ 

download.do?attachment¥key=731265. 

• In March 2010, the FCC approved LightSquared’s increased power levels. 

http://hraunfoss.fcc.gov/edocs¥public/attachmatch/DA-10-534A1.pdf. As with 

all previous FCC proceedings, the order was issued after a public proceeding 

and was fully coordinated with all interested Federal Government agencies. 

Neither GPSIC, nor any other party, filed for reconsideration or review of this 

order. 

• Also in March 2010, the FCC required LightSquared to build a ground network 

reaching 260 million people by the end of 2015. http://hraunfoss.fcc.gov/ 

edocs¥public/attachmatch/DA-10-535A1.pdf. Neither GPSIC, nor any other 

party, filed for reconsideration or review of this requirement. 

Lightsquared Is Doing Everything It Can to Work With GPS 

to Address Issues Raised Only a Few Months Ago 

• In September 2010, USGIC raised for the first time (http://fjallfoss.fcc.gov/ 

ecfs/document/view?id=7020912452)—in a general mobile satellite proceeding— 

the possibility that some GPS receivers may be subject to interference because 

they can be overpowered by signals transmitted by LightSquared inside the 

spectrum the FCC licensed to LightSquared. 

• In November 2010, LightSquared applied (http://licensing.fcc.gov/myibfs/ 

download.do?attachment¥key=852869) to allow devices onto its ground network 

that do not also communicate with its satellite. This application did not change 

the power, number, deployment or any other technical characteristic of 

LightSquared’s base stations. USGIC raised the same objection it raised in September.http://licensing.fcc.gov/myibfs/download.do?attachment¥key=854795. 

• Although the interference issue was irrelevant to this application, 

LightSquared, in January 2011, proposed a rigorous program of testing to determine the extent of the susceptibility of GPS receivers to LightSquared’s transmissions, which the FCC made a condition of granting LightSquared’s application on Jan. 26, 2011. http://hraunfoss.fcc.gov/edocs¥public/attachmatch/DA11-133A1.pdf. 

• The FCC validated the GPS testing process in April 2011 by unanimous Commission vote, noting USGIC’s September 2010 comments and the cooperative 

testing program, and stating that ‘‘responsibility for protecting services rests 

not only on new entrants but also on incumbent users themselves, who must 

use receivers that reasonably discriminate against reception of signals outside 

their allocated spectrum.’’ FCC MSS Flexibility Order, § 27 (Apr. 6, 2011). 

http://hraunfoss.fcc.gov/edocs¥public/attachmatch/FCC-11-57A1.pdf. 
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Chairman HALL. Thank you, sir, and at this time we recognize 

Dr. Pace. 

STATEMENT OF DR. SCOTT PACE, 

DIRECTOR, SPACE POLICY INSTITUTE, 

GEORGE WASHINGTON UNIVERSITY 

Dr. PACE. Thank you, Mr. Chairman. Wonderful opportunity 

today, and I appreciate the Committee’s interest in this. 

Other witnesses have ably described the importance of GPS signals to their agencies and scientific users, and as is fairly clear, scientific users tend to be the most demanding, seeking the most precision and accuracy possible. The highest precision GPS receivers 

are designed to receive not only the full range of radio-navigation 

satellite signals, including GPS, but also the mobile satellite service signals in the adjacent bands that you have heard about that 

carry wide area differential correction from commercial providers, 

and in many cases the reception of those signals is part of a contractual requirement. 

It is important to understand that GPS is not a communication 

service. It is a navigation service. It requires precision-timed measurements, not just the reception of ones and zeros, and that precision time is what results in precision position. The evolution of 

these high-precision capabilities has been made possible because of 

carefully considered past spectrum management decisions to use 

this particular spectrum neighborhood for satellite services, not terrestrial ones. 

In addition to the federal science agencies you have heard from, 

the university-scientific community is also concerned with this 

issue. In January of this year the CEO of the University Space Research Association, comprising 105 Ph.D. granting universities, 

wrote that USRA member universities are engaged in research in 

all aspects of GPS use and testing. All of these have the potential 

to be adversely affected by the LightSquared proposal unless rigorous measures are implemented to mitigate interference of the reception of GPS signals. 

The Technical Working Group final report, showed GPS interference. The TWG rightly used multiple approaches to characterize 

the interference. There were paper calculations, along with testing 

in controlled environments such as anechoic chambers, and finally, 

realistic operational scenarios were defined for specific categories of 

users as well as live sky field tests were conducted on governmentcontrolled ranges. 

Virtually all tests, the precision receivers, those used by scientists and deployed in networks around the world, were harmfully 

impacted. The GPS community concluded that 31 of 33 high-precision receivers tested were significantly affected. We can talk about 

the other two. 

There is no viable or verifiable technological solution that has 

been identified to date that would allow a ground-based broadband 

communication network to operate in close proximity to GPS signals. This is why the band has for decades been intentionally allocated for space services. Even if some new as yet unforeseen technology did appear, the industrial, commercial, and public sector 

users of GPS equipment routinely take up to 15 years to complete 
76 

a normal replacement cycle; software cycles can be fast, but hardware takes longer. 

GPS is arguably the most efficient use of spectrum the world has 

ever seen. Almost a billion people are currently benefiting from today’s signal, and this use represents a massive installed base and 

source of advantage for the United States of which international 

scientific cooperation is but one part. 

If LightSquared were deployed in a way that caused harmful interference with GPS, a major beneficiary as you have heard, would 

likely be the Russian GLONASS System as its operating frequencies are farther away from LightSquared base-station frequencies. I should add that GALILEO and COMPASS probably 

would be equally harmed because they share frequencies similar to 

GPS. 

Now, there are competing national policy objectives that need to 

be reconciled. On June 28 the Administration released two major 

policy statements. The first was aimed at expanding spectrum for 

wireless broadband use; a memorandum from the President called 

for collaboration between the FCC and the National Telecommunications and Information Administration to make available a total 

of 500 megahertz of federal and non-federal spectrum over the next 

10 years. 

However, the memorandum cautioned that agencies were to 

quote, ‘‘take into account the need to ensure no loss of critical, existing, and planned federal, state, local, and tribal government capabilities.’’ 

On the very same day the White House also released a National 

Space Policy that specifically referred to GPS as a form of spacebased position, navigation, and timing, and in this policy the President said, ‘‘The United States must maintain its leadership in the 

service, provision, and use of global navigation satellite systems.’’ 

More specifically, this required, ‘‘the protection of radio navigation 

spectrum from disruption and interference.’’ 

In my judgment the safest and most fact-based course of action 

on the data we have to date is to conclude that the terms of the 

LightSquared conditional waiver have not been met and to withdraw the LightSquared license to deploy a terrestrial network in 

the 1525 to 1559 megahertz band. It is the only approach fully consistent with the terms of both the National Space Policy and the 

broadband memorandum, and I would argue the FCC’s own regulations. 

The last 20 years have seen continuous innovation in the ability 

to use GPS for measurements of the Earth, the atmosphere, and 

the biosphere via precise positioning, navigation, and timing. If the 

LightSquared terrestrial network is allowed to operate as proposed, 

it would create new, additional, and as of yet unforeseen costs for 

federal science agencies as well as state and local governments who 

rely on high-precision GPS-derived data. It would mark a permanent decline in the capabilities that GPS has afforded scientific application in the United States. Such operations would be contrary 

to the technical facts established by independent testing. They 

would improperly place burdens on the victim service, in this case 

GPS. They would undermine the international credibility of the 

United States as built for GPS and would be contrary to the Na-
77 

tional Space Policy and the terms of the President’s own broadband 

initiative. 

Thank you for your attention, and I would be happy to answer 

any questions you might have. 

[The prepared statement of Dr. Pace follows:] 

PREPARED STATEMENT OF DR. SCOTT PACE, 

DIRECTOR, SPACE POLICY INSTITUTE, 

GEORGE WASHINGTON UNIVERSITY

Thank you, Mr. Chairman, and thanks to this Committee, for providing an opportunity to discuss this important topic. The subject of today’s hearing is a complex 

one that involves not just federal science activities, but national security, public 

safety, foreign policy, and the health of economic sectors from agriculture to information technology. 

Specifically, the Committee has asked that witnesses address the impact of the 

proposed LightSquared mobile terrestrial commercial communications network on 

federal science agencies and to discuss the recent report of the FCC-mandated technical working group that was tasked to examine radiofrequency interference with 

GPS as well as possible mitigation strategies. The technical evidence gathered to 

date clearly shows that the LightSquared network poses an unacceptable interference threat to all GPS users and especially high-precision scientific users of GPS. 

I have been involved with GPS issues for over 20 years, beginning with work at 

the U.S. Department of Commerce around the time of the first Gulf War. While at 

the RAND Corporation, I supported the Office of Science and Technology Policy during the creation of the first Presidential Decision Directive on GPS in 1996. I have 

also been involved in domestic and international conflicts over radio frequency spectrum used by GPS for almost as long, including negotiations at the International 

Telecommunications Union and proceedings before the Federal Communications 

Commission. I am currently the Director of the Space Policy Institute at George 

Washington University and am speaking today purely in a personal capacity and 

my comments do not necessarily represent the views of any agency, organization or 

company. 

The LightSquared Network Represents a Major Change in Spectrum Use 

The most commonly used GPS signal, L1, is located in the spectrum band 1559– 

1610 MHz. This band is specifically ‘‘zoned’’ internationally for radionavigation satellite services (RNSS) like GPS, the Russian GLONASS system, and the European 

Galileo system. On either side of the band are bands for mobile satellite services 

(MSS) at 1525–1559 MHz, below GPS, and at 1610–1660.5 MHz, above GPS. The 

key point is that the entire ‘‘neighborhood’’ is oriented to satellite services and such 

services require ‘‘quiet’’ spectrum as the powers of signals transmitted from space 

are many orders of magnitude weaker than those transmitted by typical terrestrial 

stations. There are major power differences between satellite services as well. The 

power of a MSS signal is much greater than that of signal coming from a GPS satellite. Thus MSS and GPS signals operate in adjacent bands where their functions 

are compatible with each other but they do not operate in the same band since MSS 

signals would easily drown out the GPS signal.Figure 1 shows how proposed uses 

of the 1525–1559 MHz band next to GPS have evolved over the past 10 years. (Attachment 1 provides a more detailed history of regulatory highlights.) 
78 

MSS services, such as those offered by Inmarsat, have historically operated purely 

through satellites. This enables service over very wide regions or even the entire 

globe. However, there will be coverage gaps for areas either outside the satellite 

service area, or more commonly, when dense urban environments block the weak 

satellite signals. This led to interest in creating an ancillary terrestrial component 

(ATC) to the MSS service in which ground-based towers would ‘‘fill in’’ the coverage 

gaps and thus enable better service to a wider range of customers. The GPS community was concerned the deployment of terrestrial base stations would create interference to the adjacent RNSS band. The U.S. GPS Industry Council negotiated with 

the proposed MSS ATC operator, then known as MSV, and reached a technical 

agreement on ‘‘out-of-band’’ emission limits to restrict any harmful spillover into the 

RNSS band. This agreement was also predicated on the requirement that the ATC 

would remain tied to satellites and that the need to avoid self-interference between 

the satellites and terrestrial components of the same company meant the MSS band 

would remain relatively quiet. This helped ensure compatibility with GPS users 

next door. 

The U.S.-licensed operator of MSS ATC in the L-band went through several ownership changes, including the most recent transfer of license to what became 

LightSquared in March 2010. The essential operational situation remained unchanged until November 2010 when LightSquared requested relaxation of the ‘‘gating requirement’’ which tied the ground-based ATC system to the satellite service. 

This would allow the terrestrial network to carry broadband services and the satellites would now be effectively ‘‘ancillary’’ to the ground network as they are not 

capable of providing broadband level service. In effect, satellite spectrum would be 

‘‘rezoned’’ to allow deployment of high-powered, terrestrial base stations in urban 

areas and across the country. This is the situation that the GPS community sought 

to avoid a decade ago. Unfortunately, the FCC granted a conditional waiver to 

LightSquared on January 26, 2011. The waiver was conditioned on the creation of 

an industry-led technical working group to examine the potential for interference to 

GPS and possible means of mitigation. 

Scientific and High-Precision GPS Users Depend on Large Bandwidths 

Other witnesses have ably described the importance of GPS signals to their agencies and scientific users. These users tend to be very demanding, seeking the most 

precision and accuracy possible. This in turn requires taking in the most information possible not only from GPS signals but other Global Navigation Satellite Systems (GNSS) such as Galileo and using accuracy augmentation signals that are carried on MSS systems. Figure 2 shows the 2 MHz wide (pink) GPS signal used by 

common smart phones. The wider blue region shows the full RNSS band used by 
79 

more capable receivers, including those designed to receive signals from foreign 

GNSS systems as well as GPS. The green bars show the proposed upper (close to 

GPS) and lower (farther from GPS) channels for LightSquared’s 4G long-term evolution (LTE) service. 

Figure 3 shows the bandwidth of the highest precision GPS receivers. They are 

designed to receive not only the full range of RNSS signals, including GPS, but also 

MSS signals in the adjacent band that carry wide-area differential GPS corrections 

from commercial providers such as Starfire. Developed by John Deere and precision 

farming groups, a Starfire-capable receiver can produce centimeter-level position 

measurements. Powerful transmissions from LightSquared base stations would unavoidably jam the reception of weaker MSS signals used by the high precision GPS 

receivers. Thus when talking about receiver bandwidths, it is not enough to receive 

just the GPS signal itself, but all the services used for precision positioning, navigation, and timing. The evolution of high precision capabilities has been possible because of carefully considered past spectrum management decisions to use this particular neighborhood for satellite services, not terrestrial ones. 

In addition to the federal science agencies, the university scientific community is 

concerned with the LightSquared network. I serve on the board of the Universities 

Space Research Association, a non-profit organization of 105 Ph.D.-granting universities conducting space and aeronautics-related research. In January of this year, 

prior to the FCC granting the requested waiver of the satellite requirement, the 

CEO of USRA wrote: 
80 

‘‘ . . . USRA member universities are very engaged in research on all aspects of 

GPS use and testing. This includes development of the impending Federal Aviation Administration’s transition to a satellite based navigation system, known 

as NextGen . . . Satellite data used by universities involving GPS tracking and 

geodetic networks across the United States could also be impacted. These applications range from global environmental monitoring, weather prediction, and 

earthquake monitoring to advanced concepts such as training for space systems 

engineers. All of these have the potential to be adversely affected by the 

LightSquared proposal unless rigorous measures are implemented to mitigate 

interference to the reception of GPS signals.’’ 

International Concerns 

While LightSquared is currently a domestic issue, it has attracted international 

notice and concern. The Japan GPS Council (JGPSC) is the non-profit association 

composed of the major firms and organizations of the civil GPS applications and 

users in Japan. On May 27, they provided a letter to the FCC docket stating: 

GPS receivers are properly designed to operate in the ‘‘satellite’’ neighborhood 

that exists in the domestic and international tables of frequency allocations in 

the 1525–1660.5 MHz range. There are no unaccounted-for high-power terrestrial signals anywhere in the world that pose the threat of harmful interference 

to GPS and other RNSS users. At least there were none until LightSquared’s 

new owners opportunistically decided to try to convert what has always been 

an ATC-enhanced satellite band into a new home for high-power terrestrial mobile broadband signals. The physics is clear; LightSquared cannot provide 4G 

LTE service in the satellite neighborhood without causing harmful interference. 

(The) U.S. and Japan have worked in close cooperation at the domestic level as 

well as in international fora to protect and preserve spectrum for GPS in order 

to safeguard national security applications as well as maintaining flexibility and 

opportunity for continued commercial innovation and critical public infrastructure . . . 

Any threat to the integrity or availability of GPS in U.S. markets would undermine and devalue the substantial investment that Japanese firms have made 

to serve users and customers in the U.S. Japanese firms provide products and 

equipment for high-precision applications to U.S. customers, . . . 

Any policy which would allow degradation of GPS service in the U.S. would also 

raise question as to the integrity of the stated U.S. commitment to maintain 

GPS as a stable and reliable global standard for positioning, navigation and 

timing. 

The European Commission expressed similar concerns in a July 19th letter to the 

FCC docket. This letter cited technical concerns raised by the European Space Agency and concerns about impacts to Galileo, which is to be interoperable with GPS: 

The band immediately below 1559 MHz, allocated by the Radio Regulations to 

the mobile-satellite service (MSS), has been used for satellite-based transmissions for many years and has proved to be broadly compatible with RNSS 

systems above 1559 MHz. The LightSquared proposal for a terrestrial network 

deployment in MSS spectrum would completely change the nature of radio 

transmissions in the band. 

Analysis carried out in Europe, including by our own technical partner the European Space Agency, has shown that transmissions from LightSquared base 

stations do indeed have considerable potential to cause harmful interference to 

Galileo receivers operating in the United States. Interference effects have been 

determined to occur in the range 100m to almost 1,000km, depending on the 

type of receiver being used. This obviously presents a grave threat to the viability of providing a Galileo service covering U.S. territory—a service which many 

studies have shown will not only benefit Galileo users, but those of GPS too as 

the two systems will be interoperable through a common signal design providing significantly improved coverage and accuracy in urban environments. 

Europe and Japan are major international partners in every area of scientific cooperation. Harmful interference to GPS and other GNSS systems in the United 

States would undermine that cooperation. It would also undermine the long-standing international commitment the United States has made to protection of RNSS 

spectrum, not just GPS, from harmful interference. This, in turn, calls into question 

the ability of the United States to be a leader at a time when other systems from 
81 

Europe, Japan, Russia, China, and India are being deployed. Ironically, if 

LightSquared were deployed in a way that caused harmful interference to GPS, a 

major beneficiary would likely be the Russian GLONASS system. Its operating frequencies are located farther away from the LightSquared base station frequencies. 

Damaging GPS and driving users to a Russian space system are not desirable outcomes for the United States. 

The Technical Working Group Final Report Shows GPS Interference 

The TWG Final Report documents issues associated with the interference threat 

to GPS receivers and GPS-dependent applications resulting from LightSquared’s 

proposal to deploy a high-power terrestrial broadband system in the 1525–1559 

MHz and 1626.5–1660.5 MHz bands on either side of the 1559–1610 MHz band used 

by GPS, GLONASS, and other satellite navigation systems. These bands were licensed to LightSquared for mobile-satellite service and ancillary terrestrial component use, prior to the Bureau’s January 2011 decision to conditionally waive the satellite ‘‘gating’’ requirement. 

The final report is over 1,000 pages long, and detailed summaries are available 

from the participating companies and government agency observers. LightSquared 

also participated in the testing and contributed to the final report. A key strength 

of the TWG report is that it used multiple approaches to characterizing interference. 

Paper calculations of potential interference were made, along with testing in controlled environments (e.g., anechoic chambers), and finally realistic operational scenarios were defined for specific categories of users and ‘‘live sky’’ field tests were 

conducted on government-controlled ranges. This reflects a best practice for interference studies when national security or public safety applications are at risk—no 

one approach is to be trusted but all are done to see if consistent results are 

achieved. 

Consistent results were achieved, supporting the expectations of early analytical 

estimates. Specifically, the planned LightSquared deployment would create harmful 

or significant interference for all categories of GPS receivers. There were three categories of interference that were examined. The first was ‘‘out of band emissions’’ 

from LightSquared into the GPS band. The observed emissions were in compliance 

with MSS ATC limits set in 2005 and were not a source of harmful interference. 

The second was ‘‘receiver overload’’ or 11receiver desensitization’’ due to the powerful terrestrial transmissions exceeding the GPS receiver’s normal tolerances with 

the MSS bands. The third was an effect known as ‘‘intermodulation’’ in which separate LightSquared signals interact to produce a composite signal in a different part 

of the spectrum. In this case, intermodulation products were observed on and near 

the center frequency of the primary GPS signal known as L1. 

Figure 4 shows a snapshot from testing conducted in New Mexico earlier this 

year. The two large peaks are the expected LightSquared terrestrial signals and the 

smaller peak to the right is the observed intermodulation effect that lies at the 

same location as the GPS L1 signal. 
82 
83 

The operational impact of interference effects for scientific applications can be inferred from impacts to high precision receivers, networks of high precision receivers, 

and space applications. Virtually all tested precision receivers, those used by scientists and deployed in networks around the world, were harmfully impacted. In the 

TWG report, the GPS community concluded that 31 of 33 high precision receivers 

tested were significantly affected in the testing. This is an unavoidable and natural 

consequence of taking in as much of the GPS signal as possible using a wideband 

receiver. It is a natural consequence of accessing multiple radionavigation satellite 

systems that share the same RNSS band as GPS. Giving up access to the best GPS 

signals available or access to other RNSS satellite systems is not a solution for scientific users. 

In addition to direct effects on the receipt of GPS signals, the LightSquared signals create co-channel interference to MSS signals in the 1525–1559 MHz band 

where they operate. This blocks the receipt of those signals by GPS receivers that 

use them to create ‘‘differential corrections’’ to augment the accuracy of the basic 

GPS receiver. The FCC has licensed commercial firms such as Starfire and 

OmniSTAR to provide augmentation services that scientific, agricultural, and other 

users rely on today across the country. 

Due to the large distances involved, GPS receivers used for navigation on spacecraft may not suffer harmful interference from the LightSquared network. However, 

GPS receivers looking at the Earth would be affected. Such receivers are used to 

understand the ionosphere and atmosphere by looking at the behavior of the GPS 

signal as it passes through them. This enables great improvements to weather forecasts, tracking hurricanes and typhoons, and establishing precise climate benchmarks to allow actual measurements of climate change. 

In addition to scientific research, State and local governments use high precision 

GPS for mapping, surveying and infrastructure maintenance. High precision data 

is used in Geographic Information Systems (GIS) for asset management, emergency 

preparedness, disaster response and E911 mapping, public sector water, wastewater 

and electric utilities, public works, environmental management, dam and structure 

monitoring, environmental health, insurance rating districts, flood zones, tax appraisals, the provision of geodetic control networks, and a host of other functions. 

The Government’s NPEF Report Is Consistent With TWG Report Results 

The National PNT Engineering Forum (NPEF) report contains the results of testing by federal agencies, including the science agencies, and had technical results 

consistent with those of the TWG effort. As with the TWG, multiple approaches 

were taken to ensure theoretical and experimental results agreed with each other. 

A summary of the TWG report is available from the National Coordination Office 

and in other testimony. I would like to therefore highlight the two recommendations 

made by the NPEF: 

• RECOMMENDATION 1: LightSquared should not commence commercial services 

per its planned deployment for terrestrial operations in the 1525–1559 MHz 

Mobile-Satellite Service (MSS) Band due to harmful interference to GPS operations. 

• RECOMMENDATION 2: The U.S. Government should conduct more thorough studies on the operational, economic and safety impacts of operating the 

LightSquared Network, to include additional ATC signal configurations not currently in LightSquared planned spectrum phases, effects on timing receivers, as 

well as transmissions from LightSquared handsets. As part of these studies the 

compatibility of ATC architectures in the MSS L-Band with GPS applications 

should be reassessed. 

The two recommendations underscore the infeasibility of operating the 

LightSquared network as proposed without harmful interference to GPS. The recommendations also note areas where testing was incomplete, raising deeper questions about the feasibility of operating even previously approved MSS ATC networks 

in the band, never mind a broadband terrestrial network. The MSS ATC networks 

approved earlier had never been deployed and realistic equipment was not available 

to verify the regulatory limits truly prevented harm to GPS. Given the discovery of 

intermodulation products, a reexamination of the feasibility of ‘‘traditional’’ ATC 

would be prudent. 

LightSquared’s Proposed Solution Is Not Sufficient 

LightSquared has proposed to change the order in which they would deploy the 

same frequencies in the band adjacent to GPS. There are two channels of spectrum 
84 

1 47 C.F.R. § 25.255. 2 The White House, ‘‘Unleashing the Wireless Broadband Revolution,’’ Office of the Press Secretary, June 28, 2010. 3 op cit. 

in the band adjacent to GPS, which they originally planned to deploy in a certain 

order. They now propose to suspend, for what is implied to be a short time, use of 

the upper 10 MHz channel and begin with the lower 10 MHz channel. This would 

potentially result in impacting high precision scientific users first and other users, 

such as aviation, later. 

The company has also proposed reducing the power of the terrestrial base stations 

by 50% from allowable levels. Unfortunately, that does not help, as cell site transmitter providers do not even supply equipment at the very high 15.8-kilowatt level 

the FCC proposes to allow. All testing was done with equipment that was available, 

that is, at roughly 10% of the maximum allowable level. 

Even if it was considered acceptable to sacrifice high precision GPS users, the 

‘‘lower 10 MHz’’ approach could be solution only if it was a complete solution. Unfortunately, it is not. LightSquared has been consistently clear that a commercially 

viable network would require more spectrum, preferably close to where they would 

already be operating. 

Deployment in the lower block alone has not been concluded to be compatible with 

GPS and would likely require around 15 years prior to commencement for new technology to be developed and existing user equipment to be replaced. However, without a permanent restriction on use of additional spectrum for terrestrial operations 

in other parts of the band, this approach merely shifts the burden of mitigation to 

the existing GPS users. 

Section 25.255 of the FCC’s rules makes the obligation of resolving harmful interference to other services that is caused by MSS ATC operations the sole responsibility of the ATC operator. 1 Nominally, at least, even under the LightSquared order, 

LightSquared is still an ATC operator subject to Section 25.255. It cannot require 

authorized users of another service to take measures—especially measures deemed 

infeasible or inappropriate by a substantial majority of the TWG—to mitigate the 

harmful interference. This obligation is LightSquared’s alone. 

There is no viable or verifiable technological solution that has been identified to 

date that would allow a ground-based broadband communications network to operate in close proximity to GPS signals. This is in part why the band has, for decades, 

been internationally allocated for space services. Even if some new, as yet unforeseen, technology did appear, the industrial, commercial and public sector users of 

GPS equipment routinely take up to 15 years to complete a normal replacement 

cycle. Equipment installed on aircraft, vessels, agricultural, construction and mining 

machinery, commercial vehicles or high-cost professional instruments used today are 

not thrown away after a few years of use—their lifetimes are measured in decades. 

There is one possible solution available today that I am aware of. LightSquared 

could operate the satellite part of its network, serving rural and public safety users 

outside of cellular coverage areas, in the L-band adjacent to GPS while developing 

its new high-powered terrestrial portion of its network in a different band, where 

it would be compatible with adjacent uses. Possible locations include the S-Band 

(above 2 GHz) or the 700 MHz bands already allocated to terrestrial 4G wireless 

services. The MSS satellite part of the LightSquared network is compatible with 

neighboring GPS uses and thus can coexist with all GPS services, applications and 

existing user equipment. The terrestrial component of the LightSquared network 

has not yet been built; therefore it is at least technically feasible to move to a different band from the outset, thus avoiding large scale disruption to GPS users 

across the United States. 

Competing National Policy Objectives Need To Be Reconciled 

On June 28, 2010, the Administration released two major policy statements. The 

first was aimed at expanding spectrum for wireless broadband use. 2 The Memorandum from the President called for collaboration between the FCC and the National Telecommunications and Information Administration to ‘‘make available a 

total of 500 MHz of Federal and nonfederal spectrum over the next 10 years, suitable for both mobile and fixed wireless broadband use.’’ However, the Memorandum 

cautioned that agencies were to ‘‘take into account the need to ensure no loss of critical existing and planned Federal, State, local, and tribal government capabilities 

. . . .’’ 3

On the same day, the White House also released a new National Space Policy that 

specifically referred to GPS as a form of space-based positioning, navigation, and 
85 

4 The White House, ‘‘National Space Policy,’’ Office of the Press Secretary, June 28, 2010. 

timing. 4 In the policy, the President said, ‘‘The United States must maintain its 

leadership in the service, provision, and use of global navigation satellite systems.’’ 

More specifically, this required the ‘‘Protection of radionavigation spectrum from 

disruption and interference.’’ 

Considering the objectives of both policies, there seem to be four options for consideration by the FCC, Administration and Congress: 

• 1. Accept the most recent LightSquared proposal to begin deployment in the 

lower 10 MHz of the 1525–1559 MHz band. Additional testing to define mitigation measures should be required as a condition of approval. 

• 2. Rescind the LightSquared waiver and bar commercial operations even in the 

lower 10 MHz pending completion of further testing and demonstration of specific mitigation measures by LightSquared to preclude harmful interference to 

GPS. 

• 3. Assist LightSquared in finding alternative spectrum for its terrestrial network outside the L-band. The FCC would have to explore legal and regulatory 

challenges in aiding such as move that may or may not be economically feasible 

for the company. 

• 4. Conclude that the terms of the LightSquared conditional waiver have not 

been met and withdraw LightSquared license to deploy a terrestrial network in 

the 1525–1559 MHz band. 

In my judgment, the safest and most fact-based course of action is number 4. It 

is the only approach fully consistent with the terms of both the National Space Policy and the Broadband Memorandum as well as the FCC’s own regulations. 

Conclusion 

It is sometimes argued that accommodations by legacy systems need to be made 

to enable new uses of spectrum and that doing so enables more efficient use of a 

scarce, natural resource. When it comes to spectrum efficiency, GPS is arguably the 

most efficient use of spectrum the world has ever seen; almost a billion people are 

currently benefitting from the 20 MHz GPS signal that is available today. In fact 

the entire global population could use GPS without any additional spectrum being 

used. This use represents a massive installed base and source of advantage for the 

United States, of which international scientific cooperation is but one part. Most importantly, it represents a high degree of trust and confidence in the United States 

and its stewardship of GPS. 

If allowed to operate in either its original or modified form, the LightSquared terrestrial network would create unacceptable harmful interference to GPS users and 

high precision scientific users in particular. Such operations would be contrary to 

the technical facts established by independent testing; they would improperly place 

burdens on the victim service, in this case GPS, undermine the international credibility the United States has built for GPS, and would be contrary the National 

Space Policy and the terms of the President’s own broadband initiative. 

The last 20 years have seen continuous improvement in the ability to use GPS 

for measurements of the Earth, the atmosphere, and the biosphere via precise positioning, navigation, and timing. If the LightSquared terrestrial network is allowed 

to operate as proposed, it will mark a permanent decline in the beneficial capabilities GPS has afforded scientific users in the United States. It would create new, additional, and unforeseen, costs for federal science agencies as well as State and local 

governments who rely on high precision GPS-derived data. 

Thank you for your attention. I would be happy to answer any questions you 

might have. 

ATTACHMENT 1—HISTORICAL NOTES ON MSS ATC AT L-BAND 

August 17, 2001: Notice of Proposed Rulemaking (NPRM) on MSS ATC Released 

• Based on applications of ICO and Motient MSS systems 

• Included consideration of out-of-band emission limits to protect GPS 

July 25, 2002, Agreement Between MSV and U.S. GPS Industry Council 

• Parties reach agreement on a—100 dBW/MHz limit for MSS ATC base stations 

in order to protect GPS/RNSS in the 1559–1610 MHz band. 
86 

• Predicated on the assumption that ATC use remained tied to satellites and that 

the service would be relatively low-density fill-in. 

February 10, 2003: First Report and Order and NPRM on MSS ATC Released 

• FCC makes clear that MSS ATC is to augment satellite service: 

Para. 1: ‘‘We do not intend, nor will we permit, the terrestrial component to become a stand-alone service.’’ 

Footnote 5: ‘‘While it is impossible to anticipate or imagine every possible way 

in which it might be possible to ‘game’ our rules by providing ATC without also 

simultaneously providing MSS and while we do not expect our licensees to 

make such attempts, we do not intend to allow such ‘gaming.’ For example, even 

if an MSS licensee were to enter an agreement to lease some or all of the access 

to its authorized MSS spectrum to a terrestrial licensee such spectrum could 

only be used if its usage met the requirements to ensure it remained ancillary 

to MSS and were used in conjunction with MSS operations, i.e., that it met all 

of our gating requirements. The purpose of our grant of ATC authority is to provide satellite licensees flexibility in providing satellite services that will benefit 

consumers, not to allow licensees to profit by selling access to their spectrum 

for a terrestrial-only service.’’ 

• Adopts ‘‘Gating Criteria’’ (FCC Part 25.149(b)(4)) to limit terrestrial deployment 

to that which is ancillary to the satellite component of the network. Effectively 

prohibits ATC-only or stand-alone terrestrial services. 

• Declined to adopt limits on emissions into the RNSS band (1559–1610 MHz) 

more stringent than GMPCS rules (–70 dBW/MHz) for BS and METs and mentioned possible rulemaking on GPS protection in a future proceeding. 

• Number of base stations limited to 1725. 

• EIRP limited to 14.1 dBW (AE6 25 watts) towards the horizon and maximum 

EIRP of 23.9 dBW (AE6245 watts) per sector (derived from limit on per-carrier 

EIRP of 19.1 dBW and the number of carriers per sector limited to three). 

November 8, 2004: MSV Order and Authorization Released 

• MSV commits to meeting a—100 dBW/MHz limit in 1559–1610 MHz RNSS 

band, which FCC imposes as a condition of the authorization (noting these limits are more stringent than FCC rules require). 

• Limit of 1725 base stations increased to 2415. 

• Gating criteria in 25.149(b)(4) retained.retaining the prohibition against standalone terrestrial services. 

• Overhead gain suppression relaxed to permit base-station antenna gain of up 

to 27 dB below the maximum directional gain in vertical angles from 30.5 to 

55.5 and up to 30 dB below the maximum directional gain in vertical angles 

from 55.5 to 145.5, as requested.’’ 

• Aggregate EIRP increased (subject to some restrictions) to 26.9 dBW toward the 

physical horizon and 31.9 dBW in other directions. 

February 25, 2005: Memorandum Opinion and Order (MO&O) Released 

• Limit on number of base stations eliminated in favor of delta T/T limit of 6% 

to protect Inmarsat MSS in the L-band. 

• Aggregate EIRP increased by rule (beyond just waiver granted to MSV) to 31.9 

dBW (AE61550 watts) generally and 26.9 dBW (AE6490 watts) per base station 

sector toward the horizon, representing an 8 dB increase over the previous 

power limits that apply when three carriers are used within an antenna sector. 

• Gating criteria in 25.149(b)(4) retained.retaining the prohibition against standalone terrestrial services. 

• No L-band MSS ATC network or equipment deployed. 

Note: Order includes extensive testing and analysis of Inmarsat terminals and interference from MSV ATC network. 

December 21, 2007: Inmarsat-MSV Spectrum Sharing Agreement 

• According to Satellite Today (January 2008): The agreement was defined in two 

phases. Phase one, from December 2007 to September 2011, gives the companies an 18- to 30-month period to transition to the modified band plan, including ‘‘modification of certain of Inmarsat’s network and end user devices and a 
87 

shift in frequencies between the MSV parties and Inmarsat,’’ according to the 

U.S. Securities and Exchange Commission report. MSV will be allocated 28 

MHz of L-band spectrum and will pay Inmarsat $250 million in cash and $87.5 

million in equity for additional spectrum. During phase two, from January 2010 

to January 2013, Inmarsat will be able to modify the amount of spectrum it 

uses over North America and make that bandwidth available to MSV for rental 

use. MSV will pay $115 million for this additional spectrum. 

• No L-band MSS ATC network or equipment yet deployed. 

March 26, 2010: FCC Issues Order on Harbinger Acquisition of SkyTerra 

• Relevant Milestones: 

March 27, 2009: Harbinger begins acquisition of SkyTerra with filing to FCC 

for transfer and control of SkyTerra to Harbinger Capital Partners, Ltd. 

November 24, 2009: FCC issues Protective Order allowing submissions by Harbinger and SkyTerra to be handled as proprietary and confidential material 

upon request. 

February 26, 2010: Harbinger submits information on its business model, including the planned build-out of an extensive terrestrial network, and requests 

it be treated as proprietary and confidential information as allowed by the Protective Order. The new business model (including the proposed building of an 

extensive terrestrial network) is not coordinated with the IRAC and Federal 

agencies. 

March 26, 2010: FCC issues a Memorandum Opinion and Order and Declaratory Ruling finalizing the acquisition of SkyTerra (to be renamed LightSquared) 

by Harbinger. 

March 26, 2010: Harbinger files a letter with the FCC on the same day the Harbinger Order is released, making available information on its business plans 

(including the building of an extensive terrestrial network) that was filed under 

a request for confidential treatment on February 26, 2010. 

April 1, 2010: Verizon files Petition for Partial Reconsideration of the Harbinger 

Order, alleging various process fouls and irregularities in the proceeding (believed to be still pending) 

April 2, 2010: AT&T files Petition for Reconsideration of the Harbinger Order, 

alleging various process fouls and irregularities in the proceeding (believed to 

be still pending). 

April 15, 2010: Harbinger withdraws its request that the February 26, 2010, information on its business plans be treated as confidential material. 

March 26, 2010: FCC Releases Order and Authorization to modify SkyTerra ATC 

license 

• Aggregate EIRP increased to 42 dBW (AE615.85 kilowatts) per sector. 

• No change to gating requirement and tying of ATC to satellites. 

• Power density limits relaxed near airports and waterways subject to Inmarsat 

making its terminals less susceptible to receiver overload interference (see paragraphs 35, 36). 

• Increased protection for GPS from femtocells added to SkyTerra authorization: 

PSD of emissions in the 1559–1605 MHz band limited to –114.7 dBW/MHz and 

that PC data cards transmitting to such femtocells should limit the PSD of 

emissions in the 1559–1605 MHz band to –111.7 dBW/MHz. 

• No L-band MSS ATC network or equipment yet deployed. 

November 2010: FCC Initiates LightSquared Waiver Proceeding 

• November 18, 2010: LightSquared Files Report to FCC on its MSS ATC Plans 

and notes that if the plans are not in conformance with the ‘‘gating criteria’’ 

in FCC’s rules, request that the requirement be waived. 

• November 19, 2010: FCC initiates proceeding on LSQ waiver request by placing 

the application on Public Notice and inviting public comment. By a separate 

Order on November 26, FCC extended comment deadline to December 2, 2010, 

with reply comments due December 9, 2010. 

• No L-band MSS ATC network or equipment yet deployed. 

January 26, 2011: FCC Grants LightSquared Waiver of Gating Criteria 
88 

• Federal agencies object to granting the gating waiver prior to completion of 

technical studies establishing whether GPS would be protected. The Department of Defense separately expresses its opposition to the FCC Chairman. 

• While noting agency objections and the creation of a ‘‘new interference environment’’ NTIA does not formally block the FCC waiver proposal. 

• On January 26, 2011, FCC granted a waiver to LightSquared of FCC rule 

25.149(b)(4), permitting stand-alone terrestrial use for the first time. 

• Establishes Technical Working Group (TWG) to examine potential interference 

to GPS. 

• Report from the TWG due to FCC on June 15, 2011. The FCC later granted 

a two-week extension to June 30, 2011 at the request of LightSquared. 

• No L-band MSS ATC network or equipment deployed. First base station equipment provided for testing in April 2011. 

June 30, 2011: FCC places TWG Report on docket for Public Comment 

• Period for comments closes July 30, 2011. Period for reply comments closes August 15, 2011. 

Chairman HALL. All right. Thank you, and thank you for your 

testimony. I would remind the Members of this Committee that the 

rules require and allow questioning for five minutes. 

And the Chair at this point will open the round of questions. I 

relegate myself to five minutes. Hope each of you can stay within 

that deal. 

And I will start out by asking Mr. Appel, are you familiar, Mr. 

Appel, with the LightSquared impact to aviation that is based on 

LightSquared? Yes. I think written by and prepared by J.C. Johns. 

Is he the director? 

Mr. APPEL. He is one of the FAA officials overseeing a lot of this 

effort. Yes. 

Chairman HALL. All right, and for the first five, one, two, three, 

four—Mr. Russo, Ms. Glackin, Mr. Sparrow, Mr. Appel, you are all 

the representatives of the people, are you not? All appointed, not 

elected, appointed, and serving, and I believe, Mr. Appel, you were 

just confirmed by the Senate, were you not? Recently. 

Mr. APPEL. 2009, actually. 

Chairman HALL. Well, good luck to you. 

Mr. APPEL. Thank you. 

Chairman HALL. And I guess I will ask all of you, Mr. Appel, are 

you familiar with the FAA’s analysis of the impact on 

LightSquared’s network, and that is what this study is. 

Mr. APPEL. Yeah. There have been a number of internal analyses 

of the FAA, and I am generally familiar with them. Yes. 

Chairman HALL. And is this assessment based on studies of 

LightSquared, LightSquared’s Technical Working Group, their 

radio technical commission for aeronautics, and other national PNT 

engineering form reports? 

Mr. APPEL. My understanding is that the work that the FAA did 

was in conjunction with the Technical Working Group and those 

other groups. Yes. 

Chairman HALL. And I think in my opening statement I mentioned some of the real problems. Did that—let us talk about the 

impact of LightSquared’s network. Did that assessment indicate an 

increase in potential aviation fatalities? 

Mr. APPEL. My understanding was that there was an internal 

FAA analysis looking at the initial LightSquared proposals that did 

some early estimates based on the original scenario. I think that 
89 

a lot of that work has been superceded by looking at the current 

scenario. 

Chairman HALL. And I think the estimate was around 800 reduced fatalities over 10 years, and to be more—to be exact, that is 

something I think we should be, there is a 64 air carrier and one 

was mentioned by the one that had a Congressman aboard. I think 

I remember the day that Congressman left here to go on an international meeting. It was a lot of secrecy about it. I have even been 

told that some people thought the airplane was shot down because 

he was on it, which is a bad loss of life there, and they were supposedly over into the wrong airways when they got shot down. 

But that was the 64. That is part of the air carrier and then the 

general aviation part, there is 730 reduced fatalities over 10 years 

according to this potential averted fatalities report and for a total 

794, not 800, but 794, and also in the report they indicated the cost 

of money. That based on input from RTCA as well as National 

Space-Based Position, Navigation, and Timing Systems Engineering Forum, proposed LightSquared development would result in an 

estimated aviation community cost. Community cost of at least $72 

billion stemming from two billion loss of existing GPS efficiency 

benefits, five billion loss of existing GPS safety benefits, 59 billion 

due to delayed NextGen benefits, and six billion in aircraft retrofit 

costs. 

Additionally, LightSquared deployment resulted in an additional 

30 million tons of CO2, and FAA would be forced to re-plan 17 billion in NextGen investments with associated additional development costs. Those are within the findings of the FAA, Federal 

Aviation Administrator’s research and report. 

Are you satisfied with that, the accuracy of it, and have you examined it on your own? 

Mr. APPEL. My—I have looked at it. My colleague, the head of 

the FAA, the Administrator, Randy Babbitt, when asked about this 

issue, has made clear that he is not going to let anything happen 

that is going to jeopardize safety of aviation. We have gotten progressively better and better every year in our aviation safety in 

this country, and the FAA takes every measure possible to ensure 

that no matter what the potential threat to safety, we address it 

before it happens. 

Chairman HALL. All right. I just have a little bit more time left. 

I think you have answered my question, and I would ask Ms. 

Glackin, and you are the only one I will ask this because I don’t 

have the time and because you are associated with the weather, 

and we are all aware of some weather around here, this Nation at 

this time, more than ever before. I don’t ever remember this many 

earthquakes or forest fires. 

If NOAA received full funding for its satellite programs but the 

LightSquared proposal was approved, how would the Nation’s 

weather forecasting capabilities be affected? 

Ms. GLACKIN. NOAA has—— 

Chairman HALL. If you can give me a good quick answer. 

Ms. GLACKIN. Yeah. I was going to say even with that full funding NOAA has concerns about the impacts of LightSquared because 

depending on how it is implemented it touches so many parts of 
90 

our warning mission, from our radars on the ground to the satellites that are operating in space. 

So I couldn’t give you any confidence today that we would be able 

to successfully deliver on that mission. It would be impacted to 

some degree, and we would need to do much more testing to understand that. 

Chairman HALL. And in closing, Mr. Russo, Mr. Sparrow, Mr. 

Appel, Dr. Applegate, would your answers have been similar to her 

answer as it affects the division you represent for the people of the 

United States? 

Mr. RUSSO. Yes, sir. 

Chairman HALL. Each of you have a yes or no on that? 

Mr. SPARROW. Yes, sir. 

Mr. APPEL. Yes, sir. 

Dr. APPLEGATE. Yes. 

Chairman HALL. All right. I have used up all my time. 

At this time I recognize Ms. Johnson, the Ranking Member, for 

five minutes or whatever time you have to use. Ms. Johnson. 

Ms. JOHNSON. Thank you very much. 

Chairman HALL. I went over about almost a minute. 

Ms. JOHNSON. A little over a minute. 

Chairman HALL. You can go for six minutes if you want to. 

Ms. JOHNSON. I understand that minimal testing was done by 

the Technical Working Group to examine whether LightSquared’s 

proposed plan to re-phase its bandwidth use and reduce power will 

mitigate the network’s impact on most GPS applications. Agency 

statements today are consistent in their call for additional testing. 

What do agencies need to know about the new LightSquared proposal to assess its impact on their programs? How long this process 

take, and I would like to hear from all witnesses, but let’s start 

with Mr. Russo and Mr. Carlisle. 

Mr. RUSSO. Yes. The first part of the question in terms of what 

we would need to know, the first thing we need to know is what 

the final end-state configuration is. In LightSquared’s recommendation paper of 29–June they had three recommendations. One was 

to broadcast initially in the lower 10 megahertz of their band, two 

was the reduction in power to basically the same power level that 

we were testing at, and the third one is the one that is problematic 

for us, which is that at some point in the future they would be 

broadcasting in the upper half, and that point is undefined. They 

called it a standstill period, and we don’t know at what point that 

would occur. That is the key missing piece to being able to construct a new test to say whether we will or will not have substantial interference. 

And in terms of how long it would take, that will depend somewhat on that answer. 

Mr. CARLISLE. To be clear, it is not true that there was no testing 

at the lower 10 by the Technical Working Group. In fact, every subgroup tested the lower 10, and it wasn’t either in the final days. 

Some of the subgroups had from the very beginning of their work 

a plan to test the lower 10 against their devices. 

So in effect, there has been testing of 130 devices across seven 

different categories on the lower 10, and some of those categories 

are fine. Precision is not as we have heard here today. We take a 
91 

measurement of 10 out of the 38 precision devices that were ultimately tested actually will operate fine in the presence of the 

power levels that will reach the ground in our network. 

But very quickly I would say if there is a specific plan for additional federal testing, we have yet to hear it from any agency at 

this point. The only claim we have seen in terms of additional testing needed is from the Department of Defense to test certain classified receivers that were not tested on the lower 10 as part of the 

Department of Defense’s testing. 

But we are completely open to speaking with the government 

agencies about facilitating further discussion on this and also about 

whether the upper 10 that Mr. Russo just mentioned is ever going 

to be—it can be used down the road. 

Ms. JOHNSON. Do you want to comment on that? 

Ms. GLACKIN. I would just comment quickly, point out that Mr. 

Russo’s original testimony really highlighted some of the shortfalls 

in the testing that was done, and in particular that only one transmit antenna was part of the testing configuration, and we know 

that there is—there can be interference effects, you know, are additive there and also the fact that the time period was so compressed. 

There is a lot of complexity to work through. 

Ms. JOHNSON. Thank you. Mr. Russo, in your opinion is it technically feasible to design a filter that simultaneously allows GPS 

users to listen to signals in LightSquared’s allocated band, and 

block LightSquared’s signals? 

Mr. RUSSO. I am sorry, ma’am. I don’t know the answer to that. 

We are dealing with a very large power difference. At half a mile 

the LightSquared signal is five billion times more powerful than 

the GPS signal by the time it gets down from space. That is a big 

number to be able to reconcile. 

Dr. Parkinson from Stanford University expressed it this way, 

that the GPS signal is like a teaspoon of water. The LightSquared 

signal is Niagara Falls. That is about a five billion difference. I am 

a very optimistic person. I think that given time, given the right 

technical people talking to each other there may be a way to do 

this, but I certainly don’t know that, and I certainly would want 

to see that tested before I would be able to say that would work. 

Ms. JOHNSON. Can you estimate its cost? 

Mr. RUSSO. No. I am sorry. I can’t. 

Ms. JOHNSON. Mr. Carlisle, would you like to comment on that? 

Mr. CARLISLE. Yes, I would. Actually, its effect which is the comparison of our base station power against the power level of GPS 

signals was known in 2005. So my question generally would be why 

did the GPS manufacturers not test that and determine there was 

an effect? Why was the overload effect never mentioned during the 

four years of testing, and why wasn’t that made a condition of 

our—any sort of condition about our investing and deploying the 

network? It was only brought up in the last year. 

Now, we have done everything we can in order to address this 

issue, and we have made sincere, real commitments in order to address it, but at the end of the day this is a six-year-old issue on 

which nothing was done in order to address receiver overload. 

Ms. JOHNSON. One last quick question. Dr. Pace, would you comment on that? 
92 

Dr. PACE. Well, I would first of all say I agree that trying to 

overcome a billion dollar, I mean, excuse me, a billion times power 

difference is technically very difficult, and because of that technical 

uncertainty it is difficult to say how much money would be required. 

With regard to how long this issue was known, I think one additional fact is that the FCC time and time again from the original 

discussions in 2002, up until January of 2010, were very adamant 

that they would forbid any sort of stand-alone terrestrial wireless 

service. In fact, they made a number of points in the proceedings 

about how they would not allow evasions of the satellite requirement, what was called the gating requirement, the need to link to 

a satellite. 

This linkage is very important because it meant that the groundbased systems, the ancillary treshold component, could not interfere with the satellite, and therefore, the mobile satellite service 

band would remain a quiet band. So I would say that the GPS industry for the period that Mr. Carlisle mentions was relying on the 

assurances of the FCC that the band would remain a satellite 

band, and the issue of numbers of ground stations and powers and 

so forth is truly an ancillary issue to the core question of would 

this band remain a satellite band. If it is a satellite band, then you 

have no problem. If it is not a satellite band, you have a problem 

that you see here today. 

Ms. JOHNSON. Thank you. My time has expired. 

Chairman HALL. Thank you. The gentleman from Wisconsin, the 

Vice Chairman of this Committee, Mr. Sensenbrenner, is recognized for five minutes. 

Mr. SENSENBRENNER. Thank you very much. 

Mr. Carlisle, all of your contracters on this panel don’t seen to 

have a high regard for your position, and I have got a few questions. Maybe I can blow a little bit of the fog away. 

Say you don’t get permission from the FCC to use the high-end 

band, meaning the upper 10, for LightSquared. Would you still invest the $14 billion in this project? 

Mr. CARLISLE. We would invest the maximum amount of money 

necessary in order to build out on the spectrum we had. So if we 

can’t use the—if we can build out on the lower 10, we will invest 

as much as we need to get a robust network. 

Mr. SENSENBRENNER. How much would that be? 

Mr. CARLISLE. I can’t tell you that sitting here right now. I would 

need a network engineer and a business model to go through that, 

but right now the plan is 14 billion. 

Mr. SENSENBRENNER. Now, what would happen if there was a reduction in power? You know, we have heard about the teaspoon of 

water versus Niagara Falls. Would you still be able to make a go 

of it if you got a tablespoon of water? 

Mr. CARLISLE. Well, that is—in order to provide a wireless 

broadband network, you need cell towers or base stations that are 

operating consistent with the power levels that you need for that 

in order to make it economically viable. Otherwise you just have 

so many cell towers it becomes economically infeasible to provide 

service. 
93 

So at the power levels we have committed to right now, that is 

a network that is the size of between 30,000 and 40,000 base stations. 

Mr. SENSENBRENNER. Okay. Now, you made a deal with Sprint, 

and they have got a lot of cell towers around the country. 

Mr. CARLISLE. Uh-huh. 

Mr. SENSENBRENNER. Because you would have access to those, 

would you still spend the 14 billion? 

Mr. CARLISLE. Our plan is yes. We are spending nine billion with 

Sprint alone in order to deploy the network, and the 14 billion is 

the total of capital and operating expenses over eight years. 

Mr. SENSENBRENNER. Now, how much of that is Sprint’s money, 

and how much of that is LightSquared’s money? 

Mr. CARLISLE. Nine, the $9 billion is what we are spending to get 

the network deployed. 

Mr. SENSENBRENNER. Is this LightSquared’s money? 

Mr. CARLISLE. I believe so. Yeah. I am not sure what the—we are 

spending—we are giving—spent $9 billion to—— 

Mr. SENSENBRENNER. You know, I noticed the name of what is 

now LightSquared has been changed as a result of reorganization 

several times in the last decade, which is—— 

Mr. CARLISLE. Right. 

Mr. SENSENBRENNER[continuing]. Not particularly comforting to 

me, you know, unless something end up midstream on this. The 

other line of questioning I would like to have in the time that I 

have remaining is what kind of testing has there been on precision 

GPSs, which are the most expensive ones and, you know, the ones 

that I would say that we need particularly in a transportation sector to make passengers safe. 

We have heard that retrofitting as a result of potential interference would cost billions of dollars, largely in an airline industry 

that really isn’t all the financially healthy. What kind of testing 

have you done on this stuff? 

Mr. CARLISLE. Well, if you are talking about—the Technical 

Working Group tested both aviation receivers, which are used in 

aircraft, and also the standards that are applicable to the WAS network that is going to be used for Next Generation, and separatelytested precision receivers, which are largely used in agriculture, 

construction, survey, and for scientific research as we have heard 

today. 

Those precision receivers were tested fully on the bottom 10. In 

terms of the level of the scale that we are talking about here, if 

we are talking about cellular phones, personal navigation devices, 

aviation receivers, and timing receivers, it is about 400 million devices around the country. If we are talking about precision as it 

was tested at the Technical Working Group, it is less than a million, probably about—between 500,000 and 750,000 receivers. 

Mr. SENSENBRENNER. Okay. 

Mr. CARLISLE. So in terms of the investment needed to replace 

those receivers, this is not, you are not talking about replacing 400 

million receivers. You are talking about replacing a much smaller 

number. 

Mr. SENSENBRENNER. One of the complaints I have heard is that 

LightSquared has been changing the parameters of what it pro-
94 

poses to do before the testing is completed. The Committee has information that you have a newer proposal. Has that been filed with 

the FCC yet? 

Mr. CARLISLE. We have a proposal in addition to our last proposal. It was filed at the FCC on Wednesday, and it is attached to 

my testimony. 

Mr. SENSENBRENNER. Okay. Now, are you going to stick by that 

proposal until the testing is done, or if something bad comes out, 

is there going to be another proposal that would be filed, in which 

case the testing would have to go to square one? 

Mr. CARLISLE. Well, let me respond to that in this way. We are 

sort of—we are acting in a situation where the GPS manufacturers 

have—and the federal agencies have most of the information about 

what GPS devices they use and how they operate. So our original 

proposal was in the absence of having that information. As the information started to become available, started to become obvious 

that there was going to be a problem on the upper 10, we came up 

with a proposal that would mitigate the issue by moving to the 

lower 10 at a cost of $100 million to the company. 

That is what you do when you see engineering problems. 

Mr. SENSENBRENNER. I don’t think that answers my question of 

whether we are going to have to go back to square one again with 

a new proposal if the testing shows that there is another problem 

that comes up. 

Mr. CARLISLE. Well, the proposal we have discussed this week is 

in addition to our other proposal, so it is incremental on top of it. 

If there are additional issues discussed, that come to light with regard to federal receivers or other receivers, we will take that into 

account and see what we can do to fix it. But at this point you do 

raise a very good issue in that we have made all the proposals to 

solve this issue, and we are spending all the money to do it. The 

GPS manufacturers have not. 

Mr. SENSENBRENNER. Well, GPS was there first, and a lot of people use GPS, and, you know, I don’t want to have to face my constituents at a town meeting if their GPS ends up not being what 

it is supposed to be and what it has been as a result of spectrum 

interference. 

You know, Mr. Carlisle, I wish I could have gotten more direct 

answers to questions that were pretty direct, but maybe you can 

supply them with written testimony later on. 

Mr. CARLISLE. I would be happy to if there is anything I didn’t 

answer. Sorry about that. 

Chairman HALL. All right. The gentleman’s time has expired. 

The Chair recognizes the gentleman from California, Mr. 

McNerney, recognized for five minutes. 

Mr. MCNERNEY. Thank you, Mr. Chairman. I just want to say to 

Mr. Carlisle, you knew this was going to be a tough afternoon, so 

I appreciate your coming out here and testifying. 

The frustrating thing is that every one of us would like to see 

you move forward because of the economic boom that broadband 

brings, but we are all very concerned about the impact on a very 

well-established and growing set of industries and businesses. 

One of the things I heard you say was that the problem in your 

opinion can be solved by responsible receiver design, and by that 
95 

I take it you mean GPS receivers. And so that implies a significant 

investment by the GPS people, and I am not even sure that that 

technology exists. A lot of folks here don’t seem to think that it 

does, but I agree with Mr. Russo. I think that there are technical 

solutions in the future that if enough investment is made will become available. 

So I am not going to be writing off anything at this point, but 

I would like to have a little bit more comfort that the technical solutions on the receiver side actually work. 

Now, you have charted out a plot on page seven of your Power 

Point that shows a 40 db reduction in signal transmission. How 

many orders of magnitude is 40 db, Dr. Pace? Do you have an idea? 

Because we are talking about a nine order of magnitude difference 

in signals. Is 40 db equal to nine orders of magnitude? 

Dr. PACE. I would have to go back and get my computer. 

Mr. MCNERNEY. Yes. Does—— 

Dr. PACE. I may look at Tony to save me, but it is on the order 

of multiple orders of magnitude. I mean, 1 db is a major change, 

10 I think is an order of magnitude. So I would guess about four 

orders of magnitude unless someone wants to correct me. 

Mr. MCNERNEY. Well, and Ms. Glackin is also concerned about 

the attenuated part also causing distortion of the GPS signal. We 

have a seven nanosecond delay. Is seven nanoseconds acceptable in 

precision GPS? 

Dr. PACE. I would have to say no, because, again, this is something that is very interesting in the different applications, and Mr. 

Carlisle is quite correct to point out the differences in the different 

categories of receivers. A seven nanosecond delay created by a filter 

may not be an issue for say a smart phone, but a seven nanosecond 

delay can be on the order of several meters of error that can be introduced, which is a big deal if you are a precision farmer working 

at two to 10 centimeters. 

So it depends on what is the baseline level of performance you 

are going to be looking for. A filter that may work for certain categories of users may not be applicable to others, and as Mr. Carlisle mentioned, the precision users are probably the most stressing 

of the folks you have to deal with. 

Mr. MCNERNEY. Well, I mean, it seems to me that there are technical solutions in the future, and I want to go there, but what is 

happening is that you are sort of saying and Mr. Carlisle, you are 

saying that the rules have changed along the way from what was 

originally required, but the problem is that if you are talking about 

public safety, that is a losing argument. We need to get to a point 

where the public safety people are comfortable, or this isn’t going 

to go forward. I mean, that is the bottom line, so I see a great deal 

of cooperation on your part and earnest effort to get there, but I 

am not convinced that we are there yet, and anything you can do 

to convince me or the Members of this panel would be useful. 

Mr. CARLISLE. If I could respond on two things. First of all, on 

public safety the primary use of GPS by public safety is two ways. 

On timing receivers and in simulcast networks, the public safety 

entity is used and in vehicles and for mission-specific use of personal navigation devices. 
96 

Under our current set of proposals no public safety devices will 

have—no personal navigation devices will have a problem with the 

deployment of our network as long as we are operating on the 

lower 10 megahertz. On the timing devices that should also be the 

case, but if some of these timing devices happen to be in close proximity to one of our transmitters, there are replacement antennas 

available that are completely filtered against our signal that are 

available on the market today for $100 each. So this is an issue 

that can be handled. 

In terms of precision receivers, this is directly out of the report. 

It is slide 12 in the Power Point attachment to my testimony. This 

line is the power level that we will be broadcasting at that will 

reach the ground. These dots are all precision receivers that were 

tested. Now, most of those fall below the line and would show 

harmful interference. These ten above the line would operate fine 

in the presence of our signal. 

This is a design choice. It is not an immutable physics problem. 

We know it because we can see the performance of the receivers. 

Mr. MCNERNEY. Okay. Well, one of the issues that has been 

brought up is a lack of testing in the lower 10 band, so I just don’t 

think we are quite there yet, and I want to see what you are proposing to go forward because it just—we need jobs, and this is 

going to create them, but in my opinion we are not quite there yet, 

and I would like to see that happen. 

So with that I will yield back. 

Chairman HALL. I thank the gentleman. 

Next the gentleman from Maryland, Dr. Bartlett, is recognized 

for five minutes. 

Mr. BARTLETT. Thank you very much. 

It seems to me that the actions of the FCC seven years ago might 

have anticipated that we would be here today talking about this 

problem because as I understand it, the FCC granted 

LightSquared, then known as MSV, conditional approval to build 

its integrated ATC ground-based wireless network using its satellite spectrum near the GPS signal. Wouldn’t it have been expected that the enormous disparity between the GPS satellite signal and these ground signals would have produced some bleed that 

we would have this problem? 

I am a little concerned as to why that spectrum so close to GPS 

was granted. I am also confused by the FCC’s rulings here. In 

2003, when they adopted the initial rules allowing commercial satellite service providers who operate a ground-based integrated with 

their satellite service, they made this statement. The purpose of 

our grant of ATC authority is to provide satellite licensees flexibility in providing satellite services that will benefit consumers, not 

to allow licensees to profit by selling access to their spectrum for 

terrestrial-only service. 

And then I note that on January 26 of this year the FCC granted 

LightSquared a conditional waiver of its ATC authority integrated 

service rule meaning its customers could offer terrestrial-only services. 

Now, did our staff make an error in this briefing paper, or is this 

a direct contradiction? 

Mr. CARLISLE. Are you asking me or—— 
97 

Mr. BARTLETT. Whoever can answer. Because it appears to me a 

direct contradiction. My concern is that I think that we, the government, are somewhat complacent in this problem that I wonder 

why we were ever—gave a spectrum so close to the GPS signal that 

when you have a billion time disparity, wasn’t it anticipated that 

there was going to be a bleed over? Who would have thought there 

wouldn’t have been a bleed over that would compromise the GPS? 

For at least the low-end technical receivers. 

Mr. CARLISLE. Well, Congressman, the FCC process is only as 

good as the input it gets, and at the time from 2001 to 2005, the 

only issue that was discussed was the possibility of our signal 

bleeding over into GPS. 

Mr. BARTLETT. Well, was it a given that being a billion times, if 

you went to a ground based and pumped it up, wasn’t it just anticipated that a billion times more powerful signal was going to bleed 

over? 

Mr. CARLISLE. And that is why we entered into an agreement in 

2002, with the GPS Industry Council to filter our transmission so 

it would not bleed over. The issue that was not—— 

Mr. BARTLETT. It is bleeding over because many of the devices 

you tested were compromised by it, and now you are using only the 

lower end of it, which still bleeds over is my understanding. 

Mr. CARLISLE. Well, as Dr. Pace’s testimony points out, the testing actually showed that if you look at what our signal is doing, 

it is not tapering off into GPS and causing a problem. We have filtered it. The problem is caused by receivers that are looking not 

only at the GPS signal but also looking at our signals. 

So even if we have a filter so we don’t bleed over into GPS, they 

are still seeing our signal. It is a receiver-side issue that was never 

raised between 2001 and 2005. 

Mr. BARTLETT. But if the frequencies were further apart, this 

wouldn’t be a problem. Right? 

Mr. CARLISLE. Not—no, it would not be a problem and—— 

Mr. BARTLETT. Okay. 

Mr. CARLISLE[continuing]. That is why we have offered to move 

to the lower part of our spectrum. 

Mr. BARTLETT. Was there no signal more distinct from GPS that 

could have been given to LightSquared? I am confused as to why 

they ended up with a spectrum so close to the GPS. 

Mr. CARLISLE. Well, we had been licensed to use that spectrum 

since 1989, when the FCC added the possibility of having a ground 

network. The only issue related to GPS interference that was 

raised was the issue that we accounted for in our filtering. This receiver overload issue was not raised to the FCC until September 

of 2010. Entities that had the information, the performance of their 

receivers and how much spectrum they actually look at, the GPS 

manufacturers did not raise it until then. 

Mr. BARTLETT. But even with the filtering and even with only 

using the lower half of the band, don’t we still have a very significant number of GPS receivers that are compromised? 

Mr. CARLISLE. The testing shows that that would be precision receivers primarily, which amount to perhaps 750,000 in the country 

compared to 400 million other types of—— 

Mr. BARTLETT. They both are big numbers. 
98 

Mr. CARLISLE. But not—in terms of precision receivers, not an 

impractical number to handle over time. 

Mr. BARTLETT. Thank you, Mr. Chairman. 

Chairman HALL. I yield you another minute. Dr. Pace has been 

holding his hand up there for about five minutes, I think wants to 

help answer this question. 

Dr. PACE. Thank you. The thing I would have to add is that 

when the discussions took place between the GPS Industry Council 

and the predecessor organization, MSV, I was at NASA at the time, 

and so I knew that these two groups were going off to have these 

conversations with each other and the out-of-band, the emission 

limits, bleed-over issue was certainly one of the issues that was discussed in great detail before the groups came back to the FCC and 

came back to the government agencies to talk about what their solution was. 

I think an integral part of that solution was the fact that this 

was still supposed to be an ancillary terrestrial component, an addon extension, a fill-in service to a satellite service. So the satellite 

gating requirement and the preservation of the band as a satellite 

band was crucial. It was not a matter of looking at one solution in 

isolation, that is the out-of-band emissions into the GPS band. It 

was a total look at what that band was like, what the neighborhood 

was like, and it rested on the assurances of the Commission that 

they intended and wanted to preserve that band for mobile satellite 

services. 

So I recall the very deep technical discussion, there was a total 

package that was looked at, there are a number of technical characteristics that were preserved. If one was to go and change those 

characteristics and say convert this satellite band to a mobile service, a terrestrial band, the normal process one would go through is 

a notice of proposed rulemaking. This is what happened up at other 

bands, what is called the S band up around two gigahertz. You 

have probably heard of Charlie Ergen and DISH Network and 

some of these other guys have proposals there. 

So the FCC engaged in proper notice and proposed rulemaking 

when they made other major changes. In this particular case they 

granted a waiver without really in my view sufficient technical 

data in place to support that waiver, then testing occurred after 

the fact to see if it could be made to work. They made a major 

change in the allocation of the band from satellite to a terrestrial 

service without the notice of proposed rulemaking that they engaged in in other areas. 

So I think your phrase that the government is a little compliant 

in this is actually quite true, that there were indications and encouragements made for a very worthy cause of more broadband but 

where sufficient homework was not done, and that has led to the 

situation we are facing today. 

Chairman HALL. Thank you very much. 

Next—do you yield back now, professor? 

Mr. BARTLETT. One final comment, Mr. Chairman. I wonder is 

there not a technology that could migrate this system for the 

ground-based component that would make it not competitive or 

threatening to GPS? 
99 

Do we have receivers that are designed to receive both the terrestrial signal and the space signal, or are they two kinds of— 

strength is enormously different; I would judge that you got two 

different—— 

Mr. CARLISLE. There are, well, for our band, yes, we are going 

to—the concept that this is going to be a terrestrial-only network 

is wrong. We will continue to have an integrated network. We invested in a satellite. We will continue to use it. We will have dualmode devices that will enable these devices to talk to the satellite 

and loop through it. 

Mr. BARTLETT. But they are dual mode—— 

Mr. CARLISLE. Yes. 

Mr. BARTLETT. [continuing]. Because they have a part of it which 

receives the terrestrial signal and another part which receives the 

space. 

Mr. CARLISLE. Absolutely. 

Mr. BARTLETT. We aren’t concerned about the satellite I understand. It is only the terrestrial part of it that is a concern. Why 

cannot we simply migrate that signal so that it is not competitive? 

Mr. CARLISLE. To the ground—— 

Mr. BARTLETT. Yes. 

Mr. CARLISLE. Network somewhere else. 

Mr. BARTLETT. Completely move the band width. 

Mr. CARLISLE. Well, that has been proposed by some of the GPS manufacturers. We have invested $4 billion in the spectrum so far 

and but what those proposals amount to is go somewhere else and 

spend another $4 billion to develop your technology in another 

band. So that is one problem. 

The other problem is that where is it? Every piece of spectrum 

that is suitable for a ground network is already taken by someone 

else. 

Chairman HALL. I would be upset if I hadn’t caused that last 

question, but I always get more of out Dr. Bartlett’s questions than 

I do out of the answers. Thank you. You are a good Member. 

And we have another good Member that has been very patient. 

The gentlelady from Maryland, Ms. Edwards, my friend, is recognized for five minutes. 

Ms. EDWARDS. Thank you, Mr. Chairman, and thank you also to 

the Ranking Member and to our witnesses today. 

You know, I am just coming at this from your basic consumer. 

I think none of us can, you know, question the fact that GPS is so 

pervasive in our lives that obviously we don’t even know it anymore because it is everywhere and everything, and that is a good 

thing, and I think it is one of those examples where the government has made a significant investment, and it is good government 

work, and you know, at a time when we seem to be, you know, cutting back and challenging every single aspect of government, I 

think the American public can be thankful for the investment that 

the Federal Government and taxpayers made in the development 

of GPS. 

I think the confusion here is that we have competing national 

policy directives. On the one hand we have the, all of the good work 

of our scientific and technological agencies that are dependent on 

GPS for important and critical services, and on the other hand we 
100 

have a policy directive from the Administration, which I think is, 

you know, right in terms of expanding the ability of broadband to 

be accessed in multiple communities, and that was my signal that 

I am going to keep going until my time is up. 

And so—and I share that, I share the value of doing that. I 

mean, in urban and suburban areas, even like ones represented in 

my Congressional district, that are plenty of people who for a variety of reasons because of the level of competition and the lack of 

access, there are plenty of communities underserved, both suburban and urban, who need greater access and need that at competitive rates that people can afford. In rural areas, obviously, that 

challenge exists, too, and so it is a great goal to have to expand 

broadband access. 

And so what I would like to know is given the level of investment 

that the Federal Government has put in and the competing policy 

directives, why it is that our agencies don’t have some responsibility and the Federal Government doesn’t have some responsibility 

to figure out a solution that allows LightSquared to move forward 

at the same time that we protect our vital GPS services. And it 

does seem to me that our federal agencies can’t just sort of sit and 

wait and say, well, LightSquared, you figure that out without some 

responsibility of our own agencies. 

I mean, NextGen, for example, is just in development. Why is it 

that we are not investing in the technology that is going to allow 

for the existence of these two services, even if it means that at 

least part of the band width isn’t used in order to guard GPS but 

then allows LightSquared to develop the part of the band with— 

that can be used. 

And so my question for the agencies is what investment are you 

all making to try to meet the dual directives, policy directives of 

the Administration that I outlined previously? 

Any one of you can take that question. 

Mr. RUSSO. I will start off, see if I can get part of this. We recognize the dual directives. The one piece I want to point out is that 

the President’s broadband directive also contains the caveat that it 

not be done at the expense of critical federal, state, and local capabilities. So he recognized that when they gave the initiative out, 

that, you know, do this but do this without stepping on other 

things. 

In terms of investment, we do need to make ourselves more efficient, and as Dr. Pace said, GPS is really the most efficient spectrum use we have ever seen, where we have a billion users in 20 

megahertz. But we concur that we need to work towards making 

it even more efficient in the future. Our demands for spectrum are 

going to continue to grow, especially in terms of our broadband 

needs. 

So we do have a responsibility to try to work with all of our partners to make that more efficient, and the FCC is the lead for that. 

In terms of this specific issue, we have taken out of hide all of 

the technical experts that we have available to try to work this 

problem. We don’t have—this NPEF I talked about is not a standing organization. When I sent the tasker out, people had to be 

pulled from their regular jobs in order to come together to do this 

testing. 
101 

So the departments and agencies don’t want to do this perpetually. They want to be able to do this on a focused answer. We 

can’t do this 365 days a year. You haven’t authorized us the money 

to be able to keep these people as a standing test for anything that 

somebody might come up with. 

So that is part of the answer. We are willing to work on future 

testing and future alternatives to try to make this work. We are 

seeking a win-win solution, and that is guidance we will receive 

from the White House, and we are all working towards that. Could 

we do more? Maybe. We are also resource constrained. 

Ms. EDWARDS. Could I hear for a moment from the Department 

of Transportation because, you know, NextGen is just in development. You are not finished, you are not done, you are not, you 

know, where you need to be yet. Why is it that you can’t work on 

some technological solution that allows the compatible existence of 

these two technologies? 

Mr. APPEL. Certainly. The Department of Transportation believes 

that we would want nothing more than to have expanded 

broadband capabilities. Expanded broadband capabilities has tremendous benefits for transportation in improving efficiency, in improving environmental sustainability, and just getting better 

routings, not just from the navigation GPS but from better 

broadband applications across the spectrum. 

So in the case of this win-win that Mr. Russo is talking about, 

yes, we are—the FAA has put people, we are working very closely 

with the Technical Working Group, not just to find problems, but 

to find solutions, to find that win-win. 

In the case of NextGen in particular, yeah, we want to make 

NextGen work as well as it can based on what we have with which 

to work. A lot of the receivers, for example, on which NextGen will 

be based are already either there or in development. There are future aspects of NextGen, there will be several billion dollars in additional investment from each of the public and private sector, and 

that can be affected by the state of the world today, but there is 

also a lot that is already in place that we have to work from. 

So we just—so bottom line we would want to as best as we can 

help find the win-win solution. We would also have to accept that 

there are certain give-ins that we have to deal with. 

Ms. EDWARDS. Thank you, Mr. Chairman. I failed in staying in 

my five minutes. 

Chairman HALL. You did pretty good. I thank the gentlelady, and 

I thank the gentleman for his answers. 

The gentleman from California, Mr. Rohrabacher, is recognized 

for five minutes. 

Mr. ROHRABACHER. Thank you, Mr. Chairman, and I have been 

trying to take in the information. I was actually—when I left, I was 

watching you from my office, which is what we often do. 

Let me ask, first of all, let me suggest that—is it Carlisle? Is that 

how you pronounce your name? You are doing a terrific job for your 

company. Let me just note that you have got all of these guys 

against you, and there you are, and you are holding your own, and 

I often find myself in that position, so I certainly appreciate it. 

Chairman HALL. The gentleman’s time is almost over. 
102 

Mr. ROHRABACHER. Let me—so I am trying to glean exactly how 

we get to the core of the issues here, but because I admire the job 

you are doing doesn’t mean I agree with the positions that you 

have taken. 

The—we are talking about a company now, LightSquared, that 

received a waiver originally from what other companies would have 

been expected to, and how much did LightSquared pay for the right 

to own this band? 

Mr. CARLISLE. We received the spectrum in 1989, when spectrum 

was still allocated on a competitive process. Auctions didn’t start 

until the late 1990s. 

Mr. ROHRABACHER. So how much did you pay? 

Mr. CARLISLE. We paid nothing at the time. 

Mr. ROHRABACHER. You paid nothing at the time for that right, 

and you had a waiver for other restrictions, and so while I would 

have to admit that my sympathies might be a little bit greater if 

I would have learned that your company had actually paid a great 

deal of money out of their pocket for the right to this to begin with, 

so we are recognizing that this was a publicly-owned asset that 

was transferred ownership to your company for nothing. 

Mr. CARLISLE. Sir, can I respond to that? 

Mr. ROHRABACHER. Yes. Please. 

Mr. CARLISLE. Okay. Originally when we received the allocation, 

it was before auctions were in place. That is how spectrum was allocated, and in fact, that is how the original cellular networks were 

built by the companies that own them. 

Mr. ROHRABACHER. Yes. 

Mr. CARLISLE. Cingular, all the rest of them, they got spectrum 

for nothing as well—— 

Mr. ROHRABACHER. Yeah. 

Mr. CARLISLE [continuing]. Before auctions were instituted. We 

subsequently invested several billion dollars to put up satellites to 

use it—— 

Mr. ROHRABACHER. Right. 

Mr. CARLISLE [continuing]. And provide public safety services 

and significant public benefit to the United States. When our company was acquired for $3 billion last year, that was an investment 

in the spectrum, and further investment—— 

Mr. ROHRABACHER. When you were granted this and the waiver 

was specifically—had something to do with whether or not—as long 

as you were not interfering with others’ use of the band near your 

band width, was that correct? I mean, that was part of the agreement that you had when you received this right to this band width. 

You did not receive—— 

Mr. CARLISLE. Are you talking about the waiver in January? 

Mr. ROHRABACHER. The waiver and the original grant. You 

were—wasn’t there pre-condition that this would not be interfering 

with other activities in nearby band widths? 

Mr. CARLISLE. Well, anybody who receives spectrum has the obligation not to interfere with adjacent bands. 

Mr. ROHRABACHER. Right. 

Mr. CARLISLE. We are operating within the limits—— 

Mr. ROHRABACHER. Okay. 

Mr. CARLISLE [continuing].On our network. 
103 

Mr. ROHRABACHER. And wasn’t it pretty well understood as then 

the satellite that if you did choose to go the satellite route in the 

development of your right to use this band, that it might, indeed, 

complicate things to the point that you were interfering or there 

was a potential interference, because now you are using satellite 

rather than ground-based systems. 

Mr. CARLISLE. Well, there was no issue with the development of 

our satellite network, which we have operated for 15 years. That 

is—that does not cause interference with GPS. The potential interference comes from the ground-based network. 

Mr. ROHRABACHER. Okay. I am trying to—that is what I am trying to learn here. We are not—none of us are engineers. So right 

now what we have heard from these witnesses is that there is potential interference at least in a very small, maybe 98 percent has 

been corrected, but there is a small area where there might be 

some kind of interference, and you have, of course, confirmed that. 

Now, you don’t—your company’s position isn’t that you should 

move forward even though there is this potential interference. You 

seem to be saying if the people who are being interfered with will 

buy certain types of technology, that interference can be overcome 

or might, it might be overcome. 

Mr. CARLISLE. Well, and we have committed to fund the research 

of the—take the cost of that off the GPS manufacturers and fund 

it ourselves. So we have actually put earnest money up in order to 

solve this problem. 

Mr. ROHRABACHER. And but that is in terms of the scientific research. Have—are we satisfied that the science exists, not that we 

will pay for it until it comes out, that the science exists to take care 

of the problem, meaning that last entity or part of the band that 

will possibly interfere with GPS? Is the consensus that technology 

exists, or is this a—something that is—you are suggesting that it 

might exist if we made this investment in research and development? 

Mr. CARLISLE. We know it exists today because these receivers, 

these precision receivers are just fine. It is a technology design 

choice. 

Mr. ROHRABACHER. I have one last question, Mr. Chairman. Are 

you in agreement with that, that you were—he said we are satisfied that the technology does exist by this test? 

Mr. RUSSO. Sir, there is not a consensus on that. Some of the receivers passed, but they may have a different application. Not all 

precision receivers do the same thing. The GPS community is so diverse and the way this TWG report is presented, it is—there is an 

anonymous receivers. In order to get everybody’s cooperation, the 

manufacturers that submitted devices didn’t want their device to 

be named. So I don’t know whether the ones that are above the 

line, what specific function they do. So it may be that they don’t 

need to be as precise as other ones, and therefore, can have more 

filtering. 

So the answer from inside the government is that our technical 

experts are split as to whether it is even feasible that we could put 

a filter in that was both strong enough to knock out the 

LightSquared signal and still allow us to do our mission. That is 

the hard part is the second part of that, not the first part. 
104 

Mr. ROHRABACHER. Thank you very much, Mr. Chairman, for the 

extra time. 

Chairman HALL. Thank you. The Chair recognizes Mr. 

Neugebauer, who is one of the members who asked for this hearing, and recognize him for five minutes or whatever time he has 

to use. 

Mr. NEUGEBAUER. Well, thank you, Mr. Chairman. I think this 

has been a good hearing, and one of the problems of being one of 

the last people in the question queue is I think a lot of the questions and statements that I wanted to make have been asked, but 

I do appreciate you holding this hearing. I think it is an important 

issue. Certainly, you know, the broadband issue is for—spreading 

that around to the rest of the country is important, but it is also 

important that we protect our GPS as well. 

And so I ask unanimous consent, Mr. Chairman, that a letter 

that we wrote the FCC Chairman, which you so kindly joined in 

on June the 7th, as well as the response I received, that they be 

made a part of this record. 

Chairman HALL. Without objection. 

[The information can be found in Appendix 2.] 

Mr. NEUGEBAUER. I also ask unanimous consent that the testimony of the Save our GPS Coalition be made a part of the record 

for today’s hearing as well. They were not able to provide a witness 

for today but ask that their testimony be included in the record. 

Chairman HALL. Is there objection? The Chair hears none. 

[The information can be found in Appendix 2.] 

Mr. NEUGEBAUER. And I thank the Chairman and I thank the 

Chairman for having this hearing. 

Chairman HALL. And you yield back. I would say this. The members of the Committee may have additional questions. We may 

have to ask you to respond to those in writing, if we might, and 

the record will remain open for two weeks for additional comments 

from members. 

I ask for unanimous consent to enter a number of documents into 

the record that were previously shared with the minority, including 

the list of over 400 individuals who submitted comments to the 

Committee. And I have heard a lot of testimony about funds. I 

have heard very little testimony about the 800 fatalities. We maybe 

need another hearing for that sometime in the near future. 

But hearing no objection, it is so ordered. 

[The information can be found in Appendix 2.] 

Chairman HALL. The Chairman calls this hearing adjourned. 

[Whereupon, at 4:04 p.m., the Committee was adjourned.] 
(105) 

Appendix 

ANSWERS TO POST-HEARING QUESTIONS
106 

ANSWERS TO POST-HEARING QUESTIONS

Responses by Mr. Anthony Russo, Director, The National Coordination Office 

for Space-Based Positioning, Navigation, and Timing 

Questions submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

A1. In response to an August 9th request by Mr Strickling (NTIA Administrator), 

federal agencies identified a current inventory of over one million wideband and 

high precision GPS receivers. This inventory does not include State, local, tribal, or 

commercial high precision receivers. While the number of non-federal receivers is 

unknown, it would be in the hundreds of thousands. According to a September 29th 

market study conducted by ABI Research, the high precision market is expected to 

double between now and 2016. Areas that are expected to experience strong growth 

include agriculture, construction, aviation, GIS mapping, and military high 

precisionb applications. 

There is no universally accepted definition of what constitutes a ‘‘wideband’’ or 

‘‘high precision’’ receiver, so the number of affected receivers might vary based on 

different interpretations. 

Q1a. How much do they cost? 

A1a. High precision receivers vary greatly in terms of their mission requirements 

and applications. Therefore, there is also a wide variation in cost. On the lower end 

of the high precision market, receivers cost between $4,000 and $20,000. On the 

higher end, receivers can be as high as $40,000 to $50,000, occasionally even higher. 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at federal departments and agencies? 

A1b. The federal agencies were not able to provide an estimate of their normal upgrade time, but federal users do typically keep their equipment much longer than 

their commercial counterparts. Certain high precision applications, for example 

aviation infrastructure, would require longer—as much as 10–15 years. Fifteen 

years was also the upper end identified by GPS Industry in the FCC-directed Technical Working Group final report. It should be noted that LightSquared disputed 

this estimate and believes it could be accomplished in significantly less time. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use ofthe ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Are federal agencies prepared to upgrade or re-equip all their GPS equipment 

in that time frame? 

A2a. No federal agency has indicated they are prepared to upgrade or re-equip in 

this time frame. 

Q2b. What would be the cost to implement this strategy at federal departments and 

agencies? 

A2b. No feasible mitigation has been proposed for tbe ‘‘upper’’ portion of the spectrum. Even the LightSquared-compatible receiver recently announced by JAVAD 

GNSS does not mitigate upper channel induced interference. No credible estimate 

of implementation cost can be provided until the set of effective mitigation solutions 

is identified and fully tested. Certainly re-equipage of GPS equipment across the 

Federal Government would cost tens of billions of dollars if it is necessary. 

Q2c. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? 

A2c. No, there is no way federal agencies would be able to accomplish such widespread equipment changes in this time frame. We have one previous data point on 

how long is ‘‘reasonable’’ when faced with the issue of upgrading or re-equipping. 

In 2008, a Memorandum of Understanding (MOU) between the Departments of Defense and Transportation was set to expire, which had allowed the used of ‘‘semicodeless’’ techniques. These techniques took advantage of the encrypted military signal to augment the accuracy of civil applications. Because this decision impacted 
107 

several hundred thousand civilian high precision receivers, the Federal Government 

spent considerable time analyzing the impacts and engaging industry to quantify 

the installed base affected, estimate its economic value, and determine an acceptable time frame for deferring the planned GPS military signal modications to allow 

an extension of semi-codeless accesss for civilian GPS access. It took longer to conduct interagency coordination of the task statement than the entire amount of time 

devoted to LightSquared testing. 

Office of the Secretary of Defense (OSD) authorized deferral of changes to the 

military GPS signal until December 31, 2020, so that civilian users of semi-codeless 

GPS augmentations techniques could have more time to upgrade or change to alternatives. OSD established and announced this revised policy via Federal Register notification. That is more than 12 years after an effective migitation was identified. 

Q3. LightSquared’s modified business plan starts commercial operations with just 

the ‘‘lower’’ portion of its spectrum and will be limited to urban areas. Does this 

satisfy your concerns about short-term interference issues to wideband and high 

precision GPS receivers? If not, why not? 

A3. No, the modifications to LightSquared’s plans have not satisfied the concerns 

about interference to GPS receivers. During the first round of GPS interference testing, the limited tests performed using only the lower LightSquared channel demonstrated significant interference to wideband, high precision GPS receivers. According to the FCC-directed Technical Working Group Report’s Executive Summary, 31 

of 33 high precision receivers experience harmful interference even with transmissions restricted to the ‘‘lower’’ portion of the LightSquared spectrum allocation. 

In addition, many of these receivers—supporting a diverse set of important applications—are used in urban environments and will be affected by the first day of 

LightSquared operations. 

On behalf of multiple federal agencies, we recommended to NTIA additional testing be performed to better understand the interference effects of the lower channel 

on high precision receivers, and to determine whether receiver mitigation techniques 

proposed by LightSquared are effective. Both NTIA and FCC have concurred with 

this recommendation, and we expect NTIA to request this testing as soon as 

LightSquared can provide the propsed receiver mitigation hardware. 

Q4. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different to your agency than their original proposal? 

A4. Their new proposal is significant and constructive. It reduces the impact to 

most GPS receivers in the near term and provides several years to find mitigations 

(if they exist) for the second phase of their implementation. However, 

LightSquared’s filings and their congressional testimony to several committees indicate they still intend to operate in both the lower and upper portion of their identified spectrum. Therefore, the end-state remains unchanged and the extensive testing by LightSquared, GPS industry, and the government all indicate unresolved interference problems that cannot be addressed in the expected time frame. Contrary 

to media accounts, neither LightSquared nor the FCC have taken upper channel operations ‘‘off the table.’’ 

Q5. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A5. We strongly support protecting the taxpayer investment in GPS including the 

modernization of GPS to ensure innovative new applications in the future. At the 

same time, we continue to support the President’s goals to identify 500 MHz of spectrum to make available for innvative mobile broadband services. We welcome all 

new entrants to the broadband marketplace provided they demonstrate they can 

provide new broadband services without jeopardizing existing and planned spacebased Positioning, Navigation, and Timing (PNT) capabilities. 

Q6. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If not, why not? 

A6. Maybe. JAVAD GNSS claims its filters mitigate the interference problem for 

the first phase (‘‘lower 10 MHz’’) of LightSquared’s planned deployment. Although 

currently this applies to only the small number of precision receivers built by 

JAVAD GNSS, the company also claims it can adapt their proprietary solution to 
108 

devices built by other manufacturers. Other manufacturers are also working independently on designing solutions for their own systems. It should be noted this solution does not mitigate upper channel overload interference or the intermodulation 

products that will occur when LightSquared implements their upper channel, which 

is still in their plans as filed with the FCC. This JAVAD GNSS solution, by itself, 

also does not mitigate the co-channel interference to GPS augmentation systems like 

StarFire and OmniStar that receive signals from satellite service providers, such as 

LightSquared and Inmarsat, in the Mobile Satellite Service (MSS) band. However, 

if JAVAD GNSS is able to demonstrate they have successfully done as they have 

claimed, it represents a very significant step to resolving the problems for many 

users. 

Q6a. If so, what testing has been done to demonstrate their effectiveness? If filters 

are developed and tested, how long would it take to retrofit existing units? How 

much would this cost? 

A6a. We are not aware of any independent testing done to demonstrate the effectiveness of this solution. Extensive, independent tests must be conducted once hardware is made available. The testing must not only ensure the filtering out of the 

LightSquared transmission, but also verify required performance characteristics can 

still be met with the modified devices. At this time, it is unclear how long it would 

take to retrofit existing units, and LightSquared has stated it may not be possible 

to retrofit some types of units. We do not know how much retrofitting would cost 

for those units where it is feasible to do so. 

Q7. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A7. The three key strategies for mitigation LightSquared interference to GPS are: 

(1) frequency separation, (2) physical separation, and (3) reduction in the 

LightSquared transmitted power. LightSquared has already offered to move (temporarily) from the GPS boundary as far as possible within the band allocated to MSS. 

They have also proposed a subtantial reduction in their authorized tramsmit power. 

LightSquared has expressed some flexibility in working with the federal agencies on 

the location of their towers to protect certain fixed installations (for example, military training facilities) that must use wideband GPS receivers. Physical separation 

is a major factor since the resulting interference power reduces with the square of 

the separation distance. 

In addition to mitigation measures that LightSquared can do on the transmit side, 

there are also potential strategies for mitigation on the receiver side. The most logical mitigation strategy for the lower portion of the MSS spectrum is to reduce the 

bandwidth and steepen the ‘‘cutoff’’ slope of the radio frequency (RF) filters used by 

GPS receivers; however, this will likely result in some accuracy and performance 

degradation to the receivers. Precision GPS receivers traditionally have used very 

wideband filters to capture as much GPS signal energy as possible in order to 

achieve the best possible accuracy. Another reason for the wideband filters is to 

allow reception of differential correction signals from communications satellites in 

the MSS band, which improve navigation accuracy. Precision agriculture and some 

military applications depend on these correction signals. Relocation of these correction signals to the top of the MSS band and not transmitting terrestrial signals in 

the upper part of the MSS band are both necessary in order to contemplate a way 

to mitigate terrestrial signals in the lower part of the band. Whether mitigation filters can be successful without impairing present or future accuracy has not been 

confirmed. 

There is no known mitigation strategy for mitigation of the interference resulting 

from use of the upper portion of the MSS band. 

Q8. Mr. Carlisle states in his testimony that ‘‘the GPS manufacturers failed to raise 

issue at the FCC when it was developing its rules and could have addressed this 

issue in the design of their receivers years ago.’’ 

Q8a. Does identifying who is to blame for the current interference issues minimize 

the interference to U.S. government receivers today? 

A8a. No. 

Q8b. Does the fact that GPS companies did not mention these issues in the past minimize interference to U.S. government rceeivers today? 

A8b. No. 
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Q8c. To your knowledge, did the U.S. Government raise concerns (at any time) about 

potential interference to high precision receivers that ‘‘look’’ into spectrum licensed to LightSquared? 

A8c. GPS interference concerns with respect to Ancillary Terrestrial Component 

(ATC) operation in the MSS band were raised immediately by the federal agencies 

through the NTIA when LightSquared’s predecessor first submitted their application in 2001. At the time, the primary interference concern was out-of-band-emissions (OOBE). LightSquared successfully developed a custom filter for their base 

stations that mitigates OOBE interference. The concerns about ‘‘overload’’ or desensitization interference effects that severely affect wideband GPS receivers—many 

used for high precision applications—were not raised within the Federal Government until relatively recently. The government raised a concern about this particular type of interference effect in December 2010. Prior to that time, GPS had 

some protection from overload interference effects because of the satellite ‘‘gating’’ 

requirements for dual mode (terrestrial/satellite) handsets the FCC included in the 

original 2003 Order and in all subsequent Orders between 2003 and 2010. 

Based on federal agency comments, NTIA wrote a letter to FCC (January 12, 

2011) which raised significant interference concerns and conveyed the agencies’ desire to have a waiver decision deferred pending testing. On that date the Deputy 

Secretary of Defense also wrote to the FCC Defense Commissioner citing national 

security concerns and also strongly recommending deferral. To address these concerns, the FCC made the January 26, 2011, ATC waiver approval—which waived 

the gating requirements for the first time—conditional on resolving the overload interference to GPS. 

Q9. I understand that you have proposed additional testing of the LightSquared proposal over the next six months. What type of GPS receivers would be tested? Are 

there specific areas that are of more concern than the others? 

A9. The Government’s evaluation conducted by the National Space-Based Positioning, Navigation, and Timing Systems Engineering Forum (NPEF) from February 

to May of this year had some significant limitations. I described these limitations 

in detail in my testimony to this Committee. The NPEF final report recommends 

an additional evaluation period of at least six months to enable completion of a thorough assessment of LightSquared’s network. Some of the specific reasons identified 

for this additional testing: (1) Testing of LightSquared’s new signal configuration 

(‘‘10 MHz Low’’) which had not been identified at the time of the NPEF testing; (2) 

Effects of multiple ATC towers instead of one tower (interference effects aggregate); 

(3) Testing of timing receivers which the NPEF could not evaluate due to schedule 

constraints; (4) Systems-level testing vice just looking at GPS receivers; (5) Testing 

of propsed mitigation strategies; and (6) Testing of LightSquared handsets which 

were not available to the government during the NPEF testing. This additional test 

period has not been directed or authorized at this time. 

Separate from the additional testing recommended above, the NTIA requested (on 

September 9, 2011) that the NPEF revalidate two of the seven areas tested by the 

FCC-directed Technical Working Group. These areas focus on cellular devices and 

General Location/Navigation systems such as personal navigation devices used by 

consumers in their cars. This effort is underway and we expect to complete testing 

of these two areas by November 30, 2011. 

Q10. What is the National Coordination Office’s official recommendation to the FCC 

for granting a final license to LightSquared? Please explain your concerns. 

A10. The National Coordination Office (NCO) is an administrative office serving 

the National Space-Based Positioning, Navigation, and Timing Executive Committee. It is not a decision-making or policy-making body. Therefore all NCO recommendations are provided through the Executive Committeee and not directly to 

FCC. Ultimately, NTIA filed the measurement recommendations on behalf of the 

Administration. 

The Executive Committee’s recommendations are: 

• LightSquared should not commence commercial services per its planned deployment for terrestrial operations in the 1525—1559 MHz Mobile-Satellite Service 

(MSS) Band due to harmful interference to GPS operations. 

• The U.S. Government should conduct more thorough studies on the operation, 

economic, and safety impacts of operating the LightSquared Network, to include 

compatibility of ATC architectures in the MSS L Band with GPS-dependent applications, signal configurations not currently in LightSquared planned spectrum phases, effects on timing receivers, and transmissions from LightSquared 

handsets. 
110 

The Executive Committee (EXCOM) remains concerned the interference issues are 

still not resolved, despite several constructive mitigation proposals from 

LightSquared. The EXCOM would like to see thorough testing of all proposed mitigation strategies. In addition, the EXCOM has expressed concern about the need for 

a defined ‘‘end-state.’’ LightSquared’s authorization, their recommendations filed 

with the FCC, and their testimony to three Congressional Committees all refer to 

using both the lower and upper channels. The upper channel transmission has 

beeen discribed as being put in ‘‘standstill,’’ but that term lacks clarity and makes 

it difficult to fully estimate the ultimate cost and timeline for interference mitigation. 

Q11. How much would additional testing on high precision receivers cost? 

A11. There has not been any cost estimate done on how much additional testing 

of high precision receivers would cost. We have taken an initial inventory of how 

many high precision devices are in use by federal agencies, but no testing has been 

initiated to date. 

Q11a. Do agencies already have funding available to conduct this testing? 

A11a. No agency has funding to conduct this testing. Multiple agencies have raised 

the lack of funding as a concern if we are asked to complete this testing in a timely 

fashion. 

Q11b. Has LightSquared offered to fund additional testing on their new proposal? 

A11b. Yes, LightSquared has offered, in general terms, to partially fund this testing and has offered in-kind services such as use of their contracted test facilities 

and LightSquared hardware. It is not clear if federal agencies can accept the funding LightSquared is offering. The NCO continues to address this issue through discussion with government legal counsel, but has not yet identified a mechanism 

where we can accept this offer. 

Q12. Have you been involved in any efforts to quantify the potential costs to the Federal Government of mitigating interference from the LightSquared proposal? 

A12. Yes. At the request of the National Executive Committtee for Space-Based Positioning, Navigation, and Timing (EXCOM), I tasked each member agency to quantify costs of mitigating GPS interference and to provide their estimate to NTIA. The 

relevant text from my June 8th task letter is: 

• ‘‘To the extent possible, qualify, quantify, and describe risks to your agency’s 

GPS-based mission capability, including ‘lost benefits’ if GPS performance were 

degraded (or lost) due to LightSquared’s signals including the costs to modify 

(or replace) GPS receiver infrastructure and the time frame required to replace 

that infrastructure.’’ 

Q12a. Do you currently have any ‘‘order of magnitude’’ estimates of the total potential costs? 

A12a. Some of the agencies that provided estimates to NTIA also provided the 

NCO a courtesy copy. Not all agencies were able to provide the requested estimates 

because of the uncertainties of the final end-state signal configuration and of the 

effectiveness of mitigation techniques. Some were able to answer only in general 

terms, while others did make an ‘‘order of magnitude’’ estimate. NTIA has asked 

me not to provide copies of these estimates to Congress because they are still considered pre-decisional and part of the deliberative process of the Executive Branch. 

Q13. State and local governments are also heavy users of GPS equipment. Is any effort being made to estimate the potential costs to state and local governments 

of mitigating interference from the LightSquared proposal? 

A13. I am not aware of any effort to provide an overall estimate of the impact to 

State and local governments. The FCC has regulatory responsibility over non-federal users. State and local governments are very significant users of GPS and especially high precision GPS. There are over 100 high precision networks, supporting 

tens of thousands of receivers, in use by 37 different States and more are being 

built. Some of the areas supported are: heavy construction, municipal surveying, 

high precision agriculture, roadwork, machine control, disaster response, emergency 

first responders, asset management, intelligent transportation, structural integrity 

monitoring, wastewater treatment service, water distribution systems, and many 

others. 

NITA represents federal agency interests in this matter. However, in their response to NTIA, several federal agencies (i.e., Department of Transportation) also 
111 

have represented the concerns of non-federal entities they regulate. I am unaware 

of the manner and extent to which NTIA will factor in these concerns in its recommendation to the FCC. The FCC is responsible for issues concerning State and 

local government use of spectrum, but I am not aware of any attempt to estimate 

the cost impacts of interference mitigation on those entities. State and local governments were allowed to file comments to the FCC Public Notice, and many did. However, these include only anecdotal estimates for narrow application. A few examples: 

• The North Carolina Department of Agriculture cited: ‘‘Basic land navigation, 

forest fire response, suppression, and reporting affecting some 1,400 communities at risk, fire suppression aviation assets such as firespotting aircraft and 

water-dropping helicopters and airplanes, and forest measurement services for 

300,000 private forestland owners. In addition, damaging America’s GPS would 

nullify over $1,000,000 of taxpayer investment in GPS-based tools for the NC 

Forest Service alone.’’ 

• The Wisconsin Department of Transportation has invested approximately $20M 

in a Height Modernization Program that relies on high precision GPS reference 

stations. They have over 900 registered users of the GPS Continuously Operating Reference Station (CORS), a system our preliminary results indicate 

would be impacted by operation at ‘‘10 MHz Low.’’ 

• Houston County, a small rural county in Minnesota, told the FCC it invested 

$90,000 in high precision GPS equipment and would have to revert to more 

labor-intensive methods requiring additional personnel and longer delivery 

times. 

• The City of Bellevue in Washington State says survey projects that can be done 

with high precision GPS receivers in less than a year would require 10 years 

to complete with other methods. They estimate high precision GPS has saved 

them ‘‘many millions of dollars.’’ 

Questions Submitted by Ranking Member Eddie Bernice Johnson 

Q1. There seems to be a difference of opinion among LightSquared proponents and 

detractors on when federal agencies initially voiced concerns about the 

LightSquared network. In your view, when was the issue of potential interference first surfaced by federal agencies, what triggered agencies’ concerns, and 

what was your office’s involvement? Were these concerns relayed to the FCC? 

What was the FCC’s response? 

A1. Federal agencies immediately raised concerns about potential interference to 

GPS when LightSquared’s predecessor company applied for a license in 2001 for an 

Ancillary Terrestrial Component (ATC) to its Mobile Satellite Service (MSS). These 

concerns primarily dealt with Out-of-Band-Emissions (OOBE), or transmissions 

from LightSquared’s signals that would bleed into GPS’s band. Through collaboration between federal agencies, LightSquared’s predecessor, the GPS industry, and 

NTIA, the FCC addressed the concerns in its rulemaking. Since then, LightSquared 

invested considerable money to have custom filters designed for their transmitters 

to meet OOBE restrictions. Government testing confirms that LightSquared base 

station transmissions meet the OOBE requirements established in the original rulemaking. We have not yet conducted testing on potential OOBE created by 

LightSquared handsets, since no handsets have been available for testing. 

A second type of interference effect is called ‘‘Intermodulation’’ and occurs when 

transmissions from the two high power LightSquared channels interact with the 

front end of a GPS receiver to create a third signal (also called an ‘‘Intermodulation 

Product’’) inside the receiver. NTIA raised this as a concern to FCC in 2002. At the 

time, there were no LightSquared base stations or hardware available to conduct 

testing. Recent government testing of actual hardware in 2011 found that intermodulation effects did occur with dual-channel LightSquared transmissions and the 

intermodulations product is unfortunately created in the center of the GPS receive 

frequency band. LightSquared has acknowledged this effect and points out that it 

will not occur if they only broadcast one channel in the lower half of their spectrum. 

The issue is unresolved for the eventual dual-channel transmissions. 

A third type of interference called ‘‘overload’’ or ‘‘desensitization’’ interference involves the inability of current filters on GPS receivers to screen out the high power 

signals from nearby terrestrial base stations. Some GPS reveivers also intentionally 

use filters wide enough to receive signals from across the MSS band. One reason 

for this is to receive correction signals from MSS providers (like LightSquared) that 

improve the accuracy of GPS signals. LightSquared’s proposed transmissions are 

properly within their own band, but are billions of times more powerful than the 
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weak satellite signals that are currently operating in the Mobile Satellite Service 

band. To the best of my knowledge, federal agencies did not raise overload interference to GPS as an issue until December 2010, in part because of assumptions 

GPS was protected by satellite ‘‘gating’’ requirements which forced terrestrial 

handsets to also be capable of working with the MSS satellite. 

Neither my office, nor the Executive Committee it serves, existed in 2001–2002, 

when the federal agencies first raised concerns about MSS/ATC interference. However, we have been involved in the current issue concerning overload interference. 

The issue of overload interference was brought to my attention on December 21, 

2010, in the context of LightSquared’s application for a waiver to the integrated 

service rules which would have resulted in a de facto repurposing of the spectrum 

for terrestrial broadband instead of MSS. This represented a significant change to 

the interference environment in terms of the number and density of the ATC base 

stations we would expect to see. I immediately brought the issue to the attention 

of the Executive Steering Group (Assistant Secretary-level) and on December 27, I 

wrote to NTIA to request that any action on LightSquared’s request for waiver be 

deferred until testing could be performed. On January 3, 2011, I provided a point 

paper to all the members of the Executive Committee (Deputy Secretary-level) and 

requested the Deputy Secretary of Defense engage the FCC Chairman to seek a 

delay to the waiver decision until specific interference effects and mitigation actions 

could be identified. 

Based on the engagement of the Co-Chairs of the Executive Committee (Mr. Lynn 

and Mr. Porcari) with NTIA and FCC, as well as senior level engagement from all 

of the departments that are GPS stakeholders, the FCC agreed to grant the waiver 

only on a conditional basis. One of the conditions stated that LightSquared is not 

to commence commercial operations until the overload GPS interference concerns 

are resolved. On September 13, the FCC issued a Public Notice [DA 11–1537] stating additional targeted testing is needed to ensure any potential commercial terrestrial service offered by LightSquared will not cause harmful interference to GPS operations. 

Q2. A terrestrial network was envisioned by LightSquared’s predecessors as a fillin to their mobile satellite services. They have had permission to build an extensive terrestrial network for eight years. Can you explain why federal agencies 

waited until just recently to point out that such ground-based towers could 

drown out GPS signals? 

A2. This question contains an incorrect premise. Eight years ago, LightSquared’s 

predecessor received permission to build an ancillary terrestrial network, not an extensive network. There are a number of serious constraints that went along with 

this permsision, and ancillary was defined by FCC (in part) as being ‘‘for the purpose of augmenting signals in areas where the principal service signal, the satellite 

signal, is attenuated.’’ The examples given were urban areas where the buildings 

might block a satellite signal and inside buildings. 

Eight years ago, the FCC Order authorizing ancillary terrestrial service also contained strict technical limits on the transmit power, the bandwidth, the total number of terrestrial base stations, and other parameters. Many of these limits were 

changed over the years in reconsideration actions, modfications, amendments, and 

waivers. There is absolutely nothing wrong with this; requirements, market conditions, and technology all evolve over time so the rules need to evolve also. However 

it is not accurate to equate the system LightSquared proposes today with what was 

envisioned when the predecessor received permission in 2003. 

Two important restrictions on ATC use did not change between 2003 and 2011: 

(1) The terrestrial service needed to remain ancillary to the satellite service, and 

(2) terrestrial and space services must remain integrated. The purpose for the latter 

requirement was acknowledged by LightSquared’s predecessor in its application in 

2001. ‘‘Because MSV’s <Mobile Satellite Venture> own satellite system will be the 

most affected by signals generated by ancillary terrestrial operations, it will have 

every incentive to monitor and minimize these signal levels in order to ensure that 

the quality of its satelllite service is not compromised.’’ In other words, the integrated service rules requiring terrestrial handsets to be able to communicate with 

the satellite ensure intererence protection fo GPS because of the self-interference 

issue. 

This integrated service rule is not a minor administrative technicality. Two 

months before LightSquared applied for its waiver to this rule, GlobalStar had its 

license suspended for failing to meet the appropriate criteria. The criteria FCC established are ‘‘ . . . intended to ensure compliance with the ancillary requirement.’’ 

While many of the technical criteria in the various FCC Orders are difficult for non- 
113 

spectrum experts to comprehend, the FCC’s made its intent in these Orders crystal 

clear. Examples from the 2003 Order: 

• ‘‘The purpose of our grant of ATC authority is to provide satellite licensees flexibility in providing satellite services that will benefit consumers, not to allow licensees to profit by selling access to their spectrum for a terrestrial-only service.’’ 

And 

• ‘‘We reiterate our intention not to allow ATC to become a stand-alone system 

. . . We will not permit MSS/ATC operator to offer ATC-only subscriptions . . . .’’ 

So while it is legitimate to question why federal agencies did not act more forcefully to the easing of some of the technical restrictions that occurred incrementally 

throughout 2003–2011, the principal change to the nature of the terrestrial service 

was not anticiated until LightSquared’s November 2010 request that essentially 

changes the entire purpose of the spectrum. FCC’s conditional waiver of the integrated service rules allows changes that had asserted would ‘‘never’’ be permitted 

and now permits—for the first time in this band—a primary and stand-alone terrestrial service. However, the FCC also clearly made this change conditional on resolving the GPS interference conerns and that work is in progress. 

Q3. NOAA’s prepared statement says that its engineers are concerned that a filter 

capable of blocking out the powerful LightSquared signal at the lower channel 

may also prevent the receiver from detecting the GPS signal, rendering it useless. 

Q3a. In your opinion, is it technically feasible to design a filter that simultaneously 

allows GPS users to listen to signals in LightSquared’s allocated bandwidth 

and block LightSquared’s signals? 

A3a. In my opinion, yes, it is possible to block LightSquared signals in the lower 

channel while allowing GPS receivers to receive signals in the upper part of 

LightSquared’s band. LightSquared has recently announced partnership with a GPS 

manufactureer and with a filter company and has provided information to NTIA and 

FCC supporting the feasibility of this. The federal agencies have not yet been provided this information or conducted testing of these concepts. 

However, the key issue is not simply blocking out LightSquared signals, but being 

able to still perform the intended mission of the receiver after adding this filtering. 

Filters add cost and weight to a receiver and cause performance problems such as: 

signal attenuation, increased thermal noise floor, phase and group delay variations 

with temperature and between frequencies, and loss of narrow correlator processing 

benefits. Because of the diversity of high precision GPS applications, thorough testing of modified receivers integrated with proposed changes to antennas and the new 

filter must be conducted before we can evaluate whether LightSquared’s proposal 

mitigates the interference issues. 

Q3b. Can you estimate its cost? 

A3b No, we currently do not have sufficiant information. 

Q3c. What are the challenges associated with certifying such filters for aviation use? 

A3c. The Federal Aviation Adminstration (FAA) could provide a more complete answer, but I do know the airworthiness process requires a very detailed assessment 

of all hardware and software functions to ensure no unintended effects that would 

create a safety issue. This process typically takes five years to certify new devices 

once there is a new agreed-upon technical standard. Retrofitting aviation systems 

with newly certified devices can take another 10 years or more. 

Q4. What can Congress do to protect the future value of spectrum and ensure user 

receivers do not bleed into spectrum not assigned to them? 

A4. The Executive Committee has not sought any congressional action and remains 

committed to working these concerns through the regulatory process with NTIA and 

FCC. 

Q4a. What are the challenges associated with establishing receiver standards to preclude devices from picking up unintended spectrum? 

A4a. The primary challenges are the size and diversity of the installed user base 

and the lengthy transition time it would take to implement significant changes. 
114 

Q5. Your testimony highlights testing that was conducted by federal agencies independent of the work mandated by the FCC. Can you quantify the level of resources and staff time expended in doing such testing? 

A5. The original testing conducted by the National Space-Based Positioning, Navigation, and Timing Engineering Forum (NPEF) was initiated February 9, 2011, and 

concluded in a final report signed June 2, 2011. The effort involved support from 

all members of the agencies that make up the Executive Committee. The total cost 

to government agencies of this first round of testing was approximately $1.2M. This 

does not include the considerable efforts that have been done in support of 

LightSquared analysis outside of this particular test phase, such as the 10 government personnel who were detailed to support the Technical Working Group, the people who supported the FAA/RTCA analysis, or the staff personnel who have been 

trying to keep senior agency leaders, White House officials, and congressional staff 

informed about the complex issues raised in this testing. 

Q5a. Were there any lessons learned that federal agencies might apply if called on 

to conduct more interference testing? 

A5a. Yes. This testing has made us much more aware the government does not 

have a standing infrastructure to conduct this type of technical assessment in the 

very short time frames requested. The testing we did was successful, but ad hoc and 

with significant limitations. More time is needed in upfront planning to include the 

identification of personnel, test facilities, and other resources. Because no funding 

or personnel lines exist for this type of work, everything used to support this testing 

had to be reallocated from other tasks and negatively impacted the intended use of 

those resources. Limitations on resources limited the test, especially in terms of the 

numbers and types of devices that could be tested. 

More time is needed regarding the identification of test articles because GPS is 

essential to so many different applications. And more time is needed for the coordination and staffing of results and analyses at the end of testing because of the large 

number of government agencies that are stakeholders. 
115 

Responses by Ms. Mary Glackin, Deputy Under Secretary, 

National Oceanic and Atmospheric Administration 

Questions submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

Q1a. How much do they cost? 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at 

your agency? 

A1, 1a, 1b. Wideband, high-precision GPS receivers are commonly used throughout 

the construction, mining, surveying, and agricultural industries. They are also used 

in shipping port operations, offshore oil rig positioning, pipeline and cable infrastructure mapping, and other critical business operations. Within the government, 

such GPS equipment is widely used for geodesy. surveying, earthquake monitoring, 

weather forecasting, spacecraft control, space-based Earth observations, sea level 

measurement, and many other applications. 

Wideband GPS receivers are high-end products that are much more expensive 

than consumer-grade GPS gear. A typical wideband receiver costs thousands of dollars per unit. Some cost tens of thousands of dollars. Many are used in broad networks consisting of hundreds or thousands of high-precision receivers, such as 

NOAA’s nationwide network of over 1,800 Continuously Operating Reference Stations (CORS). The receivers that make up CORS are owned and operated by over 

200 government, academic, and private organizations. NOAA presently owns 85 receivers. The cost for replacing these receivers would be approximately $22,000 to 

$27,000 per site. 

Users in the government and in the commercial sector expect their capital investments in high-precision GPS equipment to last for many years—typically, a decade 

or longer. As a point of reference, in 2008, when the U.S. Government announced 

its intent to phase out certain types of wide band, high precision GPS equipment 

known as ‘‘semi-codeless’’ receivers, it gave users until December 31, 2020—12 

years—to re-equip. This extended time period was chosen to allow users to replace 

their costly GPS equipment as part of their normal recapitalization and upgrade 

cycle. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use of the ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Is NOAA prepared to upgrade or re-equip all their GPS equipment in that time 

frame? 

Q2b. What would be the cost to implement this strategy within your agency? 

Q2c. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? 

A2–2c. NOAA is not prepared to support a replacement or upgrade of all our GPS 

equipment in order to mitigate LightSquared use of the upper spectrum within two 

to three years. At this time, we do not have a complete estimate of the cost of all 

NOAA GPS receivers. We do not believe it is reasonable to expect federal agencies 

to upgrade or re-equip any GPS equipment before suitable mitigations have been 

identified, fully verified, costed, and made available. 

Q3. LightSquared’s modified business plan starts commercial operations with just 

the ‘‘lower’’ portion of its spectrum and will be limited to urban areas. Does this 

satisfy your concerns about short-term interference issues to wideband and high 

precision GPS receivers? If not, why not? 

A3. No, the modifications to LightSquared’s plans have not satisfied NOAA’s concerns about interference to wideband, high precision GPS receivers. During the first 

round of GPS interference testing, the limited tests performed using only the lower 

LightSquared channel demonstrated significant interference to wideband, high precision GPS receivers. NOAA supports recent calls for additional testing to better understand the interference effects of the [ower channel on high precision receivers, 

and to find out whether receiver mitigation techniques proposed by LightSquared 

are effective. 
116 

Q4. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different to your agency than their original proposal? 

A4. In terms of the impacts to NOAA operations, and the potential costs to reequip, we still have the same concerns we had under LightSquared’s original operating plan. 

Q5. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A5. The President has set a goal of repurposing 500 MHz. The Administration continues to explore whether LightSquared can implement its proposed system while 

protecting GPS. 

Q6. Does NOAA feel that adequate testing has been done on all of the issues associated with LightSquared interference on the agency’s missions? Should there be 

more testing on high precision units? 

A6. NOAA concurs with the National Space-Based Positioning, Navigation, and 

Timing Executive Committee (PNT EXCOM) that adequate testing has now been 

completed and no additional testing is warranted at this time. 

Q7. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If not, why not? 

If so, what testing has been done to demonstrate their effectiveness? Who should 

pay for this testing? 

A7. Javad GNSS announced new receivers in September, but we have not had a 

chance to test them or review any test results associated with them. In order to 

mitigate the interference to wideband and high precision GPS receivers, the equipment must not only block out the jamming effects of the LightSquared signal, but 

also demonstrate high precision performance similar to today’s equipment. In addition to new receivers, Javad and other companies have also announced filters that 

may be retrofitted onto existing high precision equipment. We have not had an opportunity to test these filters. Again, it is not enough to block out the jamming effects using filters; existing receivers must be able to continue delivering high precision measurements, or they will fail to perform their intended function. 

Q8. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A8. The National Space-Based PNT Systems Engineering Forum explored a wide 

range of potential mitigation strategies but could not identify any feasible solution 

other than to move LightSquared’s terrestrial transmissions to another part of the 

radio spectrum, far away from GPS bands. At this time, there are no known mitigation strategies for LightSquared’s use ofthe upper 10 MHz band. We believe the 

power levels proposed by LightSquared for the lower 10 MHz signal may be impossible to overcome unless filter solutions are demonstrated that can mitigate the interference without impacting receiver performance. 

Q9. How much would it cost your agency to mitigate the interference issues from the 

LightSquared signal on your missions? 

Q9a. Does your agency currently have funds set aside for this purpose? 

A9, 9a. At this time, we do not have a complete estimate of the cost of all NOAA 

GPS receivers that would need to be replaced or upgraded to mitigate 

LightSquared’s proposed signals. NOAA’s current budget does not include any funding for GPS interference mitigation. 

Q10. Since August 15, the FCC has had the ability to rule on the LightSquared proposal, and to my knowledge, NTIA has yet to submit comments to the FCC on 

behalf of affected agencies. 

Q10a. Has NTIA provided your comments to the FCC? 

Q10b. Will NOAA submit its comments directly to the FCC if NTIA fails to do so? 

If so, when? 

Q10c. Would you agree that your agency’s assessment should be made public so that 

everyone can understand the extent to which LightSquared interference to 
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GPS will impact the ability of your agency to perform its duties, and the costs 

that may be incurred due to this interference? 

A10c . NOAA has followed, and will continue to follow, the established process by 

which federal agencies provide comments to the FCC through NTIA, the Administration’s lead agency for spectrum policy matters, rather than each agency submitting comments directly to the FCC. The impact statements contain core deliberative 

communications from Executive Branch agencies that provide critical advice to 

NTIA in its role as spectrum manager on behalf of the Federal Government. Agency 

inputs as part of this deliberative process have not been released to the public. 

Q11. I understand from my staff that were briefed by NOAA officials that there are 

significant issues with interference from the LightSquared signal on the GPS 

signal utilized in major NOAA systems used for weather forecasting, climate 

observation, search and rescue, vessel navigation, emergency response mapping, 

geodesy, time distribution, and census operations. Do you have an estimate on 

what the costs to NOAA may be to mitigate interference from the LightSquared 

signal? 

A11. We have some rough estimates on costs to mitigate LightSquared interference 

to a few specific NOAA systems, but we do not have an estimate for the total cost 

to mitigate all systems across NOAA. If LightSquared is allowed to proceed with 

operations involving signals in both the upper and lower 10 MHz, we are concerned 

that this would negatively impact currently operational capabilities essential to our 

mission. 

Q12. Given that LightSquared has modified its original business plan to start commercial operations with just the ‘‘lower’’ portion of its spectrum, the spectrum 

furthest away from the GPS signal, do you feel that there has been adequate 

testing on the impacts to NOAA’s systems if their latest proposal is approved? 

A12. Adequate testing has not been completed at this time. NTIA and FCC recently called for additional testing to better understand the interference effects 

caused by LightSquared’s lower channel only. Part of this testing, focusing on cellular and general/personal navigation receivers, has just been completed, but the 

data have not been analyzed. NOAA actively participated in the latest testing and 

will also engage in the future testing involving wideband receivers. Please note that 

the latest testing, like the original testing, occurred on an extremely compressed 

schedule that prevented us from testing all the equipment that could potentially be 

affected by the LightSquared proposals. 

Q13. I understand it is LightSquared’s stated intent to eventually utilize its entire 

authorized spectrum, including the upper portion near the GPS signal, as it 

builds out its network. How much time would be required to upgrade existing 

equipment, and how much would that cost? 

Q13a. Does NOAA currently have funding available for these upgrades? 

Q13b. What would NOAA cut in order to fund these upgrades? 

A13–13b. At this time, we do not have a complete estimate of the cost of all NOAA 

GPS receivers that would need to be replaced or upgraded to mitigate 

LightSquarcd’s proposed signals. NOAA’s current budget does not include any funding for GPS interference mitigation. NOAA cannot plan to upgrade or re-equip any 

GPS equipment before suitable mitigations have been identified, fully verified, 

costed, and made available. 

Q14. The limited testing conducted by the TWG showed significant interference from 

the LightSquared signal on high precision GPS equipment even with the newly 

proposed LightSquared strategy to limit initial commercials operations to the 

‘‘lower’’ spectrum using less power. LightSquared maintains that filters can be 

developed to minimize their interference with the GPS signals. 

Q14a. Can you tell the Committee how NOAA plans to use filters to mitigate the interference issues? 

Q14b. What are the costs associated with developing these filters? 

Q14c. Since NOAA weather satellites are already in orbit and future satellites are 

already designed or built, how would those assets be affected? 

A14–14c. We have no current plans to use filters to mitigate interference to our 

high precision equipment, as the FCC has not approved LightSquared network operations, and the proposed filters do not exist yet. We do not know what the filters 

would cost, but they will likely cost more than the $300–$800 price that Javad 
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GNSS cited to retrofit Javad’s own products. It is important to note that this cost 

only includes the hardware; it does not account for the significant labor costs involved in retrofitting, re-certifying, and retraining, nor does it include the operational impacts of taking systems offline for upgrades. NOAA has hundreds of devices that may need upgrading. In the case ofthe six COSMIC satellites in space 

and the NPP satellite launched October 28, our latest analysis suggests that 

LightSquared’s lower channel will not affect the receivers used on the COSMIC satellites. However, we remain concerned about potential interference to COSMIC if 

LightSquared eventually operates using its upper channel since we have no way of 

modifying the GPS receivers they carry on board. 

Q15. Approximately two months ago I asked all agencies within this Committee’s jurisdiction to provide the Committee with the comments they submitted to NTIA 

regarding the LightSquared proposal. I have not yet received responses from 

NOAA, NIST, and DHS. Will NOAA agree to provide those comments to the 

Committee so that we, and the American people, can better understand the impact that the LightSquared proposal would have on NOAA operations? 

A15. NOAA has followed, and will continue to follow, the established process by 

which federal agencies provide comments to the FCC through NTIA, the Administration’s lead agency for spectrum policy matters, rather than each agency submitting comments directly to the FCC. The impact statements contain core deliberative 

communications from Executive Branch agencies that provide critical advice to 

NTIA in its role as spectrum manager on behalf of the Federal Government. Agency 

inputs as part of this deliberative process have not been released to the public. 

Q16. If LightSquared’s modified spectrum plan on June 30, 2011 (which only involves the lower 10 MHz) were to be implemented, what capabilities in service 

would the agency lose? 

A16. NOAA has several major capabilities at risk under the lower channel proposal. We need to do more testing to confirm the scope ofthe potential impacts. The 

capabilities include: 

• (1) GPS-based surveying of airport runways and shorelines; 

• (2) monitoring sea level trends (rise and fall), to protect natural and human 

communities; 

• (3) the Ground-Based GPS Meteorology project, which measures atmospheric 

moisture to improve short-term forecasts; 

• (4) issuance of the U.S. Total Electron Content product, to inform the public of 

space weather conditions affecting GPS accuracy; and 

• (5) maintaining the National Spatial Reference System, to ensure compatibility 

among U.S. maps and surveys. 

Q17. Please list the systems and functions that would be impacted by GPS interference. 

Q17a. How would weather forecasting bc impacted? 

A17, 17a. GPS interference—under both the original and modified LightSquared 

plans—threatens to disable or degrade our environmental satellites and sensors, 

causing data corruption and gaps that reduce the accuracy of our weather forecasts 

and warnings. We are particularly concerned that our Ground-based GPS Meteorology (GPS-Met) system, which depends on wideband GPS receivers, could be significantly impacted by LightSquared’s use of the lower channel. Loss of the data 

from GPS-based weather instruments would not stop us from predicting hurricanes 

and other severe weather, but our forecasts would be less accurate. For example, 

we would have to issue storm warnings to broader swaths of the Nation, causing 

needless public concern and the expense of needless evacuations, which can cost up 

to $1 million per mile of coastline. The hurricane warnings would become less accurate as landfall is approached due to LightSquared interference with GPS in the 

coastal areas. 

Q17b. How would climate observation be impacted? 

A17b. The same sensors we use for weather forecasting feed data into our longerterm climate models. The term ‘‘climate’’ refers to weather conditions any time in 

the future beyond two weeks. GPS interference would lead to degraded climate modeling accuracy. 

Q17c. How wouId search and rescue be impacted? 
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A17c. NOAA’s Search and Rescue Satellite-Aided Tracking (SARSAT) system relays distress signals via satellite from emergency beacons to the ground stations and 

mission control center, which sends alerts and beacon locations to search and rescue 

authorities. It is a major component of the International COSPAS-SARSAT system, 

a critical life and safety service with national and international requirements. 

SARSAT ground stations (Local User Terminals, or LUTs) utilize multiple GPS receivers to determine and maintain precise time. LUTs calibrate the oscillators that 

keep time for the SARSAT instruments on GOES and POES satellites. GPS is also 

integrated into some distress beacons to determine the user’s location and include 

it in the distress alert. The ability of such beacons to independently and more accurately determine and report their locations greatly improves response times and the 

chances of a successful rescue. The current MSS/ATC rules require that all base stations within 27 kilometer or within the radio horizon of a SARSAT LUT earth station be coordinated. This requirement applies to base stations operating throughout 

the 1525–1559 MHz band which would cover both the upper and lower 10 MHz signal proposals from LightSquared. Given the coordination requirements in the current rules for SARSAT LUTs, GPS receivers used at LUTs should not be impacted 

by the LightSquared original or current spectrum proposal. NOAA is planning to 

conduct tests with LightSquared to verify the 27-kilometer coordination distance 

provides sufficient protection. GPS interference on land or along coasts would prevent GPS-enabled emergency beacons from reporting accurate distress locations. We 

hope to perform additional testing of GPS-enabled search and rescue beacons in the 

future. 

Q17d. How would vessel navigation be impacted? 

A17d. NOAA operates a fleet of 19 vessels in the Pacific and Atlantic Oceans for 

oceanographic, atmospheric, fisheries and coral reef research, nautical charting, environmental monitoring and ocean exploration. The fleet employs a variety of GPS 

and differential GPS receivers for navigation and scientific use. Position Heading 

and Attitude Sensors are used to determine the vessel’s position, heading and attitude (heave, pitch and roll) with input from GPS receivers. If GPS service became 

unavailable and unreliable, NOAA vessels would be unable to perform many of their 

operations and missions. Overcoming these impacts would require extensive equipment purchases and installations on NOAA vessels (assuming a replacement system 

and equipment are available), the costs of which are not within our current operational and capital budget. 

The existing MSS/ATC rules require that the emissions from a base station operating in the 1525–1541.5 MHz and 1547.5–1559 MHz bands at the water edge of 

a navigable waterway is limited to a total power flux density (PFD). Given the base 

station PFD requirements in the current rules, GPS receivers on board vessels 

should not be impacted by the original or current spectrum proposal made by 

LightSquared. NOAA hopes to test some marine navigation equipment in a future 

round of interference testing to verify this is the case. 

Q17e. How would emergency response mapping be impacted? 

A17e. Following major disasters, NOAA flies aircraft over the affected areas to collect aerial imagery. Such imagery facilitates disaster relief efforts in areas affected 

by natural disasters, such as hurricanes, earthquakes, floods, etc., as well as manmade disasters such as oil spills. NOAA also deploys vessels after severe storm 

events to scan the seafloor for potential hazardous obstructions that may impede 

safe passage of the Marine Transportation System. GPS is used to georeference the 

aerial imagery and provides a spatial context to its suite of ocean mapping sensors, 

making it possible to identify areas devoid of landmarks and accurately map underwater hazards. Without accurate GPS, the locations of these features might not be 

known, and NOAA anticipates there would be resulting impacts on marine commerce, as well as reductions in the U.S. government savings enabled by NOAA 

emergency response. Potential loss of savings enabled by NOAA emergency response 

imagery is estimated at $1.42 million per 10,000 affected homes, while a marine 

transportation shut-down in just Hampton Roads alone could impede an estimated 

$5 million worth of cargo every hour. We have not identified any possible mitigation 

for the loss of GPS in this function; NOAA would lose this capability. 

Q17f. How would geodesy be impacted? 

A17f. NOAA’s National Geodetic Survey uses a nationwide network of Continuously Operating Reference Stations (CORS) to define the National Spatial Reference 

System (NSRS). CORS is a network of high precision GPS receivers at over 1,800 

fixed reference stations across the United States that continuously observe the GPS 

satellite orbits and relay the data to a central archive. The NSRS and CORS data 
120 

are distributed to users via the Online Positioning User Service (OPUS), which processes and corrects collected GPS measurements with high precision. NSRS also provides the basis for real time positioning networks (RTNs) operated by states in support of agriculture, maritime operations, surveying, floodplain mapping, etc. 

Based on initial testing, we believe the wideband, high precision GPS receivers 

in the CORS network are at risk of interference even if LightSquared only uses its 

lower 10 MHz channel. Without reliable GPS, the entire CORS network could become unusable, and we would be forced to use less accurate, more labor-intensive, 

and more costly methods to define the NSRS. For example, the cost to update the 

International Great Lakes Datum would increase from less than $30 million using 

GPS to $160 million using traditional line-of-sight survey methods. The Nation 

could lose an estimated $758 million in annual socioeconomic benefits from CORS. 

State investments in real time positioning networks (RTN) that depend on CORS 

for NSRS access would be lost, as would the significant economic activities RTNs 

support. OPUS would not function as designed, affecting approximately 20,000 

users/month, resulting in a $12 million/month loss of economic benefits. It is unclear 

at this time whether filtering is possible without losing the functionality of high precision GPS receivers. If filtering is possible, upgrading every CORS site would be 

time and labor intensive, and likely cost millions of dollars, a cost that would be 

borne largely by the States, universities, and other CORS stakeholders. There would 

also be significant outreach and training costs, and increased operating costs. 

Q17g. How would time distribution be impacted? 

A17g. We use GPS time to synchronize nearly all of our environmental sensors to 

the same time scale. This ensures that millions of data inputs are kept in proper 

chronological order as they are ingested into models and analyzed. GPS time synchronization is also critical to the transmission of data from more than 23,000 land, 

sea, and mobile-based observational platforms via the GOES and POES Data Collection Systems (DCS). Examples of platforms include the National Water Level Observation Network, National Estuarine Research Reserves System-wide Monitoring 

Program weather and water quality stations, Coastal Marine Automated Network, 

and weather and hurricane observing buoys. Each platform transmits at predefined 

wavelengths and times. GPS receivers discipline the platform transmitters to maintain their frequency and time assignments. GPS receivers at the GOES and POES 

ground stations keep the satellites in time synchronization with the DCS platforms. 

Prolonged, continuous GPS interference at DCS platforms would lead to clock 

drift. Data could be transmitted at the wrong times, resulting in lost, missing, or 

corrupt data affecting weather forecast models and climate records. After a certain 

amount of time without access to GPS, the DCS platform radios are programmed 

to cease transmission and shut down, resulting in data gaps. Interference to the 

GPS receiver on the GOES-R satellite could prevent it from properly relaying any 

data from DCS platforms. To mitigate widespread GPS interference, the entire DCS 

would have be re-engineered so fewer platforms transmit data on the same frequencies per hour. The result would be a drastic (roughly one order of magnitude) 

reduction in data collection capability. The cost to apply the fix to all of the deployed 

platforms could be prohibitively expensive, leading to losses of capability. 

Q17h. Would the entire fleet of NOAA satellites be put at risk? 

A17h. Yes. There is a real possibility that GPS interference from LightSquared’s 

network could adversely affect our satellite ground stations’ ability to command and 

control our current satellites. Our future satellites could also be affected if 

LightSquared transmissions interfere with their onboard GPS equipment. 

Q18. Does NOAA have any way to mitigate the loss of GPS service? 

A18. We would need to implement mitigations on a system-by-system basis, as 

there is no single solution that addresses all types of GPS uses across NOAA. We 

have identified potential mitigations to some of our systems, but almost none of 

these have been demonstrated, costed, or tested. Some NOAA functions could be accomplished by reverting to older technologies and methods, but we would lose operational capabilities and cost efficiencies associated with GPS. For certain systems, 

such as satellites already in space, we have no way to mitigate potential GPS interference. 

Q19. How much would it cost to replace all of NOAA’s GPS receivers? 

A19. At this time, we do not have a complete estimate of the cost of all NOAA GPS 

receivers that would need to be replaced or upgraded to mitigate LightSquared’s 

proposed signals. NOAA cannot plan to upgrade or re-equip any GPS equipment be-
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fore suitable mitigations have been identified, fully verified, costed, and made available. 

Q20. How much would it cost to retrofit all of NOAA’s GPS receivers, if a filter could 

be developed? 

A20. At this time, we do not have a complete estimate of the cost of all NOAA GPS 

receivers that would need to be replaced or upgraded to mitigate LightSquared’s 

proposed signals. NOAA cannot plan to upgrade or re-equip any GPS equipment before suitable mitigations have been identified, fully verified, costed, and made available. 

Q21. What programs would NOAA cut in order to pay for these upgrades? 

A21. If and when we get to the point when we need to pay for upgrades, we will 

analyze all of our mission priorities to determine what lost GPS-based capabilities 

we need to preserve and what future improvements or other activities we may need 

to defer in order to do so. Given that the cost of mitigation is unknown at this time, 

it would be impossible to perform such analysis. 

Q22. Does NOAA have any way to modify, replace, or retrofit GPS receivers in space, 

or being prepared for launch? 

A22. No, we do not. If LightSquared transmissions affect those satellites, we will 

have no way to mitigate the interference. Those satellites could lose capability to 

maintain accurate orbits and orient themselves correctly, leading to degraded 

weather forecasts and climate data collection. 

Q23. If LightSquared was allowed to use both the upper and lower 10 MHz of its 

spectrum (as it has states it eventually intends to do), how would NOAA operations be impacted? 

A23. It is expected that interference to GPS from both the upper and lower 

LightSquared channels would cause serious performance degradation or a total loss 

of mission for a wide range of NOAA’s operational systems, resulting in the loss of 

critical services and potential loss of life and property. These systems include major 

satellite, airborne, sea-based, and terrestrial systems used for weather forecasting, 

climate observation, search and rescue, vessel navigation, nautical charting, emergency response, and geodesy. Since virtually all of NOAA’s operational systems and 

functions are integrated with GPS technology, the impacts would be felt across all 

of our Line Offices. The American public, which relies on NOAA for weather forecasting, research, and life-saving capabilities, could experience severe degradation 

or total loss of some products and services. 

Q24. Please describe how the following systems would be impacted by the 

LightSquared network (as planned on June 30, 2011). Please include an assessment of the costs associated with each individual system/program. 

A24. The LightSquared operating plan of June 30, 2011, still includes eventual use 

of the problematic upper 10 MHz channel next to GPS. The information below is 

based on our concerns about the upper channel. We have not yet had a chance to 

test whether all of the systems and functions below would be adversely affected by 

use of the lower 10 MHz channel only. 

GOES/POES/NPP/JPSS 

The Geostationary Operational Environmental Satellite (GOES) system provides 

continuous monitoring of the Western Hemisphere to support warnings of tornadoes, 

hurricanes, and other severe weather directly affecting U.S. public safety, protection 

of property, and economic health and development. The current Polar-orbiting Operational Environmental Satellite (POES) system, the National Polar-orbiting Operational Environmental Satellite System Preparatory Project (NPP), and the future 

Joint Polar-orbiting Satellite System (JPSS) collect global data to support weather 

forecasting, climate change research, monitor volcanic eruptions, detect forest fires, 

and support search and rescue. Today’s GOES and POES satellite operation centers 

use GPS on the ground to maintain the accuracy of local frequency standards used 

for system timing applications in their respective mission systems. The ground stations routinely upload time corrections to the satellites to keep them synchronized 

with the GPS time scale used at the ground stations and across NOAA. The GOES 

and POES ground stations also use GPS time to generate and upload highly accurate spacecraft ephemeris (orbit information) essential for attitude control and navigation. 
122 

Any loss of GPS lock at the operational centers takes a minimum of 20 minutes 

to re-establish. Prolonged, continuous GPS interference at the ground stations would 

cause timing systems to drift out of specification, causing widespread errors that 

could not be effectively managed, even with constant, manual application of time 

corrections. This would cause attitude control and timing inaccuracies on the satellites, degrading the quality of weather and climate measurements and leading to 

less accurate warnings of severe weather. Eventually, if the timing systems get into 

errors on the order of a few microseconds, spacecraft could become unstable and 

ground stations could completely lose the ability to command and control them. If 

NOAA ground stations cannot be protected from interference through LightSquared 

exclusion zones or physical relocation, the satellite operation centers would likely 

need to procure and maintain new cesium clocks for time reference at high initial 

and annual cost. 

NOAA’s next-generation satellites, including GOES-R, NPP, and JPSS, will use 

on-board GPS receivers to provide autonomous orbit determination and a time reference accurate to 250 nanoseconds. Loss of GPS on board these satellites would 

cause them to rely on less accurate star trackers for pointing, degrading data quality and forecasts. The next-generation satellites cannot be upgraded as long as a 

mitigating filter has not been developed, proven, space-qualified, and made available. This is especially true for those satellites that are now being readied for 

launch. We would have to develop ground-based ephemeris products and time corrections for the next-generation satellites, adding cost and labor requirements to the 

programs. 

GOES and POES Data Collection Systems (DCS) 

The GOES and POES Data Collection Systems (DCS) enable the collection of essential data from over 23,000 land, sea, and mobile-based observational platforms, 

which use the GOES and POES satellites as data relays. Examples of platforms include the National Water Level Observation Network, National Estuarine Research 

Reserves System-wide Monitoring Program weather and water quality stations, 

Coastal Marine Automated Network, and weather and hurricane observing buoys. 

Each platform transmits at predefined wavelengths and times. GPS receivers discipline the platform transmitters to maintain their frequency and time assignments. 

GPS receivers at the GOES and POES ground stations keep the satellites in time 

synchronization with the DCS platforms. 

Prolonged, continuous GPS interference at DCS platforms would lead to clock 

drift. Data could be transmitted at the wrong times, resulting in lost, missing, or 

corrupt data affecting weather forecast models and climate records. After a certain 

amount of time without access to GPS, the DCS platform radios are programmed 

to cease transmission and shut down, resulting in data gaps. Interference to the 

GPS receiver on the GOES-R satellite could prevent it from properly relaying any 

data from DCS platforms. To mitigate widespread GPS interference, the entire DCS 

would have be re-engineered so fewer platforms transmit data on the same frequencies per hour. The result would be a drastic (roughly one order of magnitude) 

reduction in data collection capability. Applying the fix to all of the deployed platforms would incur costs in terms of hardware, labor, and travel to many remotely 

located platforms. 

COSMIC and COSMIC–2 

The Constellation Observing System for Meteorology, Ionosphere and Climate 

(COSMIC) is designed to fill in global gaps in atmospheric data where weather balloon observations are scarce. COSMIC involves six satellites in low Earth orbit that 

use the GPS radio occultation (GPSRO) technique to perform atmospheric soundings 

of pressure, temperature, water vapor, and electron density. The technique involves 

the observation of the GPS satellite signals from other satellites in space. The signals refract (bend) as they pass through the limb of the Earth’s atmosphere. Measuring the amount of GPS signal refraction through different ‘‘slices’’ of the atmosphere allows researchers to derive the physical properties of those slices. COSMIC 

data significantly improves the modeling of hurricanes and other storm patterns. 

COSMIC also collects global data on electron density to improve space weather forecasts. 

GPS interference from the LightSquared network could prevent the collection of 

GPSRO data over the United States. At this time, our analysis suggests that receivers on the COSMIC satellite will not be affected if LightSquared uses its lower 

channel only. However, we remain concerned about potential interference to COSMIC, which is already suffering from degraded operations as it operates beyond its 
123 

design life, if LightSquared eventually operates using its upper channel. If interference occurs under any scenario, there would be no possible mitigation; this entire 

capability would be lost. 

SARSAT 

NOAA’s Search and Rescue Satellite-Aided Tracking (SARSAT) system relays distress signals via satellite from emergency beacons to the ground stations and mission control center, which sends alerts and beacon locations to search and rescue 

authorities. It is a major component of the International COSPAS-SARSAT system, 

a critical life and safety service with national and international requirements. 

SARSAT ground stations (Local User Terminals, or LUTs) utilize multiple GPS receivers to determine and maintain precise time. LUTs calibrate the oscillators that 

keep time for the SARSAT instruments on GOES and POES satellites. GPS is also 

integrated into some distress beacons to determine the user’s location and include 

it in the distress alert. The ability of such beacons to independently and more accurately determine and report their locations greatly improves response times and the 

chances of a successful rescue. 

GPS interference on land or along coasts would prevent GPS-enabled emergency 

beacons from reporting accurate distress locations. We hope to perform additional 

testing of GPS-enabled search and rescue beacons in the future. 

The current MSS/ATC rules require that all base stations within 27 kilometer or 

within the radio horizon of a SARSAT LUT earth station be coordinated. This requirement applies to base stations operating throughout the 1525–1559 MHz band 

which would cover both the upper and lower 10 MHz signal proposals from 

LightSquared. Given the coordination requirements in the current rules for 

SARSAT LUTs, GPS receivers used at LUTs should not be impacted by the original 

or current spectrum proposal made by LightSquared. NOAA is planning to conduct 

tests with LightSquared to verify the 27-kilometer coordination distance provides 

sufficient protection. 

NOAA Emergency Response Imagery 

Following major disasters, NOAA flies aircraft over the affected areas to collect 

aerial imagery. Such imagery facilitates disaster relief efforts in areas affected by 

natural disasters, such as hurricanes, earthquakes, floods, etc., as well as manmade 

disasters such as oil spills. NOAA also deploys vessels after severe storm events to 

scan the seafloor for potential hazardous obstructions that may impede safe passage 

of the Marine Transportation System. GPS is used to georeference the aerial imagery and provides a spatial context to its suite of ocean mapping sensors, making 

it possible to identify areas devoid of landmarks and accurately map underwater 

hazards. Without accurate GPS, the locations of these features might not be known, 

and NOAA anticipates there would be resulting impacts on marine commerce, as 

well as reductions in the U.S. Government savings enabled by NOAA emergency response. Potential loss of savings enabled by NOAA emergency response imagery is 

estimated at $1.42 million per 10,000 affected homes, while a marine transportation 

shut-down in just Hampton Roads alone could impede an estimated $5 million 

worth of cargo every hour. We have not identified any possible mitigation for the 

loss of GPS in this function; NOAA would lose this capability. 

Global Maritime Distress and Safety System (GMDSS) 

GMDSS is used to facilitate worldwide rescue of distressed vessels and aircraft. 

It disseminates navigational warnings, meteorological warnings and forecasts, and 

other urgent safety-related information to all ships on the world’s oceans, regardless 

of location or atmospheric conditions. The National Weather Service participates in 

the GMDSS by preparing meteorological forecasts and warnings for broadcast via 

systems that use GPS to program the receiver properly for receipt of the appropriate 

data. 

The existing MSS/ATC rules require that the emissions from a base station operating in the 1525–15415 MHz and 1547.5–1559 MHz bands at the water edge of a 

navigable waterway is limited to a total power flux density (PFD). The PFD limits 

in the current rules were developed in coordination with the Coast Guard specifically to protect GMDSS operations in navigable waterways. Given the base station 

PPD requirements in the current rules, GMDSS receivers on board vessels should 

not be impacted by the original or current spectrum proposals made by 

LightSquared. NOAA hopes to test some marine navigation equipment in a future 

round ofinterference testing to verify this is the case. 
124 

Next-Generation Radar (NEXRAD) 

NEXRAD is a network of 159 high resolution weather surveillance radars that 

transmit data that can be processed to show patterns of precipitation and its movement. Each radar contains a GPS unit for time stamping of data, troubleshooting, 

and auditing purposes. NEXRAD communications require extremely accurate timing 

and rely on GPS for Universal Time Coordinated (UTC) stamps. 

If the radar loses GPS time, it will rely on local equipment. Over a prolonged period, the equipment will begin to drift, causing radar pointing errors and system 

alarms. Forecasters and air traffic controllers could generate erroneous reports. This 

problem is somewhat mitigated by software that ensures internal timing sources 

match, even if they are wrong. If GPS service is not available, the Radar Operations 

Center will need to engineer a separate time server and make a significant number 

of changes, mostly in software, to rehome radar sub-components to the new time 

source. 

Continuously Operating Reference System (CORS) 

CORS is a network of high precision GPS receivers at over 1,800 fixed reference 

stations across the United States that continuously observes the GPS satellite orbits 

and relays the data to a central archive. CORS provides the means for defining the 

National Spatial Reference System (NSRS), the common standard for all U.S. 

geospatial activities such as mapping and surveying. The NSRS and CORS data are 

distributed to users via the Online Positioning User Service (OPUS), which processes and corrects collectcd GPS measurements with high precision. NSRS also provides the basis for real time positioning networks (RTNs) operated by states in support of agriculture, maritime operations, surveying, floodplain mapping, etc. 

Based on initial testing, we believe thc wideband, high precision GPS receivers 

in the CORS network are at risk of interference even if LightSquared only uses its 

lower 10 MHz channel. Without reliable GPS, the entire CORS network could become unusable, and we would be forced to use less accurate, more labor-intensive, 

and more costly methods to define the NSRS. For example, the cost to update the 

International Great Lakes Datum would increase from less than $30 million using 

GPS to $160 million using traditional line-of-sight survey methods. The Nation 

could lose an estimated $758 million in annual socioeconomic benefits from CORS. 

State investments in real time positioning networks (RTN) that depend on CORS 

for NSRS access would be lost, as would the significant economic activities RTNs 

support. OPUS would not function as designed, affecting approximately 20,000 

users/month, resulting in a $12 million/month loss of economic benefits. It is unclear 

at this time whether filtering is possible without losing the functionality of high precision GPS receivers. If filtering is possible, upgrading every CORS site would be 

time and labor intensive and likely cost millions of dollars, a cost that would be 

borne largely by the states, universities, and other CORS stakeholders. There would 

also be significant outreach and training costs, and increased operating costs. 

Aeronautical Survey Program 

NOAA provides airport geodetic control, runway, navigational aid, obstruction, 

and other aeronautical data that is critical to the operation of the National Airspace 

System. This data is used to develop runway approach procedures and obstruction 

charts. We use high precision GPS equipment to perform the field surveys. 

Based on initial testing, we believe the wideband, high precision GPS receivers 

we use for aeronautical surveying are at risk if LightSquared uses its lower channel 

only. If our aeronautical surveying equipment were to cease functioning, we would 

have to conduct the surveys using traditional methods that are less accurate, resulting in decreased safety at the airports we survey in the future. Using traditional 

surveying methods would also significantly increase the time and cost, and reduce 

the number of surveys that could be performed each year. A single survey mark cost 

$14,649 in 1984 using traditional methods vs. $822 in 2004 with GPS, and the team 

costs dropped from $439,455 to $24,647. 

The existing MSS/ATC rules require that the emissions from a base station operating in the 1525–1559 MHz band at the edge of all airport runways and aircraft 

stand areas, including takeoff and land paths, is limited to a total power flux density (PPD). The planned future round of interference testing involving high precision 

GPS equipment should provide data on whether the existing PFD limits provide 

adequate protection for ground surveying equipment at airports. 
125 

Coast Mapping Program 

NOAA provides the critical baseline data for demarcating the Nation’s marine territorial limits, including its Exclusive Economic Zone, and for the geographic reference needed to maintain coastal resources and many other uses. We use GPS to 

georeference shoreline information during data collection. 

GPS interference would prevent the georeferencing. We have not identified any 

possible mitigation for the loss of GPS; NOAA would lose capability. 

National Data Buoy Center Observation System 

NOAA’s National Data Buoy Center operates a network of weather and hurricane 

observing buoys, coastal stations, the Tropical Atmosphere Ocean climate monitoring buoys, and tsunami detection stations that provide hourly observations on 

wind, atmospheric, and sea surface conditions. The system depends on continuous 

GPS capability for positioning, data acquisition system timing, and transmission of 

data. 

GPS interference in coastal areas would cause weather and hurricane observing 

buoys and Coastal Marine Automated Network (C-MAN) stations to cease transmitting all weather data via GOES satellite (see GOES and POES Data Collection Systems). The positions of affected buoys would be unknown. Affected buoys that break 

free of their moorings would not be tracked, causing a navigation hazard and loss 

of the buoy. To mitigate the loss of GPS, we could outfit the weather and hurricane 

buoys and the C-MAN stations with IRIDIUM data transmission capability at an 

estimated cost of $2 million (one-time cost) plus an annual maintenance cost of $1 

million. If expedited deployment of new equipment were required to restore service, 

the additional cost is estimated to be $25 million for additional labor and ship time. 

The estimated cost to replace buoys that go adrift and become lost at sea due to 

the inability to track buoy position, cover additional logistics costs for transportation 

to and from ports, and provide larger vessels for the additional buoy spares would 

be $14 million per year. This is a recurring cost and includes equipment purchases 

and preparation of 35 spare buoys per year. 

Radiosonde Upper-Air Observing System 

NOAA flies instruments called radiosondes on weather balloons to measure profiles of pressure, temperature, and relative humidity from the Earth’s surface to the 

mid-stratosphere. The data is used by weather forecasters in numerical prediction 

models and by the aviation industry for use in air traffic. Each instrument includes 

a GPS receiver to provide accurate position and velocity data as it is carried aloft. 

The velocity data is used to compute the winds aloft and the positioning data is 

used to determine the instrument’s height. One site uses GPS height data to derive 

the air-pressure measurement, and there are actions under way to implement the 

same technology in all radiosondes. 

Prolonged, continuous GPS interference would render our radiosondes incapable 

of reporting any wind data, directly impacting the National Weather Service’s numerical weather prediction models, aviation weather products, independent reference for calibration of satellite remote sensing systems, and international commitments to exchange global atmospheric wind and thermodynamic information. Alternate methods would cost approximately $1 million for research and development 

and up to $20 million to implement. They would require at least five years to develop and as long as 15 years to implement, yet produce less data accuracy and 

quality. One alternative method is to triangulate radiosonde course and speed for 

computation of wind data. A second method is to modify the system to operate as 

a radio-theodolite and use radio-direction finding to compute wind data. 

GPS Dropsondes 

NOAA’s ‘‘hurricane hunter’’ aircraft release instruments called dropsondes into 

the eye of hurricanes to obtain data, enabling forecasters to track and predict hurricane movements. This results in warnings that save human lives and property. 

These data are also used by the hurricane research community. Each dropsonde 

contains a GPS receiver, along with pressure, temperature, and humidity sensors 

to capture atmospheric profiles and thermodynamic data. 

Interference with the GPS signals would affect hurricane reconnaissance and surveillance missions, especially along the immediate coast of the United States, and 

would hamper any ability to accurately predict the strength, location, and direction 

of a hurricane or cyclone and to implement disaster management plans. If the 

LightSquared system interferes with the signals from dropsondes, this would re-
126 

quire dropsonde redesign efforts exceeding $200,000, including redesign, prototypes, 

and testing. 

Hydrological and Geospatial Data 

NOAA’s National Weather Service relies upon geospatial hydrologic data received 

from numerous internal and external sources, with over 14,000 data collection platforms. These data support weather forecasts and storm alerts of significant rainfall/ 

snowfall. The data collection platforms use GPS to correct normal clock drift. 

Disruption of the GPS signal would result in transmission of data at incorrect 

times, which may result in lost, missing, or corrupt data, affecting the National 

Weather Service’s ability to provide hydrologic forecast services. To mitigate widespread GPS interference, the entire data collection system would have be re-engineered so fewer platforms transmit data on the same frequencies per hour. The result would be a drastic (roughly one order of magnitude) reduction in data collection 

capability. Applying the fix to all of the deployed platforms would incur costs in 

terms of hardware, labor, and travel to many remotely located platforms. 

Digital Gamma Radiation Detection Systems 

NOAA flies digital gamma radiation detection systems on aircraft to measure soil 

moisture and snow water. These systems are often the sole source of in situ data 

available during floods driven by spring snowmelt, such as those experienced recently in the Upper Midwest. The data streams provided by these systems contain 

GPS-derived location information, necessary for assimilating gamma-based measurements into river forecasting decision support systems. 

Imprecise gamma flight line location would decrease the accuracy, precision, and 

confidence of flood forecast models dependent on these data. The gamma survey system’s GPS data stream could be replaced with the aircraft’s GPS location data 

stream at a cost of about $10,000. But if the avionics were also degraded by 

LightSquared transmissions, no mitigation would be possible, and this current 

NOAA capability would be lost. 

Observation Station Location Data 

Accurate and precise measurements of observation station locations are essential 

to the assimilation and validation of ground-based observations of 

hydrometeorological variables. Station locations are routinely measured using commercial GPS receivers. 

In the absence of GPS, the National Weather Service would use USGS topographic maps to determine the locations of observation stations. This imprecise data 

will have an unacceptable effect on model-generated forecasts of water levels and 

flooding by decreasing model confidence levels. We have not identified any possible 

mitigation for the loss of GPS; NOAA would lose capability. 

Tsunami Warning Centers 

The National Weather Service operates tsunami warning centers in Alaska and 

Hawaii as part of an international cooperative effort among 26 member states to 

save lives and protect property. Both centers are highly dependent on reliable GPS 

to conduct their mission. Both use seismic and sea-level data, nearly all of which 

are timed using GPS clocks, to detect and analyze earthquakes for their tsunami 

potential and to detect and measure tsunami waves to forecast their impact. Further, all of the computers within the two centers that are used to do the analysis 

and create and issue the products are timed using GPS clocks. 

In the presence of GPS interference, the clocks would begin drifting such that 

within a fairly short time—probably less than a day—timings would be affected, degrading the tsunami warning centers’ performance. Also, many of the coastal sea 

level stations have a small (as small as five seconds) time window in which to send 

their data to the satellite. If the local clock drifts out of the window, then the transmission can overlap with the transmission from another gauge, destroying both sets 

of data. To mitigate widespread GPS interference, the entire data collection system 

would have be re-engineered so fewer platforms transmit data on the same frequencies per hour. The result would be a drastic (roughly one order of magnitude) 

reduction in data collection capability. Applying the fix to all of the deployed platforms would incur costs in terms of hardware, labor, and travel to many remotely 

located platforms. 
127 

Pacific Island GPS Sensors 

These sensors provide continuous total accumulated moisture within the atmosphere for a better depiction of the atmosphere as conditions change. They also support atmospheric modeling. The sensors provide geologic information on island 

vertical and horizontal displacement. These data also provide information about the 

duration and strength of seismic activities. GPS provides time and position data as 

well as detection of water vapor based on the atmospheric effects on the GPS signals. 

GPS interference would result in a loss of sensor data. We have not identified any 

possible mitigation for the loss of GPS; NOAA would lose capability. These sensors 

provide valuable information in the Pacific that cannot otherwise be obtained without great cost to the Nation. 

Alaska Fisheries Science Center (AFSC) 

The Alaska Fisheries Science Center (AFSC) generates scientific information and 

analysis necessary for the conservation, management, and utilization of the Alaska 

region’s living marine resources, and GPS is linked to every geo-referenced piece of 

data collected for this purpose. It is used for accurate data mapping, precise sampling, and geographic information system analysis to understand distributions of 

fish, protected species, habitat biota, oil, and marine chemistry. For instance, it is 

used to follow marine mammals through tracking collars and geo-referenced photography. Without GPS, mammal positions would have to be calculated with Service 

Argos, with a significant loss of precision. Additionally observer data, fisheries survey data, acoustic mapping and hydrographic mapping all rely on the accuracy and 

dependability of GPS. The above-mentioned benefits of GPS are not specific to 

AFSC. Over the last decade almost every fisheries science program and commercial 

fishing operation has come to rely on GPS to provide economical, accurate, highquality positioning information. 

Emergency beacon (G-EPIRB) signals use GPS positions and are critical to personnel safety, particularly for those operating in remote and harsh environments 

such as the Alaska region. AFSC issues hundreds of personal locator beacons to 

staff and contracted fishery observers. It also distributes several dozen GPS units 

used by field researchers and small vessel operators when operating in remote 

areas. NOAA vessels and small boats rely entirely on GPS for positioning and navigation of field operations, even in waters considered near shore. In emergency situations, GPS degradation could prevent fast responses and position certainty. As a result, personnel would be exposed to more safety risks than their jobs currently pose. 

Without GPS, economical and accurate positioning and geospatial referencing will 

be much more expensive, time consuming, and inaccurate. At a minimum, service 

interruptions would compromise our ability to enforce fishing regulations (vessel 

monitoring system accuracy), monitor habitat changes, and collect accurate 

geospatial research and commercial catch data. At worst, it could invalidate data 

needed to support decision-making actions required by the Magnuson-Stevens Fishery Conservation and Management Act, the Endangered Species Act, the Marine 

Mammal Protection Act, and a host of other legislation. 

National Estuarine Research Reserve System (NERRS) 

The NERRS System-wide Monitoring Program provides high-resolution data on 

water quality and weather at 28 coastal reserves across the Nation. Sentinel site 

networks are now being established to track the impacts of coastal uplift and sea 

level rise on coastal ecosystems. Monitoring of ecological observations within an accurate and consistent geospatial framework requires high precision GPS. It is used 

to connect tidal and geodetic datums, establish spatial relationships between trends 

observed within a network of surface elevation tables, and monitor the rate of local 

vertical land movement, as well as the height of the marsh surface and ground 

water relative to local sea level. In many locations, elevation changes below one centimeter can have profound effects on the structure and function of coastal ecosystems; therefore high-precision GPS capability is critical. 

Based on initial testing, we believe the wideband, high precision GPS equipment 

used to measure sea level trends is at risk even under the LightSquared lower channel only. If high precision GPS service became unavailable or unreliable, it would 

have profound effects on the ability to monitor impacts of sea level changes and inundation from storms and coastal flooding on coastal communities and ecosystems. 

This would undermine the ability of communities to identify their risk to sea level 

change and episodic storm events. The loss of GPS service would require extensive 
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reliance on field-based leveling, which is exponentially more expensive in terms of 

time and labor costs. 

Coastal Services Center 

The Center works with state and local coastal programs to determine data needs 

and deliver the data, tools and training needed to turn these data into useful information relative to socioeconomics, orthoimagery, marine boundaries, land cover, hydrography, elevation, etc. GPS receivers are used in marking boundaries and mapping shorelines, monitoring erosion, assisting with dock permitting and other management plans, tracking endangered animals, and rapidly assimilating post-storm 

damage assessments. LIDAR elevation mapping and aerial photography use high 

precision GPS. Validation of the mapped data also requires high precision GPS. 

If GPS services were not available, elevation products needed to meet requirements for flood mapping and sea level rise mapping may not be possible. It was only 

with the advent of high precision GPS that wide-area coverage at the required accuracies became feasible. Aerial photography could still be done, but at additional 

costs for crews to put down target panels and survey them in. That surveying would 

also have to be done with older, more expensive, technology. Costs might be anywhere from 50–100 percent greater. 

Center for Operational Oceanograpbic Products and Services (CO-OPS) 

CO-OPS provides the national infrastructure, science, and technical expertise to 

monitor, assess, and distribute oceanographic data for coastal waters, including historical and real-time observations and predictions of tide, current, water level, and 

other coastal oceanographic data. GPS time synchronization is necessary for the 

time stamping of data shared and ingested to produce products (six-minute data, 

high and low data, hourly heights, and datums). 

If the GPS signals are degraded or not reliable, all CO-OPS operations would be 

affected. Loss of GPS time stamps would prevent data processing and reduce support to the Physical Oceanographic Real-Time System, hydrographic surveys photogrammetry, National Water Level Observation Network, VDatum, COASTAL partners, OCS, other federal agencies, and the general public. We have not identified 

any possible mitigation for the loss of GPS; NOAA would lose capability. 

Bench Mark Elevation Data 

This data is necessary to vertically reference water level observations to establish 

tidal datums. Without a vertical datum reference, water level data have minimal 

value and cannot be used to update tidal datums, derive nautical chart depths from 

bathymetric survey data, or establish privately owned land, state-owned land, territorial sea, exclusive economic zone, and high seas boundaries. CO-OPS collects GPS 

observations on bench marks and submits the data to the OPUS database. 

Lost or degraded GPS signals would affect the collection of ellipsoid elevations, 

geodetic elevations and hence would affect the compilation of the VDatum Complete 

List for the VDatum Program, which in turn would affect the development and update of the VDatum models. We have not identified any possible mitigation for the 

loss of GPS; NOAA would lose capability. 

National Current Observations Program (NCOP) 

NCOP supports tidal current predictions for various coastal regions and location 

as well as recovery of expensive subsurface measurement systems. It relies on GPS 

position data to mark locations of moored current measurement instrumentation. 

Loss of GPS would result in inaccurate or missing position data and potential loss 

of instrumentation. We have not identified any possible mitigation for the loss of 

GPS; NOAA would lose capability. 

Sea Surface Radar Altimeters 

These instruments measure sea state and ocean currents to improve weather and 

climate models, as well as models used to inform NOAA and Coast Guard searchand-rescue efforts and other operations at sea. GPS time synchronization enables 

time-based sharing of radio frequencies among dozens of radars. This capability will 

soon become a requirement by international and domestic regulations for all high 

frequency radars, as it allows for nearly simultaneous use of the same transmit frequency. 
129 

Loss of GPS time synchronization would prevent the radar network from properly 

sharing the radio frequencies, degrading data collection capabilities and reducing 

the accuracy of meteorological models. The systems would not comply with the impending regulations. The systems would be required to operate on a non-interference basis. Radars would need much more spectrum to continue operating at current levels. Increased spectrum requirement will result in lost capability due to lack 

of available frequencies. Capability would be lost in support of Coast Guard search 

and rescue activities and NOAA/Coast Guard oil spill response. We have not identified any possible mitigation for the loss of GPS; NOAA would lose capability. 

Ship Mounted Current Profiler Systems 

NOAA vessels measure sea currents by combining GPS motion data (ship’s speed 

over ground, course over ground, and heading) with acoustic profiler data to obtain 

current measurements referenced to earth-fixed coordinates. In coastal areas where 

the impact would be greatest, interference to GPS on our vessels would lead to inaccurate or missing position and motion data. We have not identified any possible 

mitigation for the loss of GPS; NOAA would lose capability. 

NOAA 

Vessel Navigation Systems 

NOAA operates a fleet of 19 vessels in the Pacific and Atlantic Oceans for oceanographic, atmospheric, fisheries and coral reef research, nautical charting, environmental monitoring and ocean exploration. The fleet employs a variety of GPS and 

differential GPS receivers for navigation and scientific use. Position Heading and 

Attitude Sensors are used to determine the vessel’s position, heading and attitude 

(heave, pitch and roll) with input from GPS receivers. 

The existing MSS/ATC rules require that the emissions from a base station operating in the 1525–J541.5 MHz and 1547.5–1559 MHz bands at the water edge of 

a navigable waterway is limited to a total power flux density (PFD). Given the base 

station PFD requirements in the current rules GPS receivers on board vessels 

should not be impacted by the original or current spectrum proposal made by 

LightSquared. NOAA hopes to test some marine navigation equipment in a future 

round of interference testing to verify if this is the case. 

Electronic Chart Display (ECDIS) and Information System/Electronic Navigational 

Charts (ENC) 

ECDIS and ENCs replace paper nautical charts aboard maritime vessels. The 

International Maritime Organization (IMO) mandated carriage of ECDlS and ENCs 

aboard commercial vessels starting in July 2012. An ECDIS displays the information from an ENC and integrates current position information from GPS and other 

navigational sensors. Interference to GPS on vessels would lead to incorrect operation of IMO-mandated ECDIS and ENCs for navigation. We have not identified 

any possible mitigation for the loss of GPS; NOAA would lose capability. 

Autonomous Underwater Vehicles (AUV) 

NOAA uses AUVs in robotic studies of lakes, the ocean, and the ocean floor. A 

variety of sensors measures the concentration of various elements or compounds, the 

absorption or reflection of light, and map features of the ocean. AUVs navigate 

using an underwater acoustic positioning system. Surface references, such as a support ship, use baseline positioning to calculate where the AUV is relative to the 

known (GPS) position of the surface craft. When operating completely autonomously, the AUV will surface and take its own GPS fix. 

Interference with GPS positioning data along U.S. coasts would render information mapped by the UAV inaccurate or speculative. We have not identified any possible mitigation for the loss of GPS; NOAA would lose capability. 

Ocean Mapping Sensor Network 

NOAA uses this network to acquire hydrographic data to update the Nation’s nautical charts and navigation products. NOAA is responsible for surveying 3.2 million 

miles of the U.S. Exclusive Economic Zone. GPS provides precise positioning for acquiring hydrographic survey data. NOAA’s Office of Coast Survey relies heavily on 

this data to accurately position its sensors. 
130 

Our analysis ofthe LightSquared testing data suggests that our survey boats could 

be affected from as far as 1.2 miles from shore. We have not identified any possible 

mitigation for the loss of GPS; NOAA would lose capability. 

Ground-Based GPS Meteorology Project (GPS-Met) 

GPS-Met provides atmospheric profiles across the United States in support of improved weather forecasting, climate monitoring, and satellite sensor calibration and 

validation. GPS-Met utilizes high precision GPS receivers co-located with surface 

meteorological sensors to calculate the total precipitable water vapor directly above 

the site, vastly improving short-term weather forecasting. 

Based on initial tests, we believe the wideband, high-precision GPS equipment 

used by GPS-Met is at risk even if LightSquared uses its lower channel only. GPS 

interference would prevent GPS-Met data and products from being assimilated into 

operational weather models used by forecasters for nowcasting. Model and forecaster prediction skill, especially during severe weather, would fall. Atmospheric 

river observatories and warning systems would be rendered largely useless. Independent monitoring of weather balloon and aircraft moisture observation quality 

would stop, allowing increased inclusion of errors in models, time series, climate 

records, and satellite data products. As GPS-Met is based entirely on wideband GPS 

observations, we stand to lose this entire capability. 

Scanning Doppler Lidar Systems 

These systems measure atmospheric wind velocity in a large cone and produce 

three-dimensional portraits of atmospheric activity. The Lidar systems are operated 

on moving platforms, including research vessels and aircraft. Differential GPS is 

used to measure the platform orientation and motion, control the pointing of the 

scanning device, and remove the impact of the platform’s motion from the measurements. 

GPS interference is already a problem for the sensitive differential GPS navigation systems around ports. Increased interference to vessels near coastal urban 

areas or to aircraft over land would worsen the situation. There is currently no 

backup navigation system for making stabilized Doppler Lidar wind measurements. 

We have not identified any possible mitigation for the loss of GPS; NOAA would 

lose capability. 

Wind Profiling Radars 

NOAA operates a network of 35 wind profiling radars around the United States. 

They detect wind speed and direction at various elevations to support forecasting 

and timely reporting for flight planning. GPS is used to synchronize the time 

stamps across the national network and provide location information for collected 

data. 

Without GPS time stamps and georeference information, data cannot be properly 

ingested into weather models, degrading the accuracy of forecasts. To mitigate GPS 

interference, NOAA could purchase and maintain atomic time standards for each of 

the 35 radar sites at great expense. However, even absent GPS interference, the 

wind profilers arc expected to experience interruptions in the future once the European Galileo satellites, which operate on the same frequency as the profilers, are 

launched. 

Space Weather Prediction Center 

SWPC provides space weather information and warnings to a variety of customers 

including airlines, power distribution systems, oil rigs and survey vessels, marine 

construction surveyors, satellite operators, and GPS users. It also produces ionospheric models that can be applied as corrections to improve GPS positioning accuracy. SWPC uses networks of high precision GPS reference stations to observe GPS 

signal delays that reveal the electron content of the upper atmosphere. 

Based on initial testing, we believe the wideband, high precision GPS equipment 

used by SWPC is at risk even if LightSquared uses its lower channel only. GPS interference would degrade the accuracy and usefulness of SWPC products such as the 

U.S. Total Electron Content (US-TEC) product, which informs surveyors, construction operations, and other customers about space weather conditions affecting GPS 

accuracy. We have not identified any possible mitigation for the loss of GPS; NOAA 

would lose capability. 
131 

Frequency Measurement and Analysis Service; Time Measurement and Analysis 

Service/Phasor Measurement Units/Inter-American Metrology System 

NOAA is not involved with these particular systems and functions. 
132 

Responses by Mr. Victor Sparrow, Director, Spectrum Policy, 

Space Communications and Navigation, 

Space Operations Mission Directorate, 

National Aeronautics and Space Administration 

Questions submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

Q1a. How much do they cost? 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at 

your agency? 

A1, 1a, 1b. Radio occultation techniques used by Global Positioning System (GPS) 

receivers (also known as GPS occultation science) are believed to be the most susceptible to severe interference from the LightSquared network and were studied 

both in the Federal Communications Commission (FCC)-mandated technical Working group (TWG) and the National Space-based Positioning, Navigation, and Timing 

(PNT) Systems Engineering Forum (NPEF). Both space-based and ground-based 

radio occultation science programs would be affected: 

• Space Missions Affected: NASA estimates 20-plus satellites will be launched for 

radio occultation measurements over the next 10 years. The normal upgrade 

cycle for flight receivers is 10 years, and the effective mission length of these 

satellites has been about eight years. 

• Ground-based Tracking Networks Affected: For impacts to NASA ground-based 

GPS occultation science on the Global Differential GPS (GDGPS) network, the 

cost is approximately $50 thousand per station, for a total of at least 100 NASA 

sites, which results in a conservative estimate of $5 million. An additional 500- 

plus sites for International Global Navigation Satellite Systems (GNSS) Service 

(IGS) totals $25 million, with an additional $50 million for the National Science 

Foundation (NSF) Plate Boundary Observatory. 

• Uninhabited Aerial Vehicle Synthetic Aperture Radar (UAVSAR): NASA operates aircraft-based radar which uses both augmented GPS to provide accurate 

real-time navigation and centimeter-level post processed positioning to achieve 

the precision required for interferometric synthetic aperture radar. 

There are, however, additional impacts to other programs and missions, including: 

• Geodetic Science: It is difficult to estimate the costs associated with disturbing 

the GPS-based measurements used to maintain and update the reference frame, 

but these could be significant because such errors will in turn affect high precision applications that use GPS for climate and environmental monitoring. 

• Tracking of Launch Vehicles: NASA uses GPS for tracking launch vehicles at 

Wallops Flight Facility (WFF) and as the primary tracking source for the Autonomous Flight Safety System (AFSS) being developed by WFF and Kennedy 

Space Center (KSC). NASA also uses commercial rockets to launch science missions from the Eastern and Western Air Force Ranges that increasingly rely on 

GPS. Not knowing where a vehicle is during a launch because of GPS interference could result in a rocket and its payload being destroyed unnecessarily. 

Since the interference degradation from LightSquared emissions is highly dependent on the specific design of the GPS receiver front-end, the effect on other space 

receivers is unknown at this time. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use of the ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Is NASA prepared to upgrade or re-equip all their GPS equipment in that time 

frame? 

Q2b. Can you tell the members of the Committee what the cost would be to implement this strategy within your agency? 

Q2c. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? 
133 

A2–2c. The proposed filters are not yet available to NASA, and preliminary discussions with filter manufacturers (e.g., Delta Microwave, which was referred to NASA 

by LightSquared) indicate that filtering for high precision GPS receivers would result in significant degradation in receiver performance and accuracy. If interference 

mitigation techniques are identified, testing would be necessary to determine the 

impact on receiver performance. 

A more realistic time frame to upgrade and/or re-equip missions under development has been demonstrated by the U.S. Department of Defense (DoD), which provided a decade of transition time for worldwide GPS codeless/semi-codeless users to 

migrate to the new L2C signal by 2020 to enable unfettered GPS Precise Positioning 

System (GPS PPS) Flex Power on the modernized GPS constellation. 

It will take 10 or more years for most of the GPS receivers that are operating 

in space today (or close to launch now) to reach the end of their operational life. 

It is not feasible to retro-fit satellites that are already on orbit, so harmful interference would directly compromise these missions. 

Q3. LightSquared’s modified business plan starts commercial operations with just 

the ‘‘lower’’ portion of its spectrum and will be limited to urban areas. Does this 

satisfy your concerns about short-term interference issues to wideband and high 

precision GPS receivers? If not, why not? 

A3. NASA testing shows that the use of just the lower 10 MegaHertz (MHz) band 

still results in significant interference to NASA’s next generation space-based GPS 

receiver and terrestrial high precision science receivers. Further, NASA expects that 

the addition of filters to reduce the interference from the lower 10 MHz 

LightSquared signal would cause significant performance degradation. If interference mitigation techniques are identified, testing would be necessary to determine the impact on receiver performance. 

Q4. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different to your agency than their original proposal? 

A4. For GPS high precision receivers, there would be very little difference; NASA’s 

testing shows that the use of just the lower 10 MHz band still results in significant 

interference to the Agency’s missions, particularly Uninhabited Aerial Vehicle-Synthetic Aperture Radar (UAVSAR), geodetic science, and launch operations. Future 

GPS flight receivers will need to be equipped to deal with all LightSquared signals 

that may be broadcast during the mission lifetime. 

Q5. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A5. NASA fully supports the Administration’s goal of identifying additional spectrum for broadband use, and will continue to cooperatively investigate and assess 

mitigation strategies, while seeking not to compromise the performance of NASA’s 

GPS-dependent systems or missions. 

Q6. Does NASA feel that adequate testing has been done on all of the issues associated with LightSquared interference on their agency’s missions? Should there be 

more testing on high precision units? 

A6. Since the interference degradation from the LightSquared emission is highly 

dependent on the specific design of the GPS receiver front-end, the effect on other 

space receivers is unknown at this time. 

Additional analyses are also needed for ‘‘non-high-precision’’ receivers used by 

NASA and other space operators, in applications such as: (1) International Space 

Station (ISS) operations, including human and/or automated space vehicles performing rendezvous with the Station; and (2) launch vehicles and/or space vehicles 

performing re-entry and landing where a vehicle could be operating much closer to 

an interfering source. 

The issue of interference with GPS receivers from LightSquared handset emissions has not been completely tested. In NASA’s view, extensive testing of handset 

emissions is a necessity before any LightSquared field use. 

Q7. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If not, why not? 

If so, what testing has been done to demonstrate their effectiveness? 
134 

A7. These filters have not been made available to NASA for assessment. Preliminary discussions with experienced filter manufacturers (e.g., Delta Microwave) indicate that filtering for high precision GPS receivers would result in significant degradation in receiver performance and accuracy. 

The JAVAD website states, ‘‘We have also invented a unique solution for timing 

applications in which we dynamically compensate for group delay variations with 

the accuracy of better than 100 picoseconds. We are developing techniques to reduce 

this to better than 10 picoseconds.’’ NASA has not had the opportunity to test the 

accuracy of these statements but, even if accurate, 10 picoseconds is 30 times higher 

than nominal system noise error at C/No = 52 dB-Hz, which amounts to independent 1-second errors of 0.3 ps at the GPS L1 frequency (100 picoseconds is 300 

times higher), and would still fail to meet the requirements of NASA missions such 

as GRACE (which requires 0.060 nanosecond precision to enable gravity field measurements). 

In addition, these filters would only remove the signals in the lower portion of 

the spectrum allocated to LightSquared; if the company eventually utilizes the 

upper portion, as well, the filters would not mitigate signal interference. 

Q8. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A8. NASA is not aware of any mitigation strategies at the proposed LightSquared 

frequencies that would not impose significant performance penalties on the high 

precision receivers. If interference mitigation techniques are identified, testing 

would be necessary to determine the impact on receiver performance. 

Q9. How much would it cost your agency to mitigate the interference issues from the 

LightSquared signal on your missions? 

Q9a. Does your agency currently have funds set aside for this purpose? 

A9, 9a. NASA is not aware of any mitigation strategies that would not impose significant performance penalties on its high precision receivers. No funds have been 

authorized or set aside for mitigation of interference impacts due to LightSquared 

emissions in the upper 10 MHz portion of the spectrum. Additionally, many receivers are already serving operational missions on-orbit, so there is no way to retrieve 

the satellite to retrofit the impacted receivers if the upper 10 MHz is used by 

LightSquared. We are also concerned about the impact to the next generation of 

GPS receivers used for future missions that could be impacted by LightSquared 

emissions in both the upper and lower 10 MHz areas. 

Q10. Since August 15, the FCC has had the ability to rule on the LightSquared proposal, and to my knowledge, NTIA has yet to submit comments to the FCC on 

behalf of affected agencies. 

Q10a. Has NTIA provided your comments to the FCC? 

Q10b. Will NASA submit its comments directly to the FCC if NTIA fails to do so? 

If so, when? 

Q10c. Would you agree that your agency’s assessment should be made public so that 

everyone can understand the extent to which LightSquared interference to 

GPS will impact the ability of your agency to perform its duties, and the costs 

that may be incurred due to this interference? 

A10–10b. To NASA’s knowledge, NTIA has not provided formal comments, on behalf of the Administration, to the FCC on the LightSquared proceedings. However, 

NTIA did provide the NPEF Report to the FCC on July 6, 2011. NASA has no plans 

to submit comments directly to the FCC, but reserves the option to do so. NASA 

provided its assessment in testimony to the House Committee on Science, Space and 

Technology on September 8, 2011. 

Q11. The NASA letter to the NTIA states that NASA extensively uses high precision 

GPS receivers for scientific applications and ‘‘we have seen no evidence that 

these receivers can be filtered without significantly reducing receiver accuracy 

and performance.’’ 

Q11a. Is additional testing necessary to determine the impacts on these high precision GPS receivers? 

Q11b. Should LightSquared be required to satisfy all members of the GPS community, including those high precision users that are not represented by industry, 

before they’re allowed to commence commercial operations? 
135 

A11–11b. The interference degradation from the LightSquared emission is highly 

dependent on the specific design of the GPS receiver front-end, so the effect on other 

high precision space receivers is unknown at this time. 

Additional testing could help to quantify the degree of impact to high precision 

GPS receivers, but it is clear that significant impacts will be introduced with current LightSquared plans unless interference mitigation techniques are identified 

that do not impact performance. In NASA’s view, commercial operations should not 

be allowed to commence if significant interference would occur to existing NASA operations and scientific research that benefits the Nation as a whole. NASA cannot 

speak for all members of the GPS community. 

Q12. One possible solution proposed by NASA is to ‘‘find alternative spectrum, including spectrum holdings LightSquared already has, in which to conduct 

LightSquared’s planned terrestrial operations.’’ Can you expand on this solution for the Committee? What other spectrum could be utilized by LightSquared 

for its operations? Would that spectrum be far removed from the GPS signal 

and not cause significant interference issues? 

A12. NASA fully supports the Administration’s goal of identifying additional spectrum for broadband use, and will continue to cooperatively investigate and assess 

mitigation strategies, while not compromising the performance of NASA’s GPS-dependent systems or missions. 

LightSquared press releases refer to its control of 59 MHz of spectrum, some of 

which is presumably available for terrestrial use. Some of the spectrum is around 

1.4 GigaHertz (GHz) and some is around 1.6 GHz, both removed from the 1.5 GHz 

region where GPS operates. While testing and analysis would be necessary for 

verification, the use of spectrum away from GPS helps reduce interference considerably. 

Q13. Since it is well established that LightSquared intends to operate on the upper 

10 megahertz of the L-Band after some interim period, and since it is also well 

established that such use of the upper 10 megahertz channel will have catastrophic negative results for GPS reception, is the use of the Low-10 option a 

viable option? 

A13. Testing by NASA Jet Propulsion Laboratory (JPL) engineers indicates the use 

of just the lower 10 MHz band still results in significant interference to NASA’s 

next generation space-based GPS receiver and terrestrial high precision science receivers. These are similar to receivers used by other nations to process GPS and 

other similar PNT systems such as Galileo. Moreover, with respect to the interference impact to NASA space receivers from LightSquared emissions in the lower 

10 MHz band, it should be noted that only two space receivers were tested during 

the TWG process. Since the interference degradation from the LightSquared emission is highly dependent on the specific design of the GPS receiver front-end, the 

affect on other space receivers, including those used onboard the ISS and NASA 

launch vehicles, is unknown at this time. NASA has identified this to NTIA as an 

area for further study. 

The implementation of a system that causes GPS ‘‘dead spots’’ would have a significant impact on NASA’s scientific research. There are many examples where this 

interference would be detrimental, some of which are described below. 

• Ground-truth measurements. In order to calibrate on-orbit instruments, scientists often use ground-truth measurements. Precise knowledge of the location 

of these measurements is critical to enabling accurate calibration of the on-orbit 

instrument. For example, for a new spacecraft instrument taking a measurement of algae blooms in lakes or air samples, measurements are taken over a 

precisely identified time and location, as defined by the spacecraft GPS location 

data. The ground measurement is also precisely known (in time and location) 

based on GPS data. If the measurements on the spacecraft match the measurements on the ground, scientists know the on-board instrument is working properly. This important calibration procedure is completely dependent on the availability of the in situ GPS location data. Without this ground truth of the instrument data, the resulting observations and data interpretations will be suspect. 

• Ground-based infrastructure. The National Research Council recently published 

a report on the national imperatives for a precision positioning infrastructure. 

NASA is a lead agency in the operation and maintenance of this infrastructure, 

and interference with GPS operations would compromise the utility of this infrastructure. There are numerous applications of ground-based science that are 

dependent on the precise location information available from GPS. One critical 

type of science is research on natural hazards such as earthquakes, landslides, 
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and volcanic eruptions. In this research area, the smallest movement of the 

Earth’s surface is tracked to better understand the possibility of catastrophic 

events. These measurements must be extremely precise if scientists are to have 

insight into the pressures building up within fault zones or volcanoes that ultimately result in a release of the pressure in the form of an earthquake or volcanic eruption. Natural hazards research has become increasingly dependent on 

GPS data, the loss or impairment of which could be devastating and jeopardize 

thousands of lives. 

• Ionospheric measurements. The sun routinely sends out radiation that, on 

Earth, is trapped by the ionosphere. When a particularly strong solar flare 

erupts, it has the potential to send enough radiation to disrupt (and even disable) the country’s electric power grid and to disrupt communications and radar 

tracking. By using very precise GPS measurements, scientists can watch for 

changes in the ionosphere to mitigate the effect of these changes or to prepare 

for impending events. This information is useful to a broad group of users including electric companies (which can take action to protect their systems), 

radar and radio operators, and scientists who seek to better understand and respond to this phenomenon. Without these GPS measurements, notification of 

potential disruptions would be delayed, resulting in damage to the power grid 

or interference to radar and radio transmissions. 

• Uninhabited Aerial Vehicle (UAV) and Aircraft operations. Not all science data 

are collected from satellites or in situ measurements; some are collected using 

UAVs and other aircraft. For example, NASA’s highly successful UAV Synthetic 

Aperture Radar (SAR) project recently flew a sophisticated radar to study the 

Gulf of Mexico oil disaster and the impact of the Mississippi floods on levees 

and farmland. These UAVs and other aircraft use GPS for navigation, and 

would not be usable for this type of science without it (or without a costly 

change to perform navigation using another method). In the case of 

interferometric SAR, no other navigation is capable of determining the relative 

position between repeat UAV passes with sub-centimeter accuracy to allow successful data collection. 

• Precision spacecraft navigation. Spacecraft use GPS for precise navigation. 

While the LightSquared transmission towers would not interfere with the use 

of GPS signals that are directly overhead of the spacecraft, there would be interference with ultra-precise navigation that requires the input of multiple GPS 

signals simultaneously. In this instance, the scientific satellite would be looking 

at a very low angle to obtain the signals from GPS satellites that are farther 

away. The high power emissions from the LightSquared transmission towers 

would interfere with these low look-angle signals, thereby reducing the accuracy 

of the navigation information and leading to a degradation of the science data. 

Many spacecraft also use a reference system of ground networks that would be 

dramatically impacted by this GPS interference. The U.S. hosts a significant 

number of ground observatories that function as reference sites for the precision 

navigation of satellites and aircraft, and interference to the GPS signal would 

degrade the science data. 

• Weather sensing. GPS radio occultation uses the bending of GPS signals by the 

atmosphere as they travel from the GPS satellites to an orbiting spacecraft. 

This NASA-developed technique is now used operationally by NOAA to improve 

their long-range weather forecasts. The interference to the GPS signal would 

render this technique, which looks all the way down to the Earth’s surface, useless over the continental U.S., thus impacting the accuracy of NOAA’s weather 

forecasts. Radio occultation is also used to help set an absolute benchmark to 

answer the question of global climate change. Geographical biases due to, for 

example, degraded results near the continental United States, would be a severe challenge to this important benchmark. 

In addition, although the plans of LightSquared are for towers within the continental United States, approval for this U.S. Company could have global implications. There is great concern that companies outside the U.S. will pick up this technology, causing scientific impacts across the globe and eroding the capabilities of all 

Global Navigation Satellite Systems, not just the U.S. GPS. In short, use of just the 

lower 10 MHz for high-precision GPS receivers does not appear technically acceptable to NASA. 

In summary, due to the very physics of GPS-based PNT, there is no apparent option that would allow the high-precision GPS receivers to operate in the presence 

of the LightSquared lower 10 MHz signal unless interference mitigation techniques 

are developed that do not impact performance. 
137 

Q14. Now that the United States is dependent on Russia for access to the International Space Station and the failure of the Soyuz Launch Vehicle leaves the 

U.S. grounded, how would NASA operations be impacted if the U.S. was dependent upon Russia’s GLONASS system, or any other precision, navigation, 

and timing system? 

A14. The impact to NASA is minimal since the cause of the Soyuz failure has been 

determined and Soyuz flights have resumed. The Progress 45 mission was successfully launched on a Soyuz vehicle on October 30, 2011. 

The proposed LightSquared network, however, does have the potential to cause 

significant impact to NASA and other U.S. rocket launches. NASA uses GPS for 

tracking launch vehicles at Wallops Flight Facility (WFF) and as the primary tracking source for the Autonomous Flight Safety System being developed by WFF and 

Kennedy Space Center (KSC). NASA also uses commercial rockets to launch science 

missions from the Eastern and Western Air Force Ranges that increasingly rely on 

GPS. Not knowing where a vehicle is during a launch because of GPS interference 

could result in a rocket and its payload being destroyed unnecessarily. The costs of 

a failed mission depend on the vehicle and payload, but could be in excess of $1 billion. 

In terms of using the Russian GLONASS system for navigation, as suggested in 

the question, the Russian GLONASS system uses a very different signal structure 

that requires its own receivers. It is not fully interoperable with GPS receivers, although there are receivers that process both GPS and GLONASS signals. Also, 

GLONASS has had serious reliability problems in the past. Therefore, GLONASS 

is not a substitute for GPS today, and other international systems are not yet operational. 

Questions Submitted by Ranking Member Eddie Bernice Johnson 

Q1. I understand that NASA uses high precision receivers on its satellites. Limited 

tests have shown that such high precision receivers may be more prone to interference from the proposed LightSquared network than say, the GPS receiver in 

cell phones. 

Q1a. What NASA applications require high precision receivers? 

A1a. NASA scientists use GPS science receivers, in combination with other measurement techniques such as laser ranging and radar altimeters, to monitor our environment. This includes, for example, monitoring the changes in Earth’s surface, sea 

level height, and atmospheric measurements, and providing precise knowledge of 

Earth’s shape and rotation (Figure 1). Global Positioning System (GPS) technology 

has become an essential tool for monitoring and improving our understanding of 

Earth systems, including climate change and solid earth hazards, such as earthquakes and volcanic activity. This knowledge of our environment and its changes 

is also used for resource management, protection, and environmental impact mitigation. 

Some examples of the use of GPS to improve our knowledge of the Earth are: determining the atmosphere’s water content; improving the accuracy of weather forecasts; sensing changes in the small-scale distribution of ground water; accurately 

measuring the mass changes in glaciers and polar ice caps; setting an accurate 

present-day benchmark for the global averaged atmospheric temperature; generating ‘‘now-casts’’ of space weather; and enabling ocean topography measurements 

to determine currents and long-term changes in sea height. Ground-based GPS networks are also playing an increasingly prominent role in monitoring ground movement to identify potential conditions that may precede earthquakes and volcanic activity. In addition, some insurance companies use GPS-based maps of accumulated 

tectonic strain to predict risk. The same data are used by other Government agencies beyond NASA. GPS technology assists NASA scientists in understanding the 

physical characteristics of the Earth and its atmosphere, and changes over time. 

The Earth system, like the human body, comprises diverse components that interact 

in complex ways. Scientists work to understand the Earth’s ionosphere, atmosphere, 

oceans, interior, and biosphere as a single connected system. The planet is changing 

on all spatial and temporal scales. 
138 

Specific satellite-based NASA GPS-based science applications include, but are not 

limited to: radio occultation, gravity field modeling, altimetry, surface reflectometry, 

precise time transfer, global topography, and aeronomy. 

• Radio Occultation: GPS facilitates weather forecasts and also provides an unbiased benchmark for analyzing climate change. Early use of radio occultation 

(RO) data from the COSMIC–1 constellation has been incorporated into weather 

models and has demonstrated an 8-hour improvement in weather forecast skill 

at day four and 15-hour improvement at day seven. This means without RO 

data, scientists could predict with a certain confidence 48 hours in the future. 

After adding RO data, they can now predict with the same confidence out to 

56 hours. Radio occultation data provide a very well calibrated measure of the 

global average atmospheric absolute temperature and, thus, measurements can 

be compared from one mission to another with very low systematic errors. This 

will provide a key benchmark for climate change studies. 

• Gravity Field: GPS enables measurement of the Earth’s gravity field with high 

resolution in time and space. For example, the GRACE mission can measure a 

one-centimeter change in ground water level over the state of Ohio with onemonth temporal resolution. Some applications include hydrology, measurement 

of variations in mass captured in ice caps and glaciers due to global temperature changes, and determination of ocean currents at depths which have societal applications to fisheries and transportation. 

• Altimetry: GPS facilitates precise orbit determination in altimetry (measuring 

sea level height and/or ice sheet thickness). Ocean altimetry data from missions 

such as TOPEX/Poseidon, Jason, the Ocean Surface Topography Mission 

(OSTM), and Jason–3 use GPS to translate radar altimeter measurements to 

place the ocean surface in an Earth fixed reference frame, which supports applications such as fisheries, transportation, weather, and sea level rise. Data from 

missions such as the Ice, Cloud, and land Elevation Satellite (ICESat), and 

ICESat Follow-On enable the determination of ice sheet thickness and estimation of the ‘‘global ice budget’’ to observe the effects of climate change. 

• Surface Reflectometry: The use of GPS signal surface reflections is currently 

being developed to provide synoptic altimetry and scatterometry observables. 

This is an important tool for applications such as, for example, measuring sea 

level height in real time. 

• Time Transfer: GPS facilitates precise time transfer between satellites as needed for coordinated observations from separate satellite platforms. For example, 

the GRACE constellation used GPS time transfer with 0.060 nanosecond precision to enable gravity field measurements. 
139 

• Global Topography: GPS supports orbit determination for global topographic 

mapping. For example, GPS provided 60-centimeter navigation of the Space 

Shuttle during the Shuttle Radar Topography Mission (SRTM), which used 

Interferometric Synthetic Aperture Radar (InSAR) to obtain the first global 

topographic map. 

• Aeronomy: The inference of atmospheric state (aeronomy) from observed drag 

using precise GPS-determined orbits is used to improve models of the upper atmosphere. These models enable space missions to better estimate the effect of 

atmospheric drag and orbit decay of spacecraft in Low Earth Orbit (LEO). 

The science data obtained using GPS enable the continually improved precise 

navigation provided by GPS to all other GPS users. In turn, these scientific data 

have enabled GPS to continue improving. Thus, the data from Earth science missions support the continued improvement of GPS capabilities while, at the same 

time, GPS provides data for scientific research. 

The potential disruption of GPS reception due to interference from the 

LightSquared terrestrial wireless network could affect a number of terrestrial and 

space-based NASA science missions. Affected terrestrial missions include primarily 

Earth science applications such as geodesy (e.g., earthquake monitoring and measurement of changes on the Earth’s surface) and environmental monitoring relying 

on GPS measurements at the ground sites of the Global Differential GPS System 

(GDGPS) and International Global Navigation Satellite Systems Service (IGS). 

Space-based science missions potentially affected would include receivers used for 

GPS occultation measurements for atmospheric and ionospheric monitoring and 

characterization. 

Q1b. Are these high precision receivers only space-based? 

A1b. No, as described in the response to the previous question. 

Q1c. Are there any alternatives to GPS for conducting such science missions? 

A1c. GPS is a valuable tool that supports a broad range of NASA science applications. The proposed mitigation techniques do not address the concerns of GPS-based 

science applications. There are no practical alternatives to GPS since they’d have 

to be specific to each of the areas described in the response to question 1a and, thus, 

prohibitively expensive. Should GPS not be available to support high precision 

science, it is likely that most of these science applications would quite simply not 

be performed. 

Q1d. What current missions would be impacted, and what science is NASA at risk 

of losing? What upcoming missions would be affected? 

A1d. There are substantial risks to ongoing and planned NASA missions and 

science. In addition to impacts to space missions, and ground-based networks, there 

are also impacts when supporting operations such as rocket launches. 

Direct Impact to NASA Science 

• Space Missions Affected: NASA estimates 20-plus satellites will be launched for 

radio occultation measurements over the next 10 years. The normal upgrade 

cycle for flight receivers is 10 years, and the effective mission length of these 

satellites has been about eight years. 

• Ground-based Tracking Networks Affected: For impacts to NASA ground-based 

GPS occultation science on the Global Differential GPS (GDGPS) network, the 

cost is approximately $50 thousand per station, for a total of at least 100 NASA 

sites, which results in a conservative estimate of $5 million. An additional 500- 

plus sites for International Global Navigation Satellite Systems Service (IGS) 

totals $25 million with an additional $50 million for the National Science Foundation (NSF) Plate Boundary Observatory. 

A conservative overall estimate of the cost to NASA space and ground-based 

science missions directly at risk from LightSquared is $2.1-plus billion. 

Impact to Rocket Launches 

NASA uses GPS for tracking launch vehicles at Wallops Flight Facility (WFF) and 

as the primary tracking source for the Autonomous Flight Safety System (AFSS) 

being developed by WFF and Kennedy Space Center (KSC). NASA also uses commercial rockets to launch science missions from the Eastern and Western Air Force 

Ranges that increasingly rely on GPS. Not knowing where a vehicle is during a 
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launch because of GPS interference could result in a rocket and its payload being 

destroyed unnecessarily. 

Additional Impacts 

• NASA Geodesy: It is difficult to estimate the costs associated with disturbing 

the GPS-based measurements used to maintain and update the reference frame, 

but these could be significant because these errors would in turn affect high 

precision uses such as climate and environmental monitoring. 

In summary, over the coming decade, scientists will be analyzing the data from 

orbiting spacecraft to characterize, understand, and predict variability and trends 

in Earth’s system for both research and applications. Over a third of the U.S. economy is influenced by climate, weather, space weather, and natural hazards, and 

other applications of Earth Science. Thus, costs to society and the nation of losing 

NASA’s existing GPS-dependent capabilities would go well beyond the estimated 

$2.1-plus billion in direct costs. 

Q2. NASA said in the Technical Working Group report that ‘‘it was impossible to 

adequately evaluate and thoroughly investigate potential interference mitigation 

options for space-based and high precision receivers.’’ LightSquared said in the 

same section of the report that it believes that a new type of receiver currently 

in development could be modified to achieve complete mitigation with minimal 

impact on NASA science missions. 

Q2a. What receivers did NASA and the Technical Working Group test? 

Q2b. What is required to evaluate a mitigation technology? 

Q2c. What is your view of LightSquared’s assessment that a receiver currently in development could be modified to provide complete mitigation? 

A2–2c. Only two space receivers (IGOR and TriG) were tested during the TWG 

process. Since the interference degradation from the LightSquared emission is highly dependent on the specific design of the GPS receiver front-end, the effect on other 

space receivers, including those used onboard the ISS and NASA launch vehicles, 

is unknown at this time. 

The proposed filters have not yet been made available to NASA from 

LightSquared or the filter manufacturers and, therefore, would need to be evaluated 

before a complete mitigation can be implemented. However, preliminary discussions 

with filter manufacturers (e.g., Delta Microwave, which was referred to NASA by 

LightSquared) indicate filtering for high precision GPS receivers would result in significant degradation in receiver performance and accuracy. 

A mitigation technology must be evaluated analytically (e.g., via simulations), 

tested under controlled conditions (e.g., in anechoic chambers), and be operationally 

practical in real-world scenarios. 

Lacking an actual filter or other mitigation technology to test, it is not possible 

to prove claims that mitigation is possible or to measure the degree of performance 

degradation likely to be experienced by the GPS receiver. Complete mitigation is a 

desirable goal, but as yet there is no evidence to prove that this is possible, and 

much to suggest that it is not. If interference mitigation techniques are identified, 

testing would be necessary to determine the impact on receiver performance. 
141 

Responses by Hon. Peter H. Appel, 

Administrator, Research and Innovative Technology Administration, 

Department of Transportation 

Questions submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

Q1a. How much do they cost? 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at 

your agency? 

A1–1b. Many Global Positioning System (GPS) receivers use wide portions of the 

GPS frequency band to provide extremely precise measurements used for applications such as safety-of-life transportation applications, precision agriculture, earthquake and infrastructure monitoring, severe weather forecasting, and surveying. 

The wider bandwidth allows for better signal tracking, which improves the accuracy over low-cost GPS units that often are designed to function using a narrow 

bandwidth. These wideband GPS receivers include 90 percent of those used for aviation today in the U.S. (more than 60,000 aircraft), another 5,600–8,000 receivers on 

international operators’ aircraft from 105 nations coming into the U.S., and all of 

those receivers planned to be used in the future to support the Next Generation Air 

Transportation System (NextGen) navigation and surveillance. Wideband and highprecision receivers are also used in Unmanned Aircraft Systems and National Airspace System infrastructure. 

Many of the high-precision applications for transportation involve surveying, machine control for construction, airborne and ground flight inspection, and reference 

receivers for differential networks. The cost for these receivers is generally a few 

thousand dollars. The Federal Aviation Administration (FAA) Wide Area Augmentation System (WAAS) Program uses this class of receiver in all its ground reference 

station sites. The WAAS receivers generally cost on the order of $40,000 per unit. 

Beyond federal use, State and local governments and their contractors employ tens 

of thousands of high precision and timing receivers on a daily basis for road construction, asset management, and infrastructure monitoring. 

Timing receivers are used nationwide for traffic signal and operations coordination in road and rail, in ground stations for Automatic Dependent SurveillanceBroadcast and the Automatic Identification System, and serve a number of applications at Air Route Traffic Control Centers. 

The retrofit of existing aircraft occurs at points of opportunity as industry cycles 

its respective aircraft through maintenance cycles. The normal upgrade cycle ranges 

from 10 to 20 years. For other transportation applications, it is usually on the order 

of seven to 10 years. For positive train control (PTC) systems, however, the anticipated upgrade cycle will be much closer to the 15- to 20-year range. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use of the ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Is DOT prepared to upgrade or re-equip all their GPS equipment in that time 

frame? 

Q2b. What would be the cost to implement this strategy within your agency? 

Q2c. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? 

A2–2c. No mitigation measures have been identified for LightSquared’s use of the 

upper 10 megahertz (MHz) portion of the band. If mitigation measures are identified, it would then take a minimum of 10 years to re-equip systems, based on an 

assumption of three years to complete standards and product development, followed 

by seven years to complete the retrofit. Based on these considerations, DOT cannot 

upgrade or re-equip GPS equipment in a two- or three-year period. 

The cost for DOT and its stakeholders to implement this strategy is likely over 

$10 billion, based on historical standards and equipment development and certification costs, in addition to the costs to industry of an upgrade/re-equip investment 

cycle. FAA estimates $6 billion in unplanned aviation retrofit costs alone. 
142 

In addition, the lack of mitigation measures would preclude many freight railroads’ and commuter railroads’ deployment of PTC by December 31, 2015, which is 

mandated by section 104 of the Rail Safety Improvement Act of 2008 (RSIA) (49 

U.S.C. 20157). With the exception of the Northeast Corridor, the railroad industry 

is progressing with the implementation of GPS-based PTC systems. The same mitigation-time considerations would be applicable the current GPS-based PTC systems. 

Shifting to non-GPS-based PTC systems, in an attempt to meet the RSIA’s deadline, 

would result in nonrecoverable expenditures for GPS-based PTC systems on the 

order of $3 billion to $4 billion or more as a yet-to-be-determined cost for alternative 

non-GPS-based PTC technology. As the GPS-based technology is cheaper than nonGPS-based technology, the current, roughly 20-to-1 adverse cost-benefit ratio would 

become significantly worse. 

Q3. LightSquared’s modified business plan starts commercial operations with just 

the ‘‘lower’’ portion of its spectrum and will be limited to urban areas. Does this 

satisfy your concerns about short-term interference issues to wideband and high 

precision GPS receivers? If not, why not? 

A3. Initially limiting LightSquared service to urban areas does not satisfy DOT’s 

concerns, as aviation and other transportation safety and timing applications are 

widespread in urban areas. Per the U.S. National Space-Based PNT [Position, Navigation, and Timing] Policy, DOT is responsible for representing the space-based 

PNT interests of partner civilian Federal agencies, as well as our own. 

The impact of LightSquared’s initially operating on the lower 10 MHz will not be 

fully understood until additional testing is conducted. However, limited testing on 

the lower 10 MHz has demonstrated it is incompatible with many existing GPS high 

precision and timing receivers that operate both in urban and rural environments. 

Additional testing of the lower 10 MHz is required to assess the impact to general 

navigation and cellular devices that are prevalent within urban areas. 

Additionally, no testing has been performed on the effects of the LightSquared 

user handsets on GPS receivers. The frequency band proposed by Light Squared for 

these devices is 1620.5–1660.5 MHz. No testing has been performed on the handsets 

due to non-availability of hardware. 

Q4. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different to your agency than their original proposal? 

A4. The new proposal is substantively no different than LightSquared’s original 

proposal, other than it delays implementation of the upper 10 MHz channel, which 

testing has demonstrated to have significant impact on virtually all GPS applications. 

As noted previously, the impact of LightSquared initially operating on the lower 

10 MHz will not be fully understood until additional testing is conducted; however, 

limited testing on the lower 10 MHz has demonstrated it is incompatible with many 

existing GPS high precision and timing receivers. 

Q5. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A5. DOT recognizes that there are other satellite-based terrestrial broadband business plans being proposed. DOT supports the President’s National Broadband Plan 

and welcomes approaches to providing increased wireless broadband services that 

do not impact existing critical infrastructure systems, such as GPS. 

Q6. Does DOT feel that adequate testing has been done on all of the issues associated 

with LightSquared interference on the agency’s missions? Should there be more 

testing on high precision units? 

A6. Testing and analysis to date have clearly demonstrated that LightSquared operations on the upper 10 MHz are incompatible with virtually all GPS applications. 

Limited testing on the lower 10 MHz has demonstrated that the proposed 

LightSquared signal emissions are incompatible with many existing GPS high-precision and timing receivers. 

Additional testing of the lower 10 MHz is required to assess any impact to general 

navigation and cellular devices, as well as for high precision and timing receivers 

once the LightSquared-proposed filters and antennas for these devices are available. 
143 

Q7. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If not, why not? 

If so, what testing has been done to demonstrate their effectiveness? Who should 

pay for this testing? 

A7. The proposed filter offered by LightSquared and a GPS receiver manufacturer, 

JAVAD, is designed to address LightSquared emissions only in the lower 10 MHz. 

It does not resolve the interference problem with LightSquared’s potential use of 

both the lower and upper 10 MHz channels. There is no known filter solution that 

could mitigate the degradation caused by an upper 10 MHz channel LightSquared 

signal emission. 

To our knowledge, no tests have been performed regarding the filter’s ability to 

reject the LightSquared signal while still maintaining GPS receiver capability. 

LightSquared has stated that the filter for the high-precision and timing devices 

will be available for Federal Government testing in November 2011 and March 

2012, respectively. 

LightSquared has offered to pay for testing, but it is not clear that the Federal 

Government can legally accept this offer. DOT has no position on who should pay 

for this testing. DOT continues to pursue ways to participate in the testing within 

existing resources, as DOT could not have anticipated this unexpected expense and 

made the appropriate budgetary request. 

Q8. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A8. There are currently no known mitigation strategies that make sense for wideband or high precision GPS receivers. Mitigation measures have not been identified 

for LightSquared’s use of the upper 10 MHz portion of the band. LightSquared and 

JAVAD have proposed a filter designed to address LightSquared emissions only in 

the lower 10 MHz. To our knowledge, no tests have been performed regarding the 

filter’s ability to reject the LightSquared signal while still maintaining GPS receiver 

capability. 

Q9. How much would it cost your agency to mitigate the interference issues from the 

LightSquared signal on your missions? 

Q9a. Does your agency currently have funds set aside for this purpose? 

A9–9a. There are currently no known mitigation strategies that make sense for 

wideband or high precision GPS receivers. Mitigation measures have not been identified for LightSquared’s use of the upper 10 MHz portion of the band. If mitigation 

measures are identified, it would take a minimum of 10 years to re-equip systems, 

as previously stated. 

As previously stated, the cost for DOT and its stakeholders to implement this 

strategy is likely over $10 billion. FAA estimates $6 billion in unplanned aviation 

retrofit costs alone. 

DOT does not have any funds identified to mitigate interference issues from the 

LightSquared signal for our mission, and it is not clear that the issues could be 

mitigated at any cost. 

Q10. Since August 15, the FCC has had the ability to rule on the LightSquared proposal, and to my knowledge, NTIA has yet to submit comments to the FCC on 

behalf of affected agencies. 

Q10a. Has NTIA provided your comments to the FCC? 

Q10b. Will DOT submit its comments directly to the FCC if NTIA fails to do so? If 

so, when? 

Q10c. Would you agree that your agency’s assessment should be made public so that 

everyone can understand the extent to which LightSquared interference to 

GPS will impact the ability of your agency to perform its duties, and the costs 

that may be incurred due to this interference? 

A10–10c. To our knowledge, the National Telecommunications and Information Administration (NTIA) has not formally provided DOT’s July 21, 2011, comments on 

LightSquared’s proposal to the Federal Communications Commission (FCC). DOT 

does not plan to submit its comments directly to the FCC. DOT supports NTIA’s 

role as the principal Executive Branch adviser on telecommunications policies. 

DOT looks forward to participating in the upcoming test of the lower 10 MHz on 

general navigation and cellular devices and then testing precision and timing receivers early next year. We anticipate that NTIA will provide the outcome of those tests 

to the FCC. 
144 

Q11. The DOT letter to the NTIA provides many details on the impact on the Next 

Generation Air Transportation System (NextGen) from the latest LightSquared 

proposal. Estimates range from 10 years to design and certify modified equipment in the civil aviation fleet, delayed deployment of NextGen by 10 years, 

and additional costs of billions of dollars. 

Q11a. How is DOT planning to pay for these delays and the necessary mitigation 

implementation? 

A11–11a. Current technology does not provide a mitigation capability for certified 

aircraft avionics without severe performance degradation. If a compatible GPS 

equipment mitigation were identified and determined acceptable, the FAA estimates 

that the cost impact to modify all aircraft would be $6 billion. The necessary avionics modification costs would normally be an airlines and aircraft operators’ expense. Additionally, approximately $17 billion in NextGen investments would need 

to be replanned including civil aviation industry estimated investments of $9 billion 

and $8 billion in FAA infrastructure investments. The FAA would require additional 

obligation authority to address cost growth as a result of replanning and procurement, integration, and logistics support for U.S. National Airspace System (NAS) 

GPS timing and high-precision infrastructure equipment. 

Q12. Your testimony mentions a possible mitigation technique where NextGen would 

rely on the navigation signals of the Russian GLONASS System instead of 

GPS. To what extent will the NextGen program rely on the Russian GLONASS 

system if the FAA is forced to proceed with this mitigation strategy? 

A12. The FAA would not find it acceptable to base the U.S. National Airspace System, as a key element of U.S. critical infrastructure, solely on the use of a foreign 

global navigation satellite system (GNSS). FAA NextGen infrastructure is currently 

based upon the use of GPS and the Wide Area Augmentation System (WAAS). The 

2010 National Space Policy states ‘‘Foreign positioning, navigation, and timing 

(PNT) services may be used to augment and strengthen the resiliency of GPS.’’ 

When the Russian Federation achieves full GLONASS operational status and provides GLONASS performance standard commitments to the international community that are consistent with International Civil Aviation Organization (ICAO) 

standards and recommended practices, the FAA and GPS manufacturers could assess the cost effectiveness of developing GPS/GLONASS equipment that might provide acceptable function in the presence of LightSquared’s proposed upper 10 MHz 

channel emissions. However, GLONASS-capable receivers, which operate on frequencies further away from the proposed LightSquared base station frequencies, 

would also need to be assessed for potential interference from LightSquared user 

handsets that transmit at GLONASS frequencies. 

It should be noted that the FAA has worked with other elements of the U.S. government to encourage interoperability of other governments’ GNSS with GPS. Most 

foreign GNSS providers plan to transmit an interoperable wideband L1 signal that 

is compatible with the modernized GPS L1C signal. These new wideband GNSS signals are expected to have greater susceptibility to the effects of LightSquared interference. 

Q13. DOT estimates that aircraft retrofit costs will be $6 billion and take six to 10 

years to fully deploy. What are the costs associated with the loss of productivity 

or environmental impacts from the delays to the NextGen system? 

A13. The FAA estimated that if LightSquared were to use the upper 10 MHz channel starting in 2014, the loss of productivity and environmental impacts over a 10- 

year retrofit/replanning period would result in an estimated impact to aviation community of at least $2 billion in baselined GPS aviation efficiency benefits. In addition, it would severely impact the NextGen program, with a loss of $59 billion in 

estimated benefits and an associated 31 million tons of additional carbon dioxide 

emissions savings. 

Q14. What is the impact on safety if the GPS signal is unavailable or degraded because of interference from the LightSquared network signal? 

A14. DOT provided the results of an operational, economic, and public safety impact assessment of the original LightSquared Concept of Operations (upper and 

lower 10 MHz channels) in a letter to NTIA on July 21, 2011, which is posted on 

the Committee’s website. DOT supports the statement made by FCC Chairman 

Genachowski during an August 9, 2011, press conference on LightSquared, ‘‘We’re 

not going to do anything that creates problems for GPS safety and service as we 

explore technical solutions that will both protect GPS and allow a new service to 

launch.’’ 
145 

Q15. DOT has stated that use of the LightSquared ‘‘upper’’ portion of its spectrum, 

the portion closest to the GPS signal, is unacceptable at any power level. However, LightSquared’s newly proposed plan still relies on the utilization of the 

upper spectrum in the 2013–14 time frame. How long would it take the Department to implement mitigation measures and re-equip its systems to be compatible with this time frame? 

A15. As previously stated, no mitigation measures have been identified for 

LightSquared’s use of the upper 10 MHz portion of the band, and if mitigation 

measures are identified, re-equipping systems would take at least 10 years. 

Q16. Your testimony states that approximately 60,000 civil aircraft would need to be 

retro-fitted with new GPS equipment to mitigate the impacts of the interference 

from the LightSquared signal. How much would it cost the FAA and the airlines to retro-fit those aircraft? 

A16. A mitigating technology has not been developed and may not be feasible. The 

FAA estimate was based on an assumed replacement of existing GPS avionics 

equipment. The FAA estimated that aircraft equipment retrofits would cost the airlines and aircraft operators $6 billion to retrofit, if LightSquared deployed using 

both the upper and lower 10 MHz channels. 

Q17. LightSquared has stated that their new approach will solve ‘‘99.5 percent’’ of 

the interference problems for GPS. Do you agree with that assumption? Can 

you explain how LightSquared has quantified this claim? 

A17. DOT does not agree with that assumption based upon an understanding of 

current technology. No one knows exactly how many GPS receivers are in use today. 

Moreover, none of the testing groups—the Technical Working Group, RTCA, Inc. or 

the National Space-Based PNT Engineering Forum—performed comprehensive testing of just the lower 10 MHz option. More testing is needed to determine which 

users would be affected. 

DOT has no insight into how LightSquared quantified this estimate. 

Questions submitted by Acting Ranking Member Mr. Costello 

Q1. Your prepared statement indicates that FAA has initiated an Alternative Positioning, Navigation, and Timing research program to identify technologies that 

meet the requirements of NextGen in the event that GPS is disrupted. What is 

the nature of the research program, when was it initiated, and what has been 

accomplished so far? 

A1. The Alternate Positioning Navigation and Timing (APNT) research program is 

tasked to assess various architectures to provide position, navigation, and timing 

(PNT) services, as a backup to GPS for the U.S. National Airspace System (NAS) 

in the 2025 time frame. This program was initiated in 2009, with a goal of identifying a more cost-effective backup for temporary GPS disruptions (e.g., testing or 

interference). The APNT program is not intended to replicate the full performance 

and economic efficiencies provided by GPS and the Wide Area Augmentation System 

(WAAS). APNT studies and public meetings are being conducted to scope the requirements for, and technical trade-offs of, a cost-effective GPS backup for the NAS. 

Q2. How is the safety of General Aviation impacted by the potential loss of GPS capability? Has FAA documented any decrease in fatalities in General Aviation as 

a direct result of the use of GPS? 

A2. The safety benefits associated with General Aviation (GA) use of GPS have 

been significant. The earliest hard evidence of the benefits from such equipment 

came from the CAPSTONE program in Alaska and its demonstration of GPS navigation, moving maps and Automatic Dependent Surveillance-Broadcast (ADS-B). 

Based on a before-and-after comparison of accidents in Alaska from FY 2002 

through FY 2005 (before the surge in glass cockpits as standard equipment in the 

GA fleet improved visibility), a detailed study by FAA and Mitre found that CAPSTONE alone would reduce fatal accidents in Alaska by one-third. 

Nationally, in the past five years fatal Controlled Flight Into Terrain (CFIT) accidents in GA and Part 135 (commuter and on-demand) operations have decreased 44 

percent from the preceding five years, while fatal approach-and-landing accidents 

and all fatal accidents at night have decreased by 30 percent. GPS and glass cockpits together are a primary explanation for these improvements, and these rapid improvements will likely continue for several more years as GPS-based equipment continues to penetrate the GA market. The actual decrease in fatalities from CFIT, approach-and-landing, and nighttime accidents has averaged 76.6 per year over the 
146 

past five years versus the preceding five years. Part of this decrease can be attributed to the fact that GA and on-demand Part 135 hours flown are down an average 

of about 6.2% annually in the past five years versus the preceding five years, so one 

would expect at least some decline in various types of accidents. However, if one 

were to adjust the annual average to account for this reduction in volume, there remains an annual average observed reduction of about 73 fatalities per year that 

FAA believes is attributable directly to GPS. 

With the loss of GPS, those benefits already achieved would be immediately reversed, and the opportunity for even more long-term benefits would be lost. Unlike 

air carriers, GA losses would not be offset by air traffic control and Instrument 

Landing Systems (ILS) because the GA fleet would either not be equipped with ILS 

or may not be under air traffic control. 

Q3. Assuming filters can be developed, what is involved in certifying new electronics 

incorporating such filters and retrofitting the aircraft fleet? What is the basis for 

FAA’s projected time frame of 10 years to perform retrofits? 

A3. It is technically questionable if filters can be developed that would mitigate 

the negative effects of GPS on aviation users and still provide the required performance, and comply with the size and environment constraints required to install them 

on aircraft. Assuming such a technical breakthrough is possible, it typically takes 

several years to develop a revised technical standard that is agreed to by the industry. The development of an approved product takes several more years, as a specific 

design is updated to ensure reliable performance under the stressing conditions of 

an aircraft and to ensure there are no failure conditions that adversely affect safety. 

Once the equipment is available, it can take years to retrofit all aircraft. The retrofit of existing aircraft occurs at points of opportunity as industry cycles its respective aircraft through maintenance cycles, in order to reduce the costs of the retrofit. 

The current level of GPS equipage has been achieved after 17 years of equipment 

availability, and has been motivated by the benefits that GPS delivers. There are 

a number of factors which can reduce this time, including mandates or cost-sharing 

or reimbursement (e.g., if LightSquared or another entity paid for the retrofit). An 

estimate of ten years assumes an effective mandate and is based on an assumption 

of three years to complete standards and product development, followed by seven 

years to complete the retrofit. 

Q4. In describing the impact of the proposed LightSquared network on its operations 

to NTIA, FAA stated that LightSquared’s proposal ‘‘could adversely affect U.S. 

international leadership in aviation.’’ Could you expand on this statement by 

identifying areas in which U.S. leadership would be affected? 

A4. GPS is used globally for aviation, and has spurred development of similar systems by the European Union, Russia, Japan, India, and China. Due to the market 

dominance and excellent record of service of GPS, the U.S. has maintained an international leadership position, to protect GPS reception from interference, to promote 

signal compatibility, and to promote acceptance of GPS for aviation in countries that 

do not have their own infrastructure. Recognizing that the protection of GPS from 

interference has been a significant component of the U.S. position, a decision to approve any system that causes widespread interference would jeopardize our credibility and damage our leadership position in aviation use of GPS. 
147 

Responses by Dr. David Applegate, 

Associate Director, Natural Hazards, U.S. Geological Survey 

Questions Submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

Q1a. How much do they cost? 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at 

your agency? 

A1–1b. Wideband high precision GPS receivers are fairly commonplace. The Department of the Interior owns over 6,000. They are used for a variety of applications 

from surveying and mapping to earthquake and volcano monitoring. The testing 

conducted to date shows that high precision GPS receivers are susceptible to interference from the lower portion of the spectrum proposed for use by Lightsquared. 

These receivers come in a variety of makes and models and their prices vary from 

about $5,000 to as much as $30,000. The typical upgrade cycle for this type of equipment ranges from eight to 15 years. 

For example, the U.S. Geological Survey’s (USGS) Earthquake Hazards Program 

is in the process of upgrading high precision GPS receivers that monitor crustal deformation in earthquake-prone southern California. Of the 102 high precision receivers operated by the USGS in that region, 38 are 15 years old, 35 are less than 10 

years old but are now obsolete and no longer manufactured, and 29 are the new 

modern receivers. The USGS is in the process of upgrading all 38 of the oldest receivers, and most of the 35 older receivers. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use of the ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Is USGS prepared to upgrade or re-equip all their GPS equipment in that time 

frame? 

Q2b. What would be the cost to implement this strategy within your agency? 

Q2c. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? 

A2–2c. There are no known mitigation strategies that have been shown to be effective, particularly for the upper portion of the LightSquared spectrum. So it seems 

very unlikely that effective mitigation can be accomplished for the upper portion of 

the spectrum in two to three years. It would be equally difficult for the USGS to 

re-equip all of our GPS equipment even if mitigation for the upper portion were realized. For instance, the USGS has replaced 38 receivers in one year as part of the 

modernization effort by the USGS Earthquake Hazards Program. The USGS upgrades were delayed because of technical problems that are now resolved but which 

added months to the modernization process, which is expected to be completed later 

this year. This small number of receivers took over a year to be replaced, and the 

process is still not complete. 

It is difficult to estimate the cost of replacing GPS equipment in a two–three year 

time frame. However, based upon the 2010 DOI GPS Survey, the USGS estimates 

$20–40 million has been invested for current USGS GPS hardware and software. 

If we include labor and training cost, the USGS believes a GPS replacement strategy would double the estimated cost resulting in expenditures between $40–80 million. It does not seem reasonable for federal agencies to re-equip in this short time 

frame even if we had the resources to do so. 

Q3. LightSquared’s modified business plan starts commercial operations with just 

the ‘‘lower’’ portion of its spectrum and will be limited to urban areas. Does this 

satisfy your concerns about short-term interference issues to wideband and high 

precision GPS receivers? If not, why not? 

A3. No, LightSquared has acknowledged, and the testing showed, operations in the 

lower portion of their spectrum cause harmful interference to high precision GPS 

receivers. No known techniques have yet been shown to mitigate this harmful interference. The USGS has a range of applications in urban areas using high precision 

GPS receivers. For example, the USGS and its partners operate a network of high 
148 

precision GPS receivers for monitoring earthquakes in urban areas of Alaska, California, Nevada, Utah and Washington states. In addition, of the 9,000 nationwide 

USGS watergages, many are located in or near urban areas and may also be impacted because they use GPS timing receivers for data transmissions. 

Q4. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different to your agency than their original proposal? 

A4. LightSquared‘s new plan is different in that it starts with the lower portion 

of the spectrum. Testing on this lower portion of the spectrum has been limited so 

further testing on this lower portion of the spectrum is needed to better understand 

whether LightSquared’s signal causes harmful interference for GPS. 

The higher portion of the spectrum is clearly problematic for the foreseeable future. The use of LightSquared’s transmissions in the higher portion of their proposed spectrum is already known to cause harmful interference to GPS. 

Q5. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A5. GPS is a critical technology for the USGS. If different spectrum can be found 

located further from the GPS band for broadband signals, such a move would solve 

the harmful interference concerns. 

Q6. Does USGS feel that adequate testing has been done on all of the issues associated with LightSquared interference on their agency’s missions? Should there be 

more testing on high precision units? 

A6. The USGS believes that additional testing of the lower portion of 

LightSquared’s spectrum is needed. This new approach by LightSquared was not 

tested nor was it part of LightSquared’s original plan. High precision receivers were 

particularly impacted in the limited testing that has been done on LightSquared’s 

lower portion of the spectrum. The USGS believes that additional testing of high 

precision receivers is needed particularly to evaluate whether mitigation techniques 

to eliminate harmful interference are feasible without impacting performance. 

Q7. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If not, why not? 

If so, what testing has been done to demonstrate their effectiveness? Who should 

pay for this testing? 

A7. USGS has examined the filtering techniques that are proposed by JAVAD 

GNSS. USGS believes this is a serious effort that holds some promise of mitigating 

the harmful interference effects of the lower portion of LightSquared’s spectrum. It 

should be noted, however, that this filtering technique does not mitigate the higher 

portion of LightSquared’s spectrum, nor was it designed to. As of Oct 7, 2011, no 

equipment or filters have been manufactured by JAVAD GNSS. Once this equipment is available, it will need thorough testing and evaluation to see if it does effectively mitigate the harmful interference without impacting the performance of high 

precision receivers. 

Plans for testing are under consideration, and the USGS believes that government-led testing is appropriate to obtain unbiased results and analysis. The cost of 

the testing, however, would not be insignificant and is not included the FY 2012 

Budget. 

Q8. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A8. No known mitigation techniques have been shown to work for harmful interference from LightSquared’s signals. High precision receivers that employ a wide 

bandwidth are particularly susceptible to this harmful interference. Alternative 

spectrum has been recommended by the Space-Based Positioning, Navigation, and 

Timing Advisory Board. 

Q9. How much would it cost your agency to mitigate the interference issues from the 

LightSquared signal on your missions? 

Q9a. Does your agency currently have funds set aside for this purpose? 
149 

A9–9a. No known mitigation techniques have been shown to work for harmful interference from LightSquared’s signals. It is not clear what the cost of mitigation 

would be. The USGS estimates the replacement cost of current GPS equipment to 

be about $40–80 million. The USGS does not have funds set aside to mitigate harmful interference from LightSquared’s signals, nor are those costs included in the FY 

2012 Budget. 

Q10. Since August 15, the FCC has had the ability to rule on the LightSquared proposal, and to my knowledge, NTIA has yet to submit comments to the FCC on 

behalf of affected agencies. 

Q10a. Has NTIA provided your comments to the FCC? 

Q10b. Will USGS submit its comments directly to the FCC if NTIA fails to do so? 

If so, when? 

Q10c. Would you agree that your agency’s assessment should be made public so that 

everyone can understand the extent to which LightSquared interference to 

GPS will impact the ability of your agency to perform its duties, and the costs 

that may be incurred due to this interference? 

A10–10c. The USGS is unaware of what specific actions NTIA has taken with the 

information that has been provided by the Department of the Interior. The USGS 

will continue to work within the Department to convey additional comments as appropriate. These comments contain core deliberative communications from Executive 

Branch agencies that provide critical advice to NTIA in its role as spectrum manager on behalf of the Federal Government. Agency comments have not yet been released to the public in keeping with this deliberative process. 

Q11. The Department of Interior letter to the NTIA states that impacts to natural 

disaster response, law enforcement, and seismic and volcanic monitoring will 

be caused by the LightSquared network. The Department estimates the costs to 

mitigate the problems associated with those areas range from $250M to $500M. 

Q11a. Do these costs stay the same if LightSquared is allowed to begin commercial 

operations utilizing the ‘‘lower’’ portion of its spectrum? 

Q11b. Does this level of additional funding currently exist in the Department’s budget? In other words, would the Department need additional funding to carry 

out its mitigation strategy or are there sufficient funds available? 

Q11c. What sort of hard choices would need to be made to offset that spending? Are 

there modernization plans or capabilities that would be put on hold to deal 

with the interference issues? 

A11–11c. The Department of the Interior estimated the replacement costs of the 

existing GPS infrastructure within the Department. The Department, including the 

USGS, does not know what the cost to mitigate LightSquared’s signals will be because it has not yet been shown they can be mitigated. Without additional testing, 

including demonstration of mitigation techniques, it will be difficult to know what 

mitigation actions will be effective, the impact on performance, and what their cost 

might be. 

Whatever the cost, the USGS has not planned for any funding to pay for receiverbased mitigations. 

Any decision about how to implement a receiver-based mitigation strategy over a 

short period of time would pose a significant challenge. It is likely our services that 

rely on GPS would be impacted. As we learn more about mitigation techniques and 

implementation decisions, the USGS will be able to refine its approach to mitigation. 

At present, the USGS is continuing to implement GPS equipment modernization. 

For example, the USGS is planning on installing 60 modern high precision GPS receivers in the next year to enhance its earthquake monitoring capabilities. 

Q12. The Department of Interior letter to the NTIA states that the Department has 

approximately $100M to $200M invested in GPS technology. Of particular note, 

the letter states that The Department spent almost $2M last year on state-ofthe-art GPS equipment for its Earthquake and Volcano Hazards Programs. If 

LightSquared is allowed to begin commercial operations, would that new expensive equipment essentially become obsolete? 

A12. No, the equipment would still be state-of-the-art, but it would be susceptible 

to interference from LightSquared’s signals. The equipment would work fine in 

areas far enough away from LightSquared base station transmissions. For example, 
150 

the equipment could be used for post-disaster missions in foreign countries, where 

Lightsquared is not operating. 

Q13. This summer the country battled forest fires in Texas, flooding in the northeast, and recently experienced a rare earthquake here in the Washington area. 

How would our understanding of these events be impacted by the LightSquared 

network? 

A13. Our understanding of the potential impact of the LightSquared network is 

based on an understanding of our current activities and those of other bureaus in 

the Department of the Interior. The LightSquared signals would make it more difficult to fight fires, and to collect earthquake, flood, and volcano data, because of 

the harmful interference to GPS. In short, it would set back USGS mission activities, and our understanding of these events would be more limited, compromising 

situational awareness for emergency response. 
151 

Responses by Mr. Jeffrey J. Carlisle, 

Executive Vice President, Regulatory Affairs 

and Public Policy, LightSquared 

Questions Submitted by Chairman Ralph Hall 

Q1. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 

proposal to start with just the lower portion, how is the new proposal really any 

different than the original proposal? 

A1. Our new proposal is entirely different from our old business plan and is a significant concession to the use of our spectrum by GPS manufacturers. Importantly, 

it eliminates the need for replacing hundreds of millions of GPS devices used by consumers and the aviation industry. 

We respectfully disagree with the premise of the question. Eventually, 

LightSquared will need to add additional capacity to its network, assuming retailers 

using the network bring enough subscribers to require such capacity. We do not expect to need such capacity for five to six years at least. When needed, this additional 

capacity could be added by bringing the upper portion of our spectrum online. However, it could also be met by (1) adding more towers in the lower part of our spectrum, (2) using the upper portion in ways that are substantially different from the 

old plan (lower power, etc.), and (3) using alternative spectrum. Moreover, it must 

be borne in mind that our customers are retailers who can reasonably be expected 

to have alternatives in the marketplace by the time we would need to add more capacity. 

Accordingly, our intent is exactly what we proposed to the FCC: to move forward 

with deployment on the lower portion of the spectrum, while setting aside the upper 

portion in order to allow a further discussion of how safe deployment of that spectrum could be achieved within a commercially reasonable time frame. The above alternatives must be explored in an objective way, but there is no need for that process to delay the deployment of an urgently needed network on the lower portion of 

spectrum. 

Implementing this proposal will cost the company $100 million. This is a significant cost to LightSquared, particularly in light of the fact that the interference problem at issue is caused by GPS receivers looking into the spectrum licensed to 

LightSquared. This proposal, however, allows us to move forward with a network 

deployment while removing the need for anyone to replace cellular, personal navigation, timing or aviation devices. 

Q2. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A2. LightSquared’s proposals eliminate the need to replace all but a small portion 

of precision GPS devices. As discussed in further detail below, GPS manufacturers 

are already stepping forward with solutions for the remaining number of precision 

devices—estimated to number about 750,000 devices total but those requiring replacement or retrofit are likely to be far fewer. Thus, it is not accurate to say that 

development of our spectrum puts the taxpayer investment in GPS at risk in any 

way. Taxpayers will continue to have access to a robust GPS system and also have 

the substantial benefits of a competitive nationwide wireless broadband network. 

With respect to alternatives, while all alternatives should be pursued, the U.S. 

cannot afford to turn its back on a privately funded network that will bring significant amounts of spectrum to market and invest $14 billion in the U.S. economy. 

Even though there are initiatives underway to make more spectrum available, it 

will be some number of years before any of this spectrum will actually be made 

available to consumers. The National Broadband Plan identified 300 MHz of spectrum that should be made available for mobile broadband within five years, and 500 

MHz within 10 years. LightSquared’s spectrum is included in that 300 MHz, along 

with all other spectrum that could reasonably made available. Yet more than a year 

and a half after release of the Plan, only the LightSquared spectrum is on the verge 

of deployment. None of the other spectrum identified has any clear timetable for deployment. 

• The 700 MHz ‘‘D Block’’ has not been auctioned as planned and may be needed 

for the national public safety broadband network. 
152 

• Little progress has been made in preparing the ‘‘AWS’’ spectrum for auction, in 

part because of the difficulty of reallocating government spectrum, which required relocating government users. 

• The companies that held the MSS S-band spectrum in 2009 have been through 

bankruptcy and the buyers of that spectrum are awaiting approval from the 

FCC. 

• Although the WCS spectrum has been licensed, none of the owners have announced any plans to deploy it. 

• The FCC does not have authority to reclaim and auction television broadcast 

spectrum, as the National Broadband Plan proposed. Even if Congress grants 

authority, it appears that perhaps 60 to 84 MHz of broadcast spectrum could 

be made available at most, rather than the 120 MHz originally planned. Auction of that spectrum is many years away. 

Moreover, deployment of much of this spectrum will be delayed by the inevitable 

presence of existing users and nearby operators who deploy inefficient receivers (like 

GPS manufacturers). In the meantime, Americans will continue to live and work at 

a significant disadvantage to other countries—the U.S. is currently 15th in the 

world in terms of broadband adoption. Additional spectrum and competitive networks are desperately needed to address this situation, and LightSquared could 

start providing service next year. 

Finally, it is important to understand that this is not the first technology GPS 

has threatened and it will not be the last. GPS receivers are, in some cases, so poorly designed that they can be sensitive to transmissions many tens of megahertz to 

either side of the frequencies actually authorized for GPS. The only spectrum suitable for mobile wireless broadband network is at frequencies of 3 GHz or less, and 

GPS sits square in the middle of that range at 1.6 GHz. The threat to taxpayers 

thus comes from the insistence of a few GPS manufacturers on selling inefficient 

receivers that have the effect of blocking needed services in other bands. Our network is threatened by this inefficiency, and proposed future spectrum is close 

enough to GPS to conceivably raise interference issues. Given that the interference 

problem can be solved, it should be, as otherwise GPS manufacturers will continue 

to delay or even stop beneficial technologies from reaching the public. 

Q3. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? If so, what testing has been done to demonstrate their effectiveness? Who should pay for this 

testing? 

A3. The new Javad device eliminates potential overload interference to wideband 

and high precision GPS devices, and shows that all manufacturers can quickly and 

inexpensively deploy such solutions. The Javad solution was accomplished simply by 

upgrading the components and signal processing in an existing product. Prior to 

this, many in the GPS industry had claimed that it was impossible to design a high 

precision GPS receiver that could operate in this environment. Javad is expected to 

have units ready for testing as early as November 14, 2011. These can be tested 

by the government by the terms prescribed by NTIA in its letter of September 9 

to PNT ExCom. Alternatively, LightSquared has also engaged an independent laboratory for testing if necessary. To be clear, LightSquared is happy to pay for any 

testing necessary to validate this or any other solutions. 

Q4. In your testimony you state that LightSquared’s ‘‘ground network will provide 

over 260 million people with wireless broadband service.’’ Can you meet that 

goal by only utilizing the lower portion of your spectrum, as you recently proposed? 

Q4a. Have no other companies proposed developing spectrum for 4G Broadband? 

A4–4a. Yes. We can meet the FCC coverage requirement of reaching 260 million 

people by the end of 2015 utilizing the lower portion of our spectrum. As discussed 

in response to question 1, above, adding the upper portion is one way of addressing 

the eventual need for capacity assuming subscribers (and data usage) increases, but 

not the only way. 

As of this date, the only companies that have proposed deploying nationwide 4G 

networks are AT&T, Verizon Wireless, Clearwire, and Sprint (building out both 

their own and our spectrum). There are no other nationwide networks currently proposed. Moreover, as mentioned in response to question 2, there are no alternatives 

for spectrum that could be deployed for the next several years. The United States, 

then, cannot afford a ‘‘not in my back yard’’ approach to spectrum. There are no 

‘‘clear’’ portions of spectrum proposed to be brought online in the foreseeable fu-
153 

ture—there will always be transition costs given that spectrum is extremely crowded and will remain so. Accordingly, it is crucial that the U.S. resolve all spectrum 

issues—such as the current one—in ways that (1) promote coexistence and (2) prevent inefficient users of spectrum from blocking infrastructure investment. 

Q5. The media has reported that LightSquared believes its move to the lower part 

of the Mobile Satellite Service band resolves GPS interference problems for 

99.5% of receivers. Can you explain to us how you arrived at that 99.5% number? Is your analysis of that data consistent with industry standards for analyzing interference? 

A5. These numbers were derived based on the testing that was conducted by the 

members of the GPS community and LightSquared as part of the Technical Working 

Group. LightSquared estimates that there are over 400 million GPS units currently 

in use in the United States. Of these, approximately 300 million reside within cellular phones, 100 million reside in general location/navigation (GLN) devices, 500 

thousand in high precision devices and another 500 thousand used in timing and 

aviation devices. 

Representative samples of all classes of devices were tested by the TWG and 

LightSquared’s assessment of the efficacy of its mitigation plan is based entirely on 

the results attained in the TWG testing, and for aviation devices on the results of 

an analysis of existing minimum performance standards and testing of some aviation devices. 

Cellular 

Every cellular device tested by the TWG showed no degradation of operation according to established industry and regulatory standards. Thus, LightSquared was 

able to conclude that none of the 300 million cell phones in use would be impacted 

by its operation on the lower 10 MHz channel. 

General Location/Navigation (GLN) 

The results of the testing of the GLN devices also showed that they would be unaffected by LightSquared’s operation on the Lower 10 MHz channel. There was initially disagreement between GPS manufacturers and LightSquared on the appropriate interference threshold and on propagation models to predict LightSquared’s 

on-the-ground signal strength. The LightSquared commitment to initially limit its 

measured power to a power level of –30 dBm eliminates any basis for disagreement. 

Even though TWG testing showed that there were two outlier devices that did experience a slight rise in the noise floor at this signal strength, there was no indication 

whatsoever that this would impact the normal performance of the devices tested. 

Thus the TWG results confirm that none of the 100 million GLN devices would be 

impacted by LightSquared’s proposed operating parameters. 

Timing 

Timing devices showed similar results, with all but one tested showing no impact 

from LightSquared’s proposed operation even using the GPS industry’s very conservative interference criteria. The confidentiality requirements imposed by the 

TWG prevent LightSquared from disclosing specific information about the one 

outlier device, but LightSquared believes this device to be in very limited use and 

has already identified mitigation options which it can address directly with the 

manufacturer and users of the device in question. 

Aviation 

The limited number of aviation devices tested by the TWG showed complete resilience to LightSquared’s lower 10 MHz operation. However the FAA and aviation industry have previously indicated that the preferred approach for determining potential impact to aviation uses of GPS is through an analysis of LightSquared’s operating parameters in the context of existing minimum performance standards for 

GPS devices used in Aviation. The TWG report concluded that additional study was 

needed to determine whether LightSquared’s proposed operations were compatible 

with existing aviation standards. That work is ongoing and LightSquared is optimistic that it will be able to reach a mutually acceptable conclusion with the FAA 

on the analytical parameters and ultimate determination. 
154 

High Precision 

The sole area that the TWG report identified that was not automatically solved 

by LightSquared’s proposed mitigation plan is for high precision GPS units. A significant percentage of these devices showed in tests that they could operate with no 

perceptible interference from LightSquared’s operation on its Lower 10 MHz. There 

are an estimated 500,000 high precision GPS devices in use, with some estimates 

as high as 1 million devices. Even using the upper bound of 1 million high precision 

GPS devices and assuming all the devices would be adversely affected, 

LightSquared’s mitigation proposal would resolve interference for 400 million devices, which yields a measure of 99.75%. 

Q6. We have seen in the public comments filed at the FCC a discussion about possible interference from, not only the LightSquared grid network, but also the 

LightSquared handsets. It is my understanding that no handsets were available 

to be tested. When will LightSquared make their handsets available so they can 

be tested? Do you think it is a major oversight that no handsets are available? 

There could potentially be hundreds of thousands or millions of LightSquared 

handsets in circulation—should this issue be tested now before they are on the 

market? 

A6. The unavailability of LightSquared handsets in no way limited the TWG in its 

testing protocol. First, it should be noted that the test procedures for most of the 

sub-teams simulated LightSquared’s base station signal, even though actual base 

stations were available to the TWG. This is normal practice as the design of the 

anechoic chamber test environment often makes it impractical to utilize production 

equipment. Additionally, using signal generators tuned to the exact parameters of 

the expected transmission produce more reliable test results by allowing the setting 

of very precise parameters and varying such parameters according to the test methodology. This type of flexibility is often not afforded when production devices are 

used. It is for this reason that most sub-teams chose to simulate base station signals. 

The sub-team that tested high precision devices in fact used a simulated signal 

in order to test the potential impact of user devices operating in proximity to high 

precision receivers. This sub-team, which included representatives from Trimble and 

John Deere, among others, did not raise any issues with the simulation of user device transmissions, nor would one expect them to do so as this is consistent with 

quality testing practices. Other sub-teams could have employed a similar test setup, 

but chose not to perform tests including LightSquared simulated user devices. 

The recent letter from NTIA to PNT ExCom does call for testing to include configurations simulating a LightSquared user device. LightSquared is confident that, 

as was done in the TWG, this signal can be accurately generated in the laboratory 

environment. 

Q7. LightSquared has argued that the GPS industry has been developing defective 

equipment because it produced receivers that ‘‘look’’ into LightSquared’s spectrum. When did you become aware that high-precision GPS receivers used part 

of LightSquared’s spectrum? Has LightSquared ever been compensated for the 

use of this spectrum? If so, how much? If so, when did it first receive compensation? Did any of LightSquared’s predecessor company’s ever receive compensation for the use of their spectrum? If so, when, and how much? 

A7. High precision GPS devices, which as we note above represent a small fraction 

of the total GPS devices in use, are generally designed to receive two signals: (1) 

the signal from GPS satellites and (2) an ‘‘augmentation’’ signal. The devices listen 

to the GPS signal across the widest possible bandwidth in order to increase their 

accuracy and use the augmentation signal to provide additional information to boost 

accuracy even further. The augmentation signal can come from a number of sources, 

such as a satellite signal in a number of different spectrum bands, including the 

L-band (LightSquared’s spectrum) or a terrestrial network. 

Many high precision receivers were designed by GPS manufacturers without the 

filtering needed to prevent their listening to the far ends of the GPS signal all the 

way into the LightSquared spectrum. LightSquared did not learn of this design decision until late 2010 when GPS manufacturers first raised it with LightSquared. 

LightSquared and its corporate predecessors have never received compensation for 

this use of its spectrum—such as a royalty paid by the GPS manufacturers—by GPS 

devices. With respect to high-precision GPS devices that receive an augmentation 

signal from an L-band satellite, LightSquared was aware of such receivers from the 
155 

1 We have also been aware that Inmarsat provides a similar augmentation signal to GPS 

manufacturers. 2 Since 1997, LightSquared (and its predecessors) have sold satellite capacity to a company 

called, Omnistar, which resold that capacity to supply augmentation services to GPS manufacturers, including Trimble Navigation Limited. Omnistar was purchased by Trimble in March 

2011. We understand that the GPS manufacturers charge a significant mark up on their subscriptions to end users for augmentation signals. For instance, we understand that a typical annual subscription can range from $800 to several thousands of dollars a year. 3 As one GPS manufacturer conceded to the FCC, ‘‘[a]ll GPS receivers use filters that overlap 

in the MSS band.’’ http://www.saveourgps.org/pdf/fcc/Deere¥Co¥Ex¥Parte.pdf 4That same GPS manufacturer noted that ‘‘[out of band emissions] is not a problem in the 

GPS band if LightSquared filters their signals as they have committed.’’ http:// 

www.saveourgps.org/pdf/fcc/Deere¥Co¥Ex¥Parte.pdf 

time that it first began providing this service to resellers that offer this service. 1

LightSquared’s predecessors began offering this service in 1997, and the annual revenue has been approximately $500,000. 2

In this respect, it is important to note that LightSquared has received nothing 

from any of the high precision manufacturers that use other L-band augmentation 

services, and it has received nothing from manufacturers of GPS devices that look 

into the upper portion of our spectrum and do not rely on our satellite signal for 

augmentation. Effectively, these manufacturers use LightSquared’s licensed spectrum for free, and are trying to establish a continuing right to do so. 

LightSquared has never dictated or been aware of the design choices made by 

manufacturers of high precision GPS devices, including those that use an L-band 

augmentation signal. Despite ample notice, the GPS manufacturers have had more 

than sufficient time to make appropriate design decisions to ensure that their devices were compatible with LightSquared’s planned network. LightSquared continues to believe that such devices can be designed to be compatible with its terrestrial network. 

The results of the Technical Working Group confirm that the GPS ‘‘interference’’ 

issue is caused by the design choices made by GPS device manufacturers. 3 The 

TWG confirmed that this incompatibility is not caused by LightSquared’s emissions 

‘‘bleeding’’ into the GPS spectrum—it is solely a matter of GPS receiver design. In 

2002 and 2003, LightSquared and the GPS industry reached agreement to limit 

strictly such emissions—known as ‘‘out of band emissions’’—to ensure that 

LightSquared’s network did not interfere with GPS devices. 4 The GPS industry 

raised other concerns along the way, including as late as 2009, all of which 

LightSquared resolved. The GPS industry never raised any concerns about ‘‘overload’’ at any of those times. 

Apparently, GPS manufacturers designed high precision GPS devices to use a single, open front-end (which consists of antennas, amplifiers, and filters) to receive 

both GPS and augmentation signals. The GPS manufacturers could have designed 

their high precision GPS devices to separate the GPS signal from the satellite augmentation to avoid the overload issue. As one commentator has noted, ‘‘the common 

analog front end amplifies the [LightSquared] allocation when it should be filtered, 

a very bad design indeed and one that blatantly violates design guidelines issued 

by the DoD’s 2008 Global Positioning System Standard Positioning Service Performance Standard.’’ http://www.itif.org/publications/itif-comments-lightsquaredgpstesting. 

As we discuss in response to Representative Neugebauer’s first question, the GPS 

industry has been on notice as a result of the FCC proceedings and decisions since 

2003 that LightSquared intended to build an integrated terrestrial and satellite network. In addition, OmniSTAR’s customers, including presumably Trimble, should 

have known since 2008 that their operations would have to change to accommodate 

changes in the service that LightSquared was providing to Omnistar. For example, 

in February 2008, OmniSTAR was told by LightSquared that after 2011, 

‘‘OmniSTAR must have converted its network to MSV’s next-generation service . . . 

moved to another operator, or shut down its network.’’ 

In short, the GPS manufacturers made deliberate design decisions that created 

the potential for overload by LightSquared’s network terrestrial network. Since 

2003, the GPS manufacturers were on notice that they needed to review their design decisions to ensure that they were compatible with LightSquared’s network. In 

addition, with respect to those GPS manufacturers that purchased an augmentation 

signal from LightSquared, they received further notice since 2008 about 

LightSquared’s transition to an integrated terrestrial and satellite network. 

Q8. Agencies that use high precision GPS have indicated that the use of the upper 

band of LightSquared’s spectrum will never be able to be used without inter-
156 

fering with high precision GPS. Will LightSquared commit to never using that 

upper band of spectrum that is closest to the GPS signal? 

A8. Please see our answers to questions 1 and 4. We take the concerns expressed 

by federal agencies seriously. They must be taken into account as we engage in the 

discussion of whether the upper portion of our spectrum could be safely deployed 

in a commercially reasonable time frame. 

Please note, however, that regardless of use of the upper portion of the spectrum 

for a ground network, the upper portion of this spectrum can continue to be used 

for satellite services, which have been provided for 15 years without any interference with GPS receivers. 

Q9. When will you submit filters for high-precision GPS for testing? Who will conduct this testing? How long will it take? Will federal agencies be able to conduct 

their own independent testing, similar to the TWG and the NPEF, prior to 

LightSquared operations? 

A9. On its own initiative, LightSquared has recently completed a request for information (RFI) process that requested filter suppliers to deliver filters meeting the 

specifications defined by the GPS industry. In less than 30 days from issuing the 

RFI, LightSquared began receiving shipments of filters and testing on these filters 

can begin immediately. LightSquared intends to conduct its own testing of these filters using respected, independent laboratories. These filters are also available for 

testing according to the terms outlined by NTIA in its September 9, 2011, letter to 

the PNT ExCom. 

Questions Submitted by Ranking Member Eddie Bernice Johnson 

Q1. What can Congress do to protect the future value of spectrum and ensure user 

receivers do not bleed into spectrum not assigned to them? What are the challenges associated with establishing receiver standards to preclude devices from 

picking up unintended spectrum? 

A1. Spectrum will become much more intensively used in the next few years as 

more and more Americans use smartphones—which use 24 to 25 times the data as 

cellphones—and businesses begin to take advantage of the capabilities of new wireless infrastructure. But there is no spectrum available that does not already have 

existing users. Accordingly, new networks and existing users will have to find ways 

of coexisting, as otherwise the U.S. will never be able to bring sufficient spectrum 

to meet increasing demand. The losers in that scenario will not be the companies 

arguing over spectrum—it will inevitably be the American consumer, who will pay 

more for worse service. 

Coexistence should be a question of technology and economics: how do you fix it 

and who pays? These are questions that can normally be solved by agreement of 

new networks and existing users, and we strongly believe that should continue to 

be the model. 

The current issue, however, shows what happens when a powerful entrenched industry decides that it would rather take the chance that it cannot be stopped from 

deploying inefficient technology. We believe that this issue can be solved, and are 

more confident in this belief with each passing week as more manufacturers announce solutions. However, to the extent some continue to try to hold out, there are 

three things Congress should do: 

• Instead of taking sides, Congress should encourage parties to work these issues 

out as success means benefits to all Americans from new uses of spectrum while 

retaining and strengthening old uses. 

• The current regulatory regime—Part 15—makes clear that devices that look 

outside their authorized bands are not entitled to interference protection. Indeed, I have attached hereto an excerpt from a Garmin GPS receiver manual 

that provides standard language to this effect. Accordingly, the FCC today has 

the tools in its hands to allow networks to move forward, simply by allowing 

them to do so and thus making clear that device manufacturers have to innovate and adapt. Congress should encourage FCC to stand by this rule and its 

own longstanding precedent. 

• Finally, in order to avoid future situations where the current tools may prove 

insufficient, Congress should explicitly authorize the FCC to apply receiver 

standards that would protect authorized adjacent band operations. Many countries apply receiver standards today, and if limited to these specific issues, the 
157 

effect of such requirements would be to maximize efficient use of spectrum 

while minimizing regulatory burden. 

Q2. LightSquared claims that its service has been beneficial to federal, state, and 

local governments and first responders in times of national emergencies as it 

provides an interoperable network for first responders to utilize when cell phone 

service is not an option. Can you elaborate on the services provided by 

LightSquared to our first responders? Does this service require use of your mobile satellite assets? In what way is the terrestrial network used? 

A2. LightSquared and its predecessor companies have a long history of providing 

satellite-based communication services to federal, tribal, state, and local governments on a continuing basis and during times of emergencies. The company currently has hundreds of federal, tribal, and state and local government accounts representing thousands of end users and offers a broad variety of satellite services including telephony voice, two-way radio, push-to-track and mobile data. 

LightSquared also offers Satellite Mutual Aid Radio Talkgroups (‘‘SMART’’) nationwide and regionally that enable critical and interoperable communications among 

homeland security officials, law enforcement, emergency responders, and public 

safety officials from various departments and agencies across the United States. 

LightSquared’s satellite-based communication services have facilitated critical emergency communications among nationwide and local first responders during disasters 

such as Hurricane Katrina, Hurricane Ike, Hurricane Irene, the Kentucky ice 

storms in 2009, the California wild fires and the earthquake in Haiti—for U.S.- 

based first responders operating in Haiti following that disaster. 

While LightSquared’s current network is satellite based, such a network involves 

some terrestrial equipment such as earth stations to receive and transmit signals. 

When a satellite-initiated telephone call is connected to an Earth-based, traditional 

cellular or wireline telephone, the call also transits another carrier’s terrestrial network. 

Q3. Former lawmakers, now lobbyists for LightSquared, recently wrote an Op-Ed 

claiming that tests indicate LightSquared’s new wireless service would not cause 

any interference for 99.95 percent of all GPS users. 

Q3a. What is the basis for the 99.95 percentage figure? 

Q3b. Are there tests and analysis to support this claim? 

Q3c. Were these tests conducted using federal agency equipment and observed by federal agency personnel? 

A3–3c. Please see our answer to Chairman Hall’s question number 5, above, for 

the basis for our 99.5% figure, which in the worst case is actually 99.75%. 

To our knowledge, LightSquared has never claimed that our proposal would protect 99.95% of all receivers. If you have an example of such a claim, however, we 

would be happy to review it and provide a response. 

The Technical Working Group (TWG) tests included the participation of representatives from the Department of Defense, the Federal Aviation Administration and 

NASA. These participants had full access to all of the deliberations of the TWG, test 

methodologies, and testing data. Testing was performed on commercial receivers, 

some of which are used by federal agencies. Information regarding the types of facilities and resources utilized is as follows: 

• Testing for the Cellular and General Location/Navigation categories were performed by engineers at independent laboratories, with all costs paid for by 

LightSquared. 

• Testing for the High Precision, Networks and Timing categories occurred at the 

US Navy’s NAVAIR facility, for which LightSquared paid the facility’s standard 

commercial rate; testing of these devices was performed by employees of the 

manufacturers of the devices tested. 

• Testing for the Space-Based device category was conducted at the Jet Propulsion Laboratory by NASA and JPL employees. 

• Testing of aviation devices was performed at Zeta Associates, Inc. (ZAI) by ZAI 

employees, under the terms of a then-existing contract with the FAA. 

• Additionally, the U.S. Air Force, Space Command conducted testing of certain 

classified and unclassified special purpose receivers, though this testing was not 

part of the work undertaken by the TWG. 
158 

Q4. How long would LightSquared operate its network using only the lower portion 

of the spectrum allocated to it by the FCC? If FCC granted you permission to 

build out a broadband system in your lower 10 MHz portion of the spectrum 

band, would you expect to need to go back to the FCC for approval to expand 

your build out into your upper 10 MHz portion of the band—those that sit next 

to GPS? 

A4. As stated in response to Chairman Hall’s question number 1, above, we expect 

to be able to operate our network on the lower portion of the spectrum for at least 

five to six years. Under our current proposals, we would want to have a further discussion of how safe deployment of the upper portion of the spectrum could be 

achieved within a commercially reasonable time frame. In any event, however, we 

would not be able to deploy that spectrum unless we were specifically authorized 

by the FCC, which would consult with NTIA, the Department of Defense, and other 

government agencies before taking any action. 

Questions Submitted by Rep. Randy Neugebauer 

Q1. LightSquared continuously makes claims that the GPS community knew this 

was coming, but I would venture to say it is the other way around. The FCC 

has always firmly opposed a ground-based network in this spectrum band (and 

the FCC’s allowance of an ancillary terrestrial network does not indicate willingness to allow a plan like LightSquared’s), and LightSquared’s attempts are 

clearly against the grain. Since years and years of explicit FCC precedent has 

reserved the spectrum band in question for only ancillary terrestrial use because 

of the obvious impacts on GPS technology, why did LightSquared invest so 

much money in this plan to severely expand a ground-based system in the first 

place? Why did your company not look for other spectrum that would not impact 

GPS systems at all? 

A1. LightSquared’s plan—to build an integrated satellite and terrestrial broadband 

network in its spectrum—is fully consistent with FCC precedents and has been fully 

authorized by the FCC since 2003. The FCC, under both the current and prior Administrations, has confirmed this view. As recently, as April 6, 2011, the FCC noted 

that ‘‘[i]n the case of GPS, we note that extensive terrestrial operations have been 

anticipated in the L-band for at least 8 years (emphasis added).’’ http:// 

fjallfoss.fcc.gov/edocs¥public/attachmatch/FCC-11-57A1.pdf. 

In addition, in October 2008, the FCC further stated that: 

[T]he integration of an ATC into MSS systems would have several benefits, including the filling of gaps in MSS coverage, increasing MSS network capacity, and 

the development of new and innovative service offerings that satellite-only MSS systems cannot offer, including, e.g., ubiquitous digital telecommunications and 

broadband services and other services that take advantage of the unique coverage 

and capacity characteristics of ATC-enabled MSS (emphasis added). 

http://licensing.fcc.gov/myibfs/download.do?attachment¥key=678085 

LightSquared (and its corporate predecessors) worked for almost a decade with 

the GPS industry to ensure that its plans for a terrestrial broadband network could 

co-exist with GPS devices. The kind of interference that GPS manufacturers now 

complain of—overload interference—should have been just as much of a concern 

then as it is now, but the GPS manufacturers failed to raise the overload issue until 

late 2010. The only exception is Deere, which raised the issue briefly in 2001 and 

then without explanation failed to raise it again until late 2010. Under the circumstances, LightSquared had every reason to believe that GPS manufacturers 

were designing their devices so that their only concern was LightSquared emissions 

into the GPS band (the ‘‘out-of-band emission’’ or ‘‘OOBE’’ issue), and not overload. 

• In 2002, LightSquared and the GPS industry submitted a voluntary agreement 

under which LightSquared would limit its emissions to avoid interference with 

GPS devices. When it submitted that agreement, the GPS industry stated that 

‘‘[LightSquared’s] proposed terrestrial augmentations are also well known.’’ 

http://fjallfoss.fcc.gov/ecfs/document/view?id=6513283601 

• In 2003, the GPS industry trade association requested that the FCC approve 

this voluntary agreement because these limits ‘‘to protect GPS represent a ‘winwin’ for [LightSquared], for the Commission’s reliance on OOBE to limit interference, and for GPS safety of life and public safety use.’’ http:// 

fjallfoss.fcc.gov/ecfs/document/view?id=6515082621 

• In July 2009, the GPS industry raised concerns about possible interference with 

GPS devices, but, as the FCC itself recently noted, ‘‘[o]ne month later . . . the 
159 

[GPS industry association] filed a joint letter with LightSquared agreeing that 

the GPS interference issues had been resolved (emphasis in original).’’ http:// 

fjallfoss.fcc.gov/ecfs/document/view?id=7021686751 

Not only has the GPS industry fully participated in all regulatory proceedings, 

known about potential interference issues, and worked with LightSquared to resolve 

those issues—it actually applauded LightSquared’s efforts and urged the FCC to approve its application to build an integrated satellite and terrestrial broadband network. In a March 24, 2004, letter from the GPS trade association to the FCC, which 

is worth quoting in full, they stated: 

The U.S. GPS Industry Council (‘‘the Council’’) . . . urges the Commission to grant 

the above-referenced applications of [LightSquared] and to do so as soon as possible. 

[T]he Council and [LightSquared] worked diligently to develop out-of-band emission 

(‘‘OOBE’’) limits from MSV ancillary terrestrial component (‘‘ATC’’) base stations 

and terminals into the GPS band, which are intended to protect GPS receivers and 

at the same time allow [LightSquared] to maximize the utility of its ATC service to 

its users. 

[LightSquared] proposes to operate at OOBE levels that are even more stringent 

than those set out in its agreement with the Council. We believe that [LightSquared] 

is to be commended for its proposal to use its spectrum in a responsible manner that 

ensures the continued utility of GPS receivers operating in the vicinity of 

[LightSquared] ATC stations. The major issues raised in its application have been 

before the Commission and fully briefed since at least mid 2003 and, in many cases, 

for far longer. Thus, the Commission’s granting [LightSquared’s] applications expeditiously would validate [LightSquared’s] adherence to best commercial practices and 

advance the public and national interests in promoting the responsible use of spectrum (emphasis added). http://licensing.fcc.gov/myibfs/ 

download.do?attachment¥key=366878 

We note that some in the GPS industry have recently attempted to deny this extensive regulatory record and their own words in asserting that ‘‘FCC rules also did 

not allow the terrestrial-only broadband services LightSquared now wants to provide.’’ http://www.amerisurv.com/ 

index.php?option=comlcontent&task=view&id=9208&Itemid=2. This is simply revisionist history for the following reasons: 

• The GPS industry told the FCC in 2003 that it knew of the extent of 

LightSquared’s plans. In a filing to the FCC in 2003, the GPS industry noted 

that LightSquared’s network would have ‘‘increased user density from potentially millions of MSS mobile terminals operating in ATC mode in the 1626.5- 

1660.5 MHz bands will transmit back to potentially tens of thousands of ATC 

wireless base stations in the 1525-1559 MHz bands . . . (emphasis added).’’ 

http://fjallfoss.fcc.gov/ecfs/document/view?id=6515082621. 

• The GPS industry warned its own investors as early as 2001 about possible interference issues. For example, in 2001, Trimble Navigation Limited, 

in its Form 10–K stated that: ‘‘[E]missions from mobile satellite service and 

other equipment operating in adjacent frequency bands or inband may materially and adversely affect the utility and reliability of our products, which could 

result in a material adverse effect on our operating result.’’ http:// 

files.shareholder.com/downloads/TRMB/1422870148x0x34031/919048BF-0668- 

4353-97B5-7EFDF7718E64/2001¥10K.pdf. 

• The undisputed regulatory record shows that, as early as 2003, 

LightSquared was intending to build, and the FCC had approved, an 

extensive integrated satellite and terrestrial broadband network. This 

chart summarizes the regulatory history of the number of base stations and the 

power levels that those base stations that LightSquared was authorized to operate: 
160 

6 These FCC’s conclusions completely rebut Dr. Scott Pace’s written testimony at the Committee’s hearing that LightSquared was only authorized to build a ‘‘fill in’’ terrestrial network for 

gaps in satellite coverage. http://science.house.gov/sites/republicans.science.house.gov/files/documents/hearings/0908011¥Pace.pdf. Dr. Pace also grossly errs in his recitation of the regulatory history, stating that LightSquared was limited to the construction of only 1725 base stations in 2003 and 2145 base stations in 2004. This is plainly and demonstratively wrong, as 

explained in the footnote above. 

• Contrary to the suggestions of the GPS industry, the FCC’s rules do not 

require that satellite service be the ‘‘predominant’’ or ‘‘primary’’ use of 

LightSquared’s licensed L-band spectrum. Indeed, such a requirement—as 

well as other restrictions, such as limiting base stations to areas without satellite coverage and requiring user devices to first look to the satellite before connecting to the terrestrial network—was explicitly rejected by the FCC in 2003 

and 2005 as spectrally inefficient, unnecessarily costly, and operationally inefficient. 6

• The GPS industry’s argument—that the January 2011 conditional waiver of the integrated services rule represented a fundamental change in 

LightSquared’s network—is wrong. As the chart above illustrates, it has 

been well-known for nearly eight years that LightSquared had the authority to 

build an integrated satellite and terrestrial network consisting of over 10,000 

base stations at power levels that are as high as or exceed LightSquared’s current plans. As the FCC itself noted recently, ‘‘[t]he [conditional waiver of the 

FCC integrated services rule] was not the trigger to permit LightSquared access 

to the spectrum in the band adjacent to GPS. LightSquared’s predecessors have 

had access to this L-Band satellite spectrum since 1995 and have been authorized to provide terrestrial service since 2004. (emphasis added).’’ http:// 

fjallfoss.fcc.gov/ecfs/document/view?id=7021686751 

• The GPS industry has never offered that LightSquared could begin to 

operate under its pre-January 2011 authorizations. If the January 2011 

conditional waiver represented a fundamental change in LightSquared’s network, as the GPS industry argues, they should be comfortable in allowing 

LightSquared to deploy its network under its earlier authorizations. They have 

never offered that compromise because they know that the technical characteristics approved by the FCC from 2003 to 2005 and blessed by the GPS industry 

are the same as the network that LightSquared intends to deploy today. 

In summary, LightSquared chose to invest $14 billion in private capital to build 

an integrated satellite and terrestrial network in its own spectrum because: 
161 

• Over the course of eight years, it had the undisputed legal and regulatory authorization to build its integrated satellite and terrestrial network. Those FCC 

authorizations occurred in 2003, 2004, 2005, and 2010. 

• Over that same period, it worked extensively with the GPS industry to resolve 

any interference issues. The GPS industry itself has characterized that cooperation as a ‘‘win-win,’’ ‘‘intended to protect GPS receivers and at the same time 

allow [LightSquared] to maximize the utility of its ATC services to its users,’’′′ 

and in ‘‘the public and national interests in promoting the responsible use of 

spectrum.’’ 

• LightSquared does not need to find new spectrum farther away from GPS receivers because it has the legal right to build and operate an integrated satellite 

and terrestrial network in its own spectrum. While LightSquared is fully committed to finding technical solutions to co-exist with the GPS industry, as a 

legal matter, it has no obligation to move from its spectrum to accommodate 

GPS devices that were intentionally designed to look into LightSquared’s spectrum. 

Q2. LightSquared has claimed that your new plan resolves interference problems for 

99.5 percent of GPS receivers. I have not seen this claim substantiated. Could 

you please provide evidence for this claim? Also, have you estimated the economic impacts of the supposedly small percentage of receivers that will be affected by your current plan? It seems to me, from the testimonies of the experts 

at the hearing and from various studies, that the most economically valuable 

and critically important GPS users will be the ones still affected by 

LightSquared’s use of the lower half of the spectrum. 

A2. With regard to the first part of the question, substantiation of the 99.5% figure, please see our answers to Chairman Hall’s question number 5 and Ranking 

Member Johnson’s question number 3, above. 

With regard to the second part of the question regarding economic impact on precision receivers, LightSquared’s position is that there should be no economic impact 

on any users, as manufacturers should be responsible for providing their users devices that can operate consistent with rules the FCC issued years ago, which as discussed above in response top Chairman Hall’s question number 3, has been shown 

to be completely feasible with a minimal investment of time and resources. As explained in response to your question 1, above, the public record clearly shows that 

LightSquared’s planned use of its network was anticipated for years. GPS manufacturers, however, have repeatedly tried to focus debate on how LightSquared will impact GPS users in order to distract policymakers and the public from the real question of their own responsibility for replacing or retrofitting devices. 

It is important to note in this respect that while use of precision devices is important, the hundreds of millions of devices LightSquared’s proposals address contribute significantly to the economy. Hundreds of millions of smartphones and personal navigation devices—used by consumers but also used by business, government 

and public safety—will not need to be replaced. Devices used in aviation—the economic importance of which is clear—will not need to be replaced. And timing devices—used in wireless and other critical networks that contribute tens of billions 

of dollars of value every year to the U.S. economy—will not need to be replaced. 

This is the result of an investment by LightSquared of over $100 million to solve 

the problem for these devices, thus absolving the GPS manufacturers if responsibility to do so. 

What is left is something less than the estimated 500,000–1,000,000 precision devices used largely in agriculture, surveying and construction. There will be no impact from our deployment for a significant number of these devices for three reasons: 

• Testing has demonstrated that, even using the most restrictive definitions of 

harmful interference proposed by the GPS manufacturers, 10 out of 38 precision 

devices—26%—did not suffer harmful interference. 

• Assuming LightSquared is operating in the spectrum farthest from GPS, harmful interference for the remaining devices would be limited to a relatively close 

distance from our base station, meaning that many precision receivers used in 

remote areas and for agriculture will never be close enough to our network to 

suffer any effect. 

• Our network will be deployed over five years, meaning that some portion of devices would have been traded out for new devices in the ordinary course of business. 
162 

7 LightSquared News Release, October 13, 2011, LightSquared Shows Filtering Technology: 

‘‘In addition to receivers developed by Javad GNSS, several other high-tech companies have also 

created LightSquared compatible components that can be integrated into receivers. For example, 

PCTEL has developed LightSquared compatible chip sets, and Partron America has created a 

filtering component that only costs $6.’’ http://www.lightsquared.com/press-room/press-releases/lightsquared-shows-filtering-technology/ 

After accounting for these factors, what is left is a portion of the total number 

of devices, which could be as few as 100,000–200,000, but under any set of reasonable assumptions will not be as many as 1 million. 

For these devices, we have recently demonstrated, together with our partners, 

Javad and Partron America, that filters for precision receivers could be developed 

within days and would cost as little as $6. 7 This proves three concepts: that the 

interference issue can be solved; that it can be solved quickly; and that it can be 

solved inexpensively. 

In this respect it is important to compare this with a recent recall of GPS devices 

by Garmin. Issued in August, 2010, Garmin recalled 1.2 million devices because of 

battery issues. This is one manufacturer. The present situation involves only a portion of this number, spread out over a GPS industry that is manifestly capable of 

bearing the cost. Not only do GPS manufacturers enjoy the use of government spectrum for free, but they are well funded, with John Deere alone carrying over $3 billion in cash, Garmin over $1.5 billion, and Trimble over $250 million. 

Given the limited scope of the remaining receivers—the receivers not already protected by the investment LightSquared is making—there is simply no reasonable argument as to why this cannot be solved. LightSquared will invest $14 billion of private funds in the American economy, support 15,000 jobs a year for each year of 

our build out, and create an unprecedented integrated network that will allow dozens of retail competitors to offer broadband across the U.S. The economic cost of 

solving this last portion of devices should not stand in the way of bringing this investment at a time when jobs, infrastructure, and innovation are sorely needed in 

the U.S. economy. 

If we fail to solve it because certain GPS manufacturers are allowed to continue 

to avoid responsibility for addressing the issue, the economic consequences to the 

country will be extremely damaging. Companies and investors will have serious 

doubts about the ability of the U.S. government to bring more spectrum to market. 

They will also doubt the government’s willingness to enforce longstanding license 

rights in spectrum. The combined effect will push the value of spectrum down, and 

therefore reduce significantly the receipts the Federal Government can expect from 

the auction of licensed spectrum. Investors will direct investment to countries where 

spectrum rights are enforced, and where operators can expect to be able to deploy 

networks as authorized. The United States has long drawn private investment in 

wireless telecommunications because it has stood by these principles, and must continue to do so. 
163 
164 

Responses by Dr. Scott Pace, 

Director, Space Policy Institute, 

George Washington University 

Questions Submitted by Chairman Ralph Hall 

Q1. How common are the wideband and high precision GPS receivers that are at 

risk of interference from LightSquared’s modified business plan that starts commercial operations with just the ‘‘lower’’ portion of its spectrum? 

Q1a. How much do they cost? 

Q1b. What is the normal upgrade or re-equipage cycle for these GPS receivers at federal departments and agencies? 

A1–1b. Wideband and high precision GPS receivers are not as common as mobile 

phones, but they are standard equipment in multiple sectors of the global economy, 

from machine control, survey, mapping, and construction, to precision agriculture 

and timing/network synchronization. More than 100,000 receivers for high precision 

applications are sold in North America each year. Prices for high precision receivers can range from $1,000 to in excess of $100,000 but currently average between $9,000 and $13,000 (NDP Consulting 2011). Typical 

re-equipage times can average around 15 years. Software upgrades occur on faster 

cycles but proposed mitigations to the effects of LightSquared emissions have typically been to change external antennas or modify the receiver front ends. These are 

not software fixes. Federal agencies may hold on to equipment for longer periods 

of time and, as with commercial users, employing older receivers as base stations 

while using more current equipment in mobile applications. 

Q2. LightSquared has agreed to a ‘‘standstill’’ on the use of the ‘‘upper’’ portion of 

their spectrum, the portion closest to the GPS signal. LightSquared has stated 

they would like to work with the GPS community to develop mitigation strategies in order to initiate commercial operations of the upper spectrum within two 

to three years. 

Q2a. Is two to three years a reasonable time frame to expect federal agencies to upgrade or re-equip? What would be the costs? 

A2–2a. Two to three years is not a reasonable time frame. When major changes 

were made to GPS in the past, such as turning Selective Availability to zero or 

transitioning semi-codeless users to a second coded civil signal, transition times of 

a decade or more were used. The potential interference from LightSquared is more 

disruptive and technically difficult to mitigate. 

It is not yet clear that use of the lower band by LightSquared is technically possible without unacceptable harm to GPS high precision and other users (e.g., specialized receivers used in spaceflight). The upper band is even more problematic and 

the consensus in the GPS community seems to be that use of the upper band should 

be ‘‘off the table.’’ 

Despite press releases, no proposed filters have been made available for independent testing. Even if they function as claimed, filters alone are not sufficient to 

make a regulatory decision. Actual high precision equipment with the proposed filter fully integrated must be tested to assess degradation in receiver performance 

and accuracy. Equipment that is proven able to function in the face of lower band 

interference may or may not be able to provide the same level of performance if 

LightSquared uses both the upper and lower bands. 

It is virtually impossible to provide a cost estimate on upgrading or re-equipping 

the GPS receivers used by federal agencies as key pieces of information are missing: 

(1) is it possible to suppress the effects of LightSquared emissions without significant harm to GPS receiver performance? (2) What are the operational characteristics of the ‘‘new’’ receivers? (e.g., thermal stability, weight, form and fit factors, degree of hardware and software modifications, etc.), and (3) If there is a solution that 

works at the lower band, does it also work at the upper band or would another 

round of changes be required? 

Even assuming technical feasibility, there are applications where upgrades and/ 

or re-equipage are not possible. Examples could include satellite constellations performing radio-occultation science where the receiver lifetimes can be up to 15 years 

and the only ‘mitigation’ possible is to launch new satellites at a cost of hundreds 

of millions of dollars each. 

Q3. Given that LightSquared has clearly shown that it intends to ultimately utilize 

both the upper and the lower portion of its spectrum, even with its new business 
165 

1 47 C.F.R. §25.255. 

proposal to start with just the lower portion, how is the new proposal really any 

different to federal agencies than the original proposal? 

A3. In my opinion, it is merely a change in sequencing and timing of 

LightSquared’s proposed deployment plan and does not represent a fundamental 

technical change. 

Since the upper band is still allowed by the current FCC regulations, the GPS 

community must assume its use in their assessments of LightSquared interference. 

If and when the FCC officially and publicly rules that the upper band will not be 

used for terrestrial transmissions, the GPS community can modify its assessments 

to focus only on the lower band. 

The same is true for the maximum authorized power of LightSquared’s terrestrial 

signals. Current FCC regulations allow maximum power ten times greater than 

LightSquared’s current planned power. Unless the FCC regulations are updated to 

document a new, lower maximum authorized power for LightSquared terrestrial 

transmissions; the assessment of interference to GPS must be based on the higher 

authorized power. 

Q4. I understand there are now other companies exploring a similar terrestrial 

broadband business plan but in an entirely different part of the spectrum that 

would not interfere with the GPS signal. If we can accommodate the President’s 

goals for the Broadband Initiative using spectrum that doesn’t interfere with 

GPS, why should we risk the taxpayer investment in GPS? 

A4. The taxpayer investment in GPS need not and should not be put at risk. The 

MSS satellite part of the LightSquared network is compatible with neighboring GPS 

uses and thus can coexist with all GPS services, applications and existing user 

equipment if it is used solely for space-service links. The terrestrial component of 

the LightSquared network has not yet been built therefore it is at least technically 

feasible to move to a different band from the outset, thus avoiding large scale disruption to GPS users across the United States. Possible locations include the SBand (above 2 GHz) or the 700 MHz bands already allocated to terrestrial 4G wireless services. 

In addition, handsets are an important part of the LightSquared terrestrial network; they are the user terminals that subscribers will use for high-speed 

broadband applications. These user terminals have, for the most part, been overlooked in the immediate debate over LightSquared’s terrestrial base station transmitters. Each of these user terminals is also a radio transmitter, operating in the 

frequency band 1626.5–1660.5 MHz, just above the GPS L1 frequencies. 

LightSquared claims it will have 260 million subscribers by 2015. Each of these subscribers will carry in their hand a potential source of GPS interference. GPS users 

in automobiles, aircraft, or on a city sidewalk could find themselves in close proximity (1 meter or less) to one or more of these LightSquared user terminals. Preliminary testing by the high precision sub-team of the FCC Technical Working Group 

(TWG), published in the 30 June 2011 TWG Final Report, confirmed that 

LightSquared handsets do have the potential to interfere with GPS, and so the final 

assessment of LightSquared’s total interference to GPS must include a careful examination of the effects of emissions from handsets as well as base stations. 

Q5. Will the filters proposed by JAVAD GNSS and LightSquared mitigate the interference problem to wideband and high precision GPS receivers? What testing 

has been done to demonstrate their effectiveness? Who should pay for this testing? 

A5. It is unknown whether the proposed filters will mitigate interference due to 

LightSquared’s terrestrial operations. Some performance charts have been provided 

to the FCC in an ex parte presentation claiming improved protection but no filters 

or prototype high precision receivers are yet available for independent testing. 

Section 25.255 of the FCC’s rules makes the obligation of resolving harmful interference to other services that is caused by MSS ATC operations the sole responsibility of the ATC operator. 1 These regulations, which went into effect on 5 June 

2003, clearly state ‘‘If harmful interference is caused to other services by ancillary 

MSS ATC operations, either from ATC base stations or mobile terminals, the MSS 

ATC operator must resolve any such interference.’’ LightSquared is still nominally 

an ATC operator subject to Section 25.255 and thus I would argue that 

LightSquared should pay for testing of equipment that it claims will mitigate interference it proposes to create. If that equipment proves to be effective at mitigating 

LightSquared interference to GPS, then Section 25.255 would also suggest that 
166 

2 See http://www.dailyfinance.com/2011/10/15/lightsquared-our-lte-network-will-be-betterthan-a/ 

LightSquared is responsible for the cost of manufacturing, delivery, installation, recalibration, recertification, and subsequent maintenance of that mitigation hardware 

for the life of any affected GPS application. This would apply to GPS use by federal 

agencies, state, local, and tribal governments and the private sector. 

Q6. Are there currently any mitigation strategies that make sense for wideband or 

high precision GPS receivers? 

A6. The only assured mitigation strategy I am aware of would be one in which the 

band 1525–1559 MHz remains a satellite services band and terrestrial mobile services are moved to a frequency band distant from GPS signals as I describe in my 

response to Question #4 above. It should be noted, however, that even if 

LightSquared were to vacate the 1525–1559 MHz band completely with their terrestrial transmissions, that LightSquared handset transmissions in the 1626.5–1660.5 

MHz band could still prove to be a major source of interference to GPS. 

Q7. Mr. Carlisle states in his testimony that ‘‘many consumers in rural America 

don’t even have a wireless broadband option: 28 percent of people who live in 

rural America still have no access to broadband.’’ 

Q7a. Will LightSquared’s new proposal roll out a ground network in rural areas? 

Q7b. Will its satellite service be able to reach rural areas? 

Q7c. What is the definition of broadband service? 

Q7d. Will LightSquared’s satellite component be able to meet that broadband definition? 

Q7e. So, in summary: Will LightSquared be able to provide broadband to rural 

areas under its current proposal? 

A7–7e. LightSquared’s proposed rollout plan is still considered proprietary to the 

best of my knowledge. That said, business considerations would likely create an emphasis on serving high-density urban areas first and thus terrestrial tower deployments should be expected in key cities before service is extended to rural areas. The 

satellite service is certainly capable of reaching rural areas, however the satellite 

service does not and will not provide broadband performance. 

The FCC defines broadband as 1 Mbps up and 4 Mbps down (see http:// 

www.fcc.gov/DailylReleases/Daily¥Business/2010/db0720/FCC-10-129A1.pdf) 

and the maximum data rates possible from the LightSquared SkyTerra I satellite 

are 300–400 Kbps (see http://www.pcworld.com/businesscenter/article/210570/ 

lightsquareds¥mobile¥hopes¥to¥rise¥with¥satellite.html). Thus the satellite coverage looks to be voice, text messages, and similar low data rate services but not 

4G LTE broadband. Given the economic pressure to build out terrestrial capacity 

in urban areas first and limitations of the satellites, it is unlikely that rural areas 

will benefit from LightSquared broadband capacity any time soon. 

LightSquared Chief Marketing Officer Frank Boulben confirmed this point in a 

press statement this past week. To quote: ‘‘But Boulben cautioned that 

LightSquared’s satellite service will provide only voice and text coverage and will 

not provide the kind of high-speed data services for users who live near its terrestrial LTE network.’’ 2

Q8. Mr. Carlisle states in his testimony that ‘‘no other company could conceivably 

offer this broad coverage in the same time frame.’’ 

Q8a. Are there any other options, or is LightSquared the ‘‘only game in town’’? 

A8–8a. Broadband can be delivered in many ways (e.g., DSL, cable modem, fiber 

optics, wireless, satellite, etc.) Certainly, LightSquared has (or had) expectations of 

being able to offer broad coverage in short period of time, but this required a variety 

of regulatory, technical, and financial assumptions. I cannot comment on their business viability, but given expressions of interest by other companies in using different MSS spectrum for terrestrial 4G LTE broadband (e.g., DISH Network has applied to use its spectrum for terrestrial broadband services), alternatives exist to the 

LightSquared proposal. 

Q9. Mr. Carlisle states in his testimony that the GPS manufacturers failed to raise 

issues at the FCC when it was developing its rules and could have addressed 

this issue in the design of their receivers years ago. But in fact, some high precision GPS receivers actually use the LightSquared signal. 
167 

3 In the original FCC Order dated February 10, 2003, Paragraph 1: ‘‘We do not intend, nor 

will we permit, the terrestrial component to become a stand-alone service.’’ The gating criteria 

that maintained this prohibition was never waived until January of this year. 

Q9a. Did users know about this issue years ago? 

Q9b. Is it disingenuous for LightSquared to blame GPS manufacturers? 

A9–9b. The GPS community did not know years ago, and could not have predicted, 

that the FCC would effectively seek to reallocate spectrum from space services such 

as the MSS to terrestrial mobile services without a notice of proposed rule-making 

and in contradiction to prior statements that it would maintain the satellite gating 

requirement that prohibited stand-alone terrestrial services as LightSquared has 

proposed. Speculation that the Commission would do so would have rightly been dismissed as unfounded speculation by the FCC. In numerous formal rulemakings, 

FCC indicated they would not allow stand-alone terrestrial services and GPS users 

and manufacturers relied on those assurances. 3

In addition, some high precision receivers use MSS signals in the adjacent spectrum as part of contractually agreed on services from Inmarsat and the Skyterra 

satellite now owned by LightSquared. It would seem unusual to expect GPS manufactures to design equipment providing poorer performance in the expectation that 

existing satellite services would be eliminated by a future regulatory action that the 

Commissions denied it would ever take. 

Q10. What impact would LightSquared’s network have on high precision GPS receivers? 

Q10a. First, how important are high precision receivers today? 

Q10b. Is the trend for higher precision receivers across the board in all industries? 

Q10c. How are these receivers affected by LightSquared’s most recent proposal? 

Q10d. Does LightSquared have a viable solution for the high precision receivers? 

Q10e. What do you see as a solution for these types of receivers? 

A10–10e. High precision GPS receivers are crucial to multiple areas or the economy 

and scientific work. The accuracy and precision of high end GPS receivers are relied 

upon in surveying, mapping, construction, machine control, and agriculture to the 

extent that readily available substitutes do not exist. 

The LightSquared proposal and associated interference does not represent a single 

type of threat. Different applications have different requirements for precision with 

scientific users perhaps being the most demanding. While it is possible to expect 

mobile phones to be unaffected by LightSquared operations that are restricted to the 

lower band, it is not possible to imagine the same for wideband and high precision 

receivers. LightSquared interference would most severely impact scientific work 

supported by federal agencies and economically impact those areas of the economy 

reliant on high precision positioning and timing.There is only one GPS and one set 

of GPS signals that are used in such critical applications. There are multiple means 

for providing broadband communications. The highest levels of GPS precision positioning and timing should not, and need not, be sacrificed for a capability that can 

be supplied in other ways. In my opinion, the solution for high precision receivers 

is to maintain the 1525–1559 MHz band as a dedicated space services band as it 

has been for many decades. 

Questions Submitted by Ranking Member Eddie Bernice Johnson 

Q1. NOAA’s prepared statement says that its engineers are concerned that a filter 

capable of blocking out the powerful LightSquared signal at the lower channel 

may also prevent the receiver from detecting the GPS signal, rendering it useless. 

Q1a. In your opinion, is it technically feasible to design a filter that simultaneously 

allows GPS users to listen to signals in LightSquared’s allocated bandwidth 

and block LightSquared’s signals? 

Q1b. Can you estimate its cost? 

Q1c. What are the challenges associated with certifying such filters for aviation use? 

A1–1c. I don’t believe you can have a commercial filter that can discriminate between wanted and unwanted emissions that are effectively identical. Blocking a sig-
168 

nal in a certain frequency band means blocking all signals unless one is using sophisticated anti-jam/anti-spoofing techniques that would be impractical for non-military users. I could not estimate the cost of such devices. 

Hypothetically assuming a new filter existed, aviation certification would require 

incorporating the filter into an existing aviation receiver or creating a new receiver 

for certification. It is the aviation receiver whose performance has to meet Minimum 

Operational Performance Specifications (MOPS), not just the filter itself. Certifying 

a new type of receiver can take years. 

Q2. What can Congress do to protect the future value of spectrum and ensure user 

receivers do not bleed into spectrum not assigned to them? What are the challenges associated with establishing receiver standards to preclude devices from 

picking up unintended spectrum? 

A2. It would be more accurate to say that transmitters pose a risk of their emissions bleeding over into spectrum not assigned to them. The type of interference 

caused by LightSquared to GPS arises from both the practical design of GPS filters 

and the power of the LightSquared terrestrial signal. It is not accurate to characterize the interference as solely a GPS receiver problem. This is true both technically, and in terms of the FCC regulations 47 CFR 25.255, which states that the 

MSS ATC operator must resolve any interference. The fact is that all GPS receivers 

incorporate filters that are carefully designed and calibrated for the environment in 

which they are expected to operate. 

Receivers incorporate filters to protect against unwanted emissions and in the 

case of GPS receivers operating next to the MSS spectrum, most have filters to prevent interference from the more powerful MSS signals coming from the satellite. In 

some cases, the GPS receivers are even designed to received MSS signals through 

the same antenna and front-end as used for the GPS signals. Unfortunately, no filters have not yet been demonstrated that can protect GPS receivers from the many 

billions of times stronger terrestrial LightSquared signal. 

The ability of real-world hardware filters to reject interference is not infinite. Any 

filter can eventually be overcome by a sufficiently strong interference source. Incidentally, this is why it is critically important for the FCC to formally limit the authorized maximum power of LightSquared ATC transmissions to the lower levels at 

which LightSquared has promised to operate. If FCC regulations allow 

LightSquared to raise their base station power by a factor of 10 in the future, any 

filter mitigation developed and deployed today—even if it is technically feasible— 

could be once again overwhelmed and rendered ineffective if LightSquared increases 

its terrestrial power in the future. 

Industry already develops and uses standards to serve their customers and markets. There are normal market forces that drive receiver performance. The government should not seek to define separate standards except for compelling purposes 

of national security (e.g., military applications) or public safety (e.g. as with aviation 

receivers). The government should certainly not try to establish standards that 

would limit the performance of receivers used in scientific research—whether in 

space or on the Earth. 

On the subject of standards, it is important to clarify claims that ‘‘GPS commercial device manufacturers have ignored government design standards.’’ The standard to which LightSquared refers was published by the Department of Defense in 

2008 and is known as the Standard Positioning Service Performance Standard (SPS 

PS). As its name implies, the SPS PS is a performance standard, not a design standard. The SPS PS defines the level of accuracy and other performance a representative GPS receiver can expect from the GPS system of satellites and ground control 

elements, but it is not in any way a GPS receiver design standard. Section 2.0 of 

the SPS PS clearly states: ‘‘The representative receiver characteristics are used to 

provide a framework for defining the SPS performance standards. They are not intended to impose any minimum requirements on receiver manufacturers or integrators, although they are necessary attributes to achieve the SPS performance described in this document.’’ Therefore, claims that the SPS PS serves as a ‘‘government design standard’’ are incorrect. 

The most effective oversight action the Congress could take is to ensure that the 

FCC follows the Administrative Procedures Act and that changes in the allocation 

of spectrum are done through normal notices of proposed rulemaking based on technical facts openly presented. 

Q3. Your statement provides several ways to move forward, including an option to 

help LightSquared find alternative spectrum for its terrestrial network outside 

the L-band. Is there any precedent for FCC doing such a thing? 
169 

A3. The FCC has provided ‘‘bidding credits’’ in spectrum auctions to certain categories of applicants, such as small businesses or those serving tribal lands. The 

Commission could seek authorization from the Congress to provide assistance to 

LightSquared or other similarly situated MSS ATC operators to secure non-L-band 

spectrum already allocated for terrestrial mobile services if it was determined that 

such assistance was warranted. As a practical matter, the Commission would likely 

be reluctant to undertake the difficult work necessary to make this happen, but it 

is an option if the policy case for broadband was sufficiently compelling. 

Q4. The European Union and the United Nations’ aviation body ICAO have voiced 

concern about the potential disruption to aviation use of GPS caused by the proposed LightSquared network. What agreements do we have in place that we risk 

violating were such disruptions occur? 

A4. Article 11 of the 2004 Agreement between the U.S. and European Union on 

the use of GPS and Galileo states: 

The Parties shall work together to promote adequate frequency allocations for satellite-based navigation and timing signals, to ensure radio frequency compatibility 

in spectrum use between each other’s signals, to make all practicable efforts to protect each other’s signals from interference by the radio frequency emissions of other 

systems, and to promote harmonized use of spectrum on a global basis, notably at 

the ITU. The Parties shall cooperate with respect to identifying sources of interference and taking appropriate follow-on actions.In 2007, the FAA submitted a letter to ICAO that reaffirmed ‘‘the United States Government’s commitment to provide the Global Positioning System (GPS) Standard Positioning Service (SPS) for 

aviation throughout the world. Further, the United States commits to provide the 

Wide-Area Augmentation System (WAAS) service within its prescribed service volume.’’ The letter goes on to say ‘‘The U.S. Government plans to take all necessary 

measures for the foreseeable future to maintain the integrity, reliability and availability of the GPS SPS and WAAS service and expects to provide at least six years’ 

notice prior to any termination of such operations or elimination of such services.’’ 

While not a formal agreement, the 1998 Joint Statement between the United 

States and Japan recognized GPS cooperation between the two countries along with 

the commitment that the two countries would ‘‘help develop effective approaches toward providing adequate radio frequency allocations for GPS and other radionavigation systems.’’ 

(171) 

Appendix 2 

ADDITIONAL MATERIAL FOR THE RECORD
172 

ADDITIONAL MATERIAL FOR THE RECORD

PREPARED STATEMENT OF MR. RANDY NEUGEBAUER

U.S. HOUSE COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY

Mr. Chairman, thank you for holding this full Committee hearing to review the 

effects of the proposed LightSquared broadband network on federal science activities. Multiple studies have indicated that LightSquared’s proposal will cause widespread degradation of virtually every Global Positioning System (GPS) application 

in the United States, and I have significant concerns about its effects in particular 

on federal science activities. I also am concerned that the network will severely 

damage GPS usage for agricultural production in the U.S., which is a major concern 

for my constituents in the 19th District of Texas. 

LightSquared intends to build 40,000 high-powered ground transmission units, 

creating a signal one billion times stronger than GPS signals. This could lead to 

major interference issues since the spectrum to be used is immediately adjacent to 

GPS spectrum. 

The President’s national broadband initiative is admirable, but as with any major 

proposal it is imperative that we consider the consequences. The Administration has 

seemed amicable to LightSquared because it advertises massive expansion of 

broadband technology to millions of Americans if it is allowed to build out its terrestrial network. However, I am worried that the negative impacts of the technology 

will far outweigh the benefits. The scientific problems with the substantial terrestrial usage of this spectrum—for which FCC precedent has only allowed ancillary 

terrestrial usage in the past—have been well documented. As a result LightSquared 

has recently published a modified proposal to use only the lower half of the spectrum initially. Preliminary studies indicate that even this proposal would have severe effects on federal science activities. There is certainly not sufficient evidence 

to support this alternative proposal without further study. 

I look forward to the verbal testimony of the panel before the Committee today. 

Based on current evidence, LightSquared’s proposal could severely inhibit federal 

science activities. I believe that the experts testifying here today will provide valuable insight into the problems this plan could cause. 

Thank you. 
173 

LETTER FROM MEMBERS OF CONGRESS TO HON. JULIUS GENACHOWSKI, 

CHAIRMAN, FEDERAL COMMUNICATIONS COMMISSION, WASHINGTON, DC 
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RESPONSE TO HON. RANDY NEUGEBAUER FROM

HON. JULIUS GENACHOWSKI, 

CHAIRMAN, FEDERAL COMMUNICATIONS COMMISSION, 

WASHINGTON, DC 
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WRITTEN STATEMENT OF THE COALITION TO SAVE OUR GPS 

PRESENTED TO THE HOUSE COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY
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LETTER TO HON. RALPH M. HALL, CHAIRMAN, 

U.S. HOUSE COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY, 

FROM MR. MALCOLM D. JACKSON, ASSISTANT ADMINISTRATOR AND

CHIEF INFORMATION OFFICER, U.S. ENVIRONMENTAL PROTECTION AGENCY
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LETTER TO HON. RALPH M. HALL, CHAIRMAN, 

U.S. HOUSE COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY, 

FROM MR. MICHAEL W. LOCATIS III, CHIEF INFORMATION OFFICER, 

U.S. DEPARTMENT OF ENERGY
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LETTER TO HON. RALPH M. HALL, CHAIRMAN, 

U.S. HOUSE COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY, 

FROM MR. SUBRA SURESH, DIRECTOR, NATIONAL SCIENCE FOUNDATION
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LETTER TO MR. LARRY STRICKLING, 

ASSISTANT SECRETARY OF COMMERCE, 

U.S. DEPARTMENT OF COMMERCE, FROM NASA 
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FEDERAL AVIATION ADMINISTRATION: 

LIGHTSQUARED IMPACT TO AVIATION: FAA PERSPECTIVE: 

POWERPOINT PRESENTATION TO U.S. HOUSE COMMITTEE ON

SCIENCE, SPACE, AND TECHNOLOGY
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LETTER TO MR. KARL B. NEBBIA, ASSOCIATE ADMINISTRATOR, 

NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION, 

FROM MR. JOEL SZABAT, DEPUTY ASSISTANT SECRETARY FOR

TRANSPORTATION POLICY, U.S. DEPARTMENT OF TRANSPORTATION
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MEMORANDUM FOR MR. KARL NEBBIA, ASSOCIATE ADMINISTRATOR, 

NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION, 

FROM DEANNA ARCHULETA, SENIOR ADVISOR TO THE SECRETARY, 

DEPARTMENT OF THE INTERIOR
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Æ