Says Based On Facts, Wireless Company's Alternative Plans Lacks Credibility

In a document released last Friday, The Coalition To Save Our GPS presented a review of wireless company LightSquared's proposal to allow it to continue to establish a nationwide wireless broadband service. The group used as its primary source a 1,000-plus page report issued on June 30, 2011 by the FCC-mandated Technical Working Group which analyzes interference from LightSquared's proposed deployment plans in the Mobile Satellite Service (MSS) band adjacent to the Global Positioning System (GPS).

The report was based on LightSquared's February 2011, description of its planned three phases for deployment: Phase 0, Phase 1 and Phase 2. All three phases identified by LightSquared for study used a portion of the MSS band directly adjacent to GPS, 1545.2-1555.2 MHz (the "Upper MSS band"). The working group test results showed that use of this portion of the MSS band caused overwhelming interference to every category of the 500 million GPS receivers in use in the United States, from those used by airplanes, police vehicles and ambulances to everyday consumer cell phones and personal navigational devices.

Up to the point of the June 30 report filing, LightSquared had repeatedly said that its proposed operations would not interfere with GPS. Faced with the report's overwhelming evidence of massive interference – and no doubt in order to preempt these highly negative results -- LightSquared simultaneously released a 37-page "Recommendation" document (RD) that it developed totally outside of the Technical Working Group established to collaboratively study the problem.

In that document, the coalition says, LightSquared proposed an entirely new deployment scenario, not included in the initial scope of the working group analysis, which would not use the Upper MSS band at all, and a series of mitigation measures – many of which were never disclosed or discussed during the four-month working group study process. Further, the document tries to blame the "commercial GPS industry" for any interference caused by its operations, and also claims, without citation to the working group study or any other supporting data, that its proposal will solve interference for 99 percent of GPS receivers.

The coalition asserts that the utter failure of LightSquared's initial deployment plans to pass interference tests raises fundamental questions about the representations LightSquared made to the FCC prior to its January 2011 decision that convinced the FCC to grant the waiver and convene the interference study process in the first place, and raises significant questions about the credibility of LightSquared's various claims and whether they hold up to scrutiny. The current strong indication is that whatever LightSquared told the FCC prior to January 2011 was highly inaccurate, to a degree that verges on negligence. These questions logically follow from the failure of the original deployment plan: Was LightSquared transparent in its dealings with the FCC? In other words, what did LightSquared know, and when did it know it? 

In all of its documents and public statements, LightSquared claims a long history of familiarity with the technical rules of the MSS band and a wealth of technical expertise on interference issues. LightSquared is clearly the most knowledgeable about its own network technology, and also claims to be intimately familiar with prior proceedings relating to MSS interference and GPS. And it appears to claim that it has been working on these plans for years. Yet, in February 2011 it proposed only deployment scenarios which used the upper MSS bands, which overwhelming technical evidence shows will cause massive interference to every GPS receiver studied. The coalition maintains that this raises a variety of questions: Did LightSquared not know that its proposed upper MSS band operations would cause interference? If it didn't know, that places its technical competence in severe doubt. Did LightSquared know, or have very strong reason to believe, before January 2011 that massive interference would result? If so, why did it not disclose this to the FCC? There certainly was ample available evidence that harmful interference would result. The US GPS Council knew, and presented testing results and analysis demonstrating this interference to the FCC in both December 2010 and January 2011. So did major U.S. government departments and agencies, which communicated serious concerns to the FCC in a formal letter in January 2011. LightSquared's reaction? It dismissed these findings out of hand.

The Coalition To Save Our GPS contends that, since LightSquared was completely wrong in formulating its initial deployment plans and claiming that they would not cause interference, the company's reassuring technical claims about its "new" deployment plan lack credibility.  LightSquared's "recommendation" document makes a host of other inaccurate or misleading statements, and a number of its major misstatements are discussed below. The bottom line, coalition members say, is that "just as LightSquared was wrong in 2010 and the first six months of 2011, it is wrong now."

FMI: www.saveourgps.org