GPS Alliance Takes Shot at LightSquared Testing

The GPS Innovation Alliance has submitted an ex parte filing to the FCC taking a shot at testing plans by LightSquared LLC consultants for assessing the compatibility between terrestrial broadband and GPS operations.

In an Aug. 14 filing in IB docket 12-340 that was posted online yesterday, the alliance referred to a July 15 filing by LightSquared that submitted a revised test plan prepared by its consultants, Roberson and Associates LLC (TRDaily, July 16).

“LightSquared’s letter asserts that it previously sought input on its test plan from interested parties, but that it was nonetheless renewing its request so that it could ‘receive feedback within the next week, since testing is anticipated to begin by the end of this month.’ While LightSquared is free to submit any technical information to the Commission, the GPS Innovation Alliance (‘GPSIA’) does not support duplicative testing and wishes to make clear that it will focus its technical efforts on the government assessment of adjacent-band compatibility issues that is currently being conducted by the Department of Transportation (‘DoT’),” the filing said. “If and when LightSquared submits technical analyses for the record, GPSIA will comment at that time.”

“GPSIA’s understanding that federal stakeholders – including NTIA, the Department of Defense and the Commission – have provided DoT with feedback on the proposed test plan. When DoT publishes the test plan in the Federal Register, all interested parties – federal and non-federal entities – will have a further and complete opportunity to provide feedback so that DoT is fully informed about how tests should be conducted,” the alliance added. “Indeed, DoT has already conducted several workshops on this topic and stakeholders – including LightSquared – have actively participated in those workshops.

“Aside from being duplicative, it is evident that the testing proposed by LightSquared would reinvent any number of test methods and acceptance criteria,” the filing added. “For example, the LightSquared test plan focuses on a unilateral sampling of key performance indicators (‘KPIs’) of questionable relevance. Many of the performance requirements for GPS devices are internationally agreed upon by the International Telecommunications Union, the International Civil Aviation Authority, and other world standards bodies.

“GPSIA continues to maintain that a proceeding such as this, focused on one service provider, is not an appropriate place for domestic modification of established international standards that would have repercussions not just within our borders but for numerous cross-border applications, such as aviation,” the alliance said. “In any case, GPSIA expects that the methodology for analysis of potential interference and the criteria for determination of harmful interference will be central issues in the DoT compatibility assessment, and GPSIA will provide substantive comments on these issues as part of that proceeding.”

LightSquared submitted a filing today replying to the alliance’s submission.

“GPSIA has now made clear that despite ample opportunity to do so, it does not wish to provide useful input or help to the Roberson testing,” the company said. “While input from GPSIA and its members was solicited in the spirit of openness and transparency, Roberson is proceeding with testing devices that are most representative of each category of GPS devices, and thus the most significant portions of the market for such devices, as planned.

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

LightSquared added “that GPSIA’s characterization of the Roberson testing as using standards ‘of questionable relevance’ is wholly incorrect. GPSIA provides no specific criticisms of any of the standards proposed by Roberson that would allow substantiation of such a claim. For example, GPSIA does not explain how anyone would consider a measure such as position error to be of ‘questionable relevance’ to the performance of a GPS device, the primary purpose of which is to report position to a user. GPSIA apparently prefers ‘internationally agreed’ standards, but provides no detail at all as to what standards it means.”

Meanwhile, another filing posted online yesterday from the American Meteorological Society and the National Weather Association encouraged “careful deliberation regarding the options and their consequences, before any decision is made regarding sharing of the 1675-1695 MHz radio spectrum band between current meteorological and hydrological users and terrestrial broadband wireless.” – Paul Kirby, paul.kirby@wolterskluwer.com