More than 20 parties with interests in GPS, satellite communications, and weather and other environmental data reiterated their concerns June 27 with Ligado Networks LLC’s proposed nationwide LTE network.
“We have read with interest recent FCC filings and statements in the press from Ligado claiming that virtually all of the opposition to its pending license modification application and request for rulemaking to utilize spectrum at 1675-1680 MHz have been resolved. Contrary to the assertions in Ligado’s FCC advocacy and recent media blitz, its proposed terrestrial operations continue to pose a significant interference risk to numerous parties that receive real-time weather and related environmental information from the National Oceanic and Atmospheric Administration (‘NOAA’), certified GPS receivers and aeronautical safety SATCOM relied upon by the aviation industry, and Iridium’s 869,000 government and commercial subscribers,” said the ex parte filing in IB dockets 11-109 and 12-340.
“The risks to these critical services are very real and, consistent with the public interest, cannot be brushed aside,” the filing continued. “This is particularly true when contrasting the impact of interference on the services provided and/or depended on by the undersigned organizations with the highly uncertain benefits of Ligado’s proposal. For example, while Ligado is currently portraying itself as a hybrid satellite-terrestrial Internet of Things (‘IoT’) service provider, a recently released Ligado-commissioned economic analysis suggests that Ligado seeks the ability to sell its spectrum to the highest bidder, underscoring the uncertainty of any prospective value of the services it has on previous occasions suggested it may provide. As stated in the analysis, ‘Ligado and similarly-situated entities should be able to transfer spectrum interests in such a manner that entities that value spectrum more than Ligado can acquire it. … Clearer property rights [achieved by granting Ligado’s application] for spectrum would benefit not just Ligado but all parties with economic interests in spectrum.’”
“Whether as a result of pressure from investors or regulatory fatigue, there is a clear effort by Ligado to downplay the significance of the technical concerns it continues to receive from numerous directions,” the filing added. “Multiple parties have made it clear to the Commission that they continue to have serious concerns about the potential for significant interference. We will not describe in detail each of our concerns raised in opposition here, but wish to make clear that any Commission action without successful resolution of the concerns we have raised would be premature.”
“Each of the undersigned organizations has serious unresolved concerns with Ligado’s proposed operations for different reasons. What we each have in common is the shared belief that the Commission cannot act on Ligado’s requests until the Commission has sufficiently studied and addressed the many interference issues still outstanding, including the receipt of input from the affected federal agencies who are also studying these issues,” the letter said. “In the event that a satisfactory agreement cannot be reached between Ligado and the aviation community (concerning GPS and SATCOM services), Iridium, and the real-time environmental satellite data community, the Commission should deny Ligado’s pending license modification application and reject Ligado’s proposal to share the 1675-1680 MHz band spectrum with NOAA. The existing services provided by the SATCOM, aviation and real-time environmental satellite data communities, which depend upon interference-free operations in spectrum adjacent to or co-channel to spectrum central to Ligado’s plans, are too important to jeopardize, especially for the speculative benefits of Ligado’s constantly evolving proposals.”
Among those signing the filing were AccuWeather, the Aerospace Industries Association, the Aircraft Owners and Pilots Association, Airlines for America, the American Geophysical Union, the American Meteorological Society, the American Weather and Climate Industry Association, the General Aviation Manufacturers Association, Gogo Business Aviation, the Helicopter Association International, the International Air Transport Association, Iridium Communications, Inc., the National Hydrologic Warning Council, the National Weather Association, and Thales USA, Inc.
In response to today’s filing, a Ligado spokesperson said, “We have worked with the Commission and interested parties for nearly two years to resolve interference concerns, including signing cooperation agreements with major GPS companies that ensure Ligado is compatible with GPS and will not interfere with aviation safety or NOAA’s operations. Safety of life is paramount, and that’s why we have collaborated extensively with the FAA to protect aviation safety and provide the industry with an advanced level of connectivity currently unavailable today. Additionally, we have proposed that NOAA use a fiber cable and cloud-based delivery system for its weather data. This proposal and Ligado’s commitment to protect NOAA’s own operations will allow an auction of the 1675-1680 MHz band and preserve NOAA’s mission. Today’s filing contains no new information, no new technical analysis, no new data. It is simply a re-packaging of the same old complaints, all of which have already been amply addressed in the record before the FCC.” —Paul Kirby, firstname.lastname@example.org