June 22, 2016–Deere & Company has clarified its position regarding license modifications sought by Ligado Networks LLC. In reply comments filed in IB dockets 11-109 and 12-340, Deere said that it “wishes to clarify for the record: (1) its position with respect to the grant of the Modification Application; (2) the appropriate terms and conditions of any such grant; (3) the proper characterization of the Deere-LightSquared litigation Settlement Agreement; and (4) the appropriate metric for determining whether a GPS receiver under test has experienced harmful interference.”

Deere, which did not file initial comments in response to an FCC public notice released in April (TRDaily, April 22), said that its  “primary interest in Ligado’s network proposals — and in its predecessor’s proposal — is to ensure that the deployment of a terrestrial high power network in what was historically satellite spectrum will not cause interference to the adjacent U.S. GPS and other international Global Navigation Service Systems (‘GNSS’). Deere herein confirms that it does not oppose grant of the Modification Application, as proposed, that would incorporate the full set of technical parameters and licensing conditions, including specified power limits, out-of-band emissions (‘OOBE’) limits, and the determination that the 1545-1555 MHz band may not be used for terrestrial operations, consistent with Deere’s Settlement Agreement with Ligado.”

Deere added “that the Settlement Agreement reflects Deere’s judgment only that, notwithstanding interference to existing Deere receivers, it will be able to address interference issues in its technology plan for future Deere receivers assuming the Ligado network complies with the technical and other terms set forth in the Settlement Agreement. The Deere Settlement Agreement was not intended to be — nor could it be — a resolution of all technical and public policy issues that may be raised by Ligado’s Modification Application. Any other technical and public interest issues raised in this proceeding are outside the scope of Deere’s Settlement Agreement and this Reply.” Deere also cautioned “that its position with respect to Ligado’s Modification Application must not be interpreted as Deere’s acquiescence in or support for a metric other than the established 1 dB decrease in carrier-to-noise power density standard to determine potential harm to GPS and other GNSS systems. Deere remains a staunch supporter of the 1 dB C/N0 standard for assessing interference. No empirical, universal, and quantifiable alternative to the 1 dB C/N0 standard exists for evaluating harmful interference into GPS/GNSS service. Deere urges the Commission to avoid the obvious pitfalls and shortcomings of attempting to evaluate interference into GPS/GNSS service based on end user outputs or metrics, which are inherently subjective and unreliable in this context.” – Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily