Questiny Group

To quote a famous Frank Sinatra song, “the end is near.”  At least it appears that way for LightSquared.  On February 14, the NTIA released a letter to the FCC stating, “We conclude at this time that there are no mitigation strategies that both solve the interference issues and provide LightSquared with an adequate commercial network deployment.”  Responding to that letter, today the FCC released a spoken statement that said, “The International Bureau of the Commission is proposing to (1) vacate the Conditional Waiver Order, and (2) suspend indefinitely LightSquared’s Ancillary Terrestrial Component authority to an extent consistent with the NTIA letter.”  In short, LightSquared’s access to the spectrum has been denied.  It’s likely that from this point forward, the lawyers will be the primary recipient of funds.

This is a sad result, although predictable.  As LightSquared heads for bankruptcy  or buyout (the fourth in this Companies history, if I count correctly), it’s appropriate to reflect.  While nearing the end, the aftermath of LightSquared’s attempts will be long.  However, I am hopeful that some positive change might result.  While true that politics became the dominate force in this debate, I consider that actually a plus since politics often arises when so many are affected by the outcome.  As I have said many times, the outcome of this could be predicted by the number of voters that had GPS units compared to the voters with LightSquared handsets.  But in a larger context, this whole issue has raised the awareness of many to our reliance on GPS, its vulnerability; the intense battle for spectrum to support our insatiable appetite for wireless devices; and the complexities of dealing with spectrum regulation (there were at least five agencies involved in this debate excluding Congress, Dept. of Transportation, NTIA, FCC, DoD, NPEF, and the FAA to name a few).  It is my hope that the result of this will create an awareness that GPS has become a critical public service worthy of strengthened policy and legislation protecting its civilian use.  It is also my hope, that the FCC and DoD can better their spectrum management to address situations where manufacturers that ignore the technical parameters in adjacent spectrum cannot seek “protection in numbers”, and the FCC begins to monitor the circumstances that foster spectrum squatting.

I may in a minority, but I actually think the FCC got more right with this than wrong.  Nothing about the January 2011 waiver required a change in the technical parameters for LightSquared, so in my mind, it did not require a Notice for Proposed Rule Making (NPRM) by the FCC.  However, there are those such as Scott Pace, Director of Space Policy at George Washington University, that disagree believing that such a widespread deployment of terrestrial capacity was a change in the spectrum use.  It is an argument, and one that LightSquared bet on – at least one way.  However, the GPS community bet the opposite way.  Any Company deploying a Ancillary Terrestrial Component in this frequency range will create the issues raised by the LightSquared testing.  It’s just a matter of how widespread.

My last hope for a positive outcome of this drama, is the highlighting of the support for space technology and space communications.  LightSquared may have been a thinly veiled attempt at auction free wireless spectrum (hardly free by Falcon’s accounting at the moment), but it was a satellite system too; and in that it was an attempt to create a economically  viable hybrid network of satellite and terrestrial capacity.  That in itself is a noble goal in that it would bring a national service to rural communities and provide a competitive alternative to the wireless oligarchy emerging in the US.  The good news on that front is that while LightSquared may be at its end, EchoStar is coming, ViaSat has launched, and either of them have a better chance at success.  To quote Mr. Churchill, “This is not the beginning of the end, but it is the end of the beginning!”

An NTIA Report leaked to Bloomberg Press stated that LighSquared’s basestations continue to disrupt GPS receivers.  The Bloomberg article specifically stated,  “The results from testing conducted Oct. 31 to
Nov. 4 show that “millions of fielded GPS units are not compatible” with  the planned nationwide wholesale service, according to the draft seen by Bloomberg News.   “LightSquared signals caused harmful interference  to majority of GPS receivers tested,” according to the draft prepared  for a meeting next week of U.S. officials reviewing the LightSquared  proposal. “No additional testing is required to confirm harmful
interference exists.””  The article went on to say that, “It [the Report] found that 69 of 92, or 75 percent, of receivers tested “experienced harmful interference” at the equivalent of 100 meters (109 yards) from a
LightSquared base station.”  Without a copy of the report and access to the test data, Questiny cannot comment on the validity of the claims.  However, our previous analysis shows that even the single carrier LightSquared spectrum plan would degrade the performance of GPS receivers that did not have sufficient attenuation at the LightSquared’s frequencies (1526-1536 MHz).  It appears that the NTIA’s direct testing has confirmed this situation — but this is not new news.

LightSquared stated at the conclusion of the FCC testing in June of 2011 that additional filtering would be needed, and contracted with the Javed corporation to construct external filters for such GPS units.  There has never been any dougt in our minds that such filters could be developed, and that they would provide sufficient filtering of the LightSquared signal to permit operation of the GPS units.  The issue has always been the conditions under which EXISTING GPS receivers would work WITHOUT MODIFICATION.  Thus it is also no surprise to to us that GPS users would frequently  find themselves in such conditions.  The report states taht 75% of the receivers would be impacted when within 100m (328 feet) of the base station.  This is fairly close to the basestation, and such close range only provides 76 dBm of attenuation (free-space) due to propagation leading to a received power at the GPS unit of (62 dBm-76 dB) -14 dBm — a strong signal level.  The GPS units must then filter that signal by more that 100 dB to minimize the effect of the LightSquared signal on its performance.  It is not surprising that standard commercial units have such filtering when they were likely designed assuming adjacent signal levels of -120 dBm not -14 dBm!

All of this is the backdrop to the FCC’s decision that it has to address the fact that even if LightSquared operates well within the technical limits of their license, such operation will still degrade the operation of existing GPS receivers not designed to accommodate such signals.  As for our prediction as to how this will turn out…as there are more voters with GPS units than voters with LightSquared units, Questiny has always believed that the FCC will eventually side with the GPS community, and revoke LightSquared’s license.  From there, LightSquared will likely sue the FCC for damages, and the FCC will find other spectrum for LightSquared.  All of this will likely be too late for LightSquared to achieve sufficient revenue to remain solvent, and once again, LightSquared will find itself at the brink of bankruptcy.

An article came out today announcing that LightSquared solves GPS interference with new device!  The article stated that  GPS device manufacturer Javad GNSS has come up with a device that “”The solution we’ve come up with dispels the myth that a product that eliminates  interference couldn’t be done,” Martin Harriman, executive vice president of  LightSquared’s Ecosystem Development and Satellite Business, said on a  conference call with reporters. “We did it. And it didn’t cost billions of  dollars or 10 years to do it. We did it.”  The article goes on to say, “Harriman said that through its partnership with Javad GNSS, which makes GPS  devices for such clients as the U.S. Geological Survey, has developed new  receivers that can be used to avoid interference between LTE and GPS.  Javad GNSS  has also completed designing and testing prototypes that can be adapted to work  with existing high-precision GPS devices, including those already being used in  the field.”

Am I missing something?  I thought the issue was not the inability to build new receivers, but the willingnesss of existing manufacturers and GPS users to accept retrofits and modifications to units already in the field?  Afterall this is not really a “Eureka” moment considering that LightSquared has had to 1) reduce the generation of intermodulation products by dropping the upper carriers and 2)consolidate GPS augmentation signals in that same part of their spectrum.  This latest announcement seems to be simply  a new receiver with better filtering, and that only has an effect AFTER the other two changes have been made.

After my shock that this is presented as such a “revelation”, the factis that with better filtering, the precision GPS receivers can coexist wtih LightSquared using the lower 10 MHz.  But we always knew this.  The issue for LightSquared is that this still sacrifices half of their capacity, and add the cost of retrofitting existing GPS receivers.  If anyone reads this article and believes that this solves the two-carrier LightSquared problem, please comment and let me know.

A article published today cited that the head of the FCC’s Office of Engineering and Technology, Julius Knapp, sent a letter to LightSquared and the GPS Council asking for more information on which devices were specifically interfered with by LightSquared, ane the effects of LightSquared’s new proposal to use only the lower portion of their licensed band (1,526 MHz to 1,536 MHz).  This is a valid, and not unexpected, question from the FCC especially since the Technical Working Group Report randomized the devices so that no correlation could be made between the device, device manufacturer and the test result.  This is understandable since the GPS receiver manufacturers likely want to preserve their proprietary performance from public disclosure to their competitors.  However, as Questiny looked at the data, we could not correlate the measured performance to the device characteristics.  For example, some of the receivers use automatic gain control (AGC) and 3-bit analog to digital convertors (A/Ds) , whereas other receivers use no AGC, and a 1-bit A/D.  The performance between these two devices is predictably differerent (the 1 bit A/D will be more sensitive to overload).  The figure shows the results of static tests performed for the General Navigation Class of GPS Receivers where the LightSquared power level was measured at the device such that the GPS carrier-to-noise level was reduced by 1 dB (or 25%).  As the figure shows, the range of power needed to create the same degradation across receivers varied by more than 70 dB (10 million time).  This is a huge difference in performance.  As the TWG only provided an index for the device, their technical characteristics could not be correlated to account for this range of performance difference.  (Note gaps in the measurements indicated devices that did not suffer any loss or were not tested.)

Regardless of the previous results of the TWG.  LightSquared essentially nullified their relevance when they proposed a new frequency plan on June 15.  Now, as expected, the FCC has ordered additional testing for this new LightSquared frequency plan, and they have reassured the GPS community that they will not impact the GPS performance.  As my colleague at TMF points out, this could put severe pressure on LightSquared vis-a-vis Sprint’s ability to back out of their deal should LightSquare be unable to raise additional capital and make their required payments.

Received Power (at Device) Required for 1 dB loss in GPS in C/N0 for General Navigation Devices

The Comerce Department’s telecommunication division has released a report stating that, “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.”  Strong words from a Government Agency.  Although, this is no real news since LightSquared’s own report to the FCC reached essentially the same conclusion.  The tests were so bad that LightSquared delayed the report two weeks to have time to prepare an alternate plan where they would delay operation in the upper portions of their licensed downlink band to minimize the impacts.   We have been conducting our independent review of the technical report delivered to the FCC, but at over 1000 pages, it will take some time.  There has much “banter” back and forth in a “He said, she said” game.  In reality, the truth is somewhere in the middle.  It is true that LightSquared is meeting the technical terms of their license.  It is true that the LS downlink transmissions will impact the current generation of GPS receivers, and it is also true that the GPS industry should have known that this was coming.  But such arguments are akin to children arguing on the playground.  The “adult” in this equation is, or should have been, the FCC.  In other areas the FCC, and their big brother-the International Telecommunications Union (ITU), demands progress be made toward the implementation of systems that use the spectrum.  For example, if satellite companies don’t meet progress milestones  on time, the can lose their license for a particular satellite slot.  For this spectrum, the satellite use was taken up rapidly, but the terrestrial component, or Ancillary Terrestrial Component (ATC), has languishes for years – the very period where GPS devices found their way into mainstream America.  In my opinion, this is where the fault lies. 

As the deployment of the ATC component of this spectrum languished, the FCC could have taken steps to either remove the allocation as an MSS/ATC band, to an MSS-only spectrum, or revoke the licenses of those who did not meet their milestones.  The fact that they did not take pro-active action to avoid this problem is their failing of leadership.  Now the FCC will likely claim that they cannot adjudicate the business plans of Companies by granting and revoking licenses, but this is a false claim.  They do that all the time with other spectrum license holders.  So the FCC “dropped the ball” on this one.  So what.  Every organization has it faux pas’, but it’s the recovery that matters.  Now is the time for the FCC to take a leadership position.  They need to step in and stop the wrangling, name calling, and wanton waste of treasure from all who are seeking a solution in their favor.  In short, the FCC needs to re-allocate this spectrum.  It’s not ideal, it may not even be right, but it is necessary. 

Millions of GPS devices exist and are relied upon.  That is a fact.  These devices were not designed to accomodate high power transmissions in adjacent spectrum.  Also a fact.  LightSquared had rights to that adjacent spectrum.  Also a fact.  However, LightSquared got their too late.  It sucks to be late.  LightSquared has a legitamate claim to spectrum, and LightSquard’s desires are in line with overall policy of the current Administration and the FCC.   The FCC needs to find other spectrum that will accommodate the growth of wireless.  The market questions of bandwidth and mobility have been answered-consumers will by as much bandwidth as they can get, and they will take as much of that bandwidth on the road with them as they can.  Now the FCC needs to get on with the business at hand and develop a better National spectrum policy that provides the spectrum resources that satisfy that market.

On June 30, 2011, LightSquared™ officially submitted the final report from the Technical Working group tasked with analyzing the impact of LightSquared’s deployment on the GPS community. In addition, LightSquared™ officially recommended that they defer their immediate plans to use the upper 10 MHz of their downlink spectrum (1545.2 MHz-1555.2 MHz), and operate solely on the lower 10 MHz portion (1526 MHz – 1536 MHz). LightSquared™ cited the correct source of the impact as to the filtering in the GPS receivers allowing the LightSquared™ signals to enter and distort within the GPS receiver. LightSquared™ also correctly noted that the use of only the lower 10 MHz LTE carrier will dramatically reduce the interaction between the GPS receivers and the LightSquared™ towers. Our calculations show that the distance for a given degradation is reduced by about 5x when the upper carrier is inoperative. For example, the distance for a 2 dB receiver desensitization (i.e., reduction in C/No or Eb/No) is reduced from approximately 5 km to under 1 km in free-space (no shadowing by buildings or effects from the Earth).

Figure 1. Receiver Desensitization Distance

Figure 2 shows the impact of the reduction of the upper carrier on the intermodulation power spectral density, and it’s dramatic reduction around the 0 frequency point (the location of the L1 GPS carrier). This characterizes the impact on the GPS-only receivers; it does not address the precision GPS receivers whose front-end filters intentionally include the adjacent MSS band to receive location augmentation information over satellites (such as Inmarsat). We will examine this impact next.

Figure 2a. Single carrier intermodulation power spectral density (-61 dBm)

Figure 2b. Intermodulation power spectra for dual LightSquared carrier operation

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Most notably, in the recommendation is the GPS signal degradation employed to assess impacts. LightSquared considered a 6 dB loss in C/N0 as acceptable if the GPS receiver still functioned, whereas the GPS portion of the TWG, thought that a loss of 1 dB in C/N0 was a significant impact to the performance of the GPS receiver.  Arguments for either side can be made, and this is another area for our investigation into the technical results published today.  It should be noted that for satellite systems, the International Telecommunications Union (ITU) uses a 6% dT/T criteria which is equivalent to a 0.25 dB degradation in C/No!

The final technical report contains more than 600 pages of technical documentation and test results.  This will take some time to review.

Analysis of LightSquared™™ Terrestrial Carriers on GPS Receivers

Keith R. Barker, Questiny Group, Inc.

Monday LightSquared™ offered to move its spectrum from the current location to mitigate their impact on existing GPS receivers.  This is the first admission that no real solution existed to this problem.  Details are sketchy at this moment, but in an article published by Wireless Week, they stated that, ” LightSquared™ plans to use spectrum leased under an existing contract with Inmarsat instead of its own L-band spectrum until it can figure out how to use its own bandwidth without affecting GPS.  The company also said its base stations will transmit their signals at half-strength to further minimize interference.”  That article went on to state that, “The Inmarsat spectrum slated to be used by LightSquared™ runs from 1526 MHz to 1536 MHz and is located further away from bands used by GPS receivers, which run from about 1559 MHz to 1610 MHz, helping to reduce the likelihood that LightSquared™’s transmitters will knock out GPS service.”  The article quoted the Company as stating that even this fix would not remove the impact to all of the precision GPS receivers currently deployed.

The article suggests that LightSquared™ is giving up on a two-carrier configuration in their spectrum.  In their FCC filing, LightSquared™ proposed a phased deployment plan.  The last phase, Phase 2, used two 10 MHz wide LTE carriers located at 1,526-1,536 MHz and 1,545.2-1,555.2 MHz.  Each of these carriers were opertated at an effective radiated power of 32 dBW.  The plan suggested by LightSquared™ appears to drop plans to use the upper carrier (1,545.2-1,555.2 MHz), and to cut the power of their carriers to 32 dBW.

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