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!”

The “National Defense Authorization Act for Fiscal Year 2012” signed by President Obama signed at the end of 2011 included a section (Title IX, Subtitle B, Section 911) that directed that ” The Federal Communications Commission shall not lift the conditions imposed on commercial terrestrial operations in the Order and Authorization adopted on January 26, 2011 (DA 11–133), or otherwise permit such perations, until the Commission has resolved concerns of widespread harmful interference by such commercial terrestrial operations to covered GPS devices.”  In other words, LightSquared is prohibited from deploying their terrestrial base stations until it is determined that there are no impacts to “covered GPS devices” (i.e., military GPS receivers).  The Act goes on to order the Secretary of Defense to report to Congress every 90 days the results of testing that t if Military GPS receivers are effected by LightSquared operations.  This report is to be delivered to Congress every 90 days for two years.  Ouch!

Such legislation has some dire consequences for LightSquared.  Some background may be needed.  First, the FCC provides no protection for commercial receivers of any kind (other than to limit their own radiation through Type A and Type B certifications).  If a manufacturer builds a poor receiver that does not function, too bad for that manufacturer.  Also, there are no protections for commercial civilian GPS receivers.   the fact is that the GPS system is a DoD satellite navigation system, designed and operated by and for the military.  As far as I know, no federal agency or legislation protects the civilian use of GPS, and no tax dollars outside of the DoD’s budget goes to operate or maintain GPS.  If the DoD saw fit to turn GPS off, they could do so, and commercial users have no recourse.  No one believes such a thing would happen, but I understand that it is fully within the DoD’s right to do so.  This is why the Defense Authorization Act can only address “covered GPS devices.”  However, this creates quite a problem for LightSquared.

LightSquared has taken several steps to mitigate the interference to commercial GPS devices.  They have offered to reduce their power levels, operate on limited carriers for a period of time for manufacturers to improve their receivers and time for these improved receivers to diffuse into the market.  In addition, LightSquared has developed new filters to assist commercial precision GPS receivers that operate within the LightSquared spectrum.  All of these are the actions of a “good spectrum neighbor”, but unfortunately, they do not apply to the Military.  The Military has, and now must, conduct their own testing of these devices.  This means that LightSquared has to protect the US Military use of GPS before Congress will allow the FCC to license LightSquared. The consequence to LightSquared is that this will take time, and time is something I believe LightSquared is running short of.

It’s been reported that LightSquared needs additional funding to continue operations, and that these financial needs are becoming immediate.  If the Military can determine that LightSquared will not interfere with their receivers, then LightSquare might be granted a license to operate, paving the way for more funding.  But how long will this take?  I speculate that it could take the DoD more than 90 days just to identify the organizations impacted and the GPS equipment that should be tested.  Once that is decided, units would have to be procured and tested under conditions the US Military users accept.  To me, this sounds like a very long process.

For planning, let’s say the results are that there are some impacts the Military GPS devices, but they can be fixed with modifications to the GPS receivers (all big ifs).  Such modifications will have to conform to military procurement.  Military procurements take much longer civilian manufacturing.  Furthermore, such procurements are much more expensive, and many of the GPS devices are within classified equipment.  In times of declining defense budgets, where would the DoD find such money?  Under this scenario, LightSquared has limited options to mitigate the impacts and reduce any delays.

LightSquared might have a trump card, and I don’t know why they have not played it so far.  The card is this.  If GPS is so critical to Military Operations, then why can a civilian system affect its performance when it is operating well within its technical parameters and on an adjacent spectrum?  Doesn’t this mean that GPS is extremely vulnerable, and needs to be fixed anyway?  That may be happening.  I understand that GPS 3/R, the latest GPS replacement satellites, offers improved protection for Military users.  However, that still doesn’t ease the delay for LightSquared.  In the end, the “tyranny of the clock” may be working against LightSquared.

I think it sad if LightSquared should succumb to the business pressure resulting from these delays.  LightSquared is the first real attempt at a hybrid satellite-terrestrial communications system.  It is my opinion that such systems are needed if a viable communications satellite industry continue in the United States.  Such a system does not have to operate on spectrum adjacent to GPS, but it will need access to spectrum amenable to dual terrestrial and satellite operation.

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.

In their latest proposal, LightSquared has offered some concessions to mitigate their impacts with GPS.  They have offered the following adjustments to their technical design:

1. Limit the received power within the region 50m to 500m to under -30 dBm
2. Limit the degradation due to LS signals to under a 1 dB degradation in C/N0
3. Move the satellite GPS augmentation signals to the upper portion of the MSS Spectrum (above 1,536 MHz), and offer filters with 40 dB rejection at 1,536 MHz

On the first item of their proposal, the analysis below shows that in free-space, the received power from a LightSquared tower will exceed -30 dB by as much as 21.5 dB (power received at 50m from a 62 dBW EIRP  base station at a 10m antenna height). However, if the average loss is more urban-like (loss exponent of 2.7), the the received power drops to more than 3 dB below the -30 dBm limit they have set.

The FCC dictates that free-space loss be used in all calculations.  However, urban environments are not free-space, actual attenuation is often larger than free-space.  Such facts indicate that LightSquared is betting that propagation loss in excess of free-space is more likely, and they will not have to reduce their transmit power and reduce their transmit power.  Although calculated, this is a risky bet.  Measurements on GPS receivers made by LightSquared indicate that many general purpose GPS receivers perform well when subjected to LightSquared interference below -30 dBm with the exception of the precision GPS receivers that use augmented GPS information.  This brings up the second and third aspects to their proposal.

It seems LightSquared has dropped their opposition to using a 1 dB drop in received GPS signal-to-noise ratio (or Carrier-to-noise density ratio, C/N0) as the bench mark for performance.  This is a positive step forward.  Many standards use a 1 dB criteria as the limit of harmful interference.  In fact, some satellite regulations require interference be limited to a C/N0 degradation of less than 0.25 dB, so 1 dB is quite gracious.  Furthermore, it is measurable.

The last point in their proposal is the effect of their carrier on the precision receivers.  This is a more difficult issue as the receivers are designed to receive augmented GPS signals transmitted over satellites using the LightSquared frequency band.  To solve this, LightSquared has proposed consolidating the GPS augmentation signals at the upper portion of their band, and supplying the precision GPS receivers with external filters that provide the needed rejection/attenuation of the LightSquared carrier in lower portion of the band.  The analysis they present in their FCC proposal indicates that the degradation to precision receivers is limited, but the question remains if manufacturers and system operators (such as John Deere, Inc.) would accept such additions. 

In short, LightSquared has indeed made concessions by taking on more risk relative to interference with GPS receivers, such concession will make their system roll-out and set-up much more difficult/expensive. Furthermore, while LightSquared may now have a technically workable proposal for their initial roll-out, it still does not provide access to the upper portions of their spectrum in the long-term.  If an agreement is not reached for that spectrum, LightSquared will have one-half the capacity their current business model assumes.  Not a pretty picture for investors.

Analysis of Received Power Limitation to Below -30 dBm

LightSquared has offered a maximum received power level of less than -30 dBm within a circle of 50m to 500m around its towers.  This level seems currently based upon their latest test results of GPS receivers to their current frequency plan of using only the lower 10MHz portion of their spectrum. 

LightSquared Testing of General GPS Receivers to Lower 10 MHz LTE Carrier

In addition, a sectored antenna is assumed with a downtilt of 7 degrees.Below is an analysis that examines the received power levels at GPS receivers from three different height Light Squared

The plot below shows the region around the tower where LightSquared intends to limit the received power to less than -30 dBm.  The minor ticks are every 10m showing the resolution to which LightSquared will measure the power levels.

Power Controlled Region around LightSquared ATC Tower

Starting with the power limitation on the ground, we can write an equation for the received power, Pt=PrGv/FSL.  This is the transmit power times the antenna pattern divided by the spreading loss (aka, free-space loss).  The average propagation loss is a function of the distance from the transmit source, the frequency, and the average loss exponent.  Free-space loss has a loss exponent of 2.  The formula is shown below.

The distance from the transmit source may be determined from the Pythagorean theorem assuming the tower antenna height and the distance from the tower base.

Combining these two equations shows and plotting as a function of transmit antenna height (10, 20, and 30 meters), we have the following free-space propagation loss for the three tower antenna heights.  As shown, there is little difference between the tower heights.

Free-space Loss between GPS Receiver and Tower Antennas (Antenna Heights = 10m, 20m, 30m)

The plot shows that the loss across the area surrounding a tower varies from a minimum of 71 dB to over 90 dB.  However, if the loss exponent is increased to 2.7, representing a suburban envioronment (urban environments have even higher exponents), the loss increases to 98 dB to over 120 dB (top, green line).

Propagation Loss from 20m Antenna Height to GPS Receiver for Loss Exponents 2.0, 2.4, and 2.7

The maximum effective isotropic radiated transmit power (EIRP) for LightSquared is 62 dBm, and the following plot shows the maximum received power at a GPS receiver from a 20m tower along the 50m to 500m distance LightSquared has defined.  The top curve (blue) shows the power received assuming free-space loss.  Note that since the FSL nearly the same for the three tower heights, this is what typical interference calculations for GPS receivers would use.  This shows a received power level of -8.8 dBm, or 21.2 dB higher than the -30 dBm specified by LightSquared’s proposal.  However, if the environment is more like an suburban environment, the received power is -33.5 dBm, or 3.5 dB better than the -30 dBM in the proposal.

Power Received at GPS Receiver Assuming Free-space Loss and Transmit EIRP of 62 dBm

However, the situation is  better when including the effects of a sectored cellular antenna.  The antenna pattern will further attenuate the LS signal as the GPS receivers move closer to the tower. 

A cellular antenna such as the Kathrein 724222 or 742223 has a 20 degree half-power beam width (HPBW), and the cellular operators typically point the antennas down to the ground (called a down tilt angle).  Typical downtilt angles vary from 3 degrees to 8 degrees.  For this analysis, 7 degrees is used.  If we assume a parabolic elevation antenna pattern, then along the maximum azimuth pattern, the antenna directivity is shown below (Downtilted Base Station Antennas –A Simulation Model Proposal and Impact on HSPA and LTE Performance, Fredrik Gunnarsson, Martin N Johansson, Anders Furuskär, Magnus Lundevall, Arne Simonsson, Claes Tidestav, Mats Blomgren).

This antenna model assume a side-lobe level of -20 dB. 

The geometric angle to the mobile terminal from the base station transmit antenna may be determined from simple trigonometry resulting in the following plot.

As shown, the angle to the GPS user is  is below 32 degrees.

Angle from Tower Antenna to GPS Receiver

Combining the angle calculations into a antenna equation, and calculating the the received power to a GPS receiver results in the following equation( as a function of the distance from the tower).  Plotting the equation for the various tower heights, frequency and loss exponent.

Plotting the above equation for three antenna/tower heights (10m, 20m, and 30m) shows that the received power when the antenna pattern is included.  The worst case is for a 10m tower antenna height, 50m away with a received power of -8.5 dBm.  Next is the 20m tower height with a received power of -10.6 dBm, and finally the 30m tower with -14.1 dBm.  Notice, however, that the power levels increase above this within the 50m circle for the lower tower heights.  This is also where one might expect free-space loss (exponent=2) to be more prevalent.

Increasing the loss exponent to 2.7, the received power is -33.1 dBm, -35.4 dBm, and -40.1 dBm for tower heights of 10m, 20m, and 30m, respectively.

Subtracting the -30 dBm from the above plot indicates the level of additional attenuation required for LightSquared to meet their proposed power limit.  The plot below shows the maximum attenuation they would need to achieve (for free-space) is approximately 21.5 dB (10m antenna tower).  This is a substantial reduction in power levels.  However, if the loss exponent is increased from 2 (free-space) to 2.7, LightSquared actually has margin!

Note that this risk is mitigated by the probability that a GPS receiver will be within it 50 meter radius of the tower.  If we assume that GPS receivers are uniformly distributed around the tower, we can calcuate the probability that GPS receivers are within the a particular distance from the tower.  As shown, 99% of the users are further away than 50m, and 95% are more than 110m away from the tower.

THE BOTTOM LINE.  This is the key point of LightSquared’s proposal.  By shifting to received power, typcial interference analysis would indicate that LightSquared would have to reduce their power level by 21.5 dB to 40.5 dBm.  However, by taking the risk that most areas will be experiencing something greater than free-space loss, LightSquared has a greater opportunity to operate at their current power levels.  This is not incorrect reasoning, but it does involve a calculated risk.  Flat, open regions that experience nearly free-space loss will indeed have to operate at reduced power, and in those regions, LightSquared will require more towers to cover the same area, or have to accept less capacity.

Companion Receiver Analysis

It’s insightful to examine how the received power from a LightSquared tower compares to typical GPS receiver characteristics.  From this analysis, we can determine the internal attenuation that GPS receivers likely have to the lower LightSquared carrier.  A usefull resource for GPS calculations is from National Instruments (http://zone.ni.com/devzone/cda/tut/p/id/7189).  This states that a good value to use for the received power from GPS satellites is -136 dBm, and that typical receivers have a noise figure between 2 dB and 5 dB.

The GPS receiver sensitivity may be determined from the following equation. 

Calculating the receiver noise density for a 10 dB noise figure:

This is equal to a receiver C/N0 of:

For a 1 dB degradation in C/N0, the required interference noise density (-5.8 dB from the receiver noise density)

If the interfereing LightSquared signal is received at the specified -30 dBm, or a noise density of -100 dBm (-30 dBm-10Log(10MHz), then nearly 76 dB of added attenuation is needed to achieve a 28 dB CNR. Such attenuation is possible when there are no intermodulation products created in the receiver front-end, and the receiver tests performed by LightSquared appears to support this.  However, the situation requires even more receiver attenuation when we consider the expected maximum average received power calculated from above.

When the received power is incorporated with the required interference noise density produced by LightSquared’s carrier, the required receiver attenuation exceeds 90 dB when 50m from the tower. 

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

Today (June 9, 2011), FCC Chairman Julius Genachowski held a press conference stating that the FCC would protect GPS services, but that it was continuing to examine ways the two services could coexist.  As the article in Broadcast and Cable stated, “There continued to be an interference problem, they said, particularly in the upper portion of the band closest to GPS. While LightSquared’s proposal anticipates eventually using that spectrum as well, one FCC official said he did not see that happening anytime soon, and that the commission was focusing on the lower-band proposal.”  As also stated in the article, this is essentially a “proceed at your own risk” statement.  In other words, LightSquared’s business plan depends on rapid buildout of their network to derive free cash flow as soon as possible, but the FCC has essentially halted this until more testing can be completed for one-half of the spectrum for which LightSquared requested licensing and upon which they defined their business plan.  If I were an investor, this would dramatically increase my risk assessment for the LightSquared venture.

An FAA report leaked to the press concluded that the deployment of the LightSquared broadband communications system will cost the aviation community $70B and add 30 million tons of CO₂ to the atmosphere. There are really no surprises in this report. The impact to GPS receivers by signals such as LightSquared is relatively easy to predict, but the more relevant situation this report brings to light is the conflicting policies that overlay spectrum licensing. On one hand, we have a National Space Policy that says we must lead in the area of space-based navigation and timing; while on the other hand, we have a national broadband plan that states we must provide broadband access to larger segments of the U.S. Furthermore, we have spectrum policy that states that the FCC regulations that do not provide protection for manufacturers that build sub-performing receivers, and licenses spectrum users on this basis.

Spectrum fights are nothing new, but what is new are the economic stakes. Never before has the U.S. had to contend with so many dependent upon the electromagnetic spectrum. Historical spectrum management has relied on the “everyone gets their slice, and please play nice” policy. That meant that users licensed to operate within a given spectrum were granted access to that spectrum provided that they stayed within their technical requirements and did not interfere with other users (adjacent or otherwise). That policy appears to assume that there is sufficient time and capital for existing users of the spectrum to upgrade or accommodate new uses of the spectrum. However, demand for spectrum is exceeding the ability and capital to upgrade existing systems (especially when many of the existing users of this spectrum are the Government and municipalities). While I have not seen any reference to it, the FCC is dealing with a “sea change”, and not just a specific spectrum issue. I sense that the LightSquared-GPS issue, of which this Report is part, is a harbinger (pun intended) of things to come.

REPORT SUMMARY

An FAA report leaked to the press concluded that the deployment of the LightSquared broadband communications system will cost the aviation community $70B and add 30 million tons of CO₂ to the atmosphere. The Report cites the following reasons for this conclusion:

• Loss of benefits from the delayed NextGen [Next Generation Air Transport System] technologies and procedures
• Loss of existing GPS efficiency benefits
• Loss of existing GPS safety benefits
• Aircraft retrofit costs

The Report goes on to imply that the deployment of LightSquared is counter to the 2010 National Space Policy for the United States of America where “the U.S. must maintain its leadership in the services, provision, and use of global navigation satellite systems.” It stated that, “The international market for U.S. satellite navigation technology could be damaged.” Furthermore, the Report based these findings on the June 30, 2011 LightSquared proposal where LightSquared would begin operations in 2012 on the lower of their two 10 MHz carriers, and at reduced power (from that authorized by their license). Subsequently, LightSquared would begin operations on both carriers in 2014 (The report assumed that operation on both carriers would be at the reduced power levels). In addition to providing specific numbers for the economic benefit for GPS in the aviation community (or detriment of degraded GPS performance), the Report dismisses LightSquared’s proposals for mitigating GPS receiver overload through the use of in-line filters. The FAA essentially states that no such filters exist, and it would take 6-10 years to deploy them even if such filters did exist. The Report offered no conclusions on the impact of the initial LightSquared operation (operating only the single, lower carrier) other than it would impact the use of precision GPS receivers. These receivers operate in essentially the same frequency band as LightSquared so that no filtering would provide adequate mitigation.

The FAA Report was specifically requested by the Executive Office of the President’s Space-Based Positioning, Navigation and Timing Executive Committee’s National Coordination Office (PNT NCO) Director (1) to answer the following questions:

1. Summarize and quantify current and future benefits provided by use of GPS-based applications and any cost-benefit analyses
2. Summarize and quantify total sunk costs in GPS-based infrastructure (prior years to date) and planned investments going forward
3. To the extent possible, qualify, quantify and describe the risks to your agencies GPS-based mission capability, including “lost benefits” if GPS performance were degraded (or lost) due to LightSquared’s signals including the cost to modify (or replace) GPS receiver infrastructure and time frame required to replace that infrastructure.

In response to these questions, the FAA reported that GPS provides “at least $200 million in efficiency benefits” and saves 800 lives over the next 10 years ($5B of public safety benefit). However, they go on to cite that the primary benefit is through the Next Generation Air Transport (NextGen) system of $123B and reducing carbon emissions by 64 million tons by 2030. From Questiny’s perspective the impacts to NextGen, whether real or perceived, are the delay to that program. NextGen is an upgrade to the FAA air traffic control system to use precision GPS data rather than ground-based radars to locate and track aircraft. In the 1980’s the FAA attempted to upgrade the air traffic control system, and while my memory is a bit hazy on the details, I recall that that upgrade was fraught with problems and eventually cancelled. The Joint Planning and Development Office (JDPO) for NextGen estimates that “not expanding the ATC system’s capacity will be costing the U.S. economy $40 billion per year by 2020 because the overburdened system will force significant rationing of flights.” Thus, even a 2 year delay in NextGen could cost $80B to the economy.

(1) The PNT NCO was established in 2006 and its Charter states: “The Executive Committee is the senior-level federal government body established by the President’s Space-Based PNT Policy to advise and coordinate among member Departments and Agencies responsible for the strategic decisions regarding policies, architectures, requirements, and resource allocation for maintaining and improving U.S. space-based PNT infrastructure.”

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.

PC World’s online news reported that the House Appropriations Committee “passed a measure that would use Congress’ control of the FCC’s purse strings to stop the agency from letting LightSquared move forward.” The article quoted the Committee as stating, “None of the funds made available in this Act may be used by the Federal Communications Commission to remove the conditions imposed on commercial terrestrial operations … until the Commission has resolved concerns of potential widespread harmful interference,” with GPS, said the text of the measure, an amendment to a funding bill. This seems to increase the pressure on LightSquared as this will likely further delay their deployment, or at least, curtail it. Given LightSquared’s desire to deploy a terrestrial system within 12-18 months, this places great pressure on their engineers to develop a system design that reconciles handset design, base station configuration, antenna design, etc. If LightSquared limits their terrestrial component to the 1 lower 10 MHz carrier in the 1500 MHz band, and are granted other slots in the AWS band (conjecture on my part) at 2100 MHz, the engineers have quite a frequency plan to resolve. This AWS frequency is 40% away from their allocated spectrum, and I believe it is upaired. This creates many issues on the selection of filters, receiver cards and base station equipment, as well as, the issue with the handsets. Engineers can be quite creative to finding solutions to all of these issues, provided their is sufficent money and budget to solve them. The engineers at LightSquared have quite a challenge ahead of them.

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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