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.

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.