Letter to Senate Says FCC Order Will Negatively Impact Industry and Government - Inside GNSS - Global Navigation Satellite Systems Engineering, Policy, and Design

Letter to Senate Says FCC Order Will Negatively Impact Industry and Government

A broad cross-industry coalition sent a strongly worded letter to the  Senate Commerce Committee warning that the Federal Communications Commission’s (FCC’s) Ligado Order that impacts GPS, if left in place, “would upend decades of sound spectrum policy, negatively impact a significant cross-section of commercial, federal, and academic users who rely on the many different L-band satellite services, and threaten the safety of most Americans.”

In all, 78 organizations representing multiple industries signed the letter, which was addressed to Senate Commerce Committee Chairman Roger Wicker and Ranking Member Maria Cantwell. Signers included Trimble, Iridium, Airbus, several airlines and airline associations and pilot associations.

The full text of the letter reads:

October 27, 2020

The Honorable Roger Wicker Chairman
Committee on Commerce, Science, and Transportation
United States Senate Washington, DC 20510

The Honorable Maria Cantwell Ranking Member
Committee on Commerce, Science, and Transportation
United States Senate Washington, DC 20510

Dear Chairman Wicker and Ranking Member Cantwell:

We write to you today to express our profound concern over the Federal Communications Commission’s (“Commission”) flawed Ligado Order1 that, if left in place, would upend decades of sound spectrum policy, negatively impact a significant cross-section of commercial, federal, and academic users who rely on the many different L-band satellite services, and threaten the safety of most Americans. As you know,

L-Band satellite services are “fundamental to the Nation’s economy, national security, and continued technological leadership.”2 We therefore respectfully request your Committee’s assistance in ensuring that the Commission reconsider its decision to allow a harmful terrestrial network to be built using L- band spectrum.

Operators and users of L-band satellite systems have relied on a stable spectrum environment free from harmful interference to deploy their networks and conduct their operations that depend upon those networks. Ligado’s proposed terrestrial network would fundamentally put the vital L-band satellite communications services—that in some instances serve as the only way to reach even the most remote regions of the world and are critical to safe aviation—at risk. In addition, the proposed Ligado network would disrupt the reliability of satellite communications services and the many critical applications that rely upon Global Positioning System (“GPS”), which has direct implications for safety-of-life in commercial aviation operations, precision farming and irrigation management that have revolutionized the agriculture economy, autonomous ground and air vehicles that will bring a new generation of transportation, precise and actionable weather data that can predict hurricanes and other life-threatening natural events, and many other applications. Simply put, the Ligado Order failed to take full account of the diverse services in the L-band, including those relied on by military, federal, and public safety users, that would be stranded or significantly impaired (without available alternatives) by the harmful interference caused by Ligado’s proposed terrestrial network.

The L-band is heavily and efficiently utilized by the undersigned organizations and companies. Regrettably, the Ligado Order is predicated on an insufficient appreciation for the real-world risks of harmful interference and the impacts that interference would have on our organizations, fourteen federal agencies and departments, and the broad cross-section of the American people we serve. Should Ligado be allowed to deploy its proposed network, our experience and analyses demonstrate that it could result in the degradation of the safety-of-life and the many more satellite services provided over L-band spectrum. These concerns have culminated in the almost unprecedented step of the National Telecommunicatios and Information Administration (“NTIA”) asking the Commission to reconsider its decision based on the detrimental effect Ligado’s proposed new adjacent band terrestrial operations would have.3

We therefore request your direct involvement to protect the satellite communications and GPS services that we provide and are relied on by tens of millions of Americans every day. We urge you to work with the Commission to set aside the flawed Ligado Order in favor of a process that is responsive to the concerns of the incredibly broad cross-section of L-band operators and users representing the aviation, aerospace, agriculture, GPS, ground transportation, mapping, marine, metrological, public safety, satellite communications, and surveying industries and professions. We look forward to continuing our dialogue with you and thank you for your consideration.

Respectfully submitted,

AccuWeather, Inc.

Aerospace Industries Association (AIA) Agricultural Retailers Association Aircraft Electronics Association

Airbus

Aircraft Owners and Pilots Association (AOPA) Aireon

Airlines For America

Air Line Pilots Association, International ALERT Users Group

Allegiant Air

American Association of Airport Executives American Association of Port Authorities American Farm Bureau Federation American Geophysical Union (AGU) American Meteorological Society (AMS) American Rental Association

American Road & Transportation Builders Association

American Soybean Association American Sportfishing Association American Trucking Associations American Weather and Climate Industry Association (AWCIA)

Associated Equipment Distributors Association of Equipment Manufacturers Association for Unmanned Vehicle Systems International

Aviation Spectrum Resources, Inc. (ASRI) Blue Origin

BoatU.S. CalAmp

Cargo Airline Association Center for Sportfishing Policy CNH Industrial

CoBANK

Helicopter Association International (HAI) Hellen Systems

Intelligent Transportation Society of America International Air Transport Association Iridium

Marine Retailers Association of the Americas Micorom Environmental

Narayan Strategy

National Air Carrier Association National Defense Industry Association

National Air Traffic Controllers Association (NATCA)

National Air Transportation Association National Agricultural Aviation Association

National Society of Professional Surveyors (NSPS) National Weather Association (NWA)

NetJets Association of Shared Aircraft Pilots (NJASAP)

NEXA Capital Partners, LLC PlanetiQ

Polar Air Cargo Worldwide Regional Airline Association

Resilient Navigation and Timing Foundation Seafarers International Union

The Semaphore Group

Space Science and Engineering Center (SSEC) at the University of Wisconsin- Madison

Spire Global Spirit Airlines SKYTRAC

Southwest Airlines Pilots Association

Subsurface Utility Engineering Association (SUEA)

Sun Country Airlines

Trimble

Crown Consulting Inc. Cubic

DTN

Equipment Dealers Association Frontier Airlines

FLYHT Aerospace Solutions Ltd.

General Aviation Manufacturers Association GeoOptics, Inc.

Geospatial Equipment & Technology Institute (GETI)

University Corporation for Atmospheric Research (UCAR)

USA Rice

U.S. Contract Tower Association

U.S. Geospatial Executives Organization (U.S. GEO)

Vertical Flight Society Weather Elevate

_________

1 In the Matter of Ligado Amendment to License Modification Applications IBFS File Nos. SESMOD- 20151231-00981, SAT-MOD-20151231-00090, and SAT-MOD-20151231-00091, Order and Authorization, IB Docket No. 11-109, FCC 20-48 (Apr. 22, 2020).

2 Letter from Douglas W. Kinkoph, Deputy Assistant Secretary (Acting), NTIA, to Ajit Pai, Chairman, FCC (Dec. 6, 2019).

3 Petition for Reconsideration or Clarification of NTIA, IB Docket Nos. 12-340, et al., at 1 (May 22, 2020).