Comment Deadlines Established Regarding The GPS-LightSquared Technical Working Group Report
Federal Communications Commission
News Media Information 202 / 418-0500445 12th Street, S.W.
Washington, D.C. 20554
June 30, 2011
COMMENT DEADLINES ESTABLISHED REGARDING THE LIGHTSQUARED
TECHNICAL WORKING GROUP REPORT
IB Docket No. 11-109
Comment Date: July 30, 2011
Reply Comment Date: August 15, 2011
technical working group co-chaired by LightSquared and the United States Global Positioning System
(GPS) Industry Council (USGIC)1 and organized in response to a condition in FCC Order and
Authorization, DA 11-133 (released January 26, 2011).2 The condition required that LightSquared help
organize and participate in a technical working group "that brings LightSquared and the GPS
community together" to address potential interference issues recently raised by members of the GPS
community.3 The Order "envision[ed] a working group in which cooperative and candid discussions
can ensue, and where information, including proprietary information, can be shared among the
participants with appropriate measures in place to protect the confidentiality of that information."4 The
condition required submission of a final report that includes the working group's analyses of the
potential for overload interference to GPS devices from LightSquared's terrestrial network of base
stations, technical and operational steps to avoid any such interference, and specific recommendations
going forward to mitigate potential interference to GPS devices. Among other things,5 the Order also
made clear that, "as a condition of granting this waiver, the [working group] process . . . addressing the
interference concerns regarding GPS must be completed to the Commission's satisfaction before
1 The report is available through the FCC's Electronic Comment Filing System (ECFS) in IB Docket No. 11-
2 26 FCC Rcd 566, 588, 48 (Int'l Bur. 2011).
3 26 FCC Rcd at 586, 41.
5 The Order also, for example, required LightSquared to ensure substantial market availability of mobile satellite
service by requiring LightSquared to dedicate at least 6 MHz of L-band spectrum, nationwide, exclusively to
satellite service. 26 FCC Rcd at 583-584, 36.
LightSquared commences offering commercial service pursuant to this waiver on its L-band MSS
The technical working group effort identified significant technical issues related to potential
LightSquared operations in the upper portion of the L-Band, which is most proximate to the band used
by GPS. Over more than three months, the technical working group tested more than 130 representative
devices in seven different receiver categories, in a number of different test environments. The tests
demonstrated potentially significant interference between LightSquared operations in the upper portion
of the band and various GPS receivers. The tests also identified some interference issues in the lower 10
MHz portion of the band. The overall conclusion of the testing is that transmissions in the upper 10
MHz channel -- the channel nearest to the 1559-1610 MHz GPS band -- will adversely affect the
performance of a significant number of legacy GPS receivers.
In addition to the technical working group report, LightSquared has submitted its
recommendations to address the problems identified by the working group.7 In particular, LightSquared
indicates its willingness to: (1) operate at lower power than permitted by its existing FCC authorization;
(2) agree to a "standstill" in the terrestrial use of its Upper 10 MHz frequencies immediately adjacent to
the GPS band; and (3) commence terrestrial commercial operations only on the lower 10 MHz portion
of its spectrum and to coordinate and share the cost of underwriting a workable solution for the small
number of legacy precision measurement devices that may be at risk. We specifically invite comment
on these recommendations, including any alternative proposals to enable these two important services
GPS devices and L-band mobile broadband to co-exist. We also welcome comments on the technical
working group report generally. Comments should be filed no later than July 30, 2011, and reply
comments by August 15, 2011.
Comments and Reply Comments. Comments and reply comments may be filed using: (1) the
Commission's Electronic Comment Filing System (ECFS); or (2) by filing paper copies. All filings
should reference the docket number of this proceeding, IB Docket No. 11-109.
Electronic Filers: Comments may be filed electronically using the Internet by accessing the
ECFS: http://fjallfoss.fcc.gov/ecfs2/. Filers should follow the instructions provided on the
website for submitting comments. In completing the transmittal screen, ECFS filers should
include their full name, U.S. Postal Service mailing address, and IB Docket No. 11-109.
Paper Filers: Parties that choose to file by paper must file an original and one copy of each
filing. Filings can be sent by hand or messenger delivery, by commercial overnight courier, or
by first class or overnight U.S. Postal Service mail. All filings must be addressed to the
Commission's Secretary, Office of the Secretary, Federal Communications Commission.
All hand-delivered or messenger-delivered paper filings for the Commission's
Secretary must be delivered to FCC Headquarters at 445 12th St., SW, Room TW-
A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand
deliveries must be held together with rubber bands or fasteners. Any envelopes or
boxes must be disposed of before entering the building.
6 26 FCC Rcd at 586-587, 43.
7 LightSquared's recommendation is also available through the FCC's Electronic Comment Filing System in IB
Docket No. 11-109.
Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority
Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.
U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th
Street, SW, Washington DC 20554.
Accessibility Information. To request materials in accessible formats for people with
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the Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY).
The comments and reply comments filed in response to this Public Notice will be available via
ECFS at: http://fjallfoss.fcc.gov/ecfs2/; you may search by docket number (IB Docket No. 11-109).
Comments and reply comments are also available for public inspection and copying during business
hours in the FCC Reference Information Center, Portals II, 445 12th Street S.W., Room CY-A257,
Washington, D.C. 20554. Copies may also be purchased from Best Copy and Printing, Inc., telephone
(800) 378-3160, facsimile (202) 488-5563, e-mail FCC@BCPIWEB.com.
Ex Parte Rules. This proceeding shall be treated as a "permit-but-disclose" proceeding in
accordance with the Commission's ex parte rules.8 Persons making ex parte presentations must file a
copy of any written presentation or a memorandum summarizing any oral presentation within two
business days after the presentation (unless a different deadline applicable to the Sunshine period
applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the
presentation must: (1) list all persons attending or otherwise participating in the meeting at which the ex
parte presentation was made; and (2) summarize all data presented and arguments made during the
presentation. If the presentation consisted in whole or in part of the presentation of data or arguments
already reflected in the presenter's written comments, memoranda or other filings in the proceeding, the
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or
other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can
be found) in lieu of summarizing them in the memorandum. Documents shown or given to
Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be
filed consistent with section 1.1206(b) of the Commission's rules. In proceedings governed by section
1.49(f) of the rules or for which the Commission has made available a method of electronic filing,
written ex parte presentations and memoranda summarizing oral ex parte presentations, and all
attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants
in this proceeding should familiarize themselves with the Commission's ex parte rules.
By the Chief, International Bureau
8 See 47 C.F.R. 1.1200 et seq.
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