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LightSquared: By Hook or Crook

What this really says is: We don’t care if we interfere with GPS receivers; it is not our fault but the fault of the receivers, which should not be afforded any protection in any event; this is our spectrum and we want to use it for a purpose for which it was not intended regardless of the outcome.

Happy New Year!…2012 is already shaping up to be a very interesting year in wireless. AT&T called off its acquisition of T-Mobile, but did get the nod from the FCC to complete the purchase of the 700-MHz spectrum Qualcomm was using for its mobile TV network. This spectrum will be incorporated somehow into the existing AT&T 700-MHz spectrum holdings. Meanwhile, on December 20, 2011, LightSquared took off the gloves and basically demanded that the FCC “resolve the regulatory status of unlicensed commercial Global Positioning System (GPS) receivers vis-à-vis LightSquared’s licensed operations in the 1525–1559-MHz Mobile-Satellite Service (MSS) band.”

In its Petition for Declaratory Ruling, LightSquared is basically saying that it has the right to make use of this spectrum for a terrestrial LTE broadband system even if doing so might interfere with existing GPS receivers. The reason, LightSquared states, is not because its network might cause the interference but rather because the GPS industry receivers were not sufficiently protected as to reject interference from the LightSquared spectrum. One of the most interesting (to me) statements in this document is, “It does not matter whether the Commission characterizes commercial GPS receivers as unlicensed receive-only earth stations that operate under Part 25 of the Commission’s rules, or as unlicensed devices that operate under Part 15 of the Commission’s rules. The relevant precedent under either analysis reaches the same inescapable result: unlicensed commercial GPS receivers simply are not entitled to interference protection from LightSquared’s licensed operations in the MSS band.”

What this really says is: We don’t care if we interfere with GPS receivers; it is not our fault but the fault of the receivers, which should not be afforded any protection in any event; this is our spectrum and we want to use it for a purpose for which it was not intended regardless of the outcome. I cannot believe that this document was well received at the FCC, and to me it shows how desperate LightSquared is becoming as it digs a deeper hole for itself, or rather a number of holes.

The first problem is that it may, according to some sources, be running out of money. Next is the fact that its deal with Sprint was supposed to expire at the end of 2011 but Sprint gave LightSquared a thirty-day reprieve to obtain permission from the FCC to build its terrestrial network. The FCC has never acted on anything I can remember within thirty days—certainly the FCC does not care about these types of business deal deadlines. Congress is stirred up about the GPS interference as is the DODFAA, and other agencies, and now LightSquared is basically threatening the FCC by demanding to be permitted to use its spectrum for something other than what it was originally licensed for (satellite communications with SOME infill of terrestrial stations to cover dead spots). Not only is it threatening the FCC, LightSquared is also saying that it doesn’t have any obligation to fix any interference problems it creates to GPS systems including those that could result in deaths and severe accidents if GPS devices fail to work properly.

The only word I have for LightSquared at this point is “arrogant.” It followed a method of selling wholesale services prior to having a network in place to “prove” it is relevant. It is also promising lots of new jobs and an influx of revenue. LightSquared hit the scene when there were questions about the number of network operators, yet neither the FCC nor the Department of Justice took it seriously enough to help mitigate the ATT/T-Mobile merger. Instead, the ATT deal died because it would reduce competition and stifle competitiveness—which we all know is simply not true. I have to ask if LightSquared was a serious player, wouldn’t the FCC and DOJ have taken that into consideration before they opposed the merger?

Since they did not, do you suppose there is a reason? Perhaps both the DOJ and FCC saw the writing on the wall and decided that LightSquared was not a serious competitor to AT&T and Verizon since LightSquared doesn’t even have permission to build out its network. Or perhaps both the FCC and DOJ are aware of the true investment that must be made by LightSquared and decided that the company does not have the resources to make its network happen. In any event, it appears as though LightSquared may be taking its last breaths of air, and that means it is getting desperate, pulling out all of the stops for permission to build out its network. But what happens if it fails to gain the approval of the FCC, and Congress is in a position to stop the FCC from giving LightSquared the green light? While Congress doesn’t control the FCC, it does control the FCC’s funding, which is the same as controlling the FCC.

So if LightSquared tanks, and I think it will, what is next for it and the industry? The partial answer is that LightSquared spectrum value would drop dramatically, its investors would take a beating, and the wireless industry is back where it started except that the thirty or so companies that signed up to resell the LightSquared broadband service are now in the wind. However, the names of these companies are now known and it won’t take long for the nationwide network operators to propose agreements with them and see if they really have the stomach for the type of investment it takes to play in the wireless market space.

My best guess is that of the thirty companies that have signed on to the LightSquared network, only about ten have the desire to proceed to bring LTE into their markets. Perhaps the rest of them will go back to what they were doing prior to the LightSquared deal, or perhaps they will try to work with another operator and come face to face with the reality of the marketing dollars involved in entering the wireless marketplace. No matter what, not all thirty-plus of these companies will ever be in a position to offer wireless broadband services. Rather, I think that many of them have been sold on the wonderful opportunities as portrayed by LightSquared and that when reality hits them in the face, many will simply cut their losses and go home. Wireless broadband service is about size and scale, money, spectrum, and above all, marketing dollars. Regardless of what they have been told by the LightSquared folks, selling against the big guys won’t be an easy task.

LightSquared is a perfect example of companies bitten by the wireless bug. They never open a spreadsheet and go to DC with a story that those who make the rules want to believe: Affordable broadband for all, very quickly; an opportunity to provide broadband in competition with the big boys; and the ability to make money in markets where no money has ever been made before. This is merely a pipe dream but giving LightSquared credit, it has certainly stirred up a hornet’s nest and made promises it cannot possibly keep.

So I, for one, hope the FCC and Congress stick to their guns and don’t let the false promises of a zillion new jobs and two zillion in income sway them to even consider permitting LightSquared to build a terrestrial system in this spectrum. We cannot afford to have any network that could, potentially, disrupt our GPS system. It would be a disaster and all of the jobs promised and the infusion of dollars promised could never make up for the loss of a single life because of the malfunction of a GPS receiver due to interference.

Andrew M. Seybold

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5 Comments on “LightSquared: By Hook or Crook”

  1. Rich says:

    I am glad to see that the FCC is finally recogising that the recievers should also be looked at. All this stuff about GPS going off the air is way overblown to the magnitude that it has been. Any aircraft or military device HAS to be tolerant of jammers. No amount of stuff by lightsquared woudl affect these.

    So what are we talking about now? Garmin and Tom Tom? Cheap chips which put no front end filter on them and have out of band jammers making their noise floor raise? Ok, so why did hte FCC not limit the box being made with a band limiter? I would say that the companies took the risk of making a cheap product over making it robust to jammers and assuming that NOBODY would put anything next to GPS.

    Same problem came up with Sirius and XM. cheap roll off filter on the front end, but when Nextwave bought teh sepctrum next to it, Nextwave COULD have taken XM andSirius out of business by legally radiating in their own band. but due to grandfathering and poor reciver specs, everyone had to jump thru hoops to use spectrum that the FCC sold full well knowing that it would mess up.

    It is high time we had front end filter reciever specs as part of the FCC part 15 qualifications. Make sure you only work in your own band and set a filter mask for out of band like 43 10log(p) like the transmitters have to do.

    With this, we end having these debates for years over who is more important, what is noise, etc.

    But PLEASE, do not post any more about the Military and Jet liners being taken out by this. That is just plain not true.

    • sverbil says:

      Rich:

      We’re all a little tired of the LighSquared fanboys asserting facts not in evidence, and simply ignoring physics as if wishing it would make it so. The evidence, after witnessed tests, is in – and it shows that the LightSquared proposed system will interfere with consumer and commercial users of GPS. The FCC is entitled to set is regulations so that weak signal applications live next to weak signal applications, and that precedent is long established – it is the reason the FCC was able to force Sprint/Nextel to pay for all of the rebanding costs caused by the near/far problem they created with the interference-limited design iDen system immediately adjacent to the noise-limited design public safety systems.

      The marketplace requires a level of certainty so that investments can be made – and the certainty in the GPS business is that it is a (very) weak signal environment that would stay that way. Following your argument to its logical (and ludicrous) conclusion, you would fault appliance manufacturers who deliver to the North American market for not designing *all* of their appliances to run on 230 volts as well as 115 volts simply because at some point it is possible that we might decide to change the voltage level across North America. Ya’ know, (most) of that wiring has 600 volts insulation, so there shouldn’t be any problems, right?

      Bottom line here is: follow the money. LightSquared is following the same Nextel business model that we were all burned by before… buy the frequencies cheap (because the market priced them that way precisely *due to* their limitations as space-based frequencies) and get a regulatory change approved that would (surprise!) radically raise the value of their investment.

      That looks like special-interest deregulation to me, and let me say “no thanks” to that, as we’ve seen how well that went with U.S. banking, and with Nextel.

  2. Sverbil–I could not have said it any better, Rich do you work with LightSquared? Are you affiliated with them in any way? Radio Spectrum is a finite resource and we need more for broadband services to be sure but not at the potential expense of interference to GPS receivers. In reality the process should have been to request engineering studies first, letting the FCC engineers and other make tests, and THEN apply for a waiver once it was proven (or in this case disproven) that there would be no interfernce.
    Someday we are going to learn that spectrum issues should not be decided by lawyers and politicians who become enamoured with a concept instead of sound engineering studies.
    This is actually the third case in recent memory when this happended. The first as Sverbil stated was the Nextel fisaco, which was forseen by some very good engineers whose input was ignored, the second was the FCC’s desire to auction off what was known as AWS-2 spectrum as Time Division Duplex (TDD) spectrum right above the AWS-1 FCC spectrum, a lot of which was bought at auction by T-Mobile. T-Mobile to their credit pushed tests and proved that FDD and TDD systems in adjacent spectrum would cause interferenc to the FCC systems. The plan now is to auction the AWS-2 and AWS-3 spectrum as paired spectrum for FDD so it will have not impact on the systems in the AWS-1 spectrum. However, in addition to the T-Mobile testing it was just plain good fortune that the FCC held up on ths Auction because Congress was looking at all spectrum auctions otherwise who knows what would have happened.
    And BTW I have never said that war planes and commerical planes would fall out of the sky, I merely included a link to the FAA’s and Airforce findings. When it comes to this type of thing I rely on the experts.
    Andy

  3. wd8chl says:

    Let’s also not forget that the reason GPS receivers hear in that spectrum is that, many years ago, it was Lightsquared that told the manufacturers that they could use their satellites for higher-accuracy position reporting for certain applications. Andy might have more of the history on that, but Lightsquared CANNOT blame GPS receivers for hearing in that spectrum, when they were the ones who suggested using it in the first place.
    And yes, it is absolutely true that aviation and military GPS will be affected by this. Anyone who actually understands RF, propagation, and things like adjacent channel interference, intermodulation products, and why a digitally modulated signal will generate more interference than an analog one, or why a broad bandwidth signal will generate more interference than a narrow one, will look at this and say, ‘duh…heelllloooo.’
    I do see however, that the FCC should not have allowed this waiver to begin with, just as they should not have allowed Nextel to operate the way they did either. Again, anyone who really understands RF could see the problem coming miles (or in this case years) away.

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