FCC Comment

Public Interest Organizations Support LightSquared Wholesale Mobile Network

  • and John Bergmayer, Harold Feld; Public Knowledge; Chris Riley, Matthew F. Wood, Free Press; and Chrystiane Pereira, Media Access Project
August 1, 2011 |

In 2010, the Federal Communications Commission approved an application by LightSquared to create a wholesale mobile broadband network by combining land-based and mobile satellite services. Subsequently, the commercial GPS industry opposed the network, arguing it would cause harmful interference to GPS devices. In response to a request for comments about the report of the Technical Working Group ordered by the FCC to study the interference issues, the New America Foundation, Free Press, Public Knowledge, and Media Access Project (the Public Interest Organizations) urge the FCC to actively intervene to broker, or impose if necessary, a plan that will not leave the L Band spectrum that LightSquared controls fallow, that will permit LightSquared to deploy its promised wholesale-only mobile broadband network on at least part of its spectrum, and that will safeguard essential GPS services.

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Before the Federal Communications Commission
Washington, D.C. 20554

In the Matter of LightSquared Subsidiary LLC Request for Modification of Its Authority for an Ancillary Terrestrial Component

IB Docket 11-109
SAT-MOD-20101118-00239

COMMENTS REGARDING THE LIGHTSQUARED TECHNICAL WORKING GROUP REPORT

New America Foundation, Free Press, Public Knowledge and Media Access Project (collectively, “Public Interest Organizations”) hereby file these comments in response to the Commission’s request for comments regarding the final report of the technical working group (“TWG”) co-chaired by LightSquared Subsidiary LLC (“LightSquared”) and the United States Global Positioning System Industry Council (“USGIC”) in response to a condition in the International Bureau’s Order and Authorization (“O&A”)1 approving the application by LightSquared to modify its current authorization to offer an integrated MSS/terrestrial service.2 The Public Interest Organizations believe it is incumbent upon the Commission to actively intervene to broker or, if necessary, impose a plan that will not leave the L Band fallow, that will permit LightSquared to deploy its promised wholesale-only mobile broadband network, and that will safeguard essential GPS services, while calling on both parties to share the costs of a longterm transition.

SUMMARY
The Public Interest Organizations urge the Commission to actively intervene to broker, or impose if necessary, a plan that will not leave the L Band fallow, that will permit LightSquared to deploy its promised wholesale-only mobile broadband network, and that will safeguard essential GPS services. The role of the Commission must be hands-on, and it must insist that both parties work cooperatively through a Commission-defined process to develop both a short- and long-term resolution that fulfills the National Broadband Plan’s recommendation that L Band spectrum be available for mobile broadband services. Specifically, the Commission should seek to mitigate GPS interference through the establishment of receiver standards and an equitable division of costs of mutual accommodation that address the incentives for incumbents to degrade the utility of adjacent spectrum bands. In addition, the Public Interest Organizations ask the Commission to support the coexistence of GPS and LTE services by refraining from reversing LightSquared’s integrated service waiver. In support of its request, the Public Interest Organizations point to the compelling public interest benefits of injecting into the mobile broadband market a competition-spurring wholesale carrier entrant into an increasingly uncompetitive market.

1 In the Matter of LightSquared LLC Request for Modification of its Authority for an
Ancillary Terrestrial Component, Order and Authorization, 26 FCC Rcd 566, 588, ¶ 48 (rel. Jan.
26, 2011) (“O&A”).
2 See Application of LightSquared for Modification of its MSS ATC Authority, SATMOD-
20101118-00239, at 1 (filed Nov.18, 2010) (“November 18th Letter”).

"The public interest benefits of a wholesale carrier in the increasingly uncompetitive mobile broadband marketplace are too compelling to forfeit when technical and/or policy paths are available to sustain both [GPS and mobile satellite] services."