Inside GNSS Media & Research

JUL-AUG 2019

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Page 20 of 67 J U L Y / A U G U S T 2 0 1 9 Inside GNSS 21 ough that seems straightforward it is not entirely clear how the firm's request will be handled. The Commission has considered a handful of cases under Section 7 on an ad hoc basis, the FCC wrote in a February 2018 Notice of Proposed Rulemaking. That NPRM, how- ever, is specifically underway to set the rules for how Section 7 will be implemented. In other words the process for handling Section 7 requests is in the middle of being changed. Among the matters that the FCC is considering is how to decide if a technology is actually new, including how to handle things like incremental improvements. Regulators are also proposing that, given the tight 1-year deadline, applications under Section 7 include a separate section demonstrat- ing that a new technology or service is both technically feasible and available for commercial use. e GPS Innovation Alliance (GPSIA) said in its comments on the proposed rule that an applicant should have to demonstrate that "its innovation can successfully transi- tion from a laboratory environment to a production environment as well as a 'real world' environment" and that its equipment can be produced using commercially available com- ponents and representative manufac- turing techniques. is can be a real issue. During the early days of the LightSquared debate there was a prob- lem getting the new network equip- ment to test to see if it caused interfer- ence to GPS receivers. e new offerings also need to be consistent with the Commission's spec- trum management responsibilities, the GPSIA wrote. "In the case of any proposed new service or technology that will use spectrum in or adjacent to bands that support navigation services, the public interest review must take into con- sideration fundamental distinctions among different services—particularly navigation and communications ser- vices and their different levels of sus- ceptibility to potential interference," the GPSIA said. "e Commission should therefore recognize, as part of this review and its application of core spectrum management principles, the impact that a 1 dB decrease in the carrier-to-noise density ratio ("C/N0") has on navigation services and the actions that any proponents of new transmission technologies can, and as a matter of public policy should, take to protect against these decreases." The Upshot So where does that leave the Ligado proposal? Ligado is pushing for a deci- sion under Section 7 and insists that the record is complete. e firm also insists that it has addressed issues of GPS interference (despite the points noted above) and concerns raised by Iridium and INMARSAT, two other satellites firms. Ligado also refers to the NTIA in its Section 7 application, an agency of the previously mentioned Department of Commerce, asserting that it has had its input. "Ligado also understands that dur- ing this time the Commission has held numerous discussions with NTIA staff concerning the license modification applications and how Ligado's spec- trum plan can co-exist with users in adjacent bands," the firm wrote in its section 7 request. But there's more to the NTIA element than that. As noted in the background, during the LightSquared controversy the NTIA sent a letter to the FCC laying out the government's GPS interference test results. That letter fed into the decision to deny the LightSquared request. Under government proce- dure the NTIA is supposed to send another letter to the FCC, as it did before, articulating the executive branch's position. Inside GNSS has found no hint that that has hap- pened. Given the public opposi- tion of the PNT Advisory Board, the opposition of a number of the ExCom agencies and the data from DOT's ABC tests, it would seem likely that a new NTIA letter would oppose approval of Ligado's plan. One can't help but wonder if NTIA is the government agency Ligado may actually be taking aim at when it refers to politics—hoping its Section 7 request will speed an FCC decision, even if it's without a recommendation from the NTIA. "Aer more than 1,200 days," Ligado wrote, "any government agency interested in this proceeding and in 5G deployment considerations has had more than enough time and opportunity to bring forth its formal views. Waiting indefinitely for any further input from another govern- ment agency would effectively grant that agency a veto—contrary to the authority vested in the Commission by the Communications Act—and would flout the direction of Congress under Section 7 that the Commission decide these kinds of applications expeditiously." Waiting indefinitely for any further input from another government agency would effectively grant that agency a veto —contrary to the authority vested in the Commission by the Communications Act— and would flout the direction of Congress under Section 7 that the Commission decide these kinds of applications expeditiously." Ligado Networks "

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