Federal Agencies: LightSquared Unacceptable Safety, Environmental, Economic Consequences
October 11, 2011In the public interest, the U.S. House of Representatives Committee on Science, Space, and Technology has released some of the impact statements provided by federal agencies to the National Telecommunications and Information Administration (NTIA). The reports reveal deep concerns about and opposition to the LightSquared proposal, and detail cost estimates and other adverse impacts to government-wide operations should it go forward.
The NTIA itself has refused to make these agency reports public, rebuffing a Freedom of Information Act (FOIA) request by GPS World magazine and, so far, giving the same response to Congressional committees on both the House and Senate side.
The House Committee does not yet have access to all the agency statements; still missing are those from the Department of Homeland Security (DHS), the Department of Commerce (DOC), the National Oceanic and Atmospheric Administration (NOAA), and the National Institutes of Standards and Technology (NIST). The committee has written to those departments asking for their reports; GPS World has also filed further FOIA requests specifically with those agencies. The Department of Defense impact statement is presumed to be classified.
The Federal Aviation Administration (FAA) impact statement is the strongest. The FAA stated, among many other findings, that the LightSquared proposal would cost the aviation community at least $72 billion, preclude elimination/reduction of an estimated 794 air-traffic fatalities over the next 10 years, set back planned air-traffic safety and efficiency measures by that same period, affect U.S. leadership in aviation, and damage the international market for U.S. satellite technology.
“FAA cannot conclude that operations using just the lower portion of the spectrum are compatible with civil aircraft receivers without definition of LightSquared’s end-state deployment and further study," the FAA said. “Proposed LightSquared deployment (both upper and lower channels by 2014) would result in an estimated aviation community cost impact of at least $72 billion and delay NextGen implementation by approximately 10 years.
“Proposed LightSquared operations would severely impact the efficiency and modernization of the safest, most efficient aerospace system in the world.”
The full FAA impact statement is available here.
The National Aeronautics and Space Administration filed this statement:
“NASA has extensive use of the GPS for positioning, navigation, and timing, as wel as many science applications. NASA would like to highlight its use, as well as other federal and commercial users, of high-precision receivers. We have seen no evidence that these receivers can be filtered without significantly reducing receiver accuracy and performance, which may render the receivers incapable of performing the science and commercial missions for which they were designed. In addition, LightSquared, in its Recommendations, suggested possible filtering for the TriG receiver [A GNSS precise-orbit and radio-occultation space receiver]. This was not examined in the Technical Working Group (TWG), and since this receiver will use the signals of multiple GNSS constellations, filtering may not be possible without negatively affecting receiver performance and mission objectives," the FAA said.
“NASA is very concerned with LightSquared’s Recommendations, as it also articulates a partial solution, use of just the lower 1-MHz on a temporary basis, to its need for deployment of a robust high-density terrestrial network. LightSquared has indicated, in meetings with Federal agencies and filing in this proceeding, that the upper 10-MHz is needed to provide a viable 4G LTE service.
“NASA requests that NTIA solicit the FCC on LightSquared’s intended use of the exclusive lower-10 MHz, and its adquacty for a competitive wireless service. NASA feels that due to the severity of the operational impacts, to both government and commercial users, it is conclusive that LightSquared’s implementation on the upper 10-MHz is not feasible in the near or long-term.”
The Department of Transportation (DOT) statement recaps the highlights of the FAA report, and then outlines effects in rail, maritime, and road transport, concluding with a section on the NDGPS.
- Railroads would face increased costs of up to $25 billion over 20 years to re-equip were GPS degraded or unavailable, and would lose productivity gains (“most of which accrue to society at large) of up to $29 billion.
- “The dollar value on potential contributory ship groundings, collisions, and allusion could run into tens of billions of dollars in hull, cargo, and oil pollution costs, not to mention injuries and loss of life as well as economic losses to ports and corporations negatively impacted by a related incident. Any interference or degradation of the GPS signal through LightSquared utilization of interfering frequency bands is unacceptable due to potential safety, environmental, and economic consequences. Likewise, the retrofit of GPS marine equipment with filters or other fixes is not practical from a deployment of an economic perspective.
- LightSquared will prevent the successful operation of vehicle-to-vehicle and vehicle-to-infrastructure safety applications, “eliminate[ing] . . . the opportunity to reduces crashes, injuries, and fatalities.” Further, “significant transportation benefits such as decreased travel times, fuel savings, and corresponding environmental benefits . . . would most likely be lost.”
- The Nationwide Differential GPS (NDGPS) would be unable to operate if LightSquared operations were allowed to proceed as planned. NDGPS supplies a growing public and private-sector reliance for transportation, agricultural, environmental, natural resource management, surveying, weather forecasting, and other applications.”
The Department of the Interior statement reviewed many GPS applications in which DOI receivers were tested and found to be adversely impacted by LightSquared transmissions: survey, natural resources, wildfire, law enforcement, geospatial programs, and hazards. It concluded that “Department-wide replacement or modification [of GPS receivers] would be chaotic, expensive, and negatively influence the Department’s GPS applications.”
Other agencies were less communicative.
“The EPA expects that the assessments developed by other departments represent our best interests and provide an accurate depiction of federal-wide concerns about the issuance of the LightSquared spectrum license,” the Environmental Protection Agency responded.
“DOE has not been asked to conduct such an assessment, and has not done so,” the Department of Energy averred.
“The [National Science] Foundation has not provided any assessment to the NTIA on this issue, so I have nothing to provide to the committee.”
This page provides PDFs of impact statements from the departments of Energy, Transportation, and Interior, and the Environmental Protection Agency, the National Aeronautics and Space Agency, the National Science Foundation, and the Federal Aviation Administration.
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