LightSquared Burn Out
February 9, 2012 By: Eric GakstatterSurvey Scene, February 2012
The LightSquared debate has been fascinating to watch as it has unfolded over the past year. In my 20+ years of involvement in the GPS/GNSS industry, nothing has come close to matching the mix of technical and political complexity that has the potential of reaching nearly each and every high-precision GPS/GNSS user in the United States. The industry’s destiny is somewhat controlled by a federal agency that is not very knowledgeable about how, when and where GPS is used, although I’m sure they’ve learned a lot in the past year, especially with respect to the high-precision GPS/GNSS markets. Furthermore, while the GPS/GNSS receiver manufacturer have a firm grip on the technical complications of what LightSquared is proposing, they are jockeying for market position so information released to the public is being filtered through their marketing heads. Lastly, the media coverage is all over the place; from “LightSquared is doomed” to “this is likely going to happen”.
I've been a bit silent on this issue the past 60 days or so (unless you follow me on Twitter, where I've been quite active). Part of it is because a lot of "news" you are reading is just noise, but partly because I also suffer from a mild case of LightSquared B.O. No, it's not a foul fragrant affliction that one contracts when the political maneuvering reaches a certain unpalatable threshold, but rather I've suffered from LightSquared Burn Out.
Not to fear, I'm cured and ready to rock. Let's start with the latest happenings that contain substance.
On January 13, 2012, the U.S. Deputy Secretary of Defense (Ashton Carter) and the U.S. Deputy Secretary of Transportation (John Porcari) sent a memo to the U.S. Department of Commerce Assistant Secretary for Communications and Information - NTIA (Lawrence Strickling), under the letterhead of the Space-Based Positioning Navigation & Timing National Executive Committee (PNT Excom) stating that:
"the unanimous conclusion of the test findings by the PNT Excom Agencies that both LightSquared's original and modified plans for its proposed mobile network would cause harmful interference to many GPS receivers. Additionally, an analysis by the Federal Aviation Administration (FAA) has concluded that the LightSquared proposals are not compatible with several GPS-dependent aircraft safety-of-flight systems. Based upon this testing and analysis, there appear to be no practical solutions or mitigations that would permit the LightSquared broadband service, as proposed, to operate in the next few months or years without significantly interfering with GPS. As a result, no additional testing is warranted at this time."
If you recall in May of last year, I wrote that the high-precision GPS user community would likely be thrown under the bus. Precisely, I wrote:
"I’m going to keep this simple. You, the high-precision GPS user, are likely going to be considered collateral damage.
The military is going to be accommodated in the name of national security. The aviation industry is going to be accommodated in the name of safety-of-life..."
Well, it just so happens that LightSquared can't accomodate military GPS users nor aviation GPS users. Those of you who use high-precision GPS can count your lucky stars that high-precision GPS users have the military and aviation folks standing in your corner.
The January 13, 2012 letter was further supported by testimony from U.S. Deputy Secretary of Transportation John Porcari at Wednesday's House subcommittee meeting on GPS and aviation. In it, Mr. Porcari reiterated that "there appears to be no practical solutions or mitigations that would permit LightSquared broadband service, as proposed, to operate in the next few months or years without significantly interfering with GPS". Furthermore, he testified that the FAA spent over $2 million of taxpayer dollars with two different independent labs to arrive at its conclusion, and that further investment in testing cannot be justified. It wasn't a good day for LightSquared. In fact, probably the worst one yet.
February 8, 2012 House Congressional Subcommittee Hearing on GPS and Aviation
Don't expect the Department of Defense (DoD) to provide similar testimony at a public hearing. They will play their "veto card" off-air and out of the public eye, but after the January 13th letter, it's a safe bet that it will be played, if it hasn't already.
After a December 2011 U.S. Federal government report noted that in the second round of testing 75 percent of GPS receivers examined were interfered with at a distance of 100 meters from a LightSquared base station, LightSquared has seemingly resigned itself that it has no solid technical argument other than picking at test criteria.
After the December test report, LightSquared hit back and called the testing unfair.
LightSquared reportedly believes that up to 8dB is acceptable interference while the NTIA set at 1dB, which is the same level they used in the ultra-wideband spectrum debate of years past. The rumor is that the FCC is/was considering "splitting the difference". That would be disasterous for the high-precision GPS user community. Can you imagine losing 4dB in signal strength, especially considering semicodeless technique that L1/L2 receivers employ?
Another technical tidbit that LightSquared is arguing about is the propogation model used during testing. The NTIA choose to use neither a model proposed by the GPS folks (free space) nor what LightSquared asked for. A compromise of sorts.
LightSquared also complained that the "testing protocol deliberately focused on obsolete and niche market devices". A source close to the testing told me that LightSquared had full access to the list of devices to be tested beforehand. Also, if you recall from an article I wrote last year, the U.S. Bureau of Land Management (BLM) reported that the device least affected during their testing was a 15 year old Trimble GeoExplorer 3. The fact is that newer GPS receivers are using more and more of the spectrum allocated for GPS/GNSS and that trend will likely continue as GNSS receivers (GPS, GLONASS, Galileo, Compass) become the norm. I would think LightSquared might be pleased that some narrow-band GPS receivers were used.
LightSquared also continues to complain about GPS receivers "looking into our spectrum" as the reason for the interference GPS receivers are suffering. If you missed Richard Keegan's December 2011 article in GPS World, you should take a look at it. He succinctly addresses this issue in addition to an article I wrote in November 2011 about LightSquared profiting from the high-precision GPS user community while simultaneously complaining about high-precision GPS receivers "looking into our spectrum".
As LightSquared has clearly lost the engineering argument, it has taken a very creative approach in an attempt to convince the FCC that this isn't an engineering problem, but rather all about the FCC rules.
GPS Receivers Are Not Entitled to Interference Protection
In a new, fascinating twist, lawyer style, LightSquared is petitioning the FCC to confirm that "GPS devices are not entitled to protection from interference".
A crazy statement? If you think so, consider the following.
Do you recall ever reading the following statement on electronic devices (eg. GPS receivers)? That statement (or a similar one) is on almost every electronic device that relies on radio signals.
"This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions:
What if LightSquared can convince the FCC that GPS receivers do, indeed, fall within the confines of Part 15 of the FCC rules and aren't entitled to interference protection?
That's what LightSquared is trying to do and that's why this battle isn't over. You can read LightSquared's entire submission to the FCC here (Part 1) and here (Part 2).
Specifically, LightSquared is trying to convince the FCC that:
1. Manufacturers and users of unlicensed commercial GPS receivers lack standing to file complaints or other pleadings seeking "protection" from allegedly incompatible operations in adjacent MSS bands - including ATC operations - that are permitted by the Commission's rules and the U.S. Table of Frequency Allocations.
2. Commercial GPS receivers have no independent right to "protection" from operations in adjacent MSS bands, independent of the license conditions that limit the out-of-band power that may be emitted by MSS band transmitters into the RNSS band, and other than the benefit afforded by the guard band that should separate LightSquared's terrestrial operations in the MSS band from commercial GPS operations in the RNSS band.
3. Commercial GPS devices that receive GPS signals in the MSS band are "nonconforming" and inconsistent with the MSS allocation in that band, and as such are not entitled to any "protection" regardless of whether they are licensed.
4. The costs of ensuring that GPS devices are compatible with adjacent band operations - including any costs necessary to retrofit legacy devices are the responsibility of GPS manufacturers--or, at a minimum, are not the obligation of MSS/ ATC licensees.
Clearly, LightSquared's Petition has caught the FCC's attention, so much so that the FCC have opened a public comment period that closes on February 27, 2012. Reply comments are due by March 13, 2012. Details of how to file are in the February 2012 issue of ACSM Bulletin.
I will be submitting my comments and I hope you do too. Yes, the DoD and DoT have made their point clear, but don't underestimate the power of the Whitehouse pushing the National Broadband Plan. Even Mr. Porcari stated during his testimony on Wednesday that:
"Now, as you know, the LightSquared corporation has proposed to create a wireless broadband network. In the Obama administration, we believe deeply in what LightSquared is attempting to do, which is to make the Internet more accessible to more people all across the country. This is an urgent national priority."
Wouldn't LightSquared's network provide ubiquitous communications for my RTK operations?
I've heard and/or read statements from some people within the GPS industry who believe that the LightSquared service will do wonders for RTK operations, somehow replacing the communications methods we currently use (UHF/VHF, 900MHz, GSM/GPRS, CDMA, Wifi/Mifi, etc.). You may choose to believe it, but I don't. Here's why...
LightSquared is relying on Sprint's infrastructure (~31,000 towers) for their terrestrial operations, and supplementing them with ~3,400 LightSquared towers at some point. I've used Sprint's mobile phone service for about 12 years and I used Sprint's data card service for several years (not any longer). I pretty much know that Sprint is good for metro areas and poor for rural areas. Like other wireless providers (AT&T, Verizon, T-Mobile, etc.), Sprint is strong in some geographic areas, and weak in others. Since LightSquared is focused on serving people (densely populated areas) rather than geographic areas (eg. farmlands), their terrestrial service is not going to be even close to being nationwide. LightSquared's solution for areas not covered by their terrestrial service is to use satellite communications for internet connectivity. If you want to know more about this, read Tim Farrar's blog on the subject which includes a map of LightSquared's terrestrial coverage. I've asked LightSquared for the most current deployment map, but received no response. I've been unable to find it even in their FCC filings (maybe you can), but I have to believe that if it was something to be proud of, they would be showing it to everyone.
If you think that you'll enjoy ubiquitous coverage with satellite communications for your RTK operations, think about OmniSTAR's service which is in the same spectrum as what LightSquared proposes. OmniSTAR works great when there's a clear view of the sky to one of OmniSTAR's satellites (ironically, operated by LightSquared) such as in the agriculture industry, but I've used it a bit and it doesn't work in buildings, in vehicles, under trees or any other location where the sky is obstructed (similar to GPS). Can you imagine using a LightSquared mobile phone that doesn't work in buildings, in cars, or under trees? You wouldn't. Furthermore, anyone who's ever used RTK knows that spotty base/rover communications is the quickest way to spoil an RTK party. With GPS/GLONASS receivers allowing us to use RTK in places where we've rarely ventured before, the limitation wouldn't be the number of navigation satellites in view, but rather if the LightSquared satellite was in view.
In his testimony, Mr. Porcari stated that in the aviation industry alone, 60,000 receiver upgrades would cost $40,000 each equaling $2.4 billion. I think that's conservative because I doubt it covers the infrastructure upgrade cost (WAAS, GBAS, etc.) or the cost of NextGen program delays.
How about something closer to home?
I queried the administrator of a statewide RTK Network that consists of 103 GNSS reference stations. I asked him what he estimates his costs would be to upgrade all of his reference stations in his network, excluding the cost of the actual GNSS hardware and assuming at least the antenna would need to be replaced and perhaps the receiver.
According to him, the upgrade procedure would be a “staged” replacement (vs. replacing all at once). A temporary unit would be setup near existing site. 10 x 24 hour data sets would be collected and analyzed to geodetically certify the temporary site after which legacy receiver/antenna is sent to the manufacturer.
After modified receiver/antenna is received back from manufacturer, it needs to be installed and tested along with existing (possibly new) cabling. Again, 10 x 24 hour data sets need to be collected and analyzed to geodetically certify the new equipment.
Six receiver/antenna sets would need to be purchased to be used as temporary CORS to facilitate the upgrade of 103 units over a six month period. Remember, during the upgrade, they have to provide the same level of service to their users.
The network of 103 receivers consists of ten different makes/models. Each variation has to be tested. Additionally, each new antenna design must be modeled and associated software needs to be upgraded to include the new antenna models.
Generally, the task/costs line items are as follows.
- Purchase six temp receiver/antenna combinations
- Geodetic certification process for temporary stations
- Test upgraded receivers/antennas
- Cable/terminations/communications hardware
- Geodetic certification process for upgraded stations
- Misc. install services/hardware (bucket truck rental, cable runs, tools)
- Two trips to each site (labor)
- Travel cost (some overnights required)
The total estimate for labor/materials, not including the cost of the receiver/antenna upgrade, is $7,200.
$7,200 x 103 receivers = $741,600.
Optimistic: $2,000 x 103 receivers = $206,000
Likely: $6,000 x 103 receivers = $618,000
Pessimistic: $10,000 x 103 receivers = $1,030,000
Optimistic: $741,600 + $206,000 = $947,600 ($9,200 per receiver)
Likely: $741,600 + $618,000 = $1,359,600 ($13,200 per receiver)
Pessimistic: $741,600 + $1,030,000 = $1,771,600 ($17,200 per receiver)
Optimistic: $50,400,000 + $14,000,000 = $64,400,000
Likely: $50,400,000 + $42,000,000 = $92,400,000
Pessimistic: $50,400,000 + $70,000,000 = $120,400,000
Keep in mind that this is only the high-precision GPS/GNSS infrastructure in the U.S.
There are still hundreds of thousands of high-precision GPS/GNSS receivers owned by high-precision GPS/GNSS users across the U.S. that would have to be upgraded at a cost of $2,000-$10,000 per receiver. For many GPS receivers (think handheld), there will be no upgrade solution so the manufacturer may offer trade-in credit for a new GPS receiver.
Of course, the installation cost of upgrading user equipment will not be as high, but don't fool yourself into believing it's just a matter of swapping antennas and/or receivers, and it's not going to be a few hundred dollars. Not by a long shot.
After spending time to understand the actual costs of accomodating LightSquared, one state legislator who initially voiced his support for LightSquared said "we can't afford it".
Then, there's the cost of upgrading military GPS receivers (hundreds of thousands, if not more than one million)...that's a story for another day.
Letter to the Editor
[Response to “Should GPS Users Accept New ‘Fees’?” by Gavin M. Schrock, published in GPS World Survey Scene newsletter.]
I have to admit that it was Eric Gakstatter’s introductory remarks that “He [the author G M Schrock] is usually not as cynical as he is when facing potential forced upgrades/replacements/production losses for his profession and the GNSS community” that made me read Schrock’s article “Should GPS Users Accept New ‘Fees’?” (Survey, January 12, 2012). Having read it, unfortunately I must admit that I didn’t learn anything.
Since I see no useful purpose for responding in detail to Mr. Schrock’s line of thinking, I do offer the following remarks:
In January of 1983, I gave a workshop on Geodetic Surveying with GPS at Penn State University in connection with the densification of the Montgomery County Network. Perhaps some readers might recall those early days of GPS satellite surveying. The receiver at the time was the Macrometer, developed at M.I.T., that needed two able-bodied men to move it. Clearly, where would we be now if we had ignored signs of progress and subsequent innovations? More to the point, a major portion of the attendees were specialized in building Bilby Towers (I wonder if the reader still remembers them). You can imagine their facial expressions after my presentation. However, none of them got the idea to recast their actual loss of business and need to refocus as a “fee” imposed on them.
A similar situation developed much later when narrow-correlating receivers were introduced. Various manufacturers scrambled to follow the lead manufacturer in updating their receivers. Again, I do not recall any surveyors, who upgraded their receivers, talking about a “fee” being imposed on them. Actually, the situation with the narrow-correlating receivers is very similar to that of the new filtering now causing the uproar. It was easy to implement once you had thought about it and it could readily be implemented by all manufacturers of high-accuracy receivers. Actually, I recall listening to one speaker at an annual ION meeting, who was surprised that nobody had thought about this before, and yet we had worked with substandard receiver technology for so long.
Fortunately, there are exceptionally qualified and innovative engineers in the GPS receiver manufacturing industry. This talented pool of individuals will always be innovative. I am sure that even Mr. Schrock recognized that. What I find most disturbing, therefore, is his concluding paragraph where he is actually negative toward those capable engineers who were the first to develop a solution to the LightSquared challenge and who sketched innovative approaches to geodetic networks. I do not recall a case in my 30+ year career in GPS when the success of researcher and innovators was held against them. It is even obvious to a fellow from academia that private industry advertises the use of their innovations. We should be pleased to have such brilliant engineers caring for geodetic applications. Furthermore, it is belittling the business sense of surveyors to insinuate that they would only buy from manufacturers who might either be “late to the game” or might have failed to secure a Plan B in times of rapid technological change. The laws of the market do not work like that.
Although the LightSquared issues might be resolved soon one way or the other, either completely or partially, similar situations might arise and we will be looking again to outstanding engineers to find solutions.
Alfred Leick is Professor in at the School of Computing and Information Science at the University of Maine, author of the book GPS Satellite Surveying, author of the GPS-GAP online course series, and Editor In Chief of the peer-reviewed journal GPS Solutions, published by Springer Verlag.
Schrock response: I am not against innovation or outstanding engineers nobly innovate. Innovation is an imperative. But only if such innovation is bourn of responsible actions. There is NO negativity to the fine engineers developing solutions. But there is a big difference between developing solutions for a new hazard, and actively advocating for the rapid precipitation of the new hazard – cavalier disregard for those who will have to pay for it, their livelihoods, safety, and security. Are we well served by simply acquiescing without question or scrutiny?
About the Author: Eric Gakstatter
RSS
Become a Fan
Join our Network
Follow Us
Please send any technical comments or questions to our webmaster.