If, like me, you have been following the long-running saga in which Ligado is seeking the FCC's permission to use the long dormant L-Band spectrum, you definitely should read the December 9 letter from former NASA Administrator Daniel Goldin to FCC Chairman Ajit Pai. Mr. Goldin's letter is here.
Please read the entire letter – the essence of which is to vigorously contest NTIA's position that Ligado's applications, which seek to deploy a hybrid terrestrial-satellite network in the L-Band that will provide “Internet of Things” services and boost America’s position in the global race to 5G, should not be granted.
In the meantime, here are a few key excerpts:
- On 5G, we have fallen behind, and badly. Of most immediate concern is the lack of available, appropriate spectrum for our wireless carriers to deploy. I have spent countless hours educating myself alongside a team of world class telecom executives and spectrum technical experts on these issues, notably L-Band's ability to drastically shorten the timeline for the U.S. to deploy 5G and truly compete with China. I am convinced the technological and policy justifications for allowing this "Ligado" modification to proceed are sound.
- This 35 MHz is not just one spectrum option to advance 5G. Properly understood, it is absolutely critical to a viable U.S. 5G deployment strategy.
- Simply put, GPS is not at risk I have studied the record. I have worked with an unparalleled technical team, and over 5000 hours of testing has shown there is no harmful interference. Globally recognized experts continue to refute all claims alleging actual degradation of GPS devices.
- As it relates to a 1DB C/N out-of-band standard for interference, I agree that we cannot and will not set this unprecedented standard. Doing so would result in the FCC having to revoke substantial amounts of other adjacent spectrum already deployed. Setting such an unreasonably restrictive standard would also have catastrophic consequences on future spectrum in the pipeline. It is possible to protect GPS and still issue the L-Band license modification order; we must do both.
- c Of course, historically, the U.S. has transitioned new spectrum many times. There is always a strong push to preserve the status quo.
I do not purport to be an expert regarding spectrum interference or other engineering matters – although I know a heck of a lot more in this regard than I did over four decades ago when I first began participating in and studying Commission proceedings. I have a high degree of confidence that the FCC's engineers possess sufficient expertise to determine whether Mr. Goldin's and others' assertions regarding the 1DB C/N out-of-band standard for interference are correct. The notion that, if such a 1DB C/N out-of-band standard is adopted the Commission would be required to revoke a substantial amount of already-deployed spectrum, is surely troubling.
While I do not purport to be a spectrum engineering expert, I do consider myself an expert, by dent of considerable practical experience and "battle scars" as well as scholarly study and academic endeavors, regarding the operation of institutional bureaucratic and "public choice" imperatives frequently at work in agency matters. The fact of the matter is that there are incentives for one party or another to use the available administrative processes to protect its turf, and spectrum proceedings – including those involving government agencies – are by no means immune from this "self-protective" phenomenon. As Mr. Goldin aptly puts it, "[t]here is always a strong push to preserve the status quo."
In this instance, I submit, for the reasons Mr. Goldin cites, especially including the need to make available mid-band spectrum so that the U.S. does not fall behind China (or other nations) in the race to deploy 5G, that it is very important for the FCC to reject the urge to preserve the status quo. The Commission needs to move ahead to act on Ligado's long-pending applications. As Mr. Goldin puts it, "the stakes are too high not to act."
It would be wrong, of course, for the FCC not to give due consideration to NTIA's views regarding impacts on the use of government spectrum, especially including impacts on national security. Presumably, the FCC already has done so in preparing a draft order, and if it hasn't, it should.
At the end of the day, however, the FCC is an independent agency that must exercise its responsibility, based on its presumed expertise, to oversee the use of spectrum designated for private sector use in a way that serves the overall public interest.
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