What Others Are Saying
Diana Furchtgott-Roth
Former deputy assistant secretary for research and development at the U.S. Department of Transportation
"But now the entire GPS system is endangered by a misguided decision the Federal Communications Commission made during the Trump administration. GPS is vulnerable to interference from ground-based transmissions, yet last April the FCC unanimously granted an application by Ligado Networks, based in Reston, Va., to offer a ground-based 5G service in spectrum, much of which is next to spectrum allocated for GPS."
Capt. Chesley “Sully” Sullenberger
“Miracle on the Hudson” pilot
Statement for the Record to the Space Based Positioning, Navigation, and Timing Advisory Board
"The FCC’s decision to approve Ligado Networks’ use of a portion of the L-band spectrum is ill-advised, and constitutes a dereliction of duty on the FCC’s part. Frequency spectrum is a precious national asset and we are all obligated to protect it. Not only does this decision benefit just the shareholders of one company, but it is a dangerous decision that must be reversed."
“Independent testing and analyses conducted by nine federal departments and agencies show that allowing Ligado's proposed system—including its proposed modifications—to operate in close proximity to the GPS spectrum would cause harmful interference to millions of GPS receivers across the U.S. The FCC's decision will disrupt the daily lives and commerce of millions of Americans and inject unacceptable risk into systems that are critical for emergency response, aviation and missile defense. Further, it will stunt innovation in GPS; people won't use the system if they can't depend on it everywhere, all the time. For these and many other reasons, 13 federal agencies, along with leaders from a range of industries, called on the FCC to deny the Ligado request.
The first and most sacred responsibility of government is to protect and defend its people. GPS allows us to pinpoint 911 calls, launch precision airstrikes, prepare our forces for combat, and otherwise act to safeguard health and well-being. Interfering with the accuracy and reliability of GPS risks the safety of the American people and undermines national and economic security. America deserves a better alternative.”
“Historically, the FCC has worked collaboratively with NTIA and other federal stakeholders to reach reasonable and mutually satisfactory solutions to governmental concerns, including concerns significantly less alarming than those raised in this matter. Here, the Commission made little, if any, cognizable effort to accommodate federal concerns, and it surely did not ‘resolve’ such concerns, as Section 343 of the Communications Act requires. This omission in and of itself warrants grant of a stay to maintain the status quo while the Commission corrects this error.”
“The Commission’s utter disregard for Executive Branch concerns regarding harmful interference to federal GPS devices standing alone is sufficient to warrant a stay, let alone the other serious issues with the Order and the potential for harm to public safety described herein.”
“We write to you to express our deep concern with the commission’s approval of the subject proceeding. The national security community was unanimous in the judgement that approval of the use of certain portions of the L band spectrum could pose an unacceptable risk to the use of the Global Positioning System (GPS) in the United States. In addition, other federal and nonfederal users of this spectrum have raised serious concerns, including satellite communications providers and airlines.”
“We are concerned that your approval of any mitigation efforts not rigorously tested and approved by national security technical experts may be inconsistent with the legislative direction to resolve concerns prior to permitting commercial terrestrial operations. We urge the commission to reconsider and impose additional mitigation steps to address the concerns of these users.”
“In adopting the Ligado Order, the Commission effectively permitted the construction and operation of a 24/7 outdoor concert venue, whose speaker volume deprives neighbors even blocks away from the enjoyment of their otherwise quiet, residential community. Despite the strong concerns of and opposition from a wide array of private sector and government experts and stakeholders in this community, and a record replete with evidence that granting Ligado’s proposal would cause harmful interference, the Commission ignored material questions of fact, did not properly weigh the costs and benefits of Ligado’s proposal, and offered a series of “remedies” that are patently inadequate.”
“Had the Commission conducted a rigorous cost-benefit analysis consistent with its existing policies and the Executive Branch’s executive order regarding the total incremental cost of all new regulations, it would have found that the costs imposed by the Applications are significant and far outweigh the at-best-speculative benefits.”
“The Order, at bottom, puts air safety and aviation operations at risk for the benefit of a private company with dubious claims on providing the benefits of advanced communications in a small amount of spectrum.”
“As a consequence of the Order, taken as a whole, the public should expect adverse and serious nationwide impacts on aviation and safety-of-flight, in particular, as well as on national and homeland security, agriculture, ground transportation, maritime users, and other sectors of the U.S. economy.”
Association of Equipment Manufacturers, The American Farm Bureau and the American Road & Transportation Builders Association
May 22, 2020
“The Commission's conclusion that it should require Ligado to compensate federal, but not private, entities for the repair and replacement of GPS devices lacks any support in FCC precedent, and its related decision to require everyday users of GPS devices to notify Ligado of interference and bear the burden of proof of interference turns sound spectrum management on its head.”
“The Commission expects everyday businesses and consumers using GPS devices, upon becoming aware of harmful interference from Ligado's network, to contact Ligado using a toll-free number. But equipment manufacturers, farmers, road construction companies, and others are not in the communications business, and do not, unlike the companies the FCC is used to dealing with, employ communications engineers or FCC lawyers.”
Aireon LLC, Iridium Communications Inc, Flyht Aerospace Solutions Ltd and Skytrac Systems Ltd
May 22, 2020
“The Order repeatedly dismisses concerns regarding likely interference on the flimsiest of grounds, uncritically regurgitating Ligado’s claims and rejecting in conclusory fashion technical analysis by Iridium, NTIA, and DOD proving harm caused by Ligado’s operations.”
“If Ligado showed no interest in meaningfully remedying expected interference while its applications were pending, there is no reason to think it has any incentive to reach arrangements that are “satisfactory to both parties” now, with or without the agency’s ‘encourage[ment].’”
“The Order’s public-interest discussion is based not on analysis of the claimed benefits, but rather on a rote, reflexive recitation of Ligado’s advocacy points.”
National Telecommunications and Information Administration
May 22, 2020
Petition for Reconsideration or Clarification
May 22, 2020
“Ligado should not be permitted to deploy its network until NTIA’s Petition for Reconsideration or Clarification (Petition) is addressed and executive branch concerns of harmful interference to federal government and other GPS devices are satisfactorily resolved.”
“The Ligado Order places great weight on the Commission’s conclusion that harmful interference to GPS devices is unlikely. However, as the text of the Ligado Order and the several conditions therein disturbingly but correctly imply, harmful interference will arise.”
“It is crucial that the Commission acknowledge that further technical studies and testing must be undertaken to ensure that Ligado’s actual terrestrial network would not cause harmful interference to GPS and other authorized services before it is authorized to operate anywhere.”
“The Ligado Order’s incorrect or insufficient consideration of government-sponsored test results and inadequate license conditions will likely cause widespread harmful interference to millions of GPS receivers in the U.S., including those used to support national and homeland security operations as well as public safety. Even if there is no immediately recognizable interference to GPS operations, the mad scramble to prevent such interference on an involuntary and unfunded basis is bound to have profound impacts for years to come.”
Dana Deasy
Chief Information Officer, Department of Defense
Testimony of Dana Deasy from U.S. Senate Committee on Armed Services Hearing: Department of Defense Spectrum Policy and the Impact of the Federal Communications Commission’s Ligado Decision on National Security
May 6, 2020
“The Department believes this FCC ruling increases the risk that American families and businesses may turn to foreign space-based navigation and timing systems like China’s BeiDou and Russia’s GLONASS, to replace the functions of GPS if it becomes unreliable due to interference from Ligado operations. This is fundamentally a bad deal for America’s national and economic security.”
“The bottom line is that there are too many unknowns and the risks are too great to allow the proposed Ligado system to proceed in light of the operational impact to GPS.”
“GPS allows us to pinpoint 911 calls, launch precision airstrikes, prepare our forces for combat, and engage in many other actions foundational to protecting the American public at large. Furthermore, the Department utilizes GPS to protect and serve the public by tracking national security and terrorist threats and building readiness to protect the homeland and our interests abroad. It is for this reason that the DoD strongly opposes the Ligado license modification request as not being in the best interest of our nation.”
Michael D. Griffin
Under Secretary of Defense for Research and Engineering
Testimony of Michael D. Griffin from U.S. Senate Committee on Armed Services Hearing: Department of Defense Spectrum Policy and the Impact of the Federal Communications Commission’s Ligado Decision on National Security
May 6, 2020
“GPS is not just a critical pillar of our national security, it is the foundation on which much of the United States’, indeed the world’s, current and future economy is built. To that point, if the recent decision of the Federal Communications Commission (FCC) to approve Ligado Network, LLC’s license modification petition is allowed to stand, it will undermine both our national defense and economic security.”
“Leaving entirely aside the national security implications of jamming our own military navigation system, if Ligado moves forward with establishing its network, we in the United States will have imposed a self-inflicted wound on GPS.”
Thad W. Allen
Admiral, U.S. Coast Guard (retired)
Testimony of Thad W. Allen from U.S. Senate Committee on Armed Services Hearing: Department of Defense Spectrum Policy and the Impact of the Federal Communications Commission’s Ligado Decision on National Security
May 6, 2020
“It seems to me, given the importance of GPS to the overall national interest, consideration should have been given to protecting and sustaining the overall spectral environment in which GPS operates.”
“The overall national interest is best served by ensuring that the national and global utility that is GPS is not disrupted or degraded.”
General John W. Raymond
Chief of Space Operations, U.S. Space Force; Commander, United States Space Command
Testimony of General John W. Raymond from U.S. Senate Committee on Armed Services Hearing: Department of Defense Spectrum Policy and the Impact of the Federal Communications Commission’s Ligado Decision on National Security
May 6, 2020
“As with military forces conducting our critical Homeland Defense mission, or training for combat in the United States, degradation of GPS signals can affect safety of flight for aircraft and other segments of the national transportation system; prevent first responders from finding their way to emergencies or communicate when they arrive, and affect the economic activity of every American.”
“I cannot take direct action to protect America’s use of GPS in the homeland, but I can provide awareness of the threats, the impacts of those threats on our joint military forces, and strongly advise against emitters that can negatively impact our ability to operate our critical space capabilities that fuel our American way of life and our American way of war.”