LightSquared Roundup: Comment Period Extended to March 16, 2012

On February 29, the FCC granted LightSquared’s request to extend the comment period for the public notice inviting input regarding the results of government testing on potential interference and proposals addressing those results.   The Coalition to Save Our GPS, of which NCC is a member, opposed the original request for a 30 day extension, but was amenable to a 10 day extension.  The comment period was extended from March 1 until March 16; additional reply comments may be filed by March 30.

As you know the FCC moved on Feb. 14 to block LightSquared’s planned nationwide wireless network because the National Telecommunications Information Administration concluded that there are not enough effective mitigation measures to eliminate interference with GPS systems. (see cotton.org for more info). The FCC is accepting comments and NCC has drafted comments, which are pasted below, for consideration by interest organizations.  Please alter to suit your organization.  Instructions for  posting comments directly to the FCC website are also below.  The deadline to submit comments is now March 16, 2012.  Reply comments may be submitted by March 30, 2012.  Thank you for engaging in this important issue by submitting comments of your own.  Stakeholder support will help ensure that the FCC proceeds with withdrawing its waiver modifying LightSquared’s license to prohibit them from building a ground-based wireless network that would interfere with our use of GPS.

Please contact Christy Birdsong or John Maguire if you have questions.  202-745-7805

HOW TO FILE COMMENTS:

The FCC has an easy-to-use portal on its website to submit feedback on the Public Notice:

(1)  Click on this link for the FCC’s Electronic Comments Filing System (ECFS):  http://fjallfoss.fcc.gov/ecfs/upload/begin?procName=&filedFrom=X

(2)  In the box which says “Proceeding Number,” type:  11-109.  It is important to include this docket number with your comments.

(3)  In the designated boxes, enter (a) your name or your company’s name, and (b) your mailing address/city/state/zip.

(4)  In the box which says “Type in or paste your brief comments,” do so.  Click “Continue”.

(5)  A review page will load listing all of the information entered.  If correct, click “Confirm.” (6)  If you have trouble, contact the FCC ECFS Helpdesk at 202-418-0193 or e-mail at ecfshelp@fcc.gov.

SAMPLE LETTER:

We appreciate the opportunity to comment on a letter submitted by the National Telecommunications and Information Administration (NTIA) on February 14, 2012, concerning the results of government testing of the potential interference effects of communications equipment operator LightSquared Subsidiary LLC (LightSquared).  We support the Federal Communications Commission’s subsequent proposal to withdraw the January 2011 waiver that allowed LightSquared to proceed with its planned wireless network; and modify LightSquared’s satellite license to prohibit LightSquared from building any ground-based wireless network.

We have been closely watching the FCC proceedings regarding LightSquared, as GPS technology is vital to the continued efficiency of cotton production.  American cotton farmers depend on GPS tools in meeting their need for precision in modern agricultural practices.   GPS, combined with on-board yield sensor technology,   provides detailed information and coordinates for optimal planting, targeted pesticide application, and efficient irrigation.  Accuracy in irrigation helps farmers to conserve water, and precise applications of pesticides reduce farmworker and wildlife exposure in the fields.  For these tools to provide necessary returns to a producer, the precision of location identification is critical. This is especially true for a management-intensive crop such as cotton.   Allowing the LightSquared proposal to go forward would infringe upon the bandwidth used by agricultural GPS, impact the accuracy upon which precision agriculture applications depend and seriously compromise its overall effectiveness.  Cotton farmers would have one less tool in providing food and fiber for a growing population.

The interference studies released by the Federal government on February 14 clearly demonstrate that LightSquared’s network interferes with GPS and that there are no practical fixes to solve that interference.  While more capacity for wireless broadband services is important, it should not come at the expense of GPS, which is critical to U.S. cotton production. Again, we applaud the two recommendations included in the FCC’s Public Notice, which if adopted would prohibit LightSquared from buildings its wireless network, and we strongly urge the FCC to adopt both proposals.

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