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'Discussion Not Sufficient'

Aviation Interests Pushing for Studies of and Conditions on Ligado's LTE Plans

The effects of Ligado's proposed LTE network on aviation GPS receivers should be tested before any FCC action on the company's plan, said multiple aviation and aeronautics industry parties, according to an ex parte filing posted Monday in docket 11-109. The Federal Aviation Administration and Radio Technical Commission for Aeronautics (RTCA) should study and test possible effects on receivers used by fixed-wing aircraft and helicopters, they said in the filing laying out their multipart set of concerns with and recommendations for license modifications and the NPRM.

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In a statement Monday, Ligado said it remains "highly committed to resolving all potential interference concerns from the aviation community. A key to that is ensuring Ligado’s operations meet current and future FAA standards, and that is why we asked the FCC to enshrine that requirement in our spectrum license. We have confidence in the regulators’ ability to make sure their standards are met, and we look forward to continuing an open and transparent process that puts the right mechanisms in place to ensure that safety comes first.”

The aviation and aerospace industries "appreciate that Ligado is in discussion with the FAA [and others] regarding interference threats to GPS [but] that is not sufficient for grant of the applications," the aviation parties said. The proposed testing should include Ligado's full emission and deployment plan, under FAA authority, using RTCA expertise, the aviation parties said. The theoretical assessment "should be backed up" with physical testing of aviation GPS compatibility -- testing overseen by the FAA to verify the results, they said.

Those theoretical field test results would help Ligado develop operational limits and conditions, "with final approval coming from the FAA, which should retain ongoing oversight over compatibility issues," the aviation filers said. If that testing leads to FAA-approved Ligado operating conditions, deployment "should be fully coordinated with FAA and the aviation industry" and done "in a gradual manner," with "clear conditions" that would halt that rollout in the face of GPS signal interference, the industry parties said. If interference occurs, they said, "full site assessments" would be needed before restarting Ligado operations. They also supported the 1 dB degradation standard as the yardstick for measuring GPS interference tolerances -- a point of contention in the proceeding (see 1605240021) -- and concern about any interference with satellite communications.

At the meeting were representatives from the Aerospace Industries Association, Airlines for America, American Airlines, the American Helicopter Society, Aviation Spectrum Resources, Boeing, Bristow, Harris, Helicopter Association International, Honeywell, International Air Transport Association, Iridium, Lockheed Martin, National Air Transportation Association, Rockwell Collins, United Airlines and UPS. They met with staff from the Wireless and International bureaus and offices of Engineering and Technology and of General Counsel.

Iridium separately is pressing its concerns about Ligado's LTE plans, said an ex parte filing posted Monday in the docket on a meeting between Iridium Chief Legal Officer Thomas Hickey and Philip Verveer of Chairman Tom Wheeler's office. It said Hickey repeated Iridium's concerns (see 1607070010) about possible interference to Iridium mobile terminals from Ligado terrestrial deployment, saying it remains committed to hammering out those issues with Ligado. "Absent an agreement, Iridium seeks appropriate conditions ... to ensure sufficient interference protection," said Iridium.

Ligado is continuing its own lobbying, said an ex parte filing Monday in the docket on a meeting between former FCC Chairman Reed Hundt and representatives of Commissioners Jessica Rosenworcel and Mignon Clyburn. It said they discussed Ligado's work with the GPS industry to resolve their concerns, how the National Oceanic and Atmospheric Administration's base stations and operations can be protected even with shared use of 1675-1680 MHz, and the company's hope for a conclusion this fall.