Ligado Says Confusion 'Plagues' Weather Community Over TLPS
Pointing to what it considers extensive confusion in the weather community, Ligado is trying to make clear its case that its broadband terrestrial low-power service (TLPS) plans aren't a threat to the plethora of sensors the National Oceanic and Atmospheric Administration uses to track weather conditions. "We don't know why there is such confusion, but there is," said Ligado outside counsel Gerard Waldron of Covington and Burling Monday, as the company filed at the FCC a 10-page presentation on NOAA's data collection system in RM-11681. Ligado repeatedly sought an NPRM, and Waldron said that would be the best way to clear any confusion.
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Having attended an American Meteorological Society (AMS) conference earlier this year and now made the filing, Waldron said the company is putting its focus on the NPRM. "The record is pretty full for the commission to go forward," he said. Ligado urged NOAA "to end the widespread misunderstanding that plagues the weather community." Ligado has talked with commissioners, but consideration of a possible NPRM is still at the staff level, said an industry official.
"As a matter of physics, there is absolutely no reason to worry about any of these [weather sensors experiencing] any sort of impact from a base station or handset" using the 1675-1680 MHz, Ligado said. Only a small number of earth stations receive data from NOAA's Geostationary Operational Environmental Satellite (Goes) system -- "a couple of dozen" federally owned ones and fewer than 100 non-federal earth stations, the company said.
The federally owned earth stations should get protections in the form of FCC-required protection zones, the firm said, saying NOAA never suggested the protection zone regime Ligado has been pushing (see 1609200001) is "anything other than entirely satisfactory." For the non-governmental users of that spectrum, Ligado pushed its proposal for a cloud-based content delivery network (see 1607280022) -- which it said would be akin to the system used by the Financial Industry Regulatory Authority.
With a cloud-based approach, "you are dependent on that being there when serious events happen, when there are power outages, things like that -- which is exactly the time when that might not be there," Paul Higgins, AMS policy program director, told us. With the weather community concerns about how spectrum sharing could interfere with critical capabilities like forecasting and communicating extreme weather events, the Ligado proposals haven't been adequate because they don't seem able to provide the data as quickly or as reliably as the spectrum-based status quo is, he said.
Until independent testing answers whether co-existence is feasible, the FCC shouldn't move ahead on any NPRM, Renee Clarke, principal at weather and technology consulting firm Narayan Strategy, told us. She said Ligado is incorrect that there is no weather community use of 1675-1680 MHz, since the just-launched GOES-R satellite will use that spectrum, she said. She said she is involved in the proceeding as an AMS member. NOAA didn't comment.
There are about 20,000 sensors in operation measuring water levels, water directions and currents, but none send or receive in the 1675-1680 MHz band, instead sending data to Goes in the 401.7-402.4 MHz band, said Ligado. That data is then downlinked to NOAA earth stations using the 1694 MHz frequency, it said, saying once the Goes-R satellite is operational, it will use the 1679.7 MHz frequency.