Ligado's LTE Plans Face NOAA Resistance

Similar concerns have been voiced by many in the weather community (see 1607280022). They reflect "a fundamental misunderstanding" of how NOAA collects and disseminates weather data, resulting in much of the resistance seen to commercial sharing of 1675-1680 MHz, Ligado said. It continued its push for the FCC to launch a rulemaking to allow that sharing -- including protection conditions for NOAA earth stations and requirements of creating a content delivery network (CDN) for non-NOAA users.

Many critics remain wary of the sharing plan, with it not being clear a CDN would be an adequate substitute for a direct readout from NOAA's Geostationary Operational Environmental Satellite (GOES) system, a collection of aviation industry members said in a filing.

"Commenters have been badly misinformed," Ligado said. The firm tried to rebut misunderstandings: that GOES-R transmissions would be shielded by protection zones, its downlinks will broadcast at 1679.7 MHz and higher and not across the entire band being considered for sharing and that numerous GOES transmissions will be unaffected by any sharing regime. Only downlink signals to NOAA earth stations are involved in the sharing plans, Ligado said, and NOAA hasn't shown any evidence of interference to them if protection zones are mandated around those stations. NOAA primarily uses spectrum outside 1675-1680 MHz to collect and distribute data, Ligado said, saying concerns that have been raised about interference to 27,000 hydrology, seismic and environmental sensors are misplaced since they go to GOES satellites over a 401 MHz uplink channel.

Ligado's cloud-based prototype CDN should be operational within 60 days, Chief Legal Officer Valerie Green told us Friday. The company is experimenting with IP delivery of the data received by NOAA earth stations (see 1607280022). It would give non-NOAA users "the same data they receive now in an equally effective way," while also opening the door to new users having access, Ligado said.

Having largely resolved concerns from the GPS industry about its LTE plans (see 1602040015, 1512180020), the company also faces pushback from the aviation industry on its license modification application and possible interference to certified aviation GPS receivers (see 1608010036). Green said the satellite company is talking with many companies and aviation groups directly and will expand that effort. Ligado counsel Gerard Waldron of Covington and Burling said many of the routes by which the company has addressed weather concerns should also address aviation community worries. He said that in the company's ongoing talks with the Federal Aviation Administration, there have been no indications Ligado plan will require any major modifications to meet whatever guidelines that agency imposes.

The aviation parties raised NOAA-related concerns, with the GOES system "a crucial facilitator of aviation safety and operational efficiency," they said. Pointing to a lack of specifics regarding protection of existing non-federal ground stations receiving GOES data and about its CDN proposal, the joint aviation parties urged the FCC not to grant a rulemaking petition. The filing was from Airlines for America, Cargo Airline Association, Delta Airlines, FedEx Express, Helicopter Association International, National Air Transportation Association and others.

NOAA's Senate presentation said its satellite operations at Wallops Island, Virginia, already sees interference from Ligado operations in 1670-1675 MHz, resulting in "loss and corruption of mission critical satellite data," and sharing 1675-1680 raises worries about the inability of protecting federal and non-federal data collection outside protection zones. That will affect emergency management, weather warnings and wildfire management efforts, NOAA said. Alternately, the agency said, the number of ground stations requiring protection zones could make the band not economically viable for broadband service. "Ultimately, the problem isn't NOAA's alone," affecting users of its real-time data, the agency said in its statement to us.

Any terrestrial mobile use of 1675-1680 MHz should come with protections of federal safety uses of the band and the "legitimate investment-based expectations of AWS-3 licensees," SNR Wireless said. SNR said the Ligado plan would result in "significant unanticipated costs" for AWS-3 licensees like it -- costs that should be borne by 1675-1680 MHz licensees. Those expected costs come from the fact Ligado's base station network would add to the interference in the protection zones around federal users' earth stations, reducing the interference budget available for AWS-3 licensees and thus limiting the number of AWS-3 mobile devices that could operate there, SNR said. The FCC should hold 1675-1680 MHz licensees to the same monitoring and coordination requirements that AWS-3 licensees are, including ongoing radio frequency monitoring, engaging with federal users on increasing the available interference budget and coordinating with federal users through the Commerce Spectrum Management Advisory Committee process, it said.

With so many weather professionals relying on 1675-1680 MHz, and satellite downlink spectrum at 1680-1695 MHz, any sharing with non-meteorological services first needs more analysis and testing to see what the effects might be, the Weather Coalition said. Members include AccuWeather, Boeing, Northrop Grumman, the American Geophysical Union and 20 higher educational institutions.

The Ligado plan has some backers. Competitive Carriers Association said the FCC should follow up the comments with a rulemaking proceeding for shared use of the spectrum and for designating the spectrum for auction. Any outstanding concerns could be addressed in that rulemaking, CCA said. The group said that creating an auction schedule in a timely fashion lets possible bidders consider 1675-1680 MHz alongside any plans they might have regarding the broadcast incentive auction.