Defense of Ligado Approval Full of Holes, Petitioners Tell FCC

coordinate with, not just consult with, NTIA and other agencies on a mobile satellite service license change under ancillary terrestrial component authorization in the L band, NTIA said. It and the FCC are co-regulators of the band and that requires “careful coordination,” particularly in areas of national defense and life service safety, said NTIA: Ligado and the FCC are wrongly assuming federal agency opposition is based on Ligado’s initial higher power proposal instead of the available data and analyses done by NTIA’s Interdepartment Radio Advisory Committee Technical Focus Group. Under the Administrative Procedure Act, the FCC should have launched an NPRM about allowing an independent or stand-alone terrestrial service in the MSS L band, the Resilient Navigation and Timing Foundation said. The commission also needs a service rules proceeding to address such issues as rules of use for terrestrial mobile service allocation, RNTF said. Aviation interests said Ligado’s oppositions often don't respond directly to the petitioners’ arguments and mischaracterize the record. The Ligado decision relies in part on FAA analysis the FAA acknowledges wasn't definitive, they said. The Air Line Pilots Association International said the order didn’t properly address concerns applicable to certified aviation receivers and the FCC did an incomplete analysis of risks to airline operations. Ligado’s arguments against the petitions don’t deal with the sizable evidence that public interest claims were significantly overstated or that Ligado would cause harmful interference with aeronautical mobile satellite (route) service, said Iridium, Aireon, Flyht Aerospace and Skytrac Systems. They said the approval wrongly uses out-of-band emissions limits set in 2005, when vastly fewer mobile devices were in the U.S. The order has an “unprecedented” complaint reporting process that lets the interfering party decide whether a complaint it gets is credible before it takes action, Lockheed Martin said. “Limited and dismissive analysis of the 1 dB standard and harmful interference” isn’t the kind of review the agency is supposed to take, it said. The FCC isn't required to do a cost-benefit analysis of the order, but not doing so “demonstrates the Commission’s lack of reasoned decision-making and justifies reconsideration,” it said. Trimble said the commission needed a notice and comment rulemaking proceeding. The RTCA Tactical Operations Committee submitted an analysis outlining remaining concerns in the aeronautical community about Ligado's planned use of standoff cylinders to define where GPS receivers might see interference.