September 15, 2022
A collection of weather, water, Earth science and aviation-related organizations have submitted an FCC filing on the recently released “Spectrum Pipeline Reallocation 1675–1680 MHz Engineering Study (SPRES) Program Report.”
Our organizations and members rely on real-time data services from NOAA’s Geostationary Operational Environmental Satellite (GOES) between 1675 and 1695 MHz for critical early warning of severe weather, floods and wildfires, as well as important information for marine transportation, aviation, agriculture and numerous other weather-dependent industries.
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The detailed analysis presented in the SPRES report, paired with the information in numerous Ex Partes by our and other science focused organizations, provides a clear basis of evidence suggesting that claims by Ligado that their proposed system will not harm environmental data users are false. Added to the evidence presented by the GPS, satellite communications and other related industries about other Ligado efforts to conduct terrestrial operations in the L-band, the SPRES report reinforces the need for the FCC to prevent any further consideration of the Ligado proposal to share 1675-1680 MHz, and stay the April 2020 FCC decision authorizing operation of a terrestrial radio network near the GPS frequency bands.
We understand the FCC’s interest in advancing spectrum sharing for the future but believe our long-stated concerns and the evidence provided in the SPRES report should signal a significant warning. The FCC should vacate its efforts to proceed with final rulemaking in the 1675-1680 MHz radio spectrum. Thank you for the opportunity to represent our organizations and comment on this issue of importance to the safety and wellbeing of society.
Sincerely,
AccuWeather, Inc.
Air Line Pilots Association, International
ALERT Users Group
American Geophysical Union (AGU)
American Meteorological Society (AMS)
American Weather and Climate Industry Association (AWCIA)
GeoOptics, Inc.
National Weather Association
Microcom Environmental
PlanetIQ
The Semaphore Group
Space Science and Engineering Center at University of Wisconsin-Madison
University Corporation for Atmospheric Research (UCAR)
Additionally, the Satellite Safety Alliance statement on the SPRES report underscored the fact that Ligado will disrupt critical data collection tools used for forecasting severe weather, floods and wildfires. The analysis clearly demonstrates that no realistic solutions exist to mitigate the harmful effects caused by Ligado’s proposed network.
The full Spectrum Pipeline Reallocation 1675–1680 MHz Engineering Study (SPRES) Program Report is also available here. Read the filing in full here.