Filings

National Telecommunications and Information Administration Petition For Reconsideration and Petition For Stay of Ligado Order

On May 22, 2020, the National Telecommunications and Information Administration (NTIA) filed a Petition for Reconsideration of the FCC’s Ligado Decision. Additionally, NTIA filed a Petition for Stay of the Order and Authorization of the proceeding that the Commission granted Ligado. 

In the Petition for Reconsideration, they argue:

“There are a number of procedural and substantive flaws in this proceeding and Ligado Order. The FCC repeatedly refused to consider the impact of the broader regulatory and policy issues under consideration in this proceeding, including national implications for GPS capabilities and alleged 5G benefits, through appropriate notice and comment rulemaking. The Ligado Order effectively modifies the Commission’s MSS/ATC rules and policies for the L- Band, and these now should be addressed in that context subject to independent technical assessment and evaluation.”

  • The Ligado Order Failed to Satisfactorily Address and Resolve Executive Branch
    Concerns Regarding the Risks of Harmful Interference to GPS
  • The FCC should acknowledge that further technical studies and testing are needed to
    ensure that Ligado’s actual terrestrial network would not cause harmful interference
    to GPS and other authorized services.
  • The Ligado Order’s Conditions Must be Significantly Modified to Adequately Prevent
    or Remediate Harmful Interference to Federal GPS Devices

In the Petition for Stay, they argue:

“Ligado should not be permitted to deploy its network until NTIA’s Petition for Reconsideration or Clarification (Petition) is addressed and executive branch concerns of harmful interference to federal government and other GPS devices are satisfactorily resolved. Because the Commission relies upon a new and unproven “harmful interference” metric and imposes unworkable conditions while still uncertain whether GPS receivers critical to national security and public safety would experience remediable harmful interference, the Commission should stay the Ligado Order. In this manner, the Commission can meaningfully and promptly consider the appropriate metrics and mitigation procedures – and their realistic application to Ligado’s actual terrestrial network – before coordination and deployment efforts under the current conditions commence.”

  • THE NEW AND UNPROVEN PERFORMANCE-BASED HARMFUL INTERFERENCE METRIC SHOULD BE TESTED SCIENTIFICALLY BEFORE LIGADO CAN DEPLOY A POTENTIALLY HARMFUL TERRESTRIAL NETWORK
  • THE PRESENT CONDITIONS SET FORTH IN THE LIGADO ORDER WILL NOT PREVENT HARM TO GPS

Read the full Petition for Reconsideration here

Read the full Petition for Stay here