On June 8, 2020, Air Line Pilots Association (ALPA) filed a reply to Ligado Networks’ Opposition to petitions for reconsideration or clarification filed by ALPA and ASRI.
In the filing, ALPA notes:
“Airline pilots rely upon reliable and secure GPS satellite services for critical navigation and warning systems that have prevented airline accidents. Terrain Awareness and Warning Systems (TAWS) and GPS-navigation systems aboard airliners provide pilots and passengers with invisible three-dimensional life-saving guardrails in the sky. With the increasing elimination of traditional ground-based navigation and radar facilities by the Federal Aviation Administration (FAA) it is more important today than ever to ensure that critical GPS-based cockpit warnings and navigation continue to operate as intended. Nothing presented in the Oppositions filed in response to the Air Line Pilots Association, International’s (ALPA’s) Petition for Reconsideration1 presents any valid reason for the Federal Communications Commission (FCC) to refuse ALPA’s reasonable requests to reconsider its decision to ensure that airline GPS-navigation and TAWS are properly protected, and to give these critical airline safety systems the evaluation they deserve before granting Ligado a license.”
- The Order Did Not Properly Address Concerns Applicable to Certified Aviation Receivers
- The Commission’s Analysis of Risks to Airline Operations including to Terrain Awareness and Warning Systems (TAWS) was Incomplete
- ALPA’s Safety Concerns about Risks from UAS and General Aviation aircraft remain Unrebutted
- The Issues raised in the Commission’s 2020 Licensing Order are distinctly new and different those covered in the 2003 Flexible Delivery Rulemaking
“Considering the evidence of and the risks identified by ALPA and others, it is clear the Commission made a hasty, arbitrary, and incorrect decision will impede ongoing work on spectrum sharing. For that and the reasons discussed above ALPA urges the Commission to reconsider, reverse its decision, and withdraw in its entirety its April 22, 2020 Order granting Ligado a license and authorizing the operation of terrestrial transmitters in the 1525-1559 MHz and 1626.5-1660.5 MHz bands.”