Today, the Federal Communications Commission (FCC) voted unanimously to authorize Ligado Networks LLC to provide a mobile broadband network using frequencies adjacent to those used for GPS, a National Security System. The Association of Old Crows (AOC) sides with the US Department of Defense (DoD) and strongly opposes this approval of the license. While we recognize that Ligado has made certain accommodations to alleviate concerns about interference and disruption, the accommodations may still be insufficient and the potential costs – both financially and technologically – to the DoD and other federal agencies remain high. The AOC believes the risks identified by the DoD may not be sufficiently mitigated and there is a need for more testing to ensure the fidelity of GPS systems in coexistence with the new broadband network.
The US military is heavily reliant on the electromagnetic spectrum (EMS) to conduct any and every military operation around the world, including domestic military training and national security support to other US federal agencies. Military superiority in the EMS Domain is a prerequisite for successful military operations. In an era of timing and precision, global connectivity, and multi-function technology, even the slightest interference or disruption of GPS signals can have cascading adverse effects across a broad range of military systems and capabilities.
The license in question has evolved since 2011 when testing on Ligado’s (formerly LightSquared) wireless broadband service proposal found significant disruption of most general-purpose approved GPS receivers. AOC first raised concerns about these findings in a 2011 press release in which the AOC stated that, “[d]ue to global dependence upon the GPS system, reliable access to GPS frequencies must be protected and managed as a National resource and no longer simply as a commercial opportunity.” Little has changed since then. Unfortunately, the FCC moved forward without the full cooperation and support of the DoD. This decision sets a precedent and the FCC should have ensured the decision represented full stakeholder cooperation and a proper balance between commercial benefit and operational efficacy.
The AOC unequivocally supports DoD’s position stated in the Memorandum for IRAC Chairman dated February 14, 2020 and signed by 13 leading national security stakeholders. Specifically, the Memorandum states, “It is DoD’s position that FCC approval of Ligado’s license modification would cause unacceptable operational impacts to the warfighter and adversely affect the military potential of GPS by negatively impacting GPS receivers. Ligado’s proposed accommodations of identifying and then repairing or replacing potentially impacted legacy equipment is not feasible, affordable or technically executable given the vast number of systems implicated, including critical national security and weapon systems. Accordingly, DoD remains strongly opposed to granting the license modification sought by Ligado.”
While the AOC recognizes the tremendous economic potential of advances in 5G telecommunications and the need for DoD to modernize its policies and processes to strengthen investment in military solutions that keep pace with commercial technology, the decision by the FCC is short-sighted. It unnecessarily increases risk to a critical military network and capability and does not sufficiently cement the US as a leader in 5G network development.
Founded in 1964, and with over 14,000 members internationally, the Association of Old Crows (AOC) is an organization for individuals who have common interests in Electronic Warfare (EW), Electromagnetic Spectrum Operations (EMSO), Cyber Electromagnetic Activities (CEMA), Information Operations (IO), and other information related capabilities. The Association of Old Crows provides a means of connecting members and organizations nationally and internationally across government, defense, industry, and academia to promote the exchange of ideas and information, and provides a platform to recognize advances and contributions in these fields.