The Honorable Julius Genachowski
Chairman, Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554
Ex Parte Communication. IB Docket No. 11-109
February 27, 2012
Dear Chairman Genachowski:
For the reasons outlined below I find your recent decision regarding LightSquared's network deployment to be unfair and harmful to not only the U.S. economy, but to the future of innovation.
It has been proven time and again that GPS and LightSquared can coexist. I demonstrated this to the PNT earlier this year, and results from independent labs confirmed my results. Even more telling, the recently published recommendations from the NTIA to the FCC do not dispute this fact.
The only real issue is retrofitting faulty GPS units. Let's take into consideration the aviation industry, which is highly regulated and extremely safety conscious. You can subpoena their retrofit histories and see when they found a problem in any parts of their aircrafts and how long it took them to fix the problems. Considering that changing a GPS antenna is easy task compared to other retrofits that they conducted, it will not be surprising to see this retrofit can take in some weeks.
The cost of such retrofits is under $500 per aircraft. It would cost less than $20M to fix any existing issues within the industry and only take a few months to complete. Please also note that all existing GPS receivers are semi-obsolete and will soon need to be replaced anyway (with or without LightSquared) because current systems do not track the modernized signals of GPS, GLONASS and Galileo.
Please do not allow $14B of private investment in the nation's broadband infrastructure to disappear, especially when it will cost less than $100M to solve any problems associated with existing units. Your decision could render years of innovation and investment obsolete.
GPS manufacturers should not be able to get away with faulty designs and the U.S. government should do not promote, support, and encourage design of flawed units. Even now, when the GPS industry is aware of a simple solution, they keep manufacturing and selling defective units to compound the problem.
Please do not allow technology to lose to politics. It will be a national disaster if we lose 4G competitiveness and discourage investment in this country. If FCC loses control of the precocious spectrum in this case, who knows what will happen in the future?
CEO, Javad GNSS
San Jose, California