Says FCC 'Must Reverse Harmful Decision'

ALPA has called on the Federal Communications Commission (FCC) to reconsider a recent decision that threatens the safe operation of Global Positioning System (GPS) aviation communication, navigation, and surveillance services. In its Petition for Reconsideration, ALPA called the Commission’s Ligado Networks decision “arbitrary, irrational, and unsupported on any logical basis by the record.”

“ALPA is seriously concerned that the Commission did not fully comprehend or appreciate the safety performance levels required to ensure safe operation of GPS aviation communication, navigation and surveillance services, or the threat of adverse operational impacts from Ligado’s proposed service,” wrote Capt. Bob Fox, ALPA’s first vice president and national safety coordinator. “The tests and evidence relied upon by the Commission were inadequate to rule out failure modes that can result in serious adverse safety consequences from interference with critical GPS-dependent aviation equipment and services.”

Last month, as the world was focused on how to best navigate through the COVID-19 public health crisis, the FCC took the opportunity to grant Ligado access to the public airwaves adjacent to bands traditionally reserved for satellite navigation and communication services. The decision, made without public or stakeholder input on Ligado’s most recent proposal, also failed to properly consider aviation safety standards when they granted access to the sensitive spectrum that has typically been reserved for GPS.

“The Commission’s decision to allow relatively powerful terrestrial transmitters to operate in and adjacent to bands traditionally reserved for satellite navigation and communication services raises important public policy concerns that should have been addressed in an open and comprehensive public proceeding with full and fair notice and opportunity for comment, rather than in this limited license application proceeding,” added Fox.

For years, ALPA has been raising aviation safety concerns regarding this proposed use of spectrum because it threatens the reliability and usability of GPS, which has become essential in helping to reduce approach and landing accidents, controlled flight into terrain, and runway incursions. Today’s petition adds to the growing chorus of stakeholders who have repeatedly expressed similar concerns. Garmin and other manufacturers of aviation GPS receivers, also expressed concern that the aviation industry’s safety issues had not been adequately addressed and that the Commission should work closely with the Federal Aviation Administration (FAA) to enlarge the inquiry to focus on and exhaustively review those safety-related concerns.

In its order, the FCC failed to comprehensively account for tests that document the impact to aircraft navigation systems and misinterpreted and misapplied FAA safety standards.

“The order’s mitigation conclusions appear to be based upon a misunderstanding, or lack of understanding, of aircraft operations. This is an unacceptable way to go about analyzing any threat to the nation’s air transport system,” said Fox.

FMI: www.alpa.org