NNSquad - Network Neutrality Squad
[ NNSquad ] Re: New U.S. wireless network a hazard for GPS (Lauren Weinstein)
David wrote: The problem, if there is one, is that perfectly legal transmissions that are in the LightSquared band (and which would have been legal to other users of that band) are potentially going to make low-quality GPS receivers malfunction. Now he seems to suggest that the solution to that is that the FCC regulate receivers. Given the excellent track record of FCC regulation and command-and-control management of economic activities, that's one possible solution. Another is for the FCC and society generally to say, "Look, you always knew what the rules were. You choose to build receivers that were less expensive but less able to reject interference. Sorry. Good luck with the product liability lawsuits." I think it is important for the regulators to clearly define the protections that users will get from out of band emissions (how much power lands in their band, how strong signals in adjacent channels are, etc.). And, I think the current system in the U.S. does not provide sufficiently clear assurances in this area. But, regulating the susceptibility of devices to interference is a separate issue and one that can easily result in inefficient outcomes. (By the way, the FCC can regulate some kinds of receivers. See 47 USC 302(a). Ironically, this provision was championed by and enacted as a result of the activities of Barry Goldwater who loved amateur radio more than he hated government regulation. <grin>). Chuck ====================== Charles L. Jackson 301 656 8716 desk phone 888 469 0805 fax 301 775 1023 mobile PO Box 221 Port Tobacco, MD 20677 -----Original Message----- From: nnsquad-bounces+clj=jacksons.net@nnsquad.org [mailto:nnsquad-bounces+clj=jacksons.net@nnsquad.org] On Behalf Of David P. Reed Sent: Thursday, April 07, 2011 3:37 PM To: nnsquad@nnsquad.org Cc: nnsquad-request@nnsquad.org Subject: [ NNSquad ] Re: New U.S. wireless network a hazard for GPS (Lauren Weinstein) During the deep and thoughtful discussions that were carried out in the Spectrum Policy Task Force at the FCC, and in the FCC Technological Advisory Committee when I was a part of it, many of us engineers recognized that the current structure of FCC regulations that regulate only transmission are the source of many problems. The problem between LightSquared's licensed band and the GPS receivers is one example. The FCC doesn't regulate that receivers should not be designed so that they fail due to transmissions in other bands. This is because the FCC does not currently regulate receivers at all, unlike the UK radio spectrum regulators. The problem, if there is one, is that perfectly legal transmissions that are in the LightSquared band (and which would have been legal to other users of that band) are potentially going to make low-quality GPS receivers malfunction. Now one of the complainers is Trimble. Trimble does not make GPS transmitters that I know of. They just make products that gain value from the GPS transmitters in the sky. Unfortunately, the "quality of experience" of Trimble's users will degrade, to the extent that their receivers are poorly designed in terms of dealing with radios operating in adjacent channels. Why were they poorly designed for this? One might well ask. Who is responsible to the customers? Well, ultimately Trimble. However Trimble and others have a practical problem - their product is hard to recall. So instead, they want LightSquared to pay for their design weakness. I wonder if that is "right"? Rather than recall the products, they could seek a different remedy - they could pay the FCC for the unusability of adjacent channel services. Surely Trimble has the money from its product liability insurers to make such a payment. Money need not be spent on the "impractical" recall, but can be spent where the cost of the fix is more practical - paying the US Government (and the taxpayers who will not get the benefit of the services in the adjacent channel due to Trimble's mistakes) what their mistake has cost the public. This of course would match the value of "auctioning" the spectrum that would otherwise accrue to the Federal Budget. Probably a few 10's of Billions of US $ would cover the loss caused by careless design. [ This seems like an approach certainly worthy of consideration -- though I would expect technically-oriented legal battles over liability in such cases to be fierce. But from my standpoint, it is most important that consumer GPS units in the field not be rendered unusable by LightSquared transmissions. Even if manufacturers agreed to try replace every unit in the field for free, many consumers would never be located and more would routinely ignore all such contacts. Since failure of GPS when you expect it to work can have very serious consequences, protection of consumers should be the main priority. -- Lauren Weinstein NNSquad Moderator ]