LightSquared: FCC public comment period ends...

They got mine a few weeks ago. If others haven't yet, do.

I sent mine ...

I sent mine. I have been reading through some of the comments and the vast majority are opposed to any interference and disruption of GPS.

But there are a few that only appear to have read the LightSquared propaganda. Would it be wrong to email some of them and politely explain what they are not understanding? One guy even wrote that the GPS industry is walking on the LightSquared spectrum.

Done.

I submitted mine.

Looks like they're up to 2,469 comments.

Looks like nearly all the politicians making comments have bought into Lightsquared's propaganda without any consideration for the aspects of destruction of what has become essential GPS services.

Up to 2460 filings currently, still lists as open, so if you haven't commented, do so now!

I randomly read a few, AN awful lot of support for LS in my random selection, many having bought into the idea that this is a GPS industry problem AND that it was ignored for eight years, blah blah blah, If you were sitting on the FCC side reading these, I think you would be getting very mixed signals.

SHG

Shelby - I read your letter this morning, good job. I submitted mine on Saturday and it is now posted as well. (Much to my chagrin I now learn that I misspelled Ms. Dortch's surname - I copied it from another letter that had it wrong as well:-( .)

No one can say that LightSquared is sparing any PR efforts. Many of those comments you noted in support of LightSquared seem to come from state legislators in midwest and plains states and their comments echo a LightSquared release. These elected officials seem convinced that when LightSquared commences operation, even East Overshoe, Minnesota will become a little Silicon Valley and all the grandchildren will move back to their ancestral roots. And if they don't it's all because of the evil GPS industry.

Methinks this ubiquitous-rural-coverage dream dancing in the politicians' heads is wishful thinking for a couple of reasons -

1. LightSquared (so far) says they will be a wholesale-only provider, so a separate entity will need to be the retail reseller who actually brings the service to the low-density and expensive-to-serve hinterlands. There is no guarantee that will ever happen and there is little profit incentive to do so anyway.

2. LightSquared has committed to provide service to 260 million Americans by 2015. While that sounds like a lot, it will still leave a huge swath of rural America without broadband coverage (unless you consider slow and latency-plagued satellite internet to be broadband, which the Rural Mobile & Broadband Alliance does not (you may need to give your name and e-mail address to get that 18-page report).

So I did some armchair research that is not perfect by any definition but should give an order-of-magnitude idea of how much unserved land area remains after LightSquared meets its commitment to serve 260 million Americans.

Using the 2010 census information for the 3100-plus counties in the United States (excluding Alaska because of the gross distortion that would be caused by including that huge land area with small population) and sorting by population density (people per unit of land area) it comes out that you can reach 260 million and still leave 78% of the land area uncovered. Or, sorting by population per county, there will still be 71% of the land area uncovered. Admittedly this is not precise analysis, but I believe it supports a claim that 70% or more of the land area in the 48 contiguous states will not be served by LightSquared's wireless broadband when LightSquared meets its 260-million commitment.

GB

Just remember, this is what happens when money became speach.

2732 and counting.

Quite a days jump. Again. If you haven't commented there still appears to be time.

How I Learned to Stop Worrying and Love the LightSquared

My 2011-08-01 post above was way too generous!! (Bold emphasis below is mine.)

On page 32 of its 30 June 2011 Recommendation LightSquared is explaining why its terrestrial network will not pose much problem for precision GPS receivers -

". . a substantial percentage of precision GPS receivers are used in applications such as precision farming and precision mining that are highly unlikely to be near a LightSquared base station and certainly not in the next several years given the expected rollout of LightSquared’s network over time. LightSquared's terrestrial deployment plans necessarily focus initially on population centers and only gradually begin to cover less densely populated areas where most precision agriculture and precision mining are practiced. Indeed, LightSquared’s terrestrial deployment plans project coverage of almost 270 million Americans or 86 percent of the U.S. population by the end of 2014, but this population would be located in densely populated areas that cover only 12 percent of the U.S. land mass."

And all along I thought LightSquared was the selfless champion of rural America. If they are planning to leave 88% of the country's land area unserved I may have to reconsider.

Then on page 35 they say essentially the same thing -

"As an initial matter, as noted above, a substantial percentage of legacy precision receivers are used for applications such as agriculture and mining and tend to operate in rural and other remote areas. Given LightSquared build-out plans discussed above, in which initial deployment will focus on densely-populated urban and suburban areas, these receivers will be unaffected by LightSquared’s deployment for many years."

Many years? The state representative from Frostbite Falls, Minnesota was planning to stream "A Christmas Story" (You'll shoot your eye out!) on his new iPad this year.

Not to worry - LightSquared's ubiquitous and magical satellites will come to the rescue.

But now we see that on page 6 of the Letter Narrative LightSquared submitted to the FCC on 18 November 2010 (that was essentially a request for a waiver of the FCC's ATC integrated-service requirements) they outline their pricing strategy -

"The company will have both a satellite-only and an integrated rate. When a LightSquared customer pays the integrated rate, the customer will have access to both the terrestrial and satellite networks for that single rate. For each GB of terrestrial usage, the customer will receive 500 kb of satellite usage, with a competitively-priced, usage-sensitive charge for satellite usage above this amount."

Giving them the benefit of a doubt and assuming LightSquared meant "500 kB" (kilobytes) instead of the "500 kb" (kilobits) they wrote, that's going from about a full CD of data via terrestrial to the amount of data it takes to check e-mail via satellite - a ratio of 2000 to 1. To interpret "usage-sensitive charge" - that means it's going to be expensive to watch that movie over satellite internet.

Finally, in footnote 7 on page 7 LightSquared states -

"LightSquared estimates that the capacity of its fully deployed terrestrial network across all base stations will be tens of thousands of times the capacity of either of the SkyTerra satellites."

OK, "either" means there are two satellites, so figuring that the terrestrial-network capacity is only one x 10,000 the capacity of one of their satellites, and the terrestrial network is designed, constructed, and backhauled to provide broadband-class service to 270 million people, then it would follow that each satellite could (maybe, if you ignore latency and all the other problems that plague satellite internet) provide broadband-class service to 27,000 people for total coverage of 54,000 broadband-craving souls. That's a pretty small portion of the 40 million living in the unserved 88% of the American land mass.

The FCC comment period is over, so now it's time for GPS proponents to contact all (Federal, state, and local) elected officials. You can be sure LightSquared will!

GB