FCC Grants Ligado MSS License Modification Applications

On April 22, 2020, the Commission released an Order and Authorization (“Order”) granting, with conditions, Ligado Networks LLC’s (“Ligado”) mobile satellite service (“MSS”) license modification applications to allow the deployment of a low-power terrestrial nationwide network in the 1526-1536 MHz, 1627.5-1637.5 MHz, and 1646.5-1656.5 MHz bands that will support the Internet of Things (“IoT”) services (IB Docket Nos. 11-109, 12-340).

As background, Ligado is authorized to provide MSS in the 1525-1559 MHz (downlink) and 1626.5-1660.5 MHz (uplink). In 2004, Ligado was granted authorization for Ancillary Terrestrial Component (“ATC”) operations and subsequently was granted a waiver of certain ATC operating terms and conditions. In 2012, Ligado sought to modify its ATC authorizations, and its buildout obligations for its MSS L-Band license and ATC authorization were tolled while these applications were under review. In 2015, Ligado filed satellite modification applications in which it proposed to abandon its authority for terrestrial operations in the 1545-1555 MHz portion of the MSS downlink band and to operate in three other L-band segments—base stations in the 1526-1536 MHz portion of the MSS downlink band and user equipment in the 1627.5-1637.5 MHz and 1646.5-1656.5 MHz portions of the MSS uplink band. In 2018, Ligado filed an amendment to the 2015 applications proposing that the Commission authorize Ligado’s ATC downlink terrestrial operations at 1526-1536 MHz subject to conditions aimed at protecting GPS receivers and imposing specific reporting, notification and monitoring obligations. Ligado’s amended license modification applications significantly reduce the power level of its operations from earlier proposals and commit Ligado to ensure a significant guard-band in the MSS spectrum to further separate its terrestrial transmissions from neighboring operations in the Radionavigation-Satellite Service (“RNSS”) allocation.

The Order concludes that the grant of Ligado’s ATC authorization, as proposed in 2015 and then amended in 2018, combined with the below stringent conditions, adequately address harmful interference concerns with respect to GPS operations in the adjacent RNSS allocation and MSS licensees’ operations in the L-band. The Order finds it in the public interest to grant Ligado’s modification applications that will result in the deployment of a low-power terrestrial network in support of Industrial IoT services, using its MSS license in conjunction with ATC authority for terrestrial operations, through “drastically reduced downlink power levels from those initially proposed.” The Order also recognizes that Ligado intends to partner with carriers to support more broad-based 5G deployment.

  1. Compliance with GPS Co-Existence Agreements – Ligado shall comply fully with any and all terms and conditions set forth in its currently effective agreements with the following GPS manufacturing entities: Garmin International, Inc., Trimble Navigation Limited, Deere & Company, NovAtel, Inc., Topcon Positioning Systems, Inc., and Hexagon Positioning Intelligence. To the extent these agreements are modified, Ligado shall comply with all changes not inconsistent with these conditions. In addition, Ligado will comply with the terms and conditions set forth in any new co-existence agreements with additional GPS device manufacturers, to the extent they are entered into. The Commission finds that these agreements along with the conditions imposed address concerns about harmful interference to GPS receivers.
  2. Power Levels and Operating Restrictions – Ligado will comply with the following power levels and operating restrictions:
    • Downlink Power Level – Ligado’s ATC base stations operating in the 1526-1536 MHz band shall not exceed an EIRP of 9.8 dBW (10 W) with a +/- 45-degree cross-polarized station antenna. The minimum inter-station separation distance shall be 433 meters in a hexagonal grid.
    • Uplink power level – Ligado shall not exceed a power level of -7 dBW in the 1627.5-1637.5 MHz and the 1646.5-1656.5 MHz uplink bands, but that, for a period of five years, the maximum EIRP for the lowest five megahertz of this spectrum—that is, 1627.5-1632.5 MHz—will ramp up from -31 dBW at 1627.5 MHz to -7 dBW at 1632.5 MHz before becoming subject to the -7 dBW limit for the entire segment.
    • No Terrestrial Operation in the Upper-Downlink Band – Ligado shall not operate using its ATC authority in its MSS downlink spectrum from 1545-1555 MHz.
    • ATC Base Station Limitation in Lower Downlink – Ligado may not operate any ATC base station antenna in its lower downlink band, 1526-1536 MHz, at a location less than 250 feet laterally or less than 30 feet below an obstacle clearance surface established by the FAA.
    • Commencement of Operations – Ligado is prohibited from commencing commercial operations in the 1525-1559 or the 1626.5-1660.5 MHz bands until at least 90 days from the release of this Order. For commercial terrestrial operations in the 1526-1536 MHz band, Ligado must also comply with additional restrictions listed in Condition #4.
  3. Out-of-Band Emissions – Ligado must maintain certain EIRP limits for its ATC mobile terminal out-of-channel emissions, ATC mobile terminal discrete emissions, ATC base station emissions, and ATC base station discrete emissions. In addition, Ligado shall ensure that test results demonstrating compliance with the listed emissions limits in the 1559-1610 MHz band are included in any application for equipment authorization.
  4. Notification and Coordination – Ligado must engage in coordination with federal agency GPS users and GPS device manufacturers. For instance, on the federal side, Ligado must replace or repair as needed any U.S. Government GPS devices that experience or are likely to experience harmful interference from Ligado’s operations, and shall launch a program to facilitate the exchange of information between it and the U.S. Government within six months of the release of this Order or no less than 30 days prior to the deployment of a downlink base station at 1526-1536 under ATC authority, whichever is sooner. With respect to the private side, Ligado must provide no less than six months advance notice regarding the activation of its base station transmitting in the 1526-1536 MHz band to specified GPS manufacturing companies in the Order, or to other GPS manufacturing companies that Ligado knows or reasonably should know could be potentially affected by its ATC network operations. Ligado must establish and maintain a toll-free telephone number (to be listed on its website) prior to the deployment of any downlink base station under ATC authority in the 1526-1536 MHz band, for the public to report apparent incidences of interference from Ligado’s operations to GPS operations. Ligado must notify the FCC’s Operations Center with detailed information of an incident within one hour upon receipt of a report of GPS disruption (or becoming aware that licensed operating parameters have been exceeded) and maintain “stop buzzer” capability that will cease transmissions of all base station transmitters within the radio horizon of the impacted area within 15 minutes of an FCC Operations request.
  5. Base Station Database, Drive-Testing, and Monitoring – Ligado must work with stakeholders, including ASRI, to establish a database available to the affected aviation community and include the base station information at least 30 days before commencing transmission at a base station site and must update the database to enter the required base station technical parameters for any subsequently activated base station at least 30 days prior to commencing any transmission. In addition, no later than six months following its initial base station deployments, Ligado must conduct a driving test for each of its deployed areas and shall conduct drive tests for each of its subsequently deployed areas every six months. Finally, Ligado must maintain network operations center procedures for 24/7 continuous monitoring.
  6. Integrated Service Rule Waiver – In regard to the Commission’s waiver of the integrated service rule, the Order requires Ligado to ensure market availability of substantial MSS by marketing a commercially competitive satellite service, dedicating at least 6 MHz of its MSS L-band spectrum exclusively to satellite service nationwide, and ensuring its satellites and satellite-capable devices can operate across the entirety of its MSS L-band spectrum. In addition, Ligado must ensure market availability of commercially competitive 5G satellite/terrestrial services and devices by offering competitive pricing terms for commercial satellite access, ensuring that dual-mode MSS/ATC-capable L-Band IoT devices are available in the marketplace no later than September 30, 2024, standardizing satellite IoT technology in 3GPP to enable incorporation of satellite connectivity into chipsets, ensuring its network can support MSS/ATC IoT devices, and not offering preferential terms for its services.
  7. Reporting Requirements – Ligado agrees to undertake reporting requirements including filing information exchange quarterly status and progress reports with the Commission, FAA and FCC downlink operation reports, interference compliant reports, deployment and drive test reports, and integrated service rule waiver reports.

The Commission clarifies that this Order fully addresses Ligado’s ATC authority, and therefore the prior tolled buildout obligations are terminated, and unless otherwise stated, the Conditions imposed in this Order, supersede those imposed on Ligado in prior orders.

The Order was adopted by a 5-0 vote, with the two Democrats concurring, noting that the decision was “an extremely close call” but ultimately, they were “compelled to support the expert technical analysis done by FCC engineering staff.” The Order is effective upon release. Please let us know if you have any questions or would like additional information.

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