 and Washington Office Director of the Secure World Foundation. The Secure World Foundation is a private operating foundation that promotes cooperative solutions for space sustainability. Our vision is a secure, sustainable, and peaceful use of outer space that contributes to global stability on Earth. Given the increasing democratization of access to space and the way in which space is being more and more tightly woven in daily lives, economic development, and national security, it is ever more apparent that the international community must come together to ensure a safe, secure, and sustainable space environment. In order to see to it that current space stakeholders and future users can benefit from space over the long term, it is important to lay the foundations for approaching space in a cooperative manner now. Space sustainability depends upon the reliable and predictable access to space assets and confidence in one's ability to utilize the space assets as warranted. Our continued ability to get benefits and space assets will be interrupted if spectrum is not responsibly protected. This issue is coming up more and more often, particularly so in meetings last November in Geneva for the World Radio Communication Conference. As the government looks to the future of GPS and other positioning, navigation, and timing systems, there are policy considerations by the US government which may affect future use of spectrum. To recent examples, there was an announcement last month by the Department of Transportation that it is looking at GPS-adjacent ban compatibility assessment testing. Also, the FCC is considering currently a frequency transfer to the commercial wireless industry that could very well affect weather, water, and climate data collection and dissemination. As the US government takes on the mantle of looking at how space assets can be overall more resilient, spectrum protection is a key part of this discussion. This lunchtime panel will examine what major issues could potentially affect spectrum availability and utility over the near term and discuss what policies and or legislation could help with those challenges. So I'd like to thank our speakers for coming and being ready to share their expertise. We'll have them go through their presentations and then questions at the end. This event is being recorded as the camera and audio should indicate and is on the record. And the presentations will be available on our website afterwards. And so with that, I'm realizing we probably should have people sit in the order. Actually, we are, aren't we? There we go, we're sort of... Okay, well then, we're so good. We do things right and we don't plan to. So let's start off with Scott Pace, who'll be doing introduction for the subject. You should all have bios of the speakers in front of you. So in order to expedite getting into the fun stuff, we'll just please look that and we'll pull up your presentation, Scott. Super, wonderful. Okay, good afternoon everyone and thank you all for coming here. Pleasure to be here with the panel with a lot of old friends and colleagues. So the title of this discussion is Spectrum Protection and looking at the policy and practical implications. I hope that we have again an extensive time and discussion to cover all those issues because I'll just really just treat an overview of some of the currently what I consider to be hot topics at the moment. So as a scene setter, for those of us in the space business, we don't worry about just interference on the ground. We worry about all the different ways interference can occur with satellite systems and ground systems that operate in and across each other. So of course there's the geostationary orbit satellites but there are non-geostationary orbit satellites and there are ground transmitters. And so we worry about the entire spectrum environment and all the different interactions they can have. We of course want to have interference free operation the way internationally this tries to be accomplished just through the radio regulations, which is what that little RR and red is down there on the bottom and then trying to control interference. Interference can ever of course be 100% eliminated but it can be managed and be contained. So in the management of spectrum, this is freely stolen from our colleagues at NTIA and FCC so it's in the public domain for which I'm grateful. And they talk about four major spectrum management functions that is the allocation of spectrum to particular services, developing rules for those services, assigning frequencies to particular systems within those service allocations and then of course enforcing the rules. So the radio regs that were briefly mentioned in the previous slide for those of you who don't sort of live and breathe in the IT world is really allocates frequency bands to services. It is national administrations. It is national spectrum authorities of sovereign countries that decide what frequencies to assign to a particular system. But what you'd like to do of course is have to coordinate it so that those systems operate within services that are then compatible with each other. So you don't have a free for all of a TV station broadcasting in a radio astronomy band. You don't have GPS trying to broadcast in an FM radio band. There tries to be some sort of broad order across the international community through international radio regulations that have this treaty status. These are internationally recognized agreements, not just guidelines or nice things to have. And then it's within the national administrations that you assign these frequencies. Now of course you can imagine that for space services this is particularly tricky because spacecraft fly over all these countries. So if I make a frequency assignment decision for a space system, I'm really making a global allocation, not just something that affects a particular country and therefore the service rules that are adopted internationally are ones that are meant to protect really every user around the world, not just those in a particular country. Now one of the problems that we run into for people who live and breathe in the ITU and spectrum world and the FCC and who follow all this sort of stuff is that those of us in the space business tend to be actually a particular minority. The ground based and terrestrial based radio systems not surprisingly are the large dominance of the number of licensees, which is ironic because if you look at the spectrum chart you find that space services are called out in particular, I think of about 21 allocations, the bulk of them are for different types of space services. So while space services don't represent a high number necessarily of different systems and users, they represent quite a diversity of them. And as a result of that diversity we often find our time tells explaining what space services do to people who are in the calm world. So RF engineers who come out of the calm world they have a particular mode and I promise try not to be insulting to any calm engineers in the room. I'm an ex physics major so I can insult everyone. They think in terms of transmitter A to receiver B and it transmits in a direction and it transmits ones and zeros and you're trying to figure out what's on the other end and there's a certain link budget, a certain degradation that occurs due to distance and other intervening things. And that fairly sort of a simple model of a transmitter, a receiver, a link budget and trying to figure out what's in the ones and zeros being transmitted is really such a very dominant paradigm in the way people think about things. The problem is there are other types of space services such as passive remote sensing operations and satellite navigation systems and even radar systems that don't operate like that. And so flipping people out of that model, mental model to deal with the actual physics that are involved is actually a challenge that comes up fairly often and it's even worse if you're talking to a lawyer. So in digital radio communications, the message is really not known and you're trying to figure out what it is. In the case of radio navigation and GPS, the code, the sequence of ones and zeros is actually precisely known, in fact it's published. So you know what those things are. What you're trying to determine is when the ones and zeros occur. When does a transition between a one and a zero occur? Because if you know when that transition occurs, then you know what the speed of light is and with the speed of light and knowing the transition time, you can figure out the distance to that satellite. If you figure out the distance to four satellites, you can solve an equation of four equations and four unknowns, x, y, z and t and et voilà, you have a position. You can then look at how that changes over time, you have a velocity, you rank it up with a map, you now have a navigation system. So the precise measurement of transition, what we might call radiometric tracking, is really the core of what it's about, not measuring the ones and zeros themselves. And so if I'm looking at, I've stolen this from Brad Parkinson, if you look at the received data, there's the ones and zeros doing transitions and if there was no noise around, I'd have a nice crisp blue signal. What I actually see of course is the red signal because there's noise in the system and noise in the receivers and noise from nearby people. Okay, so the zero crossing uncertainty is greatly diminished if I can go reduce the amount of noise. If however I put filters in the systems, if I raise the background noise floor, then exactly when that transition happen gets kind of rounded off and get shaped. I know it's a one and a zero, but just right when did that happen? I don't get and that directly transmits via speed of light into a position uncertainty. So there's a great difference between tracking something at a one centimeter level versus something at a hundred meter level because of the amount of precision I need in that transition time. Therefore, the noise environment is central to whether or not my radio navigation system works at one level or another. So I call this as a primitive chart because I wrote it in about 1998 an old version of PowerPoint and it's only been updated since. This is called the multiple ways to die chart if you're in GPS spectrum. And what happens is GPS can be harmed a number of ways. Now here's the GPS crudely drawn with a CA code in the center and the military M code kind of on either side and GLONOS is in the upper part of the band. And this is where we live in the aeronautical radio navigation service and radio navigation satellite service band. So RNSS means it's kind of a GPS like system. ARNS means it's an air safety system. So it has additional regulatory protections as a safety service. And adjacent to us are mobile satellite services. So things like Global Star and Iridium are in those nearby adjacent bands. So a number of ways you can die is somebody can segment your band and decide to put something else in the middle. So your ability to move your system freely or deploy new systems is harmed. Another way to die is if somebody comes in and wants to like share a part of your band. This is something that was attempted by Europe in 1997. A spin off of Inmarsat look to share. And while the mobile satellite services are wonderful neighbors because they're also space services and therefore relatively quiet, they still operate at orders of magnitude more power than GPS does. So it'd be kind of like having a rock band deciding to camp in your living room. They're gonna be a fairly raucous crowd if they're in your living room. They're not bad next door, but in your living room, not so much. And then finally, you have out of band emissions. That is they can be next door to you, but they're creating noise and it spills over into your environment. So here we have power overlaying our signal. Our band can get segmented. We can have emissions that cut across us. And the reason all this is important is because we're talking about 10 to the minus 16th watts. This is like a light bulb, you know, a halfway to geo that you're trying to receive. And in fact, the signal is below the thermal noise floor, which means if I turn on the oscilloscope and I look around at this room, a certain room temperature in here, there's a certain amount of radio noise in here. And just created by all the warm bodies and the lights and so forth going on. If I look for the GPS signal, I won't find it. I can find your cell phone signals because they'll be sticking up above the noise. And I'll scan across. Yep, there's a cell phone, there's another cell phone. But if I look for GPS, I won't see it. I have to know exactly where to look. I have to drill down below the noise floor, extract that signal out. So if the environment becomes more noisy, my life becomes much more difficult and getting that precision becomes harder. So very, very high power systems, not only in the band, but adjacent to the band, can also cause overload to my receiver. I can be deafened by a party that's happening nearby, even if it's not exactly in my house. So to answer these questions, so look at the question of, well, what could we put in those adjacent bands? Mobile Satellite Services are in those bands now. And it's no secret that the FCC has been unhappy with Mobile Satellite Services because they haven't rolled out to be as large and as pervasive as they originally hoped. So we love them as neighbors, but others look at those bands and go, gee, couldn't we put something else there? Not an unreasonable question. What else could we put there? And the answer is there are in fact constraints on what you can put in that adjacent band, again from the physics. So I wanna build nearby, but I don't wanna destroy what's operating in the GPS band. It is not clear what the power emission limits need to be in adjacent bands in order to make a decision on, well, what else other than MSS I could put in those bands? So that's why the Department of Transportation, as a result of past conflicts that we can go into, if you want, put together a study called the adjacent band compatibility study, which is meant to define, well, what are the power masks? What are the maximum level powers that we could put in these adjacent bands? It could be MSS, it could be something else, but as long as you stay below that mask, life in the GPS bands will be okay. And so I see this as a form of creating more regulatory predictability, that if you're coming into here and you want to go in that band, there should be some technical standard you can look at and go, hey, I'm gonna be below that band, I'm gonna stay in my yard, I'm not gonna bother the folks next door. Now to date, lawyers have tried to answer this question. And the problem with lawyers answering the question is, as I'll repeat later, the photons don't care. The photons are gonna do what they're going to do. And so having a technical answer to this question is actually very, very important in this very, very contested environment. A couple of other things that are going on. It turns out that regulatory authorities and development of industry standards sometimes get disconnected from each other. I know that's really a shock. I mean, of course, standards get disconnected from regulations all the time. But there's one here that's of particular interest for the GPS community. There's a thing called the Radio Equipment Directive coming out of the European Union that all electronics being sold in EU will have to comply with really after June. And a lot of these things are basically maker marks, consumer electronic things, marks that you would find on the backs of pretty much any of these consumer items. And so they're in pretty good shape for a lot of commercial communication devices. However, standards, clear standards for GNSS systems, whether GPS or Galileo, not so much. Those standards aren't so mature. Okay, fine. People can grandfather in what they've been doing so far and there's ways of dealing with that. The problem is the standards bodies, again, thinking in that calm mode that dominates this community are talking about spectrum sharing and mitigation techniques that would create interference to these radio navigation satellite servers receivers. And so in effect, some of the industry standards in draft form that are being developed envision spectrum sharing that is actually not permitted by the ITU. So the question of, well, who's the regulator and who's the standard person? Shouldn't the standards be subordinate to the regulation? Well, it's a messy world. And what you're seeing in some of these European technical standards is essentially the standard setting bodies getting out ahead of the regulators. There is, in fact, the European Post and Telecommunications Group, European Commission, the telecom organization has a recommendation that authorizes indoor pseudolites in the band, in the GPS band. Well, we've looked at this in the US industry in times past and thought that in-band pseudolites were really a stupid idea. There's a whole bunch of problems with them near far segregation, raising noise floor, all that. And after looking at that for some time in the early 90s, the industry has all gone out of band. So if you have an indoor location positioning system, most likely it'll operate about 2.4 gigahertz in Bluetooth range, it'll operate five gigahertz or someplace like that in a Wi-Fi band. It doesn't operate in the band. So here is a standard being talked about to do something that we've rejected in the United States not only from an industry standpoint, but US regulations actually bar this kind of activity. And we control in-band emitters very, very strictly precisely for the dangers they can create. And however, this standard of 14 European administrations, 17 have voted to accept it, adopt it as of February. So we're kind of going, okay, I can tell the lawyers are running this one again. This creates a path for license and unintentional jammers to really operate across Europe. And if you have enough of it in a concentration, you see in the presentation discussions of no fly zones, I can see a no fly zone around a helicopter landing pad at a hospital, not terribly a bright idea. But this is again, where communication is not happening across the community between the regulators and with the industry. Now, other infrastructure relies on space. So I of course focus a lot on GPS because that's what I know and love. But there are other space services out there. And it turns out that the GOES series of weather satellites in turn support, not just pictures for the evening news, but they support broadcast services that then create a whole series of channels that provide information up and down the Americas. And the data that they transmit through these terrestrial sensors is used for a whole bunch of activities. The bottom one is my favorite, the release of water from reservoirs in the Potomac region and then into the DC Metro water supply is managed by data passing through with 1679 to 1680 band. Little tiny, you know, one megahertz, okay? But this is the linkage that goes to a whole bunch of other infrastructure for flood monitoring and navigation. So the concern here, and another additional concern is that the GOES direct broadcast satellite, severe weather warnings, are again go out over direct broadcast in the 1675 to 1695 megahertz band. And so since these are not GNSS bands, you know, why am I mentioning them? I mean, they're nice space bands and they're wonderful, but you know, why? Well, because it turns out that part of what's going on under the commission, there are proposals there to reallocate portions of those meteorological bands to ground-based terrestrial mobile communications. Again, people trying to find the best and highest use of that spectrum. You're pretty familiar, probably, those in this room. The FCC chairman, Wheeler's speech of the Satellite Industry Association, which was, shall we say, not the most supportive of the interest of the satellite communities. And a lot of spectrum reforms that he and the commission and so forth talk about, you know, may in fact really work for communications. So some of the spectrum sharing, some of the intelligent, you know, check-before-speaking kind of things that are really kind of interesting from a technical standpoint, not necessarily gonna work for non-com functions and navigation or remote sensing or particularly public services. So the balance of how much experimentation do you want to do and where do you want to do it versus what sort of public good infrastructures do you need to make sure you protect and where the standard of evidence may need to be a lot higher. Prove that it's safe, as we would say in NASA, as opposed to prove that it's gonna cause harm. So the standard of evidence question, again, something a lawyer would understand, is a very, very severe problem in terms of potential weakening of current international protections. And I have to say, although I've been beating up on my com people friends, it's not limited to space users. The AWS-3 auction, which was a fairly big deal, billions of dollars recently, rolling out some new terrestrial comm systems. One of the licensees pointed out that in this discussion around this band, that it's difficult, if not impossible, to reconcile the interference experience by federal users like goes between AWS-3 operations and proposed operations in this band, because there are two potential interfering operators from different bands, oops, sorry, mobile services here and somebody else over here. Identifying the offending party will be difficult, if not impossible because the interference is due to combined operations. Okay, so if you make the situation chaotic enough, it's like picking out the assailant in a large riot. Okay, who was the one who actually did that when things are fairly confused? And so as I say, the policy and politics are important, but again, the electrons and radio waves don't care. This blurring of accountability is, as somebody in the software people will say, it's not a bug, but it's a feature. Because what you do at that point is you shift responsibility for dealing with interference from the transmitter, which is the traditional mode of control in a spectrum environment, to the receiver, that is the victim has to take responsibility to defend themselves. Well, the problem with that and shifting responsibility to the victim receiver is that some victim receivers might be able to handle that, but other victim services probably can't. And again, passive remote sensing systems and environmental monitoring systems, radio navigation systems that are at necessity operating at very low powers over broad bandwidths are not gonna have the same capabilities to, quote, toughen themselves or be responsible for themselves that maybe a calm system would. And so if the noise floor rises and it's hard to hold a particular emitter culpable, that becomes then a business and liability decision that goes to a new environment that I don't think we really have a lot of experience with. And as I said, this is a particular problem for space services. So with that, let me pause and I turn to our next speaker. All right, great. So while she's setting up the slides, oh, that was quick. So James Miller from NASA headquarters and I wanna say, I think Scott really provided kind of a nice overview of spectrum threats and really the concerns that a lot of federal agencies and some in the private sector have. I will say that I am a veteran of three World Radio Communication Conferences. I kind of became the accidental spectrum guy because I worked for United Airlines in the 1990s and United was making major investments in GPS technologies. And so I was at the White House in 1996 for the Presidential Decision Directive on GPS and Vice President Al Gore unveiled it and it was really the civil community having more of a say in how GPS was managed. They created a mechanism called the Interagency GPS Executive Board. And so we were very proud and stayed engaged with the federal government in those efforts. And then what happened is I got a phone call in 1997. You have to get to Geneva at the World Radio Conference in 97 because of this mobile satellite service threat. So you can imagine, I had a hard time explaining to my boss why I had to jump on an airplane at the last minute to head off to Geneva. But basically we crashed the party. We crashed the US delegation. And what we had found is administrations were basically handcuffed. They had to continue to take positions that their national administrations were pushing. Although this encroachment into the GPS spectrum could harm a lot of aviation infrastructure and other things that were being developed based on the promise of GPS. So I call myself the accidental spectrum guy because we actually ended up creating a delegation International Air Transport Association delegation. And I became a spokesperson for that. I had a delegation in 2000 in Istanbul for the next WRC. At that time I had a new boss come in and it was really hard to explain to him why I was in Istanbul for the month. But in the end I think we proved that it was really important to stay engaged. So the lessons from all that is it is really paramount to not only invest in GPS and get value from the capabilities, but you have to be a part of shaping the environment. And so although Scott kind of set the stage for a lot of risks that are out there, I wanted to focus a little bit on the investments, that NASA specifically is making to bring additional benefits to our many constituents. Here we go. All right. Okay. So the organization that I'm in at NASA is called Space Communications and Navigation. And it is within the Human Exploration Operations Mission Directorate. And the bottom line is we acquire and operate all of the NASA networks. So a lot of you will be familiar with TDRS, Tracking Data Relay Satellite System, the Deep Space Network, all of the communications networks that we use for not only calm, but radiometric tracking. So we use it for navigation as well. So that's an important piece. And as part of that piece, we're always looking at ways to optimize use of the networks, developing new technologies. And that also includes being able to share these assets with our partners, not only the US agencies, but also our international partners. So we do a lot of standards development, international interoperability efforts with Department of State at UN forums, such as the International Committee on GNSS. And then of course, spectrum coordination. And so just touching on the GPS part of it, GPS basically expands the reach of the NASA networks. It enables spacecraft to have greater autonomy. It reduces the burden on the networks to have to maintain that two way communications link and that radiometric tracking. And so GPS is obviously a very important enabler to make our operations more efficient. So why is spectrum important to NASA? Come on. We don't really have to ask that question, do we? Almost everything that we do is spectrum dependent. And so I am a heal guy, a space ops guy. So of course I have the International Space Station in there, but at the bottom, then we have our TDRS for our relay communications from the station down back to Johnson. And then of course our deep space network, you can see the antennas, we have Goldstone in Madrid and Canberra so that always these deep space missions are in contact with our networks. And so it's just a fundamental requirement for our missions to have access to good spectrum. We can't have cell phone dropouts when we're working in the space environment. So on the spectrum side, we actually have a dedicated division. It's led by Vic Sparrow. He was a spectrum manager in Department of Defense for many years. And now he runs the spectrum division for our organization. I'm right down the hall from him. And their program really is focused on access to and protection of spectrum that's required for NASA missions. And also we wanna make sure we're in compliance with all federal regulatory policies. And so the division that I'm in, Policy and Strategic Communications actually works in partnership with the spectrum division because I have the P&T or GPS policy portfolio. And I advise NASA leadership, the deputy administrator, the administrator on a lot of issues that require their intervention. And then we have a technical team that's at all the centers to develop our policy positions. And I'd like to point out that this division, I'm the deputy, the director of my boss, Barbara Addy, is in the audience. Thanks for joining us for lunch. And so it is a partnership at NASA. So kind of following that line of logic, why does NASA care so much about GPS? It's a question I often get because people ask me, well, isn't that an Air Force system? Why are you guys so engaged? And I'll start this answer by just talking quickly about P&T because you hear this bandied about, what does it mean? So P&T is positioning navigation and services, the actual services you get out of GPS and other similar constellations. So GPS is obviously the first and well, the best known, but Russia has blown ass. Europeans have Galileo and then Chinese have Beidou. So those are the big four, but there are also regional augmentation, regional systems such as India and Japan have, and also augmentations such as the FAA's wide air augmentation system. P&T are the services. And then why does NASA really care? Because of course we're a user, but we also work with Air Force to make sure that the system has better capabilities. And we've done that through putting laser retroflectors on for laser ranging, a search and rescue package, and we're working to make sure that GPS can be used in the space environment out to Geo, and I'll touch on that in a little bit. But the bottom line is the GPS enterprise itself is managed by what's called an executive committee at the deputy secretary level, and NASA with our deputy administrator has a seat at that table. And so we talked a little bit about scan, doing a lot of other leading efforts with standards and so forth, and also the point that GPS expands the network capabilities. So how does it expand the network capabilities? We're already using it for quite some time on the International Space Station for attitude determination. We have antennas on the trusses, and it's so precise in Leo that we can actually do our attitude determination on it. For space flight, rendezvous and docking, when I first came to United Airlines in the 90s, you had to pay extra to get GPS on board your aircraft. And now we're in an environment where Boeing and Airbus are gonna charge you not to have it. It's basically standard equipment. And what we're finding is in this emerging environment of space commercialization, GPS is becoming standard equipment on Leo and now HEO in geomissions. And so a very important factor. And then of course, earth sciences, everything from monitoring tectonic plate movement to sea level change and ice melt. It's obvious how many science applications are out there. So this is just a quick past, present and future slide. The space shuttle program is retired, but we did use it. We did use GPS on it. And as a matter of fact, I thought you guys might find this interesting. Don't drop this on your toes, okay? This is a receiver that flew on Endeavour at least five or six times, okay? So if you've never touched space flown equipment, I would encourage you to take a look. It is very heavy. Miniaturized airborne GPS receiver. The funny thing is it's not so miniature anymore, right? But it was back then, it was quite innovative. And so we talked about the space station, the use for rendezvous and docking. All of the major space agencies use GPS. And so we've kind of taken it a step further where Orion new system will also have the GPS on it. It's actually based off of a receiver that was developed at Goddard called the navigator receiver. So this is a hardware and a software suite, Geons. They call it Goddard enhanced onboard navigation system. Basically, Honeywell has commercialized this and this is what's going on the Orion. So at NASA, we basically have two centers of excellence that do GPS receiver development. One at Goddard with the navigator. The other one you might have heard about is at the Jet Propulsion Laboratory, the Blackjack receiver, which now the newest version is called the Trig or Triple GNSS receiver because it will process GPS Galileo and GLONASS signals. And what we use this for is not so much HEO or space ops applications, but this is for an application called radio occultation. And radio occultation, if you're not familiar with it, it's basically we know how a radio signal operates in a vacuum. But as the GPS signals go through the atmosphere, of course, if you have differences in pressure, temperature, water vapor content, you're gonna have variations in the propagation. And so we can actually, by measuring those variations, we're able to do modeling and actually get operational weather forecasting tools out of that. And so cosmic you may have heard of actually uses radio occultation. So we took a science application and now it's an operational weather forecasting tool. Now here's an interesting thing from the spectrum perspective. It's not a formal use under radio navigation. It's an application satellite service. So to what extent should it be protected? And when we had this, well, one of our latest spectrum threats, we said, look, the presidential policy says science applications are very important to be protected. And yet we didn't have formal regulatory protections per RNSS. So we are still working with regulators to ensure that this investment on the US government is maintained and is not corroded or degraded by some of these newer spectrum applications that are coming down the pipe from the mobile services industry. So I just kind of gave you a snapshot. The bottom line is space with GPS is just becoming standard. Most of your users when we do surveys are going to be in what we call this the GPS space service volume. So if you look at a sphere from the earth out to about geo 36,000 kilometers, 95% of future space missions will operate in that sphere. Of course, you're gonna have your exploration missions that go further out. You're gonna have your HEO missions. But we're finding that many, many, if not most will benefit from having GPS equipments. And we're working with the Air Force to make this GPS space service volume more robust when they do their GPS three block by. So now we talked about the investments. We talked about how NASA's using it, providing services. How do we manage this from a national perspective? So some of you have seen this before. Some of you haven't. And I talked about the 1996 PDD. Well in 2004, they updated that and they created what's called the 2004 President P&T policy, President's P&T policy, and they created this deputy secretary level executive committee. These are all the agencies that participate. It's co-chaired by Defense and Transportation. Our next meeting's actually June 23rd. And as you can see in the text, NASA has an explicit mandate to develop requirements for GPS to support civil space systems. So that's what you'll see as very active in not just pushing the envelope in the new technology side, but also working to protect and preserve our investments. And so as part of this overall structure, we also have an advisory board. It's basically members of the private sector and academia, non-government reps. And that is really to get feedback from our users. Are we doing the right thing? You know, what should this P&T XCOM think about? And I'll also call someone out, Dana Goward. He's one of our members on the P&T advisory board. And one of our, one of our representatives. Well, he's one of our advisors. Yep. So you can see we have quite a comprehensive brain trust and actually have a list coming up. I'll also also point out that the 2010 space policy reaffirms a lot of the policy points that were raised both in 96 and 2004 reaffirming the importance of what's been said before, but also touching on spectrum protection. The need to protect not only GPS, but these other systems as well, because we do have signals that are on the same frequencies, L1 at 1575, L5 at 1176, it's very important on a global basis to protect these frequencies. And then just the, down the left side, we just kind of go through some of the international organizations that we stand in. So here are kind of the goals and objectives, high level goals and objectives. And look at what the first one is. Provide uninterrupted availability of P&T services. I mean, in my mind, that means don't degrade the signal reception, protect the spectrum. And of course, we work very hard to modernize, so that we're meeting emerging scientific and commercial demands, always will remain the preeminent military. And we wanna be internationally accepted. We do that by preserving the spectrum. And then technological leadership also plays an important role. And then on the 2010 space policy, it hits on all those points, also reaffirming the spectrum protection, but also reiterates the importance of using foreign P&T systems, not as a primary, but as a backup or complimentary. And so we wanna make sure to protect these signals again for our international partners. So we're getting towards the end. This is the P&T advisory board that I had mentioned before. And you'll recognize a lot of the names up there. Mr. Stenbitt was the former DOD CIO. He's our current chair. Previously, it was Dr. James Schlesinger. I really enjoyed working with him because I watched him on TV as I was going up while he smoked his pipe. And it was sad that he passed away, but he was quite the advocate for us. Dr. Parkinson, of course, the architect of GPS in the 70s. He's been one of our original members. Governor Garinger, the two-term governor of Wyoming. Admiral Thad Allen, you'll remember him from Hurricane Katrina. Marty Fega, the former NRL director. So we have quite a brain trust there and we're very proud of that. I wanna mention that on May 18th and 19th, the advisory board will be meeting at the National Harbor at the Gaylord at the Intervention Center and it's open to the public. So if you just Google P&T board, it will come right up, all of the details for this. And we have a federal register notice that just went out. But if you have an interest in these types of activities, I would really suggest that you go, you just sign in, be an observer, but there's a lot of interesting discussions. And on the breaks, you'll get a chance to meet and question some of our members and speakers. So I think it's something that NASA does. It's our contribution to the policy sponsoring this advisory board. I was appointed by the NASA administrator as the executive director many years ago. We set it up. This will be our 17th meeting. I think you'll find it enjoyable so I hope to see some of you there. So the focus of this advisory board, because of the vulnerabilities and the threats that we talked about, is to protect, toughen, and augment GPS services. And so as an example, protect the radio spectrum and identify and prosecute interferers. Well, if you have a GPS jammer in Australia, you might get a $25,000 fine, but if you have a GPS jammer in the US, maybe you just get taken away. So really, the technology has gone far ahead of the ability of law enforcement to kind of keep up and make sure that we sway people from actually harming the services. Toughen GPS receivers. Well, we see the spectrum environment. We know we have to be responsible and make sure our receivers are robust. Within NASA, we're always using a lot of different techniques to have a backup. And the advisory board has suggested that you have a national backup capability because GPS is so critical and could be vulnerable. So Enhanced Loran is one way that we could provide a timing signal throughout the United States. So there'll be a lot of discussion about that in May. And this slide I just wanted to put up there because it really shows, we know about the benefits and the investments, but when we're fighting these other groups that want to encroach on the GPS spectrum, they make claims that if GPS was only out of the way, GPS wasn't there. They're really, really in our way to make a lot of money, service, the US user groups. Well, I don't see that we're in the way. I see that we were there first. And also that the economic benefits generated are quantified in billions and billions of dollars. And so I think it's a very effective and efficient way to provide these services just through a couple of frequencies in the elements. And this is a study. Again, you can do a quick Google search on P&T board and pull this up. So this is actually my get off the stage chart. I think it's obvious that GPS is such a huge utility. NASA's able to capitalize on this and provide additional benefits. The Air Force gets all the credit for acquiring and operating this system, but we sure appreciate working with them to make it more robust. And GPS is located in a portion of the spectrum that is beachfront properties, always gonna be at risk. And making it a victim service and forcing the burden on the receivers and whatever interference really isn't going to solve the problem of polluting the overall spectrum commons that we all share. We have specific allocations for services. The adjacent band just below GPS is a space to earth mobile satellite service band. And to transform that into a terrestrial band we'll put the rock band into my front room, as Scott would say. And I really don't care for that. So we'll have to see where all that goes, but we are participating. And in the DOT adjacent band compatibility testing that Scott mentioned, I've ensured that NASA has numerous types of receivers in there. So we can test with the... So with that, we're gonna remain vigilant and continue to shape our environment. And I'd like to keep your interest. GPS.gov, a lot of cool stuff to access there. And that's it. Thank you. Going to flip charts, you won't find any for me. Or if you do, this will be remarkable because I didn't give you any. So thank you for being here. And good afternoon, everyone. My remarks will be brief, partly out of necessity because I'm losing my voice today. So I may end abruptly here. I knew I was following Scott and Jim's and we're all GPS fanatics. So I wasn't going to add on to what they have already ably covered. But just to, I guess, toss out some numbers to give you a feel for the space community and the importance of some of the systems that are there. By most accounts, there's over a thousand operational satellites in orbit today. And as Jim mentioned, they would be completely useless to us if we didn't have a way to get data up to them and back down to the Earth, as well as in some cases for them to communicate with one another. There is one manned space station. There's something on the order of 20 active space probes going elsewhere in the solar system. So a very important set of assets. We are all on the stage here, big fanatics of GPS in similar systems of which that's about 10% of the satellites that are in orbit today. A lot of people don't realize that beyond the 31 GPS satellites in space, that we do have 70 other navigation satellites up there. So they are growing in number, but still only a small percentage of the overall assets up there. The rest of the vehicles that are up there are used for all kinds of different purposes for communication, meteorological, scientific missions, and so on. And I thought I'd mention, I guess, what takes place at one of these fantastic parties that Jim mentioned, at the World Radio Communication Conferences. And don't be fooled, if someone tells you you're going to a month-long party and you get sent there, you'll find out quickly. It's about the worst party you've ever been to in your life. It's about a month of arguing, not just eight-hour days, but arguing all through the evenings as well to try and hammer out deals down to the, usually down to the wire. And the last, one of these fantastic parties took place just in November of last year. And I think as testimony to how important the space industry is and how it's recognized as important, the space industry actually did, or community did quite well at the last work. The biggest threat, I think, to all of space use of spectrum is the same threat that everyone's facing nowadays, which is our love for our mobile phones and mobile broadband devices has led to the world and domestically, us all trying to cram cell phone networks in every band that we can imagine. And at the last World Radio Communication Conference last November, they set their sights as one huge agenda item at all the spectrum below six gigahertz, which that community telecom industry would have loved to own the whole thing. They're mad, they only own, I don't know how much, maybe 70% of it or so. But the space industry actually did quite well. There was some losses to C-band communication frequencies that were expected, but largely the space community held their own and not only held their own, but made some gains as well. They gained protection to be able to sniff automatic dependent surveillance broadcast from aircraft, from the Arian's service that will be provided over a radium next to help with what was brought to the World Radio Communication Conference as an urgent need to deal with global flight tracking after the Malaysia incident. And there were some other gains as well, some additional frequencies gained in KU-band and elsewhere. For at the next World Radio Communication Conference, that will take place in 2019. And now the IMT, which is the international euphemism for mobile telecom industry, has their site set from everything from 26 gigahertz up to 86 gigahertz. But fortunately the space community is also well positioned because they will plan not to look at the space communication frequencies that are there. Although as we learned from Scott's presentation, just because they're not going to look at operating right in your band still doesn't mean you're fully protected. There are huge implications if they happen to go into bands on either side or anywhere near you just because of the disparate power levels. So that's something that this community will need to keep an eye on. And with those remarks, and also because I want to give Jennifer a chance to retort some of Scott's lawyer jokes. I will pass the baton at this point. Thank you. Actually, this is why we're together. We both don't have charts. So hi everyone. And I'm sure I was the exception to Scott's lawyer jokes. Right, okay. So first let me thank the Secure World Foundation for hosting a panel on this topic. And I really mean that because right now if you walk around town, you can go to a conference on spectrum probably in most conference centers. But they're all focused on mobile broadband. They're not focused on all of the other vital uses of spectrum and what the implications are for these uses from the 5G debate. And I say debate because it's not quite clear what the outcome will be. You've heard what the various government interests are in spectrum and obviously GPS specifically. But when we talked we agreed that I would kind of talk a little bit more broadly. So why is Lockheed Martin sitting up here and some of you say, oh, you do Orion, you do GPS 3, blah, blah, blah. Yes, a lot of our platforms and systems are spectrum dependent. The things we build not only for the US government but for other governments and customers as well. But the whole aerospace and defense industry is vitally interested and affected in this debate. And usually when we talk about spectrum protection it's not taking into account that there are multiple industry segments that should be engaged. It's always focused on mobile broadband versus the federal government or the US government or government interests. That's not a correct depiction because you have multiple stakeholders within industries. And the aerospace and defense sector is a key participant in this. We are trying to have our voices heard in addition to, obviously again, a lot of the platforms that you've heard about today, there are also commercial services that are being provided, whether it happens to be the Lockheed Martin GPS augmentation system to the FAA or if it's commercial planes that Boeing flies with their wireless avionics coming. No matter what it is, everything we do pretty much as an industry sector touches spectrum and is dependent upon it. So just with that is a little bit of backdrop then to kind of turn to the topic itself, spectrum protection. So that's the question is what do we need protection from, right? So we've heard about GPS needing protection from interference and most of that discussion was unintentional interference. But let's talk more broadly about intentional interference. We need protection from that as well. That is less addressed. There are plenty of examples of that when you look at some of the historical widely publicized reports, BBC Voice of America over Utah Sat being, you know, experiencing a lot of intentional interference. So what were the recourses? Because they suffered interference for a long time. The solution, I don't know if it's a solution, but the recourse was to go to the ITU, the International Telecommunications Union and at the Plenty Potentiary Conference 2014 and seek to empower the ITU to enter into Memorandum of Understanding with Earth Station monitoring facilities around the globe so that they could monitor for, or do measurements if you like of harmful interference incidents. The ITU has no enforcement authority. So it becomes a documentational function, which may have value to build the case for pinpointing interference. Again, for a public inspection if you like. I think, but there's also risks when you do this. So now you have an international regulatory body and I do believe the ITU is a regulatory body. There's a debate on that, but an international regulatory body capable of doing measurements has implications for the satellite industry. Measurements of what frequencies you're transmitting over? Where and what, not what you're transmitting, but where and how, how often, et cetera. That may not be information that all operators, be they government or commercial, want to have in the hands of a regulator or available to others, because it's not really clear how that data will be managed. So there are some view that is a little risky in a direction that that may go. And if it were to go into some of us are paranoid, if it were to go into a direction where it became a check on how heavily does one operator or one be a government or industry use a satellite? What would that measurement be used to determine? Whether or not that's an efficient use of that particular orbital slot and spectrum and whose determination unclear. But that's just a flag one element there. I think the greater question though, and from my perspective and experience over the last 20 years of these parties, is the international, I should say, the regulatory internationalization that's going on. And by that I'm referring to efforts at the national level to figure out how to spectrum share, which is good. I mean, we all need to get behind that and try and come up with very sound technology solutions. But a lot of these sharing solutions are in a very early stage. They're almost experimental. And yet regulators are looking to export them as if they are proven out, tried, tested, and true, exporting at maybe a TRL level one or two, as opposed to waiting until they're, what, maybe a seven. Because once you export these ideas, very hard to claw back, very hard to amend. So for example, we're domestically going through a process in the 3.4 to 3.7 gigahertz band. At WRC 15, there was a strong effort to try to export the use of that band as being able to be shared by mobile and satellite. The constraints and framework domestically that the FCC, in this case, is using to try to implement that sharing cannot be exported into ITU regulations. The only thing that comes up in ITU regulations is can they share, so then they show up in the framework, and then protections for cross-border, not for national use. So a national framework that's about how satellites and mobile will use spectrum based on the spectrum environment in a given country that then gets transmitted to the ITU, does not get transmitted or then implemented into radio regulations with any guidance. So a national regulator that may not have the staff, may not have the equipment, may not have the capabilities resources as an FCC or UK off-com or a French or a German regulator, may find itself in a position of just reading a radio regulation which says, oh, these are compatible, they're both in here. ITU work 19 said that, but they have no idea what the constraints are to ensure national compatibility. It's only if it's an international issue do the constraints and technical parameters get put into the radio regulations. So from where I sit, that's a huge threat and protections that need to be put in place is when we are looking at regulatory experimentation, which we should be, right? Regulatory experimentation needs to happen, but it needs to be allowed to take place for a period of time to have proofs of concept be proven. We've had experience, again, where that has not happened within five gigahertz with dynamic frequency sharing and radars. Primiturally exported, problems ensued, having to figure out how to get the fixes we're still working on here, implemented back into the international environment so that the radars, for example, that are impacted from the mistakes or misunderstandings here are corrected elsewhere in the world. These are real practical challenges and when I look at the title of this, policy and practical implications. So good meaning policy, let's extract the most intense use we can of spectrum, but prematurely trying to get the world to adopt things before they are proven out has practical implications for what I'll call the victim, the victim or the negative term incumbent uses because we all know incumbents can't be innovative and new. So that's another point. My other concern is that something we need protection from in spectrum is the omission of the regulator from the national space policy discussions. RNSS, GPS did very well to include spectrum in its US policies, but when you look at broader US space strategy and you don't hear spectrum, it's an inconvenient discussion when you want to include spectrum. And so you have wonderful goals of achieving satellite and other space leadership globally, but if you can't assure that the most basic element is protected, how do you achieve that goal to any level of reliability? How do you guarantee that to those to whom you're making promises? And I know it's an inconvenience to engage independent regulators or to try and have a discussion about something that some people think is very arcane, but when the wireless industry can talk about it as it's lifeblood. And we can't talk about it in the context of a larger strategy that is equally dependent upon access to space. We find ourselves at a disadvantage. So those would be my points and I will turn the floor back to you for any questions. Thank you. Well, actually, I'm from a sort of a narrow standpoint. I think the existing national space policy by and large is fairly good. The sections of it that are flawed to me tend to be more in the exploration side of it and some things on commercial and industry relationship that I think could probably be fixed at kind of a sectoral level. But Jennifer raises, I think, a very, very valid point about the role of a broader spectrum beyond the GPS community and she's right to point that out. And I think one of the key difficulties that might be worth a discussion on space is the relationship with the independent regulator that is the FCC versus the government agencies. So the US process is orthogonal to pretty much the way the rest of the world does things. That is we have a independent regulator for commercial and private sector spectrum allocations. We have a government agency that's responsible for government spectrum allocations and they're supposed to talk to each other. So the FCC doesn't technically report to the president. It is an independent regulator. And so it's kind of a separation of powers issue that goes really to the heart of the way US government runs. So one of the things that I would probably do to get at the salient points that Jennifer raises is I would like to have some thoughts about strengthening the relationship of the Commerce Department and for commercial space activities more generally and then NTIA within the Commerce Department to be more responsive to the needs of both agencies and of the space community. There's a number, this is probably a whole separate seminar, but there are a number of space issues that I think could be more effectively addressed by a stronger, more coherent Commerce Department, whether it's export controls, spectrum, space trade agreements, regulatory matters, trade promotion and so forth. So I think the way I would try to get at Jennifer's point is I would try to strengthen the role of the Commerce Department. Well, the 2004 P&T policy had enough substance in there and was crafted at a high enough level with the deputy secretaries coming to the table that it's lasted through two administrations. And I actually, when I was at Department of Transportation about 13 years ago or whenever it was, I actually co-chaired with Department of Defense the interagency group that crafted the charters for it. And so I would say one mistake we made is when we were basically transitioning from the 96 to the 2004 policy, there was a bit of a vacuum while we set up the new structure. But since then, if we did not have that P&T XCOM structure, there would not be a DOT adjacent band compatibility study. It was actually the DOD Deputy Secretary Defense Department said we really need to be more proactive in responding or respond prior to a threat being at our door. So I don't know that I would change much or I have much to complain about. I agree with Scott that it would be good to strengthen the role of Department of Commerce. And remember, because we have a bifurcated spectrum management process in the US FCC doing private sector and commerce, NTIA doing the federal agencies, sometimes there is a bit of a conflict to work through. And so it's a prioritization and a balancing. So those are my points. Something here, my comment about commerce is not just because I used to work there and have warm feelings for the place. It's because the Commerce Department and through NTIA represents the interests and needs of federal agencies who in turn represent, authorize and appropriated and congressionally funded public missions. So the National Science Foundation, NOAA, NASA, these are not narrow, special interests. These are public missions that the administration and the Congress support. So it's not just a nice to have. If you don't support those missions, then you're not doing the job that the Congress and the White House told you to do. And so I look at the Commerce Department as being the vessel for communicating that public interest aspect in balance with the private sector interests. And in the case of the space community, there is the happy coincidence that the private sector and the government agencies are actually fairly well intertwined. So it's not a matter of having tension so much within the community. It's a matter of saying space as it impacts broad range of public and private sector interests is appropriately protected and sustained against other perfectly worthy and competing interests that are more trustfully focused. General agreement that the PNT US policy is still good. In fact, if you look at what changed from 1996 to 2004, it wasn't profound really. It did elevate it up from an assistant secretary level up to a deputy secretary level for the management and a lot more thought was put into it, but some of the main tenants actually remain the same. I'm also in general agreement that other topic of spectrum regulatory organization in the United States, that that's something that's definitely worth looking at in a change of policy. There's been a lot of discussion about our strange, bifurcated system that we have in place now and the issues that are rising right now where NTIA used to view the federal government as their customers now is put in an awkward spot because they are being asked to find spectrum for terrestrial mobile broadband, which puts them at odds with their federal constituents that are looking for them to help protect their mission needs, which are at odds today. There's been a lot of discussion. I think it's worthwhile discussion to continue about going maybe from a bifurcated structure to a single spectrum entity that would balance the needs of the federal government systems as well as the commercial need for terrestrial mobile broadband. But here's the good and bad news about that. A single integrated system is fine if in fact it is truly integrated. What happens with a lot of our European colleagues is they will get a particular point of view, often maybe a commercial or industry point of view, and we find the national security and public safety aspects and science aspects are frozen out. So the old joke about we have the worst system except for all others, I don't necessarily envy other people's internal processes. I just think ours could be done better. We're not letting you guys ask really any questions, but I'm sorry, I think one of the interesting options would be to consolidate perhaps within the executive branch the allocation issue, which is not about the competition in providing commercial services. The FCC could be the licensing entity, licensing agency, but could you achieve the integrated allocation policy if it were in the executive branch which would have the responsibility for both commercial and commercial industry as well as all of the executive branch interests and would that be the way to integrate it into all the different strategies? I just thought that out as a question. A better accountability, because if a bad decision was made, it could be elevated and ultimately the president would be responsible for it. So there's an alignment of accountability which doesn't really exist right now. Dana Goward, R&T Foundation. So following on to all of this discussion. So the 2004 policy, there have been some good things done in the 12 years since then, but there's been, there's a lot of things that have been left undone in terms of interference detection and mitigation. We're only now really taking a serious look at protecting the spectrum and augmentation systems et cetera and so forth. So isn't there a bit that's been undone that's been left undone that might in a new P&T policy since we're talking about GPS might be better governed and structured so some of these undone tasks could be addressed? Well, I think one of the undone areas that was maybe brought up a little bit earlier is really what the international aspects of this are. I think that a more thoughtful role or a more activist role, I think on part of the State Department on our international engagement with other countries. So for example, as you know, a number of our colleagues in the UK are very fond of the E-Laran system and it has a certain amount of merit to it and it's particularly maybe valuable in and around where they are. At the same time, this is the same entity within AFCOM that has been promoting in-band pseudolites. So there is not quite always a coherence sometimes when the government left-hand doesn't know what the right-hand's doing. I think we could perform a helpful service in our engagement with other countries to try to get some more consistency. Meaning that if they're looking for international cooperation on E-Laran, for example, I would say we need to clean up domestic issues right now, like don't allow emitters in this band. Just as we have cleanup to do, I think on our own house in the US and balancing the allocation issue, I think we can see areas where there are disconnects overseas. So the international and the, excuse me, the intentional and unintentional interference threats are somewhat different. And before we can really go after intentional jammers, we have to make sure that we've done all we can, I think in our own domestic regulation to make sure there's not unintentional things. Now, in a wartime environment, you know how to deal with intentional jammers. But in a peacetime environment, you want to make sure that the environment is kept as clean and safe, as stable as you can, which means good regulation, which means consistent regulation that's globally applied. So I guess that kind of more extensive spectrum sort of outreach and consistency and alignment is probably one of the things I would look for. Dean, on your question, I think the policy actually isn't bad. It did point to a need to do interference detection and mitigation. I think the issue, and this is my personal view, is that that responsibility was given, I think to the right place, which was DHS, but back in 2004, I think anyone who deals with DHS would tell you that when they were starting out as a new organization that was a mishmash of all kinds of people from elsewhere, that there was some challenges in getting up to speed. So I think that some things that were called for in the policy to be done have been progressing much more slowly than we would have liked to see. But the policy, in my view, is sound. It's just that we had some growing pains with the new organization. So working with you, Dana, for the last several years, I will say that I think the PNTXCOM policy structures basically enable these types of issues to be brought to the senior levels of government for discussion and mitigation. The advisory board that you serve on has made several recommendations at the Depsec level, and although the XCOM itself is only supposed to be really a coordination body, they're not supposed to dictate policy, but what happens when you have government reps meeting at that level is a lot of the discussion items do end up becoming policy because of the level of interest. So what we've seen, such as the recommendation for Enhanced Loran, is budgetary constraints and actually implementing or following through on recommendations that have come up through the XCOM. But I think by and large, DHS has the opportunity to bring their issues forward. They have. At the June meeting, I'm sure this will be one of the important ones. State Department, a member of the XCOM, brings interference detection and mitigation into their international forums and reports back to the XCOM. So when we go into drafting a new policy with the new administration, should they decide to do that, I'm sure we can strengthen it, but again, I have to reiterate, we're quite pleased with what we've been able to accomplish with the structure that's in place. Paul Jaffe, a new research laboratory. Recognizing that this would probably be extremely challenging, what would be the process for securing a spectrum allocation for a new satellite service in the two gigahertz to nine gigahertz range? The question is what would be the process? Yes. So this would be for a federal system? Potentially. Yeah, I guess it would depend on. It could be either. So while there's domestic and international allocations and I guess with the Navy, you would actually work through your Navy Marine Spectrum Management Center, is it NFC? Yeah, I'm looking probably for a broader answer because it could be commercial. Just general satellite service in two to nine gigahertz range. Yeah, go ahead. And I'm looking also kind of for the, not like the flow chart necessarily, but I anticipate that there's probably a lot of external things that happen in spectrum allocations because there's so much at stake and the users have a great interest in securing the spectrum. So I'm looking for the stuff that wouldn't be in like the regulations about it. Okay, so I, okay. So we're assuming that there's no international or domestic allocation at this juncture. So you would have to, two things. You'd have to petition the FCC for a rulemaking and you would have to pursue getting an agenda item at a WRC to add an allocation for the specific satellite service, FSS, MSS, whatever you want. Into both of those processes, those significant, I'll call it multi-stakeholder consultation. And that could be, if it's depending upon of course the spectrum band chosen, you may have a lot of industry consultation. If an industry player picks a government band, you may have a lot of government consultation. There will no doubt in that range be a lot of consultation for both in-band and out-of-band issues to be addressed. And then at the, again, presuming there is no, let's say you were able to make it an urgent allocation matter and somehow get it squeezed into the WRC-19 agenda which has precedence, but it's hard. You would have a lot of studies that would have to be done on an urgent basis to demonstrate how that would be compatible with existing services in that spectrum if indeed the US would support that. Because it's, you know, if you're going to go through the US, and I'm not assuming you're the Navy when you're saying this, if an entity is going to go through the US then you would have to get pre-U.S. approval to submit to try and get it on the agenda under the US sponsorship if you like. So there's a lot of different requirements and I'm not quite sure what you're looking for outside the flow chart, but I think you'd get a lot of mobile government, non-mobile if you picked other interests in the band that are commercial engagement. You'd have to go through public proceedings as well as a lot of informal offline discussions. Jennifer, I would ask, depending on the allocation and where it impacted, is there then a budget allocation because if, for example, if the allocation went into an area of spectrum that otherwise would be auctioned, there is then a loss of spectrum auction revenue that would then have to be offset. So that would certainly be brought up by the other stakeholders, but no, I don't believe there's actually a CBOs, it depends if the band had already actually been moving toward. But depending on which band you're at, yeah. It would be a really high hurdle to add a satellite allocation to a band that has already been specifically designated for auction, like the band that's just now a broadcast spectrum. Thank you very much and thank you very much for an excellent panel discussion. We literally could be talking about this all the way until it's beer time and past. Somewhere, somewhere. Good point. Beer, someone say? And I just want to say that I'm Bob Accus with Aerospace Corporation. We're working on actually an allocation currently with NOAA for space weather and just kind of give you an idea about it. We discussed it at work 15 as an upcoming agenda item which will actually not be an agenda item until work 23. And that's space weather to develop that as an allocation. This stuff takes time. It's slow. And you have about 180 some odd countries that might disagree with you. So you go through a lot of stuff. And that's not even, we haven't even identified the spectrum yet. So it is a long, hard process. And one of the reasons is that it's hard to undo what is done. And I think what Jennifer had said earlier is very true, is once you get started down a path, it's hard to bring it back, which kind of leads to a couple of questions here that I had. And I'm going to try to put them all together so I can get one question and two questions into one. But I think one of the things that you touched on here that is important to understand is that aggregate energy in all of these other transmitters, so often when we start talking about band allocations, we'll say something like 1695, 1710, not realizing that 1694 is going to get hammered by an LTE system or something, because it doesn't stop at that line. And that energy actually moves out farther and farther and becomes noise. And so we see a rising noise floor. And so often in satellites, your link margins are based on that noise floor. And it's not as constant as it used to be. So I want to kind of ask a question about this rising amount of noise energy and the issue of aggregate interference, which is becoming a potential concern, actually is a concern, and how we might go about starting to characterize that. Because one other thing that goes with this is that you can't, when it's aggregate, who do you blame? It kind of goes back to what you said earlier. It's sort of like all you can do is which screaming child was the one that caused you to get a headache? At that moment. At that point. So you end up just all of them. Thank you. Well, I just thought on that. The FAA, at one time, had tried to actually use what they called a single to multiple entry margin to account for the fact that you have multiple screaming children, not just one. And they wanted each one to not raise the noise floor more than a tenth or something of what you could tolerate overall. That didn't go over well at all with the regulators. And part of the reason is simply because of the practicality and administrating the rules, they want to really be able to have just one metric to compare someone against without having it padded so much as you'd really want to do if you're worried about noise creep. I think it is an excellent point and one that should be addressed, I think. But the regulators really don't have a great interest in doing that. One point I'll just chuck in before I yield the floor, though, is I wish that the regulators, especially the FCC, would become a little more engineering rich as they used to be in the past because it seems like more and more now we're leaving the technical merits of different proposals to be duked out just in the public record that's accrued by some wonderful lawyers and some not so wonderful writing letters in rather than an independent engineering arm in an agency like that that could tell the merits, figure out the merits on their own and make decisions. Actually, I would say some of the best lawyers that we've had at some of these work parties have been ones that you would almost swear were engineers. After a while, you'd go, really, you're a lawyer. And because what happens in this process as Jennifer was describing the parts of the flowchart, what's really challenging about this is that things start off fairly technical. But as they move through the process, they become completely political at the end. And so if you don't understand the engineering side, well, you can't do the politics very well. But if you don't understand where the politics might be going, your engineering can be completely irrelevant. And so putting together someone who can span that whole space is really, really hard. And so what you often need is you need teams of people trusted so you need basically multi-talented functional teams to kind of take it through that whole process of technical people, legal people, acquisition, commercial people understand the industry. So it's a multi-talent kind of problem. If it's just one person or one firm, you're probably not going to get all that talent. The other thing is that this points to the need, not just for technical analysis in general, but for the need for intellectual property within the government. The government cannot be simply an entity that tries to dispassionately judge a whole bunch of different things coming forward. At some point, you actually have to apply technical judgment. And while being conscious that this is being taped, I'll say that I often could probably have a good consulting job by asserting that I could predict what the commission will do on any particular rulemaking by applying a very simple metric. Which choice requires the least amount of conscious thought? Sharing, auctioning, negotiated rulemaking, commons. I mean, there's a number of different things, none of which involve actual value judgments of this versus that. And so I think greater technical content within the commission and within the agencies on these matters is really, really important. Because ultimately, this is not stuff that one can outsource. You have to have people who actually know what they're doing inside. And then finally, with regard to the noise floor increase, this is exactly why the GPS community often talks about the 1 dB rise in the noise floor. Some of you know a C over and not. And why the policy talks about protection of the spectrum environment. Because there are people who would like to talk about particular impacts of particular applications. Like as long as my cell phone can receive a GPS signal and tell the Uber where to come, what's the problem? Well, that may not be satisfactory to somebody else doing earthquake measurements. It may not be satisfactory to somebody maybe doing water vapor measurements. So the danger of getting away from a spectrum environment metric that's actually fairly simple and you understand 1 dB rise in the noise floor, C over and not, getting to particular applications, you intrinsically get into value judgments about what application is worthwhile and what is not. OK, that starts becoming an industrial policy choice of saying which victim receivers are not worth protecting and which ones are. And who makes that decision? So what we try to do is we try to protect the overall environment and we let innovation happen within that environment. What we try not to do is to sort of pick and choose which children, child we want to save and which one we want to sacrifice. And I would point out this goes internationally as well. When we had debates over spectrum fights, there was a point at which we could choose to protect GPS but not GLONOS. And we chose to protect GLONOS as well, OK? Because we're talking about protecting the entire service allocation, which is what we signed up to at the ITU. So we don't pick and choose between systems. I just wanted to respond because I really appreciated your comments for two reasons. Besides these luncheon talks feeding us, there's really good collaboration and networking opportunities. And I really liked what you had to say because we're looking at our future TDRS services. And one of the things we're considering is what's called TAS or TDRS Augmentation Satellite Service. And what that is is basically taking what some of you may know as global differential GPS or basically the JPL ground network where we can actually monitor civil signal performance in the Air Force is using that data. And we rebroadcast that up through TDRS. And we do differential and integrity similar to how the FAA does the wide area augmentation system. So it's proven technology. But we're also looking at additional data sets we can include that the space user would be interested because we don't want to get in the aviation safety of life business. What we want to do is serve our space users. Space weather alerts through this channel because of the amazing coverage we have with the TDRS fleet is something that we're building a community of interest in. So let's you and I start. So that's the first point. The second one, in particular on the 1DB, this is something that this company that wants to use that 1525 to 1559 put in a trustee network, they want to correct the knot on that 1DB protection criteria. They just don't believe in it. So in their studies, they really want to look at where the GPS receivers lose lock. Whereas we argue back that if you're really concerned about the effect on the noise floor, you have to look at the aggregate effect of 35,000 plus base stations. And there are some things like radio occultation and Leo that when we're over KONAS, we might not be able to do that application any longer. So that's an argument that's currently in play is what metrics will be used to come up with a final regulatory decision. I have one example. So I agree completely. National regulators do not want to deal with aggregate interference. It's too much work, as they often say. However, there's been one example that I refer you to, which you may already be familiar with. And under the ITU umbrella, but kind of outside of it, which is the resolution 609 process, which is RNSS systems every year being measured to ensure that they don't exceed a threshold to protect ARMs. And what's been very interesting about that process is, one, it's worked to date. But two, it was a method to narrow down to the systems you really need to care about, which are those that are being brought into use, as opposed to paper filings or the entire satellite, all the satellite filings that say they'll come into use with RNSS. You've got to be at a certain point. And that has been very manageable. And what we'll do if and when we ever exceed or hit that threshold is a different question. But we have been able to really effectively watch and ensure how close are we coming to the threshold? Are we only calculating the systems that are really going to be emitting and trying to take this all very seriously? And that has been the one example, I think, of success in this area. But it's because we've been able to define the universe so clearly. And by definition, in our RNSS systems in use, much smaller than when we're talking about mobile broadband, handsets, or devices. Hi. My name is Ja'Elsaid Greenham with the American Meteorological Society Policy Program. And all of this GPS, PNT, GNN, and S stuff is a little new to me. So thank you. I've enjoyed learning about it. And this may be a little bit off to the side, but I think it does relate to some of the questions we were talking about, about policy process for allocation and assignment of spectrum. In the weather enterprise, the public mission is to protect life and property. But the implementation of that is through a very strong public-private academic partnership. And we've been hearing concerns from our private sector components of the enterprise that they might not be protected in the same way that federal agencies can be through NTIAs, like protective zones, for like, goes our downlink stations. And it's really concerning, possibly, to hear that you feel that NTIA already doesn't have the ability to protect and advocate for the public missions for the federal users. So if you could discuss a little bit about how you deal with protecting, advocating for public mission uses of spectrum with both private, public, and academic sectors working on that. In this case, well, in any similar case that you've described, I would strongly urge a multi-pronged advocacy effort. One is NTIA, obviously. One is the FCC. And one is Congress. Because I think all three need to hear the same message from the communities that are being impacted, whether it's congressmen who are concerned about whether in their state, whether it's congressmen that have the academic institutions in their states, but also just generally to understand how a lot of federal systems serve non-federal purposes. I think the GPS coalitions have done a fantastic job of raising the familiarity level with the Hill and other parts of the government outside of the actual system owners. But I don't think that's the same for all of the other similar-type systems. Let's just pick a NOAA weather system, a weather data system. I don't think there's that same level of awareness of the direct dependence as opposed to federal agencies just being able to provide that data and some other means to. And I think it's very important to have a three-pronged campaign. Because NTIA is in an awkward position. So not only are they looking at the federal user and then the commercial interest on the other side, you bring them a third dimension to factor in. But those interests should go directly to the FCC and the Hill as well. If others want to add. It is a good question. I just want to point out that our bifurcated system leads to weird situations where the federal government isn't protected using private systems. The federal government, the Department of Defense in particular leases a lot of commercial satellite capacity. And there's a strange situation where if they're communicating through one of these satellites, they're actually not protected now. NTIA has written a letter to FCC asking for this regulatory gap to be addressed. And it has not been replied to that I've seen anyways. So a very good question and something that needs to be addressed on both sides. Yeah, and I would sort of say that I've seen for the AMS, I guess there's been some ex-partite filings to the FCC. So that's been good to get yourself sort of on the record and in public. And then the next step, of course, is as Jennifer says, you take that to the Congress because the Congress is going to be very concerned about if their constituencies are going to be harmed. OK, there's nothing that gets a Congress from its attention quicker than you say there's a public safety issue that's impacting your district. And if you can show technical studies that demonstrate this is not hand-waving, but here's the technical data to back it up. And then you show that you have gone to the FCC and you have talked to not only NOAA, but also to the Commerce Department farther up the chain to make that point. And then you're into the Congress. And in a way, yes, you have a hard roll to hoe because this multi-pronged attack is a lot of effort and a lot of difficulty. The good news is that on the technical side and I think on the political side, you're in, I think, very fertile territory. This is not a hard sell for protecting the public if you've got the data behind you. But on the other hand, you can't assume that somebody will just do it because it's the right thing to do. If you are not noticed if you're missing. So thank you for the question. And it really made me think because we have been actually actively engaging with NOAA leadership specifically on GOES, the GOESR series that's coming up. Because we're working hard to get the Air Force to expand the availability or the coverage of GPS at GEO. GOESR and other weather programs will benefit greatly by having that capability because as you go up and altitude, your coverage varies. And so we're trying to, for the next block of GPS 3s, stabilize that. And what we found is people don't understand that weather change is becoming a national security issue. And so NOAA is just your friendly space agency. But DOD is the gorilla in the room. And they are the powerful player in the XCOM. And so to the extent that you can get military constituents to go up their chain and partner with the military agencies. It's worked for us on a number of important programs. Model University Space Research Association. I had a question concerning this discussion on advocacy and also what Jennifer Warren touched upon, which is that the debate is framed in terms of the mobile communications industry versus government. Is it inherently challenging to form a coalition to push back because GPS applications are so mirrored and so ubiquitous, time stamping on financial transactions, that the victims are unaware that they're victims? Or even if they are, they just think this is going to be sorted out. So you can't, you know, DOD is an 800-pound gorilla, but you can't get Goldman City Chase to join with you because of the ubiquity of the GPS applications. So it's sort of ironic that so much would be affected by this, but you can't get the 800-pound gorillas. You can get academia. You can get the DOD to look out for itself. But trying to build a coalition to push back against the mobile communications industry, how the debate is framed, seems to be an issue. No, no, she's taking all the questions first. Get them all in. Yeah, Mark Mulholland from NOAA. And when Jim was talking, it occurred to me that the only reason that we could formally engage on this issue that Jim talked about was that the P&T infrastructure permitted it. And we can't do that in the rest of the weather world with the spectrum. So I think there's a complement there for the P&T world. And then the only other thing I was going to bring up real quickly was in the spectrum wars, the obvious answer to us is, well, just take it off a satellite and put it on the internet, which of course is obviously quite vulnerable. The thought that pops into my head was the thing that exists in the telecom world. And because of my 102-year-old mother-in-law, I'm very aware of the carrier of last resort, where the telecoms have to provide really, really old, really, really copper service because it's a necessity and a public utility. And we don't have time to get into that discussion, but I just kind of throw that out maybe in the regulatory world is a way to protect all these vital government services is to write a carrier of last resort-type thing into weather and other government services. Hi, Becky McCauley-Rench from the Potomac Institute. My question's kind of more high-level. And that is all of the issues you guys have been talking about today are really international issues. So my question is, how do you get everyone to follow the rules? How do you get people not to just be the loudest voice and do whatever they want? Our questions are looking at how do you build a coalition if you don't know you are a victim? What about the possibility of building some sort of carrier of last resort? And how do you get people to follow the rules? Go to it. Just a quick one on the coalition. The companies that actually did create a GPS coalition all get sued. So they found that being on the pointy head of a spear sometimes isn't that much fun. So that's one of the challenges you have forming a coalition like that when you do have a big gorilla like the telecom company with a lot of money behind it. That's one of the risks, I guess, of being an advocate for your broader group of constituents. One thing I would say is look to partner with trade association without conflicts. So what trade association would be without conflicts when we're talking about aerospace and defense? That's typically the Aerospace Industries Association. And so which would gladly partner because we're working on these issues in AIA. And our director of the spectrum policy working group of which I chair is sitting over there, Courtney Robinson. That's the type of partnerships we would love to work with folks on, whether it's academia or others. That's one way of building a coalition. I mean, GPS did a great job and they got sued, unfortunately. But a lot of people chose to operate behind the scenes. And it's not always being loud and visible. It's also working behind the scenes and educating quietly and trying to walk people away from the cliff that they were standing on. Let me sort of add on that. Over the years, we've seen a variety of different attacks occur on GPS. So sharing effort done in the UK, ultra wide band emissions, adjacent band power problem. Basically every form of sort of spectrum problem you can think of has been tried by a particular company or coalition of companies who are looking to come into the L band, as Jim says, is beachfront property. I would point out that every one of those companies that tried a zero sum game with GPS has died. Every one of them. So yes, people got sued and so forth. But at the end of the day, they're gone. We're still here. So I would put that record out. And that the mobile communication people are, in fact, despite the things we've been saying here, they're not the enemy. I mean, mobile com is something that people want and need. It has a public benefit. It has a commercial economic benefit. It depends actually on GPS. And it's synergistic with GPS. So you want both of these things to actually function. And the way I think you deal with the diversity that you have on the GPS side is by following the rules. The area where people get into trouble is when they try to short circuit the regulatory process. There's a whole separate discussion we can have on the Administrative Procedures Act and why notices of proposed rulemaking are put out there and why there is a public notice and comment period for everyone to engage in. So under the urgency and pressure of lots and lots of money and of political pressure, there is often a great temptation to try to evade the processes that the Congress and its wisdom have actually put in place. And so the formation of coalitions, yes, you go do that, but don't assume that it's a one-zero game with the mobile com people. The one-zero game is with people who want to follow the rules versus those people who want to sort of escape and try to find an easy way around the rules. In that same spirit regarding the weather and getting other non-GPS things in there, this is what the interagency process can and should be for. This is the relationship between OSTP and the National Security Council. And fundamentally, it's a White House organizational issue, but if there's an industry coalition, there is a real issue that is then echoed by the interagency, then you go about creating a process to handle it. Now, part of the reason the PNTXCOM was created is because it had enough ongoing things that were going on that they didn't necessarily want, as someone once put it, don't darken the White House door. Again, with this issue, we want other people to go handle it. And therefore they created a structure to go handle it. So the White House is the place for this to be handled. And then from there, you can make a decision about whether they want, you want to create a more permanent structure after it. So the only thing I would add on your question about international collaboration is that internationally, a lot of the industries to collaborate, cross borders, the satellite industry has a tremendous group of companies that work together, whether they're based in the UAE, Saudi Arabia, the United States, the UK. And we work as a unit on a lot of issues at the ITU, for example, so that one, we're sharing the same story, we're splitting our resources in terms of educational efforts, et cetera. And that's been actually quite productive, because Chris said the A&D industry had a very good result at the WRC and that a lot of collaboration was put into effect that way. It's important every country has their own vote and when you're looking at the international, but it can be taken for granted and everybody has to be educated so that you ultimately end up with a new vote. Well, on the corner. Sorry, Matt, Scott always falls. He never lets me have the last word. Because I'm a lawyer. You can't let that happen. Well, on the note that international cooperation is tricky yet important, we shall end this session. Please join me in thanking this panel for a really lively discussion. Thank you very much. We will have audio up on our website in a couple of days and a transcript up in about a week. So please check back. We look forward to seeing you guys at future events. Thank you again.