The November 2011 testing of LightSquared's wireless broadband service proposal found no significant interference to cellular phone text and voice capabilities but did find significant disruption of most all general purpose approved Global Positioning System (GPS) receivers. GPS receivers are used throughout our National infrastructures, in aviation flight safety systems and by private users and emergency services.

Interference created by LightSquared's use of EMS creates numerous safety and continuity issues across this global user base. The Federal Aviation Administration also confirmed interference to safety-of-flight systems that warn pilots of approaching terrain. GPS interference will delay first responders, increasing police, fire and emergency services response time.

Response time is directly related to victim mortality and the extent and costs of structural damage. In a widespread disaster such as a hurricane or earthquake, GPS interference would hamper the response by all state and federal agencies. Clearly, the impact to local, state and national safety would be significant and not an acceptable risk.

LightSquared's pursuit is proper in the purely commercial sense, yet wholly unsupportable in the broader operational sense. This cuts to the heart of a new and enduring issue for our Nation: Should the apportionment and licensing of frequencies across the increasingly co-occupied EMS be left solely to the "compliance paradigm" mindsets of commercial interests or is it now time to vest operationally aware stakeholders in that process, as peers?

Due to global dependence upon the GPS system, reliable access to GPS frequencies must be protected and managed as a National resource and no longer simply as a commercial opportunity.

To avoid striking such a broadly harmful agreement in the future, a whole-of-government EMS Strategy must be created in a partnership of DoD operations personnel, industry leaders and responsible legislators.

A National policy making adequate use of counsel from operational EMS experts within the DoD will effectively balance and inform future decisions on EMS apportionment and licensing, greatly reducing the potential for costly inefficiencies, litigation and associated delays. With the current stakeholders and policies in place, similar challenges to this National resource - the EMS - are nearly inevitable in our future.

The Association of Old Crows recognizes the serious impact that any source of persistent GPS interference would have on our Nation's ability to operate its critical infrastructure (e.g. banking, telecommunications, transportation, utilities, and emergency services) or respond to crises or natural disasters at all levels.

The AOC supports the test findings but recommends NTIA request the FCC to withhold authorization of LightSquared's wireless broadband service.

The AOC recommends that the FCC partially underwrite LightSquared's efforts to submit for retest a new design that does not interfere with the GPS system, since the originally licensed frequencies were unusable.

AOC is an international Electronic Warfare/Information Operations (EW/IO) association which promotes EMS operations and related activities across military, civilian and commercial applications.