GPSIA letter to White House National Economic Council

Strong and unified leadership by the US government is needed to preserve and advance Global Positioning System (GPS) leadership that recognizes the inherently unique functional and technical attributes of GPS. As a satellite-based navigation system, GPS operates in a manner that is distinctly different from terrestrial-based communications services. Given the fundamental differences in power and function between the two, it is paramount that policy formulation draw upon the expertise of the US Space Force and Department of Transportation (DoT), the US government’s lead military and civilian agencies, respectively, for the criticality of GPS to their missions and operations. These agencies’ views must continue to be a core element in any federal actions that may affect GPS. The GPS Innovation Alliance suggests the following ways that the existing expertise needed to preserve and advance GPS operations and benefits can best be incorporated into the federal spectrum decision-making processes:

• Updating the 2003 Memorandum of Understanding (MOU) between the FCC and NTIA. The current version of this document was signed nearly 20 years ago, at a time when spectrum was highly stovepiped for federal and non-federal users; thus, disputes were neither as frequent nor complex. An update of the MOU must reflect this changed and still evolving landscape, with an emphasis on establishing a formal process for resolving Executive Branch and FCC disputes, such as occurred in the FCC’s Ligado proceeding. If necessary, Congress could consider codifying this aspect of the MOU in statute, ensuring that shared decision-making authority between the two agencies is fully embraced.
• To ensure the FCC has in-house expertise relating to GPS and other technologies that use spectrum, GPSIA recommends that the Commission’s Office of Engineering & Technology maintain a detailee from one of the federal agencies responsible for managing the GPS program. This would ensure that when the FCC’s technical communications experts must address positioning, navigation, and timing (PNT) issues involving GPS, they have the benefit of relevant expertise.
• Each FCC Commissioner would also benefit from having his or her own technical advisor. A practice that was discontinued years ago and proposed once again in bipartisan legislation more than a decade ago, it would ensure that, as Commissioners tackle increasingly complex technical matters, they have the benefit of an electrical engineer or computer scientist on their staff.
• Finally, we would encourage a focus on Executive Branch preparations and leadership for the ITU World Radiocommunication Conference in 2023, to ensure  that the Administration views are appropriately developed and executed in the ITU and regional bodies that participate in the WRC. Ensuring that the Administration’s priorities are advanced requires a whole of government approach, with appropriate level engagement, funding and staffing at the Department of State and the NTIA.