GPS Is 'Vulnerable,' but So Are All Systems: GPSIA Chief

GPS is “unmatched,” though “there are a lot of existing complements out there” in space and on the ground, Dyer said. Much of the discussion is about GPS being “vulnerable, and it is,” she said, noting that’s not a problem unique to GPS. “Every single system out there is vulnerable -- look at all the money we spend on cybersecurity protections for everything.”

GPS has a 95% availability rate, is accurate to within 3 meters and is “robust,” she said. “That being said, we absolutely believe in complementary PNT.” Banks are installing backup atomic clocks in parts of their infrastructure, and other industries are taking similar steps, she said, adding that GPSIA welcomes the discussion prompted by the NOI.

Dyer said she expects an active docket. “The NextNav petition certainly generated a lot of comments, if that’s any indication, and the commissioners did reference NextNav” in the NOI, she said. “We hear about new PNT systems almost monthly.”

The discussion of complementary PNT will require a “whole of government” focus, “and it’s going to take the whole of industry as well.” The NOI should provide information that will be useful to other federal agencies, venture capitalists and others in industry, Dyer said, and the FCC seems to recognize that it has “a narrow but important” role to play.

Dyer warned that “nuances” are important. After every PNT proposal comes forward, she said she asks questions including, “Is this system going to provide positioning? Is it going to provide timing? Is it going to provide the ability for navigation? … Will it support the military and their worldwide availability requirements?”

Some proposals are only theoretical and may be used to generate marketing and raise money for a company, Dyer said. But “how long will it take” and “what’s the cost to get it to market?” There are always “a ton of questions.”

She also noted that the NOI comes as the FCC seeks comment on numerous related issues, including the next-generation 911 and wireless location accuracy Further NPRMs, which were also approved Thursday (see 2503310030). She cited the “Delete Delete Delete” docket (see 2503140049), which looks at alleviating the regulatory burden on industry. "It gets challenging to figure out” how the dockets “fit together” and how the FCC will “pull it all together in the end and come out with something that’s impactful.”

NOI Expanded

Spectrum is among the areas with new questions in the final version of the GPS NOI. “If the proposed PNT technology projects a future need for spectrum resources, what is the anticipated level of congestion over time, and when might the proposed PNT technology require additional spectrum?” the NOI now asks. “How resilient is the proposed PNT technology to radio frequency interference from other technologies? Does the proposed PNT technology pose interference implications for other spectrum users?”

The FCC also added a question about potential PNT providers’ current infrastructure buildouts. “If new infrastructure deployment is necessary, what is the anticipated timing for that deployment?” it asks: “If new or upgraded end-user equipment is required, how could the Commission promote widespread adoption of the required equipment?” Other questions ask about the resilience of proposed PNT solutions “against jamming and interference, including atmospheric interference.”

The NOI also now addresses the importance of interagency discussions “where potential approaches to PNT are explored” and clarifies that those discussions are exempt from disclosure requirements.