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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Page viii Cite
Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Suggested Citation:"Front Matter." National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. doi: 10.17226/26611.
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Prepublication Copy – Subject to Further Editorial Correction ANALYSIS OF POTENTIAL INTERFERENCE ISSUES RELATED TO FCC ORDER 20-48 Committee to Review FCC Order 20-48 Authorizing Operation of a Terrestrial Radio Network Near the GPS Frequency Bands Computer Science and Telecommunications Board Air Force Studies Board Board on Physics and Astronomy Division on Engineering and Physical Sciences National Academies of Sciences, Engineering, and Medicine National Academies Press Washington, DC Consensus Study Report PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION

NATIONAL ACADEMIES PRESS 500 Fifth Street, NW Washington, DC 20001 This activity was supported by the U.S. Department of Defense Chief Information Officer with the assistance of the Air Force Research Laboratory under award number FA955016D0001/FA8650-21-F-9309. Any opinions, findings, conclusions, or recommendations expressed in this publication do not necessarily reflect the views of any organization or agency that provided support for the project. International Standard Book Number-13: 978-0-309-XXXXX-X International Standard Book Number-10: 0-309-XXXXX-X Digital Object Identifier: https://doi.org/10.17226/26611 This publication is available from the National Academies Press, 500 Fifth Street, NW, Keck 360, Washington, DC 20001; (800) 624-6242 or (202) 334-3313; http://www.nap.edu. Copyright 2022 by the National Academy of Sciences. National Academies of Sciences, Engineering, and Medicine and National Academies Press and the graphical logos for each are all trademarks of the National Academy of Sciences. All rights reserved. Printed in the United States of America. Suggested citation: National Academies of Sciences, Engineering, and Medicine. 2022. Analysis of Potential Interference Issues Related to FCC Order 20-48. Washington, DC: The National Academies Press. https://doi.org/10.17226/26611. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION

The National Academy of Sciences was established in 1863 by an Act of Congress, signed by President Lincoln, as a private, nongovernmental institution to advise the nation on issues related to science and technology. Members are elected by their peers for outstanding contributions to research. Dr. Marcia McNutt is president. The National Academy of Engineering was established in 1964 under the charter of the National Academy of Sciences to bring the practices of engineering to advising the nation. Members are elected by their peers for extraordinary contributions to engineering. Dr. John L. Anderson is president. The National Academy of Medicine (formerly the Institute of Medicine) was established in 1970 under the charter of the National Academy of Sciences to advise the nation on medical and health issues. Members are elected by their peers for distinguished contributions to medicine and health. Dr. Victor J. Dzau is president. The three Academies work together as the National Academies of Sciences, Engineering, and Medicine to provide independent, objective analysis and advice to the nation and conduct other activities to solve complex problems and inform public policy decisions. The National Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in matters of science, engineering, and medicine. Learn more about the National Academies of Sciences, Engineering, and Medicine at www.nationalacademies.org. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION

Consensus Study Reports published by the National Academies of Sciences, Engineering, and Medicine document the evidence-based consensus on the study’s statement of task by an authoring committee of experts. Reports typically include findings, conclusions, and recommendations based on information gathered by the committee and the committee’s deliberations. Each report has been subjected to a rigorous and independent peer-review process and it represents the position of the National Academies on the statement of task. Proceedings published by the National Academies of Sciences, Engineering, and Medicine chronicle the presentations and discussions at a workshop, symposium, or other event convened by the National Academies. The statements and opinions contained in proceedings are those of the participants and are not endorsed by other participants, the planning committee, or the National Academies. Rapid Expert Consultations published by the National Academies of Sciences, Engineering, and Medicine are authored by subject-matter experts on narrowly focused topics that can be supported by a body of evidence. The discussions contained in rapid expert consultations are considered those of the authors and do not contain policy recommendations. Rapid expert consultations are reviewed by the institution before release. For information about other products and activities of the National Academies, please visit www.nationalacademies.org/about/whatwedo. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION

COMMITTEE TO REVIEW FCC ORDER 20-48 AUTHORIZING OPERATION OF A TERRESTRIAL RADIO NETWORK NEAR THE GPS FREQUENCY BANDS J. MICHAEL MCQUADE (Chair), Carnegie Mellon University JENNIFER L. ALVAREZ, Aurora Insight, Inc. KRISTINE M. LARSON, NAS,1 University of Colorado Boulder JOHN L. MANFERDELLI, VMware PRESTON F. MARSHALL, Google, LLC MARK L. PSIAKI, Virginia Tech RICHARD L. REASER, JR., Independent Consultant JEFFREY H. REED, Virginia Tech NAMBIRAJAN SESHADRI, NAE,2 University of California, San Diego J. SCOTT STADLER, Massachusetts Institute of Technology Lincoln Laboratory STEPHEN J. STAFFORD, Johns Hopkins University Applied Physics Laboratory Staff JON EISENBERG, Senior Director, Computer Science and Telecommunications Board RYAN MURPHY, Program Officer, Air Force Studies Board GREGORY MACK, Senior Program Officer, Board on Physics and Astronomy (through January 2022) SHENAE BRADLEY, Administrative Assistant, Computer Science and Telecommunications Board KATIRIA ORTIZ, Associate Program Officer, Computer Science and Telecommunications Board NOTE: See Appendix E, Disclosure of Unavoidable Conflicts of Interest. 1 Member, National Academy of Sciences. 2 Member, National Academy of Engineering. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION v

COMPUTER SCIENCE AND TELECOMMUNICATIONS BOARD LAURA HAAS (Chair), NAE,1 University of Massachusetts Amherst DAVID CULLER, NAE, University of California, Berkeley ERIC HORVITZ, NAE, Microsoft Research CHARLES ISBELL, Georgia Institute of Technology ELIZABETH MYNATT, Georgia Institute of Technology CRAIG PARTRIDGE, Colorado State University DANIELA RUS, NAE, Massachusetts Institute of Technology MARGO SELTZER, NAE, University of British Columbia NAMBIRAJAN SESHADRI, NAE, University of California, San Diego MOSHE Y. VARDI, NAS2/NAE, Rice University Staff JON K. EISENBERG, Senior Board Director SHENAE A. BRADLEY, Administrative Assistant RENEE HAWKINS, Finance Business Partner THƠ NGUYỄN, Senior Program Officer KATIRIA ORTIZ, Associate Program Officer BRENDAN ROACH, Program Officer 1 Member, National Academy of Engineering. 2 Member, National Academy of Sciences. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION vi

Reviewers This Consensus Study Report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the National Academies of Sciences, Engineering, and Medicine in making each published report as sound as possible and to ensure that it meets the institutional standards for quality, objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We thank the following individuals for their review of this report: ALISON K. BROWN, NAE,1 NAVSYS Corporation, ALDEN FUCHS, Fuchs Consulting, CHRISTOPHER HEGARTY, The MITRE Corporation, TODD HUMPHREYS, The University of Texas at Austin, MARK LOFQUIST, The Aerospace Corporation and University of Colorado Boulder, DOUGLAS LOVERRO, Loverro Consulting, JON PEHA, Carnegie Mellon University, WILLIAM PRESS, NAS,2 The University of Texas at Austin, DOROTHY ROBYN, Boston University, and DOUGLAS SICKER, University of Colorado Denver. Although the reviewers listed above provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations of this report nor did they see the final draft before its release. The review of this report was overseen by STEVEN J. BATTEL, NAE, Battel Engineering, and AROGYASWAMI J. PAULRAJ, NAE, Stanford University. They were responsible for making certain that an independent examination of this report was carried out in accordance with the standards of the National Academies and that all review comments were carefully considered. Responsibility for the final content rests entirely with the authoring committee and the National Academies. 1 Member, National Academy of Engineering. 2 Member, National Academy of Sciences. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION vii

Contents Preface xi SUMMARY 1 1 INTRODUCTION AND BACKGROUND 6 1.1 Spectrum Overview, 6 1.2 GPS Overview, 9 1.3 FCC Order 20-48, 19 1.4 Harmful Interference, 23 2 ANALYSIS REGARDING THE THREE STUDY TASKS 37 2.1 Task 1: Approaches to Evaluating Harmful Interference Concerns, 37 2.2 Task 2: Harmful Interference to GPS and Mobile Satellite Services, 42 2.3 Task 3: Feasibility, Practicality, and Effectiveness of Mitigation Measures in the FCC Order, 56 3 ADDITIONAL MATTERS 60 3.1 Toward A Better Means Of Assessing Harmful Interference, 60 3.2 Ways To Manage Potential Future Controversies, 62 4 CONCLUDING THOUGHTS 65 APPENDIXES A Statement of Task 69 B Presentations to the Committee 70 C Organizations and Individuals That Provided Written Input to the Committee 72 D Committee Member Biographical Information 73 E Disclosure of Unavoidable Conflicts of Interest 77 PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION ix

Preface Section 1663 of the Fiscal Year (FY) 2021 National Defense Authorization Act called on the Department of Defense (DoD) to enter into an agreement with the National Academies of Sciences, Engineering, and Medicine to carry out “an independent technical review of the order and authorization adopted by the Federal Communications Commission on April 19, 2020 (FCC 20-48), to the extent that such Order and Authorization affects the devices, operations, or activities of the Department of Defense.” The Office of the Secretary of Defense, Chief Information Officer, with the assistance of the Air Force Research Laboratory, entered into a contract with the National Academies, and the National Academies appointed the Committee to Review FCC Order 20-48 Authorizing Operation of a Terrestrial Radio Network Near the GPS Frequency Bands (committee member biographical information can be found in Appendix D) to carry out the study per the statement of task in Appendix A. The committee met on a nearly weekly basis from September 2021 to April 2022 to plan the study; receive briefings from experts and stakeholders (Appendix B); and review relevant reports, technical literature, and written submissions to the committee (Appendix C). Materials submitted to the committee can be obtained from the National Academies’ Public Access Records Office.1 In addition, a cleared subset of the committee received a set of classified briefings that informed a classified annex to this report. 1 Complete the National Academies of Sciences, Engineering, and Medicine “Request for Information from the Public Access Records Office” form for this project at https://www8.nationalacademies.org/pa/managerequest.aspx?key=DEPS-CSTB-21-02. PREPUBLICATION COPY – SUBJECT TO FURTHER EDITORIAL CORRECTION xi

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This report reviews Federal Communications Commission order FCC 20-48, which authorized Ligado Networks LLC to operate a low-power terrestrial radio network adjacent to the Global Positioning System (GPS) frequency band. It considers how best to evaluate harmful interference to civilian and defense users of GPS, the potential for harmful interference to GPS users and DOD activities, and the effectiveness and feasibility of the mitigation measures proposed in the FCC order.

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