Ligado Networks' President and CEO Doug Smith and Chief Legal Officer Valerie Green

Tom Lenard: Hi and welcome back to TPI’s podcast, Two Think Minimum. It’s Wednesday, December 11th, 2019 and I’m Tom Lenard, senior fellow and president emeritus of the Technology Policy Institute. Today we’re excited to talk with Doug Smith and Valerie Green of Ligado Networks. Doug is the president and chief executive officer for Ligado and is responsible for directing the vision of the company and managing every aspect of its day to day operations. With more than 25 years of domestic and international telecom and wireless industry experience, Doug has engineered, built and launched nationwide networks for GTE, Nextel, Sprint Nextel, and Clearwire. Valerie is executive vice president and chief legal officer and is responsible for the company’s legal, public affairs, and regulatory activities. Prior to joining Ligado, Valerie served in the Obama administration as assistant for the president and director of presidential personnel. She also served in the white house as deputy special counsel to the president and special assistant to the president and she started her career as a litigator with several prominent law firms. Well, thank you both for coming on the program. I’ve been following Ligado for a number of years. Ligado has, to say the least, an interesting story, which may now be at an inflection point and hopefully a good inflection point. But let me start by asking, Doug, you’re responsible for directing the vision of the company. So, talk a little bit about what that vision is. 

Doug Smith: Sure. Thanks Tom. And thanks for the warm introduction. And more importantly, thanks for the time on the podcast. It’s always nice to talk to you. So, speaking for Valerie and myself, we’re happy to be here. In terms of the vision for the company, we think we really have a great opportunity to introduce something new and contribute towards the 5G ecosystem in kind of a unique way. Where we are at Ligado is, as you know, we are, and have been, a satellite-based communications provider for many years and what we are intending to do is to complement our satellite offerings with a terrestrial 5G offering. And we think by combining the power of satellite, along with all of the technical advancements and terrestrial networks, with 5G, we can operate a pretty powerful and unique solution that can complement the existing wireless infrastructure. 

Tom Lenard: So, I know this may be basic to many people, but talk a little bit about 5G and why it’s different for 4G and what you can offer with 5G. 

Doug Smith: Sure. I think, you know, there’s certainly many benefits 5G will bring in terms of just building off the 4G infrastructure that’s there today. Probably the headline is always just faster speeds and that is certainly true and that is always helpful. But in addition to that, I think there are also some other unique offerings in 5G, in terms low latency applications and ultra-reliable applications. And one of the things that we were focused on, very focused on, in terms of serving the industrial sector would be by offering IoT solutions that will require that ultra-reliability. And we do think here from a combined satellite terrestrial perspective, we have a lot to offer. And we think about IoT and with our satellite, these would be the lower bandwidth applications, but we have ubiquitous coverage over all of North America. And so from a an IoT standpoint that coverages a fantastic and certainly satellite networks reliability is unparalleled. But by complimenting that with ground-based high-speed terrestrial networks, we can really start to take advantage of the combination of the two of these things. And so to us 5G, it is building on the 4G infrastructure and it’s just expanding its capability. But some of these things I think the industry is really interested in looking at and taking advantage of is just connecting more and more devices and making it much more available. And certainly, latency is important to that when you get into things like, a real time application, whether it’d be autonomous vehicles or others. And reliability is also important to that. So, if you’re going to start to connect the industrial infrastructure and to the networks, it’s going to be super important that you do so in a way that is safe and reliable and 5G gives us the benefit of doing that. And that we can build on that by combining both terrestrial and satellite to improve that even further. 

Tom Lenard: So, assuming you get the necessary approvals from the FCC, and we’ll get into that, obviously, in a minute, but who would your customers be?

Doug Smith: We would be expanding our customer base. So, our customers today and our customer base since we’ve been offering satellite services really are in the industrial sector. So, think of utilities and transportation companies, these include rail, manufacturing. We also serve first responders. And so, we would certainly continue to serve them and we think these offerings can, we can expand there. And part of this would also be in partnership with the existing wireless providers today. And so some of the things that we can do is, we will have this unique capability that will be the blend of satellite and terrestrial, but we’re also have an opportunity to build custom networks. And so when we think about the industrial sector where security and reliability and availability is of utmost concern and importance, we’re in a position where we can build custom networks that would be built upon dedicated spectrum. Something that doesn’t make sense for the commercial wireless operators to do. Their spectrum is and always has been spread across all of their users and that is important and for them the best use of that spectrum because it can serve so many, but there is an unmet need that’s always existed, in my experience here, which is on the industrial side of things. These large companies, take the utility companies for example, when they need their communications network the most are typically around weather events. Something’s happened and there’s been problems and there’s failures in the network and they have to get out and respond quickly to restore power. That’s also the time that the commercial wireless industries end up being taxed, whether it’s a hurricane or a snow storm, you know, if you’re out on the road, everyone’s on their phone and that’s when they become most busy and congested and availability goes down. And so for utility companies they’re going to rely on it and they need to know it’s there. And you’ve seen this in the industry where they oscillate between building their own networks and getting on commercial networks and they go back to building our own because of this availability and reliability point. One of the things that we can do here, with the 40 megahertz of spectrum, is we can start to allocate pieces of spectrum and dedicated to specific uses and specific customers to serve them. And that’s something I would see us working in partnership with existing wireless industries to do this so that we could provide those customers the benefit of their own private network in their home territory, but also, they could have the access and availability of the large broad footprints that exist today. 

Tom Lenard:  Right. So, you just mentioned the 40 megahertz of spectrum and you’ve mentioned several times combining the satellite and the terrestrial and that’s kind of the heart of the issue that has been challenging for Ligado for how long? So talk a little bit about what the issue is in terms of getting the type of license you have now, the type of license modification that you want to get and applying for. And talk about the history, about how long this has taken and what you’ve done up till now to try to meet the various concerns of various parties.

Doug Smith: Sure. Let me try to capsulate that. I’ll try not to bore you or your audience with the entire history because it really has been a very long process here. But so, what we have today is, we’ve launched satellite services and had been in service since the late nineties. Already in the mid two thousands, we were granted an application to use our spectrum for terrestrial purposes and the company, upon having that terrestrial right for the spectrum, went to build this integrated network, built new satellites and launch new satellites and started to deploy the terrestrial network. And, I guess it was probably 2010, at that time there were concerns raised that the terrestrial component of the network could interfere with GPS. And so those plans were halted, in about 2012, and that’s the time that I became the CEO of the company and really focused on addressing all the concerns that were raised between the 2010 and 2012 period. I did so by working with the industry, and when I say the industry, I really mean the GPS industry. Started with the manufacturers, and in late 2015 reached agreement with the manufacturers on how we could use the spectrum that would be safe for GPS and fully protect GPS. You know, the one thing that we all agree on is GPS is an important and critical system for the country. And protecting it was top of my list in terms of any network deployment that we would do. Now that involved, the agreement that we’ve reached with the industry, really was to solve the interference issue. It involves relinquishing terrestrial rights for some of the spectrum, that spectrum that was closest to the GPS band and did pose an interference concern. So we’ve taken that spectrum off of our terrestrial roadmap and have suggested to the FCC and asked the FCC to take that terrestrial license away. And then we also went through all of the other blocks of spectrum and worked out all the technical parameters that would provide protection for GPS. That included providing a large guard band between our transmit spectrum and the GPS band, a guard band of 23 megahertz, which is very, very significant when as an industry you typically talk about guard bands and you could be anywhere from a couple of megahertz, maybe to 5 megahertz. So it’s a 23 megahertz guard band, provides fantastic protection for GPS, but then we also went further and reduced power levels and really, cut out of band emission levels to the satisfaction of the GPS manufacturer so that we could fully protect the GPS devices that are out there today. And so once we did that, we resubmitted the applications to the FCC and felt really good about them, right? We brought forward an industry solution that allowed us to kind of balance, as a country balance these competing needs, which is you have to protect GPS first and foremost. But then we have a spectrum, a lot of really prime band spectrum, because all of our spectrum here is in the mid band. And certainly, this is getting a lot of attention, very much today, which is as a country we don’t have enough mid band spectrum for 5G services. And so this is really useful spectrum because of its propagation characteristics. You know, it’s great spectrum.

Tom Lenard: Yeah, talk about the importance of mid-band spectrum.

Doug Smith: It’s critical. I mean I think you if look at the industry, the networks were first launched in low band, the first licenses were 800 megahertz and those cover a great amount of distance, but there wasn’t enough of that spectrum to meet all of the demands of the consumer. And so, as you know, as the industry has evolved and the networks have matured, the networks then started to rely on mid-band spectrum, and this would be all of the AWS spectrum, AWS-1, you know, right up through AWS-3. And so the infrastructure has been built around the AWS spectrum and that’s mid-band and that’s right where our spectrum sits. So, we’re kind of on the lower edge of what we would call mid-band spectrum. And so, we really are lower mid-band, right at the 1.5, 1.6 gigahertz, which is really important because not only does it give you the great coverage characteristics and propagation, but it also provides a great capacity. And so it really is the sweet spot of spectrum just from a propagation standpoint, but there’s also a very practical requirement here, which is if you think about the existing infrastructure, so this is where all the cell towers are built and how the networks have been deployed today, whenever you come in and add a new technology – I’ve lived this going from the analog systems to the 2G networks and then from the 2G networks to 3G and then from 3G to 4G – what you want do and what speeds the deployment and the rollout of the new services is you use the existing infrastructure. And so if you think about the existing infrastructure as having a site spacing, you know the distance between two adjacent towers. What’s very important is that you put spectrum on those towers so that they connect to each other and you don’t have any gaps in coverage. And so the infrastructure is all built around the mid-band and one of the issues that we have in deploying 5G is that a lot of the spectrum is coming available, virtually all the spectrum is coming available for 5G services, is much higher on the bands. And so whether you’re talking about the 3.5 gigahertz, 4 gigahertz spectrum or certainly millimeter wave spectrum, that’s all much higher on the band. And the propagation isn’t nearly as robust as the mid-band. And so what happens if you were to just go out and do an overlay of the existing infrastructure with this higher band spectrum, you’ll have gaps between every adjacent cell site with its neighbor. And the only way you can fill those gaps in, if you can’t do it with good quality mid-band spectrum, is to go and build lots of small cells. And we were talking in the order of thousands of small cells that would be required to make ubiquitous coverage on 5G if you’re going to deploy in those higher bands, around the 3.5 to 4 gigahertz spectrum. And so why mid-band is so important is if you can find more mid-band spectrum, like our spectrum, it does give you the ability to roll that out on the existing infrastructure. And since the propagation of the lower mid-band spectrum, like in our case, is such that you wouldn’t have any gaps between sites, and that means it’s a faster and cheaper deployment to 5G that really can help us win the race to 5G, because if all you have to do is an overlay, those can go relatively quickly because you already have the infrastructure, it’s certainly, truck rolls as you will, which is go out and add the new spectrum to each site. But what you’re not doing is going through the long permitting and construction process to build new infrastructure. It’s really of key importance when you think about how you actually deploy the network and if you want to deploy the network like the industry did to 4G, you know, I think the leader of 4G, the big carriers were able to roll that service out, the 4G network, on the existing infrastructure. It didn’t require, since they had the spectrum available, the green field spectrum available, they were able to just do it as an overlay. And so, what you saw in 4G was the United States rolled it out well ahead of any other country. They did it very quickly and they absolutely, you know, we won the race to 4G. And we would like to do that again with 5G, but the difference here is we don’t have enough mid-band spectrum and we don’t have enough green field mid-band spectrum. The other part is, green field spectrum is very important and the carriers did have green field spectrum for 4G. Green field, I would just define a spectrum that’s available and it’s unencumbered and you can just dedicate it. You always have this competing need, which is you have spectrum on the networks, but that spectrum is fully utilized. We have a very robust and growing wireless industry, so traffic on 4G is growing and so there’s not really a great spectrum to pull from on the existing networks. And so if you have green field spectrum that also just helps you dedicate it to it and you can get a great 5G service out there and then you can start transitioning traffic to it. So that’s why new green field, mid-band spectrum is so critical to the race. 

Tom Lenard: So let’s talk about the regulatory process that you’ve been involved in and maybe bring Valerie in. One of the things you alluded to, you’re looking to deploy 40 megahertz. But my recollection is you that started out, I can’t remember what the number is, but you started out with a lot more. I guess one of the questions is, I’d like to ask Valerie in general, to talk about what their regulatory processes been like. But one of the questions is, and you probably don’t want to comment too much on what you’ve given up, but do you think interference reasons it was necessary to give up all that spectrum, which otherwise could be, could be usefully used?

Valerie Green: Tom, thanks for that question. So our plan really has always been based on 40 megahertz of combined satellite and terrestrial spectrum. As Doug mentioned earlier, we did make a decision, to protect GPS, to give up the 10 megahertz of spectrum that was closest to the GPS band. But what we’ve been working on is a plan to replace that 10 megahertz with another 10 megahertz of spectrum. So that ultimately what we would have is the same 40 megahertz that we’ve always planned to use. And the reason that 40 is so significant is all the reasons that you and Doug have just talked about in terms of how mid-band spectrum propagates and how mid-band spectrum really adds more even when you have only 40 megahertz. So, the plan that we currently have, we gave up the 10 megahertz, as Doug said, when we made the new proposal at the end of 2015, almost four years ago. And we’ve been working on a plan to bring in another 10 megahertz to replace that 10 megahertz. So in the end when we get FCC approval and in the very end after the FCC resolve the final megahertz, which is the five megahertz that we hope we’ll be able to share with NOAA, once that NPRM process and that auction process comes to a close, we’ll have the original 40 megahertz that we’d always planned on using and that we’d always plan to bring to market for our combined satellite terrestrial network. The other thing that we worked very hard, that our engineering team worked hard on, and that we worked very closely with the GPS companies on is making sure that our proposal not only protected GPS but the spectrum proposal that we made also left us with spectrum that was very usable, usable for 4G networks, usable for 5G networks. And so the concessions that we’ve made to protect GPS in terms of our outer band emissions and in terms of our power levels, they do a great deal to protect GPS, but they also leave the company and its future customers in a position to have spectrum that is very useful and can really be put to great use. And so we don’t worry about the impact of the new proposed technical parameters on our ability to deploy a network that is very powerful and can be put to great use by our customers. We knew that we could protect GPS and make great use of the spectrum and I think that’s what the proposal does.

Tom Lenard:So, you spent a lot of time and effort trying to alleviate the concerns of the GPS industry. It’s my understanding you kind of got them on board and got them to not object to the license modifications, but then after that other partys came along with objections. You want to talk about that a little bit?

Valerie Green:   Sure. You’re right. We absolutely started, as Doug said, and as we’ve talked about before and I think everybody knows, we absolutely started with the GPS manufacturers. We began to develop a proposal that we wanted to protect GPS because they’re the experts. Not only do they know about all of the GPS devices that have been in the field forever, but they are also the ones who are designing our current and future GPS devices and so we went to them as the experts to understand what did GPS devices really need. That technical question, I think everybody agrees we’ve answered and I think that’s really separate and apart from the types of objections that we’ve seen from the others, as you referenced them, I think those concerns really don’t have as much to do in all honesty with the functionality of GPS and GPS devices so much as they have to do with the same old types of politics that we see around spectrum and who’s going to control spectrum and who’s going to be able to use spectrum and who’s going to be the ultimate decision maker on how spectrum is utilized. And you’ve seen these politics play out time and time again, right? DOD has historically been probably the most infamous reluctant spectrum sharer, reluctant spectrum repurposer, you know, they are dead set against change in spectrum allocations and spectrum use and we’ve all, in the industry, we’ve all seen that for decades. I think we’ve recently begun to see other agencies following in their footsteps unfortunately. So we’ve begun to see these interagency politics emerge around spectrum. And you’ve begun to see agencies which have historically been appropriately deferential to the expert spectrum agencies like the NTIA and the FCC begin to express their own points of view. Mostly again, not around technical issues, but much more around spectrum and who’s going to be in charge of the spectrum. And so I think what you really see in terms of the opposition that we are currently facing is not legitimate concerns about the potential impact on GPS, but really this turf war. And so that’s how we really like to characterize the folks who are opposing us at this point. The science and the record before the FCC could not be any more clear about whether or not our proposal will harm GPS devices. I think all of the technical experts who are focused on a) the public interest and b) balancing competing concerns have come to that conclusion and that includes both the NTIA and the FCC. I think the other stakeholders, all of whom are focused on their own interest because that’s their charter, right? Their charter is to focus on their own interest and that stands in contrast to the charter of the NTIA and the FCC, both of which are required to think about compromise and to focus and meet the public interest standard. But I think what you really see here is more spectrum politics than an honest discussion about science and GPS interference.

Tom Lenard: So, when you say spectrum politics, you’re saying this is not a legitimate issue of interference, it’s really more turf or control of spectrum.

Valerie Green:   I think that’s right. I think, if you look, as the FCC has spent years doing, they have had all of the scientific data, that is relevant to the question of interference, has been before the expert spectrum engineers at the FCC and the NTIA for years at this point. And they have devoted countless hours to studying it and analyzing it and drawing their conclusions. And as we know, the chairman has a draft order that he wants to move forward with. And presumably that order, as it must under the FCC standards, addresses all of the scientific data. Addresses, you know, takes the time to balance competing concerns, takes the time to develop a resolution that is in the public interest in a holistic way. And I think that’s the FCCs charge. That’s what we’ve seen the FCC do historically. And that’s what they’re supposed to do. And I think that’s a little different than what some of the other agencies who are expressing, and in particular here I’m referencing the Department of Defense. I think what the Department of Defense is doing is they are expressing their own interest, which is in trying to put its infer mater and take a claim to as much spectrum as possible. Tom, you know, the defense innovation board put out a report on 5G that talked a lot about spectrum, and in fact also talked a lot about spectrum policies, I think that was last year, we can get you the date, but it identified the fact that the Department of Defense actually was in a position maybe ironically to be one of the biggest stumbling blocks to moving forward to 5G because of how much spectrum it controls and because of what a big stick that can wield when it wants to. And I think what we see here is really some of those kinds of politics playing out. The Department of Defense, not only does it want to preserve the spectrum it currently has, and we’ve seen that in other spectrum proceedings, but to the extent that it can, it also wants to dictate how other spectrum can be used and just substituted judgment for the FCC’s authority. 

Tom Lenard: I read that report. But this is a longstanding issue with government held spectrum, in particular with DOD held spectrum. Do you have, have you developed any thoughts about how the system might be reformed to perhaps give these agencies a little bit more of an incentive to let go some of the spectrum? 

Valerie Green: You know, I think everybody in our industry and in our sector probably talks about that. I recall your conference a couple of years ago tackled that. I know even the Aspen Institute has tackled that, and I think we are all thinking about how can we make this system better and more efficient, especially now as we face the spectrum crunch and even more than the spectrum crunch, a real desire to move quickly towards the deployment of next generation networks and to get to 5G faster. How can government be reformed to be an agent of that change, as opposed to, what it seems like now sometimes, is that it’s an obstacle to getting to that change. And I think, there are people, people have talked about legislative change. You know, should people rethink the role of the NTIA? Should they give the NTIA more teeth? Should they, you know, change the way that the dynamics work between the NTIA and other federal agencies or between the NTIA and the FCC. And I think there are a lot of really good ideas that are floating around about that. But maybe what we have seen the most over the last year is that we do need some additional clarity about what each of the agency’s roles are and what their authority is. But once we know that, in many ways we do know that, we really need to encourage respect for each agency’s role and each agency’s authority. I think the other thing that we’ve really started to see even more critically as we’ve watched these 5G spectrum wars play out over the last year is some additional transparency in agency decision making. The FCC is obviously governed by very strict sunshine rules and they do their very best to make information transparent to those who are seeking relief from the agency and who practice before the agency. But the FCC is unique in that way and most of the other agencies are able to hide behind laws and other policies and practices that enable them to sort of hide in the shadows and to not make their views transparent. I think we need to work as an industry with the FCC and the NTIA to have more clarity about how we’re going to talk about harmful interference, how will we measure it, how will we think about it, what can we do to help set expectations more clearly for people who have spectrum rights and people who use spectrum. And so, I think those are some of the issues that, for Ligado, and you know, Doug and I talked about these things a lot. We talked about them with other people. I think from our experience, which has been, I think, particularly and uniquely, we’ve exemplified where some of the worst flaws in our system are. You know, as we’ve sat here over the last four years, we’ve seen really all were the possible pitfalls. Those are some of the things that we’ve talked about where we might all learn from this experience so that nobody else has to suffer the faith that we suffered. 

Tom Lenard: So is it just too easy for various interested parties to object to slow up the process?

Valerie Green: Well that’s partially always been true of the FCC and there have certainly been people who’ve written about how the FCC process because there are no deadlines and you know, the record is essentially always open until the minute before the FCC issues in order or make some kind of a final decision. I certainly think that that does make it easy to capture the process. But when the FCC is motivated, as it is now, to move forward to make decisions, you know, they should be able to do so and they should be able to do so free from bullying or meddling from other federal agencies and they should be able to do so supported by the NTIA. But yes, I mean everybody always talks about how it’s so easy for someone to just drop a bomb and then the FTC is left trying to resolve that. I think that’s a challenge for sure. 

Tom Lenard: So as we finish up, it seems from reports and obviously we don’t know, or maybe you know that this process may now be coming to an end and hopefully a positive end, you want to just maybe describe for the audience where the FCC is and what it will take to finish this up?

Doug Smith: Sure, Tom, I’ll take that one. I think you’re right. I mean we are certainly hopeful that this process has come to an end. Certainly, on the public side of things, the FCC has run all of its public comment periods and has a complete record there. From the federal agency side of things, the process that Valerie just talked about, that has concluded. And so, if you follow this, then you know the FCC had sent the draft order means they have a draft order that they sent over for comments from the IRAC, part of the interagency body the NTIA runs. And so they’ve received their feedback now, so you know, the FCC is in possession of the NTIA’s consolidated feedback and their viewpoint and now it is their time to decide, meaning it’s the time for the FCC to decide. So from a process standpoint, the record’s been complete for actually a very long time, but now the process is complete. And so we have, you know, the FCC is in possession of all the data, all the views, and has run a full and complete process. And so now it is time, the only thing left to do is for the FCC to make its final decision. We’re hopeful that they will do that and do that in short order.

Tom Lenard: So what would be the implications of failing to approve the license modifications? Not just for, I mean obviously important implications just for Ligado and for the 40 megahertz that are an issue. But would there be broader implications as well?

Doug Smith: There would absolutely be broader implications and so, of course there would be severe implications for the company if they don’t move forward. But I think if you just take the industry standpoint and what the implications there would be, yeah, what this all comes down to and the only remaining objections to our application going forward, really, they all rest on really what is a just proposed definition of harmful interference. Now the FCC has a definition of harmful interference. Under that definition, that they’ve used for decades successfully, created a booming wireless industry. relying on that. It served as well. If they continue to use their same definition of harmful interference, they will move us forward. I’m confident that they will move this forward. The only objections to them moving forward is really based on kind of a new concept and interference definition. And to me it is, it’s absolutely, they’re pushing a new definition of harmful interference. It’s one would have far reaching implications across the industry because, I don’t want to get too much into the weeds on that technology, but it’s 1 DB change which is a very subtle change in the noise environment essentially and if that were adopted, meaning if the FCC were to take the advice of some of the federal agencies that are promoting that concept and they were to set a precedent that they were actually going to institute this level of protection, which is unnecessary and it’s completely unreliable, as the test data that we put in the record demonstrates, if they were to adopt that and set a precedent, then I think you would have far reaching implications for existing bands of use and certainly new bands that are coming to market. This was the new high bar that was going to be established. You would see a lot of inefficient use of spectrum and so from that standpoint it would have far reaching implications for the industry. I think the other is just also, I think if the FCC were to succumb to the pressure by agencies like the Department of Defense that don’t have the obligation to look in the public interest and to balance these competing needs, if they were to bow to the pressure of say the DOD here, it also, I think, would have, it’s a slippery slope, right? I mean at that point the FCC is not making independent decisions because, you know, I understand the FCC put forward an order and that order would allow us to go forward. And what came back and response is absolutely no new information. And so for them to change their mind, I mean, they’ve had receipt all this information. They’re well aware of it. They understand the applications of this 1 DB metric and have formed an opinion. And that isn’t something that the DOD likes. But that’s, you know, fortunately for us it’s not the DOD’s decision. We like that our future is in the hands of the FCC, the independent agency that is designed, and it has a charter to make these balanced decisions. And so that’s also a stake here, which is what is the decision making process of the FCC?

Valerie Green:  I couldn’t agree with that more. I think that’s really critical. We’ve seen the FCC have to defend itself time and time again over the last year and chairman Pai and his team had been very strong and we hope that they’ll continue in that, but to see them after all the work that they’ve done and all of the really strong scientifically based work that they’ve done, all of the facts line up, all of the law lined up, all the science lines up to see them be in a position where they wouldn’t be able to move forward based on their good hard work would be really problematic, I think in so many ways, for the agency and really it potentially be damaging to its authority and independence.

Tom Lenard: So as you all know we at TPI have written about this issue and held events about this issue, our views are no secret. We think it’s important to get as much as the spectrum out there to be used as possible. So hopefully this will be resolved shortly. I want to thank you both for agreeing to do this podcast. Very interesting. Thank you.

Valerie Green: Thank you.

Doug Smith: Yeah, thank you for the opportunity Tom. Always a pleasure to talk to you and thanks for setting up the time for your listeners to hear from us. We appreciate it.