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Good
morning Chairman Tauzin, Sub-committee Chairman Upton, and members of the
Sub-committee. I am pleased to be
here today on behalf of Geophysical Survey Systems, Inc. (GSSI), which is one of
several manufacturers of ground penetrating radar (GPR) systems. For the past 32
years, GSSI has designed, manufactured and sold GPR equipment worldwide.
We thank you for the opportunity to be here to speak about GPR and the
recent ultra-wideband (UWB) Report and Order issued by the Federal
Communications Commission. The new
regulations are an extremely important subject to everyone in the GPR industry.
I
want to be clear that I am speaking for only a part of the UWB industry. This
part is called ground penetrating radar or GPR. GPR is a very important class of
UWB devices, with a long history of applications relating to public safety and
infrastructure inspection that I will comment on shortly.
I
have four points to make today:
- GPR
is an established technology with many important applications. GPR is
different from air UWB transmitters and should be treated differently in the
regulations.
- There
is no record of GPR interference with other receivers.
- The
two most onerous and confusing provisions in the new rules were not
contained in the NPRM, which gave us no opportunity to comment on them
during the rulemaking process. We
only found out about them after the rulemaking was concluded.
- If
the rules are not changed, the outcome and consequences for the GPR industry
are extremely serious. Many companies will go out of business…and the
public’s access to a very useful technology will be severely limited, if
not eliminated.
Point
#1: GPR is an established industry
Geophysical
Survey Systems, Inc. (GSSI), is one of several manufacturers of GPR systems. For
the past 32 years, GSSI has designed, manufactured and sold GPR equipment
worldwide.
In
a nutshell…
-
Business
started 1970, purchased by the Oyo Group, Tokyo, 1990
-
Developed
and sold first commercial GPR systems in 1970
An
important class of UWB devices is Ground Penetrating Radar (GPR).
GPR is an established technology widely used in a variety of applications
in the United States and the rest of the world. GPR looks downward into the
earth, fresh water, ice and man-made materials to non-destructively detect
anomalies. Many of these
applications provide unique and significant safety-of-life and other benefits in
the public interest.
Standard
applications for GSSI GPR equipment include:
- Utility
pipe detection and 3D mapping (safety a consideration)
- Concrete
inspection to find rebar and pipes and fiber optic lines before cutting or
coring (safety a consideration)
- Highway
inspection to identify voids, pipes and required pavement thickness
(safety a consideration)
- Bridge
deck inspection for quality assurance condition assessment and maintenance
decisions
- Geophysical
surveys (locate bedrock, water table and other geological properties, also
detection of voids and anomalies)
- Airport
runway inspection to find voids and for quality assurance of pavement
thickness (used at all major airports and by NASA) (safety a
consideration)
- Railroad
bed inspection to find leaking pipes and voids (safety a consideration)
- Forensics
(locating bodies, evidence, etc.)
- Environmental
contamination surveys to determine location and extent of contamination,
pipe leaks, waste pits, etc. (safety a consideration)
- Archaeology
- mapping of underground sites prior to digging
- Mining,
location of mineral deposits, seams and water levels (safety a
consideration)
- Measure
ice thickness in rivers, lakes and in Antarctic research (safety a
consideration)
(It
is worth noting that GPR systems and GPS systems are compatible; indeed GPR
systems are sold with GPS systems without special modification.)
Non
standard and ‘once-in-a-lifetime’ uses / results of GPR surveys:
- Discovery
of the wooly mammoth in Siberia (Discovery channel)
- Survey
of unopened tomb in Xian, China
- Discovery
of unknown village near Macchu Pichu (National Geographic expedition)
- Surveys
at Mount Vernon, Monticello, and FDR's home
- Frozen
river bed survey - Russia
- Discovery
of buried murder victims, some leading to convictions
- Discovery
of emerald deposit in North Carolina, North Americas largest find
- Developing
a GPR system to go to Mars; purpose, to define creek beds where remnants of
life might be found
More
applications can be listed but clearly GPR technology has a high value to
society in the United States and the rest of the world. We mention the ‘rest
of the world’ because as many of you know, the UWB standards set here will
surely be followed in many other countries.
Point
#2: GPR is different from air UWB
transmitters
During
the rule-making process, there has been a tendency to treat GPR as just another
UWB transmission device. There are several important distinctions between GPR
and other UWB transmission devices to consider when formulating rules for UWB
transmission:
-
By
definition, GPR looks downward into the earth, water, ice and
man-made materials to non-destructively detect anomalies. GPR is not
intended for air transmission. GPR manufacturers go to some length to
reduce unwanted air transmissions.
-
In
addition to the fact that GPR does not intend to transmit into air, GPR is
also different from air UWB transmitters in Pulse Repetition Rate and in the
frequency spectrum used.
-
A
primary issue behind rule changes centers on the protection of Global
Positioning Satellite (GPS) system operations. GPR works well with GPS
systems, as evidenced by the fact that for the past 10 years GPR
manufacturers have sold GPS systems that work successfully in conjunction
with their GPR systems.
Point
#3: Comments on the UWB Rule-Making
Process
The
long history of GPR and the testing of GPR equipment provide no basis for these
regulations, and we were not even aware of them until they appeared in the final
Report and Order. As I mentioned earlier, many important aspects of the
published rules were a complete surprise to the GPR community as they were not
part of the public disclosure and debate. Isn’t
the rulemaking process itself designed to be the opportunity for public
disclosure and debate? Surely were we to have had knowledge of these particular
rules, we could have easily explained why they are inappropriate and
unnecessary.
The
background leading to this nexus:
- FCC
Rules, Part 15, created for frequency domain transmitters to keep systems
from interfering with each other
- Original
Part 15 Rules did not contemplate UWB transmitters (time domain).
- At
no time in the past 30 years has the FCC recorded any GPR interference with
other receivers.
- All
parties agreed throughout the FCC proceeding that GPRs are NOT a source of
interference.
- UWB
rules are now being written for the first time.
- The
proposed FCC rules published for comment in 2000 did NOT include the NTIA
coordination requirements and
limits on who can buy GPRs -- and the FCC cannot lawfully adopt rules that
were never proposed.
- We
believe that requirements for overly stringent rules come from (1) a
perceived need to protect against in-the-wall and through-the wall radars,
not GPRs; and (2) NTIA policy (not technical) concerns about
"intentional" emissions into certain bands, even at completely
harmless levels.
- The
new UWB rules protect GPS frequency spectrum beyond reasonable limits,
resulting in the elimination of an entire industry – the GPR industry.
Point
#4: The probable consequences of
the new regulations
The
recently published regulations intended to govern UWB devices will have two
immediate outcomes for the GPR industry:
1.
Substantial reduction of sales for GPR manufacturing companies
2.
Many GPR service providers will go out of business
The
longer-term impact of the new regulations will be the end of the GPR industry.
SUMMARY and
RECOMMENDATION
We
propose that the FCC treat GPR differently from other UWB devices – because
GPR is different from all forms of wireless communication. (See above)
Surprise
rules such as those encountered with the UWB regulations should not be a part of
the process to regulate and allocate bandwidth, or for any rulemaking process.
We
are confident that reasonable regulatory requirements can be developed which
will allow for the development and use of new wireless air transmission UWB
devices, while protecting current users of the spectrum and enabling the
continued growth of the GPR industry. We
look forward to working with policymakers on that solution.
Thank
you.
PARTIAL
LIST OF U.S. GOVERNMENT AGENCIES
USING
GSSI SYSTEMS
AIRFORCE:
Andrews
AFB, Fairchild AFB, Griffis AFB, Hanscom AFB, Hickham AFB, Hill AFB, K.I. Sawyer
AFB, McCord AFB, Moody AFB, Mount Home AFB, Plattsburgh AFB, Tinker AFB, Tyndall
AFB, Wheeler AFB,
ARMY:
Ft.
Meade, Ft. Belvoir
NAVY:
NAS
Jacksonville, NAS Pascagoula, NAS Norfolk, Naval Public Works Center San Diego.
MARINES:
Marine Corps
Air Station, Yuma.
US
Bureau of Mines
US
Bureau of Reclamation
US
Bureau of Standards
US
Coast Guard
D.O.D
( Pentagon )
USDA,
Forest Service
US
Environmental Protection Agency
FBI
NSA
US
Geological Survey
US
Parks Department
NATIONAL
LABORATORIES:
Los
Alamos
LLNA
Sandia
Oak
Ridge
Brookhaven
US
Corps of Engineers:
CRREL ( Cold
Regions Research and Engineering Laboratory ) Tulsa, WES.
Department
of Energy:
Savannah
River, Hanford, INEL, Oak Ridge
RESUME
DENNIS J. JOHNSON, President
Geophysical
Survey Systems, Inc.
Mr.
Johnson is currently President of Geophysical Survey Systems, Inc. (GSSI). GSSI
designs, develops, manufactures and sells Ground Penetrating Radar (GPR)
equipment. Sales are worldwide comprised of over fifteen different distinct
applications. The Oyo Group, Tokyo, owns GSSI.
Mr.
Johnson has had twenty-five years experience in the management of high-tech
firms. The positions he has held range from Director of Manufacturing for a
division of American Hospital Supply producing heart valves and catheters to
General Manager of a division of Schlumberger, manufacturing and selling down
hole tools for developing oil and gas wells.
He
has started up several successful companies including one that manufactured and
sold wireless, acoustic communication equipment for scuba divers.
Mr.
Johnson was one of four partners in a private equity fund that purchased
mid-size manufacturing companies. The purchased companies had sales in the range
of $100 to $400 million and each needed significant operational improvements.
All of the companies have grown and been sold at significantly higher prices.
Mr.
Johnson graduated from the U.S. Naval Academy, served on nuclear submarines as
Operations Officer and also has a MBA degree from Harvard University. He holds
several U.S. patents.
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