Globalstar CEO keeps pressure on FCC to allow TLPS

Globalstar CEO Jay Monroe rang up FCC Chairman Tom Wheeler's legal advisor Edward "Smitty" Smith last week, saying the commission should expeditiously adopt rules to authorize Globalstar to use Terrestrial Low Power Service (TLPS).

Globalstar argued that allowing it to use TLPS would serve the public interest by adding 22 megahertz to the nation's broadband spectrum inventory and alleviating congestion in the 2.4 GHz ISM band. "Simply put, consumers will be better off with the expanded capacity made available via TLPS," Globalstar said in an ex parte filing (PDF).

The satellite company, which has been waiting for the FCC to rule on its petition, has found an ally in the public interest group Public Knowledge. Representatives of Public Knowledge met with Smith last week as well, arguing that moving from proof of concept to controlled deployment is not abandoning the commission's responsibility to control against harmful interference.

Public Knowledge continues to believe that the commission's proposed approach of controlled rollout, "subject to ongoing observation and authority to require interference mitigation if it occurs, is a valuable step forward in allowing new technologies to come to market," the organization wrote in an ex parte filing (PDF).

Public Knowledge's stance is similar to the one it outlined back in November 2015. "Generally, the public interest is best served by maximizing direct public access to the spectrum without a licensed intermediary," the group said. "Where exclusivity is granted, sufficient benefit to the public must accrue to justify the exclusivity. Given the right trade off, however, the exclusivity is not a "windfall" but a necessity justified by the public interest."

The Globalstar proceeding has been in the works going on almost three years. On Nov. 1, 2013, the commission released a Notice of Proposed Rulemaking on the terrestrial use of the 2473-2495 MHz band for low-power mobile broadband networks, prosing rule changes to allow for TLPS.

Globalstar's petition for rulemaking seeks to expand its use of the 2483.5-2495 MHz band to include terrestrial broadband access using low-power equipment. Globalstar envisions both low-power access points and end-user devices operating within the 22 megahertz band designated as Channel 14 (i.e., 2473-2495 MHz) in the IEEE 802.11 standard. Channel 14 is unused by IEEE 802.11 devices today in the United States.

But while the company is getting support from Public Knowledge, it has its share of detractors who argued what it's asking for amounts to special treatment. The Bluetooth SIG maintained that if the TLPS proposal is approved, it would set a dangerous precedent by allowing one company to have a different set of rules for operation in the ISM band versus the thousands of companies already following existing rules and expending considerable time, effort and money in order to comply with those rules.

The Bluetooth SIG, Wi-Fi Alliance, the National Cable & Telecommunications Association and others said Globalstar's demonstrations have not adequately addressed concerns regarding TLPS' impact on existing uses of the 2.4 GHz band. The Wi-Fi Alliance argued that the record overwhelmingly demonstrated that authorizing TLPS would endanger present and future shared, unlicensed use of the 2.4 GHz band, and requested that the commission withdraw the draft that is circulating among the commissioners.

The Hearing Industries Association (HIA) also opposed allowing Wi-Fi to operate on Channel 14 and said Channel 14 has served as a de facto "safe harbor" in the 2.4 GHz band for lower power unlicensed devices, including Bluetooth Low Energy hearing aids, FDA-regulated wireless medical devices and other frequency hopping technologies.

Microsoft has argued that Globalstar's request may imperil Wi-fi and Bluetooth connections of all kinds, from video games to hearing aids to basic internet connections, and it has initiated testing to examine the impact of the TLPS system on Bluetooth, Bluetooth-like and Wi-Fi systems operating in the 2.4 GHz ISM band.

For more:
- see this Globalstar filing (PDF)
- see this PK filing (PDF)

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Globalstar gets positive vibe from Public Knowledge's letter to FCC

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