While Globalstar insists Terrestrial Low Power Service (TLPS) will be compatible with other services, the Hearing Industries Association (HIA) continues to register its concerns about the potential impact of TLPS on Bluetooth Low Energy devices.
"HIA is gravely concerned about technical demonstrations that show that Globalstar's proposed use of the 2473-2483.5 MHz portion of the 2.4 GHz band will degrade the performance of hearing instruments by causing unacceptable packet loss," the association told the commission. "And, testing has yet to be performed to show whether the Globalstar system would interfere with access to the three Bluetooth LE advertising channels, which are needed to establish Bluetooth LE connections and without which a Bluetooth LE hearing aid could become inoperable."
Globalstar has conducted demonstrations, including one last year at the FCC's own facilities, that it says show how TLPS will not disrupt other nearby devices in the 2.4 GHz band. However, the HIA and others say adequate testing has not been done. HIA says demonstrations by Globalstar to date have occurred in uncrowded spectral environments with unrealistically low traffic and occupancy levels on the Wi-Fi channels.
HIA argues that any testing should be done in places that are loud and where many people gather, such as airports, convention centers and trade shows, hospitals and hotels where people who use hearing aids are most in need of their assistance.
"HIA also notes that Globalstar's offer to provide an interference mitigation service is completely inadequate" when considering consumer devices such as hearing aids, the HIA said. "Consumers will not realize that problems with their hearing aids arise from RF interference, and they certainly will not be in a position to discern the source of interference to their hearing aids and report it to Globalstar for remedy."
Short seller Greg Gerst of Gerst Capital also recently met with FCC staff, including Chief Engineer Julius Knapp in the FCC Office of Engineering and Technology, presenting a detailed 24-page slide presentation and urging the commission to require adequate tests be done to show what happens to Bluetooth devices when TLPS is introduced to the environment. Specifically, he'd like the FCC to require tests to show what happens when a senior citizen with a BLE hearing aid walks into a crowded airport if both Wi-Fi and TLPS are active.
"The 2 data channels at the highest end of the BLE spectrum, where BLE traffic moves when crowded-out by Wi-Fi, is precisely where TLPS would operate," Gerst wrote in an ex parte FCC filing. "Therefore, in a typical real-world environment, what happens to BLE traffic and BLE device performance when Wi-Fi and TLPS are both active? The answer to this question is knowable, ought to be known, and can be easily known with simple tests."
The Bluetooth Special Interest Group (SIG) and Wi-Fi Alliance last year called on the FCC to drop the TLPS proceeding and deny Globalstar's request. Yet amidst heavy-hitting opposition, Globalstar continues to lobby for permission to offer TLPS. Last month, the company invited FCC Commissioner Ajit Pai and his legal advisor Brendan Carr, along with Gigi Sohn, counselor to FCC Chairman Tom Wheeler, and Gabrielle Whitehall from Wheeler's office, to visit the Washington School for Girls, where students were using Globalstar's TLPS, along with Wi-Fi channels 1, 6 and 11. Globalstar said that deployment of TLPS has been a success and confirms the public interest benefits that would result with its TLPS deployment.
In its November 2012 petition for rulemaking, Globalstar committed to providing 20,000 TLPS access points to schools and other institutions. But HIA says that number "pales in comparison" to the millions of hearing aids that are sold each year with wireless features. If Bluetooth LE or similar wireless technology becomes standard in hearing aids, annual sales of these hearing aids are likely will exceed 3 million devices a year, HIA said.
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