Globalstar is hopeful after the public interest group Public Knowledge filed a letter with the FCC last week urging the commission use the Globalstar proceeding as an opportunity to clearly explain the relationship between licensed and unlicensed spectrum.
The letter from Public Knowledge on Globalstar's proposal to use the 2473-2495 MHz band for terrestrial low power services (TLPS) also suggested the commission to use it as a chance to reframe the commission's public interest analysis "to stress the importance of unlicensed as equal to, not subordinate to, licensed spectrum."
In the filing, Public Knowledge SVP Harold Feld notes that his own blog, in which he at one point referred to Globalstar as "parasitic" in nature, is his own independent blog and represents his personal views. The new Nov. 19 filing represents the views of Public Knowledge. "The Commission should consider the evidence submitted by Globalstar that TLPS systems relieve local traffic congestion on existing Part 15 Wi-Fi systems -- in some cases quite significantly," the filing states.
It also suggests that the commission act quickly to determine what additional data it needs, such as outdoor testing, and provide 30 days for Globalstar and representative stakeholders, under supervision of the FCC's Office of Engineering and Technology, to design a new set of tests. The parties responsible would then have a period of time to conduct the tests and submit their analysis. Public Knowledge suggests requiring no more than 90 days from the time the FCC initiates the testing process to the time the commission has concluded any reporting and comment period and is prepared to make a decision based on the results.
Feld also in recent weeks has called for the commission to address the LTE-U controversy by issuing a declaratory ruling that Section 333 applies not only to deliberate jamming, but that the commission should interpret the word "willingly" as meaning deploying technology that one knows will create unacceptable levels of interference. He notes that other blogs, including those by the Electronic Frontier Foundation (EFF) and AT&T, have endorsed the general approach of relying on Section 333 to police bad actors and remediate situations where deployment of Part 15 devices create unacceptable levels of interference. Feld argues, however, that the commission doesn't need a rulemaking to clarify the meaning of Section 333.
The Globalstar proceeding has been in the works for more than two years. Over the past year, Globalstar has shared results of indoor demonstrations, but its detractors are not satisfied and believe that TLPS will interfere with Bluetooth devices, especially hearing aids, and other unlicensed users.
Globalstar General Counsel and Vice President of Regulatory Affairs Barbee Ponder was pleased to see Public Knowledge's latest filing, calling the letter "another step forward, offering creative and thoughtful insights, including the acknowledgment that TLPS does potentially confer significant benefit to the unlicensed space."
"We hope it will help the FCC move forward promptly to adopt the rules it proposed over two years ago. The FCC's new rules will enable us to increase broadband capacity quickly and relieve significant wireless congestion," he added.
As for outdoor testing, he acknowledged that Globalstar has not provided much by way of public information on any outdoor testing that it has done. "We've said since the beginning that our TLPS plans are initially focused on indoor deployments and enterprise situations, and that's where we've shown that there's really no risk of harm to other licensed or unlicensed services," he told FierceWirelessTech.
Guggenheim Partners analyst Paul Gallant said the supportive letter from Public Knowledge materially improves the chances of Globalstar winning FCC approval for its TLPS proposal. "We think the opposition to Globalstar from major tech companies like Microsoft and Google slowed Globalstar progress toward FCC approval," he said in a research note. "But we also think the FCC may see that opposition as motivated by concerns over what a Globalstar approval would mean for LTE-U (a much bigger concern for Google and Microsoft than TLPS). And in fact, we think Public Knowledge's letter could soften opposition from cable and Google because it proposes a unified policy approach to unlicensed spectrum (including TLPS) that should appeal to cable and Google."
Based on an experimental licensed granted by the FCC, Globalstar deployed TLPS at the Washington School for Girls (WSG). Julius Knapp, chief of the Office of Engineering and Technology, was among those who visited WSG on Nov. 16 to observe students using TLPS. The demo was designed as another example of how Globalstar's integration of TLPS will produce public interest benefits, according to a Globalstar filing.
For more:
- see this Public Knowledge filing
- see this Globalstar filing
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