Globalstar investors call for swift FCC TLPS approval

Some long-term investors in Globalstar are asking the FCC to make a decision on its proceeding based on the facts before it and not the filings of short-sellers, like Gerst Capital and Kerrisdale Capital, that would profit from an FCC rejection of the Globalstar petition.

The Notice of Proposed Rulemaking (NPRM) for Globalstar's proposal with the FCC was issued in November 2013, and since then, the process has been "manipulated by companies that have a vested financial interest in the failure of Globalstar with regards to this proceeding," wrote Mark Walton of Kennesaw, Ga., who identifies himself as someone with a financial investment in Globalstar, in a March 25 filing with the FCC.

Showing a vote of confidence in Globalstar's management, another investor, Jeremy L. Berry of Midlothian, Texas, urged the commission to consider the spectrum needs of the nation, including schools and libraries, which would benefit from Globalstar's use of terrestrial low power services (TLPS). Spectrum is so vital to the economy that legislators are introducing the Federal Spectrum Incentive Bill, he said, arguing that the attacks from Gerst and Kerrisdale lack merit and should be disregarded.

Globalstar is urging the commission to adopt the rules proposed in November 2013 to allow Globalstar to provide TLPS in its own licensed spectrum and in adjacent, unlicensed spectrum. The company says by doing so, it can help relieve some of the congestion that Wi-Fi services are experiencing.

According to a March 27 Globalstar filing, commission staff at the FCC Laboratory in Columbia, Md., on March 24 and 25 performed a series of tests on two access points enabled for TLPS operations in Globalstar's licensed spectrum at 2483.5-2495 MHz and adjacent, unlicensed spectrum at 2473-2483.5 MHz.

Ruckus Wireless access points also were used in a demonstration of TLPS technology at the FCC's Technology Experience Center (TEC) on March 6 and March 9-10. At the FCC's lab, commission staff conducted radiated emissions tests, where RF radiation from the TLPS access point was studied in an anechoic chamber and conducted emissions tests, where the TLPS access point was directly connected to a spectrum analyzer via a coaxial cable, Globalstar said.

Globalstar says demonstrations confirm that TLPS is a good neighbor to Wi-Fi operations in the IEEE 802.11 Channel 11 and other channels, and with Bluetooth in the unlicensed ISM band at 2400-2483.5 MHz. The Bluetooth Special Interest Group (SIG), however, says demonstrations at the FCC actually provided illustrations of interference with Bluetooth hearing aids and Bluetooth Smart Lighting.

Meanwhile, Gerst Capital is pressing the FCC to take its time in evaluating the tests and methodology that have been done recently. "Contrary to Globalstar's claims, their demonstrations provide neither the level of technical rigor nor the level of information necessary for the FCC to make an informed decision regarding TLPS," wrote Greg Gerst in his March 31 filing.

"Given the technical controversy surrounding Globalstar's TLPS proposal, it is critical all interested parties have a chance to review relevant Part 15.247 emissions test results for the Ruckus access points used in the TLPS demonstrations," Gerst said. "This is especially important in light of the fact that there has NEVER been a published set of emissions test results for any 802.11n Wi-Fi device transmitting on Channel 14/TLPS."

For more:
- see this FCC filing and this filing
- see this Globalstar filing
- see this Gerst Capital filing

Related articles:
Bluetooth SIG, others dispute Globalstar's TLPS test results
Globalstar: Tests at FCC facility show successful TLPS implementation
Globalstar asked to prove TLPS will work on iPhone 6
Investor says Globalstar's Wi-Fi tests are 'not real tests'
Globalstar fights back against investor who claims the company's spectrum is worthless

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