With Globalstar proceeding, saying 'it's complicated' is an understatement

Monica Alleven, FierceWirelessTechThe phrase "jumping the shark" is based on a scene from an episode of Happy Days when Fonzie jumps over a shark while on water skis. It's used to indicate the moment when a brand, design, franchise or creative effort's evolution is clearly on the decline.

I say this "might" apply in the case of Globalstar because... it's complicated, to say the least. I know what some interested parties are saying and what has been filed in the public FCC docket. There may be things going on of which I am unaware. So, that said, now I'm going to try to explain why I'm even suggesting the shark analogy.

Last week, the FCC's Office of Engineering and Technology published a staff report on demonstrations of Globalstar's proposed terrestrial low-power service (TLPS) that would operate on channel 14 (2473-2495 MHz) of the IEEE 802.11 standard. The report documents the environment setup, equipment used, transmission parameters (EIRP, data rate), and Wi-Fi channels operated during the demonstrations.

The report does not contain any staff analyses of those demonstrations, which is too bad. The FCC says the participating parties are expected to submit their own results and analyses into the record. It would have been nice to hear what the FCC staff thinks about this. Instead, we're left to wonder how that part turns out, like a cliffhanger episode in a TV miniseries. All shall be revealed... at a later time. Bummer.

As it stands now, Globalstar insists the tests show that TLPS will not interfere with Bluetooth or Wi-Fi, and the company, as well as some of its long-term investors, want the FCC to expeditiously OK plans to use the spectrum for mobile broadband services. As I understand it, the spectrum initially was for satellite services, but the company wants to use it for Wi-Fi types of services.

Bluetooth SIG, CableLabs, the National Cable Television Association (NCTA) and the Wi-Fi Alliance (WFA) participated in the demonstrations at the FCC's Technology Experience Center to see how Globalstar's proposed TLPS operation on channel 14 works with existing Wi-Fi devices and Bluetooth classic (BT) and Bluetooth low-energy (BLE) devices operating in the 2400-2483.5 MHz band.

Starkey Laboratories and Cambridge Silicon Radio (CSR) conducted demonstrations on BLE devices on behalf of Bluetooth SIG; AT4 wireless, Roberson and Associates and Jarvinian conducted demonstrations on BT, BLE and Wi-Fi devices on behalf of Globalstar; and CableLabs conducted demonstrations on Wi-Fi devices on behalf of NCTA and the Wi-Fi Alliance. The Wireless Internet Service Providers Association (WISPA) participated in the planning of the demonstrations, and indicated that they were satisfied with CableLabs' planned demonstrations, according to the FCC's report.

The Bluetooth SIG has been pretty clear on where it stands, saying its demonstrations at the FCC showed TLPS interference with Bluetooth hearing aids and Bluetooth Smart Lighting. As Bluetooth SIG CEO Mark Powell wrote in a blog post, Globalstar is seeking a change in the rules in the ISM band so that it can use a portion of it in an "overlapping/spill-over way."

He raises the question: Why should the FCC allow one company to use the ISM band with preferential rules only applying to them? If it couldn't succeed operating a satellite service, what suggests Globalstar would be good at operating a different commercial service? "Shouldn't the FCC take the frequency back and allocate it to someone who could operate the service successfully?" Powell asks.

NCTA is expected to submit its report later this month, although back in March it said it's hard to believe the FCC would draw any conclusions "from a non-scientific demo rather than real testing--especially when the FCC has indicated that it would do further testing." Globalstar already has told the commission that CableLabs' TLPS/Wi-Fi demonstration setup was "in no sense representative of a real-world deployment," and that "any results provided by CableLabs in this proceeding should be entirely discounted."

Google also weighed in last week, saying more or less that regardless of what the tests show, real-world operations of TLPS may differ substantially from the conditions tested. Google points out that nothing in the commission's current rules for the 2400-2483.5 MHz band would specifically require Globalstar to adopt a polite protocol, as Wi-Fi has, for its TLPS operations if such operations were authorized.

Technical issues are just one troubling aspect of Globalstar's proposal to use the 2400-2483.5 MHz unlicensed frequencies, the search giant said in its filing. "Globalstar's request raises a basic question whether it is consistent with the public interest for a commission licensee to leverage that permission to gain preferential use of spectrum outside the scope of its license, particularly when that other spectrum has been designated for unlicensed use on a shared basis," the company said.

If the FCC permits Globalstar, and only Globalstar, to use Wi-Fi Channel 14 at full Part 15 power levels, without the current restrictive spectrum mask, it will have granted a single company de facto exclusive use of frequencies between 2472-2483.5 MHz. Neither commission precedent nor sound spectrum management allows licensees to claim such privileged access to shared frequencies that are outside the scope of the license, Google said.

Google suggests alternative courses of action if low power operation in Channel 14 is possible without harmfully interfering with Globalstar's mobile satellite service (MSS) operations. Globalstar could reframe its proposal to, for instance, ask for permission to operate an ancillary terrestrial network, such as a 10 MHz TD-LTE system, on the spectrum above 2483.5 MHz, for which is already has a license. "What the commission should not do is give Globalstar authorization to use shared spectrum between 2472 and 2483.5 MHz on a priority basis, simply because it is the licensee of adjacent spectrum," wrote Google general counsel Aparna Sridhar.

Last year, the short-sellers at the hedge fund Kerrisdale Capital set out to tear Globalstar apart, declaring the company was "worthless" and bound for bankruptcy. They made some inflammatory allegations, arguing that Wi-Fi congestion is "massively overstated" and vowing to demonstrate "irrefutably" that Globalstar's TLPS concept is "laughable" and will never be commercially viable. You could chalk that up to activist investors out to make money and a name for themselves by saying negative things about the company. Ultimately, you have to wonder about the short-sellers' credibility.  

However, when you have the Bluetooth SIG saying the results of the demonstrations show significant potential impact upon users of Bluetooth products by TLPS deployment, that's a problem. Unless Globalstar can come up with some compromise or workaround with the Bluetooth and Wi-Fi communities, I don't see how it will move forward with its TLPS proposal.

Also weighing in on the matter is Gerst Capital, which is mainly a one-man show run by Greg Gerst. You can call him a short seller--he's admitted that he stands to gain when the news is negative for Globalstar--but in earlier and one of this latest filings, he raises a lot of technical questions that seem like they ought to be addressed before the FCC greenlights Globalstar's proposal. Of course, Globalstar will disagree.

Globalstar's story is a tough one. One the one hand, you want the underdog to win. In some ways, Globalstar can be seen as a scrappy, albeit billion-dollar, entity that has seen hard times in the past but is trying its darndest to create something successful. It's not as if its leaders are sitting idle and intentionally letting spectrum sit fallow, which is a strategy that others seem to have taken in the past.

Since FCC staff were present during the March tests and they were conducted at FCC offices, it would seem that they would have a pretty good idea what's going on here. But of course, nothing is simple when it comes to these types of things.

The proceeding is rife with complicated, sometimes confusing intricacies. But from pretty much any vantage point, it's time for the season finale. The commission should act soon, both to give Globalstar some kind of clarity about its future and the Wi-Fi and Bluetooth communities their due.--Monica

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