Google (NASDAQ: GOOG) is revisiting the idea that the FCC consider whether it is possible to allow general unlicensed use by the public of Channel 14 while still protecting Globalstar's satellite services.
In an ex parte filing, Google Communications Law Director Austin Schlick said he spoke by phone with FCC Chairman Tom Wheeler's legal advisor Edward Smith on March 22 regarding Globalstar's application to occupy Wi-Fi Channel 14 with its terrestrial low power service (TLPS). During the call, Schlick observed that if the commission were to grant Globalstar special rights to test a proprietary service in currently unlicensed spectrum, then "fairness and sound spectrum planning require that such testing include examination of options for general public use of Wi-Fi Channel 14," the filing states.
The New America Open Technology Institute (OTI) and Public Knowledge (PK) also referenced the idea proposed last year in separate filings with the commission whereby the commission could consider a public interest condition, enabling both TLPS and enhanced Wi-Fi more broadly. OTI says that in exchange for the valuable terrestrial mobile waiver and conditions that Globalstar is seeking, the commission could authorize reciprocal public use of Wi-Fi Channel 14 in locations where Globalstar's TLPS is not deployed and where Globalstar itself has determined that Channel 14 transmissions create virtually no risk of harmful interference to its mobile satellite device customers.
"Although Globalstar has a legitimate claim to exclusive use of the licensed portion of Channel 14 where and when it actually commences service, the [OTI/PK] advocates noted that Globalstar is highly unlikely to deploy immediately on a nationwide basis," OTI's March 24 filing states. "In return for the auctionfree windfall that Globalstar seeks, unlicensed operations should be able to use Channel 14 on an opportunistic basis, as the Commission has adopted for the 600 MHz band post-incentive auction."
Globalstar has said it doesn't believe that TLPS will have any negative impact on unlicensed services, but it is committed to use interference detection and mitigation techniques. It has proposed providing a carrier-grade network operating system (NOS) analogous to the systems used to manage pico- and femto-cellular infrastructure.
In his ex-parte filing, Schlick says that at a minimum, as part of any real-world testing, Globalstar should publish all protocol(s) its NOS uses to authorize spectrum used by TLPS devices in Channel 14 and demonstrate that the NOS is capable of exchanging with non-TLPS devices all information needed for spectrum use in Channel 14, without reliance on non-public protocols or standards.
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