Protections for BRS, BAS, Unlicensed Users Demanded in Globalstar Terrestrial Service Proceeding

Globalstar said if the proposed low-power broadband rules are adopted, its terrestrial low-power service would comply with existing Part 15 technical rules for operations below 2483.5 MHz. TLPS would satisfy the FCC’s proposal to “limit unwanted emissions below 2473 MHz to at least 20 dB below the fundamental power in the 100 kHz bandwidth within the band containing the highest level of desired power,” it said (http://bit.ly/QfrAIo). The FCC should maintain its emissions limit for unlicensed operations at the 2483.5 MHz band edge to avoid threatening the future of Globalstar’s authorized MSS network, it said. Instead of requiring re-certification and new FCC IDs for updated, TLPS-capable devices, the FCC should allow modification of existing consumer devices through its permissive change process, Globalstar said.

Dish generally supports the plan for a terrestrial low-power service (TLPS). Dish supports rule changes that would relieve Globalstar from certain ancillary terrestrial component (ATC) gating criteria and other changes to the FCC Part 25 rules that would enable the deployment of Globalstar’s proposed service, it said (http://bit.ly/1fVuCxT). It said it supports making an exception for low-power ATC “from rules requiring detailed showings concerning satellite system coverage and replacement satellites.” Dish agreed that a simplified showing is sufficient.

NTCH, a small carrier, supports the TLPS plan due in part to the differences in the conditions placed on Dish’s AWS-4 spectrum. The FCC doesn’t propose to relieve Globalstar entirely of the obligation to provide satellite service, it said (http://bit.ly/1fVADed). This proposal “has a much greater likelihood of an early roll-out than the Dish license,” it said.

Cisco asked that Globalstar’s effort to deploy TLPS doesn’t adversely impact the use of the 2.4 GHz band. Globalstar should be required to describe in far more detail how it intends to update the software in consumers’ existing IEEE 802.11 devices to operate on Channel 14 and how it will thereafter “utilize network management and security techniques to control these modified devices to prevent unauthorized use of the 2473-2495 MHz band,” it said (http://bit.ly/1s3ZYm3). It’s essential that the FCC state in clear, unambiguous language that Globalstar’s use of 2473-2483.5 MHz “will be on precisely the same terms and conditions as any other Part 15 user,” it said. Cisco doesn’t take a position on the TLPS, but supports the power and unwanted emissions limits proposed in the NPRM.

Iridium included a revised spectrum plan that asks the FCC to reassign only the 1617.5-1618.725 MHz portion “for Iridium’s exclusive use for now” (http://bit.ly/1kMqGNg). This is a 1.225 MHz increase to Iridium’s licensed 1.6 GHz satellite operations, “and shared, co-primary access to an additional 1.5 MHz of spectrum ... currently available only to Globalstar,” it said. Iridium continued to urge the commission to grant its petition to reallocate big low earth orbit (LEO) spectrum from Globalstar to Iridium (CD Nov 5 p5). Globalstar’s proposals highlight the need to protect and promote continued development and viability of satellite services, it said.

The commission should require Globalstar to show it won’t cause an “unacceptable amount of interference to unlicensed users of the 2.4 GHz band,” NCTA said (http://bit.ly/1jBxEGL). Globalstar should be required to disclose publicly and in full “the experimental test data and results on which it based its conclusion that TLPS interference to unlicensed is unlikely so other stakeholders can analyze Globalstar’s methods and results,” it said. Technical operating rules and interference protection rules should place Globalstar on the same footing as 2.4 GHz unlicensed operations, it said.

The Wireless Communications Association International (WCAI) and Sprint sought to protect Broadband Radio Service (BRS) Channel 1. “Without such protection, Sprint is concerned about the potential for harmful interference due from” out-of-band emissions “from TLPS to Sprint’s receivers operating on the BRS-1 Channel,” said Sprint (http://bit.ly/1qf8gvD). Sprint supports the FCC proposal to require that equipment vendors obtain consent from Globalstar and provide evidence of that consent for certification of equipment to be used in the 2483.5-2495 MHz band, it said. The FCC must assure that “all devices capable of operating at 2483.5-2495 are under Globalstar’s control at all times,” WCAI said (http://bit.ly/1sm7yu8). The association urged the FCC to take no action on the NPRM until Globalstar fully answers questions and establishes “that it can, as a practical matter, satisfy its absolute obligation to protect operations on BRS Channel 1."

The Wi-Fi Alliance urged the commission to reject the proposal because it isn’t expected to be interoperable with devices certified by Wi-Fi Alliance as “Wi-Fi Certified” (http://bit.ly/RojcYm). Globalstar hasn’t demonstrated that its proposed operations can coexist with Wi-Fi and other operations in the 2.4 GHz band, the Wi-Fi Alliance said. It also urged the commission to reject the testing results by Jarvinian as a basis to proceed (CD June 19 p21). The summary report doesn’t describe test conditions and setup, “making it impossible for interested parties to verify for themselves the purported results of the study,” it said. The Wireless Internet Service Providers Association (WISPA) said the record doesn’t support adopting the proposal. WISPA has concerns on the limitations on current and future uses of the 2400-2473 MHz and 2473-2483.5 MHz bands, it said (http://bit.ly/1g8P1tT). Globalstar’s claim that harmful interference from TLPS operations to Channel 11 is “highly unlikely under real-world conditions” is completely unsupported by any technical evidence in the public record, it said.

The Society of Broadcast Engineers argued that the proposal would have adverse implications for BAS channels A8 and A9. It also urged the FCC to adopt its 2003 proposal to “refarm” 2.5 GHz, which would accommodate both MSS and BRS/EBS operation in the 2483.5-2500 MHz band (http://bit.ly/1kMsCFm). ATC in this band isn’t spectrum-efficient, it said. The FCC seems to be willing to sacrifice real-time news, event reporting and other services “that the public expects just as much as it expects available mobile broadband services,” SBE said. The American Radio Relay League pointed out the need to protect use of devices in 2473-2483.5 MHz. ARRL urged the FCC to consider a “spectrum overlay” in that band “on the basis of reliable compatibility analyses rather than on mere assumptions of compatibility” (http://bit.ly/1mDlZXc).