Interference Protections, Assurance of Existing MSS Urged in Globalstar Terrestrial Service Comments

The Wi-Fi Alliance continued to reject the TLPS proposal, arguing that the rules shouldn’t be changed “in light of the limited technical support and the numerous concerns raised by nearly every commenting party” (http://bit.ly/Ss8S1p). Approving the proposal would “perpetuate the designation of what would otherwise be spectrum used for public, enterprise, and consumer Wi-Fi systems,” it said. While Part 15 devices aren’t entitled to interference protection, the FCC has recognized “the need to balance different operational needs within a frequency band,” it said. The FCC adopted rules on the multilateration location and monitoring service (M-LMS) requiring M-LMS licensees to demonstrate through field tests that their systems didn’t cause unacceptable levels of interference to Part 15 devices, it said.

The Wireless Internet Service Providers Association said it will oppose adopting the proposal “until testing shows that existing Part 15 devices would not be adversely affected.” The FCC cannot substitute the benefits of the existing 2.4 GHz ecosystem “for the potential benefits of an interfering service,” it said (http://bit.ly/1uLGE01). WISPA alleged that Globalstar didn’t address any interference concerns, it said. The commission can’t ignore the record or its authority to require testing, it said. WISPA urged the FCC to use the M-LMS order as a guide in this proceeding. The Wireless Communications Association International agreed that many unanswered questions remain. While WCAI is pleased that Globalstar acknowledged its obligation to provide interference protection to Broadband Radio Service Channel 1 operations, “too many questions remain unanswered as to how Globalstar will provide the requisite interference protection,” it said (http://bit.ly/SsIc0k). Until those questions are answered, the FCC should refrain from granting Globalstar the authority to provide TLPS, it said. Wi-Fi Alliance, WISPA and WCAI expressed similar concerns in initial comments (CD May 8 p18).

Iridium said Globalstar’s proposal warrants “prompt action” on Iridium’s proposal for reallocating some big low-earth orbit spectrum from Globalstar to Iridium. The rule changes would allow Globalstar “to cease providing its current satellite services, and the business plan it outlines contemplates the creation of nationwide exclusion zones for its two-way satellite operations,” it said (http://bit.ly/1pcZf53). Globalstar never suggests that its network operations system (NOS) will enable it to offer TLPS and two-way satellite services in the same area, Iridium said. Although it suggests that the NOS gives it the capability to turn off TLPS operations to protect customers, “it stops short of stating that it actually will do so anytime a satellite user comes into a TLPS service area,” it said.

Changes to the gating criteria for Globalstar should include a requirement it continue supporting its current commercial services in the U.S. as a condition of offering TLPS, said the Mobile Satellite Users Association. The association said there’s a lack of information in the record demonstrating how Globalstar’s low-power ancillary terrestrial component (ATC) service will coexist with its mobile satellite services(http://bit.ly/1hB8k54). It’s “far from clear how much interference would be caused to existing MSS users by the proposed low-power ATC service and what the implications would be for satellite system coverage,” it said.

The FCC should approve TLPS with a reduction of the out-of-band emissions limit, which would most benefit customers “by both adding spectrum to the congested mobile broadband market and opening up additional spectrum for unlicensed use,” said student attorneys at the Samuelson-Glushko Technology Law & Policy Clinic at the University of Colorado-Boulder (http://bit.ly/1kTOJhc). The FCC record shows that most of the opposition to TLPS “comes from unlicensed users who have no right to expect to continue to operate on their frequencies, much less protection from interference,” it said. In the M-LMS order, the FCC adopted a safe harbor rule that gave unlicensed users a measure of protection, it said. The FCC emphasized that its rules sought to “minimize” rather than “eliminate” interference to unlicensed users, it said.

The commission should reject arguments urging relaxation of existing OOBE at the 2483.5 MHz band edge, Globalstar said (http://bit.ly/1s0T99S). If not, unrestricted and unfiltered Wi-Fi transmissions with a standard 802.11 emissions mask would be permitted on Wi-Fi channels 12-13, causing disruption to Globalstar’s licensed MSS offerings, it said. In this scenario, the FCC couldn’t assure Globalstar that its MSS offerings would be free from harmful interference from unlicensed operations, it said. The FCC decision on M-LMS is irrelevant to this proceeding, Globalstar said. Unlike M-LMS, TLPS “would be entirely compatible with other 802.11 Wi-Fi operations at 2.4 GHz,” said Globalstar. The company said it will use its NOS to make certain that TLPS doesn’t become an extension of the unlimited and uncontrolled Wi-Fi operations that occur throughout the rest of the 2.4 GHz industrial, scientific and medical band.