06.24.15

A time to hold and a time to fold…

Posted in Globalstar, Iridium, Operators, Regulatory, Spectrum at 4:06 pm by timfarrar

In recent months Globalstar has vented its frustration with the slow progress of the TLPS NPRM, telling the Commission in April that “it is time for the Commission to move forward with an order in this proceeding and realize the substantial public interest benefits of TLPS.” Nevertheless Globalstar has previously been unwilling to compromise, indicating that it would only accept approval of the rules proposed in the November 2013 TLPS NPRM and that it would not relinquish spectrum to Iridium.

However, in the face of overwhelming pressure from Microsoft, Google, Sprint and others, it seems Globalstar has now decided it will have to accept a compromise as an interim measure to avoid being stuck in limbo for many more months. In a meeting with the FCC International Bureau last Friday, Globalstar struck a much different tone, urging the FCC “to grant Globalstar the proposed ATC authority,” a term which Globalstar has always declined to use, preferring instead to refer to the Commission’s “regulatory framework for low power wireless broadband.”

Moreover, Globalstar “expressed support for the Commission’s 2013 proposal” apparently hinting at the existence of a new 2015 proposal. Looking at the elements that Globalstar “urged” the Commission to adopt (apparently Globalstar’s bottom line) compared to those that it “encouraged” or “asked” the Commission to consider (those elements that are not essential), it is clear that Globalstar now wants a grant of “ATC authority” under “proposed rules” which no longer necessarily comport with the 2013 NPRM. Globalstar also “asked” (but didn’t “urge”) the Commission to “reject the unsubstantiated technical and policy requests by [its] opponents,” suggesting that any decision on TLPS OOBE limits can be deferred.

In contrast, back in May, Globalstar “urged the Commission to adopt its proposed rules expeditiously to add 22 megahertz to the nation’s wireless broadband spectrum inventory and ease the congestion that is diminishing the quality of Wi-Fi service at high-traffic 802.11 hotspots and other locations,” i.e. to approve TLPS specifically.

This move now points the way to a near term order written by the International Bureau on the narrower matter of ATC authority for Globalstar within its existing 11.5MHz of licensed S-band spectrum from 2483.5-2495MHz, in exchange for granting Iridium’s request to share more of the L-band. That would be a close parallel to the FCC’s ruling in November 2007, when it issued an NPRM on extension of Globalstar’s ATC authority in conjunction with the last reallocation of L-band Big LEO spectrum.

I would expect the FCC to defer any potential approval of the wider 22MHz TLPS channel to a further proceeding, with more testing and analysis of interference concerns to be undertaken. The main uncertainty relates to whether the approval of ATC authority would be for full power use, along the lines of the Open Range approval (but adapted to LTE), in conjunction with protection measures for BAS, or whether the approval will be limited to the much lower power levels contemplated in the TLPS NPRM.

I would assume that high power ATC usage is likely to be approved (as it is hard to see a limited low power channel being acceptable to Globalstar), with Globalstar welcoming this ruling as offering it more flexibility to either lease a single 10MHz LTE channel to a wireless operator in the near term or to later gain approval for TLPS at the end of the further rulemaking process.

Of course the debate would then move to appropriate valuation benchmarks, which are much easier to assess for standard licensed spectrum, albeit with upwards adjustments for lack of a buildout requirement and downwards adjustments for maintaining an MSS network and creating an ecosystem for a non-standard band. In addition the potential timeline and cost must be considered for the rebanding needed to avoid interference with grandfathered BAS users.

I’m sure that some will emphasize AWS-3 benchmarks of $2+/MHzPOP as a baseline, while others will highlight the MoffettNathanson assessment that spectrum around 2.5GHz, like that owned by Sprint, is only worth around $0.40/MHzPOP, and this enormous discrepancy means that the debate about what Globalstar’s spectrum is actually worth will certainly continue. Nevertheless, approval of a high power licensed spectrum block, even if limited to only a single 10MHz LTE channel, will make it harder to argue that Globalstar’s spectrum is completely worthless.

2 Comments »

  1. dane1234 said,

    June 24, 2015 at 8:00 pm

    Rebanding the 2.5 GHz TV BAS band means modifying the hardware of all 2.5 GHz TV BAS licensees to three digital channels at 2,450-2,483.5 MHz, not just the grandfathered A10 (2,483.5-2,500 MHz) licensees. A similar process worked out well for both AWS and broadcasters in the refarming of the 2 GHz TV BAS band, from 1,990-2,110 MHz to 2,025-2,110 MHz; that is, from 17-MHz wide analog channels to 12-MHz wide digital channels, to free up 35 MHz of spectrum for AWS. The cost to Sprint Nextel was about $700M (WT Docket 02-55). The cost of refarming the 2.5 GHz TV BAS band would be less, since the radios from the 2 GHz transition are frequency and modulation agile, so in most cases could be reprogrammed rather than replaced. As a bonus, this would also solve the FCC’s problem with 2,496-2,502 MHz BRS Channel 1 stations vs grandfathered A10 stations.

  2. TMF Associates blog » Back to the Future Part 2… said,

    November 10, 2016 at 1:29 pm

    [...] 10MHz TDLTE channel, which is restricted to operate only at low power? Back in June 2015, I noted that there clearly would be some value for standard high power operation, but the question is a very different one for a low power [...]

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