Finding the poison pill…

Posted in Financials, Globalstar, Operators, Regulatory, Spectrum at 2:41 pm by timfarrar

As I noted after the Satellite 2016 conference a couple of weeks ago, the outline of an FCC compromise over Globalstar’s TLPS proposal has become clear in recent weeks. That would involve increased sharing of the Big LEO L-band spectrum (which led Jay Monroe to use nearly as many F-words about Matt Desch as he did about me at the conference) and a restriction of the initial approval to operate at a power level of not more than 200mW (consistent with, but not specifically limited to, indoor operation). Then testing of Globalstar’s (supposedly all-capable, but apparently not yet contracted from ViaSat or even fully defined) Network Operating System would be required to demonstrate that any interference would be prevented, before any potential increase in power levels would be contemplated.

This mechanism was sought by Globalstar because then it would have an authorization for commercial deployment and, on the back of that, could go and raise $150M to keep the company funded (and avoid Jay having to put in any more money) for the next couple of years, while Globalstar looked for a partner that would attribute value to TLPS. Of course that may well be an endless task, if the cable companies do not “have an interest in leasing or buying Globalstar’s spectrum even if that company received approval by the FCC” and Cisco is unwilling to pay billions of dollars to acquire Globalstar.

I was told that an FCC order would very likely come before the end of this month, because the FCC wanted to get a precedent in place (of non-interference with existing unlicensed services, as recommended by Public Knowledge) before it considered what to do about LTE-U.

However, it seems everyone reckoned without Google’s continued interest in the proceeding, which has now forced Public Knowledge to change its tune, and emphasize that the FCC should impose the “public interest condition” of “authoriz[ing] reciprocal public use of Wi-Fi Channel 14 in locations where Globalstar’s TLPS is not deployed…in return for the auction-free windfall that Globalstar seeks.”

Google’s insistence on the “examination of options for general public use of Wi-Fi Channel 14″ seems like just the sort of poison pill that would prevent Globalstar from raising additional funding after the initial approval, because who would give Globalstar money for spectrum that they could use anyway whenever Globalstar had not deployed in a given location?

So if the FCC does include this condition, it seems highly likely that Jay will reject the deal, just as he did last summer when the FCC tried another compromise that would have involved low power approval only within Globalstar’s licensed spectrum, along with increased L-band sharing with Iridium. As a result, the uncertainty about the eventual outcome of the TLPS proceeding may last a little longer yet.


  1. dane1234 said,

    March 27, 2016 at 3:54 pm

    What about protection of co-channel TV BAS Channel A10 stations, a licensed and co-primary service? Part 15 WiFi anything is obligated to protect any licensed service. TLPS, as a newcomer co-primary service, would also be obligated to protect TV BAS, as an incumbent co-primary service. The effectiveness of a post hoc telephone call to a Globalstar NOS for interference mitigation is not credible. If the Google ex parte filing delays an otherwise imminent R&O, then great.

  2. ORBITRAX said,

    April 8, 2016 at 10:21 am

    I find the concept of this “NOS” fascinating. No one seems to have mentioned that non of the current lineup of the Globalstar duplex phones/modems have a GPS receiver? Globalstar patented a “triangulation” scheme to provide “vague” position location to determine international borders back in 1997 or so.. Back in 2001, I used a 1600 which would not provide me service about 3 miles from the Mexican boarder because I didn’t have roaming for Mexico as a subscriber. However, the system deduced that I was in Mexico instead of in the US. Now that vague approximation was with 48 satellites in it’s constellation. Now with 32 or less, One can only assume that the triangulation opportunities would be less, and location determination worse.

    Not sure how beneficial this triangulated “location data” would be to a NOS in this situation. But, then again, Open Range didn’t have any type of NOS to protect MSS, and that operated at power levels 1000″s of % higher than WiFi.


  3. timfarrar said,

    April 8, 2016 at 11:31 am

    Why would there be any intention to protect the MSS service from TLPS, especially on existing handsets (note there is no protection needed for TLPS since the satellite downlink signal is so weak)? Globalstar has never promised that it intends to give priority to MSS uses (or that handsets would even work in the vicinity of a higher power AWS-5 base station).

    As indicated in multiple filings, dating back to before the NPRM, the NOS is only intended to provide a mechanism for other parties (WiFi, Bluetooth, BAS, BRS/EBS) to complain if they receive interference:
    “a TLPS NOS will also create a rapid means of specifically identifying and controlling potential interference to adjacent-band operators”

    However, in practice the TLPS service will just look like additional noise and the now apparently ultra-low power operations will have little impact when the satellite handset must be used outdoors and the TLPS deployments will presumably be almost all indoors.

    Note that other intended terrestrial deployments in MSS spectrum (e.g. LightSquared) have only aimed to protect existing safety critical terminals. Inmarsat’s first generation ISatPhone handsets would have been unable to operate in the vicinity of the LightSquared tower (if they had deployed the downlink as originally intended), whereas maritime and aeronautical terminals would have had filters retrofitted to them. Newer Inmarsat terminals do now incorporate filters and won’t need to be retrofitted.

  4. ORBITRAX said,

    April 8, 2016 at 5:28 pm

    The argument circulated that Channel 14 (unlicensed) can not be opened to the commons, is based on the concept that MSS must be protected and a common control mechanism to regulate MSS/ATC AWS-5 operations.

    Globalstar’s Petition requests.
    “Add co-primary Fixed and Mobile allocations to the 2483.5-2495 MHz band (or “AWS-5” band);
    Modify Globalstar’s Big LEO license to include AWS-5 terrestrial authority, with common control of MSS and AWS-5 operations enabling intensive coordination to minimize interference to Globalstar’s MSS offerings;”

    Likewise, the FCC’s own NPRM states

    4 In adopting ATC rules, the Commission found that there were spectrum efficiency benefits to “dynamic allocation” of frequency use and that those benefits can only be realized by having one licensee control both the MSS and terrestrial rights in bands allocated for MSS.

    The entire argument on not opening Channel 14 to the commons is based on the “need” for some sort of “dynamic spectrum access control” to prevent interference to MSS. Obviously, you would need some control platform to provide this benefit, and it appears that, at least Google is under the perception that the NOS will act as some form of Spectrum Access control mechanism.

    In Google’s latest ExParte they state:
    “At a minimum, Globalstar should be required to (a) publish all protocol(s) its Network Operating System (NOS) uses to authorize spectrum used by TLPS devices in Channel 14 and (b) demonstrate
    that the NOS is capable of exchanging with non-TLPS devices all information NEEDED FOR SPECTRUM USE use in Channel 14,

    So it appears that Globalstar, the FCC, and at least Google seem to be under the impression that the NOS,or some Spectrum Access control system is required/involved with Spectrum management between MSS and TLPS.

    If there were some sort of common control of Spectrum Access as envisioned by the Petition and the NPRM. Then Globalstar would need to know the precise location of both the TLPS AP’s and the precise location of the Globalstar UT. Without integrated GPS receivers in Globalstar UT’s, then this envisioned coordination would be impossible. Without the need for coordination, with what is referred to here as AWS5, to protect MSS.. Then the reasoning to prevent access by the commons to Channel 14 is mute.

  5. timfarrar said,

    April 8, 2016 at 6:29 pm

    I agree the FCC’s rationale for letting MSS operators use their satellite spectrum for terrestrial deployment without an auction was the need for common control to prevent interference. Globalstar’s NPRM petition was aligned with that mandate.

    But other operators haven’t actually planned real time co-frequency operation of MSS and terrestrial devices, merely band segmentation which could (at least in theory) be shifted in the event of an emergency requiring more spectrum for MSS (e.g. an earthquake or hurricane which knocked out power to terrestrial networks). However, in practice the need for filters to implement this band segmentation would probably prevent most MSS devices from taking advantage of any additional spectrum.

    Google rightly suspects that Globalstar’s (not yet implemented) NOS likewise is incapable of supporting co-frequency operation between MSS and TLPS. Globalstar would either use band segmentation, or (more likely given any BRS/EBS deployments in the 2496-2500MHz band will be at much higher power) simply ignore any potential interference problems, just as they did with Open Range.

    That’s why Google are asking to see the details: if Globalstar reveals there is no means of preventing interference from TLPS to MSS devices, they will argue that the (MSS-based) rationale for Globalstar to have sole use of Channel 14 WiFi is ill-founded.

    On the other hand, Globalstar could argue that band segmentation is implemented at the gateway, if it uses only the 2495-2500MHz part of its spectrum in “normal” conditions and then has the potential to extend it to other parts of the S-band in “emergency” conditions. That would not require any intervention from the NOS other than to (potentially) shut down TLPS base stations if the segmentation is changed.

    Globalstar could argue it has no guarantee other non-TLPS Channel 14 users would be shut down in these circumstances. But I doubt Globalstar will say that it intends to implement band segmentation and not operate TLPS and MSS in the same frequencies because it would limit capacity (especially given the multiple gateways in North America) if only the highest four S-band channels were used (not to mention the bigger potential problem of BRS/EBS interference).

  6. ORBITRAX said,

    April 9, 2016 at 10:21 pm

    Yes, I agree and was basically my point about the lack of the GPS receiver in the 1600/1700 product line. Google is prodding the FCC to see the details. But, you don’t actually need to launch a live network to see the results. Because it can’t work with the 1600/1700 products.

    Rumors/Talk of a larger scale test deployment would force Globalstar’s hand regarding co-frequency coordination between MSS and TLPS.

    If it is segmentation, then, as you stated, Google plays the no need for sole use of Channel 14 card. Besides, Globlastar would likely need a modification of it’s COFACE covenants to fund any larger scale test deployment due to their restrictions on CapEx spending.. Like you correctly point out.. Segmentation into the 2495-2500Mhz would likely cause extreme capacity problems in areas with multiple gateways like North America, with each Gateway perhaps only being assigned one channel at a time. Of course the more obvious answer would be the creation of a Spectrum Access AP. Sample the LBand for any MSS transmissions, if any exist, then move the traffic to another Wifi Channel in the 2.4Ghz band. Then it’s fool proof. Globalstar could change it’s band segmentation at any time and the LBand transmission would trigger the spectrum reassignment on the WiFi AP. Surprised Google hasn’t shown up with one yet! Just a thought.

  7. TMF Associates MSS blog » Heading for last chance saloon… said,

    May 3, 2016 at 1:11 pm

    [...] it looks probable that Globalstar was derailed not just by Google’s poison pill, but also by growing worries about potential interference with Bluetooth hearing aids, a topic that [...]

  8. TMF Associates MSS blog » Jay cries uncle… said,

    May 13, 2016 at 11:52 am

    [...] cooperation (as I had assumed) or if Microsoft anticipated the issuance of an order that all sides acknowledged would require more testing and was simply preparing to conduct its own testing after that [...]

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