05.11.16

Jay cries uncle (or not)…

Posted in Globalstar, Operators, Regulatory, Spectrum at 5:47 pm by timfarrar

As I predicted last week, TLPS missed its chance for approval on April 22, despite Jay Monroe being convinced that it was in the bag when he presented at the Burkenroad conference earlier that day. He presumably had been assured of that by Globalstar’s General Counsel, Barbee Ponder, who thought they had answered all the FCC’s questions in late March and seemingly didn’t bother to follow-up after that point.

Now today we have seen an experimental license filing from Microsoft to test TLPS in Redmond, WA. Microsoft’s application states:

“Microsoft will test terrestrial operations in the 2473-2483.5 MHz unlicensed band and the adjacent 2483.5-2500 MHz band, consistent with Globalstar Inc.s proposal to operate a terrestrial low-power service on these frequencies nationwide (see IB docket no. 13-213). Microsoft seeks to quantify the affect [sic] of such operations on the performance and reliability of unlicensed operations in the 2.4 GHz ISM band.”

The application also includes the incidental admission that Gerst is correct that the Ruckus APs have been modified (by removal of coexistence filters) from the approved versions (the testing will include “the use of an intentional radiator in the 2473-2483.5 MHz unlicensed band that has not received an equipment authorization as ordinarily required under 47 C.F.R. ยง 15.201″) although it should be noted that Microsoft plans to use different APs from those in Globalstar’s own tests, including a consumer model which was one of Microsoft’s primary concerns.

The duration of the experimental license is requested to be 6 months, from May 23 to November 23, suggesting that we may not see results until the fall. This could perhaps permit FCC consideration of the results after the November election if Microsoft identified no problems whatsoever (or if the FCC sets a hard deadline for further testing, though as noted below Bloomberg is reporting that the initial authorization will last at least a year), but more likely it will set the scene for additional back and forth between Globalstar and its opponents in the period before the next FCC Chairman gets his or her feet under the desk in spring 2017.

UPDATE (5/13): Despite Microsoft’s experimental application, Globalstar’s TLPS proposal has finally made it onto the FCC’s circulation list this afternoon. That raises the question of whether Microsoft’s application was made with Globalstar’s cooperation (as I had assumed) or if Microsoft anticipated the issuance of an order that all sides acknowledged would require more testing and simply jumped the gun in preparing to conduct its own testing after that point (which now seems the most plausible explanation).

So now the focus will shift to what this order contains. It seems to basically be taken for granted that there will be increased sharing of L-band spectrum with Iridium (though that would come in a separate parallel ruling by the International Bureau on delegated authority) and that additional power limits will be imposed as an interim measure, probably at a 200mW level. Bloomberg is also reporting that there will be constraints on the number of APs that may be deployed, with a limit of 825 in the first year, and “the FCC will assess whether they cause interference to other services”. However, prior to the rejected deal last summer the FCC also contemplated changes to the OOBE restrictions that would permit increased use of Channels 12 and 13 by terrestrial users, and it will be interesting to see if these changes are still present, or if they have been modified, perhaps due to concerns about possible impacts on Bluetooth LE users in the upper part of the unlicensed spectrum.

2 Comments »

  1. dane1234 said,

    May 11, 2016 at 6:49 pm

    Presumably the experimental authorization, if granted, will have the SBE Clause, requiring frequency coordination with broadcasters. OET normally places that condition on experimental licenses that include Broadcast Auxiliary Service frequencies. There may also be some Part 101 Public Safety licensees on the 2473-2483.5 MHz portion; broadcasters share 2450-2483.5 with Public Safety, and Seattle is a big enough metro to likely have such shared use. If so, there will probably also be a frequency coordination condition on the experimental grant requiring coordination with Public Safety licensees.

  2. ORBITRAX said,

    May 11, 2016 at 7:41 pm

    It will also be interesting if Microsoft takes upon itself to test MSS interference with standard power level Channel 14 WiFi. This experimental license will give them the unique opportunity to test the actual impact of standard Channel 14 WiFi on Globalstar S Band MSS operations.

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