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.

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).

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.

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.

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.

ORBITRAX .