A very few of us have paid much attention to something called the “Globalstar Petition.” Briefly, Globalstar would like a couple of billion dollars in free spectrum favors from the FCC to offer what it calls a “Terrestrial Low-Power Service” (TLPS) on its satellite frequencies. As Globalstar has the great good fortune to have frequencies right next to the 2.4 GHz band most popular for WiFi, Globalstar hopes to leverage existing WiFi equipment and offer a “paid, carrier grade” WiFi-like service.
Recently, Globalstar attracted my negative attention by trying to leverage a fairly important FCC proceeding to expand unlicensed spectrum use above 5 GHz. Globalstar has raised bogus interference issues in the 5 GHz proceeding, and rather unsubtly suggested to the FCC that it could solve the WiFi “traffic jam” by granting Globalstar’s Petition for spectrum goodies so we could have a pay for WiFi service instead of having more of that pesky free WiFi (you can find Globalstar’s extremely unsubtle quotes here on page 3 and here on page 2.
So it seems an opportune moment to explain:
- What’s going on with the Globalstar Petition;
- What’s going on with the UNII-1 Band in the 5 GHz proceeding;
- How Globalstar are being utterly unsubtle in their efforts to hold the 5 GHz proceeding to try to leverage their ask in their Petition; and,
- How Globalstar’s jerkwad-ittude in the UNII-1 proceeding raises serious concerns about Globalstar’s willingness to play nice with the 2.4 GHz band, which could undermine the entire “WiFi economy.”
More on Globalstar’s truly stellar chutzpah, and why the FCC may want to rethink granting the Globalstar Petition, below . . . .
Some Necessary Background To Explain Where All This Nonsense Came From In The First Place.
Globalstar, for those who have never heard of it before, provides mobile and fixed satellite telecommunications service. Since nearly forever, satellite companies have wanted to find a way to use the frequencies allocated to them for satellite service to provide some sort of terrestrial service because that way they can, they hope, make beaucoup bucks emulating the likes of Verizon wireless. From the FCC’s perspective, it makes sense to try to use spectrum more efficiently, and the path of least resistance for this is to let people who have licenses expand the use of that spectrum.
Yes, there’s a statute that says we’re not supposed to give windfalls to spectrum licensees. So how can the FCC just go ahead and give billions of dollars in spectrum rights to these companies for free? At this point, don’t worry about it. Just know we have something called “ancillary terrestrial component” (ATC) that lets satellite licensees use the frequencies allocated for satellite use for terrestrial use.
But even with ATC, no one could find a business model that made sense. So satellite companies keep chasing the ATC rainbow while occasionally going belly-up in bankruptcy and getting bought out. To get more background than you could ever possibly want, you can read my 2011 Insanely Long Field Guide to Light Squared. You can read about Globalstar’s last failed attempt to use its ATC in combination with a terrestrial WISP called Open Range here. And, just for completeness sake, you can read how DISH bought out two bankrupt satellite companies, DBDS and Terrastar, to get their ATC and start a terrestrial wireless service here.
The Globalstar Petition
In November 2012, Globalstar came back with yet-another-sure-fire-plan-to–make-beaucoup-bucks-using-ATC-and-this-time-TOTALLY-not-go-bankrupt. Also, as usual, it required the FCC to grant even more special favors than simply letting the licensee use several billion dollars worth of terrestrial spectrum rights for free. So Globalstar filed a Petition for Rulemaking asking the Commission to give it more goodies in exchange for some public interest trinkets and the general idea that More Spectrum In Use More Efficiently Is Good (when I hold the license).
Globalstar has downlink (from satellite to Earth receivers) in operation in the 2483.5 MHz – 2500 MHz band. That situates it between the stuff Clearwire and Sprint use up at 2.5 GHz (technically the “Broadband Radio Service (BRS) and the Educational Broadband Radio Service (EBRS)) and the 2.4 GHz band used for WiFi in the U.S. (technically the “Industrial, Scientific and Medical” (ISM) Band, because unlicensed use in the band is actually an underlay for licensed ISM devices; but at this point most people call it the “WiFi Band” because that is where most of the WiFi action in the U.S. happens for reasons I will not explain now).
Globalstar proposes to combine the features of the amazingly successful WiFi Band with the amazingly unsuccessful business model of Clearwire to totally not go bankrupt this time. Globalstar will offer a “terrestrial low-power service” (TLPS) which it will offer to lease out to people or otherwise make money by giving people WiFi they could get for free, but make them pay for it. According to Globalstar, TLPS will be infinitely superior to cruddy old WiFi because it is “licensed” and therefore “carrier grade” and therefore people will totally pay gajillions for this even though the thing they like about WiFi is that it’s free and they don’t have to deal with a wireless carrier.
In what can only be described as the most pathetic, paltry, and all around insulting gesture to the public interest ever, Globalstar also offers to set up some free hotspots for schools and libraries that don’t already have free hotpsots with free Wifi. Oh, and they will also do something public safety-ish.
And, just to be as parasitic as possible, Globalstar will leverage all the equipment already out there for WiFi, since it needs relatively little modification. They will also leverage the good will generated by WiFi by calling this “licensed WiFi.”
In the interests of time and space I’ll make this short and will not touch on my many reasons for thinking this is a dumb idea, although you can probably guess some of them by now. You can see some pretty diagrams of the band plan and read a much more sympathetic version of the Globalstar “Licensed WiFi” proposal here.
So What Happened To The Globalstar Petition?
The FCC put the Globalstar Petition out for public comment last January. Because the Petition did not contain much to go on, and because people rarely comment on Petitions for Rulemaking because it’s not clear they will go anywhere, the FCC got relatively modest response. Mostly it was folks like the Bluetooth Alliance and WiFi alliance saying “well, as long as this doesn’t cause problems for the 2.4 GHz band, fine. But we have a bunch of concerns over how this could ruin things for WiFi, Bluetooth, and everyone else using the 2.4 GHz unlicensed band.”
In response to this massive display of ambivalence, and in recognition that people would not focus on this until the FCC actually indicated it was serious about possibly granting Globalstar’s request, the FCC put the Globalstar Petition out as a Notice of Proposed Rulemaking back in November 2013. The NPRM has not yet appeared in the Federal Register, so we have no date for public comment yet. Again, you can read a much more sympathetic treatment of the proposed “Globalstar WiFi Chanel,” with pretty diagrams, here.
And What, Exactly, Does This Have To With 5 GHz and/or UNII-1?
Meanwhile, back in February 2013, when we were running our hit series “Everybody Love WiFi,” the FCC opened a proceeding to add several hundred MHz of unlicensed spectrum above 5 GHz. This included looking at the limits on the UNII-1 Band. When the FCC opened the “Unlicensed National Information Infrastructure” (UNII) bands for unlicensed in 1997, it limited UNII-1 (5.150-5.250 GHz) to 50 miliwatts and indoor use only to protect certain federal operations and Fixed Satellite Service (FSS). As part of the February 2012 Notice of Proposed Rulemaking, the FCC proposed to relax rules for the UNII-1 band to increase power and allow for outdoor use.
This would have huge impacts for unlicensed by opening up a big swath of spectrum capable of handling the new WiFi protocol 802.11ac. The 802.11ac protocol lets you get tons of throughput at high speed (1 gigabit/second).
Pretty much everyone agrees that getting – 1 gigabit/second WiFi – even with all the limitations of high-band spectrum, would massively improve things for users. Outdoor users like wireless ISPs (WISPs), cable operators, and licensed wireless carriers using unlicensed for offload would see huge improvements in their operations. Indoor users would see WiFi capable of handling the throughput from fiber connections. It would be a massive win for everyone.
While other parts of the FCC’s proposal face stiff opposition from the automobile industry, changing the UNII-1 rules has met with general approval. Even federal users have signaled they can live with the changes. Both Commissioner Rosenworcel and Commissioner Pai have urged the FCC to move quickly to relax the rules on UNII-1 use to make it compatible with 802.11ac. At this point, only one interested party seriously opposes relaxing the rules on the UNII-1 band.
Wait! Let Me Guess! Globalstar?
You got it!
What’s Globalstar’s Issue?
Globalstar operates both Fixed Satellite Service (FSS) and Mobile Satellite Service (MSS). It has five geographically fixed FSS “feederlinks” in the UNII-1 band. As always, one expects incumbent licensees to kick up a fuss. So it was no surprise that Globalstar in its comments in the Unlicensed NPRM and reply comments raised interference concerns.
But Globalstar has made it clear that it plans to hold up the UNII-1 Band to leverage its Petition for its “licensed WiFi” alternative.
How Unsubtle Are We Talking About?
Consider this quote from Globalstar’s Reply Comments:
“In the immediate term, the only spectrum band that can help alleviate the Wi-Fi Traffic Jam is the original Wi-Fi band at 2.4 GHz. To this end, the Commission should expeditiously issue a Notice of Proposed Rulemaking that addresses Globalstar’s November 2012 Petition for Rulemaking and proposes to expand the terrestrial use of the Upper Big LEO band (at 2483.5-2495 MHz). Among the innovative mobile broadband applications that will be possible in this band is Globalstar’s proposed TLPS, which could rapidly and dramatically relieve existing congestion on public Wi-Fi channels through a carrier-grade, carrier-managed service. In contrast to the other Wi-Fi opportunities in the spectrum bands identified above (including in the 5 GHz band), TLPS at 2.4 GHz can be implemented almost immediately by leveraging existing investment in infrastructure and existing consumer devices” (at 9-10).
O.K., But That’s Pretty Standard For An Incumbent. Also, That Happened Back In The Summer. What Pissed You Off Now?
What pissed me off as going way over the line from usual incumbent chutzpah to truly stellar chutzpah was Globalstar’s submission of an “Independent” interference assessment (aka “The Roberson Report” for the consulting firm that wrote it) purporting to prove that changing the UNII-1 rules would kill Globalstar’s fixed satellite links operating in the UNII-1 Band.
To reach this conclusion, the Roberson Report relies on unrealistic assumptions and what can only be called “technological learned helplessness.”
First, Assume The Most Sophisticated Communications Satellite System Ever Launched Is So Dumb It Cannot Store The Geographic Coordinates Of 5 Fixed Geographic Uplink Stations.
Globalstar has five geographically fixed Earthlink stations for uplink. Yet Globalstar claims that its satellites cannot remember the geographic location of these five fixed uplink sites. Instead, each Globalstar satellite as it passes in orbit can only “find” these fixed five uplink stations by (a) looking at the entire country, (b) picking out the points of emission operating in the 5096-5290 MHz band and, as it does every time, locking in on those five fixed points as if it had never done so before.
Globalstar has boasted in this proceeding of the technical capabilities of its recently launched Second Generation MSS system and it’s amazing technical capacity. Yet this sophisticated satellite system cannot store the geographic coordinates of 5 fixed uplink stations? And cannot be adjusted remotely to do so? To put it mildly, this strains credulity.
Next, Assume Unrealistic Deployment
Even accepting this rather far-fetched tale of technical incompetence wherein a satellite system launched in February 2013 is at once both the most sophisticated satellite communications system in the world but cannot store five fixed geographic coordinates from one orbital pass to the next, that is still not enough to create substantial interference. To achieve sufficient interference to “blind” its satellite from finding these five fixed terrestrial coordinates, Globalstar also assumes a wide scale deployment with no signal attenuation for buildings, trees, or atmospheric conditions. Given the well known signal attenuation problems for high frequency spectrum, notably its poor penetration and propagation characteristics (compared to low-band spectrum), this assumption is simply not tenable. Globalstar appears to contemplate a world in which every building, lamppost, tree limb and mountaintop is festooned with UNII-1 transmitters operating at full power with high-gain antennas pointing straight up.
Even Making All These Assumptions, The Fix Is Easy.
Yet even if one, like the Red Queen, chooses to believe such impossible things before breakfast, the solution to Globalstar’s concern is relatively simple. In the event Globalstar’s dire predictions of an increase in the noise floor sufficient to “blind” its satellite system comes to pass, the Commission can permit Globalstar a sufficient increase in uplink power to attract the attention of it’s idiot-savant satellite system.
The FCC Should Not Reward Globalstar’s Stellar Chutzpah.
In no event should the Commission even contemplate rewarding Globalstar for its obstructionism by complying with its-not-so-subtle suggestion that the Commission instead should “rapidly and dramatically relieve existing congestion on public Wi-Fi channels, the ‘Wi-Fi Traffic Jam,’ through a carrier-grade, carrier-managed service” which, coincidentally, Globalstar has applied to operate. It is bad enough that Globalstar has demanded billions of dollars in free spectrum rights without a single concession to compensate the public for this windfall. To then attempt to hold this proceeding hostage with bogus interference claim demonstrates, as befitting a satellite communications provider, truly stellar chutzpah.
Can We Trust Globalstar Near the 2.4 GHz Band?
More importantly, Globalstar’s anticompetitive and disingenuous behavior in the UNII-1 proceeding casts grave concerns on its willingness to be a “good neighbor” to unlicensed operations in the 2.4 GHz band?
As always, a petitioner coming in to the FCC promises everything to get the license modification, then tries to leverage it later. Globalstar has promised it will accept Part 15 interference rules for its “licensed WiFi” terrestrial low power service. But even with this limitation, Globalstar can – if it commences operations – play all sort of games to squeeze out unlicensed to drive business to its licensed service. It can also make bogus interference claims with regard to its protected licensed service in the band.
Given Globalstar’s conduct trying to hold up the UNII-1 Band, the FCC (and the rest of us) need to ask whether Globalstar will really play well with existing unlicensed operations in the 2.4 GHz band?
As we saw with the Progeny fight, once you have a licensed provider in the neighborhood, you put operation of unlicensed at risk. The 2.4 GHz unlicensed underlay is the foundation of an unlicensed spectrum economy worth – depending on estimates – about $50 billion -$100 billion a year. That’s not something you want to risk lightly. Given Globalstar’s actions to date, I don’t see why the FCC should put the entire unlicensed economy at risk to further Globalstar’s latest effort to get rich off terrestrial use of their satellite spectrum.
Stay tuned . . . .