AICC Comments on Globalstar Proposal to Use Part of Wi-Fi Spectrum

AICC Wireless Report

June 12, 2014

John Prendergast

AICC Comments on GlobalStar Proposal to Use Part of Wi-Fi Spectrum

On May 5, AICC filed comments (Attachment A) on Globalstar’s proposal to establish a terrestrial wireless network, using not only its satellite radio spectrum but also part of the unlicensed Wi-Fi spectrum. AICC is concerned that Globalstar’s operations in the 2473-2483.5 MHz portion of the Wi-Fi band could inadvertently hinder public safety response to emergency situations by causing interference to critical alarm signals sent with the assistance of Wi-Fi equipment commonly operating on spectrum immediately adjacent to that band. Multiple entities have raised the concern that interference and band crowding due to Globalstar’s proposed operations to the millions of existing WiFi devices already in use could force an unnecessary and extremely burdensome replacement process, which must be weighed against any benefits from Globalstar’s new service.

With the availability of more effective encryption technologies, a growing number of alarm systems include Wi-Fi connectivity in the alarm panel.
Increasingly, alarm systems are incorporating WiFi-enabled sensors in alarm devices.
In addition, certain alarm technologies are incorporating access to the internet, including WiFi connections, as a way to accomplish an affordable alternative path to the central station.
AICC has asked the FCC to order that thorough testing be conducted by an independent testing authority, before Globalstar’s proposed system can go forward. Affected stakeholders (including alarm industry reps) should be allowed to participate in the testing process.
AICC also supports the Commission’s proposal that Globalstar not be granted any additional interference protection rights in the unlicensed bands, but instead be subject to the same rules that apply to other unlicensed users.
Finally, AICC asks the FCC to confirm that Globalstar’s proposed operations would protect GPS operations.

Comment Summary

The Wi-Fi Alliance filed comments largely in line with previous filings, stating that Globalstar’s proposal could negatively affect the operating environment for Wi-Fi and other unlicensed operations by unacceptably increasing the level of interference to, and causing increased congestion in, the 2.4 GHz band. Wi-Fi Alliance also noted that the summary report offered by Globalstar, which was intended to show that there will be no impact on other operations from Globalstar’s system, was not sufficiently detailed for stakeholders to meaningfully assess its claims. In the event that the FCC approves Globalstar’s proposal, Wi-Fi Alliance asked that the FCC clarify that Globalstar’s operations are not entitled to interference protection from other devices operating in the 2.4 GHz band and adopt appropriate technical rules, including limits for equipment operating in the 2483.5-2495 MHz band and for unwanted emissions below 2473 MHz consistent with Section 15.247, among other things.

The Wireless Internet Service Provider Association (WISPA) filed comments stating that it could not support Globalstar’s proposal until cooperative testing takes place that actually demonstrates the absence of harmful interference. WISPA also expressed concern about Globalstar’s statements regarding band management, which it felt strongly imply Globalstar will only allow access to those that meet whatever technical, financial, legal or other criteria Globalstar unilaterally establishes.

ARRL, the national association for Amateur Radio, took no stance on specific case, but filed comments opposing the precedent it believed would flow from granting Globalstar’s petition: that, in a multiple-use radio frequency environment, a Part 15 device would not have to protect a licensed device.

The Association of Home Appliance Manufacturers filed comments likewise asking the FCC to clarify that Globalstar has no superior rights over existing users of the band and is obligated – like any other user of the 2.4 GHz band – to accept interference from the ISM devices that operate there.

Reply Comment Summary

On reply, the Wi-Fi Alliance argued that the proposed system could actually increase, not decrease, congestion in the 2.4 GHz band; that the limited information presented is insufficient to assess Globalstar’s claims; and that it had concerns regarding the potential bias of the testing conducted by Globalstar’s business partner. Wi-Fi Alliance also argued that any benefits attained by Globalstar’s TLPS would inure to the sole benefit of Globalstar and to the detriment of public Wi-Fi installations.

WISPAagreed, and further argued that Globalstar has failed to acknowledge “the Commission’s obligation to consider the interference impact on millions of unlicensed devices already providing vital services to the public.”

Bluetooth SIG also filed reply comments supporting the opposition, supporting AICC’s observation that that the testing conducted by Globalstar and its business partners is not sufficient given the “obvious room for biased results,” and that the testing process should therefore be opened up for participation by affected stakeholders, including Bluetooth and Wi-Fi manufacturers, WISPs, alarm industry representatives, and consumer groups.

In response to comments, Globalstar argued that other parties failed to raise any issue that should delay action in this proceeding. Regarding the detrimental effect on Wi-Fi and Bluetooth below 2483.5 MHz, Globalstar argues that no analysis or justification is provided for why TLPS should be treated differently from any other Part 15-compliant operation in this band. According to Globalstar, as long as TLPS complies with Part 15, the impact of this new service at 2473-2483.5 MHz should be no different than the impact of other unlicensed operations below 2483.5 MHz.

Globalstar also criticized requests for additional test data, again asserting that its TLPS operations will comply with Part 15, rendering any further technical showing or testing unnecessary. Globalstar clarified that consumer devices’ TLPS capability will not prevent those client devices from operating on other 802.11 channels or fully utilizing the 2.4 GHz ISM band for any current or future Part 15-compliant services. Rather, TLPS consumer devices will be able to engage in traditional Wi-Fi communications with non-Globalstar access points across the band.

Bottom line for AICC: As was the case with the Progeny issue, we expect several ex parte presentations lobbying the FCC pro and con on this matter. AICC and affected alarm manufacturers should carefully monitor the docket, and comment if inaccurate or unproven claims are being made; and if a joint effort forms to force more testing or other protections, AICC should consider joining.

FCC 600 MHz Incentive Auction Rules Create Opportunity For Additional Unlicensed Spectrum That Can Be Used By Alarm Devices

The FCC on May 15 adopted rules to implement the 600 MHz Broadcast Television Incentive Auction. This will set the table for an auction that will provide a significant amount of spectrum for cellular and other wireless carriers to use in augmenting their coverage and ability to provide wireless broadband services, which are no doubt being used more and more by alarm companies. However, the 600 MHz rules offer another potential benefit for the alarm industry: A portion of the 600 MHz Spectrum will not be sold at auction, but instead will be made available for low power, unlicensed use nationwide. This allocation can augment the spectrum available to alarm equipment manufacturers for unlicensed door and window contacts, PERS, remote cameras, etc. And the 600 MHz spectrum will allow better propagation than current unlicensed spectrum in, e.g., the 900 MHz and 2400 MHz bands, allowing alarm companies to cover greater distances with their unlicensed devices (which should translate into cost savings).

The full text of the Incentive Auction Report and Order (FCC 14-50) was released June 2, explaining the process by which television spectrum will be “repacked” so that some can be sold at auction, some can be used for unlicensed operations, and the remainder used by broadcasters in a more efficient way than currently done. The 600 MHz Band Plan incorporates “guard bands”, including the duplex gap (i.e., a portion of spectrum separating transmit from receive channels), to prevent harmful interference between licensed services. Depending on the amount of spectrum repurposed through the incentive auction, a total of 14 to 28 megahertz of guard band spectrum will be available for unlicensed use. The FCC will make an additional six megahertz of spectrum available by allowing unlicensed use of TV channel 37 at locations where it is not in use by incumbent broadcasters, subject to the development of the appropriate technical parameters to protect the incumbent Wireless Medical Telemetry Service (“WMTS”) and Radio Astronomy Service (“RAS”) from harmful interference. Channel 37 appears to be for use by unlicensed devices configured to consult a database of Radio Astronomy stations prior to operation, not the traditional WiFi devices.

Following the incentive auction and the post-auction transition, TV White Space devices may continue to operate on channels allocated and assigned for primary television services, consistent with current FCC rules. White Space devices differ from unlicensed band devices in that they operate within the licensed TV Band, but only in areas and on channels where the licensed spectrum is not being used by a licensed broadcaster. In contrast, unlicensed band devices typically operate at low power and use shared spectrum that has been set aside for unlicensed use. The FCC is planning to initiate a rulemaking proceeding after the release of its Incentive Auction Report and Order to consider changes to its existing Part 15 rules to facilitate unlicensed use of the television bands, 600 MHz Band guard bands and channel 37. AICC and its alarm equipment manufacturer members should monitor this proceeding carefully, and participate so as to help ensure that the maximum amount of 600 MHz spectrum will be available in a fashion that will maximize its usefulness for unlicensed alarm devices.

Of note, the two Republican Commissioners (Pai and O’Rielly) dissented to the 600 MHz Order, and expressed concern about making unlicensed spectrum available, focusing on potential interference and reduction of auction revenues.

FirstNet Update

FirstNet Seeks Replacement as General Manager Resigns

Bill D’Agostino, the general manager of First Responder Network Authority (FirstNet), has stepped down from the position for “personal and family reasons,” according to a press release by the FirstNet board. Mr. D’Agostino’s resignation came just shy of his one-year anniversary in his capacity as general manager. Deputy General Manager T.J. Kennedy took over as the interim GM. Certain trade press sources point out that Mr. D’Agostino’s resignation comes as FirstNet is addressing concerns about potential conflicts of interest (as the board includes representatives of private sector carriers and equipment vendors as well as public safety personnel); and some predict that his departure will make a swift deployment of the national public safety broadband network more difficult.

On the heels of D’Agostino’s departure, Sam Ginn is stepping down as Chairman (and leaving altogether in August), and will be replaced by Vice-Chairwoman Sue Swenson (who is already on the board). Swenson has had a long history in the telecommunications industry,Cellular One, Leap Wireless and T-Mobile USA.

The flood of new faces in high places at FirstNet will make it important for AICC to stay in front of FirstNet, in order to stay on the radar screen. FirstNet is planning multiple public notice and comment processes that focus on key foundational issues.

FirstNet Starts to Materialize as Adams County, CO LaunchesInitial FirstNet-blessed LTE Network

On June 6, Adams County, Colorado launched its public-safety LTE network—the first system deployed with the blessing of FirstNet. AdamsCounty’s LTE system gives FirstNet a welcomed victory in its effort to get the nationwide public safety broadband network off the ground. At one point, the AdamsCounty project appeared to be dead, but the county was able to push through negotiations with FirstNet and launch its system. This may have blazed the trail that will enable other state and local governments to establish LTE coverage under the FirstNet umbrella. For the alarm industry, this is a positive indication that FirstNet is moving toward becoming a reality – and that the alarm industry should proceed apace with efforts to establish a mutually beneficial relationship with FirstNet before any concrete has dried.

FCC Proposes to Allocate 150 MHz of Spectrum to “Citizens Broadband Radio Service”

The FCC has issued its proposal to provide more spectrum for general consumer use, carrier-grade small cell deployments, fixed wireless broadband services, and other innovative uses, through the creation of a new Citizens Broadband Radio Service. The Commission is proposing rules for the Citizens Broadband Radio Service in a Further Notice of Proposed Rulemaking (FNPRM) (FCC 14-49) that advances the Commission’s efforts to meet the growing demand for spectrum by proposing to make 150 megahertz available in the 3.5 GHz Band. Comments are due July 14 and reply comments are due August 1.

The FNPRM proposes innovative spectrum sharing techniques to unlock the value of the spectrum between 3550 MHz and 3650 MHz, and seeks comment on extending the proposed service to the 3700 MHz band. Specifically, the FNPRM proposes a three-tiered access and sharing model comprised of federal and non-federal incumbents, priority access licensees, and general authorized access users. Together, the proposals seek to promote flexibility and innovation by leveraging advancements in technology to facilitate sharing between different users and uses, including incumbent government uses.

Federal and non-federal incumbents would be protected from harmful interference from Citizens Broadband Radio Service users. Targeted priority access licenses would be made available for a variety of uses,including mobile broadband. General authorized access use would be permitted in a reserved amount of spectrum and on an opportunistic basis for a variety of consumer or business-oriented purposes, including advanced home wireless networking. Access and operation within the 3.5 GHz band would be managed by a spectrum access system, a dynamic database or databases that incorporates technical and functional requirements necessary to manage access and operations across the three tiers. In addition, the FNPRM seeks comment on technical, auction, and allocation rules.

This is of obvious interest to alarm service providers and device manufacturers, who should promptly determine how they may best take advantage of the proposed technology and determine if any tweaks to the FCC proposal are advisable.

FCC Increases Spectrum for Wi-Fi and Other Unlicensed Uses in 5 GHz Band

The FCC has adopted a Report and Order (FCC 14-30) that makes an additional 100 megahertz of spectrum in the 5 GHz band more accessible for unlicensed use. This action by the FCC increases the total amount of spectrum currently available for use by unlicensed devices and networks by 15 percent, and paves the way for accelerated growth and expansion of new Wi-Fi technology that the FCC says will enable speeds of one gigabit per second or more. Since more and more alarm systems are incorporating Wi-Fi technology, the expansion of available spectrum for such operations could be a valuable development, although it will require device manufacturers to design equipment that will comply with the new rules for this spectrum. Unfortunately, the 5 GHz band does not have very good propagation, limiting its range.

The new rules are applicable to Unlicensed National Information Infrastructure (U-NII) devices in the 5 GHz band and remove a current restriction on indoor-only use and increase the permissible power for devices using the 5.15-5.25 GHz portion of the band. This will allow U-NII devices to better integrate with other unlicensed portions of the 5 GHz band to offer faster speeds and reduce congestion at crowded Wi-Fi hot spots such as airports and convention centers, the FCC said.

The FCC’s ruling could be just the first step in a broader opening-up of the unlicensed band. A pending NPRM (FCC 13-22) contemplates making available an additional 195 megahertz of spectrum in the 5.35-5.47 GHz and 5.85-5.925 GHz bands for U-NII use.

Local Governments Can Require Building Owners to Ensure Effective In-Building Public Safety Communications

Over the past several years, numerous local governments have adopted ordinances that require owners of new buildings and buildings undergoing a renovation or expansion to ensure that police, fire and EMS personnel will be able to maintain effective communications using the 800 MHz band for public safety communications system inside a building. This requirement is significant, since it can add delay and cost to the building project even if the building complies with the local building codes and/or regulatory requirements.