Could Missing Filters and a Potential Conflict of Interest at the FCC Mean A Bad Deal for Wi-Fi? Another TLPS Blog

Wowsers. If you’re in the WLAN world in any capacity, you’ve likely at least heard  of TLPS. Short for terrestrial low power service, TLPS is a crazily over-hyped twinkle in satellite communications company Globalstar’s eye. The satcomm company is lobbying hard for the FCC to approve it’s very  weird offering, while a range of groups and individuals who actually understand and work with real-world WLAN technologies that would be negatively impacted by TLPS try to bring sound technical counter-arguments to the FCC’s attention. If you need some refresher material, here are past articles I’ve written on TLPS:

Then there’s skepticism by Devin Akin, Kerrisdale Capitol, and Kerrisdale again, and lots of others including the Wi-Fi Alliance the Bluetooth SIG, Microsoft, and Google.

Here’s where anyone pro-TLPS says “So what? Globalstar has it’s own army of supporters.” The problem is, many of them are stark-raving nuts, with little technical acumen, high hopes for getting rich off of TLPS, and a penchant for conspiracy theories about why the FCC hasn’t approved this steaming bundle of joy yet.

Whatever.

Then there’s Greg Gerst. He too would like to make a lot of money off of TLPS, by having it NOT be approved. Gerst is a CFA at Gerst Capitol who has taken a most public short position on Globalstar, but he also happens to be an experienced Cornell-educated BSEE with a decent technical resume in digital communications technology. I don’t know Gerst. I can’t tell you whether he’s a good human being or not, but I do know he has posted impressive ex parte filings stating his case in engineering terms that validate and expand what many of us fear about TLPS.

Gerst is calling out some pretty specific and really disturbing things. If he’s wrong, time will prove him to be a laughingstock. If he’s right, however, then absolute shady dealings are afoot in the offices of the FCC when it comes to The Demonstration (mentioned above in the Network Computing article). And to boot, a potential conflict of interest by one FCC committee member adds an odd shadow to what’s already pretty weird ground.

Globalstar conducted a limited demonstration of their TLPS technology at the FCC’s offices using Ruckus Wireless access points. (To date, I’ve read nowhere that TLPS has been demonstrated with any other brand of AP.) There is a lot of opinion about the validity and results of the rather brief demonstration, but Gerst throws a zinger here, where he claims in his 5/14/15 filing that Globalstar used MODIFIED Ruckus access points while leading the FCC to believe that the test gear was commercially available off the shelf. A screen grab from the filing (it’s an interesting read regardless of how you feel about TLPS):

gerst 1

Gerst reiterates his opinion about the missing filters equaling deceptive testing in a 7/16/15 filing that also calls into question the judgement of one of the FCC’s Technical Advisory Council Members (the chairman, I think) when it comes to TLPS, as he also happens to be a paid consultant working for Globalstar. From the filing:

Regarding the final quote above, it is ironic that Globalstar’s paid lobbyist, Blair Levin, refers to “sound engineering” when a straightforward engineering analysis clearly raises doubts that TLPS will be “compatible with existing services”. More ironic is Dennis Roberson’s involvement as Globalstar’s paid consultant in this proceeding while chairing the Commission’s Technical Advisory Council (TAC)12. In April, the TAC produced an excellent paper entitled “A Quick Introduction to Risk-Informed Interference Assessment” 13. According to the executive summary, “This short paper proposes the use of quantitative risk analysis to assess the harm that may be caused by changes in radio service rules.” In his capacity as a paid consultant to Globalstar Mr. Roberson would have the Commission rely on the fact that TLPS had no “qualitative impact” 14 on Bluetooth, while ignoring the quantitative negative impact proven by the Bluetooth SIG report1.

That feels weird from where I sit, but then again Washington is a place where millionaires claim to be po’ folk and no one bats an eye, a certain Chief Exec never had sex with the woman he had sex with, and pretty much anything goes as long as it’s done “for the children”. I won’t even pretend to know what’s OK with lobbying rules, but Gerst’s point about Mr. Roberson would equal a conflict of interest in my own world, if Mr. Roberson’s committee has any sway in whether TLPS gets accepted (provided Gerst is representing the relationship between Globalstar and Roberson properly).

Like everything regarding TLPS, it will be interesting to see where this all goes.

6 thoughts on “Could Missing Filters and a Potential Conflict of Interest at the FCC Mean A Bad Deal for Wi-Fi? Another TLPS Blog

  1. dane1234

    You realize, I trust, that Part 74 TV Broadcast Auxiliary Service (BAS) is a LICENSED service at 2.4 GHz that trumps Part 15 anything, and that Globalstar’s S-band spectrum is encumbered spectrum terrestrially because of grandfathered TV BAS Channel A10 (2,483.5-2,500 MHz) stations. These TV BAS Channel A10 stations are co-primary, not secondary, with the Mobile Satellite Service (MSS), and there is no sunset date on the grandfather rights. There are grandfathered A10 TV BAS stations in most of the large metros: Boston, Chicago, Denver, Detroit, Los Angeles, Miami, NYC, Phoenix, Salt Lake City, San Diego, San Francisco and Washington DC, to name a few. Between co-primary services, the newcomer is obligated to protect the incumbents. So an ancillary terrestrial component (ATC) MSS use would NOT be Globalstar’s exclusive spectrum.

    Reply
  2. wirednot Post author

    Thanks for reading, Dane, and for the comment. It’s been quite awhile since I’d heard the TV licenced freq thing mentioned. I’m assuming if TLPS is approved, the FCC would address that in the approval. With unicorns frolicking in the background.

    Reply
  3. gcatewifi

    Lee, I think Washington needs a full time, impartial investigation team to look into all government corruption. But I digress. Your blogs, many other tech blogs and now this allegation of “deceptive testing” strongly says Globalstar/TLPS/Ch 14 is a horrible, terrible idea! And that is why the FCC will probably approve it! Let’s just hope and pray someone in our nation’s capital listens to engineers with tech-savvy and go the direction where all will benefit and not weigh it toward one company.

    Reply
    1. wirednot Post author

      Thanks for the comment Glenn. I have a feeling you won’t see any hardware beyond Ruckus’ for testing, which in itself should raise flags.

      Reply
  4. Pingback: Did TLPS Just Publicly Become a Ruckus-Only Show? | wirednot

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