Commentary on Gerst

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Commentary on Gerst

My commentary is in bold italics and brackets - everything else is quoted or paraphrased but factual from the record in FCC 13-213 (TLPS NPRM)

"Gerst Capital Ex Parte Presentation Posted in 13-213 on 4/15/15 -
Four Technical Facts Regarding TLPS Proposal
1) TLPS Will Increase Co-Channel Interference with Bluetooth"

[Disproved by GSAT during demo; unlicensed use vs. unlicensed use - FCC rules say these users must live together and if congestion occurs, then deal with it]

"2) Wi-Fi has an outlet for 2.4GHz congestion (5GHz), Bluetooth Does Not"

[All unlicensed operators must deal with the possibility of congestion requiring them to plan ahead, FCC will be opening up further unlicensed bands for this purpose]

"3) TLPS Will Increase Adjacent-Channel Interference for Wi-Fi Channel 11"

[Disproved by GSAT during demo, and by OET report]

"4) Devices with Coexistence Filters will Impair TLPS"

[FCC doesn’t care about whether any given existing filter will “impair” TLPS. Even if that was true, it is a business issue for GSAT, not a regulatory issue for the government.]

"On April 30, 2015, L. Barbee Ponder IV, General Counsel & Vice President, Regulatory Affairs, for Globalstar, Inc. (“Globalstar”); Dennis Roberson and Ken Zdunek of Roberson and Associates, LLC; John Dooley of Jarvinian; and Steve Berman of Lawler, Metzger, Keeney & Logan, LLC, and I met with Mindel De La Torre, Troy Tanner, Jose Albuquerque, Jennifer Gilsenan, Karl Kensinger, Robert Nelson, and Lynne Montgomery from the International Bureau and Julius Knapp, Ronald Repasi, Bruce Romano, Karen Rackley, Patrick Forster, and Rashmi Doshi (via teleconference) from the Office of Engineering and Technology."

[Knowing now that the 115 page report was issued one week after this meeting, the draft OET report was likely discussed with Roberson, Zdunek and Dooley at this meeting, in order to brief them on the results and get any remaining issues or questions resolved. I expect that the FCC instigated this meeting for that purpose; that is, the meeting was not instigated by GSAT.]

The sample devices provided for these tests were manufactured by Ruckus Wireless and contained modular transmitters approved under Sections 15.247 and 15.407 of the Commission’s rules. The objective of this testing was to characterize the transmission profile of the devices; there was no intent or effort to perform comprehensive compliance testing."

“Minimal OOBS Detected” in all tests.

[IMO, with regard to the sample devices used, the FCC was simply establishing that implementation of TLPS is practical, and existing technology is available to comply with the anticipated limitations of the TLPS rules. One thing is certain, technology will change, and improve. Therefore, if the starting point looks very promising, in terms of meeting the anticipated rules, then it is reasonable to assume that interference mitigation features, as well as other technical capabilities, will only improve in future generations of technology.

With regard to “comprehensive compliance testing," that comes into play later after the rules are released. Once the rules are established and set out the allowable out of band emission levels, only then is “comprehensive compliance testing” going to possibly occur. This is done to certify TLPS equipment. Certain equipment may be certified through “permissive change” procedures (which are much quicker and streamlined, and would not require comprehensive testing), while other equipment (such newly developed Access Point devices) will have to go through the conventional certification process which involves comprehensive compliance testing.]

"Gerst Capital Ex Parte Presentation Posted in 13-213 on 5/14/15"

[I believe Gerst hastily prepared and filed this to try to address the damage done to the shorts by the OET report released one week earlier]

"The attached presentation includes an analysis that shows:
(i) A high selectivity bandpass filter included in the commercial product (FCC ID: S9G-MPE2N33A) was removed from hardware used in the TLPS demonstrations. This bandpass filter is commonly referred to as a 'coexistence filter'."

[If he is incorrect about his allegation that GSAT surreptitiously removed filters, then he loses what little chance he had at being taken seriously by FCC staff.  And, the FCC most likely still has possession of the samples as part of the record, so they can simply open them and check, assuming they don’t already know the answer to that question.  If he is correct that a filter was "removed," then in my mind, there is no way that Regina Keeney and Dennis Roberson wouldn’t have known about it and, therefore the FCC knew about it and approved of whatever filtering was or was not used. Keeney and Roberson would not risk their reputations before the FCC, even if their client was of a mind to do so (and I don't think for a second that Monroe, Ponder and Dooley would be underhanded in any way). One possibility -- was the existing filter of that Ruckus product replaced with an improved filter for purposes of the demo? The OET report simply stated that the sample Ruckus AP’s contained “modular transmitters” that were approved under Part 15. When I read that, it sounded a bit specific - why not state that the “devices” manufactured under the cited Ruckus part nos. were approved? It could be that OET only mentioned the transmitters b/c the filters in the sample devices were newer, improved filters planned for use in the new TLPS equipment. That is just my own conjecture; I do not know whether “modular transmitter” is a term of art in the industry that implies the inclusion of one or more filters.]

"(ii) Removal of this filter directly contradicts statements made by Globalstar that, among other things,they will incorporate 'high selectivity passband filters into the TLPS access points” that will “limit the risk of harmful interference to BRS-1'"

[This makes no sense. See above in item (i) relative to the possibility that improved filters were included in the sample Ruckus AP devices. Moreover, the OET Report shows minimal OOBS. Most importantly as pertains to the FCC demo, the purpose of that demo was to rebut the “concerns” of the unlicensed operators, such as Wi-Fi Alliance and Bluetooth SIG, not to address issues to BRS-1. They can defend themselves, as they see fit. I believe the FCC has already dealt with that issue and moved past it. The fact that the TLPS power levels will be dwarfed by BRS is probably determinative.]

"(iii) Globalstar has yet to demonstrate an access point that is proven to simultaneously support TLPS operation AND provide the level of filtering necessary to protect services starting at 2496MHz."

[Again, comparison of power levels will be determinative. OOBS of the sample devices was minimal. Couple that with very low power levels, and the current availability of filtering and there is little to no realistic concern. This is why Sprint has been so quiet.]

"(iv) Coexistence filters used in access points employ the same technology and have similar (if not identical) specifications to those used in LTE-enabled client devices. The fact that Globalstar found it necessary to remove coexistence filters in TLPS access points calls into question their repeated claims that a 'Broad and Immediate Ecosystem' of '802.11 compliant hardware is already capable of utilizing 802.11 Channel 14 with a device firmware modification'."

[Globalstar has never stated that “all” 802.11 compliant hardware is capable of using Channel 14 with a firmware modification. By the end of this year, predictions are that the market for 802.11 devices will be 2 billion or more in the world. But, even if only a third or half of those devices are capable of using Channel 14 with a firmware upgrade, that still represents an immediate and very valuable ecosystem of products that can be “turned on” to TLPS. We do know that Jay Monroe stated recently that one potential partner simply provided a code in order to turn one of its devices “on” to be able to operate in Channel 14. Again, Gersts statements are distortions that are easily picked apart.

Final Observations:
Note that in his presentation of one month ago, he offered four “facts” against TLPS. Then, one month later, his presentation focussed solely on his fourth “fact," that is, his filter issue. But, probably knowing that the FCC doesn’t care about his filter issue (for the reasons I stated above), he had to somehow tie it into something that the FCC might care about - interference with a co-primary licensee starting at 2496 MHz. In the end, I agree with Sat-Fi, that this latest Gerst presentation was almost incoherent. Moreover, being that he is an unknown at the FCC, the staff will want to know exactly who they are dealing with before they rely on any of his arguments or positions in formulating the Report and Order. If you are going to attempt to present yourself as a serious participant in a federal proceeding, such as a rule making procedure at the FCC, you’d better make sure that your public statements on the issues have the same level of seriousness. It wouldn’t surprise me at all if many of Gerst’s other public statements and comments, such as his snarky responses to Sat-Fi on Twitter, have already gotten back to the FCC staff. If I’m correct, this obviously works against his ability to persuade regulators over to his position, even if one could determine what his position is at this point.]
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Re: Commentary on Gerst

Do you mind if I post this on the Daily Blog page?
iptechpat iptechpat
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Re: Commentary on Gerst

no, I don't mind.