Coalition to FCC: ‘Proceed With Caution on NextNav Petition’

The FCC in August released a public notice regarding NextNav’s petition for rulemaking to reorganize the 902-928 MHz band and establish a 5G PNT network. According to NexNav, its positioning and timing technologies—powered by low-band licensed spectrum—“deliver accurate, reliable, and resilient 3D PNT solutions for critical infrastructure, GPS resiliency and commercial use cases.” Comments were due Sept. 5; the reply comment deadline is Sept. 20.

According to the 70-member coalition, which represents a broad cross-section of industry, the Lower 900 MHz band is used for a “wide range of purposes, including industrial, scientific, and medical equipment, Location and Monitoring Service (‘LMS’) systems, federal radiolocation, Part 15 unlicensed devices and amateur radio operators.” A key requirement of this band, the members said, is that the services of licensed users must coexist with Part 15 unlicensed devices. They explained that “[t]his is done through field testing to demonstrate that there is no unacceptable interference to Part 15 devices, which led manufacturers to develop a broad range and large number of unlicensed commercial and consumer products and devices for this band.”

The NextNav Petition, the coalition members pointed out in their letter (download below), “proposes to eliminate that protection, endangering the viability of Part 15 devices.” Additionally, the petition “claims that the Band is underutilized thereby justifying Commission [FCC] action to reorganize” it, but the members noted that “[m]uch of the business community utilizes Part 15 devices to increase economic productivity and efficiency, bolster safety, deliver innovation, and provide other important benefits to consumers, customers, and the public.”

They highlighted the following use cases:

• “Municipal Infrastructure: Municipal systems, including traffic control, street lighting, weather monitors, and flood warning systems that are deployed in this band to make communities safer and more energy efficient, could be disrupted.
• “Critical Infrastructure: Utilities use the 900 MHz band to remotely monitor and manage their power, gas, and water distribution networks. Interference could pose a threat to these operations, which are legally required to maintain extremely high levels of reliability because of the impact of outages or other disruptions.
• “Railroad Operations and Safety: Automatic Equipment Identification (‘AEI’), critical for the rail industry, enables accurate and efficient tracking of railcars and equipment throughout the network relying on 900 MHz frequencies. In addition to the AEI network, the rail industry’s signals and communications group rely on unlicensed 900 MHz spectrum for connecting opposing ends of signal interlockings, remote drawbridge operation over waterways, traffic control, sensors, and other communications devices essential to maintaining operational safety and efficiency.
• “Highway Infrastructure and Tolling: The Petition threatens to disrupt electronic tolling systems, such as E-ZPass and other similar toll collection systems, which rely on licensed spectrum allotments in the Lower 900 MHz band for seamless operation. Interference could lead to widespread issues in tolling accuracy and efficiency – potentially affecting millions of daily commuters – as well as foreclose important new deployments, including systems that provide urban congestion relief.
• “Smart Home and Building Devices: By potentially interfering with the 900 MHz band, the Petition undermines the reliability of smart home and building devices, from thermostats to smart locks to security systems. This would cause significant inconvenience and safety risks for property-owners relying on these technologies.
• “Security Cameras and Systems: The 900 MHz band is vital for millions of security cameras, including popular models used in homes and small businesses. These devices are essential for protecting homes, preventing package theft and home intrusions, ensuring children’s safety, and aiding law enforcement by capturing criminal activity.
• “Retail, Manufacturing, and Supply Chain Operations: Disruption to building control systems, tank, and leak monitoring systems, inventory controls systems, fleet management and asset tracking tools, price scanners, and other systems deployed in major retailers, suppliers, manufacturers, and small businesses across the United States would cause serious harm to our economy.
• “Agriculture: Our nation’s smart agriculture sector’s innovative solutions for connecting the modern farm’s Internet of Things devices and equipment leverage the reliability of the 900 MHz band to keep our farms connected.”

Additionally, the coalition members noted, innovations and deployments in the 900 MHz band “are accelerating,” including by such new and growing technologies as drone operations.

“The changes proposed by NextNav potentially threaten to disrupt these established business and governmental operations, impede ongoing innovation in this band, and undermine reliable communications systems across several industries,” the members said. “The likely adverse impact and broad set of uses indicate that the Commission should proceed with caution on the NextNav Petition and ensure that Part 15 devices remain fully operational.”

The FCC, the coalition members concluded, should maintain the existing rules, “ensuring the continued operation of hundreds of millions of Part 15 devices relied upon by consumers and commercial users across many industries including transportation, agriculture, utility, state and local governments, and more.”