On August 1, 2025, NextNav filed a Tolling Coexistence Study with the Federal Communications Commission, finding that 5G-based positioning, navigation, and timing (PNT) in the Lower 900 MHz band would impose minimal costs related to licensed tolling operations, limited to potential retuning of a subset of tolling operators’ toll readers. Furthermore, the study confirmed that optimizing the band would not require retuning or replacement of consumer toll transponders. To the extent any retuning is needed, NextNav echoed its prior commitment to providing reasonable accommodations, including financial and technical support, that contribute to a smooth transition to an optimized Lower 900 MHz band plan. The full filing is available here.
Key highlights from the filing include:
- “The Tolling Coexistence Study provides additional data and analysis supporting coexistence, in contrast to recent filings by the E-ZPass Group (“E-ZPass”) and the International Bridge, Tunnel & Turnpike Association (“IBTTA”), which have repeatedly advanced inaccurate or misleading technical and economic “sticker shock” claims without providing technical evidence or analysis to support their sky-is-falling assertions.”
- “NextNav’s proposal would fully accommodate existing tolling technologies’ operations within an optimized Lower 900 MHz band. The key technical question, therefore, is whether 5G signals might impact licensed tolling systems operating on adjacent LMS frequencies. To address this question, NextNav conducted comprehensive testing of all three major tolling technologies using standards-compliant 5G New Radio (“NR”) signals and conservative engineering assumptions. NextNav then took the measurement data from the tests and applied standard radiofrequency prediction and simulation tools to determine the effect of 5G NR signals on tolling operations.”
- The results were definitive. No impact from 5G downlink operations was observed, even under conservative tolling and 5G operational assumptions. In a simulation of 133 actual tolling sites in Northern Virginia, Fort Worth, TX, and Los Angeles, CA, not one location was shown to exceed the measured impact thresholds. Uplink interference was also negligible: using the worst performing reader/transponder measurement, the probabilities of potential impact from 5G were predicted to be just 0.0002% for the toll reader and 0.002% for the toll transponder, respectively. This performance far exceeds tolling operators’ stated performance requirements. Even under worst-case assumptions, the likelihood of interference for readers is more than 250 times lower than the toll operators’ own performance standard of five missed reads in 10,000 transactions, and for transponders, the predicted effect is still more than 25 times lower than toll operators’ specified standard.
- “The Tolling Coexistence Study reflects NextNav’s continued commitment to transparency and rigorous, fact-based engineering analysis in order to advance the Commission’s work to enable a solution to a critical national security issue: the need for a terrestrial backup and complement to GPS.”
- “As NextNav has now stated on the record three times in the past month in conjunction with filing robust, fact-based technical and economic data, the time for delay and obstruction has come to an end, and the path forward is clear: the Commission should promptly issue a Notice of Proposed Rulemaking to enable 5G-based 3D PNT in the Lower 900 MHz band.”