During July and early August, NextNav submitted three significant studies to the Federal Communications Commission (FCC) to ensure the record includes rigorous, fact-based analyses. Together, these filings demonstrate that delivering 5G-powered positioning, navigation, and timing (PNT) in the lower 900 MHz band can be achieved at minimal cost while offering significant national benefits and enabling both licensed and unlicensed users to continue to operate in the band.
 
NextNav has a proven track record of providing accurate, reliable location information to support first responders. Building on that legacy, NextNav’s 5G-powered 3D PNT solution will help meet the urgent national security and public safety need for a complement and backup to GPS.
 
One year ago, the FCC sought comment on our Petition for Rulemaking. Since that time, NextNav has consistently filed detailed studies and reports to support our proposal. We have methodically addressed technical and economic questions raised by the FCC in its Public Notice and Notice of Inquiry, Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions, and have responded with facts and deep analyses in response to our critics’ unsupported concerns, setting a firm foundation for the FCC to issue a Notice of Proposed Rulemaking (NPRM).
 
In parallel, NextNav has reached out to more than 100 stakeholders to share information about our proposal, answer questions, and learn more about others’ concerns. Our goal has and will continue to be to address an urgent national security need, while recognizing the other important uses of the band and doing the hard work required to carefully analyze the potential impact of our proposed 5G operations on those users.
 
The good news is that 5G operations will not cause unacceptable levels of interference to unlicensed Part 15 devices and that existing tolling licensees can coexist with 5G operations with only minimal retuning of some of their toll readers, and no impact on consumer toll transponders. Here is what we know:
 
Part 15 Operations Across the Entire 902–928 MHz Band
NextNav filed a supplemental technical report responding to numerous misconceptions about NextNav’s proposal and its impacts on unlicensed Part 15 devices operating in the lower 900 MHz band. We analyzed each of those claims and none could withstand scrutiny. The supplemental report also backed up an earlier technical analysis we filed in February.
 
While the NextNav Technical Study continues to stand on its own, this supplemental report further validates its assumptions and conclusions. First, this report includes a detailed discussion of the misunderstandings and mischaracterizations advanced by the critics of NextNav’s proposal, and where relevant, it provides additional data and analysis to support NextNav’s assumptions. And second, while the original assumptions in the NextNav Technical Study remain valid, this report also includes additional simulated hypothetical scenarios. This simulation demonstrates that, even if certain assumptions are modified, it does not change the bottom line regarding NextNav’s proposal—namely, that introducing 5G operations will not cause unacceptable levels of interference to unlicensed Part 15 devices in the lower 900 MHz band.
 
Coexistence with Licensed Tolling Operations
NextNav also filed a tolling coexistence study confirming that licensed tolling operations can coexist with 5G operations in the lower 900 MHz band. Our technical analysis showed that costs to ensure coexistence would be limited to the potential retuning of a subset of tolling operators’ toll readers. Optimization of the band would not require retuning or replacement of consumer toll transponders.
 
This analysis provided conclusive evidence that NextNav’s proposal would fully accommodate existing tolling technologies’ operations within an optimized lower 900 MHz band.

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.
 
Substantial National Benefits with Minimal Costs
Finally, we filed a supplemental economic analysis by the Brattle Group directly addressing a fundamentally flawed economic filing underwritten by tolling interests that erroneously presumed that both licensed and unlicensed users would need to either dramatically alter or discontinue their operations in the lower 900 MHz band.
 
The Brattle Group specifically concluded that the cost to unlicensed users should be approximately zero, and that retuning costs related to licensed tolling operations should be minimal. The report also highlighted NextNav’s commitment to reasonable accommodations for tolling licensees, including financial and technical support, that contribute to a smooth transition to an optimized band plan.
 
The Supplemental Report establishes that NextNav’s proposal to enable 5G-based positioning, navigation, and timing in the lower 900 MHz band would impose minimal costs on current users of the band while generating substantial national benefits, potentially amounting to tens of billions of dollars.
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The Supplemental Report demonstrates that [the tolling-sponsored filing’s] contrary conclusions rely on extreme, unsupported, and highly speculative assumptions, significant methodological weaknesses, and a disregard for standard industry practices.
 
The Time for Action is Now
At NextNav, we are serious about solving an urgent national security problem, and we will continue to do the hard work necessary to support the FCC’s fact-based, engineering-driven decision making. The FCC is the expert authority on commercial spectrum issues, and we believe it has all of the information it needs to take the next step in this process by issuing an NPRM that would enable 5G-powered PNT. Issuing an NPRM would also give the FCC the opportunity to ask any remaining technical or economic questions that it may deem necessary to complete its evaluation.
 
With swift action, the FCC has an opportunity to advance a near-term terrestrial complement and backup and GPS that can be available during this Administration, at no cost to taxpayers. The time for action is now.