On July 17, 2025, NextNav submitted a comprehensive supplemental economic analysis by The Brattle Group to the Federal Communications Commission, directly addressing a previously filed and fundamentally flawed report underwritten by E-ZPass, the International Bridge, Tunnel & Turnpike Association, and Neology.
 
The Brattle Group’s review of the submission found that the benefits of optimizing the Lower 900 MHz band to enable new high-value uses—including GPS backup and 5G services—clearly outweigh any costs. The Brattle Group specifically concluded that the cost to unlicensed devices should be approximately zero, and that retuning costs to licensed tolling users should be minimal, and include zero cost for toll transponders. The full filing is available here.
 
Along with the filing, NextNav released the following statement from Renee Gregory, Vice President of Regulatory Affairs:
 
This is the second comprehensive supplemental report we have filed this month, demonstrating our focus on ensuring that facts and rigorous technical and economic analyses guide this proceeding. Unfortunately, the same cannot be said of our opponents.
 
The economic filing underwritten by tolling interests should be set aside from any serious consideration due to extreme, worst-case assumptions not supported by technical evidence and inconsistent with NextNav’s proposal. Its cost estimates are fatally flawed, including erroneously presuming that both licensed and unlicensed users would need to either dramatically alter or discontinue their operations in the lower 900 MHz band. Those assertions are contrary to NexNav’s technical studies, which show that 5G operations will not cause unacceptable levels of interference to unlicensed devices, and to the reality that tolling operations can also continue to operate in the band with minimal disruption or cost. At NextNav, we’re serious about solving an urgent national security problem, and we will continue to do the hard work necessary to support the FCC’s sound, fact-based, engineering-driven decision-making process.