By Paul Kirby | August 4, 2025
NextNav, Inc., said in a filing posted today that a tolling study it has submitted to the FCC demonstrates that licensed tolling operations would be able to coexist with 5G operations in the lower 900 megahertz band.
“This study’s technical findings further validate the economic conclusions of the Brattle Second Supplemental Report, establishing that NextNav’s proposal to enable 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,” NextNav said in an ex parte filing posted today in WT dockets 25-110 and 24-240. “Optimization of the band would not require retuning or replacement of consumer toll transponders. To the extent that retuning of some toll readers is required, NextNav has committed to reasonable accommodations, including financial and technical support, that contribute to a smooth transition to an optimized Lower 900 MHz band plan.”
The tolling coexistence study was attached to the ex parte filing.
“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,” according to NextNav.
“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,” it added. “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.
“Further, actual tolling impact probability due to 5G uplink will be even less because the reported probability is based on the maximum 5G signal level in the lab test setup where no transponder impact was observed—the actual impact point will be higher, which will lead to a lower impact probability,” according to NextNav.
Tolling interests have argued that NextNav’s proposal would result in interference and reduce the total amount of spectrum available for their use. A study submitted by the industry argued that the direct and indirect costs of NextNav’s plan would be in the tens of billions of dollars with the benefits in the $1.2-$2.1-billion range. They also have complained that NextNav’s proposal would reduce the amount of spectrum for tolling from 14 megahertz to 11 MHz.
But in a recent report, the Brattle Group cited the $14.6 billion in “direct GPS benefits” that it projects could be far exceeded by indirect benefits, “potentially placing the total benefits in the many tens of billions of dollars” (TR Daily, July 18). It also said the cost of the proposal to unlicensed spectrum users “should be zero.”
In the ex parte filing today, NextNav said that it “has never proposed impairing or undermining the operations of any LMS licensee” and that its plan “would actually increase the total amount of contiguous LMS spectrum available for tolling operations and not shared with M-LMS [multilateration location monitoring service]: moving from 10 MHz to 11 MHz.” —Paul Kirby, [email protected]
Reposted With Permission of TR Daily.