The NextNav petition for rule change filed in April 2024  resulted in major activities of the industry and the RAIN Alliance during Summer 2024.

In August 2024 the Federal Communications Commission (FCC) Office of Engineering and Technology (OET) issued a public notice with a call for inputs. The RAIN Alliance encouraged our members to file comments, and we prepared comprehensive documentation which was filed on behalf of our industry. Almost 2000 separate documents were filed by the deadline, with fewer than 10 supporting the NextNav proposal.

In the October 2024 timeframe, there were some discussions related to interoperability testing, and road tolling companies (represented by the International Bridge Tunnel and Turnpike Association, IBTTA) received a proposed test plan from NextNav. Various communications have taken place related to this. The RAIN Alliance also became part of a coalition headed by the US Chamber of Commerce, who has been very active against the NextNav petition.

Now we find ourselves already three months into 2025. A new US government is in place, and new leadership has been appointed at the FCC, and NextNav has recently announced the appointment of a new VP of Regulatory Affairs.

We have not been contacted directly by NextNav in relation to the technical analysis and commentary that we provided. We are also not aware of any of our members having been contacted directly by NextNav in this context.

There has continued to be documents filed with the FCC, both in support of and against the NextNav petition – the most interesting of which are:

  1. Filing by the Resilient Navigation and Timing Foundation providing several arguments why the NextNav petition is less than candid and inappropriate. “It is less than candid in its discussion of the maturity and capability of its technology and the potential for NextNav’s agreements with telecommunications providers who already have the capability to develop and implement PNT capability without their help.” “It is inappropriate as it demands large amounts of spectrum it openly admits are not required to develop and implement its technology.” Also this filing clearly states that leading T-PNT implementations do not need what NextNav requests. Their summary is: “In short, approving NextNav’s application will unjustifiably enrich its shareholders while doing nothing to make our nation safer.”
  2. NextNav itself has filed the “Brattle report” from 2024-11-13 which supports the NextNav petition and outlines an economic analysis of the benefits to the US economy. However, this economic analysis completely ignores the negative socio-economic impacts resulting from the massive-scale supply chain disruption in retail, healthcare, logistics, manufacturing, and many other industry sectors that we outlined in our commentary.
  3. The US Chamber of Commerce filed a document challenging The Brattle Group report, and lists the RAIN Alliance as one of the partner organizations.  This US Chamber document concludes that “The (Brattle) Report’s analysis is unconvincing on its own terms and omits key elements central to the Commission’s analysis. In addition to relying on unsupported outage probabilities, the Report does not account for the costs of implementing NextNav’s technology in GPS devices, the relative value of alternative terrestrial PNT systems, and – most importantly – the potential damage that NextNav’s proposal would inflict on incumbent users of the Lower 900 MHz band.”
  4. NextNav has most recently also filed an engineering study based on a specific scenario in the San Francisco downtown area related to impacts on five technologies, namely LoRaWAN, RAIN RFID, Wi-Fi HaLow, Wi-SUN, and Z-Wave. The RAIN Alliance Radio Regulation team is undertaking a thorough review of this document and will respond in due course.

The RAIN Alliance and US RAIN Alliance members continue to monitor the situation on behalf of our industry, and we are working in parallel to be prepared for the next steps once the FCC moves forward.

In a recent blog post, Chairman Carr indicates that the FCC plans to open an inquiry later in March which will explore alternatives to GPS. The NextNav proposed solution would potentially be one alternative, but there are others. We see this inquiry as a positive step as it should be possible to find an alternative to GPS that doesn’t cause such severe impacts to other technology deployments including RAIN systems.

In case of questions or if you’re aware of any new developments on this topic, please contact Joe Preishuber-Pflügl.