The Federal Communications Commission (FCC) is currently soliciting comments on a petition from NextNav, a for-profit company, to change longstanding spectrum allocations in the 900 MHz ISM band used by RAIN RFID. If approved, NextNav’s proposal would have significant, negative ramifications for those already using the radio band, effectively prioritizing NextNav’s commercial aspirations over those who already deliver widely adopted and valuable services to the general public, including our RAIN community.
As RFID Journal already reported, NextNav’s request, if adopted, will severely inhibit the use of RAIN in the United States and dramatically impact existing users across the U.S. economy.
Retail, Logistics, Healthcare and Government Deployments At Risk
Many industries rely on RAIN: Shipping and logistics for tracking packages and pallets; healthcare for tracking medicines and medical supplies; airlines and airports for identifying and tracking passenger baggage; and retailers for inventory and self-checkout. Many U.S. government agencies also rely on RAIN: For REAL IDs, highway tolling systems, asset tracking and more.
A few of the enterprises that rely on RAIN today include Audi, Boeing, BMW, Coca-Cola, Delta Air Lines, Ford, GM, Honda, Lululemon, Mayo Clinic, Memorial Sloan Kettering Cancer Center, Nordstrom, NASA, Nike, Target, UPS, U.S. Customs and Border Patrol, U.S. Department of Defense, Walmart and Zara.
The RAIN industry has shipped more than 200 billion tag chips to date. And our industry continues growing, historically at a nearly 30 percent compounded rate. The RAIN Alliance, in collaboration with VDC Research, projects continued growth, with tag chip shipments to soar to 115 billion units annually by 2028.
The FCC Approved RAIN Usage in the 900 MHz Band in 2005
In May 2005, at the request of EPCglobal and its end-user community, the FCC’s Office of Engineering Technology issued public guidance specifically allowing RFID operation in the 902–928 MHz band under FCC Part 15. Our RAIN industry has relied on that approval.
NextNav is now asking the FCC to reconfigure the 900 MHz band and give preference to their solution, removing safe-harbor protection for existing users, including our industry. If granted, their petition will increase the power, bandwidth and priority of NextNav’s radio transmissions, which will interfere with RAIN systems and potentially allow NextNav to shut down RAIN deployments.
In 2013, the FCC decided against adopting a related NextNav petition (then through its wholly owned subsidiary, Progeny LMS, LLC) requesting a new band plan, citing concerns about significant interference with the multi-millions of existing devices already using the band. The FCC emphasized the need to protect these devices from harmful interference, maintaining a balance between new services and protecting existing users.
A decade later, the number of devices is now measured in the hundreds of billions, and the importance of protecting those users is hugely heightened.
As an industry, we’ve invested billions of dollars over two decades to deliver inventory and tracking solutions for enterprise end users. Now the FCC, with our urging, must ask: Is the disruption to deeply established incumbents driving significant public benefit across the United States a price they are willing to impose, especially when there are practical alternatives to NextNav’s solution?
RAIN Industry Must Affirm the Importance of the 900 MHz Band to FCC
RAIN helps organizations track items across the supply chain and in stores. It is used in hospital emergency room medical kits for life-saving treatment. It ensures medications are properly stored, tracked and authenticated. It helps grocers eliminate food waste and sell perishable goods before they expire. And it is poised to help ensure we can build a circular economy for reusable goods.
FCC approval of the NextNav petition darkens that horizon, effectively stopping critical economic, health, safety and environmental progress at a time when that progress couldn’t be more essential.
I ask my colleagues, peers and counterparts in the RAIN industry to submit comments affirming the importance of RAIN to your business:
- Reach out to your state’s US senators and federal representatives.
- Submit comments directly to the FCC by September 5, 2024.
- Join the RAIN Alliance’s coordinated effort to prevent this change by contacting the RAIN Alliance president, [email protected]
Impinj is working closely with the RAIN Alliance to develop an industry-level response to the NextNav petition. Given the broad use of the band by RAIN and other technologies, we hope the FCC will swiftly deny NextNav’s petition. Regardless, Impinj will do our part to keep the ISM band available for RAIN usage so our industry can continue its journey to connect every item in our everyday world.
