The LoRa Alliance formally filed its comments speaking out against NextNav’s Petition for Rulemaking, which is currently pending with the United States Federal Communications Commission (FCC). The simple fact is that if NextNav is successful and the FCC changes the rules in the 902-928 MHz band as NextNav proposes, it will pose significant risks to the rapidly growing Internet of Things (IoT) market in the U.S., which would harm communities and businesses across the country.
The unlicensed band is utilized for a wide range of services, including industrial, scientific, and medical equipment (ISM); location and monitoring service (LMS) systems; federal radiolocation; Part 15 unlicensed devices; and amateur radio operators.
This band requires that the services of licensed users must coexist with Part 15 unlicensed devices, with a lack of interference validated through field testing. This requirement allowed manufacturers to develop and bring to market innumerable unlicensed commercial and consumer products and devices for this band.
NextNav Stance
However, the NextNav petition proposes to eliminate that protection, endangering the viability of Part 15 devices and the confidence in stable FCC regulation in the 902-928 MHz band, which is absolutely necessary for investments. NextNav is seeking access to additional prime spectrum holdings in the 902-928 MHz band, which, if granted, would jeopardize the existing operation of billions of devices using the unlicensed spectrum.
While NextNav’s petition asserts that this band is underutilized, the reality is that it has a vibrant ecosystem of Part 15 users with billions of devices––the bulk of these supporting IoT applications––operating in the band. A decision by the FCC at this stage, after multiple ecosystems have built out their products and technologies in good faith, would be crippling for spectrum users in the U.S. Prolonging discussions on this ill-considered proposal only creates uncertainty and undermines confidence in FCC regulations, hindering future innovation in unlicensed bands. The LoRa Alliance strongly urges the FCC to close this docket and reject NextNav’s request.
Our full response to this situation can be found here. We are also a signatory on the U.S. Chamber of Commerce’s response, alongside many others.
What Is At Stake?
The LoRa Alliance, along with many other Part 15 technology groups, is concerned about the impact of NextNav’s proposal on their devices’ installed base and future applications. NextNav’s request would limit LoRaWAN operations to 60 percent of the available band. Coexistence mechanisms developed by the FCC for the billions of devices in 26 MHz would certainly be impossible in the remaining 11 MHz, meaning that all unlicensed services described above will be inoperable, break existing solutions, and weaken competition in the U.S. for IoT technologies.
It is important to note that LoRaWAN is far from the only technology impacted. Several other technologies are reporting similar concerns. To cite a few examples, the RAIN Alliance estimates that there are at least 80 billion items tagged with RAIN RFID in the U.S. Similarly, the Z-Wave Alliance estimates that there are more than 100 million non-spread spectrum Z-wave devices deployed, and E-ZPass estimates that nearly 60 million E-ZPass transponders are deployed, generating almost 5 billion transactions per year.
Diverse entities from Wi-Fi and Wi-SUN to amateur radio operators, the Department of Defense, emergency services, and many other spectrum users face disruption or loss of access, while NextNav still hasn’t demonstrated any clear economic or social benefit to the U.S. from its proposal.
Impact on Business
The potential impact on U.S. businesses and communities cannot be denied. The LoRaWAN standard is well-established as a critical IoT networking solution across the country. Tens of millions of sensors are deployed, and hundreds of millions are planned in the next few years in thousands of cities and throughout rural areas, supporting a wide array of use cases. LoRaWAN network flexibility means they can serve densely populated urban environments just as easily as lightly populated rural regions, supporting critical applications, commercial and not.
LoRaWAN networks are used to drive sustainability and enhance quality of life through thousands of uses across diverse markets like smart agriculture, smart industry, smart healthcare, smart logistics, smart cities, public safety, environmental monitoring, and many more.
