- The FCC comments period has closed and responses to those comments are being accepted until Sept. 20
- Companies using and selling RFID, Z-Wave, tolling 6-C systems, and LoRa are among those who have expessed objection to the petition by NextNav for domination of the lower 900 MHz band for its terrestrial navigation purposes
The Federal Communications Commission (FCC) closed its 30-day solicitation period regarding a petition from geolocation technology company NextNav with a total of 744 individuals and companies responses were posted, most in defense of protecting the lower 900 MHz band.
Many of the respondents indicated the change being requested would adversely affect the “Part 15” devices that already use the lower 900 MHz band NextNav is seeking access to, cutting off services that industries such as healthcare, defense, aerospace, retail and tolling rely on.
At issue is a NextNav petition filed in April to the FCC to expand the power level, bandwidth and priority of its licenses in the 902 to 907 and 918 to 928 MHz bands in the United States—a band currently in use by UHF RFID, Z-Wave, Zigbee, LoRa and numerous other wireless technologies. Additionally, NextNav proposes to use 5G connectivity over the relatively low bandwidth.
Expanding NextNav’s First-Responder Access
NextNav is appealing to the FCC for rule changes that would enable a terrestrial 3D PNT network for 5G and bidirectional transmissions in the lower 900 MHz band. The company claims the system could be used for location mapping and tracking services such as enhanced 911 (E911) communications, which enable first responders to view location information during emergencies.
The company’s petition recognizes that there currently are unlicensed Part 15 devices operating in the lower 900 MHz Band, but the FCC indicated that it was unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices.
With respect to Part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.” It is seeking the removal of the current requirement that those using the band not cause unacceptable levels of interference to Part 15 devices.
Responses Received From Industry Groups, Tech Companies
FCC asked for comment on the extent of Part 15 devices and amateur operations in the band and what potential impact band reconfiguration and flexible use rules would have on their communities.
Questions from the FCC included what services are being provided by Part 15 devices and amateur operations, can they be accommodated in other spectrum bands, and what are the costs for relocation as well as how long would it take? “We also seek comment on the status of any outreach with Part 15 device users and amateur licensees,” the FCC stated.
Responses to the petition were mostly in opposition and came from a wide variety of companies and enterprises, from multiple technology sectors. They are publicly posted on the FCC website.
For instance, GS1 indicated the reallocation of band would be detrimental to numerous technologies. According to Steven Keddie, Automatic Identification and Data Capture (AIDC) senior director, “GS1 is extremely concerned about NextNav’s petition,” that would increase transmit power to 3280 W/MHz EIRP for 918-928 MHz band and provide preferential treatment of NextNav devices. Keddie noted the petition’s omission of RF interference testing and analysis of impacts on the incumbents of the 902-928 MHz band.
A RAIN RFID coalition, that included Avery Dennison, Impinj, r-pac International and Zebra Technologies, recommended that the commission reject the petition. In the alternative, if the commission did not choose to fully reject the petition, the commission should require NextNav to adequately protect and accommodate existing Part 15 devices, including RAIN (UHF) RFID systems, the coalition requested.
Impacting LoRaWAN operations by 60 percent
The LoRa Alliance indicated it was “gravely concerned” about the impact of NextNav’s proposal on its installed base and future applications. The alliance provided a technical analysis demonstrating the direct and reverberating impacts of the NextNav proposal on LoRaWAN operations.
The analysis indicated that NextNav’s request would limit LoRaWAN operations to “60 percent of the available band, cause unacceptable levels of interference to many LoRaWAN systems and operations, and limit the amount of competition in the United States for Internet of Things (“IoT”) technologies.”
LoRaWAN company Netmore Group argued that the “implementation of NextNav’s plan threatens to disrupt critical infrastructure and essential services provided by our customers in vital sectors such as utilities, municipalities, and enterprises.” This proposal jeopardizes the stability and reliability of these crucial services which are integral to the well-being of communities and businesses across the nation, company officials wrote.
Effect on Healthcare
Cardinal Health reported that it utilizes RFID technology to ensure patient safety by enabling delivery of the right supplies to the right place at the right time. RFID tracking detects and prevents use of expired or recalled medical products, the company reported.
“We are concerned that granting NextNav’s petition would have major implications for global medical and pharmaceutical supply chains,” hospitals officials stated.
Cardinal Health is a distributor of pharmaceuticals, a global manufacturer and distributor of medical and laboratory products, and a provider of performance and data solutions for health care facilities. It serves about 90 percent of U.S. hospitals; more than 29,000 U.S. pharmacies; and interacts with approximately 3.4 million U.S. patients with more than 46,000 home healthcare products.
Tolling with Passive 6C-standard UHF
Washington State Department of Transportation (WSDOT) reported RFID as its strategic tool to help manage congestion, enhance mobility, fund public improvement projects, and generate revenue required for ongoing operation and maintenance costs of existing facilities. WSDOT is the owner and operator of five existing toll facilities, with four more deploying in the coming years.
“Last year, these toll facilities supported 63 million trips and collected $196 million in toll revenue,” the agency reported. “Integral to WSDOT’s electronic toll collection operations is the use of the RFID technologies that utilize FCC Part 90 license in the 902-928 MHz spectrum.”
To date, WSDOT has more than 1.9 million RFID transponders actively being used by its customers and has 79 RFID tolling points deployed. NextNav’s proposed high-power operations poses a risk of harmful interference to WSDOT’s licensed electronic tolling collection systems.
Disruptions at Golden Gate
Denis Mulligan, general manager of the Golden Gate Bridge Highway and Transportation District, indicated that its district has invested approximately $60 million in its roadside toll systems which use the ISO/IEC 18000-63 (known as 6C) communication protocol for tolling applications for the purpose of automatic vehicle identification (AVI).
Regionally, in conjunction with the Bay Area Toll Authority and other Bay Area toll agencies, its system works with the 5.5 million toll tags used by Bay Area Fast Trak and the many more issued by other California toll operators to process an average of 16 million transactions annually, representing about $146,000,000 in toll revenue.
Electronic tolling operations at the Golden Gate Bridge rely exclusively on the lower 900 MHz band to provide efficient vital transportation to the public in the Golden Gate corridor. NextNav’s proposed operations present significant risk of interference to toll collections systems, including the one that is a vital part of the District’s primary source of revenue, the state tolling agency said.
Impacting Consumer Devices
According to the Consumer Technology Association, the lower 900 MHz also serves as an innovation band that powers unlicensed devices.
Examples were on display at the Consumer Electronics Show (CES) 2024, they pointed out, where innovators debuted numerous devices operating in the lower 900 MHz band, such as those using the Z-Wave and Zigbee standards to automate homes. Recent innovations include the ability to connect devices over relatively long-distances with very low bandwidths, such as through Amazon Sidewalk.
“Far from ‘underutilized,’ [as NextNav had posited in its petition] the lower 900 MHz band is home to a huge variety of unlicensed devices and services, both new and old; it is an important complement to the higher throughput but shorter range of 2.4 GHz and higher unlicensed bands,” the association reported.
Security Concerns
Additionally, related to Z-Wave Technologies and security cameras, the Security Industry Association (SIA) commented that if Part 15 devices are unable to coexist with the proposed NextNav system, they will be forced to use less than half (11 out of 26 megahertz, or 42 percent) of the band that is currently available for shared use.
This would result in crowding of the shared use operations and degraded reliability and performance for Part 15 devices, the SIA determined, including Z-Wave alarm system devices, security camera systems, electronic access control devices, and other low power 900 MHz devices that that provide important services to consumers, as detailed.
FCC Next Step Sept. 20
Other companies that have weighed in opposition to the change include Assa Abloy, Boeing, Silicon Labs, the Wi-Sun Alliance, and the IEEE 802 LAN/MAN Standards Committee.
Technology company HID Global framed it as a question of financial and community or personal security, “HID is gravely concerned about the potentially widespread and serious impact on America’s national security and economic prosperity if the NextNav Petition is granted.”
Dominion Energy also suggested the proposal would cause harmful interference to critical utility operations that rely on the smart metering systems that connect utility meters and supervisory control and data acquisition (SCADA) systems.
After receiving the comments, the FCC begins accepting reply comments will be due September 20. The FCC will then consider the comments and replies, to determine the next step.