In a battle being played out with FCC filings, NextNav submitted the latest technical report to rebut what is sees as flawed assumptions put forth by those opposing the company’s 5G-based PNT proposal.
The NextNav submission is a defense of its earlier comprehensive technical analysis and finds that not only do the “technical merits of nextNav’s proposal withstand scrutiny,” but even after analyzing the various unlicensed claims, “Part 15 operations to continue across the entire 902–928 MHz band.”
The filing comes after the Plum Report, submitted to the federal agency by RAIN Alliance, LoRa Alliance, Wi-Fi Alliance, Wi-SUN Alliance, and Z-Wave Alliance, questioned several key assumptions and methodologies in NextNav’s analysis. It specifically took aim at NextNav studies they argued did not provide sufficient evidence to support the FCC informed decision-making regarding spectrum reallocation.
The Reason for Filing
The filing in a response to what NextNav officials characterize as opponent of their proposal “advancing misconceptions that do not hold up to rigorous, fact-based technical analysis.”
“NextNav’s supplemental technical filing confirms that 5G operations will not cause unacceptable levels of interference to unlicensed Part 15 devices in the lower 900 MHz band, and that unlicensed operations can continue to operate across the entire lower 900 MHz band,” said Renee Gregory, Vice President of Regulatory Affairs, NextNav, in a statement.
Technical Battle
NextNav concluded that submitting this supplemental report was necessary because some commenters have attempted to cast doubt on NextNav’s proposal by misconstruing and mischaracterizing its technical study.
In the filing, the Virgina-based company claimed opponents to their proposal failed to provide any rigorous technical analysis to back up their claims.
“Rather than seriously addressing the NextNav Technical Study, commenters who oppose NextNav’s proposal have advanced numerous misconceptions,” the authors of the filing wrote. “Further, such commenters have failed to provide rigorous technical analysis to back up their claims that coexistence between 5G NR and unlicensed use is not feasible.”
Plum Fight
The primary objection of the Plum Report included geographic density of 5G base stations; base station loading factors; uplink traffic analysis; simplistic indoor/outdoor assumptions; overlooked adjacent channel interference; assumptions about Part 15 devices’ behavior; and limited scenario flexibility.
NextNav submitted supplemental report reiterates that its proposal will allow Part 15 operations to continue across the entire 902–928 MHz band. Other points of contention it contests include:
- NextNav technical study showed less emissions into the band than already-authorized M-LMS deployments. Specifically, it detailed its San Francisco 5G vs M-LMS analysis is valid and proper by referencing 5G field data from an industry leading mobile network intelligence firm;
- Its technical study uses established and data-backed 5G NR network characteristics. Additionally, its approach of using real-world assumptions is superior to the implausible worst-case ones that some commenters advance; and
- The misplaced concerns that 5G uplink operations pose a risk of unacceptable levels of interference to Part 15 operations, demonstrating that 5G uplink operational characteristics pose less of an interference risk than those of Part 15 operations.
Sound Study
Gregory reiterated NextNav firmly stands behind the assumptions of its technical study and that providing additional simulation results does not change the conclusions of its study.
Specifically, the company’s proposal allows devices to continue operating across the entire band, and that 5G operations would better coexist with Part 15 operations than a comparable version of the M-LMS network that federal government has already approved for deployment in the band.
“The FCC has a near-term opportunity to advance a market-based, terrestrial backup and complement to GPS,” said Gregory. “Today’s filing further demonstrates NextNav’s commitment to ensuring that this proceeding is guided by facts, sound engineering, and rigorous technical analysis.”