Article by Aileen Ryan, RAIN Alliance President & CEO, published in RFID Journal on August 27, 2024

The resilience, diversity and security of supply chains has long been fundamental to the prosperity of the United States. By following these three key principles, the nation has built a world-class, agile, and globally competitive manufacturing base, backed by solid systems, trusted critical infrastructure, and reliable transportation. This foundation has allowed the country’s public health and national security systems to prosper.

Each of these industries have benefitted from innovative automation and digitalization capabilities that have come from using RFID to connect to the Internet of Things. At least 80 billion items have been tagged with RAIN in the U.S., with the data from these tags serving to enhance supply chain resilience through digital transformation in countless critical sectors. Furthermore, this figure looks set to continue its rapid growth with the inclusion of RAIN readers in mobile handsets enabling a new wave of innovation.

RAIN technology is therefore fundamental for key industries in modern society to continue functioning. However, a current petition under consideration by the Federal Communication Commission (FCC) risks undermining the use of UHF RFID and other “Part 15” devices in the U.S. across all use cases, leaving the country’s supply chain resilience, diversity and security in peril.

What is The Impact of The Petition?

NextNav, a 3D geolocation service provider, has filed a petition with the FCC to realign the 902-928 MHz band to expand the power level, bandwidth and priority of its licenses, which would allow the company to further push its Position, Navigation and Timing (PNT) services. However, to do so would require significant receiver blocking, cross modulation and Out Of Band (OOB) emissions, which would have a profound impact on the countless Part 15 devices operating within the band.

The power levels that NextNav proposes using would cause such notable interference that it would render RAIN operation impossible. All those that rely on RAIN devices in the U.S.—across many critical applications in a broad range of industries—would be in danger of being blocked, with this disruption resulting in significant negative socio-economic outcomes.

Three of the most notable use cases that would be negatively impacted are as follows:

  • Retail: Over 40 billion tagged items are deployed in the U.S. retail sector alone. These deliver unparalleled end-to-end operational efficiencies, helping track deliveries, automate inventory, enable online business models, prevent counterfeiting and improve profitability.
  • Healthcare: S. hospitals spend an average of $11.9 million on medical and surgical supplies each year. RAIN plays a fundamental role in elevating patient safety by helping track and monitor these materials, as well as supporting staff and patient workflow, automating replenishment and billing, authenticating quality and tracking sterilization processes.
  • National Defense: Virtually all military assets can be tracked, managed and monitored seamlessly with RFID. This engenders seamless military supply chains, especially for assets in transit to be deployed, while providing on-demand data on both traceability and inspection requirements.

Beyond these three industries, countless additional sectors depend on UHF RFID. Aerospace, the automotive industry, the energy and utility sectors, transportation, farming and the logistical chains of a host of different industries depend on the technology; all of which face significant disruption should the 902-928 MHz band be reallocated to serve the interests of NextNav.

What Actions Are Being Taken?

The RAIN Alliance Radio Regulations Advisory Committee (RRAC) is thoroughly investigating and analyzing the potential devastating impact that this petition could have. Comprised of leading RAIN experts from throughout the RAIN Alliance membership, the committee has alerted fellow industry organizations of the threat this petition poses and drafted a comprehensive position paper in collaboration with AIM which outlines these concerns in detail.

Your Voice Matters

The most important consideration is how this proposed amendment would impact those who currently rely on the 902-928 MHz band and the benefits of UHF RFID. That’s why the FCC wants to hear from you.

Every voice has a profound impact. The Wireless Telecommunications Bureau and Office of Engineering and Technology are seeking comment on the petition through the FCC to inform their decision on next steps. It is vital that the FCC consider the full scope of the adverse effects that the proposed changes would have on US critical infrastructure.

The Power of Community

At times like this, organizations like the RAIN Alliance are exemplars of the power of community. It is this strong community that we once again build on as we seek to protect the interests of industries who have built their critical supply chain infrastructure on the 902-928 MHz band, using RAIN technology.

Uniting the UHF RFID community allows the RAIN Alliance to continue its core work of enabling businesses and consumers to identify, authenticate, locate and connect billions of devices to the IoT. We continue to push for the increased availability of the global harmonized UHF frequency band, and we champion RAIN as a data carrier for the emerging EU Digital Product Passport legislation.

These activities can only be done collaboratively, using the Power of Community to align interests, ensure all voices are heard, and benefit from the collective wisdom and knowledge of the brightest minds in our industry.

We look forward to continuing to work with our membership and our partners to foster market adoption of this powerful technology. Together we are stronger.