- The geolocation company’s filing seeks priority to be given to their GPS-based devices using the band 902-928 MHz, traditionally used by UHF RFID, LoRa and other technologies
- RAIN Alliance and GS1 warn that approval of the petition could severely inhibit the use of UHF RFID technology in the U.S. and worldwide
The Federal Communication Commission (FCC) is now accepting comments related to a petition that could hinder the use of UHF RFID and other “Part 15” devices in the U.S.
In April, NextNav filed a rulemaking petition with the FCC to realign the 902-928 MHz band used by UHF RFID as well as other wireless devices. On Aug. 6, the FCC opened a period of community comment which ends on Sept. 5, 2024.
The RAIN Alliance is urging those who use or make products in the UHF RAIN RFID frequency to weigh in on the petition. For technology users, that means indicating the importance of RFID technology for how they run their business; for technology companies, the goal is to explain the value of the products and applications they provide, and how they would be impacted, said Aileen Ryan, RAIN Alliance CEO.
If the NextNav petition was awarded, the proposed changes could have damaging impacts on RFID deployments in the U.S., according to industry standards organizations RAIN Alliance and AIM Global in a joint statement.
Ryan warned if NextNav’s re-allocation bid for the bandwidth succeeds, it would impact the reliability and functionality of RFID, ultimately affecting “the resilience and efficiency of America’s supply chains, businesses and government agencies.” And because the technology is used as part of global supply chains, the impact would be felt worldwide, she added.
Seeking Priority of 910-920 MHz for Terrestrial GPS
NextNav is a positioning, navigation, timing (PNT) and 3D geolocation technology company. Its April FCC petition aimed to expand the power level, bandwidth and priority of its licenses. Additionally, NextNav proposes to use 5G connectivity over the relatively low bandwidth.
It 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.
“This plan offers enormous benefits to the public by creating a complement and backup to GPS, while also unleashing much-needed spectrum for 5G broadband,” said NextNav spokesperson Howard Waterman.
Existing 902-928 Part 15 Devices
Historically, the FCC has allowed RAIN RFID operation in the designated 902-928 MHz frequency band. Other technologies such as medical devices, smart home equipment like baby monitors and cordless phones, tolling solutions, and LoRa systems leverage this frequency band under the same unlicensed parameters.
However, manufacturers of such Part 15 devices are not protected against interference from other users and must be designed to handle interference with techniques such as frequency hopping. The difference, with the change being petitioned, would be the priority that NextNav systems would have over other devices.
Indoor Navigation
NextNav’s navigation systems provide an indoor alternative where GPS is less effective. Its technology is used in aviation, autonomous vehicles and mobile applications as well as public safety.
Waterman added that “our proposal…improves horizontal and vertical location accuracy, giving first responders more accurate information about where 911 callers are, improving emergency response times and ultimately saving lives.”
NextNav has reported that its urban GPS features could address some government objectives, pointing to the war in Ukraine where jamming of satellite-based GPS could impede essential communication.
NextNav’s Prepares for Expansion
NextNav is already preparing for the proposed change. In May, the public company invested $50 million, following submission of the petition, with potential to expand up to $80 million. And they hired a Verizon executive in June to lead its strategy for what it called an innovative spectrum solution in the lower 900 MHz band.
The navigation company officials reported that its petitioned rule-change is needed for enhancing national security and public safety through robust and resilient PNT services. In fact, some U.S. lawmakers have expressed concern about existing GPS system resiliency. In 2020, then-President Donald Trump signed an executive order on Strengthening National Resilience through Responsible Use of PNT services.
Josef Preishuber-Pflügl, RAIN Alliance’s head of regulatory affairs, warned that NextNav’s petition seeks higher priority over other Part 15 devices as well as enabling the system to act as a 5G operator which requires significantly higher power “and this certainly would cause interference.”
With the proposed new rule, NextNav would have preferential treatment which could result in RFID deployments being shut down.
Bidirectional Capacity
Additionally, if the rule was enacted, the FCC would then permit NextNav’s mobile and fixed broadband transmissions in two directions: in the 902-907 MHz (for uplink) and 918-928 MHz (for downlink) to create a new “Terrestrial Positioning, Navigation, and Timing Service” (TPNT).
Currently, the terrestrial navigation system is only unidirectional, with devices only receiving transmissions. For instance, a satellite broadcasts details to a terrestrial device, but that device does not send data back to the satellite.
To accomplish the bidirectionality, NextNav will need greater dominance in the bandwidth.
NextNav’s Waterman stated that company officials are “committed to working with all incumbents in the band to develop a better understanding of operations, including the frequencies and geographies where the band is in use.” He added that he anticipates the petition to lead to new dialog.
“The FCC’s rulemaking process allows us all to engage in these important conversations and we look forward to working together to put this spectrum to the best set of uses,” said Waterman.
Blinding RFID Readers
But those assertions may not ease the concerns for RFID industry members. Nonprofit standards group GS1 US governs the standards that power RFID technology, and in that role, “GS1 US is sharing information with industry stakeholders regarding the FCC request for comment, and GS1 US will respond to the FCC request for comment. In doing so it will outline the many benefits of the technology,” said Jonathan Gregory, GS1 US’ global standards director.
Based on technical feedback, the requested higher power levels for terrestrial GPS would “blind” RFID readers. If NextNav systems detect any interference to their solution, they would have the right to claim priority to the FCC, potentially limiting RFID usage, according to GS1 officials.
That could impact supply chains, military resources, baggage handling, medication management, healthcare systems and other systems that rely on RFID— not just a problem for the U.S., but others internationally that do business or share supply chains with the U.S., said Ryan.
Previous FCC Filing in 2013
This is not the first time NextNav has tried to persuade the federal government to override occupied bandwidth. In 2013, a previous petition requested a new bandwidth plan that would provide 15 MHz of low-band spectrum for PNT and broadband deployment, leveraging the 5G standard.
The FCC decided against adopting these proposed changes, based on concerns about interference with the multi-millions of existing Part 15 devices operating in the band. At that time, the FCC emphasized the need to protect these unlicensed devices from harmful interference, maintaining a balance between new services and the protection of existing users.
The latest petition could go about changing those rules. The proposed power levels of 3280W per MHz could render RFID operation impossible in the frequency ranges allocated to NextNav. This means that UHF RFID devices within about one kilometer of NextNav devices could be rendered inoperable.
UHF RAIN RFID in Use in the Billions
The number of RFID devices has grown exponentially since 2013. According to the RAIN Alliance, about 80 billion items have now been tagged with UHF RAIN RFID in the U.S. to digitize data about goods and assets in sectors including retail, logistics, healthcare, pharmaceuticals, automotive, aviation, smart manufacturing, food safety, energy, government and smart cities.
If the FCC were to accept the petition, “this change will have profound negative impacts on RAIN RFID operations in the U.S., destroying the resilience and efficiency of America’s supply chains, businesses and government agencies,” Ryan said.
The rule change that is being requested would cause significant adverse socio-economic impacts, as well, added Preishuber-Pflügl.
Responses Accepted Until Sept 5
Comments from the public are due by Thursday, Sept. 5, while subsequent reply comments will be due on Sept 20. The FCC will then consider the comments and replies, to determine the next step.
RAIN Alliance and AIM are preparing a joint letter which will be sent to the FCC. In the meantime, the alliance is requesting a meeting with the FCC in order to explain the potential impacts of the NextNav petition on RAIN RFID deployments and is collecting data from members and members’ customers to prepare for that.
Additionally, the alliance is engaged in a campaign to help explain the negative consequences to the FCC and plan to make their case in Washington to two committees that have oversight of this issue: the House’s Energy and Commerce Committee and the Senate’s Committee on Commerce, Science and Transportation.
Increasing Reliance on RFID
Supply chain resilience depends on RFID, Ryan argued. In fact, supply chains have digitally transformed so much in the last five years “that many businesses and essential services are actually entirely reliant on the RAIN RFID systems.”
Some of the largest users of RFID technology are retailers and hospital groups while Ryan pointed to aerospace, manufacturing; as well as military agencies that use RAIN RFID for defense applications.
“We need to think very broadly about the potential impacts here,” Ryan said. “We’re hoping to galvanize the entire ecosystem to respond.”