Comments Urge Open Mind on the Future of GPS Alternatives

NTIA, on behalf of the administration, didn’t weigh in on NextNav's or other PNT proposals. “Adopting a ‘system of systems’ approach to this inquiry will ensure that the Commission can examine a diversity of technologies, each of which may differ in positive and negative attributes,” NTIA said. The agency encouraged the FCC to explore “potential challenges for interoperability, standards adoption and graceful technology transitions.”

The commission should examine “whether PNT standards must use the same (quantifiable, testable) basis for timing and positioning so that different equipment makes or models of complementary PNT technologies can perform together in the same industry ecosystem and remain in sync,” NTIA said. It noted that safeguarding PNT “means protecting the radio frequencies that support it.”

The GPS Innovation Alliance (GPSIA) said proposed technologies should be evaluated based “on their technical performance without overstating their role in the tapestry of complementary systems” and “against current capabilities provided by [global navigation satellite systems] constellations, including the ability to provide fully nationwide and/or global coverage.” GPSIA also urged a refined definition of “complementary” to “guide the Commission’s evaluation of proposed new solutions based on the ability of the proposed solution to provide orbital, signal, or frequency diversity and improvements in PNT signal accuracy, integrity, availability, and/or continuity.”

GPS today is reliable and, since becoming operational 30 years ago, hasn’t experienced an outage, GPSIA noted: “This informed perspective is critical to the Commission’s consideration of how best to support industry efforts to develop additional effective PNT technologies and solutions for civil use of GPS.”

The goal “must be to protect the nation by eliminating PNT as a critical vulnerability,” the Resilient Navigation and Timing Foundation said. It noted that there are really two types of PNT: specialized PNT, which “serves high demand users” and is offered by numerous companies, and utility-level PNT, like that provided by GPS, which “serves all Americans” and “supports infrastructure, IT and an abundance of applications.”

The foundation also said competition is critical. The U.S. “has an abundance of non-profit and commercial entities capable and willing to provide utility-level PNT systems and services that can contribute to a resilient National Core PNT Architecture,” it said: “Fair and open competition based on well articulated requirements is the only way to select one or more providers.”

CTIA urged caution, arguing that the FCC “should support other federal agencies’ efforts and should avoid taking steps that might disrupt those agencies’ ongoing work.” The commission should also “maintain a technology-neutral approach to PNT technology while avoiding regulatory mandates.” Companies should be able to “evaluate and choose the best and most cost-effective methods to achieve their goals, while recognizing the leading roles” of the Department of Transportation, Department of Homeland Security and National Institute of Standards and Technology, the group said.

NAB highlighted the benefits of the nascent broadcast positioning system for PNT. “Using existing tower infrastructure and operating within the transmission standard to which broadcasters are already migrating, BPS can be rolled out quickly and at relatively low expense at any ATSC 3.0 broadcast site.”

NextNav

Other commenters debated NextNav’s proposal for PNT.

NextNav asked the FCC to release an NPRM on PNT in the lower 900 MHz band. “It is critical for the Commission to enable at least one future-proof solution that relies on market forces to deliver a terrestrial, widescale PNT solution that is broadly available to critical infrastructure, public safety, and consumers, and has a clear path to incorporation in end-user devices,” it said.

The company has “a proven track record of providing accurate, reliable location information to support first responders,” and “building on that legacy, NextNav’s next-generation 5G-based 3D PNT solution, ‘NextGen,’ will help meet the urgent national security and public safety need for a complement and backup to GPS,” NextNav said.

The Telecommunications Industry Association noted that the NextNav proposal “has drawn significant and broad opposition from a diverse cross-section of the economy as having a profound negative impact on other uses in the 902-928 MHz band.” The success of unlicensed devices in spectrum didn’t “occur by happenstance -- it is a direct result of the FCC’s decision to protect unlicensed devices from interference caused by licensed services, such as NextNav,” the group said. The International Bridge, Tunnel & Turnpike Association said NextNav’s proposal “would disrupt important incumbent operations.”

GPS uses the L band, but there's no reason why an alternative or complementary PNT system couldn't use other satellite frequencies, SES/O3b said. The FCC should support establishing an alternative or complementary PNT service in any satellite band or orbit, it said, adding that no rule changes would be needed, since PNT signals are likely at or below the power limits for existing satellite service allocations.