On the Record: NextNav's Campaign for Terrestrial PNT
NextNav is working hard at the FCC to reconfigure the Lower 900 MHz Band (902-928 MHz) to support a 5G-based Positioning, Navigation, and Timing (PNT) service
Introduction
Over the past year or so, NextNav has been engaged in a regulatory campaign to reconfigure the Lower 900 MHz Band (902-928 MHz) to support a 5G-based terrestrial PNT service designed to complement and provide a resilient backup to the Global Positioning System (GPS). Through a series of filings across multiple dockets, NextNav has articulated a consistent vision that intertwines national security imperatives with a market-based solution for deploying next-generation PNT and mobile broadband services.
The company's primary regulatory vehicle was its Petition for Rulemaking (WT Docket 24-240), which seeks to replace what it deems outdated and restrictive Part 90 Multilateration Location and Monitoring Service (M-LMS) rules with a flexible-use framework. Specifically, NextNav proposes a new band plan creating a 15-megahertz frequency-division-duplex (FDD) allocation, comprised of a 5-megahertz uplink (902-907 MHz) and a 10-megahertz downlink (918-928 MHz). This structure, aligned with 3GPP standards, is presented as the foundational step required to enable its PNT service, which would be delivered through partnerships with mobile network operators. The company consistently frames this proposal as a privately funded initiative that will be provided "at no cost to taxpayers," addressing a long-acknowledged national vulnerability.
This campaign has drawn significant opposition from a diverse coalition of stakeholders. Incumbent users of the 900 MHz band, including tolling authorities such as the E-ZPass Group and the International Bridge, Tunnel, and Turnpike Association (IBTTA), alongside the Association of American Railroads (AAR), have raised concerns about potential interference with their critical safety and operational systems. They are joined by a formidable group of technology alliances representing unlicensed Part 15 devices—such as the Wi-Fi Alliance, LoRa Alliance, and RAIN Alliance—who fear that high-power 5G operations could disrupt the delicate ecosystem of the industrial, scientific, and medical (ISM) band. NextNav's strategy reveals a pattern of direct and repeated rebuttal to these interference concerns, coupled with proactive engagement in new, related dockets to keep its proposal at the center of the Commission’s broader PNT resiliency discussions.
Detailed Discussion
NextNav’s current regulatory effort commenced on April 16, 2024, with their Petition for Rulemaking. In this initial filing, the company presented the Commission with what it called "a unique opportunity to reconfigure the 902-928 MHz band" to enable a terrestrial complement to GPS, arguing that the existing rules had led to significant underutilization of the spectrum.1 This petition, which opened WT Docket 24-240, established the core tenets of NextNav's argument: the vulnerability of GPS demands a terrestrial alternative, and the Lower 900 MHz band is the ideal home for such a system if modernized for flexible, 5G-based use.
In subsequent months, NextNav elaborated on this vision. In a June 2024 letter, the company formally proposed updating Part 90 rules to permit mobile and fixed broadband in specific uplink (902-907 MHz) and downlink (918-928 MHz) segments, a prerequisite for its PNT deployment model.2 The strategy is not merely to provide PNT, but to unlock the value of its low-band spectrum holdings for 5G broadband by leveraging the public interest benefits of a GPS backup.
As the proceeding advanced, a broad spectrum of opposition emerged. By September 2024, NextNav’s filings began to systematically name and counter arguments from a wide array of entities. In its Reply to Comments, the company addressed concerns from over a dozen parties, including incumbent toll operators, railroad associations, and technology consortia like the LoRa and Z-Wave Alliances.3 A central theme in NextNav’s response was to position its proposal as "the only viable, commercially funded solution" to the nation's PNT resiliency problem, framing opposition as a defense of an inefficient status quo. The company asserted, "No one else has proposed a credible solution to the widely recognized and increasingly urgent problem that the United States has no “widescale” TPNT service."4
Recognizing that interference was the primary technical hurdle, NextNav dedicated significant effort to rebutting these claims. In an ex parte filing in November 2024, the company stated that the opposing parties’ concerns were "unfounded, in large part because they are based on a misunderstanding of how NextNav intends to use its licensed Lower 900 MHz spectrum." It argued that practical equipment constraints and commercial incentives for frequency reuse would prevent operations from causing harm to incumbent or unlicensed users.5 This message was repeated consistently, with later submissions asserting that "5G operations will not cause unacceptable levels of interference to unlicensed Part 15 devices."6 To soften this firm stance, NextNav also signaled a willingness to collaborate, confirming its "commitment to working with those incumbent operators to develop coexistence solutions, which may include financial and technical support to retune or replace equipment" in a May 2025 filing.7
On January 10, 2025, NextNav filed a request for an extension of its M-LMS license buildout deadlines. The justification provided was the regulatory uncertainty created by its own pending Petition for Rulemaking, thereby linking its operational requirements directly to the successful outcome of its policy campaign.8
When the Commission initiated a new, broader Notice of Inquiry on "Complementary PNT" (WT Docket 25-110) in 2025, NextNav moved quickly to frame the new proceeding around its existing proposal. It urged the Commission to promptly issue a Notice of Proposed Rulemaking in its original docket (24-240). It argued that the new inquiry should adopt a "system-of-systems" approach, with NextNav’s 900 MHz solution as a key component. The Company claimed that true PNT resilience requires multiple, diverse technologies, including both space-based and terrestrial options. Their specific argument is that for this system-of-systems to work without massive government spending, it must include at least one scalable, market-driven terrestrial solution. They position their 5G-based proposal as the only one that can achieve widescale deployment through existing infrastructure and the consumer smartphone ecosystem, thus filling a critical gap in the "system-of-systems" model that other technologies or government-funded projects cannot.9 The company also sought to strategically bifurcate the issues, arguing in a March 2025 letter that interference questions were best addressed in the original rulemaking proceeding, rather than the new PNT inquiry.10
As the campaign progressed into mid-2025, NextNav’s arguments became more pointed. In its reply comments in the PNT NOI, it characterized criticism of its market-based approach as "little more than delay tactics and unsupported, heated rhetoric" from actors aiming to "maintain the status quo, rather than serve the public interest."11 This demonstrates a clear strategic decision to portray its plan as the sole path forward for PNT resiliency. Filings through June 2025 show a continued, high-tempo engagement with Commission staff, reiterating the core message that its proposal enables a "near-term, future-proof, widescale 5G-based 3D PNT... at no cost to taxpayers" and with broad consumer device availability.12 The record shows that NextNav is navigating FCC processes to advance a singular, transformative vision for its spectrum and the nation's PNT infrastructure.
WT 25-110, or Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions, has more than 140 filings. It is a complex docket. Please let us know if you’d like us to write it up.
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July 08, 2025
[PETITION FOR RULEMAKING, https://docket-rocket.io/filings/10416238018537]
[REPLY TO COMMENTS, https://docket-rocket.io/filings/109210013201773]
[REPLY TO COMMENTS, https://docket-rocket.io/filings/109210013201773]
[NOTICE OF EXPARTE, https://docket-rocket.io/filings/11011885007350]
[NOTICE OF EXPARTE, https://docket-rocket.io/filings/10523121419619]
[NOTICE OF EXPARTE, https://docket-rocket.io/filings/1050115322064]
[REPLY TO COMMENTS, https://docket-rocket.io/filings/1051466194656]
[NOTICE OF EXPARTE, https://docket-rocket.io/filings/1061378520739]