Positioning, Navigation & Timing (PNT) Notice of Inquiry, WT Docket No. 25-110 - "On The Record"

A comprehensive review of the record, as of July 8, 2025

I. Introduction

On March 27, 2025, the FCC adopted a Notice of Inquiry (NOI) in WT Docket No. 25-110 to explore the landscape of Positioning, Navigation, and Timing (PNT) Technologies and Solutions. The proceeding seeks to build a comprehensive record on actions the Commission can take to support the development of a resilient "system of systems" to complement the Global Positioning System (GPS). The NOI frames PNT resilience as a matter of national and economic security, stating that sole reliance on GPS creates a single point of failure. The Commission is seeking public comment on a wide range of issues, including the capabilities of various space-based and terrestrial technologies, their infrastructure and spectrum requirements, performance characteristics, and the economic trade-offs between public and private provision. The NOI also asks for input on national security implications, such as the use of foreign Global Navigation Satellite Systems (GNSS); potential interference to incumbent services; and what specific rule changes, such as new spectrum allocations, equipment authorizations, or the creation of Innovation Zones, may be necessary to accelerate development and deployment. In a deviation from standard practice, the Wireless Telecommunications Bureau (WTB) applied “permit-but-disclose” ex parte rules to the inquiry to provide “maximum transparency.”¹

II. Stakeholders’ Proposals

A diverse group of stakeholders, including technology developers, industry associations, and public interest groups, filed comments supporting the Commission’s inquiry and proposing a wide array of solutions. A broad consensus emerged around the need for a technology-neutral, market-driven, "system of systems" approach to PNT resilience.

• Space-Based PNT Solutions:

  • Low Earth Orbit (LEO) Systems: Commenters presented multiple LEO-based solutions. Iridium Communications Inc. (Iridium) detailed its operational Satellite Time and Location (STL) service, arguing its stronger signal enables indoor penetration and its cryptographic techniques resist spoofing.² Space Exploration Holdings, LLC (SpaceX) advocated for leveraging next-generation LEO constellations and ongoing work in 3GPP for "GNSS-free" PNT. They urged the Commission to authorize the sharing of “chronically underused” Mobile-Satellite Service (MSS) spectrum to promote innovation.³ AST & Science, LLC (AST) promoted its SpaceMobile network, arguing its direct-to-device infrastructure could support PNT in cellular spectrum with stronger signals than GPS.⁴ TrustPoint, Inc. proposed a new LEO system using an encrypted C-Band signal for frequency diversity.⁵ Xona Space Systems, Inc. (Xona) presented its commercial Radionavigation-Satellite Service (RNSS) system, a LEO constellation designed as a high-performance, encrypted alternative to GPS that could be integrated with existing user devices via a firmware update.⁶

  • Other Orbital Solutions: Higher Ground, LLC detailed its GEOFix™ solution, which it argued could provide assured PNT within a year by leveraging existing Geostationary Earth Orbit (GEO) satellites without new spectrum or regulatory frameworks.⁷ HEO Satellite, LLC recommended including Highly Elliptical Orbit (HEO) systems, contending that their unique orbits enhance survivability.⁸ SES Americom, Inc. and O3b Limited (SES) encouraged the Commission to support alternative PNT in any satellite band and orbit, arguing systems could be implemented quickly using existing satellites under current power limits.⁹

  • Signals of Opportunity (SoOP) from Satellites: Parsons Government Services, Inc. presented its Assured Positioning System (APS), a Technical Readiness Level 8 (TRL-8) solution that derives PNT from commercial LEO and government GEO satellites in MSS frequencies, providing natural immunity to GPS jamming.¹⁰ CARMEN+ UTC detailed a framework to provide PNT by dual-purposing OneWeb's Ku-band LEO signal using a network of reference stations.¹¹

• Terrestrial PNT Solutions:

  • Broadcast Positioning System (BPS): Broadcasters and their partners strongly advocated for BPS, which leverages ATSC 3.0 television signals. Proponents, including the National Association of Broadcasters (NAB), Sinclair, Nexstar, Trinity Broadcasting Network (TBN), and Pearl TV, argued that BPS is a rapidly deployable, cost-efficient, and jamming-resistant solution using existing, resilient "high-power, tall tower" infrastructure. They urged the Commission to establish a timeline for a complete nationwide transition to Next Gen TV by sunsetting the ATSC 1.0 standard to enable the service.¹² Public broadcasters, represented by America's Public Television Stations (APTS) and the Public Media Venture Group (PMVG), highlighted their hardened, nationwide infrastructure as a key asset for BPS deployment.¹³

  • Enhanced Long-Range Navigation (eLoran): UrsaNav and Hellen Systems Inc. (Hellen) presented eLoran as a mature, TRL-9 dissimilar complement to GPS. They argued that its high-power, low-frequency signal (90-110 kHz) is practically "un-jammable" and that the U.S. is falling behind other nations in deploying this technology. They advocated for a "Government owned, Contractor operated" or public-private partnership (PPP) model for a nationwide build-out.¹⁴

  • 5G-Based and Other Broadcast Solutions: NextNav Inc. (NextNav) strongly advocated for its "NextGen" 5G-based PNT solution in the Lower 900 MHz band, arguing it is a scalable, market-based terrestrial component that can exceed the Commission's z-axis accuracy requirements without taxpayer funding. The proposal was supported by public safety groups and telecom equipment vendors, including the California Fire Chiefs Association, the TEXAS 9-1-1 ALLIANCE, 3AM Innovations Inc., RadiSys Corporation (RadiSys), and Oscilloquartz.¹⁵ Castanet 5G LLC detailed its 5G Broadcast Internet Positioning System (BIPS), leveraging Low Power Television (LPTV) infrastructure and 3GPP standards, which could coexist with BPS. XGN Network, LLC (XGN) also championed 5G Broadcast as a lighter and faster alternative to ATSC 3.0-based systems.

  • Other Terrestrial Technologies: Locata Corporation (Locata) presented its TRL-9 technology, used as a truth reference system by the USAF, which provides centimeter-level positioning independent of GPS.¹⁶ MerlinTPS Corp detailed its solution utilizing existing terrestrial Signals of Opportunity (SoOP) and AI algorithms, which require no regulatory changes.¹⁷ Balboa Geolocation presented its POINTER system, which utilizes magneto-quasi-static (MQS) fields for sub-meter 4D tracking in GPS-denied environments to address the needs of first responders.¹⁸

• Hybrid, Network-Based, and Non-RF Solutions:

  • Network and Data-Centric Solutions: Several filers proposed solutions leveraging existing network infrastructure and data. Safran Trusted 4D (ST4D) emphasized the importance of fiber-optic networks in delivering time directly from UTC sources, while Net Insight promoted its Precision TimeNet (PTN) technology for distributing timing over IP networks.¹⁹ NAVSYS Corporation argued for a PNT as a Service (PNTaaS™) data model to leverage existing RF signals without new spectrum.²⁰ The Wi-Fi Alliance and Apple Inc. (Apple) highlighted the value of existing technologies like Wi-Fi CERTIFIED Location™ and crowd-sourced data for complementary positioning.²¹

  • Non-RF and Emerging Technologies: Filers presented innovative solutions that do not rely on RF signals. Skyline Nav AI, Inc., Juxta Technology, Inc. (Juxta), Astra Navigation, Inc. (AstraNav), and Tern AI Inc. detailed systems using computer vision, inertial measurement units (IMUs), the Earth’s magnetic field, and onboard vehicle sensors, respectively, to provide positioning that is inherently immune to RF jamming and spoofing.²² Xairos Systems, Inc. (Xairos) introduced a space-based Quantum Time Transfer (QTT) system using entangled photons for highly secure timing that requires no new RF spectrum.²³

• Policy and Framework Recommendations:

  • Protect and Modernize GPS: The GPS Innovation Alliance (GPSIA) and Lockheed Martin Corporation (Lockheed Martin) argued the focus should be on "complementing, not replacing, GPS" and investing in the ongoing modernization of the GPS constellation.²⁴ oneNav, Inc. (oneNav) emphasized improving receiver technology to acquire the more resilient L5 signal directly.²⁵ Professor Dennis Akos proposed a strategy to "Protect GPS rather than replace" it by using a crowdsourced network of smartphones to detect and locate interference.²⁶

  • Use of Foreign GNSS: A strong consensus emerged among industry groups like CTIA, the Consumer Technology Association (CTA), the Alliance for Automotive Innovation (Auto Innovators), GPSIA, and public safety advocates like NENA: The 9-1-1 Association (NENA) that the Commission should update its "antiquated" Part 25 rules to facilitate the reception of foreign GNSS signals. They argued that the accuracy and resilience benefits for consumer and public safety applications outweigh the minimal security risks.²⁷

  • Government Role and Framework: The National Telecommunications and Information Administration (NTIA), on behalf of the Executive Branch, supported the Commission's "whole of government" approach and stressed the need to protect spectrum for geodetic observations critical to PNT accuracy.²⁸ The Open PNT Industry Alliance (OPIA), the U.S. Chamber of Commerce (Chamber), and Apple advocated for a technology-neutral framework that allows market competition to determine the best solutions, cautioning the FCC against picking winners and losers.²⁹ The Resilient Navigation and Timing Foundation (RNTF) argued for a government-led National Core PNT Architecture, with services contracted from the private sector and made available for free public use.³⁰

III. Opposition

Significant opposition and dissenting views were filed in response to specific proposals that commenters argued would be disruptive to incumbent services or economically unviable.

• Opposition to NextNav’s Lower 900 MHz Band Proposal:

  • The proposal from NextNav to reconfigure the Lower 900 MHz band for its 5G-based PNT solution drew widespread and forceful opposition from a broad coalition of incumbent spectrum users. Opponents included representatives from the electronic tolling industry (International Bridge, Tunnel & Turnpike Association (IBTTA), E-ZPass Group, Neology, Inc.); utilities (Edison Electric Institute (EEI), Utilities Technology Council (UTC)); the IoT ecosystem (LoRa Alliance, Ad Hoc RAIN RFID Coalition, Wi-SUN Alliance, Wi-Fi Alliance); precision agriculture (Deere & Company (Deere)); and numerous other industry associations and technology companies (ITI, NCTA, TIA, SIA, Apple).

  • Interference Concerns: The central argument was that introducing high-power 5G signals would cause "pervasive, disruptive, and costly harmful interference" to the hundreds of millions of devices that rely on the band, including electronic toll tags, utility smart meters, IoT sensors, and Wi-Fi HaLow devices.³¹ The IEEE 802 LAN/MAN Standards Committee (LMSC) argued the plan would "severely impact" the operation of devices under its standards.³²

  • Economic and Technical Arguments: Opponents cited an economic study by Harold Furchtgott-Roth estimating costs of $27-$33 billion to replace affected devices, which they argued far outweigh any benefits of the proposal.³³ They also submitted technical analyses, such as the Plum Report, asserting that NextNav’s coexistence study was "incorrect and misleading."³⁴

  • Policy Arguments: Critics characterized the proposal as an unnecessary "spectrum grab" that would provide NextNav with an unfair "windfall" by granting it a nationwide broadband license without an auction, while abrogating its legal obligation to protect unlicensed users. Many argued that the proposal should be rejected because numerous non-disruptive alternatives exist within the record.³⁵

  • NextNav’s Rebuttal: NextNav characterized the opposition as "delay tactics and unsupported, heated rhetoric," arguing its engineering studies show coexistence is possible and that its critics' economic and technical analyses are based on "false or distorted assumptions." The company urged the Commission to issue an NPRM to move the debate to concrete rule proposals.³⁶

• Counter-Arguments and Other Dissenting Views:

  • Mandated ATSC 3.0 Transition: NCTA - The Internet & Television Association (NCTA) argued against a mandated transition to ATSC 3.0 to facilitate BPS, contending it would impose substantial costs on consumers and MVPDs. One Ministries, Inc. (OMI) argued such a mandate would be "unfunded" and could force smaller, independent broadcasters off the air.³⁷

  • MSS Spectrum Sharing: Globalstar, Inc. (Globalstar) opposed SpaceX’s call for spectrum sharing in the Big LEO MSS band, arguing it would cause harmful interference to its existing network, which already supports PNT-capable services.³⁸

  • Foreign GNSS Security: Parsons and Xona raised national security concerns about the "risk of manipulation" from using GNSS systems controlled by adversaries like Russia and China.³⁹

  • eLoran Form Factor: Apple raised a practical concern about eLoran, noting its antenna size makes it incompatible with modern mobile and wearable devices.⁴⁰

IV. Ex Parte Filings

Stakeholders engaged in numerous ex parte meetings with Commission staff and leadership to advocate for their positions.

• Opposition to NextNav Proposal: A significant number of meetings focused on opposing the NextNav proposal. IBTTA, Neology, and Avery Dennison met with staff prior to the NOI's adoption to urge the inclusion of a question regarding interference.⁴¹ After comments were filed, representatives for IBTTA, the E-ZPass Group, and Neology met with the offices of Chairman Carr and Commissioners Simington and Gomez to present the Furchtgott-Roth study detailing the proposal's high economic costs.⁴² The Wi-Fi Alliance met with senior staff to reiterate that the proposal would imperil Wi-Fi HaLow devices and argued that NextNav had failed to account for interference to its proposed network.⁴³ Avery Dennison also submitted ex parte comments expanding on its opposition and highlighting the vulnerability of passive RFID systems.⁴⁴

• Advocacy for NextNav Proposal: NextNav met with staff from the WTB and the Office of Engineering and Technology (OET), as well as an advisor to Commissioner Gomez, to continue advocating for its proposal. The company asserted its solution could be deployed rapidly. It reiterated its commitment to provide financial and technical support to incumbent licensees to ensure a smooth transition.⁴⁵

• Advocacy for Other Solutions: Iridium met with the Space Bureau and later with staff from several other bureaus to promote its STL service and propose the creation of a reference tool for consumers.⁴⁶ APTS met with Commissioner Simington to highlight the role public television stations can play in PNT resilience.⁴⁷ AstraNav met with staff to promote its non-RF solution and a holistic, market-driven approach.⁴⁸ oneNav met with staff from OET, the Public Safety and Homeland Security Bureau (PSHSB), and the Wireless Bureau to recommend specific E911 rule changes and advocate for the operational deployment of the GPS L5 system.⁴⁹

• General Policy and Framework Discussions: GPSIA met with staff to frame the discussion around "complementary" PNT assets and emphasize the strength of the existing commercial market.⁵⁰ Professor Dennis Akos presented research to staff arguing for a strategy focused on protecting GPS from interference.⁵¹ John Raquet and William Burruss, with support from Apple, submitted a white paper arguing for the low security risk of using foreign GNSS signals.⁵²

V. Conclusion

The record in response to the PNT NOI reveals a vibrant and innovative ecosystem of potential technologies to enhance the nation's PNT resilience. A broad consensus exists among stakeholders on the need for a "system of systems" that incorporates multiple, diverse technologies and is fostered by a technology-neutral, market-driven regulatory framework. However, the filings also highlight significant points of conflict that the Commission will need to address. The most contentious issue is NextNav's proposal to reconfigure the Lower 900 MHz band, which has generated substantial opposition from a wide range of incumbent users who warn of debilitating interference and massive economic costs. While there is general agreement on modernizing rules to permit the use of foreign GNSS, the path forward for specific terrestrial solutions, such as BPS and the NextNav proposal, remains highly contested. The record provides the Commission with a comprehensive survey of available and emerging technologies, along with detailed arguments regarding their benefits, drawbacks, and the regulatory actions needed to support or reject them, setting the stage for potential future rulemakings.

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This is the proceeding page for 25-110:

1. [Public Notice, Wireless Telecommunications Bureau, https://docs.fcc.gov/public/attachments/DA-25-196A1.pdf] [Other, Wireless Telecommunications Bureau, https://www.fcc.gov/public/attachments/FCC-25-20A1.pdf].

2. [Comment, Iridium Communications Inc., https://www.fcc.gov/ecfs/document/1042879480901/1]

3. [Comment, Space Exploration Holdings, LLC, https://www.fcc.gov/ecfs/document/10429169905282/1] [Reply To Comments, Space Exploration Holdings, LLC, https://www.fcc.gov/ecfs/document/1051418495002/1]

4. [Comment, AST & Science, LLC, https://www.fcc.gov/ecfs/document/1042887278189/1]

5. [Comment, TrustPoint, Inc., https://www.fcc.gov/ecfs/document/10428044843368/1]

6. [Comment, Xona, https://www.fcc.gov/ecfs/document/104290421620204/1] [Reply To Comments, Xona, https://www.fcc.gov/ecfs/document/10514579106813/1]

7. [Comment, Higher Ground, LLC, https://www.fcc.gov/ecfs/document/104282490901597/1]

8. [Comment, HEO Satellite, LLC, https://www.fcc.gov/ecfs/document/10417224470438/1]

9. [Comment, SES Americom, Inc. and O3b Limited, https://www.fcc.gov/ecfs/document/1042817693470/1]

10. [Comment, Parsons Government Services, Inc., https://www.fcc.gov/ecfs/document/10428682515746/1]

11. [Comment, CARMEN+ UTC, https://www.fcc.gov/ecfs/document/10428285655685/1]

12. [Comment, National Association of Broadcasters, https://www.fcc.gov/ecfs/document/10428212620125/1] [Comment, Sinclair Inc., https://www.fcc.gov/ecfs/document/104281371817037/1] [Reply To Comments, Nexstar Media Inc., https://www.fcc.gov/ecfs/document/10513309501300/1] [Comment, Trinity Broadcasting Network, https://www.fcc.gov/ecfs/document/1042849705976/1] [Reply To Comments, Pearl TV, https://www.fcc.gov/ecfs/document/1051477677362/1]

13. [Notice Of Exparte, America's Public Television Stations, https://www.fcc.gov/ecfs/document/10415611216653/1] [Comment, Public Media Venture Group, https://www.fcc.gov/ecfs/document/10428666623021/1]

14. [Comment, UrsaNav, https://www.fcc.gov/ecfs/document/10425106741527/1] [Comment, Hellen Systems Inc., https://www.fcc.gov/ecfs/document/1042876254263/1]

15. [Comment, NextNav Inc., https://www.fcc.gov/ecfs/document/10428207122908/1] [Letter, California Fire Chiefs Association, https://www.fcc.gov/ecfs/document/10528198294341/1] [Comment, TEXAS 9-1-1 ALLIANCE, https://www.fcc.gov/ecfs/document/10428636508498/1] [Comment, Ganesh Shenbagaraman, https://www.fcc.gov/ecfs/document/1042890727905/1] [Comment, Mr. Gil Biran, https://www.fcc.gov/ecfs/document/10429832401924/1]

16. [Comment, Locata Corporation, https://www.fcc.gov/ecfs/document/1051208274604/1]

17. [Reply, MerlinTPS Corp, https://www.fcc.gov/ecfs/document/1042837693813/1]

18. [Supplement, Balboa Geolocation, https://www.fcc.gov/ecfs/document/104231425327947/1]

19. [Comment, Safran Trusted 4D, https://www.fcc.gov/ecfs/document/1042836787256/1] [Reply To Comments, Steve Craycraft, Per Lindgren, Roger Bjork, Christoffer Ramm, Tim Kruger, Magnus Danielson, https://www.fcc.gov/ecfs/document/10422817614256/1]

20. [Comment, Alison K Brown, https://www.fcc.gov/ecfs/document/1042962394404/1]

21. [Comment, Wi-Fi Alliance, https://www.fcc.gov/ecfs/document/10428132781589/1] [Comment, Apple Inc., https://www.fcc.gov/ecfs/document/1042813126394/1]

22. [Comment, Skyline Nav AI, Inc., https://www.fcc.gov/ecfs/document/10428423816175/1] [Comment, Juxta Technology, Inc., https://www.fcc.gov/ecfs/document/10520733819594/1] [Comment, Astra Navigation, Inc., https://www.fcc.gov/ecfs/document/104281976818792/1] [Comment, Tern AI Inc., https://www.fcc.gov/ecfs/document/10428091699611/1]

23. [Comment, Xairos Systems, Inc., https://www.fcc.gov/ecfs/document/10428417704995/1]

24. [Comment, GPS Innovation Alliance, https://www.fcc.gov/ecfs/document/1042846153376/1] [Comment, Lockheed Martin Corporation, https://www.fcc.gov/ecfs/document/10428228053344/1]

25. [Comment, oneNav, Inc., https://www.fcc.gov/ecfs/document/1042804249261/1]

26. [Notice Of Exparte, Dennis Akos, https://www.fcc.gov/ecfs/document/105132802906091/1]

27. [Comment, CTIA, https://www.fcc.gov/ecfs/document/10428099365497/1] [Reply To Comments, Alliance for Automotive Innovation, https://www.fcc.gov/ecfs/document/10513069981230/1] [Comment, NENA: The 9-1-1 Association, https://www.fcc.gov/ecfs/document/10428282759080/1]

28. [Comment, National Telecommunications and Information Administration, https://www.fcc.gov/ecfs/document/1042889209712/1]

29. [Comment, Open PNT Industry Alliance, https://www.fcc.gov/ecfs/document/10428582926330/1] [Reply To Comments, U.S. Chamber of Commerce, https://www.fcc.gov/ecfs/document/10510137267179/1]

30. [Comment, Resilient Navigation and Timing Foundation, https://www.fcc.gov/ecfs/document/10426302821456/1]

31. [Comment, International Bridge, Tunnel & Turnpike Association (IBTTA), https://www.fcc.gov/ecfs/document/10428203750336/1] [Comment, Edison Electric Institute, https://www.fcc.gov/ecfs/document/10428830001344/1] [Comment, Wi-Fi Alliance, https://www.fcc.gov/ecfs/document/10428132781589/1]

32. [Reply To Comments, James Gilb (IEEE 802 LAN/MAN Standards Committee), https://www.fcc.gov/ecfs/document/105062009000660/1]

33. [Comment, Neology, Inc., https://www.fcc.gov/ecfs/document/104280476117508/1]

34. [Letter, Wi-Fi Alliance, https://www.fcc.gov/ecfs/document/1042817716000/1]

35. [Comment, EchoStar Corporation, https://www.fcc.gov/ecfs/document/104282682326740/1] [Comment, Open Technology Institute at New America, Public Knowledge, https://www.fcc.gov/ecfs/document/104291982811791/1]

36. [Reply To Comments, NextNav Inc., https://www.fcc.gov/ecfs/document/1051466194656/1]

37. [Reply To Comments, NCTA - The Internet & Television Association, https://www.fcc.gov/ecfs/document/10514007020338/1] [Reply To Comments, One Ministries Inc, https://www.fcc.gov/ecfs/document/10512801918204/1]

38. [Reply To Comments, Globalstar, Inc., https://www.fcc.gov/ecfs/document/1051313879317/1]

39. [Comment, Parsons Government Services, Inc., https://www.fcc.gov/ecfs/document/10428682515746/1] [Comment, Xona, https://www.fcc.gov/ecfs/document/104290421620204/1]

40. [Comment, Apple Inc., https://www.fcc.gov/ecfs/document/1042813126394/1]

41. [Notice Of Exparte, International Bridge, Tunnel & Turnpike Association (IBTTA), https://www.fcc.gov/ecfs/document/1031499117451/1]

42. [Notice Of Exparte, International Bridge, Tunnel & Turnpike Association (IBTTA), E-ZPass Group, Neology, Inc., https://www.fcc.gov/ecfs/document/105292372113691/1]

43. [Notice Of Exparte, Wi-Fi Alliance, https://www.fcc.gov/ecfs/document/1062785148889/1]

44. [Notice Of Exparte, Avery Dennison Corporation, https://www.fcc.gov/ecfs/document/106102552515979/1]

45. [Notice Of Exparte, NextNav Inc., https://www.fcc.gov/ecfs/document/1061378520739/1] [Notice Of Exparte, NextNav Inc., https://www.fcc.gov/ecfs/document/10613601318105/1]

46. [Notice Of Exparte, Iridium Communications Inc., https://www.fcc.gov/ecfs/document/104242439328735/1] [Notice Of Exparte, Iridium Communications Inc., https://www.fcc.gov/ecfs/document/1062731584657/1]

47. [Notice Of Exparte, America's Public Television Stations, https://www.fcc.gov/ecfs/document/10415611216653/1]

48. [Notice Of Exparte, Astra Navigation, Inc., https://www.fcc.gov/ecfs/document/10602199252965/1]

49. [Notice Of Exparte, oneNav, Inc., https://www.fcc.gov/ecfs/document/107033071820533/1]

50. [Notice Of Exparte, Lisa Dyer, https://www.fcc.gov/ecfs/document/104140814005621/1]

51. [Notice Of Exparte, Dennis Akos, https://www.fcc.gov/ecfs/document/105132802906091/1]

52. [Notice Of Exparte, John Raquet, William Burruss, https://www.fcc.gov/ecfs/document/10331505428967/1]