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On March 27, 2025, the Federal Communications Commission (FCC) launched a proceeding on commercial technologies that would complement GPS. “Although GPS is indispensable to America’s economic and national security, it represents a single point of failure that can be vulnerable to disruption or manipulation by our adversaries,” said the FCC’s announcement, highlighting the federal government’s bipartisan call to develop complementary systems that provide positioning, navigation and timing (PNT) data to to better achieve PNT resilience nationwide and protect America’s economic and national security.

The Security Industry Association (SIA) commends the FCC’s commitment to protecting America’s economic and national security and exploring available PNT options. We believe the docket will show that there is a wide array of PNT technologies that can complement to GPS, and we look forward to providing information to the Commission about tradeoffs among these emerging PNT offerings and encouraging the Commission to avoid taking action that could disproportionately disrupt valuable public safety technologies.

One company, the for-profit entity NextNav, has petitioned the FCC to reconfigure the 902-928 MHz band (the Lower 900 MHz frequency) and grant it a nationwide license for 15 MHz of spectrum so it can establish a 5G terrestrial-based PNT network. NextNav also seeks the removal of the current requirement that it not cause unacceptable levels of interference to Part 15 devices. These devices include low-power, radio frequency (RF) devices ranging from consumer electronics and appliances to wireless alarm systems, smart home equipment, electronic access control devices and a wide range of devices used to increase economic productivity and efficiency, bolster safety, deliver innovation and provide other important benefits to consumers. This proposal has a dangerous likelihood of causing significant interference in the band that would be adverse to the public interest and threaten public safety.

The Lower 900 MHz band is vital for millions of security cameras, including popular models used in homes and small businesses. These devices are essential for protecting homes, preventing package theft and home intrusions, ensuring children’s safety and aiding law enforcement by capturing criminal activity. The changes proposed by NextNav would likely force these incumbent users into a shared portion of spectrum that is almost 60% smaller than the current Lower 900 MHz band — crowding that will cause many devices to stop operating reliably, compromising Americans’ safety and the security of our facilities and communities, and will be exacerbated by the growing concentration of devices using new technologies that require more spectrum bandwidth.

Another important service likely to be disrupted by the proposed band restructuring would be Z-Wave technologies. Z-Wave technology enables comprehensive home automation and security solutions —such as smart locks, thermostats and security systems — to integrate seamlessly with various smart home devices, while preserving advanced security features such as encrypted communication and secure inclusion. Z-Wave devices are not designed to withstand interference from fixed and/or mobile devices operating at commercial macro power limits and out-of-band emission limits, such as those in NextNav’s proposed high-power operations.

Additionally, millions of electronic access control and other wireless connected devices that are now in use in residential, institutional, commercial and government buildings across the United States would be impacted. The interference generated from NextNav’s higher-power communications would significantly impact the reliability of these important safety and security products and ecosystems, effectively making them unusable in the same spectrum.

In addition to these public safety and security uses, more critical systems that could be disrupted include:

• Municipal infrastructure, including such systems as traffic control, street lighting, weather monitors and flood warning systems that are deployed in this band to make communities safer and more energy efficient.
• Critical infrastructure, including utilities’ use of the band for remote monitoring and management of power, gas and water distribution networks.
• Railroad operations and safety, including the Automatic Equipment Identification network that enables tracking of rail cars and equipment, as well as essential traffic control, sensors and other devices necessary for operational safety and efficiency.
• Highway infrastructure and tolling, including the operation of electronic tolling systems, such as E-ZPass and other similar toll collection systems.
• Retail, manufacturing and supply chain operations, including building control…