A related document that may be of interest was filed by NextNav, which was presented to the FCC on 27-Feb:
Simulation study concluding that there is no risk of disruption to any other services from the proposed reconfiguration of the licensed bands and change in licensing limitations. One thing I spotted is that the study assumes the maximum ERP from NextNav will
be limited to 4W (36 dBm). This contrasts with the petition for rule making in which they ask the FCC to allow operation at "full power" as allowed in Part 27. The latter ask is more consistent with some of the other claims of benefit in the petition (e.g.
large area coverage, indoor navigation).
And important point is that 802 technologies currently provide the navigation and positioning services that NextNav includes in their estimates of economic benefits. 802.15.4 provides much more precise indoor navigation, for example, at less than 1/4000th
of the peak ERP assumed in the simulation study, millions of times less power of part 27 limits they ask for in the petition, at far lower energy consumption and zero potential to impact existing uses of the 902 to 928 band. 802 standard based UWB is present
in many millions of consumer devices already and is rolling out in devices such as enterprise access points, ideal for providing indoor location and navigation services which NextNav claimes are critical. We could also point out that 802.11, provides performance
similar to the NextNav claims at similar power levels assumed in the simulation study (36 dBm), and many orders of magnitude less than part 27 limits - with economic benefits to operators compared to the NextNav sub-licensing model.
We also should ask the FCC that any reconfiguration of the band limit total ERP to what is assumed in the simulation study, or lower, rather than part 27 limits as requested in the petition. My suggestion is a limit of 1W as specified in 15.247 (the rule under
which 802.11 and 802.15.4 technologies operate in the 902-928 band). The current 15.247 limits have been very effective in promoting innovative and efficient use of the spectrum for quite some time.
A couple points to consider, FWIW.
Ben
On 3/9/2025 2:28 PM, Edward Au wrote:
Dear 802.18 participants,
cc. 802.11, 802.15, 802.19 participants,
For the upcoming March 2025 FCC Open Commission Meeting, one of the agenda items is "Exploring Alternatives to GPS" and the commissioners will vote on a draft Notice of Inquiry (NOI) on Positioning, Navigation, and Timing (PNT).
Of possible interest to us is paragraph 29 about a proposal to reconfigure the 902 MHz to 928 MHz band for PNT, that may affect the current deployment of IEEE 802.11 and IEEE 802.15 based devices operating in the same band.
For details, please visit
https://docs.fcc.gov/public/attachments/DOC-410031A1.pdf
If the motion in the FCC Open Commission Meeting carries, then the comment deadline and the reply comment deadline are 30 days and 45 days, respectively, after the NOI is posted on the Federal Register (https://www.federalregister.gov/).
I would encourage you to bring any contribution or draft response to IEEE 802.18 to review and discuss as soon as possible, given we typically need 2 additional weeks for LMSC to review and approve if the motion at IEEE 802.18 carries.
Regards,
Edward
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Benjamin A. Rolfe
Blind Creek Associates
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+1 408 332 0725 (Mobile)
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