The LORA Alliance formally filed its comments in opposition to Nextna’s rulemaking petition, which is currently pending with the United States Federal Communications Commission (FCC). The simple fact is that if NextNav succeeds and the FCC proposes rules on NextNav in the 902-928 MHz band, it will pose significant risks to the fast-growing Internet of Things (IoT) market in the United States, harming communities. and businesses across the country.
The unlicensed band is used for a variety of services including industrial, scientific and medical equipment (ISM); Location and Tracking Service (LMS) systems; Federal Radiological Site; Part 15 Unlicensed Devices; and amateur radio operators.
This band must be compatible with licensed users of the Services Part 15 unlicensed devices. This demand allowed manufacturers to create and market countless unlicensed commercial and consumer products and devices for this band.
NextNav position
However, the NextNav petition proposes to remove that protection, jeopardizing the reliability of Part 15 devices and the reliance on consistent FCC regulation in the 902-928 MHz band, which is absolutely necessary for investments. NextNav seeks access to additional prime spectrum holdings in the 902-928 MHz band, which, if granted, would affect the current operation of billions of devices using unlicensed spectrum.
Nextna’s petition says the band isn’t underutilized, given the fact that it has a vibrant ecosystem of Area 15 users with billions of devices––most of these supporting IoT applications––operating in the band. After many ecosystems have built their products and technologies in good faith, a decision by the FCC at this point would cripple spectrum users in the United States. Continuing discussions about this ill-conceived proposal creates uncertainty and undermines confidence in FCC regulations. Prevents future inventions in unlicensed bands. The LoRa Alliance strongly urges the FCC to close this document and reject NextNav’s request.
Our full response to this situation can be found here. We are a signatory to the US Chamber of Commerce’s response, among others.
What is at stake?
The LoRa Alliance, along with several Area 15 technical groups, are concerned about the impact of NextNav’s proposal on the installed base and future applications of their devices. NextNav’s request limits LoRaWAN operations to 60 percent of the available band. The coexistence mechanisms developed by the FCC for the billions of devices on 26 MHz will certainly be impossible on the remaining 11 MHz, which means that all the unlicensed services described above will not work, breaking existing solutions and weakening competition in the US for IoT technologies.
It should be noted that LoRaWAN is far from the only technology affected by the technology. Many other technologies report similar concerns. To cite a few examples, the RAIN Alliance estimates that there are at least 80 billion items tagged with RAIN RFID in the United States, the Z-Wave Alliance estimates that more than 100 million spread-spectrum Z-Wave devices are in use, and E-ZPass estimates that nearly 60 million E-ZPass devices are in use. Transponders are used and generate nearly 5 billion transactions per year.
From Wi-Fi and Wi-SUN to amateur radio operators, the defense industry, emergency services and many other spectrum users face disruption or loss of access. From its proposal the U.S.
Impact on business
The potential impact on American businesses and communities is undeniable. The LoRaWAN standard is well established as an important IoT networking solution across the country. Tens of thousands of sensors are deployed, and hundreds of millions are planned over the next few years in thousands of cities and rural areas, supporting a wide range of use cases. LoRaWAN network flexibility is essential in densely populated urban environments, supporting critical, non-commercial applications, such as sparsely populated rural areas.
LoRaWAN networks are used to improve sustainability and improve quality of life through thousands of applications in various markets such as smart agriculture, smart industry, smart healthcare, smart logistics, smart cities, public safety, environmental monitoring, and more.
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