= NOW 18 WPM transition file follows =

The Federal Communications Commission accepted for public comment a
Petition for Rulemaking filed by NextNav Inc., a licensee in the 900
MHz Location and Monitoring Service, to completely reconfigure the
902 to 928 MHz band and replace the LMS with high powered 5G
cellular and related location services.  The FCC Notice requested
comment on the effects that NextNavs proposals would have on amateur
radio operations in the band. ARRL is preparing comments urging
protection of existing and future amateur uses in this band and
urges all amateurs to file their own comments describing their
activities in this band and the expected effect of the proposed
changes. Click here for a guide to filing comments.  NextNav
currently holds licenses in the 900 MHz band that authorize it to
provide services limited to determining the location and status of
mobile radio units.  NextNav ties its request to provide high power
broadband, cellular and location services to the vulnerabilities of
the current satellite based GPS system and argues that
implementation of its proposal would complement GPS by providing an
alternative nationwide terrestrial location system in addition to
cellular and broadband services. Under its proposal, NextNav would
be designated the sole nationwide licensee for this spectrum in
exchange for its more limited licenses.  The new nationwide license
would authorize NextNav to provide much higher powered traditional
broadband and 5G cellular services as well as the related location
service occupying 15 of the total 26 megahertz available in the
band. The reconfiguration proposed by NextNav would create a 5
megahertz wide uplink subband at 902 to 907 MHz paired with a 10
megahertz downlink subband at 918 to 928 MHz.  The 5 megahertz
uplink subband would be limited to use by mobiles with a maximum of
3 watts ERP.  On the 10 megahertz downlink subband, up to 2000 watts
ERP would be permitted in rural areas and 1000 watts ERP in urban
and suburban areas, radiating from tower structures that could reach
1000 or more feet above average terrain.  These configurations
reflect the FCCs rules for standard cellular configurations that
have been adopted to govern a number of other bands used for similar
5G and like services.  Although uses by the Amateur Radio Service in
this band are secondary to LMS, NextNav is proposing substantial
technical and use changes that would completely alter the foundation
upon which the current rules and spectrum sharing arrangements rely
and undercut shared use of the band by amateurs as well as a variety
of other users.  In addition, NextNav proposes deletion of a
specific interference provision in the Commissions rules that was
adopted to encourage and protect continued sharing with amateurs and
other secondary users.  NextNav, in its petition, argues without
evidence that the changes that it proposes to the 902 to 928 MHz
band will not impede amateur operations.  In an 8 page description
of NextNavs proposal released by the FCCs Wireless
Telecommunications Bureau, the FCC staff asks a series of questions
that would clarify the proposal and help the Commission ascertain
the likely effect of the proposed changes on existing users if the
requested changes were adopted.  Comment was specifically requested
on the extent of amateur operations in the band, the potential
impact of the proposed changes, any other spectrum options that may
exist, and the costs for relocations if other options exist.  ARRL
is preparing comments urging protection of existing and future
amateur uses in this band.  ARRL urges all amateurs to study the
proposal and file their own comments describing their activities in
this band and the expected effect of the proposed changes. The
filing deadline is September 5, 2024.  Replies to comments are due
by September 20, 2024.  Information on how to file comments can be
found at, //www.arrl.org/ .

= END OF 18 WPM transition file <