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The Open Technology Institute (OTI) at ¹ú²úÊÓƵ and Public Knowledge (PK) submitted to the Federal Communications Commission (FCC) on the Notice of Inquiry on "Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions." There are many viable options for additional Position, Navigation, and Timing (PNT) systems in the United States. We encourage the Commission to prioritize solutions that offer the most accurate, reliable service while imposing the least costs and disruption to consumers. To that end, we recommend that the Commission reject NextNav’s proposal for a PNT service, as it would come at the expense of the incumbent unlicensed users of the lower 900 MHz band.

The OTI and PK agree wholeheartedly with the Federal Communications Commission’s intention to uplift one or more additional PNT systems to complement or serve as an alternative to the current U.S. Global Positioning System (GPS). GPS offers vital services that span industries and the globe, and we agree that our current reliance on GPS alone leaves us vulnerable to critical disruption, whether intentional or accidental. Diversifying our reliance on critical infrastructure is best practice.

OTI and PK encourage the Commission to facilitate the use of multiple technologies or services that offer the necessary security and quality at the least cost and while doing the least harm to other, existing services. Importantly, OTI and PK advise the Commission to give a wide berth to NextNav’s suggested PNT service. NextNav’s proposal hinges on upending a band that currently houses unlicensed Part 15 devices that power every aspect of the economy. There are better options that do not.