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FCC seek comments on NextNav petition for rulemaking on lower 900MHz ISM band (fcc.gov)
168 points by pera 4 months ago | hide | past | favorite | 106 comments



I just don't understand how the FCC can justify just giving away spectrum forever to the first person to ask.

They should instead hold an auction every decade for every bit of commercial spectrum. Winner can use it for 10 yrs. Stagger the auctions so a new chunk in each band is coming up for auction every month.

Nothing should be given away forever. Not even the 2.4 Ghz wifi band. One day there will be a better use for that band, and one bloke running his 50 year old wifi camera shouldn't be able to shut down the new use for a whole city block.


So all the tech you bought fails when the company doesn’t renew? Although uk works on auctions and they work.

Perhaps combine with restrictions on use - if you don’t use the spectrum, or use more than you need, it gets taken away


nearly all wireless devices in your home use unlicensed spectrum (2.4 Ghz wifi, bluetooth, ISM for car remotes, etc).

Licensed spectrum is nearly always used by subscription services - eg. your cell phone service.


> Nothing should be given away forever. Not even the 2.4 Ghz wifi band

Given this line, how exactly is this response a defense of your original comment?


I get the impression from their wording that the licensed and unlicensed bands would have different thresholds and rules.

For unlicensed, it wouldn't be about registration, it would be about making effective use. It's hard to imagine a situation where nobody is making good use of 2.4GHz, so it should stay unlicensed, but the aspect of effectiveness is still there. Occasionally old tech that is acting like a noise blaster might need to be culled.


Victory Coffee and Gin might taste interesting the first time...


>I just don't understand how the FCC can justify just giving away spectrum forever to the first person to ask.

Strong agree, which is why they've traditionally licensed transmitters at specific sites. The coordination of use of a limited resource is the proper role of the FCC.

>They should instead hold an auction...

Strong disagree. Any auction is a tax, that gets increased and passed along to users. The whole idea of making a "profit" from the airwaves is a premature (and evil) optimization.

Part of a broadcast license should be expanded to include operating a timing and navigation beacon, supplied and maintained by the government, which transmits precision timing (via local atomic clock(s)) and thus can be coordinated with others to measure position. This should also apply to all cell sites.

Also, the shutdown of ground based navaids by the FAA should be reversed as much as possible. Full ground coverage in the event of a GPS loss should be maintained.


> Any auction is a tax, that gets increased and passed along to users.

The FCC is a cost center. Enforcement costs needs money which comes from taxes (auction or income). So to me it's a wash regardless of where the money comes from.

The market is the most efficient form of pricing a scarce resource (bandwidth in this case) so it makes sense that an auction is the appropriate way to sell it.


The market has been such an efficient form of allocating spectrum that WiFi et al. in the few blocks for public use push the vast majority of bits out there, while the other 70% of precious spectrum we sold to companies for exclusive use nickel and dime you on the gigabyte. Great fucking success story that is.

They even have the audacity to make up things like "WiFi calling" that push you to the public spectrum while still charging you. The market really figured that one trick out.


For some bands, the opportunity for abuse is low because it's only allowed to be used at low power or for voice or other limitations that don't scale up much. But cellphone data has more demand than the spectrum can provide. If they didn't charge users, some people would try to hog all of it and ruin it for everyone. Same goes for broadcast radio transmission. Access has to be restricted somehow. If not by payment, then probably something that makes less efficient use of it like non-transferrable first-in-first-served or lottery.


Wouldn't this lead to a spectrum monopoly and the death of family radios, home wifi, etc.?

The market may be "efficient", but I don't want my radio regulator to optimize for cost alone, rather for balancing a variety of different needs, ranges, and durations like they are now.


First, I would argue we haven't efficiently used the bandwidth at all. In many places you'll find large swaths of bandwidth not being used at the moment. This gets particularly more pronounced at night.

E.g. Why can't I use FM frequencies that aren't being used in the area for my personal use of a few hundred feet? Why can't I use the frequencies the local car dealership is using after 6pm when they've closed for the night?


I'd agree with that, and wish we could phase out many of the old analog frequencies and relicense them for use with more efficient digital encodings.


Digital encodings are analog down deep under everything, and often they are far, FAR less reliable when you don't have 20 dB+ s/(s+n). Analog at least degrades in a fairly transparent and predictable manner. Many public service departments across the country are giving up their old "vhf" channels... and then regretting it when the new UHF digital stuff just doesn't work half the time.


Almost any channel adaptive digital encoding (ie. where the sender gets feedback from the receiver about how much data is successfully arriving) will end up sending more useful data than any analogue scheme in any conditions.

Super weak voice channel where you can barely make out any words? That same channel, with the same transmit power, will get a decent telephone quality digital voice down, as long as you use modern low bitrate audio encoding. And it would send pages of text per second if you can handle typing not speaking.


FT8 I think is a great example of low power digital working well.

It's not huge amounts of data or traffic, but it seems to be fairly reliable.


I see. Thanks for the input!


Also, there should be no reserve price. If just one person bids, then rent it to them for a dollar.

Then the outcome becomes effectively the same as the current "just ask nicely" system, whilst there aren't many people wanting to use the bandwidth.


> Not even the 2.4 Ghz wifi band.

I think the problem for something like this is that devices have chips hardcoded for this spectrum and have been shipped. And it is not like cellular, where the provider goes away and then all the phones/devices stop working. People can have 2.4ghz routers talking to 2.4ghz devices in their house, and they will work basically forever. Is this tragedy of the commons?

even so, I do agree with you. I think there should be a "for limited time" clause for spectrum, but like patents, not like copyright.


If I were the FCC, I would issue "transmission licenses" valid for 10 years, to anyone who wants one for the unlicensed bands. The license would be a signed digital file shipped on hardware. They would work like let's encrypt - when nearing expiry, your device could auto-renew its license via the internet. It could transmit its license via a wifi beacon packet, allowing other devices to use the license too (with the same expiry time).

Basically, if your device is offline for 10 years, and isn't in range of any other online device for 10 years, then it will stop working.

The license would list frequency bands and power levels. That allows the FCC to decide to limit power later, or reduce/widen frequency ranges, and devices already in the field will start to comply within 10 years.

A few bands intended for less smart devices (ie. doesn't have both transmit and receive, isn't digital, doesn't have a clock or storage, etc) wouldn't require such licenses.


From a security angle, I'm not sure that I want to connect every transmitter to the internet if it doesn't have a natural reason to be. It may make sense for a WiFi access point, but if something doesn't need internet connection to function, adding that attack surface comes with a cost.


> Nothing should be given away forever.

Government should auction all property (land plots) every 10 years too?


Some countries kinda do this. Either by the government owning large chunks of the land and renting it to the citizens, or the government having large land taxes, which if unpaid the land reverts to the government.


99 years or 999 years. AKA a leasehold


Those are quite different lengths in practice. 99 is less than some individual humans have lived. 999 is longer than any* country has continuously lived.

If I have a 999 year leasehold, that's the same as ownership in practical terms as my ownership goes away when the government fails and is replaced/taken over/overthrown.

In tech specifically, a 99 year lease is practically permanent as well. (1925 was before the first RF transmission of a television picture.)

* Maybe Japan is an exception here.


Contenders: Denmark, Hungary, China, Czechia, France, England and a bunch of others depending on how you count, like Georgia, Russia, Ukraine, Sweden etc.


Nobodys claiming no group of people lived in Denmark, Hungary, China, etc for 999+ years.

They're claiming none of their governements is over 999 years old.

Denmark's constitution is from 1849 [1].

Hungary's constitution is from 1949 / 1989 [2].

China's government is form 1949 (when the previous government got overthrown and went to Taiwan) [3].

I'm not going through the whole list.

[1]: https://en.wikipedia.org/wiki/Denmark#Government_and_politic...

[2]: https://en.wikipedia.org/wiki/Politics_of_Hungary

[3]: https://en.wikipedia.org/wiki/Government_of_China


Yes, we should have a Land Value Tax to replace income tax.


As a government entity they should be optimizing for 'public benefit' not auction revenue. Licenses should be for who can make the best use of the spectrum.


We need to expand ISM license-free zones to facilitate experimentation and development, not shrink them even more. 902-925 is not ISM in Europe and it sucks. Don't let them take it from you over in the US!


What I notice when I travel with a scanner is that the US West Coast and East Coast are entirely different in terms of radio, that includes not just inland areas but also the area around New York City.

The 2 meter band for instance is back to back busy with people speaking English, Spanish and other languages in L.A. but if I scan for a while in NYC I’ll eventually hear two people talking on a repeater.

So far as I can tell startups in the Bay Area try to develop 900 MHz devices and come to the conclusion that the band is too crowded because every Stanford student and his uncle is testing some gadget they made. If somebody tried that in the Research Triangle Park area, however, they’d probably wonder if their receiver was dead.

So more products dogpile in the 2.4G band which is crowded everywhere.

The situation is at the most blatant where it seems the utilization of TV channels is much less than 10% on the East coat because our cities are too spread out for it to be easy to cover people but are too close together to be able to reuse frequencies. Thus you can get more channels than some cable plans with just a pair of rabbit ears in LA but it is not like that in NYC where reflections are so bad in the canyons I wouldn’t count in tuning into anything in Manhattan.


> Thus you can get more channels than some cable plans with just a pair of rabbit ears in LA but it is not like that in NYC

In LA I think part of that is the repeaters on every mountaintop in the area. Most of LA county and the Inland Empire have clear line of sight to the San Gabriel mountains and most of Orange County has a clear LoS to the Santa Ana mountains. Both ranges have peaks in excess of a mile above sea level.

Even before digital TV broadcast the VHF dial was full and there were a lot of UHF channels. I'd guess the Bay Area was similar as most of the population has a pretty clear view of some high peaks with repeaters on them.


Are the channels any good? Living in a high rise in Atlanta I could get 100+ OTA digital channels but they mostly sucked. What was interesting was the 4 or 5 channels I could get on Analog though, which I assume were some sort of pirate situation. All random Asian language programming.


> Are the channels any good?

I haven't lived in Southern California for about twenty years now so I can't speak to the current stations but in the 90s and early 00s I recall a lot of the UHF stations were foreign language. The English-language stations mostly aired reruns. So overall the plethora of stations wasn't all that attractive to me personally but the number was impressive.


Looking at the channel listings, there really is a huge amount of foreign language content in LA in a wide number of languages. Today is has to be more than it was in the 1990s because ATSC can fit multiple channels in the bandwidth taken by NTSC.

I'd contrast that to the Syracuse and Binghamton markets which I can both get most of the stations reliably where there are no foreign language channels but quite a few that show reruns of shows like Columbo, Farscape, That 70's show and such as well as news from the BBC and Japan.

This station is crazy powerful

https://en.wikipedia.org/wiki/WSYT

and I can receive it indoors with rabbit ears in an old house which is full of little nails that interfere with radio. (Usually I use a small outdoor antenna, though it is hard to watch broadcast TV now that there is FAST.) People on the other side of Lake Erie in Canada watch for it DX when tropospheric conditions are favorable, on some of those days our repeater opens up an I can talk to them.


2.4G is also the archetypical ISM because USA lobbied ITU-T to make it international garbage band precisely to allow airplanes to use microwaves.

So it's garbage band that works pretty much everywhere.


https://en.wikipedia.org/wiki/33-centimeter_band for info on the current and historical use of this band.

> In 1985, the Federal Communications Commission allocated the frequency band between 902 and 928 MHz to Part 18 ISM (industrial, scientific, and medical) devices. In that proceeding, the band was also allocated to the Amateur Radio Service on a secondary basis meaning amateurs could use the band as long as they accepted interference from, and did not cause interference to, primary users.


Do they have any explanation as to why they somehow _require_ 15 continuous MHz of bandwidth in order to provide basic PNT services? This is exceptionally disruptive for technical reasons that are not clearly enumerated in this notice.


Because they want a nationwide bandwidth block that they can hoard. They don't need 15Mhz for PNT.

This is so they can offer nationwide machine to machine long distance communication. Commercial meshtastic. They spectrum would be entirely theirs across the whole country, and could be used for any purpose. The extra anticompetitive move is that it would kick out and constraint free users of this bandwidth at the same time offering paid services in the same band. Corporate enshitification of the commons.


Less about PNT, more about using it for LTE or 5G, as 15MHz is a standard bandwidth used there.


From Wikipedia: https://en.m.wikipedia.org/wiki/NextNav

On March 11, 2024, NextNav announced it signed an agreement to acquire spectrum licenses covering an additional 4 MHz in the lower 900 MHz band (902-928) from Telesaurus Holdings GB LLC, and Skybridge Spectrum Foundation. NextNav acquired the additional spectrum licenses for a total purchase price of up to $50 million, paid for through a combination of cash and NextNav common stock. The acquired licenses are in the same lower 900 MHz band as NextNav's current licensed spectrum. On April 16, 2024, NextNav filed a rulemaking petition with the Federal Communications Commission to deliver a spectrum solution in the Lower 900 MHz band to facilitate a terrestrial positioning, navigation, and timing network (as a complement and backup to GPS) and broadband.



"NextNav’s Petition for Rulemaking. NextNav asks that the Commission reconfigure the Lower 900 MHz Band by creating a 5-megahertz uplink in the 902-907 MHz band paired with a 10-megahertz downlink in the 918-928 MHz band, shifting all the remaining non-M-LMS licensees to the 907-918 MHz portion of the band. Petition at 28–30."

Hmmm


One should not forget how the FCC gifted the bottom of the 220 MHz band to UPS, who never used it.

https://en.wikipedia.org/wiki/1.25-meter_band#U.S._reallocat...

I have a better idea. Take the old UHF TV channels 70-83 that were re-allocated to AMPS cellular and re-allocate them again.


Didn't that get reallocated to other cellular phones? AMPS band became GSM 850 and later LTE band 5 / 5G band n5.

TV above channel 37 has been reallocated for even more cellular phone use in two more chunks since then.

Cellular phones get a lot of bandwidth, but it's highly utilized.


220-222 MHz is Part 90 now and it is definitely in use.


I'm a bit confused, UPS didn't end up using spectrum it asked for in 1977 to build radio relay stations in 1988, so in 2024, we should take old TV channels and reallocate them to UPS? NextNav?


Overall people are frustrated at so much radio frequency lying fallow. My pet peeve is that the density of commercial TV and radio stations in the U.S. East coast is a fraction of what it is in the West coast. Seems cities in the East are too spread out for a single station to cover much population but too close together to reuse frequencies between cities. Turn your dial on your TV and radio and it is a lot of dead air.


Seems like NextNav is following the The Firangi Rules of Acquisition to Profit at the expense of every existing service in the 902 to 907 MHz band.


Just remember:

If companies could reasonably expect to get away with it, they'd offer murder-for-hire as-a-service so long as it was profitable, and if they didn't, there'd probably be at least one activist shareholder who would push for it.


True Also companies are made of people. There is no magic threshold of size at which bad stuff seeps in


Isn’t that what Blackwater is?


Companies do, just not the ones we read about on Hacker News.


This is statement is so ridiculous. It's like saying "Just remember: some humans are murderers"


Corporations in the US are structured in a way that many will act with ethics much lower than the median ethics of the employees.


The point isn't just that it would happen, it's that it would be rewarded and encouraged, and ethics preventing the most profitable action (murder) would lead to being outcompeted by an organization with a structure that allows its members to coordinate and profit from murder without their ethics preventing such action. i.e. the market will ruthlessly optimize ethics out of decision-making.


We clearly need ground based navigation and time distribution to back up GPS, but it should be run by the Department of Transportation, or the DoD, not rent seekers.


I agree, this is literally what LORAN was/is for navigation (and we can and should build a better LORAN), and for time distribution WWVB and WWV already exist.


LORAN was great for being in the right part of the ocean, but being up to 1/4 mile off when navigating land is unacceptable as a replacement for GPS.

WWV isn't a precision timing source, and is only sporadically available depending on a number of factors.

The best option would be something like a sub carrier on DTV and FM broadcasting, along with a beacon at all cell sites.

Auctions of the airwaves are a hidden tax, and should end.


NextNav is city-wide navigation. It looks like beacone can cover a few miles which makes sense with the frequency. It can also work indoors.

Navigation system like that is useful for more accuracy or when GPS has problem. But not at the expense of 900 MHz band for other useful things. I'm surprised that they can't find an awkward slice of low-band that mobile provider would get rid of or lease.


I have been very interested in 802.11ah halow (wifi in 900mhz ism band) to solve the inconvenient distances where 2.4g wifi has insufficient range, but something like a LTE catM modem is overkill. I'd be very disappointed if this effectively takes over the band nationwide.

Can anyone comment on nextnav's intended duty cycle or just how much they'll occupy? They're asking for a lot of bandwidth, so perhaps it's in a short enough burst and infrequent enough to not cause real problems?


> Can anyone comment on nextnav's intended duty cycle or just how much they'll occupy? They're asking for a lot of bandwidth, so perhaps it's in a short enough burst and infrequent enough to not cause real problems?

According to the FCC doc nextnav plans on "making excess spectrum available for commercial broadband service" (LTE/5G or similar I assume). So, it could be pretty impactful to current users of the band.


> 2.4g wifi has insufficient range

Is this about propagation over obstructed Fresnel zone paths?

I ask because generally 2.4GHz has much longer range than 900MHz due to the much higher gain antennas achievable at higher frequencies.

But if there's something in the way (trees, buildings, a bit of terrain), then 900MHz can work on a path when 2.4GHz doesn't. I suppose that's one definition of "has sufficient range".


Yes, forest is my exact use case, with roving devices that are too cheap to have phased arrays so get stuck on low gain antennas.


How would these roving devices even use a phase array? They are moving. Sounds like you dont want directional coverage and just need repeaters


Have you found 802.11ah hardware? I'm also interested in it but haven't found hardware to play with.


I've been experimenting with the ALFA HaLow HAT [1] for some personal projects. There's also a number of APs good for point-to-point use.

[1] https://www.sparkfun.com/products/19956


So basically they want the FCC to punish a bunch of ISM and Ham users by taking that spectrum more or less for themselves?


>Finally, we seek comment on the windfall that NextNav might receive as a result of its proposed spectrum swap for a new nationwide license, including the acquisition of accompanying rights as a licensee and lessor, the application of flexible use and less restrictive technical rules to this band, and how the Commission should address any such windfall.

Seems like you might want to send in your comments.


The worst part about this is they will be out of business in 10 years, and resold the bands to an existing telecom.

In this day and age, the protocols do not require exclusive control over a band to function in spread spectrum modes.

Pretty douche move, and pissing off 68000 amateur radio folks in an election year may be unwise. =3


The thing with 915 ISM is that it's not just crotchety old Elmer, K0LD, sitting his shack that you're screwing over.

Meshtastic devices are really starting to see uptake among techies in general, and in the US, the primary band they operate on is 915Mhz. It's to the point now that DefCon will put extra strain on the mesh and the project has to release patches ahead of time. If news got there this year, you can count on some jimmies having been rustled.


For sure, some use 900MHz 802.15.4 equipment for industrial, agriculture, and environmental monitoring systems.

People need the lower frequency to punch though the water vapor, and can't get away with <14cm without cutting range.

Using it for 5G bandwidths is stupidly inefficient, as it will cap out at a few hundred users a cell. Maybe they are getting the bands for cheap... lol =)


It's honestly as stupid as that HFT shop that was trying to grab a bunch of shortwave bandwidth for god knows what sort of shenanigans instead of just building microwave towers or doing something else mildly more intelligent.


From the article: “ NextNav asks that the Commission reconfigure the Lower 900 MHz Band by creating a 5-megahertz uplink in the 902-907 MHz band paired with a 10-megahertz downlink in the 918-928 MHz band, shifting all the remaining non-M-LMS licensees to the 907-918 MHz portion of the band. Petition at 28–30.”

So at least all LoRa based applications seem unaffected by this. Though I don’t know how much traffic in the proposed NetNav bands will migrate to 915 MHz bands, crowding the spectrum.


I thought the LoRa "915 MHz" band ran from 902.3 to 914.9 MHz.


"The USA LoRaWAN frequency spectrum has 64 uplink channels available (125 kHz each) (channels 0-63) starting at 902.3 MHz which increment every 200 kHz up to 914.9 MHz. There are 8 additional uplink channels (500 kHz each) (channels 64-71) from 903 MHz which increment every 1.6 MHz up to 914.2 MHz." ( https://www.baranidesign.com/faq-articles/2019/4/23/lorawan-... )


Things in my house that use the lower 900Mhz band already:

- Z-wave network

- Weather Stations

In the past - cordless phones

- baby monitors

Do we have any guarantees that these devices will continue to work?


I'm not super familiar with this so I could be totally misreading this, but assuming those are operating under part 15 the answer to whether they are guaranteed to continue working seems to be explicitly "no" under NextNav's proposal:

>NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices. See Petition at A-6 (proposing to amend § 90.361), A-11 (proposing to add § 90.1410(c)).



Mmm… power meters mesh in that freq range as I recall as well…


These policy tradeoffs are interesting (and tricky) - if you have a huge number of different parties that are unorganized yet impacted by a policy, how do you ensure you have adequate representation from them when compared to a single well-organized party?

> The Petition recognizes that there currently are unlicensed part 15 devices operating in the Lower 900 MHz Band, but it is unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices. With respect to part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.” Id.

> NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices. See Petition at A-6 (proposing to amend § 90.361), A-11 (proposing to add § 90.1410(c)).

Requesting public comment is perhaps better than nothing (and likely better than just allowing lobbyists to influence policy behind closed doors), but it's a hard problem to quantify whether the collected comments are representative when one side is more heavily resourced and organized than the other?

Is it even possible to "work with unlicensed users to understand their spectrum requirements" in a way that doesn't ignore a potentially substantial long-tail of varied usage?


I saw response from LoRa organization in another article. They use the ISM allocation.

That is also amateur radio band and their organization, ARRL, will probably be involved.

There are products, like ZWave, that are in band and might protest. The short-range in-house probably won't interfere with the outside users.


I think the primary benefit of ARRL (and the main reason I'm a member) is that they do regulatory and legislative advocacy for amateur radio bands.

https://www.arrl.org/regulatory-advocacy


Is there a way to restrain what they can use this spectrum for, or is it doomed to be resold to someone else, basically depriving the public of spectrum?


Spectrogram of 902-928 MHz here in Silicon Valley with just an indoor antenna. Tons of power and gas meters pinging away.

https://www.youtube.com/watch?v=GK60cMsBaFo

Make sure to switch to 1080p.


Casually showing off your B210 lol jk, I’m just jealous. My RSP1A clone only goes about 10MHz wide. Patiently waiting for an affordable 30MHz wide SDR.


> The Petition recognizes that there currently are unlicensed part 15 devices operating in the Lower 900 MHz Band, but it is unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices. With respect to part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.”

> NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices. See Petition at A-6 (proposing to amend § 90.361), A-11 (proposing to add § 90.1410(c)). NextNav also states that updating the band to increase flexibility will not impact amateur users.

If you were really going to do the first part then surely you don't need to remove the no interference requirement, right? If the rule is "$new_thing can occupy this spectrum but it must not interfere with existing usages of the spectrum" then what's to discuss, it's a win-win? It seems like the FCC is doing what they need to and making them actually specify what is required to not interfere with existing users so it can be made part of the rule. So I guess I'll hold my breath and see what they come up with.


When the FCC licenses off spectrum they should collect an upfront fee and perpetual royalty fees that should be used to pay down the public debt (or some other use that can't be politicized), unless the use is primarily for the public good. I don't know anything about NextNav but AI says...

>will Metropolitan Beacon System charge a royalty for devices to use its network?

>Yes, the Metropolitan Beacon System (MBS) developed by NextNav is a proprietary technology, and it is likely that there will be charges associated with using its network. These charges could include royalties or licensing fees for devices that utilize the MBS network for precise location and timing services


My friends are running a company called FOAM Space that has also put a lot of research into 3D terrestrial-base positioning [1]. Their system, though, can also make "claims" about the position, which is a cryptographic proof that the object that created the claim was at location X at time Y. So, not only you can find where you are but you can also you prove to others that you are there. They use unregulated LoRa bandwidths to operate.

[1] https://foam.space/

EDIT: typos



This company seems to be publically traded -- should we all buy it's stock and take it over ?


Just a reminder, this is a request from the agency for comments from the public. That means you. If you are opposed to the proposal then make your feelings heard by submitting them at https://www.fcc.gov/ecfs/filings using proceeding/docket # 24-240.


Every. Single. USA based HNer. Stop right now and file a comment against.

To quote another HNer:

> If you are opposed to the proposal then make your feelings heard by submitting them at https://www.fcc.gov/ecfs/filings using proceeding/docket # 24-240


What should we say? I'm a licensed ham, meshtastic user and z-wave user but I'm not sure exactly what to include in an FCC comment that would be useful, other than "Hey! I use this!".


You could say it's unethical, you use the spectrum, it leaves regular citizens even less experimental bandwidth, it's never coming back after it's gone, and there is an enormous amount of privately held spectrum in the USA they could purchase rather than seizing a public resource.


I used Claude to draft something, might help others submit comments:

RE: WT Docket No. 24-240, RM-11989

To the Federal Communications Commission:

I strongly oppose NextNav's petition to reconfigure the 902-928 MHz band. As an amateur radio operator and user of various devices operating in this spectrum, I believe this proposal would have significant negative impacts on both hobbyists and consumers.

1. Impact on Amateur Radio: This band is crucial for amateur radio experimentation and innovation. I personally use it for Meshtastic devices, which provide valuable experience in mesh networking and could be vital for emergency communications. Displacing these activities would hinder technological advancement and public service capabilities.

2. Consumer Device Disruption: Many common household devices operate in this band. For example, I use Z-Wave devices for home automation. The proposal could render these devices inoperable, forcing consumers to replace expensive equipment and potentially reducing the availability of affordable smart home technologies.

3. Unlicensed Innovation: The 902-928 MHz band has fostered significant innovation in unlicensed devices. Restricting this spectrum could stifle future developments in IoT, smart cities, and other emerging technologies that rely on license-free operation.

4. Inadequate Protection for Incumbents: NextNav's vague assurances about working with incumbents are insufficient. The proposal lacks specific, enforceable protections for existing users, including amateurs and Part 15 devices.

5. Potential Windfall Concerns: The proposed "spectrum swap" appears to grant NextNav significantly more valuable spectrum rights without clear public interest benefits. This raises concerns about equitable spectrum management.

6. Alternative Solutions: The Commission should explore alternative methods to support PNT systems that don't involve disrupting a heavily used and innovative spectrum band.

I urge the Commission to reject this proposal and maintain the current diverse ecosystem in the 902-928 MHz band, which supports amateur radio, consumer devices, and technological innovation.

Respectfully submitted,

[Your Name]

Amateur Radio Operator, [Your Call Sign]


I would have to imagine the manufacturers of the millions of smart electric, water, and natural gas meters across the US might have some comments.


This is bullshit taking from the commons. I abhor the writing style of this document which might be "obvious" to an FCC insider, but this is clearly an unmitigated theft.


I agree, the problem is the widely held belief that neutrality in writing is possible and positive. It's not possible for information to be presented without bias, even when done in the best of faith. Attempting to be neutral itself is of course biased by the experiences and information that has led one to an understanding of what "neutral" is. Neutrality is however a fantastic tool for hiding bias and ultimately that is (I think, at least) the reason it's such a popular idea.

I think transparency actually gives the benefits that neutrality claims. Everything I think and do has bias, I will (as best I can) tell you what my biases are and let you evaluate that how you will.


highly recommend people read Master Switch by tim wu. In part talks about how the FCC in the past has destroyed competition and progress.


What would this potentially do to Z-Wave devices?


Great question. I’m wondering the same. According to Wikipedia:

> in Europe it operates at the 868-869 MHz band while in North America the band varies from 908-916 MHz when Z-Wave is operating as a mesh network and 912-920 MHz when Z-Wave is operating with a star topology in Z-Wave LR mode.

So there definitely would be overlap in North America.


Is this going to mess up LORA at 915 MHz? Because a lot of people I know will be upset.


"NextNav’s Petition for Rulemaking. NextNav asks that the Commission reconfigure the Lower 900 MHz Band by creating a 5-megahertz uplink in the 902-907 MHz band paired with a 10-megahertz downlink in the 918-928 MHz band, shifting all the remaining non-M-LMS licensees to the 907-918 MHz portion of the band. Petition at 28–30."

This suggests they'd leave 915 alone?


Most "915MHz" devices are just naming the center of the band, and can operate anywhere within it, or across the whole thing. Nothing operates at a single infinitesimally-narrow frequency except a pure unmodulated sine wave, which carries no information. As soon as you modulate it, you occupy a range. The more modulation, the wider the band.

I have a basement full of Ricochet hardware that operates across the whole band, and it occasionally proves useful for data links that're tricky in other ways. It'd all be junk if this goes through.


902-928 MHz IS the 915Mhz ISM Band currently.

They're requesting more than half of that space.




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