A look at the main concerns noted during the comment period.
America’s Global Positioning System (GPS) is simultaneously amazing, indispensable and vulnerable. If its positioning, navigation and timing (PNT) signals were to become unavailable for any reason, the nation and its citizens would be irreparably harmed. So says the Federal Communications Commission (FCC):
“Although GPS is indispensable to America’s economic and national security, it represents a single point of failure that can be vulnerable to disruption or manipulation by our adversaries,” according to an FCC news release.
At the same time, many of America’s adversaries, most notably China and Russia, have terrestrial sources of PNT in addition to those from Global Navigation Satellite Systems (GNSS). This makes GPS satellites and signals particularly attractive targets in any great-power conflict. Many observers have opined this is occurring at a low level already, with Russia interfering with GPS signals in northern Europe to punish its neighbors for growing closer to the west.
The FCC’s Interest in PNT
While the responsibility for PNT policy and leadership in the U.S. nominally lies with a committee co-chaired by the Department of Defense (DoD) and Department of Transportation (DOT), the government body most vocal and engaged with the public on PNT issues of late has been the FCC. At first glance, this might seem a non-sequitur. The FCC is an independent agency (i.e. not part of the executive branch) and is tasked with regulating the nation’s use of spectrum.
Yet, the commission has been engaged in PNT issues before. Most notably, the long running and still-contentious Lightsquared/Ligado controversy.
Lightsquared, and then its successor Ligado, petitioned the FCC for the right to transmit on frequencies adjacent to those used by GPS. Despite strenuous objections from the executive branch, including vociferous opposition from the DoD and the DOT that this would deny or degrade GPS reception for many users, the commission approved the request in 2020. And despite seven petitions for reconsideration filed that year, a subsequent National Academy of Sciences report affirming interference concerns—and Ligado filing for bankruptcy—the commission’s decision still stands.
The FCC’s most recent engagement with PNT issues, former Commissioner Nathan Simington said, resulted from his long-standing concern that PNT is a huge national security issue and the two pending petitions that seek to address that issue.
The first petition is from NextNav. It asks for approximately $5 billion worth of spectrum to be reallocated for its use. NextNav plans to use this spectrum to work with telecommunications companies and establish a 5G telecommunications-based PNT system, according to the company.
The second petition is from the National Association of Broadcasters (NAB). It asks that the FCC establish a schedule for adopting a new television broadcast format called ATSC 3.0. The new format brings a number of advantages, according to the group, such as the ability to include PNT signals.
This confluence of issues resulted in a 27-page Notice of Inquiry (NOI). At the FCC’s March 2025 public meeting, Chairman Brendan Carr had this to say about the NOI:
“With this inquiry, we will explore other PNT systems that can be complements or alternatives to GPS, with an emphasis on complementary systems. Beyond answering technical questions, we hope this effort will engage stakeholders across government and industry to encourage the development of new PNT technologies and solutions.”
What You Had to Say
More than 140 comments filling nearly 1,300 pages were filed to the docket during the fairly brief 47 day period allocated for comments and reply comments.*
Here are a few themes:
America needs a more resilient system of systems PNT. There was near universal agreement with the FCC’s conclusion that the nation’s PNT was in dire need of an upgrade. Most respondents said they appreciated the commission’s efforts. Many cited the need for a system-of-systems approach, discussing it as “multi-layered,” “diversified” and a “PNT fabric,” or by citing the need for a variety of diverse sources, such as terrestrial broadcast, fiber and space-based systems, used in combination.
Endorsements of terrestrial broadcast PNT. The next most frequent comments were positive mentions of terrestrial broadcast systems. The National Association of Broadcasters’ Broadcast Positioning System (BPS), also described as ATSC 3.0, received the most mentions, and eLoran was cited a dozen times. A few concerns were expressed about the cost impact of mandating ATSC 3.0 on independent television stations.
Referendum on NextNav’s petition. While the commission is still considering NextNav’s petition in another docket, many of the respondents saw the NOI as another opportunity to comment on that proposal. More than two dozen commenters (over half of which were industry associations) urged the FCC to deny NextNav’s petition. Another five cautioned against actions that would impact existing spectrum users without specifically mentioning NextNav. Only three organizations that weren’t NextNav or one of their business partners urged the FCC to approve the request.
Space-based PNT. A significant number of respondents recommended better use of GNSS, implementation of low Earth orbit (LEO) PNT and/or other space-based assets without mentioning other systems.
Policy issues. While the NOI asked about a number of interesting policy issues, most respondents focused their replies on technology. The most frequently mentioned policy issue was the desire to avoid regulatory mandates, with some of those comments tempered saying “no unnecessary mandates.”
What’s Next?
The FCC has not given any indication of next steps with the information generated by the NOI. Whether it is incorporated into its calculus for the NextNav, NAB or other petitions or decisions is entirely up to the commission.
Former commissioner Simington argues that regardless of how the chairman and commission elect to proceed, the NOI was exceptionally important. The commission has always been a political body and remains one today. Public input like what was provided through the NOI is critical in decisions that have a significant political component.
Regardless of the FCC’s next moves, it’s clear America has a wealth of mature, commercially available, technologies. Government leaders have a responsibility to leverage some of these and establish a Core National PNT Architecture, if only to protect government systems and applications with resilient PNT. This will reinforce the administration’s messaging around resilient PNT, and more importantly, create a framework industry can build on, integrate with, and enhance.
