A live fight over the United States’ lower 900 MHz band shows why the hardest lobbying campaigns are no longer arguments about whether innovation is desirable. They are arguments about engineering assumptions, installed systems, transition costs and who carries the operational risk when policy changes.

By Frank Farnel | Responsible Public Affairs | October 5, 2026

Executive Summary

• NextNav has asked the Federal Communications Commission to reorganize the 902–928 MHz band so that a nationwide 5G-based terrestrial positioning, navigation and timing network could complement and back up GPS. The company also proposes broadband use of 15 MHz under a new flexible-use license. The FCC opened a public record in 2024 but has not decided the petition.
• The latest phase is a sharp coalition response. Letters reported on October 2 were signed by 80 companies and associations in one case and 62 in another. Because some organizations signed both, those figures cannot be added. The joint campaign represents more than 100 distinct businesses and trade groups, according to the reporting.
• The dispute is not a simple contest between innovation and incumbency. It concerns whether high-power licensed operations can coexist with tolling, logistics, security, utility, industrial and consumer devices already using the band; how representative competing tests are; and whether transition costs can be identified, allocated and enforced.
• For public-affairs leaders, the case illustrates a wider principle: in technical rulemaking, influence depends less on rhetorical access than on the quality of the administrative record. The decisive advocacy assets are reproducible evidence, transparent assumptions, credible implementation commitments and a coalition whose operational exposure can be documented.
• Two earlier spectrum conflicts reinforce the point. The FCC’s conditional authorization of Ligado and the negotiated rollout of 5G C-band services near airports show different outcomes when regulators must reconcile new network value with interference and safety concerns.

The Latest Development: Two Letters, One Regulatory Contest

On October 2, Broadband Breakfast reported that more than 100 companies and trade associations had asked senior administration officials to oppose elements of NextNav’s plan for the lower 900 MHz band. One letter, addressed to National Economic Council Director Kevin Hassett, carried 80 signatures. A second, to Transportation Secretary Sean Duffy, carried 62. Walmart, Boeing, Duke Energy, major airlines, tolling interests and several national trade associations were among the participants.¹

The arithmetic matters. Eighty plus 62 does not establish 142 opponents because some signatories appear on both letters. Coalition size is often used as a proxy for political weight, but duplicate counting can turn a legitimate campaign metric into a misleading claim. The supportable description is the one reported by the publication: more than 100 companies and associations across the combined effort.

The letters also show a deliberate change of venue. The formal technical proceeding belongs to the FCC. Yet opponents wrote to economic and transportation officials because the policy consequences extend beyond radio engineering. Retail inventory systems, highway tolling, logistics, aviation, utilities and critical infrastructure all translate interference assumptions into operational and economic exposure. The advocacy strategy is therefore to make a specialist spectrum docket legible to officials responsible for economic resilience and transportation continuity.

That move does not resolve the merits. NextNav’s government-affairs chief responded that the questions belong before the FCC’s engineers, where coexistence, interference and positioning resilience can be evaluated through a fact-based process. That is not merely a defensive message. It is a claim about institutional competence: the company is arguing that a technical regulator, working from a disclosed record, should decide the issue rather than a coalition campaign or an appropriations rider.¹

The status therefore needs to be stated precisely. The FCC has not approved NextNav’s proposed band reconfiguration. The existence of an agency filing under executive review does not prove that a forthcoming notice will adopt the company’s architecture. Opponents have said that they fear a future FCC proposal may incorporate elements of it. That is a reported expectation, not a Commission decision.

What NextNav Is Actually Asking For

The lower 900 MHz band spans 902–928 MHz. It is not an empty block waiting for a single modern use. The FCC’s August 2024 public notice describes a layered environment containing federal radiolocation, industrial, scientific and medical equipment, licensed location and monitoring services, unlicensed devices and other operations governed by different rights and interference expectations.²

NextNav’s April 2024 petition asks the FCC to change that architecture. The proposed band plan would create a 5 MHz uplink from 902–907 MHz and a 10 MHz downlink from 918–928 MHz, with other incumbent operations concentrated in the intervening spectrum. NextNav seeks a nationwide 15 MHz flexible-use license that would support a terrestrial 5G network capable of delivering positioning, navigation and timing, or PNT, while also supporting broadband services.³

The public purpose is substantial. GPS underpins transport, telecommunications, finance, emergency response, energy systems and countless commercial applications. It is also vulnerable to jamming, spoofing, obstruction and disruption. A 2022 Government Accountability Office review found weaknesses in the Department of Transportation’s processes for identifying interference incidents and called for a more documented, cross-modal approach to resilience.⁴ In March 2025, the FCC unanimously opened a broader inquiry into alternative and complementary PNT technologies. That inquiry expressly took no position on the merits of the NextNav petition and treated the two proceedings as independent.⁵

NextNav’s proposition is that a terrestrial, standards-based network could answer a recognized national need without requiring a wholly taxpayer-funded infrastructure. The company says 5G technology, low-band propagation and its existing spectrum position can provide wide-area and indoor capability while preserving coexistence opportunities. It has published studies and demonstrations concerning RFID, tolling, security equipment and timing performance.⁶

Opponents do not necessarily dispute the need for resilient PNT. Their argument is narrower and more consequential: this particular band plan could impose interference, equipment replacement, retuning or operational risks on a vast installed base. The SpecTech Alliance, launched in September by organizations representing airlines, trucking, retailers, consumer technology, RFID and security interests, frames the dispute around billions already invested in systems that depend on the band.⁷

The policy question is therefore not “Do we need a GPS backup?” It is: “Does this design produce sufficient additional public value, under realistic operating conditions, to justify changing the rights, risks and costs borne by existing users?” That is a very different question—and a much better one.

The Five-Record Framework for Technical Lobbying

Technical lobbying often fails because organizations treat one persuasive artifact as the whole case. A laboratory result becomes a policy conclusion. A large coalition becomes proof of interference. A national-security benefit becomes a reason to discount transition costs. None is enough on its own.

A mature campaign should build five connected records.

1. The Rights Record

Start with the legal and regulatory hierarchy. Who is licensed? Who operates on an unlicensed basis? Which uses are primary, secondary or subject to accepting interference? What obligations attach to a flexible-use license? Existing users may have real economic reliance without possessing an absolute right to an unchanged radio environment. Conversely, formal priority does not erase the public consequences of disabling millions of lawful devices.

2. The Measurement Record

Interference claims turn on power, distance, density, antenna characteristics, device sensitivity, duty cycle, terrain and the difference between a controlled demonstration and a scaled commercial network. The right advocacy question is not “Which study supports us?” but “Which assumptions would a neutral engineer need in order to reproduce the result?”

This is the heart of the current dispute. The Security Industry Association has argued that NextNav’s San Jose test equipment operated under limits that did not replicate a full mobile deployment. NextNav responded that it operated at the maximum power authorized under its experimental license and in a manner consistent with 5G use.¹ Those positions cannot be reconciled by a press release. They require agreed test scenarios, disclosed configurations and results that can be evaluated in the Commission record.

3. The Installed-Base Record

Regulators need to know what is actually in the field: the number and type of devices, where they operate, their replacement cycles, their tolerance to changed conditions and the practical ability to retune them. Industry estimates are useful only when the methodology separates readers from tags, fixed infrastructure from consumer equipment, and replacement from software or configuration changes.

NextNav has said toll transponders would not require replacement and that some reader retuning could be supported through technical and financial accommodations.⁸ Opponents forecast much broader costs and disruption. That gap is not secondary. It is the policy problem.

4. The Public-Purpose Record

Technical rulemaking is rarely about coexistence alone. Decision-makers must compare competing public purposes: PNT resilience, efficient spectrum use, broadband capacity, public safety, supply-chain continuity and consumer cost. Advocates weaken their case when they claim exclusive ownership of the public interest. The credible position identifies the benefit it creates, the benefit others protect and the conditions under which both can coexist.

5. The Transition Record

If change is justified, who pays, who verifies, who bears residual risk and what happens when assumptions fail? A promise to offer “reasonable accommodation” is a starting point, not a complete transition mechanism. A workable record specifies eligibility, testing, remediation, timing, dispute resolution, funding assurance and enforcement.

In technical lobbying, the winning message is rarely a slogan. It is a decision architecture that a regulator can administer after the campaign ends.

Case Study One: NextNav and the Contest Over Test Design

The NextNav proceeding demonstrates lobbying by demonstration. The company has sought to convert its proposition into observable evidence, including coexistence demonstrations involving RFID and security devices. In May 2026, it described a San Jose test in which a standard RFID reader and tags operated alongside its 5G PNT network.⁶

The response shows why a demonstration is never self-interpreting. The Security Industry Association questioned access, representativeness and the relation between a short demonstration and a full coexistence study. Its broader commissioned analysis argues that high-power operations could interfere with Part 15 security and life-safety systems.⁹ NextNav has challenged the assumptions and reproduced parts of the opposing methodology with different results.

For practitioners, the lesson is not that company evidence is inherently suspect or that an opposition study is more objective. Both are advocacy materials unless and until their assumptions survive independent scrutiny. The role of public affairs is to make those assumptions explicit, obtain the operational data that engineers may not possess and ensure that the policy claim does not outrun the test.

The case also demonstrates coalition asymmetry. NextNav advances a concentrated proposal with a clear engineering architecture and commercial sponsor. Its opponents represent a distributed installed base spanning sectors that do not ordinarily lobby together. The proponent can iterate one design; the opposition must aggregate many different failure modes. That makes coalition governance essential. A retailer’s RFID concern, an airline’s safety case, a toll operator’s reader configuration and a utility’s sensor network cannot be reduced to one undifferentiated number.

Case Study Two: Ligado and Conditional Approval

The FCC’s 2020 Ligado order offers a different model. The Commission approved modified use of L-band spectrum for a terrestrial network, but attached technical and operational conditions intended to protect GPS and other neighboring services. These included lower power levels, restrictions, cooperation with federal agencies, provision of base-station information and programs to repair or replace affected federal equipment.¹⁰

The order did not end the political dispute. Defense and other federal stakeholders continued to raise concerns, and Congress became another venue. The case shows that a regulator can produce a legally operative mitigation framework while the broader legitimacy and implementation contest remains unresolved.

For lobbyists, the important distinction is between winning authorization and securing deployability. An approval burdened by contested assumptions, cross-agency resistance or uncertain remediation may have less practical value than its headline suggests. Technical advocacy must therefore test not only whether a regulator can say yes, but whether the conditions create a stable operating settlement.

Case Study Three: 5G C-Band and Negotiated Sequencing

The rollout of 5G services in the 3.7–3.98 GHz band raised concerns about possible interference with aircraft radio altimeters operating in neighboring spectrum. The dispute became acute because telecom deployment schedules and aviation safety processes were moving on different clocks.

The eventual response combined delay, geographic mitigation, data exchange, equipment testing and retrofit. AT&T and Verizon voluntarily delayed some deployments; 50 airports received temporary buffer zones; the FAA used transmitter-location and power information to assess operations; and airlines upgraded altimeters. The FAA says the entire U.S. airline fleet had completed the necessary upgrades by the end of September 2023.¹¹

The case is not evidence that every spectrum conflict can be solved by delay. It does show the value of converting a binary disagreement into a staged implementation program. In July 2026, the FAA announced new performance requirements for radio altimeters in anticipation of additional upper C-band spectrum use, linking future wireless deployment to equipment resilience and defined safeguards.¹²

This is the most useful precedent for public-affairs leaders. The settlement emerged when the policy system moved beyond competing assurances and organized a sequence: share network data, identify exposure, create temporary buffers, certify or replace equipment, and then normalize deployment under clearer standards.

Comparison: Three Ways a Technical Lobbying Contest Can End

Case	Policy objective	Central conflict	Institutional response	Practical lesson
NextNav lower 900 MHz	Terrestrial PNT resilience plus flexible 5G use	Coexistence, installed-base cost and allocation of transition risk	Open FCC record; continuing tests, filings and coalition advocacy; no final decision	The test design and transition mechanism are the policy, not technical appendices
Ligado L-band	Terrestrial network use of satellite spectrum	Protection of GPS and federal systems	Conditional FCC approval followed by continuing interagency and congressional controversy	Authorization is not the same as a durable operating settlement
5G C-band and aviation	Commercial 5G deployment	Radio-altimeter performance near new transmissions	Temporary delays and buffers, data sharing, retrofits and later equipment standards	Sequencing can convert a binary conflict into a managed transition

Why This Is Lobbying—and Why the Public Record Matters

Lobbying is sometimes imagined as a private meeting in which access substitutes for evidence. FCC practice offers a more instructive model. In “permit-but-disclose” proceedings, interested parties may make presentations to decision-makers, but written materials and memoranda describing oral presentations must be placed in the relevant public record. The rules require disclosure of participants and a substantive summary of the data and arguments presented.¹³

This does not eliminate influence inequality. Organizations still differ dramatically in engineering capacity, legal resources, coalition reach and ability to sustain a multiyear docket. But the process creates traceability. A meeting becomes reviewable advocacy. A technical assertion can be challenged. A later decision can be compared with the evidence available to the agency.

That record also disciplines public-affairs teams. An argument made to a transportation official, an appropriations committee and FCC engineers cannot safely mutate from venue to venue. The level of detail may change, but the factual spine must remain consistent. If an interference estimate depends on a worst-case assumption, say so. If a demonstration represents one topology rather than a nationwide network, define its scope. If a coalition total contains overlapping signatories, do not add the lists.

What Leaders Should Do Now

1. Name the decision precisely. Separate an inquiry, petition, notice of proposed rulemaking, experimental authorization and final order. Advocacy loses credibility when procedural movement is described as policy adoption.
2. Build one assumption register. Technical, legal, economic and public-affairs teams should use the same list of power levels, device populations, test environments, replacement cycles and cost assumptions. Every external claim should trace back to it.
3. Design tests with the critic in the room. Before commissioning a demonstration, ask what an informed opponent will say it omitted. Where feasible, agree scenarios, instrumentation and reporting methods in advance.
4. Segment the installed base. Avoid a single dramatic device total. Distinguish equipment types, operating environments, regulatory status, upgrade paths and actual exposure.
5. Translate without flattening. Senior officials need an intelligible account of the risk, but simplification must preserve the conditions and uncertainty that matter to the outcome.
6. Write the transition before demanding the decision. Specify funding, eligibility, verification, remediation, deadlines and residual liability. A regulator is more likely to trust a proposal that anticipates implementation failure.
7. Keep coalition arithmetic honest. Publish the membership method, remove duplicates and distinguish companies, associations and the underlying constituencies they claim to represent.
8. Prepare for multiple venues. Technical agencies, sector regulators, budget committees and executive offices see different parts of the problem. Coordinate the record without implying that political sponsorship can replace engineering review.

Conclusion

The lower 900 MHz dispute is current because more organizations have entered the political fight. It is consequential because the outcome could alter the operating environment for a large and heterogeneous installed base while advancing a serious national resilience objective.

The easy narratives are unreliable. NextNav is not simply asking for an empty frequency block, and its opponents are not simply defending obsolete technology. The company proposes a new public-purpose network and commercially valuable spectrum rights. The coalition protects systems that already perform essential functions. Both sides therefore carry an evidentiary burden.

For experienced lobbyists, this is the larger lesson. Technical policy is not made after the engineering has finished. It is made through choices about which tests count, which risks are tolerable, which users must adapt and who pays for the transition. The strongest advocacy does not conceal those choices beneath a national-interest slogan. It makes them explicit, measurable and governable.

Key Evidence

• 902–928 MHz: the 26 MHz band addressed by NextNav’s petition; it contains multiple federal, licensed, unlicensed and industrial uses. Source: FCC public notice.²
• 15 MHz: the flexible-use spectrum NextNav seeks under its proposed 5G-based PNT and broadband architecture. Source: NextNav petition and FCC notice.²³
• 80 and 62 signatories: the two October letters involved overlapping lists and must not be added; reporting describes more than 100 distinct organizations across the campaign. Source: Broadband Breakfast.¹
• September 16, 2026: launch date of the SpecTech Alliance by eight major industry organizations opposing the proposal. Source: National Retail Federation.⁷
• 50 airports: temporary 5G C-band buffer zones established during the aviation mitigation phase. Source: FAA.¹¹

Short Glossary

Band planThe regulatory arrangement assigning frequencies, channel structures and operating rights within a portion of spectrum.CoexistenceThe ability of different radio systems to operate in the same or adjacent spectrum without harmful interference under defined conditions.Flexible-use licenseA license that permits a broader range of fixed or mobile services subject to technical and service rules.Part 15 deviceAn unlicensed radio-frequency device operating under FCC Part 15 rules, generally without protection from interference caused by authorized services.PNTPositioning, navigation and timing—the functions commonly supplied by GPS and required by transport, communications, finance and critical infrastructure.Ex parte presentationA written or oral communication with an agency decision-maker outside a fully public hearing; in FCC permit-but-disclose proceedings, its substance must be disclosed in the docket.

References and Further Reading

1. Jake Neenan, “Dozens of Groups Urge Top Trump Officials to Oppose NextNav Plan,” Broadband Breakfast, October 2, 2026.
2. Federal Communications Commission, “Wireless Telecommunications Bureau and Office of Engineering and Technology Seek Comment on NextNav Petition for Rulemaking,” DA 24-776, August 6, 2024.
3. NextNav Inc., “Petition for Rulemaking: Enabling Next-Generation Terrestrial Positioning, Navigation, and Timing and 5G,” April 16, 2024.
4. U.S. Government Accountability Office, “GPS Disruptions: DOT Could Improve Efforts to Identify Interference Incidents and Strengthen Resilience,” GAO-23-105335, November 2022.
5. Federal Communications Commission, “Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions,” FCC 25-20, March 27, 2025.
6. NextNav Inc., “Seeing Is Believing: NextNav Demonstrates 5G and RFID Coexistence in the Lower 900 MHz Band,” May 5, 2026.
7. National Retail Federation, “SpecTech Alliance: FCC Should Reject NextNav’s Plan to Seize the Lower 900 MHz Band,” September 16, 2026.
8. NextNav Inc., “NextNav Confirms Tolling Operations Can Coexist with 5G in the Lower 900 MHz Band,” January 16, 2026.
9. Security Industry Association, “Lower 900 MHz Band NextNav Interference Impact Study,” September 2025.
10. Federal Communications Commission, “Ligado Networks LLC: Order and Authorization,” FCC 20-48, April 22, 2020.
11. Federal Aviation Administration, “5G and Aviation Safety,” updated through 2026.
12. Federal Aviation Administration, “Requirements for Interference-Tolerant Radio Altimeter Systems,” July 2026.
13. Legal Information Institute, Cornell Law School, “47 CFR § 1.1206—Permit-but-disclose proceedings,” current electronic Code of Federal Regulations.

Source and Methodology Note

Research cut-off: October 5, 2026, 6:00 a.m. CEST. This article prioritizes FCC, FAA and GAO documents, the initiating petition, disclosed industry positions and reporting on the October 2026 letters. Technical and economic studies sponsored by interested parties are identified as advocacy evidence rather than treated as neutral findings. The article does not infer interference performance beyond the cited record, does not add overlapping coalition lists and does not characterize a pending FCC process as an approval. Analysis and practical lessons are the author’s interpretation of the documented record.

Suggested Internal Links

• The Test Becomes the Argument: How Regulatory Sandboxes Are Changing Lobbying
• The Bet Wants to Become a Market: Lobbying the Regulatory Perimeter
• Your Trade Association May Be Lobbying Against You

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