Comment on Positioning, Navigation, and Timing Technologies and Solutions
Today, I filed a comment to the Federal Communications Commision regarding Positioning, Navigation, and Timing Technologies and Solutions and the plan for the Lower 900 MHz Band.
October 9, 2025
VIA ELECTRONIC FILING
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street NE
Washington, DC 20554
RE: Promoting the Development of Positioning, Navigation, and Timing Technologies and Solutions (WT Docket No. 25-110); NextNav Petition for Rulemaking, Enabling Next-Generation Terrestrial Positioning, Navigation, and Timing and 5G: A Plan for the Lower 900 MHz Band (902-928 MHz), Public Notice (WT Docket No. 24-240)
Dear Ms. Dortch:
The United States has built vast military, economic, and civilian infrastructures on the backbone of the Global Positioning System (GPS). It’s more than just a tool to help families get to the beach: GPS underpins telecommunications networks, electric grids, banking systems, and transportation. It guides everything from precision munitions to farming equipment to, of course, everyday smartphone navigation.
Our country’s near-total reliance on a single, space-based technology has created a dangerous risk. If the United States loses access to GPS through jamming, spoofing, or kinetic attack, we are more than just inconvenienced. Our military loses targeting, timing, and command capabilities. Our ships and trucks reach their destinations more slowly. Farmers, who rely on GPS for successful planting and field maintenance, are hindered. Without GPS, airplanes may be unable to take off or land safely.
In short, a successful disruption of GPS could cripple both national defense and the economy in a matter of hours. And yet, there is currently no American terrestrial (i.e., ground-based) complement or backup to GPS, even as our adversaries build layered redundancies on both sea and land.
The Bull Moose Project believes it is essential for the Federal Communications Commission (FCC) to continue its work to explore GPS complements and backups. The work that the FCC is doing to advance this discussion is essential, and we appreciate Chairman Carr’s focus on engaging stakeholders across government and industry to encourage the development of new positioning, navigation, and timing (PNT) technologies and solutions.
We support a layered, “system-of-systems” approach that blends space and terrestrial technologies to secure our nation’s PNT architecture. Doing so would be a bold leap forward towards securing America’s future. As America charts a path to fortify its PNT capabilities, one option stands out for its technical advantages, speed of deployment, and market-driven scalability: a terrestrial PNT system that rides on the infrastructure of modern 5G wireless networks.
A 5G-based PNT system offers several compelling benefits:
● Stronger, Harder-to-Jam Signals
● Resilience Through Network Redundancy
● Leverages Existing 5G Ecosystem
● No Cost to Taxpayers
Given the extensive potential of a 5G-based GPS backup, we were surprised to see such a robust and often negative discussion within the FCC dockets, seemingly designed to stall progress rather than solve a major national security threat. Following an extensive investigation by the Bull Moose Project into this issue, a pattern emerged. Some opposition appeared less concerned around interference and more about stalling competition, favoring alternative approaches, or protecting China’s strategic edge and keeping America vulnerable to a single point of failure.
The attached report highlights troubling connections between several opposing associations and Chinese entities. The coalition of opponents includes the LoRa Alliance, RAIN Alliance, Security Industry Association, Wi-Sun Alliance, and Z-Wave Alliance, and others. They count among their members Chinese companies such as ZTE Corporation, Shenzhen Makerfabs Corporation, Zhejiang Chint Electrics, Ningbo Dooya Mechanic & Electronic Technology Co., and Taixin Semiconductor Co.
As the FCC evaluates the many comments within the dockets, we hope that our report can be helpful in informing that process. The Commission is the preeminent authority on spectrum management, and its engineers are among the best in the world. We urge them to closely examine the motivations of those lobbying against a secure, American-made GPS backup, and to move the FCC process forward by issuing a Notice of Proposed Rulemaking to resolve the remaining engineering questions in the docket.
A 5G-based terrestrial backup to GPS offers the fastest, most secure, and most economically efficient route to positioning and timing resiliency. The challenges are real but manageable; to solve them, we must adopt a whole-of-government approach driven by urgency. By doing so, America can re-establish itself as the vanguard of PNT innovation, much as it was when GPS was first conceived.
Sincerely,
Aiden Buzzetti
President
The Bull Moose Project
Washington, DC
