February 5, 2013
The Honorable Julius Genachowski, Chairman
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554
RE: WT Docket No. 11-49
Dear Chairman Genachowski,
I write to urge you to promptly consider the request of Progeny LMS, LLC for authority to begin
using its licensed spectrum in portions of the 902-928 MHz band for the purpose of providing
position location services to support emergency first responders.
As you know, I've long been a champion of advances in 9-1-1 technology, including the
implementation of E9-1-1 and most recently the transition to Next Generation 9-1-1, which will
enable emergency dispatch centers to accept photos, videos and text messages.
With more than 396,000 9-1-1 calls made through wireless devices each day, the need for
accurate and reliable location services is increasingly clear. As the Commission has
acknowledged (most recently in its 2011 Third Report and Order on wireless E9-I-l) such
indoor limitations on location accuracy are a "significant public safety concern" that requires
development of technical solutions.
In October 2012, I had an opportunity to visit the Sunnyvale, California facilities of Progeny and
its parent company, NextNav Holdings LLC. ProgenylNextNavare responding to the need for
improved indoor location accuracy by constructing a nationwide network that is designed to
provide highly accurate location services using spectrum that was specifically allocated by the
Commission for Multilateration Location and Monitoring Services (M-LMS).
The capabilities of the ProgenylNextNav network were tested in December 2012 by a working
group of the Commission's Communication's Security, Reliability and Interoperability Council
(CSRIC). Although the results of these tests have not yet been released, I understand that your
office is reviewing them and they are very encouraging.
I recognize that the 902-928 MHz band is a shared band, used by many different types of
wireless services, including millions of unlicensed devices such as baby monitors, cordless
telephones, automatic meter readers, RFID and other devices. As a strong supporter of
unlicensed irmovation, I believe it's important that the 902-928 MHz band remain available for
unlicensed devices, while ensuring that Progeny's location service does not cause unacceptable
levels of interference to unlicensed services.
To ensure that the ProgenylNextNav position location network can continue to operate in the
902-928 MHz band without causing unacceptable levels of interference to other important
spectrum users, I understand that the Commission directed Progeny to conduct field testing of
the spectrum sharing capabilities of its network in cooperation with manufacturers and users of
unlicensed devices that operate in the 902-928 MHz band. These field tests were reportedly
conducted begirming in 20 II and continuing through much of 2012. I understand that your staff
is reviewing the results of the field tests along with comments that were filed after the
Commission twice placed the test results on public notice for comment.
As the National Emergency Number Association ("NENA") explained in a December 21, 2012
letter that it filed with the Commission, the "development and deployment of advanced location
technologies is critical to the future of emergency calling systems and public safety response
capabilities" and for this purpose "we [... ] consider it important to support the Multilateration­
Location and Monitoring Service."
I concur with these sentiments and I urge you and your staff to complete its review ofthe test
reports expeditiously. Thank you in advance for your timely consideration ofProgenylNextNav's
request to improve the indoor location accuracy of9-1-1 calls.
Sincerely,
G. Eshoo
anking Member
Communications and Technology Subcommittee
Energy and Commerce Committee
cc: Commissioner Robert M. McDowell
Commissioner Mignon Clyburn
Commissioner Jessica Rosenworcel
Commissioner Ajit Pai