FCC considering re-licensing Z-Wave spectrum

From a post under the “Z-wave is not dead” blog:

If you’re in the US, and use Z-wave or other low-900mhz devices in your smart home, you’ll probably want to comment on this proposal to license the frequency blocks your devices rely on for their mesh.

To comment, go here:ECFS, reference proceeding/docket “24-240” and say your piece. Don’t forget to be respectful and coherent. Rage posts are not helpful.

Here’s a sample post borrowed from (and lightly edited) from the linked HN thread. Edit it a bit yourself, mass submission of form letters is also not super-helpful.

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 user of various devices operating in this spectrum, I believe this proposal would have significant negative impacts on both hobbyists and consumers.

1. 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.

2. 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.

3. 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.

4. 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.

5. 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]