Next-generation satellite services can dramatically improve American PNT resilience. Satellite-based PNT systems have long been unrivaled in their relatively low-cost ability to deliver ubiquitous PNT data to end users globally, as evidenced by the multitude of countries developing and deploying global navigation satellite systems ("GNSS") using dedicated L-band frequencies in medium-Earth orbit. But SES/O3b is correct that "there is no reason in principle why an alternative or complementary PNT system could not be implemented using other satellite frequencies … or other satellite orbits" than those current frequencies and orbits. And in contrast to an approach that relies solely on dedicated frequencies or mandates a particular solution, incorporating PNT as a service offered with next-generation satellite operators' existing services and spectrum allocations will facilitate more rapid deployment of resilient and robust PNT solutions for Americans with fewer rule changes.

Nextbigfuture has covered experiments to test the performance of the different positioning frameworks with Starlink satellites before 2024. The results showed meter level accuracy. The unprecedented results from these analyses show that, with an average of only three active Starlink satellites, a positioning solution with a 3D position estimation error of two meters can be achieved in only 20 seconds. This was done by researchers with very little money. An actual SpaceX Starlink effort focused on delivering better GPS could get broadly available accuracy to better than a meter.

In 2020, Nextbigfuture covered an arxiv paper "Fused Low-Earth-Orbit GNSS", by Peter A. Iannucci and Todd E. Humphreys of the Radionavigation Laboratory, The University of Texas at Austin. It detailed how low-earth orbit satellites can be modified to provide super-precise GPS.

SpaceX has invested considerable resources to ensure that its satellite systems can operate independent of GPS. This capability not only allows those systems to operate unhindered even if GPS is unavailable, it also sets the foundation for future solutions that can use any authorized frequency to deliver accurate, reliable, and resilient PNT to any end user device. SpaceX has also been actively working to integrate PNT solutions into its direct-to-device commercial service offerings. In so doing, SpaceX can advance the Commission's goal in this proceeding to maintain American leadership in next-generation PNT services both here at home and in over 130 countries it serves around the world.

SpaceX next-generation satellite Starlink systems that can deliver ubiquitous connectivity to millions of off-the-shelf consumer devices (direct to cellphones), along with widespread, affordable access to those devices, presents a unique, low-cost, high-reward opportunity to enhance the resilience of the PNT ecosystem without relying on government mandates or single points of failure. Achieving that outcome, however, remains contingent on the Commission's action opening the MSS spectrum. By making MSS spectrum available to the latest generation of low-Earth-orbit satellite operators, the Commission will achieve a significant victory in its effort to foster a resilient PNT system of systems that provides wide-ranging benefits to the United States' economy and the day-to-day lives of the American people.