Executive Order 13905 entitled “Strengthening National Resilience through Responsible Use of Positioning, Navigation, and Timing Service” went into effect in the United States on February 12, 2020. The E.O. initially appeared on the White House website and was later published in the Federal Register.
The purpose of E.O. 13905 is to establish policy and implementation steps to strengthen the resilience of PNT services, upon which U.S. critical infrastructure depends. The policy set out by the E.O. is to ensure that disruption or manipulation of PNT services do not undermine reliable and efficient functioning of its critical infrastructure. To this end, the Federal Government shall engage the public and private sectors to identify and promote the responsible use of PNT services.
The E.O. specifies nine separate but related policy implementation steps and assigns action responsibility primarily to the Departments of Commerce and Homeland Security as well as to the White House Office of Science and Technology Policy (OSTP).
The Open PNT Industry Alliance believes Executive Order 13905 is a good first step in enabling alternative PNT systems. The directives of this executive order support and accelerate the federal government’s efforts to avoid disruption of our national critical infrastructure in those sectors that depend on PNT services.
- Resilience is of paramount importance. The concept of assured PNT — i.e., being able to obtain precise PNT information from multiple sources — is at the heart of this executive order. Assured PNT is an essential safeguard for telecommunications networks, electrical power grids, transportation systems, emergency management services, and other types of infrastructure that rely on PNT to operate even if the U.S. Global Positioning System (GPS) is unavailable or degraded.
- There is strength in diversity. It makes sense that GPS and other global navigation satellite systems (GNSS) in medium Earth orbit (MEO) and above should be augmented and backed up by a range of technologies. Alliance members include private sector companies providing PNT solutions that are different from GPS/GNSS, thereby conforming to the various service delivery requirements and technical performance characteristics demanded by the actions of this executive order.
- The time to act is now. With this executive order, the White House has provided both the roadmap and the urgent timeline to ensure that proper alternate PNT measures are in place to protect our critical infrastructure and enhance its capabilities. The companies that make up the Open PNT Industry Alliance stand ready to fulfill the mandate of this executive order.
The alliance advocates for partnerships between civil government officials and private sector leaders to implement solutions that provide uninterrupted access to PNT sources that strengthen the resilience of critical infrastructure.
On April 8, 2020, the U.S. Department of Homeland Security (DHS) / Cybersecurity and Infrastructure Security Agency (CISA) submitted a report on alternative sources of PNT to U.S. congressional committee leaders. The Report on Positioning, Navigation, and Timing (PNT) Backup and Complementary Capabilities to the Global Positioning System (GPS) was subsequently released to the public on May 6, 2020.
This important report highlights the urgent need for GPS backup for critical applications, and it identifies and characterizes a variety of solutions that are available to meet this need today. The report also describes the essential role of the Federal Government in urging industry to implement multiple technologies instead of endorsing or investing in a single solution to back up GPS.
As directed by the National Defense Authorization Act for Fiscal Year 2017 (NDAA 2017), the focus of the report is on the requirements of the owners and operators of national critical infrastructure. While the report only highlights PNT use cases from a subset of the 16 critical infrastructure sectors — primarily those that have the highest reliance on PNT information — the pragmatic recommendations from DHS address a range of requirements across all sectors.
With respect to PNT needs for backing up GPS, DHS acknowledges the differences between and commonalities among the sectors and offers exceptional guidance for leveraging the capabilities of diverse forms of commercially available alternative PNT rather than endorsing a single, anti-competitive, government-imposed solution. In doing so, the report is aligned with Executive Order 13905 on the responsible use of PNT by directing a market-based approach that is technology agnostic.
We applaud the Federal Government’s efforts to avoid disruption of our national critical infrastructure in those sectors that depend on PNT services, and we fully agree with the recommendations and findings of this thorough report, including:
- Many out-of-domain solutions exist today. DHS notes that “critical infrastructure systems that would cease to operate without [the primary PNT domain of] GPS do so because of design choices, cost factors, increasing efficiency, or other considerations—not because of a lack of available additional means to navigate, determine location, or synchronize.” As DHS goes on to say, “there are smart, market-oriented solutions that will contribute to enhanced resilience that the U.S. Government should continue to promote, enable, and stimulate.”
- Each critical infrastructure sector has different needs, but there are certain baseline requirements. We believe that a heterogeneous backup to GPS is in the public interest, so we agree with the report’s statement that “DHS could not identify generic specifications for a national backup” because “[t]he position and navigation functions in critical infrastructure are so diverse that no single PNT system, including GPS, can fulfill all user requirements and applications.” However, as DHS explains, “a minimal acceptable precision of anywhere between 65-240 nanoseconds […] supports all critical infrastructure requirements.” The report states that this range “is expected to meet future requirements, including 5G.”
- The Federal Government should neither provide nor select a single PNT solution; rather, it should encourage diversity and invest in multiple technologies. With regard to any kind of government preference for a particular PNT system, DHS states that “the government would have to consider the repercussions of such a system in the marketplace” because “[a] free government system would negatively impact commercially available PNT systems by directly competing with them.” Our view is that a truly resilient and globally available GPS backup capability is only possible with an open, technology-neutral approach that encourages diversity. We agree with DHS that “[t]he Federal Government should encourage adoption of multiple PNT sources [by] critical infrastructure owners and operators [and] focus on facilitating the availability and adoption of PNT sources in the open market.”
- Commercial implementation will not happen without directives and requirements from the U.S. Government. “[W]ithout regulatory requirements or positive benefit-cost equations, adoption of non-GNSS services is unlikely,” DHS states in its report, adding that “business decisions, the lack of a Federal mandate, and potentially an underappreciation of the risk associated with GPS dependence are factors in the lack of resilience to GPS disruption.” We agree that an action plan is needed, which is why we are delighted to see that the findings of the report are aligned with the executive order on PNT. DHS directs that “[w]hatever the source of the PNT, it is incumbent on users to apply the principles found in Executive Order 13905, Strengthening National Resilience Through Responsible Use of Positioning, Navigation, and Timing Services [to] reduce the risk associated with the disruption or manipulation of PNT services.”
We look forward to supporting the efforts of DHS and other departments to work with infrastructure owners and operators to follow the PNT guidelines in the DHS report on alternative PNT and implement the directives of Executive Order 13905.
UPDATE – May 2021
On May 17, 2021, the U.S. Department of Homeland Security (DHS) / Homeland Security Operational Analysis Center (HSOAC) released a report entitled Analyzing a More Resilient National Positioning, Navigation, and Timing Capability. Although not published until a year after the DHS/CISA report on PNT, the DHS/HSOAC report on PNT was a key source of underlying information for CISA in their April 2020 report.
The DHS/HSOAC report reinforces much of what was said in the DHS/CISA report, including that capable non-GNSS forms of PNT exist today as an essential contingency to meet both the shared needs and individual requirements of the critical infrastructure sectors. The DHS/HSOAC report also underscores that “no single system is a perfect backup to GPS” and adds that government should not invest in a single backup for GPS. In fact, regarding the use of multiple forms of PNT, HSOAC states that “diversity of capabilities in the national PNT ecosystem is a strength, not a weakness.”
The U.S. Department of Transportation published an in-depth report for Congress entitled Complementary Positioning, Navigation, and Timing (PNT) and GPS Backup Technologies Demonstration Report. This January 2021 report follows up a DOT-organized demonstration of 11 PNT providers that was conducted in March 2020.
The members of the Open PNT Industry Alliance understand the threats and develop and deploy technologies that back up and augment GPS/GNSS to increase national resilience. The views of the coalition are aligned with the following seminal statement from the Conclusions and Recommendations section of DOT’s new report (p. 194):
“The demonstration indicates that there are suitable, mature, and commercially available technologies to backup or complement the timing services provided by GPS. However, the demonstration also indicates that none of the systems can universally backup the positioning and navigations capabilities provided by GPS and its augmentations. The critical infrastructure positioning and navigation requirements are so varied that function, application, and end-user specific positioning and navigation solutions are needed. This necessitates a diverse universe of positioning and navigation technologies.”
DOT’s findings and guidance are consistent with these core principles of the Open PNT Industry Alliance:
- The technological landscape is diverse enough to allow multiple alternatives to GPS/GNSS with varied operational characteristics to deliver against a complex and ever-expanding set of customer requirements.
- True resilience requires the widest possible diversity, meaning that a singular sole-source technology will not only fail to meet the need in terms of reliability and performance but also be unable to evolve the optimal attack prevention and threat response capabilities.
- The ingenuity of the private sector, spurred by competition and public and private investment, will drive the emergence of multiple cost-effective GPS/GNSS alternatives that evolve according to technological innovations and market dynamics. Similarly, unbridled innovation will address new and still evolving use cases not supported by GPS/GNSS.
The Open PNT Industry Alliance believes that DOT is in an excellent position to strengthen economic and national security by supporting U.S. Government efforts to accelerate the implementation of many types of backup PNT capabilities for critical infrastructure. Furthermore, we encourage government and business leaders to take steps now to adopt alternative PNT for civil and commercial applications. Read our full statement for additional information.
The National Physical Laboratory (NPL) in the United Kingdom is leading the National Timing Centre (NTC) programme. The mission of the NTC is to “pave the way for trusted and assured time and frequency distribution” throughout the country by fulfilling three objectives:
- Deliver a resilient UK national time infrastructure through the building and linking of a new atomic clock network distributed geographically in secure locations.
- Provide innovation opportunities for UK companies through funding projects in partnership with Innovate UK based on a successful NPL and Innovate UK partnership model.
- Respond to the specialist skills shortage in time and synchronization solutions through specialist, apprentice and post graduate training opportunities.
The NTC program is a five-year, £36 million ($47 million) R&D initiative that will develop the capability to improve the security, resilience, communication, and implementation of new PNT technologies across the UK in sectors such as energy, financial services, telecommunications, and aerospace, among others.
The Open PNT Industry Alliance supports the development of national PNT initiatives worldwide, since the need for reliable, continuous PNT data should be recognized and addressed as a national priority.