ITS America filed comments with the National Highway Traffic Safety Administration (NHTSA) in response to its proposed standard for Vehicle-to-Vehicle (V2V) communications.

Read the full letter from ITS America to NHTSA

Additionally, the Safety Spectrum Coalition of which ITS America is a founding member also submitted comments.

Read the full letter from the Safety Spectrum Coalition to NHTSA

ITS America believes a Federal Motor Vehicle Safety Standard is needed for vehicle-to-vehicle communications, and that the proposed standard should be performance-based and flexible enough to incorporate future technologies including everything from standards for communications, to security and privacy, to V2V applications.

Preliminary 2016 data from the National Safety Council estimates that as many as 40,000 people died in motor vehicle crashes last year. That marks a six-percent increase over 2015, the most dramatic two-year escalation since 1964. Automotive safety technologies of the past focused on crashworthiness of vehicles and protecting drivers and passengers after a crash. Now, new technology has evolved to the point where crashes can be prevented in the first place. The advancements represented by Dedicated Short Range Communications (DSRC) are especially timely and important; as there is significant risk; we may see an unprecedented long-term increase in traffic fatalities and injuries.

ITS America believes that as far as interoperability is concerned, DSRC based standards and technology are currently the most technically mature and widely accepted “cooperative” short-range approach for crash avoidance and vehicle automation. Safety is essential and DSRC has a wide range of technology suppliers, transportation authorities, infrastructure operators, and automakers that support it, which will make our highways and roads safer for drivers, passengers and pedestrians.

ITS America understands that technology is able to solve many problems, but also recognizes that business, public institutions and even the public must adjust to new realities of connectivity and the Internet of Things (IoT). We understand the potential for automated and connected vehicles to save thousands of lives and are cognizant that any such new vehicle technologies must be safe and secure in all circumstances.

The following is an excerpt from the letter:

Interoperability and Establishing Pathways for New Technology and Applications

We believe that NHTSA is correct in establishing a motor vehicle safety standard now. We also believe that as far as nteroperability is concerned, DSRC-based standards and technology are currently the most technically mature and widely accepted “cooperative” short range approach for crash avoidance and vehicle automation.

First and most broadly, the technology has a large ecosystem of technology suppliers, transportation authorities and infrastructure operators, and automakers that support it, which greatly removes barriers, speeds product to market and lowers risks to integration and deployment.

Furthermore, DSRC has established a basic level of interoperability based upon FCC technical and service rules and standards established in Institute of Electrical and Electronics Engineers (IEEE), Society of Automotive Engineers (SAE) and other voluntary consensus standards bodies.

The FCC had the foresight to layout the blueprint for the foundations for V2V when it allocated the spectrum in October 1999, established technical and service rules in 2004, and amended its rules in 2006 to provide special FCC priority and protection for V2V.

However, ITS America also believes that the proposed standard should be performance-based and flexible enough to incorporate future technologies – technologies that have not had the level of standardization, testing or validation that DSRC has had to date. Even though there has been an explosion of infotainment connectivity in vehicles, we are in the early days of highly automated vehicle systems (SAE Levels of Automation for On-Road Vehicles – J3016 levels 4 and 5) that rely upon multiple sensors, data, and safety critical communications. Just as in today’s telecommunications marketplace where broadband internet access can be delivered by a whole host of different technologies (e.g., wired broadband such as fiber, copper, and coaxial cable; licensed wireless such as 4G; and unlicensed short range wireless such as Wi-Fi, Bluetooth etc.), we look forward to a future where there is abundant options to support V2X safety.

We urge NHTSA to move carefully to ensure that any standard is flexible enough to allow other wireless technologies to be incorporated under the federal standard as long as they can demonstrate a minimal combined performance for interoperability, security, and privacy. We commit to working with USDOT and others to establish pathways for future wireless technologies such as future 5G to support V2X communications.

ITS America recognizes that V2X solutions must be market driven. We agree with NHTSA that requirements for particular V2V applications beyond interoperability and security are best left outside of scope of the rulemaking to allow industry to further innovate. Having NHTSA involved , however, in the development of a federal standard will help resolve the last of remaining technology and standards issues as they become salient (e.g., spectrum, network and application interoperability, ongoing security and privacy, etc.). Reducing such uncertainties lowers investment risk, encourages further research and deployment of V2X applications, and bolsters consumer confidence. To this end, ITS America believes NHTSA should define interoperability more broadly in reference to not just future V2V technologies, but to DSRC itself.

We disagree with NHTSA that V2V capability should only be limited to only one channel within the
DSRC band. The DSRC band was designed for multi-channel operation to allow application developers flexibility on how to leverage spectrum resources to minimize interference risk and manage channel capacity without compromising on interoperability.

ITS America agrees with NHTSA that devices participating in the V2V information environment need to exchange safety information, but urges that choice of channels should be left to industry within the
constraints of the current FCC technical and service rules.

NHTSA is mistaken when it states that “FCC has specified that BSM [Basic Safety Message] transmissions and reception will occur on channel 172.” FCC has never set requirements related to the Basic Safety Message standard, nor has anyone petitioned the FCC to do so. ITS America agrees that the FCC, not NHTSA or US DOT, has the authority to determine the commercial use of spectrum.”

However, “commercial use” of DSRC spectrum is not defined in the FCC’s ITS/DSRC technical and service rules. Although FCC has authority to define “commercial use,” it has never chosen to define the term in reference to DSRC. FCC regulations define DSRC service as systems that “use radio techniques to transfer data over short distances between roadside and mobile units, between mobile units, and between portable and mobile units to perform operations related to the improvement of traffic flow, traffic safety, and other intelligent transportation service applications in a variety of environments.”

Indeed, “commercial use” of DSRC spectrum for the provision of telecommunications services is not permitted by Section 90.373 of the FCC’s Rules. However, like most Part 90 spectrum, DSRC spectrum may be licensed to commercial entities for the provision of DSRC services.

NHTSA is also mistaken in its “expectation” that non-safety critical services will occur on other channels besides 172. On other channels, FCC rules do not prohibit V2V or safety-of-life services, and even applies a service priority framework to address. The FCC created V2V channel (channel 172) exclusively for “safety-of-life” services, as defined from the priority framework that was developed and codified in the 2004 technical and service rules. V2V is further defined as “accident avoidance and mitigation and safety of life and property applications.”

ITS America supported the petition to the FCC to designate an exclusive V2V channel in 2005, and the V2V channel was created by the FCC to prevent other critical applications from competing for resources with vehicle-based crash avoidance applications in at least one channel within band. Other channels besides 172 could be used for V2V platooning, and some early applications exist for “safety-of-life” priority services on other channels, such as pedestrian safety or intersection safety applications.

NHTSA makes a mistake, however, in addressing only channel 172 as a proposed safety standard. Narrowly defining V2V capability to a single channel in a single band is inconsistent with the agency goal of creating a performance standard that forges a pathway toward defining interoperability both within DSRC, but also beyond DSRC in reference to potential future wireless technologies.

As NHTSA seeks to understand the potential safety benefits of DSRC beyond the two V2V applications it addresses in its cost benefit analysis, ITS America believes that agency should not too narrowly define DSRC channel use lest it unintentionally excludes future V2V services.

Read Performance-Based Standards Needed for V2V Communication - Part 2

Regina Hopper is President and CEO of ITS America.