ITS America filed comments with the National Highway Traffic Safety Administration (NHTSA) in response to its proposed standard for Vehicle-to-Vehicle (V2V) communications. The following is a second excerpt from the letter, covering the role of a Federal Motor Vehicle Safety Standard in deployment of V2V:

Start with Performance-Based Standards Needed for V2V Communication - Part 1

We agree with NHTSA that the market will not achieve sufficient coverage absent near universal commitment on the part of automakers to make V2V a capability in all vehicles. A mandate in particular addresses the "Chicken and Egg" conundrum — a value proposition problem involving a product (or service) in two separate economic sectors that is dependent on the market penetration in the other.

Automakers (and for that matter even V2X aftermarket device manufacturers) have no incentive to equip with V2V if there is no commitment from others to equip. Traditional vehicle safety technologies (e.g., airbags, seat belts, electronic stability control, etc.) protect drivers the minute they drive their new car off the dealership lot. In order for drivers to benefit from V2V, however, there needs to be a critical mass of other V2V-equipped vehicles. Making V2V a requirement for all new cars will ensure a minimum number of vehicles will be deployed in a short period of time to kickstart deployment and create a positive feedback loop to grow the safety benefits of the technology. The utility of V2V communications, like any networked service, is a function of the number of users that are equipped to communicate, and the value of the service itself.

According to Metcalfe's Law, the value of a telecommunications network is proportional to the square of total number of connected nodes. Metcalf's law is suited for evaluating networks with a fixed number of always connected nodes (i.e. nodes that connected all times with a relatively fixed topology). As a result of this, the square of the market adoption percentage can used to quantify V2V utility to accommodate the V2V ad-hoc network topology. This aligns with the observation that the chance for two V2V-equipped vehicles to encounter each other is roughly the square of V2V in-vehicle equipage penetration.

ITS America believes a Federal Motor Vehicle Safety Standard will also drive deployment of V2V in existing vehicles, building upon deployment in new vehicles. With the establishment of a larger V2X application ecosystem by the auto industry and traffic technology providers, ITS America foresees DSRC growth in dashboard automotive aftermarket and consumer electronics categories of devices that will likely fill the gap between V2V equipage in new vehicles that comply with a potential future NHTSA FMVSS and existing vehicles that are excluded from this standard.

ITS America has forecasted the growth of aftermarket and consumer electronics given a V2V motor vehicle standard. Our forecast shows that by 2029 — seven years after the projected phase-in of the light vehicle V2V rule — 60% of all vehicles, or a cumulative 146 million cars, will have DSRC/V2X equipment. Adoption of aftermarket/consumer electronics DSRC/V2X devices for existing vehicles are forecast to outpace factory installed DSRC for new cars for by 2027.

The technology and growth path for V2V and V2I for existing vehicles or infrastructure, following a NHTSA V2V mandate is notable. With new V2V equipped vehicles on our nation's roadways, road agencies could then invest more in safety and traffic management V2I, and portable and aftermarket device manufacturers can begin adding V2X features in their navigation GPSs, fleet dispatch systems, dashboard and rear-view safety cams, and mobile phones. A critical mass of equipped light vehicles would also create ready market for V2X and would spur OEM and aftermarket adoption among others, such as commercial heavy vehicles fleets and vulnerable road users. Vulnerable populations benefiting from V2X through portable devices would likely include pedestrians, motorcyclists, bicyclists and other types of road users that to date have few options to protect themselves from devastating crashes. For this reason, ITS America believes that NHTSA has underestimated the benefits of V2V capability and the final positive safety impact of the rule. The agency's estimation does not take into consideration the growth in V2V aftermarket devices, vehicle-to-pedestrian or vehicle to infrastructure, none of which are captured in the agency's cost-benefit analysis.

Furthermore, ITS America believes NHTSA underestimates benefits related to future vehicle automation. Long term, with autonomous vehicles, there will be a fundamental need for cars to talk to each other, especially as more and more highly automated vehicles are introduced and intermingle in traffic and at intersections. Opportunities such as V2V platooning would improve fuel efficiency, reduce congestion and improve passenger and freight movement. The integration of V2V would improve the performance of crash sensing and driving automation –— adding data that checks the results of other sensors, creating an additional layer of safety and security. In challenging environments such as hazardous weather conditions, V2V may play a complementary role where other sensors may go blind or have diminished capacity — potentially expanding the operational design of an highly automated vehicles.

Although ITS America understands that intangible costs need to be factored into any regulatory decisions, addressing Wi-Fi use in the ITS/DSRC band as an opportunity cost of this proposed motor vehicle safety standard is ineffective. Opportunity costs are the costs incurred due to the need to divert expenditures (legal services, audits etc) to regulatory compliance. Spectrum is not, however, a regulatory compliance cost. The only case where spectrum might be a compliance cost may be if the FCC changes the technical and service rules and forces automakers to redesign and redeploy the technology to comply with regulatory changes. ITS America and others have encouraged the FCC to consider these opportunity costs in its filings to the FCC. However, "spectrum opportunity" cost beyond compliance costs lead agencies down the rabbit hole. For any agency (even at the state and local agencies) that sought to use any part of DSRC would need to conduct an "opportunity cost" evaluation of alternative uses of spectrum before proceeding with any policy, suggesting that the no one can rely upon the FCC's authority and original decision to allocate the use of the band for ITS/DSRC.

Finally and most critically, putting likely preventable fatalities lost in vehicle crashes next to economic benefits of WiFi is very problematic. Suggesting WiFi use of DSRC spectrum is a foregone opportunity implies there may be acceptable lower level of safety can be sustained so long as broadband can be expanded. This kind of analysis is not consistent with the mission of US DOT and NHTSA to advocate and promote traffic safety.

Overall, ITS America believes that any regulation should not impose unnecessary costs or burden industry. ITS America supports controlling regulatory costs and that every proposal for an agency regulation must be carefully scrutinized. ITSA will work to help the administration address costs where necessary, and will also support new measures that capture benefits of the rule are beyond those cited in the proposed rulemaking.

Conclusion: ITS America believes that the proposed standard as an important first step forward and we are looking forward assisting the agency address issues in establishing a framework for cooperative vehicle and infrastructure safety.

Regina Hopper is President and CEO of ITS America.