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Connected vehicle community voices concern over potential incursion into 5.9 GHz band by unlicensed WiFi devices

12 February 2013

The Intelligent Transportation Society of America (ITS America), along with major automakers, safety advocates and transportation officials from across the country, are urging the Federal Communications Commission (FCC) to protect the 5.9 GHz band of spectrum set aside for connected vehicle technology from potentially harmful interference that could result from allowing unlicensed Wi-Fi-based devices to operate in the band.

The Wi-Fi expansion plan, announced by FCC Chairman Julius Genachowski at the Consumer Electronics Show last month, will be the topic of a 20 February Commission meeting in which the FCC plans to consider a Notice of Proposed Rulemaking potentially to allow the use of 195 megahertz (MHz) of spectrum in the 5 gigahertz (GHz) band by Unlicensed-National Information Infrastructure (U-NII) devices.

The 5.9 GHz band—one of two bands under consideration—was allocated by the FCC for development of vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2I) communications technology which the US Department of Transportation (DOT) estimates could potentially address 80% of all unimpaired crash scenarios, saving thousands of lives each year.

A study by the National Telecommunications & Information Administration (NTIA) recognized that connected vehicle technology “could help prevent the majority of types of crashes that typically occur in the real world, such as crashes at intersections or while changing lanes.” It concluded that “further analysis is required to determine whether and how the identified risk factors can be mitigated...,” and that “While the state-of-the-art of existing and proposed spectrum sharing technologies is advancing at a rapid pace, NTIA recognizes the importance of these bands to the federal agencies…and the transportation industry and the potential risks of introducing a substantial number of new, unlicensed devices into them without proper safeguards.

We respectfully ask the Commission to allow for due diligence on this critical issue by ensuring that any timelines contained in a proposed rulemaking relating to the 75 MHz of spectrum in the 5850-5925 MHz (5.9 GHz) band are consistent with the NTIA schedule for completing its quantitative evaluation and issuing final recommendations, and do not precede a decision by the US Department of Transportation (DOT) regarding implementation of a connected vehicle network which has the potential to greatly reduce the 6 million crashes and more than 30,000 deaths which occur on U.S. roadways annually.

We would note that while Congress required the Commission to modify its regulations to allow certain unlicensed use of spectrum in the 5.4 GHz band as part of the Middle Class Tax Relief and Job Creation Act of 2012, a similar requirement for the 5.9 GHz band was removed from the final legislation, which called only for the NTIA study and did not direct the Commission to modify its regulations. This decision reflects the recognition by Congress of the life-saving potential of connected vehicle technology and the unknown but potentially serious complications associated with allowing unlicensed devices to operate in the band.

...We stand ready to work with NTIA, the wireless industry, and other federal and non-federal stakeholders to evaluate the feasibility of existing, modified, proposed and new spectrum-sharing technologies and approaches. However, this process should be allowed to proceed without a predetermination by the FCC that spectrum sharing in the 5.9 GHz should be the ultimate outcome.

Letter to the FCC

ITS America was joined on the letter by AAA, the Alliance of Automobile Manufacturers, Association of Global Automakers, American Association of State Highway and Transportation Officials, American Highway Users Alliance, American Public Transportation Association, Commercial Vehicle Safety Alliance, American Traffic Safety Services Association, Transportation for America, and numerous other public and private sector leaders.

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