On behalf of the Competitive Enterprise Institute (“CEI”), I respectfully submit these comments in response to the Office of the Secretary of Transportation’s (“OST”) Request for Comments: V2X Communications (“RFC”).
CEI is a nonprofit, nonpartisan public interest organization that focuses on regulatory policy from a pro-market perspective. CEI previously submitted comments to the National Highway Traffic Safety Administration in response to its advance notice of proposed rulemaking (Appendix A) and notice of proposed rulemaking (Appendix B) in which we opposed a contemplated vehicle-to-vehicle, dedicated short-range communications (“DSRC”) mandate.
This comment letter responds to questions posed in the RFC, where responses are numbered to correspond to the numbered questions of the RFC.
Responses to RFC Questions
In keeping with OST’s publicly pledged commitment to technology neutrality, we urge the Department to take a technology-neutral approach to the 5.9 GHz (5.850–5.925 GHz) intelligent transportation systems (“ITS”) band.
One way to achieve this outcome would be to remain neutral on possible repurposing of the ITS band for non-ITS purposes by the Federal Communications Commission—namely, permitting U-NII-4 devices to share the band with ITS devices, both DSRC and 3GPP. Another would be to keep the band ITS-exclusive, but support allowing 3GPP, also known as cellular-vehicle-to-everything (“C-V2X”), to coexist in the band with DSRC.
On the latter approach, the ITS band could be repurposed along the lines of a European spectrum-sharing proposal from the 5G Automotive Association. Here spectrum would be allocated in such a way to more closely mirror real-world marketplace decisions by developers and consumers, as opposed to previous efforts by the Department to impose a particular communications technology by administrative fiat (see Appendices A and B).
Specifically, 30 MHz of the band could be split by allocating a preferred 10 MHz channel to each DSRC and C-V2X, with a shared 10 MHz channel in between. Detect-and-vacate or a similar rule would apply across the channels. The remaining upper 45 MHz of the ITS band would be allocated at a future date as the V2X market matures based on an evaluation of the success and failures of the respective technologies in the marketplace.
CEI has a strong interest in highway platooning technology. While several earlier pilots relied on IEEE 802.11p/DSRC for the vehicle-to-vehicle communications link, recent research suggests “C-V2X . . . allows for shorter inter-truck distances than IEEE 802.11p due to more reliable communications performance under increasing congestion on the wireless channel caused by surrounding vehicles.”
This has major operational performance implications for automated vehicle platooning and supports our position on ITS band spectrum allocation as explained above in response to Question 2.
Platooning is required to realize many of the most significant hypothesized private and social benefits of automated vehicle technology. These include greater lane utilization, reduced congestion, travel time savings, reduced emissions, improved energy efficiency, and infrastructure investment savings.
As noted above in response to Question 6, the V2X communications technologies at issue carry a variety of important implications for automated vehicle platooning.
We appreciate the opportunity to submit comments to OST on this matter and look forward to further participation.
Competitive Enterprise Institute
. V2X Communications, Request for Comments, DOT-OST-2018-0210, 83 Fed. Reg. 66,338 (Dec. 26, 2018) [hereinafter RFC].
. RFC, supra note 1, at 66,339.
. Coexistence of C-V2X and ITS-G5 at 5.9GHz, 5G Automotive Association Position Paper (Apr. 5, 2018), available at http://5gaa.org/wp-content/uploads/2018/10/Position-Paper-ITG5.pdf.
. RFC, supra note 1, at 66,339.
. See, e.g., Marc Scribner, Authorizing Automated Vehicle Platooning: A Guide for State Legislators, 2018 Edition, Competitive Enter. Inst. Issue Analysis 1 (Jul. 2018), available at https://cei.org/sites/default/files/Marc_Scribner_-_Authorizing_Automated_Vehicle_Platooning_2018%20%281%29.pdf.
. Vladimir Vukadinovic et al., 3GPP C-V2X and IEEE 802.11p for Vehicle-to-Vehicle communications in highway platooning scenarios, 74 Ad Hoc Networks 17 (May 2018).
. RFC, supra note 1, at 66,339–40.
. See, e.g., Kara Kockelman, et al., An Assessment of Autonomous Vehicles: Traffic Impacts and Infrastructure Needs—Final Report, Tex. Dept. of Trans. Final Report 0-6847-1 (Mar. 2017), available at https://library.ctr.utexas.edu/ctr-publications/0-6847-1.pdf.