On behalf of the Competitive Enterprise Institute (“CEI”), I respectfully submit these comments in response to the National Highway Traffic Safety Administration’s (“NHTSA”) advance notice of proposed rulemaking in the matter of Federal Motor Vehicle Safety Standards: Vehicle-to-Vehicle (“V2V”) Communications (“ANPRM”). CEI is a nonprofit, nonpartisan public interest organization that focuses on regulatory policy from a market-oriented perspective.
Our comments develop the following points:
1) It was inappropriate for NHTSA to issue its ANPRM prior to the Federal Communications Commission (“FCC”) resolving the issues related to the rules governing the operation of Unlicensed National Information Infrastructure (“U-NII”) devices in the 5.9 GHz band;
2) NHTSA should consider recent developments in competing V2V technology that could more rapidly achieve many of the theoretical safety benefits of V2V; and
3) NHTSA fails to adequately consider vehicle automation technology that may greatly reduce the potential benefits of a V2V mandate.