Parties Disagree on 5.9 GHz Sharing Issues

Parties disagree on a number of issues as the FCC refreshes its record in the 5.9 gigahertz band proceeding ahead of planned testing to analyze whether connected-vehicle and Wi-Fi applications are able to share the spectrum. Among them are how difficult it will be to share the frequencies and what sharing approach should be used. Some parties also suggested modifications to the FCC’s testing plan, and some connected-vehicle proponents said the agency’s deadline for completing testing was too optimistic.

The FCC released a public notice last month in ET docket 13-49 seeking to refresh its record (TRDaily, June 1). The public notice set a July 30 deadline for the submission of prototype unlicensed devices and a Jan. 15, 2017, deadline for the completion of testing. The public notice sought views on the FCC’s proposed test plan, as well as on pros and cons of two proposed approaches for sharing the 5850-5925 megahertz band between dedicated short-range communications (DSRC) and Wi-Fi operations.

Under Cisco Systems, Inc.’s proposal, in which the two services would share the entire 75 MHz, unlicensed devices would detect DSRC operations and vacate the spectrum. Under Qualcomm, Inc.’s plan, DSRC safety-of-life applications would use the upper 30 MHz of the spectrum, while non-safety DSRC and Wi-Fi would share the rest. That proposal is known as rechannelization.

In December, the FCC and the Commerce and Transportation departments announced a three-phase plan to test whether Wi-Fi devices can share the 5850-5925 MHz band with connected-vehicle applications without causing interference (TRDaily, Jan. 12). But first the FCC said it would update the record in its proceeding, which was launched in 2013 (TRDaily, Feb. 20, 2013).

“As it considers how to best promote sharing between unlicensed broadband and dedicated short range communications (DSRC) in U-NII-4, the Commission should account for how each technology has developed,” said the National Cable & Telecommunications Association. “When the Commission adopted the existing 75 megahertz allocation, both DSRC and 5 GHz Wi-Fi technologies were nascent. Circumstances have changed over the past 17 years. Despite having every opportunity to use the 5.9 GHz band, DSRC proponents still have not made meaningful use of the band, allowing 75 megahertz to lay fallow for more than a decade. By comparison, Wi-Fi in the 5 GHz band has delivered broadband access to hundreds of millions of consumers every day. Sharing in the 5.9 GHz band should reflect this fact.”

NCTA added that while it “supports efforts to use wireless technology to make Americans safer on the road,” the group stressed that the FCC “need not sacrifice broadband connectivity, economic opportunity, and other benefits that faster and more ubiquitous Wi-Fi will generate in order to achieve that goal.”

“First, although DSRC proponents’ advocacy in this proceeding has focused on crash avoidance and related safety functions, these applications require only a small portion of the 75 megahertz of spectrum claimed by DSRC interests,” the trade group said. “Many other uses DSRC interests have planned for the U-NII-4 band—but have not highlighted in this proceeding—are commercial applications that are not safety services. Furthermore, many of these same services are already offered using non-DSRC spectrum today in more efficient ways that do not preclude other spectrum uses.

“The Commission should not grant non-crash avoidance DSRC operations the extraordinary special status of a free nationwide exclusive license. And the Commission should not privilege these applications over other operations simply because they use the DSRC protocol,” NCTA said. “Second, the Commission can best facilitate sharing between DSRC and unlicensed uses in the 5.9 GHz band by adopting an approach that contemplates the use of crash-avoidance and related DSRC technologies only in the portion of the U-NII-4 band needed for these activities, and then designate these frequencies for their exclusive use. The U-NII-4 band represents the best opportunity for the Commission to provide access to additional unlicensed broadband technologies, including gigabit Wi-Fi. Rechannelization achieves that goal by fully protecting safety functions and, at the same time, enabling meaningful sharing in the rest of the band—all in a manner consistent with the emerging international consensus regarding use of the 5 GHz band.”

NCTA said that 30 MHz of spectrum is enough for safety-related DSRC applications, and it ripped Cisco’s approach, saying it would limit unlicensed access to spectrum, even for DSRC uses that are not safety-related. “This proposal would permit ‘sharing’ in name only,” NCTA said. “In reality it would be a poison pill for commercial Wi-Fi operations in the band.” “Finally, as the Commission gathers information to inform its decisions on U-NII-4 rules, the Commission should carefully design its test plan to ensure that it produces meaningful data about the impact of Wi-Fi sharing proposals on DSRC performance,” NCTA continued. “Specifically, the Commission’s testing strategy should: (1) focus on the provision of basic safety messages, which are the core DSRC function; (2) investigate multiple sharing approaches; (3) investigate the impact to DSRC of the existing co-primary system; and (4) measure real-world performance and efficacy of DSRC safety applications. The Commission also should not impose specific form factor or other requirements on test devices.”

While the Wi-Fi Alliance said it “appreciates the need for inter-agency coordination, it applauds the Commission’s decision to conduct its own testing in coordination with DoT and NTIA. Like the authors of the Wi-Fi Innovation Act, Wi-Fi Alliance urges that such testing not be unduly delayed. The public interest requires that the Commission create certainty for manufacturers of devices that may potentially operate in the band, providers of innovative services that rely on the higher speeds enabled by the band, and ultimately the millions of Americans (and billions worldwide) who will take advantage of increasingly greater access to unlicensed spectrum.”

Cisco said “that its proposed ‘detect and avoid’ approach is the clearest path to an equitable sharing mechanism for the 5.9 GHz band.  Importantly, Cisco’s proposed approach leaves the 5.9 GHz band as is, meaning that DSRC manufacturers would not be required to redesign their equipment to accommodate sharing with U-NII-4 devices.  Further, retention of the existing 5.9 GHz band plan would preserve consistency with the DSRC band plan in Europe (which too is based on 10 MHz channelization), providing manufacturers of DSRC and U-NII-4 equipment with economies of scale.  It also would allow creation of a global footprint for Wi-Fi in the U-NII-3 and U-NII-4 bands which, again, will give equipment manufacturers regulatory certainty and economies of scale.”

“The rechannelization approach proposed in the Public Notice raises significant challenges,” Cisco added. “First, it would require DSRC operators to redesign their equipment for 20 MHz rather than 10 MHz channelization. This will only slow the development of DSRC systems in the United States.  Furthermore, unlike ‘detect and avoid,’ the proposed rechannelization adds complexity in terms of understanding how the competing systems will access spectrum.  From the incumbent’s perspective there is less clarity and more uncertainty, and it therefore raises the bar on test design.  And, the proposed rechannelized band plan is used nowhere else in the world.” Cisco also said “that attempting to identify ‘safety’ versus ‘non-safety’ DSRC capabilities is a false distinction, in that all DSRC channels are planned for use by safety-related communications. This is confirmed by DSRC deployments that are already moving forward under the current DSRC band plan. During the next few months, for instance, there will be several safety-related DSRC vehicle-to-infrastructure (‘V2I’) deployments that use channels other than channel 172, which is set aside for Basic Safety Messaging for vehicle-to-vehicle (‘V2V’) applications. There is no longer anything theoretical about DSRC equipment: manufacturers have moved past the testing phase, received their required FCC approvals and are putting equipment into production for commercial deployment under the current DSRC band plan. Indeed, General Motors is equipping the 2017 Cadillac CTS with DSRC devices.” 

Cisco also stressed that “Phase I of the Commission’s Test Plan is critical, as the industry needs to know which sharing protocol is preferred before field testing begins under Phases II and III.  If this does not occur, the unlicensed community will continue to be fractured in their views.  It is far better to have the unlicensed community working together to achieve successful sharing with DSRC focusing on a single approach.  Also, the Commission’s proposed test plan must recognize that (1) three band edges are at issue in the 5.9 GHz band; (2) DSRC receivers could be blocked by U-NII-4 transmissions even where a DSRC receiver and a U-NII-4 transmitter are not tuned to the same frequency; and (3) detection capability is unnecessary for the three 10 MHz DSRC channels above 5895 MHz.”

But Qualcomm said that its rechannelization proposal “best ensures the protection of DSRC safety-of-life services while providing additional 40-MHz, 80-MHz and 160-MHz-wide Wi-Fi channels. Rechannelization will most reliably protect DSRC safety-of-life communications because it places these important messages in spectrum that remains exclusively allocated to DSRC and is as far away as possible from unlicensed operations in the current U-NII-3 band and the new U-NII-4 band. Out-of-band emissions (‘OOBE’) interference into DSRC Channel 172 at the lower end of the band from U-NII-3 operations was present under the prior U-NII-3 OOBE limits, and the FCC’s recent relaxation of these OOBE limits increases the potential for interference from U-NII-3 into DSRC.”

“In contrast to the rechannelization proposal, the detect-and-avoid proposal purports to open the entire 75 MHz-wide DSRC band for unlicensed use (even though Wi-Fi does not need to use the upper 30 MHz) and does not offer DSRC safety-of-life messages protection in spectrum that remains exclusively allocated to DSRC. Instead, the detect-and-avoid proposal leaves DSRC safety-of-life channel 172 in place where it is subject to increasing levels of interference from growing U-NII-3 unlicensed operations that will be in heavy use inside of vehicles, homes, and businesses across America. … The detect-and-avoid proposal also would require the design and implementation of additional Wi-Fi device hardware, possible standards development work, and extensive verification testing for the simultaneous sensing of multiple 10 MHz channels.”

Qualcomm also said that “because it would require Wi-Fi operations to avoid the entire band when DSRC packets are detected, the detect-and-avoid proposal greatly restricts the band’s availability for Wi-Fi.”

It also said that “rechannelization need not delay the deployment of DSRC. As a leading developer of DSRC chipsets and Wi-Fi chipsets, Qualcomm has explained that it can rapidly integrate the rechannelization proposal into DSRC and Wi-Fi products. Claims that rechannelization will require more extensive testing than the detect-and-avoid proposal are completely false. Placing safety-of-life communications in a part of the DSRC band that is off limits to Wi-Fi will better protect those communications and eliminate any chance that unlicensed systems do not detect DSRC safety messages and begin transmissions that interfere with these life-critical communications.”

Ericsson urged the FCC “to implement a policy of technological neutrality that would allow for multiple approaches to unlicensed operation in the U-NII-4 band. Opening this spectrum to a variety of uses and technologies will allow DSRC licensees, as well as others, to employ this spectrum similarly to other unlicensed applications, thus expanding the opportunities for the ITS industry as well as providing room for new entrants. There is no need to distinguish non-safety ITS applications from other unlicensed operation. Other forms of unlicensed operation should be allowed to share spectrum with non-safety ITS, just as there should be technology neutrality with respect to the specific wireless technologies employed for that purpose. A technologically neutral policy approach for non-safety ITS, and allowing other systems than ITS in the non-safety ITS spectrum, will both create opportunities for new and innovative unlicensed applications and stimulate the introduction and spread of ITS technology. Such an approach can help best meet the coverage and performance and flexibility goals of non-safety ITS and provide opportunities for other types of systems.”

Ericsson added “that the Commission should establish a policy of technological neutrality that also permits the introduction of LTE-based ITS with a focus to facilitate harmonization with other nations, future proof capabilities, and encourage economies of scale.”

“Opening up additional 5.9 GHz spectrum in the US is especially important because this spectrum is immediately adjacent to spectrum already allocated for U-NII use, and would effectively be an extension of those bands, allowing for additional 20, 40, 80, and even 160 MHz Wi-Fi channels,” said the Dynamic Spectrum Alliance. “Since DSRC is based on and similar to other 802.11 standards, DSA believes that all of these devices will be able to effectively share the 5.9 GHz band.”

Microsoft Corp. said it “supports U-NII devices sharing the 5.9 GHz band with DSRC operations on a secondary basis. Microsoft’s customers, whether in an enterprise or as individual consumers, access its cloud-based services over unlicensed devices in the 2.4 GHz ISM band, and increasingly in the 5 GHz U-NII bands. The 2.4 GHz band is congested, and even the additional spectrum in the 5 GHz U-NII bands is becoming saturated at certain times and places as the demand for mobile data grows unabated. Given that the majority of mobile data is delivered to user equipment over unlicensed spectrum, Wi-Fi expansion into the 5.9 GHz band would add necessary additional spectrum for unlicensed operations and enable the creation of more efficient, larger Wi-Fi broadband channels, thereby relieving congestion in the U-NII bands.”

“In order to strike the appropriate balance between the Commission’s goals of promoting public safety and achieving ubiquitous broadband access for the public, WISPA believes that the Commission should adopt the re-channelization approach as the preferred sharing method,” said the Wireless Internet Service Providers Association. “The re-channelization option is the better option because that sharing technique would benefit both DSRC operations that would receive additional interference protection, and U-NII devices that would have access to additional spectrum without having to incorporate complex sensing technology or potentially having to meet more restrictive out-of-band emission limits.”

“Given the choices at hand, the rechannelization proposal is the only option that both ensures DSRC safety-of-life communications are safe from harmful interference and opens up the U-NII-4 band for wide-band use by unlicensed devices,” said CompTIA. “The proposal will help keep drivers safe and provide new opportunities for innovation. We hope that the Commission properly weighs the positives and negatives of the two proposals and comes to the same conclusion we have: that the rechannelization proposal is the only possible avenue to preserve the band for use by important DSRC while unleashing additional, mush-needed spectrum unlicensed technologies.”

Five members of the Public Interest Spectrum Coalition submitted joint comments urging the FCC to pursue the re-channelization approach. The entities signing onto the filing were the New America Foundation’s Open Technology Institute, Public Knowledge, Engine, Common Cause, and Next Century Cities.

Contiguous unlicensed access to at least the lower 40 megahertz of U-NII-4 band, combined with technical rules harmonized with the U-NII-3 band, will enable access to 80 and 160 megahertz channels which can greatly amplify the potential increases in capacity for Wi-Fi operations,” the groups said. They added “that the re-channelization approach to sharing strikes the best balance between DOT’s legitimate interest in promoting crash avoidance and the Commission’s interest in promoting ubiquitous broadband connectivity and innovation. … The critical factor in striking this balance is the distinction between real-time safety and other non-safety (or non-time-critical) DSRC applications.” The groups said “that non-safety of life commercial and informational DSRC applications should share at least the lower portion of the band on an equal basis with unlicensed operators.”

In joint comments, the Alliance of Automobile Manufacturers, the Association of Global Automakers, the Intelligent Transportation Society of America, and Denso International America, Inc., said they “and others have relied on the FCC’s commitment to keep the 5.9 GHz band free from harmful interference. We have also relied on the FCC’s DSRC channelization, channel size, and use restriction rules in developing and testing DSRC equipment and applications. The magnitude of this program cannot be ignored, and the challenges faced by the private and public sectors in reaching this point should not be trivialized to suit the short-term interests of providers of non-safety-related services.”

“Given this occasion to refresh the record, we welcome the opportunity to remind the Commission that maintaining interference protection for the entire 5.9 GHz DSRC band was always the intention of Congress and should remain the focus of the Commission in this proceeding, particularly in light of the years of significant investment, research, and development,” the filing added. The entities added “that sharing of the 5.9 GHz DSRC band with unlicensed devices should be permitted only if it can be shown that such sharing will not interfere with DSRC’s ability to provide timely and reliable safety communications. As of the date of this submission, it has not been definitively shown that any of the proposed sharing methods described in the Public Notice – ‘detect and avoid,’ ‘re-channelization,’ some combination or hybrid of the two, or some other method – is technically capable of preventing interference to DSRC if the 5.9 GHz band is opened up to unlicensed devices. However, of the sharing approaches being considered, the one that holds the most promise is the ‘detect and avoid’ approach.”

“As explained more fully below, this is because ‘detect and avoid’ aims to prevent interference to DSRC operations by avoiding use of the 5.9 GHz band when DSRC operations are present in a way that requires no changes to the FCC’s rules, past orders, and statements regarding the incumbent and primary DSRC service,” the entities added. “Were the Commission to adopt the ‘re-channelization’ approach, the United States Department of Transportation [and] automakers would have to discard decades of costly research and go back to the drawing board to redesign DSRC to be compatible with a re-channelized band, thereby delaying the deployment of applications and equipment that have great potential to improve road safety and provide other important benefits.

“Indeed, based on current evidence, ‘re-channelization’ would likely require a redesign of DSRC equipment and applications, additional significant, expensive and time-consuming testing, as well as modifications of widely accepted industry standards – all of which would come at significant cost and unreasonably delay the roll-out of DSRC,” according to the filing. “Moreover, if all DSRC safety-related applications are forced into the upper three DSRC-exclusive channels, as the ‘re-channelization approach’ envisions, many potentially life-saving applications could be lost or greatly reduced.” The joint filing also said that the Commission, collaborating with DoT, “should specify sharing requirements in sufficient detail to protect the public while considering private sector business interests. Given the public’s interest in preventing harmful interference to DSRC operations, the FCC should not rely on voluntary industry standards to develop the specific sharing method. The FCC’s rules carry the full weight of the law and would apply to everyone operating in the 5.9 GHz DSRC band.”

The parties also offered a critique of the FCC’s proposed test plan, saying adjustments are necessary. For example, they said that the public notice failed to “provide enough information to determine whether the FCC’s planned tests will be able to appropriately assess the proposed sharing methods.” For example, they said, Phase I of the test plan “is vague or ambiguous in a number of important areas,” while Phase II “will need to consider a wider range of DSRC safety communication environments than the USDOT’s test plan.”

“The proposed timeline for the FCC’s tests is too aggressive,” the filing added. “For example, initial feasibility testing of adjacent channel interference resulting from compressing all DSRC safety-of-life-and-property and public safety applications into the top three 10 MHz channels could likely be performed within several months, although this level of testing would only confirm the extent of redesign required for the current DSRC system. This redesign would need to occur before any significant re-channelization testing could be undertaken. It has taken many years to develop the current system under the current FCC rules, and a redesign of the DSRC system would likely require multiple years to ensure that it could meet the stringent requirements for safety-of-life applications required for a NHTSA rulemaking.”

“While some of these applications might be labeled as ‘non-safety,’ they cannot be easily separated from safety-of-life-and-property applications,” according to the joint filing. “For example, some V2I non-safety applications that depend on sensing vehicles at particular locations on the roadway are likely to depend on latency-sensitive basic safety messages (‘BSMs’) and additional messages from vehicles to eliminate congestion and provide other benefits that enhance public safety.”

Wade Newton, a spokesman for the Alliance of Automobile Manufacturers, told TRDaily today, “Our comments are clear that we’re really talking about life-saving technologies here, V2V, V2I, even vehicle to pedestrian and vehicle to bicyclist.  That’s really at the core of what automakers are pursuing.  These other features that some – outside the industry – have speculated on really would take a back seat to the fundamental safety values that our industry prioritizes.”

The CAR 2 CAR Communication Consortium (C2C-CC) said that one of its key goals “is to promote the harmonization of V2V communication standards worldwide. As we remain only in the early stages of deploying V2V communications technology, industry and government have a unique opportunity and duty to establish harmonized rules and regulations. Failure to enact harmonized requirements will lead to delays, lost safety benefits, and needless expenditure of resources. In Europe, it has already been determined that reallocation of ITS channels is not an option. This being the case, re-channelization approaches (if adopted in the U.S.) would be a major setback for harmonization.” It added, “For safety-of-life systems to function properly, the C2C-CC believes that a minimum bandwidth of 50 MHz will be required.”

The consortium also said that the Commission’s “proposed timing for testing is not realistic. It calls for prototypes by the end of July 2016 and a three-phase test plan that includes: 1) lab testing, 2) small scale field tests, and 3) large scale field tests. Final conclusions should be drawn and relevant empirical data should be collected out of this testing. Thoroughly testing and validating a mitigation technique is a pre-condition before additional allocation for RLAN usage in 5.9 GHz can be done. DSRC is the primary user of the 5.9 GHz band and the burden to prove that RLAN will not lead to harmful interference, shall lie with the RLAN side. A test plan cannot be completed until the re-channelization approach is fully defined.”

General Motors Company expressed support for the comments submitted by the auto industry groups. “Considerable strides have been made in deploying DSRC technology under the existing 5.9 GHz channel allocation, and GM urges the Commission to take into account the significant investment and effort made to date in connection with such deployment in evaluating sharing solutions,” GM said. “The Re-channelization Approach would invalidate years of industry testing, standards development, and product research and would prevent immediate deployment of a technology that could save lives. On the other hand, GM believes that the Detect and Avoid Approach potentially presents a promising pathway to support DSRC and its safety-critical communications while allowing the spectrum to be shared for additional unlicensed use.”

Ford Motor Company said Cisco’s “’Detect and Avoid’ sharing concept, if proven to be technically feasible, is the only option that allows the use of the current DSRC system design. The Re-Channelization concept, as described in the Public Notice, would require a DSRC system redesign, thereby most likely delaying V2V safety communications deployment and potential safety benefits of V2V DSRC applications in the 5.9 GHz band.” Ford also said that “the Public Notice raises concerns that could undermine the efforts of government and private sector stakeholders to allow full functionality of DSRC in the band. We agree with the Alliance that the Commission should proceed with extreme caution as it considers the substantial technical, policy, economic, and practical challenges to allow U-NII use of the 5.9 GHz band.” The automaker also said that the FCC’s “goal of completing Phase III testing by January 15, 2017, will be difficult to achieve.” “The ‘detect and vacate’ sharing proposal (referred to in the Public Notice as ‘detect and avoid’) has the best chance of avoiding harmful interference to DSRC,” said the Toyota Motor Corporation. “This approach avoids co-channel interference from U-NII devices by requiring U-NII devices to vacate a channel when DSRC is detected.  It also avoids cross-channel interference from U-NII devices by requiring U-NII devices to vacate the entire band when DSRC is detected.”

However, Toyota also said that the FCC “could take elements from both the ‘detect and vacate’ approach and the ‘re-channelization’ concept in fashioning a sharing regime.  Consistent with the ‘re-channelization’ concept, the U-NII-4 boundary could be placed at 5.895 GHz and the upper three channels of the band (Channel 180, Channel 182, and Channel 184) could be reserved for DSRC communication.  The lower 40 MHz could be shared with U-NII devices, utilizing the ‘detect and vacate’ approach.  In addition, consistent with the ‘detect and vacate’ approach, DSRC would continue to use 10 MHz channels.  This hybrid approach would be minimally disruptive to DSRC and preserve all seven channels for safety communication.” Toyota also touched on the issue of treating non-safety applications differently than safety uses. “Although there has been extensive discussion about the value of distinguishing between safety communication and non-safety communication within the DSRC band, it is unlikely that the distinction achieves what proponents of the ‘re-channelization’ concept are seeking to achieve,” according to the automaker. “Although it is not envisioned that all DSRC traffic within the band will be safety communication, the expectation is that there will be safety communication on every channel and that no channel will contain only non-safety communication.  Communication within a channel that is not restricted by the Commission to public safety (i.e., Channel 174, Channel 176, Channel 180 and Channel 182) will be prioritized based on the channel access prioritization plans laid out in the Commission’s Report and Order in 2003.  Under that plan, safety-of-life communication will have the highest priority, followed by public safety communication, followed by non-public safety communication.”      

The Hyundai America Technical Center, Inc., stressed the safety benefits of DSRC technology and said it “supports the ‘detect and avoid’ solution over the re-channelization approach” if it works as designed. Rechannelization is likely to result in a V2X system redesign that “would likely cause significant delays in implementing the technology in production vehicles,” it said.

Volvo Group North America said, “We have concerns with the proposed re-channelization concept that would require the entire DSRC system to be redesigned. Lumping DSRC channels without any guard bands poses significant risk in terms of in-band, adjacent, and spurious channel interferences, thereby restricting the number of ‘reliable’ channels available for safety applications. The proposed test procedures and methodologies need to be refined, and substantial testing will be needed to ensure that the anticipated use cases for the DSRC technology are not compromised as a result of the proposed spectrum reallocation.”

The National Safety Council said, “The auto industry and the Department of Transportation have conducted extensive research showing the significant safety benefits of V2V. Through various testing regimes, standard-setting regimes and large-scale pilots, they have also established the best ways for vehicles on the road to exchange and impart information and the best ways for V2V to operate in the field, which includes seven 10 MHz wide channels that accommodate the requirement for very low latency, stability and reliability. The first passenger vehicle deployments will begin this year and the ability to retrofit DSRC devices on older cars in the fleet will greatly increase the technology’s penetration rate.

“We appreciate the testing that you will do to determine if sharing the spectrum can be done safely with other users,” the NSC added. “The FCC must protect the 5.9 GHz band to capitalize on all the investment (both private and government), research, development, testing and progress. Sharing of the spectrum should not be allowed unless it can be demonstrated that this will not interfere with or negatively affect the safety of life functions of DSRC.”

The University of Michigan Mobility Transformation Center (MTC) expressed support for the FCC’s planned three-phase testing plan, saying that “it can generate comprehensive results that will enable objective and science-based decisions. MTC and its members offer to make our facilities available for the real-world testing phase. We have a significant number of vehicles, plus real-world test environments that could be used. Specifically, MTC is working with its members and other partners, including the U-M Transportation Research Institute (UMTRI), to deploy the world’s largest and most concentrated DSRC vehicle fleet on the streets of Ann Arbor.”

SES S.A. and Intelsat S.A. noted the fixed-satellite service allocation in the 5.9 GHz band and said they “are concerned that the questions posed and the test plan presented in the Public Notice fail to take FSS operations into account, particularly with respect to the potential aggregate interference the incumbent FSS satellites may experience from the ubiquitous nature of unlicensed U-NII devices. SES and Intelsat therefore request clarification as to when and how FSS operations will be incorporated into the final test plan evaluating how DSRC, U-NII and FSS will coexist in the 5.9 GHz band and harmful aggregate interference to FSS satellites will be minimized.” They noted that they raised this issue in response to the 2013 NPRM.

Inmarsat, Inc., urged “the Commission to consider the importance of both satellite and terrestrial ITS solutions, and ensure the safety of these solutions, regardless of platform.”

A number of state and local agencies and public safety groups also weighed in to highlight the safety benefits of DSRC applications and urge the Commission to ensure that they are protected.

The National Public Safety Telecommunications Council said it “recommends that spectrum sharing in the 5.9 GHz DSRC spectrum be pursued only if doing so would not impact the integrity and reliability of current or prospective DSRC intelligent vehicle-to-roadside or vehicle-to-vehicle operations. Accordingly, NPSTC supports comprehensive testing which incorporates real-world situations likely to be encountered if U-NII operations are ultimately allowed in the band on a shared basis with operational DSRC communications. While DSRC has only the 75 MHz of spectrum at 5.850-5.925, unlicensed U-NII operations already enjoy 580 MHz of spectrum allocated throughout the 5 GHz band.”

A coalition of public safety groups said “we strongly encourage the FCC to preserve and promote, as a matter of public safety and safety of life, the use of DSRC in the 5.9 GHz band according to the current FCC channel plan. Altering the use of 5.9 GHz or its channel plan will destroy the crucial work that has been done to bring V2V, V2I and V2P into reality just as it is on the cusp of widespread deployment. We support sharing technologies only if they can be proven safe and without any interference with the safety of life functions of DSRC across all channels in the 5.9 GHz band according to the current channel plan. The burden of proof should be on those non-DSRC entities who want to share the band. Sharing testing should in no way delay the deployment of DSRC and its transformative benefits.”

The following groups signed onto the filing: the National Association of State EMS Officials, the International Association of Fire Chiefs, the National Sheriffs’ Association, the National Association of EMS Physicians, the International Association of EMS Chiefs, the National Association of EMS Educators, and the Paramedic Foundation.

“With regard to spectrum sharing in the band, APCO recommends that any sharing arrangement ensure that no harmful interference occurs to public safety applications in the 5.9 GHz band,” the Association of Public-Safety Communications Officials-International said. “Any sharing techniques under consideration should undergo substantial testing and be proven effective in advance, before being used in a way that could impact public safety communications. In this way, the Commission could best promote the advancement of V2V and V2I’s lifesaving potential.”

“Any sharing of this protocol has to work around what is currently being deployed as well as what is planned to be deployed for DSRC applications. Thorough testing must be completed to determine whether any change in the protocol is safe before sharing implementation,” said the Arizona Department of Transportation, which is involved in projects to use the band for vehicle-to-infrastructure applications. “Proposals that call for re-channelization of the 5.9 GHz band will set back the future of traffic safety several years and cost hundreds of millions of dollars in wasted research, development and investment.”

The Colorado Department of Transportation said it “opposes any sharing” of the 5.9 GHz band. It also said it opposes both the Cisco and Qualcomm sharing proposals. “CDOT urges the Commission to give state DOTs time to deploy the needed technologies and not lose sight of how we can save lives with this technology as well as potentially transform mobility on our roads,” it added.

New York City said it “has significant concerns with proposals to reengineer the dedicated short range communications (DSRC) radio spectrum currently reserved for traffic safety and ITS. If current regulations were to be changed to allow ‘spectrum sharing’, the City of New York supports allowing those devices and systems that are tested to prove that they will cause no harm to traffic safety systems, for example by immediately suspending their communications when they detect the presence of ITS on DSRC. Any impairment to the operation of DSRC will undermine the ITS investments made and being made by the City of New York and many other jurisdictions and the automakers.

“It could prevent the City of New York and the United States from realizing the benefits of a $20 million grant from the United States Department of Transportation to use DSRC to create a ‘Connected Vehicle’ environment allowing vehicles to communicate with each other, the transportation infrastructure, and other street and sidewalk users such as pedestrians and bicyclists. It could also undermine the nation’s work to reduce the 30,000 lives lost yearly in the United States in traffic crashes and the City of New York’s Vision Zero efforts to reduce and eliminate traffic deaths and serious injuries.”

The Port Authority of New York and New Jersey said it “believes that DSRC V2V and V2I communication technologies may be able to co-exist with existing Wi-Fi technologies across the 5.9GHz spectrum, however, ample safety and security mechanisms must be built into the new devices to prevent interference of new V2V and V2I technologies designed to save lives and save money.” It urged the FCC to test both the Cisco and Qualcomm approaches.

The International Bridge, Tunnel and Turnpike Association said it “opposes any sharing of the 5850-5925 GHz Band (5.9 GHz Band) between Dedicated Short Range Communications (DSRC) and Unlicensed National Information Infrastructure (U-NII) devices.  DSRC applications for Vehicle-to-Vehicle (V2V) and Vehicle-to-Infrastructure (V2I) wireless communications promise significant safety benefits and utility to the traveling public.  There are many reasons why the development and implementation of DSRC services have been slow in coming but many applications are now poised for near-term deployment, holding the potential to save tens of thousands of lives every year. Making changes to the DSRC spectrum’s availability at this time will adversely impact bringing these service[s] to market and correspondingly delay the inherent safety benefits.”

The San Francisco Bay area’s Metropolitan Transportation Commission also urged “the Commission to preserve the 5.9 GHz band and its channelization as designed for DSRC safety-of-life benefits and mobility applications. DSRC-based applications promise significant safety benefits and utility to the traveling public. The dissemination of DSRC is now poised for near-term deployment and holds the potential to save tens of thousands of lives every year. Any sharing protocol must accommodate currently deployed and planned deployments of DSRC applications. Thorough testing must be done to ensure that the protocol is safe before any sharing implementation is done.”

In joint comments, the Oakland County, Mich., Connected Vehicle Task Force and other entities said DSRC spectrum should remain available only to such applications. Others signing onto the filing included the Michigan Department of Transportation and the Traffic Improvement Association of Michigan.

In a separate filing, the Michigan Department of Transportation, which said there are about 130 DSRC roadside units in operation in the state, said that any spectrum sharing framework must include an “assurance that DSRC transmissions on our existing and proposed time-critical safety applications are uninterrupted, with no signal interference from other equipment operating on the same or adjacent bands.”

The Utah Department of Transportation said, “Momentum has been building toward DSRC deployment for a number of years.” It cited deployments currently in Utah and nine other states with deployments in additional states and cities planned over the next 18 months. It also said that “it is difficult to classify individual applications as safety or non-safety. Further, most deployments will involve both safety and non-safety applications; the various applications are synergistic.”

Other state and local agency filers included the New Mexico Department of Transportation, the City of Albuquerque Transit Department, the Mid-Region Metropolitan Planning Organization in New Mexico, and the Maricopa County, Ariz., Department of Transportation. – Paul Kirby, paul.kirby@wolterskluwer.com

 Courtesy TRDaily