NCTA asked the FCC today “to take a fresh look” at use of the 5.9 gigahertz band, arguing that the FCC’s allocation of the spectrum for dedicated short-range communications (DSRC) operations “has failed.”
“The 5.9 GHz band is the best opportunity to fill the accelerating need for mid-band unlicensed spectrum. Its position immediately adjacent to the world’s most important existing unlicensed band means that the country can bring it into use quickly and produce the wide channels needed for the next generation of Wi-Fi. And because there are very few incumbent deployments in the band, which today is saddled with over-regulatory, technology-specific rules, the Commission would not have to impose extensive co-existence regulations that could limit deployments and utility,” NCTA said in its filing in ET docket 13-49. “Furthermore, because of these benefits, deregulating the 5.9 GHz band by opening it for unlicensed use would also be an essential step in advancing 5G and the next generation of broadband. The time has come to recognize that Dedicated Short Range Communications (DSRC) technologies’ use of this band has failed, and that the country can no longer afford to hold 75 megahertz of optimal spectrum in reserve with the hope that the next twenty years will somehow be different than the last two decades of stagnation.
“NCTA therefore requests that the FCC conclude its 5.9 GHz proceeding, which has been pending for more than five years. To move this proceeding toward resolution, the Commission should issue a Further Notice of Proposed Rulemaking or other appropriate vehicle that: (1) recognizes that the heavy-handed, technology-specific rules of the past have failed, (2) proposes to open all or a sufficient portion of the band to promote unlicensed innovation and investment, and (3) considers how to more flexibly address the need for low-power, point-to-point connectivity in the automotive sector using one or more alternative spectrum bands,” the trade group urged.
“The marketplace has rejected DSRC for several reasons,” NCTA suggested. “First, despite years of development, stakeholders continue to be concerned about DSRC’s effectiveness. Automakers like BMW and Mercedes-Benz have explained to DOT that DSRC is not ‘trustworthy’ when it comes to basic safety features. The comments filed in response to the National Highway Traffic Safety Administration’s (NHTSA) Vehicle-to-Vehicle (V2V) NPRM — which proposed to mandate DSRC in all new light vehicles — revealed significant concerns regarding DSRC communications failures or inaccuracies caused by congestion and GPS problems. Second, Americans ‘need not settle for DSRC.’ Market-driven alternatives to DSRC are flourishing, even though they were not subsidized with a spectrum grant and government funds. As numerous commenters have emphasized to DOT, technologies like cellular-V2X (CV2X) can support vehicle safety in existing cellular bands. It should come as no surprise, then, that numerous automakers (including the 5G Automotive Association, BMW, Fiat Chrysler, Mercedes-Benz, and Tesla), technology organizations (including Broadcom, NGMN Alliance, and Verizon), and policy groups opposed the proposed NHTSA mandate. Third, conversations about the future of automobile safety have shifted to autonomous vehicles, which today rely on LIDAR, cameras, sensors, and radar, potentially supplemented by V2X communications as an additional sensor input. As DOT has recently recognized, V2X communications systems may ‘enhance the benefits of automation at all levels, but should not be and realistically cannot be a precondition to the deployment of automated vehicles.’”
The FCC, working with the Department of Transportation and the National Telecommunications and Information Administration, has conducted testing to analyze whether sharing between DSRC and Wi-Fi applications in the 5850-5925 megahertz band is feasible. The first phase of the testing in the FCC’s lab is complete, but the results have not been publicly released. It is unclear when field testing would be conducted.
Commissioners Mike O’Rielly and Jessica Rosenworcel, who have called on the FCC to repurpose at least some of the 5.9 GHz band, released statements today on the NCTA filing.
“It is pure folly to believe that DSRC will ever work as envisioned, as time and technology advancements elsewhere have undermined previous use cases,” Mr. O’Rielly said. “As NCTA correctly seeks in today’s ex parte letter, the Commission should quickly reexamine the 5.9 GHz band for repurposing. Once concluded, I am confident that at least 45 megahertz can be reallocated for unlicensed services without jeopardizing automobile safety.”
“I continue to support efforts to facilitate safe, unlicensed access to the 5.9 GHz band,” Ms. Rosenworcel said. “In the nearly twenty years since the FCC allocated this spectrum, autonomous and connected vehicles have largely moved beyond dedicated short range communications technology to newer, market-driven alternatives. It is time to take a fresh look at this band to allow a broader range of uses. By taking these steps now, we can support automobile safety, increase spectrum for Wi-Fi, and grow our wireless economy.”
In response to the NCTA filing, Scott Hall, a spokesman for the Alliance of Automobile Manufacturers, said, “Automakers support preserving the 5.9 GHz spectrum band for transportation safety applications intended to prevent crashes and save lives. This technology is being developed and already deployed in some cars on the road today, and according to NHTSA has the potential to reduce up to 79 percent of crashes. Any unlicensed use in the 5.9 GHz band should not be permitted unless it is proven it will not cause harmful interference to these safety systems.” —Paul Kirby, firstname.lastname@example.org