June 1, 2016–The FCC today finally released a public notice seeking to refresh 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. The public notice, which was adopted May 25, sets a July 30 deadline for the submission of prototype unlicensed devices and a Jan. 15, 2017, deadline for the completion of testing. Comments on the notice are due 30 days after “Federal Register” publication and replies are due 15 days after that in ET docket 13-49.
The public notice seeks 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. The public notice calls this option “re-channelization.”
The Commission is also inviting comments on alternative ways to share the frequencies. And it solicits views on specific DSRC use cases, including when stakeholders expect them to be deployed.
In December, the FCC and the Commerce and Transportation departments announced a 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).
The first phase of the testing is to occur at the FCC’s lab “to determine the technical characteristics of prototype unlicensed devices and how they are designed to avoid causing harmful interference to DSRC,” the public notice observed. “As part of the Phase I tests, the agencies will assess the devices’ emission characteristics as well as parameters such as the threshold at which a U-NII device detects DSRC signals on a channel and the amount of time required for a device to vacate the channel so as to avoid interference for devices that will implement ‘detect and avoid’ approaches.”
“The second phase will be based largely on Section 6 of the DoT Test Plan and will involve basic field tests with a few vehicles at a DoT facility,” the public notice said. “The Phase II tests will determine whether the techniques to avoid interference to DSRC that were evaluated in Phase I’s lab tests are effective in the field.”
“The third phase will involve tests with many more vehicles, more test devices, and real-world scenarios at a suitable facility,” the public notice pointed out. “Phase III tests may consider many of the elements discussed in Sections 4, 5, and 9 of the DoT Test Plan (e.g., aggregate effects in dynamic environments).”
The FCC is seeking comments specifically on the first phase of the test plan. “The three phases of the test plan are interdependent. We anticipate that all three phases of the test plan will be completed before reaching any conclusions as to how unlicensed devices can safely operate in the 5.850-5.925 GHz band,” the public notice said. “The Commission, however, expects that this testing will be concluded and submitted no later than January 15, 2017. Do stakeholders believe that this is sufficient time to submit prototypes? Given the importance of this item, parties should explain in detail why any additional time should be allocated. Engineers from the FCC will carefully examine the options and mechanisms for sharing in the 5.850-5.925 GHz band and closely scrutinize the myriad interference prevention approaches. The FCC, in consultation with the DoT and NTIA, will continue to collaborate, as well as engage with other stakeholders, and may make adjustments to the plan as it evolves.
“Our goal is to collect the relevant empirical data for use in analyzing and quantifying the interference potential introduced to DSRC receivers from unlicensed transmitters operating simultaneously in the 5.850-5.925 GHz band,” the FCC added. “We anticipate that the tests conducted to date, combined with the results of the three-phase test plan described above, will provide reliable, real-world data on the performance of unlicensed devices designed to avoid interfering with DSRC operations in the 5.850-5.925 GHz band.”
In addition to seeking prototype unlicensed devices, the FCC also asked “that parties provide 5.9 GHz DSRC RSU [road side unit] and OBU [on-board unit] equipment, against which we will test the prototype unlicensed, interference avoiding devices. In addition, we request comment on what date is reasonable for prototype submission, and what constitutes an acceptable prototype (e.g., does the device need to be able to communicate with another device, or is it sufficient for the device to only demonstrate the sharing technique?). The deadline for submission of prototypes shall be July 30, 2016; however, we delegate the authority to OET to establish the submission requirements and grant waivers or extensions of the submission deadline or requirements, as necessary. Given the importance of this item, parties should explain in detail in any waiver or extension request why such request should be granted. Parties that would like to submit devices for testing should advise OET as soon as possible and should deliver their device at their earliest opportunity.”
The public notice observed that “each proposed sharing approach relies on a different mechanism to avoid co-channel operations when DSRC channels are in use at a given location. We now seek comment on the merits of these two approaches. What are the benefits and drawbacks of each approach? Would one approach be better than the other (e.g., minimize the risks of interference to DSRC more effectively while providing a comparable degree of meaningful access to spectrum for unlicensed devices)? For either approach, is it necessary for the Commission to specify all the details of the interference avoidance mechanism in the FCC rules or can this be addressed by relying primarily on industry standards bodies to develop the specific sharing methods? If the former, what specific technical details need to be specified in the FCC rules (e.g., out of bound emissions, noise tolerance, detection threshold, channel vacate time, etc.)? Has industry agreed upon performance indicators for DSRC, and if so, what are these metrics and is there a process to hold products to these performance levels?
“We also seek comment on how the choice of avoidance protocol affects the deployment and performance of DSRC,” the FCC added. “Would ‘re-channelization’ require any change in the design of the DSRC electronic components contained in DSRC prototypes or just require a change in the processing of the data? We seek comment on whether changing the channel plan would require re-testing of DSRC and, if so, precisely what would need to be done, why, and in what timeframe? Commenters responding to this question should provide specific information about why the completed tests are not applicable to re-channelization, how any new tests will differ from those already performed, and the relevant timeframes for completing these specific tasks.”
“We also seek comment on what DSRC-related use cases should be expected and permitted in this band,” the public notice added. “Commenters should provide specific information regarding what DSRC applications are anticipated, what are the projected spectrum needs for each application, and how would the commenter classify each (i.e., safety, non-safety, time critical or not)? Should the DSRC offerings provided on a priority or exclusive basis be restricted to safety-of-life or crash avoidance purposes? What are the technical or policy reasons for differentiating between safety-of-life and non-safety-of-life applications? Are there meaningful distinctions between DSRC applications that are safety-related and those that are not, such as applications that are time critical? For parties that advocate for re-channelization, is there a natural bifurcation point if we decide to separate safety-related and non-safety-related DSRC? For instance, while entertainment, social media, maps, and parking applications are not safety-related, what is a good definition for a feature or service to be considered truly a safety-of-life use? How does our current band plan and these sharing approaches match up with international efforts for safety-related DSRC systems?
“To help us fully evaluate the potential effects of re-channelization, please provide the projected timeframe for introduction of DSRC deployments under the current channel plan,” the FCC added. “What market penetration (e.g., percentage of cars on the road) is needed for DSRC to reliably provide safety-of-life functions or prevent vehicle-to-vehicle collisions? What are the projected timeframes for achieving the penetration levels needed for each safety-of-life or crash avoidance function to be effective? Will these penetration levels be met by equipment that is native to the automobile or through standalone or retrofit devices? Would these timeframes change if re-channelization occurs and by how much? In the meantime, what other spectrum bands, driver-assist technologies, and commercial offerings are providing similar services to those envisioned using DSRC? Is it possible that autonomous car and other technologies could bypass DSRC safety-of-life capabilities prior to reaching a sufficient technology penetration to make this service effective?”
The FCC also asked whether the 5.9 GHz band offers “the most value for unlicensed operations?” “In addition, we invite interested parties to suggest other approaches that would facilitate unlicensed use of the 5.850-5.925 GHz band without causing harmful interference to DSRC operations,” the public notice continued. “Would a hybrid approach taking elements from both the ‘detect and avoid’ and the ‘re-channelization’ proposals create benefits for both DSRC and U-NII users? For example, are there advantages to an approach where unlicensed users and DSRC non-safety of life applications would share access to the lower 45 megahertz of DSRC spectrum, while unlicensed devices would use a ‘detect and avoid’ approach to avoid, and thus protect, co-channel safety-of-life DSRC operations in the upper 30 megahertz of spectrum?”
In a joint statement, Commissioners Jessica Rosenworcel and Mike O’Rielly highlighted the fact that the public notice establishes deadlines for the submission of prototype devices and for testing to be completed. “Both deadlines are important,” they said. “They provide much-needed certainty for the unlicensed community and car manufacturers.
“This Public Notice puts in place a framework to demonstrate that unlicensed use in the 5.9 GHz band is possible without causing harmful interference to incumbent licensees, and in particular to Dedicated Short Range Communications (DSRC) systems,” the Commissioners added. “It establishes procedures for the submission of prototypes for testing and a test plan that will be led by the Commission, in consultation with the Department of Transportation and National Telecommunications and Information Administration. Specifically, we refresh our record in part to obtain further information about the two 5.9 GHz spectrum sharing technologies offered to date—by Qualcomm and Cisco. We look forward to the record that develops.”
They also thanked FCC Chairman Tom Wheeler “for incorporating our edits in this Public Notice. In particular, we are pleased that it now requests more information about the current status of DSRC development, anticipated DSRC uses and spectrum needs, how to define safety-of-life applications, and the treatment of non-safety-of-life functions, among others.”
“I am pleased that the agency is putting all options on the table,” Commissioner Ajit Pai said in a statement. “As we enter what will hopefully be the final stretch of this proceeding, we need to do so with open minds. The FCC allocated this spectrum for Dedicated Short Range Communications (DSRC) operations at the end of the last century. DSRC is intended to enable wireless communications to promote safety for both vehicle-to-vehicle and vehicle-to-infrastructure purposes. But at the time of the allocation, we did not have the commercial applications or new radar technologies that can play a key role in improving highway safety and thus saving lives. My hope is that we make a smart decision quickly—both in this spectrum band and in the lower, 120 MHz of the 5 GHz band—to allow this spectrum to directly benefit consumers. I look forward to working with my colleagues on doing just that.”
Stakeholders on both sides of the issue welcomed the public notice today. “The FCC took a significant step forward today toward making sharing on the 5.9 GHz band a reality,” said the National Cable & Telecommunications Association. “Not only does the FCC ask the right questions about how to test both the Qualcomm and Cisco sharing proposals, but it also asks how to distinguish crash-avoidance from non-safety DSRC applications. NCTA is committed to finding a sharing solution that works and today’s FCC action points the country in the right direction.”
“Qualcomm is very pleased that the FCC issued the Public Notice concerning 5.9 GHz,” said Dean Brenner, senior vice president-government affairs for the company. “We remain committed to the twin goals of ensuring the rapid, broadest possible rollout of DSRC safety services in a portion of the spectrum that would remain exclusively allocated for DSRC, and enabling the safe sharing of the remaining portion of the spectrum to support the rollout of other DSRC services and to provide more spectrum for Wi-Fi. Our proposal achieves these two goals. We look forward to working with the FCC and all other stakeholders as the FCC rulemaking and testing processes move forward.”
“The July 30 and January 15 deadlines for prototypes and the completion of FCC-led testing, respectively, are perhaps the most important part of the Public Notice,” said Michael Calabrese, director of the Wireless Future Project at the New America Foundation’s Open Technology Institute. “The auto industry has been squatting on this spectrum for more than 15 years without deploying anything. Testing should focus first and foremost on auto safety and determine exactly how much of the 75 megahertz band is needed if the Department of Transportation ultimately mandates vehicle-to-vehicle safety signaling. Aside from real-time safety applications, sharing between Wi-Fi and DSRC non-safety applications is an easier and less pressing concern.”
“The Alliance of Automobile Manufactures continues to work with the FCC, DOT and NTIA in evaluating potential sharing solutions for the 5.9 GHz band, while ensuring that automotive safety systems are protected from harmful interference,” the trade group said. “Automakers believe that the Cisco/Denso ‘detect and avoid’ approach is the best path forward when evaluating how to allow other stakeholders access to this spectrum for Wi-Fi purposes. Automakers have always been open to sharing the band so long as it can be done without interference and it puts roadway safety first. As the testing process moves forward, we urge the FCC, NTIA and the Administration to take into consideration all the lifesaving benefits this technology offers.” – Paul Kirby, paul.kirby@wolterskluwer.com
Courtesy TRDaily