Rulemaking comments for DSRC for V2V include potential for use of cellular-V2X, sharing of DSRC spectrum.
As the cellular industry and standards bodies increasingly seek to support connected vehicles, the federal government is considering whether to mandate the use of dedicated short-range communications capabilities – or interoperability with DSRC – in all new light vehicles. The public comment period for the National Highway Transportation Safety Administration’s proposed Federal Motor Vehicle Safety Standard rulemaking closed this week.
The NHTSA said in the proposed rulemaking it “believes that [vehicle-to-vehicle communication] has the potential to revolutionize motor vehicle safety. … The agency believes that V2V will be able to address crashes that cannot be prevented by current in-vehicle camera and sensor-based technologies (“vehicle-resident” technologies). This is because V2V would employ omnidirectional radio signals that provide 360-degree coverage along with offering the ability to “see” around corners and “see” through other vehicles. … As another source of information about the driving environment, moreover, the agency also believes that V2V can be fused with existing radar- and camera-based systems to provide even greater crash avoidance capability than either approach alone.”
The NHTSA added it believes a mandate for V2V communications is necessary in order to achieve a workable market and mass coverage for V2V and that it proposed to “standardize the content, initialization time and transmission characteristics of the basic safety message regardless of the V2V communication technology potentially used.” The proposed rulemaking outlined a timeframe in which a final rule on the subject would be made in 2019, a phase-in period would begin in 2021, and compliance would be required by 2023.
Private citizen comments on the topic consisted largely of opposition to increased radio frequency exposure and the inability to opt out of a vehicle equipped with RF communications if a mandate for V2V were to be adopted.
Below are selected excerpts from telecom and transportation companies and organizations on the National Proposed Rulemaking:
AT&T: AT&T supports the intent of the rulemaking to promote public safety, and believes the NPRM has sought to strike a balance between setting a target for spurring the widespread deployment of a V2V capability to drive vehicle safety improvements while still leaving room for innovation and competition in the marketplace.
AT&T takes no position at this time on the specific wireless technology to be used for the communication between vehicles—i.e. the transmission of the [BSM] — in the context of the proposed mandate. Given the extensive development and market readiness of DSRC-based communications, the DSRC technology appears to be a viable means of achieving many of NHTSA’s near term safety objectives. Nevertheless … there are other rapidly emerging [Third Generation Partnership Project]-based technology, including [cellular]-V2X standards … defined in 3GPP Release 14,11 that may offer improved radio access technology performance relative to DSRC and that in turn may offer both relatively greater safety benefits and relatively greater longevity and scalability. Although the nascence of this technology obviously challenges NHTSA’s ability to fully assess it now, it is clear it will be market ready in approximately the same time frame contemplated in the NPRM for deployment of a V2V capability. Accordingly, the final rule should be careful not to foreclose continued research and development into that technology—or, for that matter, any other technologies that will be supportive of NHTSA’s safety goals.
Verizon: As NHTSA moves forward with requirements for V2V, it should craft open performance requirements for V2V solutions, rather than limit the types of communications systems that might be used to meet those requirements. By focusing on system performance specifications and requiring interoperability, NHTSA will encourage developers and providers to collaborate and innovate towards efficient and safe next-generation V2V capabilities. Some of these solutions may in fact be DSRC driven. But NHSTA should not prescribe specific technology that must be deployed to meet its proposed mandate, since limiting possible solutions to a specific type of spectrum or technology will unnecessarily hamstring innovation and slow down development of
potential safety improvements. As long as a proposed solution is both interoperable with other V2V systems and meets the specifications NHTSA eventually adopts, there is no reason to limit the technology that transmits the messaging between vehicles or between a vehicle and infrastructure.
Given the long runway for widespread adoption of V2V systems, a more flexible
approach will prevent V2V systems from being permanently fossilized in 2017. At this early stage in development, the industry may not yet be ready to make a one-time, final determination about which technology is best-suited for a particular purpose for the next twenty-plus years. A flexible policy regarding the types of technology used for V2V will allow V2V efforts to reach their greatest potential. If only DSRC is permitted, the capabilities of V2V technology will always be confined to only what DSRC can do.
General Motors: GM believes that the NPRM’s proposed lead-time and phase-in are too aggressive. This is especially true given the amount of remaining open issues and the extensive vehicle integration required to develop V2V systems. FMVSS 150 is among the most far reaching and complex rules attempted in ground vehicle transportation. As we point out in these comments, parts of the proposed rule need updates and changes. These changes in turn may lead to updates in the applicable standards. And manufacturers will need time to interpret and implement these updates, as will their suppliers and other technology partners. These will include significant activities for vehicle, production control, support and “back office” systems, based upon a clear understanding of the mandate requirements and how to develop and integrate its requirements into vehicle parts and systems. V2V will be integrated with many other vehicle systems and functions, including vehicle networks, cybersecurity, telematics/infotainment, chassis/body, powertrain control, IT, electrical controls/displays, antennas and more. As a result, manufacturers will need more time than the proposal provides in order to deliver fully developed, validated and mandate-compliant products that compatibly communicate across manufacturers’ devices to create the V2V system of safety information sharing.
We suggest two changes:
a. A longer lead time from final rule to first mandated products of at least 3 years.
b. A less aggressive four year phase-in, such as: 25%, 50%, 75% and 100% over the course of consecutive years.
NCTA – The Internet and Television Association: The [Federal Communications Commission] has … identified the 5.9 GHz band for sharing and has undertaken a multi-year rulemaking and testing process to discern the best sharing technology. Because dedicated short range communications technologies are still in the pilot phase and have not yet been widely deployed commercially, now is the time for the FCC to identify an optimized sharing approach that will allow both V2V safety messages and Wi-Fi to flourish in the band. Without careful consideration, NHTSA’s regulatory mandate could undo this important endeavor and waste years of FCC and industry effort to bring high speed broadband over Wi-Fi to consumers. Unfortunately, the NPRM has not undertaken this consideration and does not reflect the costs of the proposed new regulation on national spectrum policy or on investment in and deployment of mobile broadband.
We therefore recommend that NHTSA act in this proceeding, consistent with governing law, to:
• Recognize the differing jurisdictions of NHTSA and the FCC. NHTSA lacks jurisdiction over spectrum policy and interference issues, which have been delegated by Congress to the FCC.
• Accurately account in its cost-benefit analysis for the significant opportunity cost of restricting wireless broadband associated with the proposed mandate.
• Decline to impose a mandate that companies adopt a specific technology, chosen by the agency, to achieve safety goals in light of the excessive costs of doing so.
• Consider meaningful regulatory alternatives to such a mandate.
Cisco: In the vehicular transportation segment, Cisco has authored a reference architecture for roadside deployment of (DSRC); we have proposed a potential technology solution to allow Wi-Fi to share DSRC spectrum without harmful interference to DSRC; we are activity working with the automotive industry on in-vehicle networking; and we offer cloud services to automotive manufacturers to manage data generated by vehicular systems for the service of the existing fleet and future design of vehicles.
Cisco … agrees with the notice’s finding that DSRC is “the only mature communication option that meets the latency requirements to support vehicle communication based crash avoidance.” DSRC technology, and in particular the BSM, has undergone extensive testing under the direction of the Department of Transportation and has been deployed in a wide array of demonstration projects. Business model issues are largely settled in that there is a clear idea of the cost of adding the technology to light vehicles and that the radio would be maintained and supported over time by the automotive OEMs similar to other safety technologies in vehicles today. Beyond the purchase price of the vehicle, consumers would not be asked to pay a subscription fee. … A number of radio vendors offer DSRC, including aftermarket products that can help accelerate DSRC adoption, and DSRC is now shipping as standard equipment in GM Cadillac CTS models. Use cases are proliferating and related standards work continues to advance.
As a technology vendor, Cisco is now beginning to see evidence of state implementation of roadside DSRC systems independent of the BSM-focused demonstration projects to date. Cisco further believes that cellular-based systems have great promise to address radio-based safety communications in the future, recognizing that the application of this technology is not as mature as DSRC today. Up until recently, the standards on which 4G LTE systems are based could not reasonably address radio-based communications safety for vehicles. The deficiencies were many – failure to meet latency requirements, coverage, lack of a V2V capability, etc. That is beginning to change with industry adoption of new cellular standards for V2V and we are beginning to see the first testing initiatives for safety applications of the new radios that are based on these standards, including radios that enable direct V2V communication without routing transmissions through infrastructure.
Read more industry comments on the proposed DSRC for V2V mandate from Qualcomm, NXP, Wi-Fi Alliance and more in Part Two.
