TR Daily Group Seeks ‘Flexible’ 5.9 GHz Band Licensing, Performance Requirements
Friday, May 17, 2019

Group Seeks ‘Flexible’ 5.9 GHz Band Licensing, Performance Requirements

The Association of Global Automakers, Inc., today proposed that the FCC “move to a modern, flexible-use licensing regime that will allow for regulatory certainty to facilitate the rapid deployment of road-ready technology and permission-less innovation in the 5.9 GHz band, including the introduction of new vehicle-to-everything (‘V2X’) technologies.”

In an ex parte filing in ET docket 13-49 and GN docket 18-357, the group said, “While conforming the 5.9 GHz service rules to spectrum management best practices already used by the Commission in a variety of bands, Global Automakers’ proposal will preserve and advance the life-saving safety benefits of V2X services by ensuring Basic Safety Message (‘BSM’) interoperability and/or backwards compatibility with deployed services. Finally, to ensure scaled deployment of V2X services and achieve the network-effects necessary to maximize safety benefits, Global Automakers’ proposal includes aggressive buildout requirements.”

The group’s filing comes in the wake of FCC Chairman Ajit Pai’s announcement earlier this week that he plans to ask his fellow Commissioners to open a rulemaking to consider whether the agency should reallocate the 5.9 gigahertz band for unlicensed devices or leave it as is, which he said he was “skeptical” of doing, or choose something in between (TR Daily, May 14). “Unfortunately, while Wi-Fi hit the gas in 1999 and never looked back, DSRC [dedicated short-range communications] has been stuck in neutral,” the Chairman said.

The auto group said it “recognizes that the current regulatory framework for the 5.9 GHz band is unworkable for the V2X future. By limiting use of the 5.9 GHz band to DSRC-based services, the Commission’s existing service rules for the band do not allow for deployment of other existing and future technologies that may be developed to provide V2X services. However, simply opening the band to new technologies without restrictions would undermine the very functionality of V2X services. For instance, V2X technology is built around the ability to transmit and receive the Basic Safety Message (‘BSM’), which provides key information about moving vehicles including size, position, speed, and heading. Technologies that are unable to share this message with other connected vehicles deploying different technologies will not be able to achieve the primary safety benefits of V2X services.

“Global Automakers urges the Commission to rethink its regulatory framework for the 5.9 GHz band, bearing in mind the following principles: 1. The entire 5.9 GHz band must be retained for auto-safety services. 2. The FCC and relevant federal agencies must ensure a data driven, fact-based approach for evaluating interoperability; evolution and backwards compatibility; and the potential coexistence of multiple V2X technologies in a technology-neutral manner. 3. Any band plan that accommodates multiple technologies must avoid harmful interference among existing services. 4. All V2X-equipped vehicles and infrastructure must be able to provide for communication of the Basic Safety Message. The regulatory framework must promote investment in deployment of lifesaving V2X services for the benefit of the driving public now,” the filing said.

“In light of the foregoing, Global Automakers proposes that the Commission modernize its rules for the 5.9 GHz band by transitioning from a command-and-control approach that specifies a single technology to a flexible-use licensing scheme that is agnostic to the technology used. Global Automakers further proposes adopting policies to facilitate research and development with respect to future uses of the 5.9 GHz band, including new V2X technologies and unlicensed use,” the group added. “Finally, Global Automakers proposes industry-wide buildout requirements to ensure rapid deployment.”

“Global Automakers proposes that the Commission revise Part 90 of its rules to allow any V2X auto safety technology to use the 5.9 GHz band, as long as the technology: (1) Complies with the band’s existing technical rules and does not interfere with an incumbent, deployed technology; and (2) Supports: (a) BSM interoperability; and/or (b) backwards compatibility to an incumbent, deployed technology,” according to the filing. “The benefits to this approach are threefold. First, the proposal will provide broad latitude for innovation — not only for existing technologies, but for future V2X technologies. Second, unleashing this innovation will not compromise the safety benefits of V2X technologies because of the interoperability and backwards compatibility conditions which will preserve transmission of the BSM regardless of technology. Third, this approach will remove uncertainty about the future of the 5.9 GHz band and speed deployment of V2X technologies, making transformative safety benefits available to the public now, expediting the valuable network-effects upon which these technologies rely, and solidifying industry incentives to continue investing in V2X technology.”

“Global Automakers also proposes two policies to facilitate continued research and development on future potential uses of the 5.9 GHz band that could eventually allow new services to access the band without sacrificing the Commission’s policy objectives with respect to V2X services,” the group continued. “First, the Commission should allow for experimental licensing for V2X technologies that do not meet the requirements set forth above. C-V2X [cellular vehicle to everything] providers have had success using experimental licensing to test C-V2X technology in the 5.9 GHz band in the absence of enabling service rules. Allowance for experimental licensing will allow for valuable research of this kind to continue while retaining certainty about the 5.9 GHz band plan.

“Second, the Commission should expedite FCC-DOT joint testing of the feasibility of unlicensed sharing of the 5.9 GHz band under the agreed test plan, including Phase II already underway and Phase III,” the filing said. “As Global Automakers has previously explained, this additional testing ‘should be expeditiously conducted,’ with technical changes that reflect the results of Phase I testing, ‘to inform data-driven decision-making about the future of the 5.9 GHz band.’ The testing should also be expanded to study compatibility of unlicensed use with C-V2X services in addition to DSRC.”

“Consistent with updating the regulatory framework for the 5.9 GHz band to reflect modern spectrum management best practices, Global Automakers also recommends that the FCC adopt deployment benchmarks for the band,” the filing said. “In order to ensure the 5.9 GHz band is put to use for the benefit of the driving public quickly and efficiently,” the group said, non-exclusive V2X licensees should have to meet interim and final build-out mandates.

The interim requirement would mandate the “[d]eployment of two million V2X radios within five years. Such radios could be deployed in vehicles — during manufacturing or in the aftermarket—or on roadway infrastructure. Failure to meet the interim deadline would accelerate the final build-out requirement by two years,” the filing said.

“Within ten years, deployment of V2X radios in an amount equivalent to 75% of new light vehicles sold in the U.S. in the calendar year of the final build-out deadline. If this final build-out deadline is not satisfied, the Commission would revisit alternative uses of the 5.9 GHz band,” according to the proposal. “The 5.9 GHz band has never been subject to build-out requirements. Global Automakers’ proposal addresses this shortcoming and conforms the band to modern spectrum management best practices. Imposing such benchmarks on a collective, industry-wide basis will incentivize and expedite deployment and hasten the achievement of network effects, maximizing safety benefits for the driving public.”

Other advocates of preserving road safety applications in the 5.9 GHz band reiterated their points in statements released this week in the wake of Mr. Pai’s announcement.

In response to today’s ex parte filing, WifiForward said, “The Global Automakers are trying yet again to block Chairman Pai’s effort to take a true fresh look at the 5.9 GHz band. They oppose the FCC recognizing the fact that the auto industry has had twenty years to use this band but has failed to do so – and now, incredibly, ask for another decade to try again. And they fail to recognize that the Commission can support automotive safety and bring the band into use for Wi-Fi and 5G. We agree with the FCC that the time for delay tactics is over and the time for a comprehensive further notice has come.”

The 5G Automotive Association had no comment on today’s filing. The group is a proponent of C-V2X technology.

Meanwhile, other advocates of preserving road safety applications in the 5.9 GHz band reiterated their points in statements released this week in the wake of Mr. Pai’s announcement.

“Given that human error is a factor in the vast majority of our nation’s nearly 40,000 roadway fatalities, the FCC, DOT and Congress should work to ensure that the 5.9 GHz band is preserved for both existing and emerging vehicle communication and safety technologies,” said the Alliance of Automobile Manufacturers. “Auto manufacturers understand the FCC’s mission is to maximize use of the public’s airwaves, but motor vehicle safety applications should not take a back seat to activities such as streaming videos on personal phones and wireless devices. The Alliance calls upon the FCC and DOT to complete the remaining two phases of interference testing in the 5.9 GHz band to determine the feasibility of spectrum sharing before taking further actions.”

“The Federal Communications Commission (FCC) embraced the use of spectrum to promote the development of technology that saves lives and improves the safety of U.S. roadways. It is time to move past the regulatory uncertainty that has hung like a cloud for the past six years and provide automakers as well as road operators the environment they need to make our roads safer and save lives,” said ITS America President and Chief Executive Officer Shailen Bhatt. “We welcome the opportunity to present our case to the FCC and look forward to having it considered fairly. It’s time to accelerate deployment of these technologies.”- Paul Kirby, [email protected]

MainStory: FCC FederalNews SpectrumAllocation

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