ITS America has asked the FCC to defer action on the reallocation of 45 megahertz of spectrum for unlicensed use in a draft 5.9 gigahertz band item that the agency plans to consider at its meeting next Wednesday, citing a request by the Department of Transportation for the FCC to defer action on the entire item (TR Daily, Nov. 10). Meanwhile, other parties continue to press the Commission to make changes to the item to protect road safety applications from interference and enable use of unlicensed devices.
The item—which includes a first report and order, further notice of proposed rulemaking, and order of proposed modification—would repurpose 45 MHz of the lower 5.9 GHz band for unlicensed operations, and allow cellular vehicle-to-everything (C-V2X) technology to use the upper 30 MHz band (TR Daily, Nov. 10).
In an ex parte filing posted today in ET docket 19-138, ITS America asked the Commission to withhold action on the item "regarding the reallocation of 45 MHz from the ITS band (5850-5925 MHz) for use by unlicensed devices. ITS America does not object to action on the proposed Further Notice of Proposed Rulemaking to allow Cellular Vehicle to Everything (‘C-V2X’) technologies to access the upper 30 MHz (5985-5925 MHz) of the ITS band.
"Since release of the Draft First R&O, the U.S. Department of Transportation (‘USDOT’) has affirmed its opposition to reallocation of the lower 45 MHz, stating, among other things, that the ‘Commission is disrupting a V2X ecosystem that is over two decades in the making, and which continues to evolve at a rapid pace.’ USDOT’s comments are consistent not only with its earlier expressed views in this Docket but also with those of every State Department of Transportation and many transportation safety experts, including the National Transportation Safety Board," ITS America said.
"The Draft First R&O largely dismisses these concerns by concluding that 30 MHz should be enough to accommodate basic safety and related services," the group added. "Even if that were true—and ITS America notes the record clearly establishes that existing V2X systems in the 5.9 GHz Band are utilizing the full band for safety and related services—the Commission’s decision would unravel many years of investment and planning in advanced transportation safety services and deprive Americans of advanced safety services that would save thousands of lives."
In another filing posted today, the Alliance for Automotive Innovation asked the FCC to modify the draft item—or maintain some provisions—to protect road safety applications.
For example, the group said that "[i]t would be a mistake for the Commission to adopt the indoor unlicensed out of band emissions (‘OOBE’) limits in the draft 5.9 GHz Order. The proposed limits are far too high to protect V2X from harmful interference and are significantly higher than the level currently permitted for indoor U-NII-3 access points. The Commission should instead adopt lower OOBE levels consistent with automotive stakeholder proposals for indoor U-NII-4 operations."
"The Draft 5.9 GHz Order would impose a one year timeline for existing V2X operations using DSRC technology to cease use of the lower 45 megahertz (i.e. 5.850-5.895 GHz) segment of the 5.9 GHz band," the auto group also noted. "V2X licensees should have one year at minimum from the effective date of the adopted 5.9 GHz order to transition operations out of the lower 45 megahertz of the band. A shorter transition window, as suggested by NCTA, would be unworkable. There are a significant number of DSRC deployments, both on vehicles and roadside units, that will need to be re-channelized or have service discontinued. Further, many roadside DSRC deployments are by public agencies, which in many cases face funding constraints."
"While the Draft FNPRM raises questions about provision of relocation costs for incumbent V2X licensees relocating out of the lower 45 megahertz of the 5.9 GHz band, the Commission should address this issue now, in the November order. V2X incumbents should be compensated for relocation costs by unlicensed new entrants," according to the filing. "It is especially critical that relocation costs be addressed in the adopted order given the short timeframe for DSRC incumbents to relocate."
The filing also said that the FCC "is right in the draft 5.9 GHz Order to limit unlicensed operations in the lower 45 megahertz of the band to indoor operations and seek additional comment on outdoor operations in the FNPRM. The Commission should proceed cautiously in permitting outdoor U-NII-4 band operations in any segment of the 5.9 GHz band, as it is necessary to protect co-channel federal radiolocation operations as well as co-channel and adjacent-band V2X operations from harmful interference."
"The draft 5.9 GHz Order would require use of a contention-based protocol (‘CBP’) in the lower 45 megahertz of the 5.9 GHz band to ensure an interference-free environment for DSRC operations. Although NCTA argues that the Commission should forgo such a CBP requirement because it would add additional operational complexity to deployments, the FCC should reject this argument and retain this safeguard against potential harmful interference," the filing said. "Use of a CBP, among other safeguards, will help protect incumbent operations during the transition period and beyond."
"Finally, the Commission’s adopted order should affirm that, regardless of whether the U-NII-4 devices comply with the FCC’s final technical requirements (including power and out-of-band emissions limits), the provisions of sections 15.5(b) and (c) of the FCC’s rules remain applicable if harmful interference occurs to ITS operations in the 5.895-5.925 GHz band," according to the filing.
The 5G Automotive Association, which represents the C-V2X industry, said the FCC should make "minor adjustments" to its further notice to "help develop a more accurate, complete, and organized record and better position the Commission to quickly adopt final rules for C-V2X throughout the upper 30 MHz of the 5.9 GHz band.
"First, the FNPRM should seek comment on the rules 5GAA previously proposed for C-V2X services. To facilitate the adoption of final rules, 5GAA previously submitted C-V2X service rules for a 30 MHz channel in the 5.895-5.925 GHZ band," it noted. "Presumably because 5GAA’s service rules were based on industry technical standards, these rules were supported in the record and no parties voiced any opposition."
"Second, the Commission should develop a further record on the impact of in-vehicle UNII-4 client-to-client and mobile access point operations on adjacent band C-V2X services," the group said. "As 5GAA and others previously have explained, real-world testing demonstrates that, without adequate OOBE protections, in-vehicle U-NII-4 access point and client-to-client operations would reduce the effectiveness of C-V2X safety services."
The Wireless Broadband Alliance Ltd. said it "strongly applauds and supports the Federal Communication Commission’s draft order to free up 5.850-5.895 GHz in the 5.9 GHz band for unlicensed use."
But it said that "it is vitally important that the indoor certification process enables a service provider to self-certify that existing equipment meets the Commission’s technical requirements for indoor use at the time they upgrade firmware to enable use of the additional 45 megahertz of spectrum in the 5.9 GHz band. If service providers must undertake a more complicated process, consumers will not realize the benefits of the band as quickly or cost-effectively.
"Furthermore, many client devices connecting to 5 GHz Access Points (APs) today permit client-to-client communications, without the data passing through the AP. These client-to-client communications help avoid or reduce congestion at the AP and reduce transfer times for large datasets. We encourage the Commission to allow client devices that decode enabling signals from 5.9 GHz-enabled indoor APs to communicate directly with one another using U-NII-4 spectrum," the alliance added. "This step would maximize the utility of the band, and because both client devices must be in close proximity of the 5.9 GHz APs, just as they must be in the current draft order, there is no increased risk of harmful interference to other users." —Paul Kirby, [email protected]
MainStory: FCC FederalNews SpectrumAllocation WirelessDeployment
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