Evaluation and Synthesis of Connected Vehicle Communication Technologies (2021) / Chapter Skim
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Page 53 WHITE PAPER #1 ADDENDUM V2X COMMUNICATIONS IN THE 5.9 GHZ SPECTRUM: REPLY COMMENT ADDENDUM
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Page 54 V2X COMMUNICATIONS IN THE 5.9 GHZ SPECTRUM: Reply Comment Addendum In March 2020, a white paper was published that focused on the 5.9 GHz spectrum and the important role it has played -- and will continue to play -- in achieving the many safety and efficiency goals originally established when 75 MHz of the band was first set‐aside for intelligent transportation system (ITS) services. The white paper provided a significant amount of information concerning the Notice of Proposed Rulemaking (NPRM)
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Page 55 30‐day comment period ended -- March 9, 2020. 30‐day reply comment period ended -- April 27, 2020. Summary Comparison for Both Comment Periods In both the initial comment and reply comment period, a significant majority of submissions opposed the NPRM. As shown in Figure 9, the proportion of opposing comments was very similar in both comment periods. Figure 9 ‐ Overview of Positions Taken in Both Comment Periods (percent) While the proportion remained similar, a significantly smaller number of overall submissions was anticipated (and realized)
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Page 56 during the initial comment period, 80% were either technology neutral, did not mention dedicated short‐range communication (DSRC) or cellular vehicle‐to‐everything (C‐V2X)
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Page 57 Opposition to NPRM ‐ Reply Comment Summary Reply comments in opposition to the NPRM argued that the record from the initial comment period clearly demonstrates that adoption and implementation of the proposed rule would have significant adverse impacts on transportation safety, would have economic impacts far more severe than were portrayed by the FCC, and that interference issues remain an insurmountable technical barrier to the current proposal. Those key themes carried through a majority of submissions. The Institute of Transportation Engineers, an international community of more than 16,000 transportation professionals, continued its assertion that reallocation of this spectrum will result in unnecessary deaths that otherwise would have been prevented through connected and automated vehicles: "A broad cross‐section of transportation safety experts and stakeholders has clearly objected to anything less than the current 75 MHz of bandwidth. The only support for the proposed reallocation was from those seeking to profit from free access to the spectrum to provide Wi‐Fi services."35 Several submissions added support for arguments presented during the initial comment period, such as that the change may be in violation of the Communications Act and that the reduction in traffic safety would be accompanied by significant negative economic consequences that should be considered relative to the value of opening additional bandwidth for Wi‐Fi. Removing regulatory uncertainty was also a common theme in both the initial comment and reply comment periods. General Motors made it clear: "GM and the automotive industry respectfully request that the Commission bring certainty to the automotive sector -- and the traveling public -- by abandoning the proposal to cut and/or move the allocation. The Commission must commit to preserving the full 75 megahertz in the 5.9 GHz band for life‐enhancing transportation safety services."36 Another frequent theme among submissions was the high risk and impact of interference from unlicensed devices. Many echoed Ford's comments: "Operating Wi‐Fi in channels adjacent to the ITS band [as the Commission's proposal contemplates] … produces out‐of‐band emissions that render the ITS channels unusable for safety applications."37 Some also added to this last assertion by stating that the burden should be on the FCC to provide compelling evidence that transportation safety use of a smaller spectrum could be done without increasing harmful interference, rather than requiring others to prove the opposite. 35 https://ecfsapi.fcc.gov/file/1042494875860/ITE%20Reply%20Comments%20to%20FCC%20on%205.9%20GHz%20NPRM%20April%202020_Fina l.pdf 36 https://ecfsapi.fcc.gov/file/104282729828431/GM%204‐27‐20%20Reply%20Letter%20FINAL.pdf 37 https://ecfsapi.fcc.gov/file/1042725827205/Ford%20Motor%20Company%205.9%20GHz%20FCC%20Reply%20Comments%20as%20Filed%204‐ 27‐20.pdf
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Page 58 Opposition to NPRM ‐ New or Additional Highlights from Reply Comments Since the March 9 deadline for the initial comment period concluded, a number of issues highlighted in the initial comment submissions were reinforced, and several new developments occurred. Portraying an Accurate Role of Commercial Networks In their reply comments AT&T pointed out that some of the initial comments have incorrectly stated the role of mobile network operators in future V2X communications.38 "NCTA opposes exclusive spectrum for ITS in the 5.9 GHz band, arguing that "other licensed spectrum [is] already being considered for this purpose" and quoting part of an article for the overall proposition that "AT&T, for example, ‘expects to use existing cellular bands for infrastructure‐based 5G automotive services that require ultra‐reliable, low‐latency communication (URLLC)
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Page 59 wide build out requirement: Within 5 years, a total of at least 5 million radios on vehicles and roadway infrastructure will have been deployed, including any previous V2X deployments." Every automaker that submitted comments included support for the build‐out submission of the Alliance, as did many other transportation‐related organizations. Consumer Reports, self‐designated as an independent observer, included the build‐out announcement alongside the recent actions by the FCC in the 6 GHz band for unlicensed use.41 Their comments: "Two major developments have occurred in the intervening time. One, the FCC voted in favor of opening up 1200 MHz of spectrum in the 6 GHz band for unlicensed use, a massive boon for Wi‐ Fi users and telecommunications equipment manufacturers. Two, the Alliance for Automotive Innovation pledged to deploy 5 million DSRC devices in cars and infrastructure within five years to enable the use of vehicle‐to‐everything (V2X) communications technologies, provided that the FCC maintains the full 5.9 GHz band for transportation safety and allows the use of cellular V2X within the band. These recent developments further call into question the wisdom of the FCC's proposal to divvy up the 5.9 GHz band to serve both auto safety and unlicensed spectrum use interests alike." The Alliance also quickly followed the build‐out announcement with a proposed band plan, encouraging both C‐V2X and DSRC to co‐exist in the 5.9 GHz spectrum.42 "During the first five years of the band plan, the upper 20 MHz of the 5.9 GHz band will be reserved for LTE C‐V2X exclusively, the lower 20 MHz of the 5.9 GHz band will be reserved for DSRC exclusively and the remaining 30 MHz in the middle of the band will be made available on a priority basis to NextGen DSRC and Advanced (5G)
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Page 60 American Association of State Highway and Transportation Officials (AASHTO) included this as one of the core tenets of their reply comment submission: "As a means of last resort, if the FCC wants to continue with the reallocation of the 5.9 GHz band, AASHTO finds merit in the FCC engaging with the industry in a negotiated rulemaking process. AASHTO welcomes the opportunity to be counted among the V2X stakeholders in search of a cooperative blend of appropriate technologies and addressing key issues such as interference and existing deployments. However, given the overwhelming opposition to the NPRM by those who are transportation safety experts, AASHTO believes that, first and foremost, FCC should abandon their attempt to reallocate the 5.9 GHz band."44 FCC Acted Inconsistently with License Freeze A number of reply comments urged the FCC to restart the process of awarding DSRC licenses so that lifesaving technology can reach public streets, especially in cases where investment has already been expended to do so, and the final remaining hurdle is the FCC licensing process. ITS America documented several specific cases where public safety applications have been unnecessarily delayed for many months, and highlighted inconsistencies in the way the FCC has approached this freeze:45 "The application freeze has stalled the processing of almost 500 applications proposing to add new facilities to improve transportation safety at facilities throughout the nation. The FCC has not acted consistently in applying the freeze retroactively. For example, the FCC implemented a filing freeze in the 900 MHz Band that only applied to new applications. In this case, the retroactive freeze has frustrated the efforts of public safety licensees to enhance transportation safety. Even should such authority to impose a retroactive licensing freeze exist, in this case application to public safety licensees appears once again to run afoul of the fundamental requirements of Section 1 of the Communications Act." Response to COVID‐19 The special temporary authority that allows wireless internet service providers (WISPs)
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Page 61 Airborne Applications of 5.9 GHz An addition to the NPRM opposition was an increase in stakeholders interested in and advocating for aerial uses of the band for V2V communications. Airbus had raised this possibility during the initial comment period, and they were joined by four others during the reply comment period, who all echoed that testing and plans for the 5.9 GHz Band need to evaluate both ground‐based and aerial use cases, particularly for lower‐flying vehicles like drones. Support for NPRM ‐ Reply Comment Summary Many of the reply comments in support of the current NPRM acknowledged that transportation safety applications are important, but in most cases they argued that 30 MHz would be sufficient ‐ or those applications should be moved to another band. Many submitters continued their original theme that the V2X industry had "two decades and fell short." A majority of the comments in support of the NPRM focused on the theme of needing more capacity for Wi‐Fi, and lean on previously published economic analyses that were included with their initial submissions. Some also referenced a more recently published analysis by WifiForward, and authored by Raul Katz.47 Broadcom and Facebook, in their joint reply comment, referenced the study directly: "A recent study found that, if adopted, this proposal would generate a contribution of more than $23 billion to the US GDP between 2020 and 2025 as a result of faster Wi‐Fi download speeds."48 Recent 6 GHz Allocation While opponents of the NPRM used the upcoming 1200 MHz of additional spectrum availability in the 6 GHz band as an argument in their favor, supporters of the NPRM were quick to suggest otherwise. The Wi‐Fi Alliance, in their reply comments, addressed the new availability in the 6 GHz band, and made it clear they still want both.49 "The record reflects that both actions -- designating the full 6 GHz band and a portion of the 5.9 GHz band for unlicensed use -- are necessary." Comcast went a step further and explained that the additional bandwidth in the 6 GHz spectrum is not a replacement for garnering the lower 45 MHz in the 5.9 GHz band because they don't have equipment yet available to use in the 6 GHz band.50 "The 6 GHz band will be the most restrictive unlicensed band in the United States and will require more time to bring into operation because of these rules and because it will require all new equipment." 47 http://wififorward.org/wp‐content/uploads/2020/04/5.9‐6.0‐FINAL‐for‐distribution.pdf 48 https://ecfsapi.fcc.gov/file/10427224113785/FINAL4272020ReplyCommentsinResponseto5.9GHzNPRM.pdf 49 https://ecfsapi.fcc.gov/file/10427078327120/Wi‐Fi%20Alliance%205.9%20GHz%20Reply%20Comments%204.27.2020.pdf 50 https://ecfsapi.fcc.gov/file/104282788322240/200427%20Comcast%205.9%20GHz%20Reply%20Comments.pdf
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Page 62 Disagreement Concerning Interference While most of the reply comments in support of the NPRM did not go into a significant amount of technical detail, the NCTA (Internet & Television Association) did.51 They not only devoted many pages to refuting specific points in the USDOT and Ford interference claims, but also offered a competing piece of research from CableLabs, published in April and attached it to their reply comment submission. While they acknowledged that CableLabs performed their analysis through lab testing and city‐scale simulations, the NCTA suggested that certain forms of interference -- such as packet loss -- are acceptable, and cited a 2016 DSRC development report that USDOT funded.52 "In fact, DSRC -- and presumably C‐V2X -- are specifically designed with the expectation that systems will experience packet loss, and include mechanisms to meet performance expectations under those conditions." Going further, the NCTA suggested that since many of those who oppose the NPRM cited USDOT research that they found fault with, the FCC should disregard all comments suggesting interference is a problem. "Many U‐NII‐4 opponents cite a December 2019 "Pre‐Final" National Highway Traffic Safety Administration Report for the proposition that unlicensed Wi‐Fi operations cannot co‐exist adjacent to ITS operations in the 5.9 GHz band. But as NCTA explained in detail in its opening comments, this report contains numerous and substantial flaws. For similar reasons, the Commission should not rely on other new analyses offered by ITS interests when establishing OOBE limits for U‐NII‐4 devices." What's Next for the NPRM As detailed in the original white paper, the time from closing of comment windows to FCC action can vary greatly, with both internal and external factors influencing the timing. Based on a review of initial comments and reply comments, there are several parties that could potentially play a role in how this proceeds. On behalf of the supporters for the NPRM, the NCTA provided the most detail in their submissions. They have also recorded previous ex parte meetings with FCC staff, and presumably will continue this pattern in the future.
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Page 63 potential to play the strongest role, in particular if the FCC adopts the recommendation for a negotiated rulemaking. There remain many possible outcomes from the NPRM process, as outlined in the original white paper. This should continue to be an evolving space as the FCC and others consider their next steps.
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