CEOs in IoT Spectrum Smackdown

The two executives were very polite when they met to testify before the Congressional Internet of Things Caucus last week. But beneath the veneer of pleasantries lay a severe conflict of intention over the use of wireless spectrum in the Wi-Fi range for unlicensed use.

On one side of the argument sat Gary Shapiro, president and CEO of the Consumer Electronics Association. On the other side of the debate sat Mitch Bainwol, president and CEO of the Alliance of Automobile Manufacturers. Sharpiro’s organization annually hosts the largest trade show in the world at the Las Vegas Convention Center – a show that has become so enormous that CEA has recently announced its intention to cap attendance.

Shapiro and Bainwol did not directly confront one another over their spectrum debate. The testimony and subsequent Q&A, however, left little doubt as to the depth of the difference of opinion between the two.

Shapiro touted the benefits of the Internet of Things already being realized in cars, offices, homes and hospitals and in caring for an aging population. With IoT technology pervasive throughout the CES show, the message from CEA’s massive membership channeled through Shapiro is that more spectrum is needed to enable more innovation to fuel the creation of more products and services which will stimulate growth in the economy and, thereby, raise employment - transforming and saving lives in the process.

Bainwol testified to the potential of a single application – vehicle-to-vehicle communications – based on dedicated short range communication (DSRC) technology to enable cars to communicate wirelessly with other cars and with infrastructure. The objective, in his words, to ultimately remove the driving responsibility from human beings who, in his estimation (quoting from the National Highway Traffic Safety Administration) are the causal element in 95% of car crashes.

Shapiro’s position:

“We are just beginning to understand the benefits and challenges of the IoT. In this dynamic and rapidly changing environment, governments should exercise regulatory restraint. Overly prescriptive mandates will stymie growth and become outdated. If governments must act, then such actions should be narrowly tailored to address tangible harms without creating roadblocks for future innovation. Government should not attempt to regulate based on hypothetical concerns, but should proceed slowly with targeted solutions to actual problems.”

Bainwol’s position:

“The most vital pillar is ensuring that the radio frequency spectrum now dedicated to V-to-V and V-to-I, or the 5.9 GHz band, remains solely dedicated to auto communications technologies or any solutions involving sharing maintain the integrity of DSRC.”

Bainwol concludes:

“We are entering the golden age of mobility through technology and connectivity. A top policy priority for our country is finding smart ways to put more new vehicle technologies on our roads, because more rapid adoption of these new technologies will help keep drivers safer, avoid traffic congestion, save time, save money and reduce fuel use too.

“In an Internet of Things world, where connectivity offers the promise of monumental societal benefits, getting to the future as fast as we can is critical”

(Internet of Things Hearing - video and transcript - https://tinyurl.com/q4e5826)

Shapiro’s vision is clear – open up as much spectrum as possible to as many uses as possible to stimulate innovation and the economy overall. Bainwol’s vision is to limit the potential use of sparsely allocated spectrum to a single application or make a condition of its use that other uses do not interfere with that single use.

There are multiple reasons why Shapiro’s vision is the more compelling path to the future. And there are numerous reasons to regard Bainwol’s vision with a jaundiced eye.

Shapiro is too polite and too much of a professional to directly confront Bainwol on a public stage. I, however, am not bound by similar constraints.

What Shapiro may or may not realize is how little stands in the way of the U.S. Department of Transportation moving toward rule-making on a mandate for the adoption of DSRC technology by the automotive industry. The risk of such a foolish decision being taken animates my animus.

Shapiro is correct in opposing restrictions on the use of unlicensed spectrum currently being considered for DSRC use in automobiles. Here’s why:

1. DSRC, though widely tested, is unproven in real-world circumstances for most of the applications for which it is intended – ie. hundreds of cars simultaneously sending safety signals capable of not just alerting drivers but actually taking control of on-board safety systems;
2. The specification behind DSRC-based V2V technology has been rewritten multiple times to overcome fundamental shortcomings, many of which persist to this day;
3. The V2V proposition requires a level of cooperation and collaboration between car makers that does not exist today – ie. car makers will have to disclose their plans for using V2V to ensure that other OEMs using V2V are prepared to receive and respond to their signals;
4. The massive security vulnerability created by the implementation of V2V is beyond the capacity of car companies today to cope. In view of the recent serial breaches of vehicle security at General Motors, Skoda and FCA/Chrysler, it is clear that the automotive industry is struggling to secure existing wireless connections to cars;
5. The DSRC technology in question is not used in any mass market applications or consumer devices and therefore benefits from no existing eco-system of suppliers, no proven set of use cases and no organic consumer awareness or demand;
6. All of the applications envisioned for DSRC-based V2V will eventually be available via the existing evolving cellular network – in fact, many already exist such as sign recognition, traffic light signal-phase-and-timing (SPAT), and the presence of road hazards. LTE Advanced and 5G will provide both the necessary low latency and direct device to device communication;
7. DSRC-based V2V technology will require roadside infrastructure and the ability to transmit security certificates – propositions for which cellular is already proven and better suited;
8. In-vehicle human machine interface issues have yet to be adequately defined and will need to be refined per car company, per application;
9. A DSRC mandate will require additional hardware and software adding cost and complexity to vehicles along with an additional point of security vulnerability with the prospect of a potential return on investment residing somewhere 20 years in the future.

The ultimate irony of the testimony before the Congressional IoT Caucus by Bainwol is his almost hysterical plea for the “more rapid adoption of these new technologies.” The auto industry has a long history of resistance to new life-saving technologies including everything from stability control and anti-lock brakes to airbags and seatbelts.

In fact, the adoption of airbags ultimately required the intervention of the Supreme Court which unanimously voted to overrule the Reagan Administration’s rejection of the airbag requirement – sending the matter back to the US DOT, under Secretary Elizabeth Dole, which ultimately adopted it. In the words of Justice Byron White: “For nearly a decade, the automobile industry has waged the regulatory equivalent of war against the air bag and lost…” (SOURCE: "Car Safety Wars")

The only justification for Bainwol’s enthusiasm for DSRC-based V2V technology is a political gesture by the industry to mend fences with NHTSA in the wake of the catastrophic recalls of 2014 and related and ongoing investigations.  The technology is unproven and its adoption unwise, especially if that adoption interferes with the proliferation and adoption of IoT systems and services capable of offering immediate benefits in saving and enhancing lives.

In my estimation, Shapiro handily won the match. We can all hope this was no Pyrrhic victory.