US-DOT' preliminary technical assessment of the Draft FCC NPRM on the use of the 5.850 - 5.925 GHz band [ET Docket No. 19-138]

Every tragic road accident reminds us of the madness we see daily on our roads. It makes us think when our public servants would dare to make the right decision to stop these road tragedies, it makes us question for how long should we all embrace this madness before we regain some our sanity.

The semi-truck crashing into a multi-car pileup on a Texas highway is yet another reminder that we do have a proven technology to prevent such accidents, yet we do chose not only to not deploy it, but deprive ourselves from any future opportunity to develop technologies that have the potential to save the lives of road users. The draft FCC NPRM on the use of the 5.850-5.925 GHz band presents a dramatic shift in the current rules and the spectrum allocation for transportation, as highlighted by a preliminary technical assessment prepared by the US Department of Transportation.

The document raises a multitude of concerns, some of which highlighted below:

• Accident reduction is expected to be deferred for another 5 years
• Cessation of automated truck platooning at a point when commercial truck platooning is ready
• Negative impact on the development of automated vehicles "While not an absolute requirement for ADS technology, virtually every automotive manufacturer has acknowledged the important role that V2X communications can play in enhancing safety, extending operational design domain, and improving interactions with other vehicles and the infrastructure"
• With the limitation of 30 MHz allocation, neither DSRC or LTE-V2X may be able to effectively use the 30 MHz, nor can their operations be accommodated together in the band
• The draft NPRM relies significantly on a technology (LTE-V2X) still in development. Such a shift needs to be based upon independent and objective analysis that includes not only the spectral performance of the technology, but also the safety performance
• The draft NPRM negates the safety priority and purpose of ITS crash-imminent, safety-of-life communications
• The draft NPRM is ambiguous 3GPP references with relation to LTE-V2X devices. This ambiguity raises the risk that different LTE-V2X manufacturers may develop devices that are not interoperable
• The draft NPRM does not make clear that the broadband industry can charge subscription fees for the services on the proposed 45 MHz.
• The draft NPRM does not discuss why the Wi-Fi industry's insistence on accessing the mid-band spectrum especially with the recent proposal of dedicating 1200 MHz for Wi-Fi enabling non-contiguous bandwidth to bond producing larger channels

The proposed NPRM not only falls short addressing a multitude of open questions, of which an important one not addressed in the US-DoT technical assessment: while the FCC states that the adoption of DSRC has moved slowly - which nobody can contests - it doesn't address how the NPRM intends to incentivize automakers and road operators to commit to mass deployment, hence efficiently using the 5.9 GHz band as promoted by the FCC.

The slow adoption of DSRC is more related to the lack of incentive and motivation from road operators scaling up their deployments as well as a reluctance of automotive manufacturers to voluntarily invest in a technology whose benefits are only evident once a significant level of penetration of the technology is reached. This is in contrast to other safety technologies such as radars, lidars, where such dependency on other vehicles to have similar systems is not necessarily needed to achieve the same benefits. This reality is also valid for LTE-V2X and there is no reason to believe that this FCC momentous choice is a solution or might bring a different outcome.

Lastly using the same words in the technical assessment: "if enacted, this draft NPRM will result in a serious deployment pause or full stoppage of V2X operations, and it will take the Nation a longer time to realize the lifesaving benefits of collision-avoidance and other important public benefits for the public".