5GAA comments to the NHTSA on notice of proposed rulemaking

The 5G Automotive Association (5GAA) supports the goal of the National Highway Traffic Safety Administration (NHTSA) to increase motor vehicle safety through the use of communications solutions. 5GAA is a new global cross-industry association of automotive, technology and telecommunications companies. 5GAA includes 42 members, of which 8 are founding members (AUDI AG, BMW Group, Daimler AG, Ericsson, Huawei, Intel, Nokia, Qualcomm). Our mission is to enable communications solutions that address society’s connected mobility and road safety needs.

5GAA, like the U.S. Department of Transportation (USDOT) and National Highway Traffic Safety Administration (NHTSA), values safety first and foremost; this is what makes the immediate proceeding so important to us and why we are moved to offer the sum of our expertise in providing comments. To realize the full safety benefits of vehicle communications, NHTSA’s guiding principle must be one that allows for not only the best technology of today but also for the best technologies of tomorrow. Such an approach will promote innovation and competitive market-based outcomes, ensuring that American drivers and passengers benefit from the best and most advanced safety solutions available as technology evolves. This is particularly essential for regulations touching the communications industry, which has witnessed rapid technological innovation over the past two decades – with 4G cellular prevalent today and 5G on the horizon. By contrast, rigid technology mandates, whether direct or de facto, freeze technology solutions to a past point in time. With the communications market rapidly evolving, any technology NHTSA mandates today will be outdated by the time the mandate goes into effect, if not already outdated. This will significantly impede the innovation and evolution path for Vehicle-to-Vehicle (V2V) safety, and positions the US to lag behind the rest of the world in V2V communications specifically as well as V2X broadly.

For this reason, 5GAA respectfully cannot support the proposed V2V technology mandate predicated on the use of dedicated short-range radio communications (DSRC), a technology originally designed in the 1990s. The proposed direct technology-specific mandate, by definition, is on its face not technology neutral.  Similarly, the one-way interoperability requirement in the alternate “if equipped” proposal, where “alternative” technologies would be required to be backwards interoperable with DSRC, is flawed in that it would impose no reverse interoperability requirement on DSRC to ensure backwards interoperability with other technology solutions, including today’s Cellular Vehicle-to-Everything (Cellular-V2X) solutions for V2V safety.

In effect, the “path” for compliance is not a path at all, but instead a dead-end for other technologies, as it creates a non-level playing field in the US V2V market.The 5G Automotive Association (5GAA) supports the goal of the National Highway Traffic Safety Administration (NHTSA) to increase motor vehicle safety through the use of communications solutions. 5GAA is a new global cross-industry association of automotive, technology and telecommunications companies.

5GAA includes 42 members, of which 8 are founding members (AUDI AG, BMW Group, Daimler AG, Ericsson, Huawei, Intel, Nokia, Qualcomm). Our mission is to enable communications solutions that address society’s connected mobility and road safety needs.5GAA, like the U.S. Department of Transportation (USDOT) and National Highway Traffic Safety Administration (NHTSA), values safety first and foremost; this is what makes the immediate proceeding so important to us and why we are moved to offer the sum of our expertise in providing comments. To realize the full safety benefits of vehicle communications, NHTSA’s guiding principle must be one that allows for not only the best technology of today but also for the best technologies of tomorrow. Such an approach will promote innovation and competitive market-based outcomes, ensuring that American drivers and passengers benefit from the best and most advanced safety solutions available as technology evolves. This is particularly essential for regulations touching the communications industry, which has witnessed rapid technological innovation over the past two decades – with 4G cellular prevalent today and 5G on the horizon. By contrast, rigid technology mandates, whether direct or de facto, freeze technology solutions to a past point in time. With the communications market rapidly evolving, any technology NHTSA mandates today will be outdated by the time the mandate goes into effect, if not already outdated. This will significantly impede the innovation and evolution path for Vehicle-to-Vehicle (V2V) safety, and positions the US to lag behind the rest of the world in V2V communications specifically as well as V2X broadly.

For this reason, 5GAA respectfully cannot support the proposed V2V technology mandate predicated on the use of dedicated short-range radio communications (DSRC), a technology originally designed in the 1990s. The proposed direct technology-specific mandate, by definition, is on its face not technology neutral. Similarly, the one-way interoperability requirement in the alternate “if equipped” proposal, where “alternative” technologies would be required to be backwards interoperable with DSRC, is flawed in that it would impose no reverse interoperability requirement on DSRC to ensure backwards interoperability with other technology solutions, including today’s Cellular Vehicle-to-Everything (Cellular-V2X) solutions for V2V safety. In effect, the “path” for compliance is not a path at all, but instead a dead-end for other technologies, as it creates a non-level playing field in the US V2V market.

Read the full paper here.