ATSSA Signal May June 2020

The Signal | May/June 2020 19 Innovation March 2, 2020 Docket Number: 19-138, FCC 19-129, FRS 16447 Subject: Use of the 5.850–5.925 GHz Band Submitted via Federal Register The American Traffic Safety Services Association (ATSSA) appreciates the opportunity to comment on the Federal Communications Commission’s (FCC) recent notice of proposed rulemaking focused on the reallocation of the 5.9 GHz band of spectrum. As a leading voice in roadway safety across the United States, we are steadfastly opposed to the Commission’s decision on reallocation. In 2018, more than 36,000men, women, and children died on U.S. roadways and tens of thousands more were seriously injured. By and large, these fatalities and injuries are preventable through proven lifesaving roadway safety infrastructure countermeasures as well as developing vehicle to vehicle and vehicle to infrastructure technologies. While fully connected and automated vehicles are still some time away from full deployment in the U.S. vehicle fleet, it certainly is the future of American transportation. And that future relies on a safe, secure communications systemamong vehicles and between vehicles and the surrounding roadway infrastructure. This decision by the FCC undermines that commitment to safety and security. The Commission risks putting Americanmotorists’, passengers’, pedestrians’, bicyclists’, motorcyclists’, and road constructionworkers’ lives at risk. One concern of the FCC has been the perceived slowmaximization of the 5.9 GHz band. Although first allocated in October 1999, licensing and service rules were not issued until February 2004 and further amended in 2006. Furthermore, the FCC failed to require spectrum “owners” to submit buildout plans whichwould have created clear guidelines for a path forward. According to the USDOT, there is currently over $1.5 billion in taxpayer funded investments in over 25 states with substantial V2X deployments. The proposed FCC NPRM reduces the capacity of the band initially set aside for safety by 60%. That reduction could limit the full potential of the V2X technology, which in turn reduces safety. These technologies are still under development and are starting to show signs of progress in the areas of traffic signal information, work zone locations, and lane closures to increase safety throughout the United States. Over one hundred state and local agencies are currently planning to utilize the Safety Band andmay have to alter their plans based on this NPRM, whichwill waste taxpayer dollars. Additionally, there aremore than 18,000 vehicles deployedwith aftermarket V2X communication devices and over 6,000 infrastructure element that utilize the Safety Band as well. The Safety Spectrumhas andwill continue tomake an impact on roadway safety. Some studies suggest that up to 94%of the vehicle crashes occur because of human behavior, which includes speeding and distracted driving. The Safety Spectrum in combinationwith in-vehicle technology will help reduce these types of crashes by altering the driver’s behavior or “taking over” the vehicle to implement braking in certain situations in our current driving environment. In the future, as automated vehicles penetrate themarketplace, these vehicles will also communicate utilizing the Safety Spectrum to save evenmore lives. The deployment of these types of technologies takes time andmore time is needed to allow these technologies to utilize the Safety Spectrum to save lives. For the sake of the safety and security of the traveling public, ATSSA strongly encourages the Federal Communications Commission to revise its NPRMand preserve the 75MHz allocatedwithin the 5.850- 5.925 GHz spectrum for transportation safety communication purposes. Sincerely, Roger A. Wentz President & CEO Roger A. Wentz, President & CEO American Traffic Safety Services Association 15 Riverside Parkway, Suite 100 • Fredericksburg, VA 22406-1077 Office: 540-368-1701 • Toll-Free: 800-272-8772 • Fax: 540-368-1717 www.atssa.com ATSSA Statement to the FCC