ATSSA Signal May June 2020

The Signal | May/June 2020 21 of America (ITS America), says that argu - ment ignores all thehurdles the FCC itself erected that effectively slowed the devel - opment of V2X connectivity. ITS America petitioned the FCC to set the spectrumaside for transportation safety uses inthefirstplace, andtheorganization has fought to protect it ever since. Drakepoints out that while the spectrum was dedicated in 1999, the FCC did not establish licensing rules and spectrum- sharing agreements with satellite oper - ators—measures that were critical to making thespectrumusable—until nearly a decade later. “It wasn’t really until 2008 that V2X tech - nologieswere able to be employedunen - cumbered,” Drake said. When Congress in 2012 asked the FCC to explore the idea of sharing part of the band with unlicensed uses, “that kind of implemented a pattern of regulatory uncertainty,” Drake said. PUBLIC INVESTMENTS IN JEOPARDY Despite that uncertainty, state depart - ments of transportation (DOTs), private companies, and others working in the transportationsafety spacehave invested hundreds ofmillions of dollars indevelop - inganddeployingV2X technologieswithin the spectrum. Manyof theseare taxpayer-funded invest - ments in devices that are already out on American roads. These devices were made to operate within the full 75 megahertz of the spec - trum, and they couldbe jeopardized if the FCC decides to open more than half that spectrum to other uses, said Joung Lee, director of policy and government rela - tions with the American Association of State Highway and Transportation Offi - cials (AASHTO). “Those types of investmentswouldessen - tially get stranded, because they would have no spectrum space to operate in,” Lee said. AASHTO inAugust sent a letter to the FCC opposing it’s proposal that was signedby theheads of DOTs inall 50 states, plus the District of Columbia and Puerto Rico. In 13 years at the organization, Lee said it’s the first time he can recall all 52 officials signing a policy letter. As owners of transportation infrastruc - ture, DOT officials see a critical need for dedicated spectrum to create a uniform standard for V2X connectivity, their letter shows. And while development has taken years, changing the spectrum allocation now could inhibit progressat apivotalmoment, said Drake of ITS America. “Unfortunately, theFCCseems tobeacting at a timewhenweareactuallypretty close to being able to realize some of those big safety benefits,” Drake said. LIVES AT STAKE ITSAmerica,AASHTO,andATSSAallempha - size that more than 36,000 people die each year in crashes and other incidents on American roads. TheCAV technologiesunder development within the 5.9GHz spectrumcouldpoten - tially avoidasmany as 80percent of unim - paired crashes, according to theNational Highway Traffic Safety Administration. AASHTO’s Lee said the FCC issue high - lights the need for greater recognition of the immense loss of life on American roads, and support for achievable safety measures to prevent it. “Hundreds of people die on our road - ways every day, and yet we have become accepting of that fact. That is unaccept - able,” Lee said. “We need to domore of a call to action to recognize this as a public health crisis.” Inapublichealthcrisis,governmentprotects the infrastructure that cansave lives. That is exactly what the 5.9 GHz spectrum represents for roadway safety, he argues. Proponents of the FCC proposal have suggested that transportation safety and unlicenseduses couldshare thespectrum without detriment to safety uses. But the potential ramifications of spectrum-shar - ingarenot completely knownat thispoint. ITSAmericahassupportedcongressionally mandated testing to determine whether unlicenseddevices andV2X technologies can operate together with no impact on safety. But the FCC only completed one of three required phases of the testing before abandoning further testing and proposing to share the spectrum. “It’s frustrating that it seems theFCChasn’t done their due diligence,” Drake said. He and other safety advocates say the reliability of safety technologies should be held to a higher standard than that of run-of-the-mill broadband services, so solid data are crucial to making an informed decision. “You just cannot have 99.9percent reliabil - ity in theoffchance that itmight notwork. That causes a fatal accident,” Lee said. “If a videodoesn’t load, sure just refresh it, but it’s amuchhigher bar tomeet in terms of that reliability for transportation safety purposes.”  To reach Emily Freehling, communications@atssa.com. “Hundreds of people die on our roadways every day, and yet we have become accepting of that fact. That is unacceptable.We need to domore of a call to action to recognize this as a public health crisis.” – Joung Lee, Director of Policy and Government Relations, AASHTO Innovation