Reply Comments: FCC Proposal to Give Away Majority of 5.9 GHz Spectrum Will Harm Safety

The Intelligent Transportation Society of America (ITS America) today called on the Federal Communications Commission (FCC) to heed calls from stakeholders across the transportation industry – including the U.S. Department of Transportation (USDOT), the top federal transportation safety agency – and not move forward with its plan to give away a vast majority of the spectrum used for transportation safety critical communications. The 5.9 GHz spectrum, currently allocated for Vehicle-to-Everything (V2X) communications, allows vehicles to communicate with each other, other vulnerable road users, and infrastructure.
The FCC proposal would give unlicensed (non-transportation) use 45 MHz, leaving only 30 MHz for V2X technologies, which would not only limit spectrum available for safety applications but could render that remaining spectrum unusable due to significant interference.

“For the Commission to adopt a decision that has been strongly and thoroughly opposed by safety experts throughout the United States as causing irreparable and lasting damage to traffic safety is irresponsible,” said ITS America President & CEO Shailen Bhatt

In reply comments filed today to the FCC’s Notice of proposed Rulemaking (FCC 19-129), ITS America noted that comments opposing the Commission’s proposal came from national transportation industry associations; state departments of transportation, local governments; transit agencies; automobile OEMs; trucking companies and organizations, and various first responder, safety, and vulnerable road user associations. These stakeholders universally opposed the FCC’s proposal, noting it will harm transportation safety.

The record reflects significant opposition to the Commission’s reliance on a flawed economic analysis to justify splitting the band and the failure to consider the vast positive economic impacts of V2X technologies. USDOT’s analysis notes that vehicle crashes translate into more than $300 billion in direct costs annually, and more than $800 billion when taking into account loss of life, injuries, and other quality of life factors.

ITS America added that the FCC must protect the more than $2 billion public investment in V2X technologies made by federal, state and local governments and proposed that incumbent users be permitted to continue operations until their licenses expire or January 1, 2026, whichever is later. Late last week, the auto industry committed to a five-year buildout for V2X technologies to include five millon devices for vehicles and infrastructure, predicated on the the FCC reserving the entire 5.9 GHz for transportation safety communications.

“The FCC’s proposal would be destructive and immediately harm public safety,” Bhatt added. “The lives of thousands of people depend on the Commission preserving the entire 5.9 GHz band for safety critical communications.”

Contact: Cathy St. Denis, cstdenis@itsa.org

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About ITS America: The Intelligent Transportation Society of America advances the research and deployment of intelligent transportation technologies to save lives, improve mobility, promote sustainability, and increase efficiency and productivity. Our vision is a better future transformed by intelligent mobility: safer, greener, smarter. For more information, please visit www.itsa.org