New America’s Open Technology Institute, Public Knowledge and Consumer Federation of America (“Commenters”) write today in response to the National Highway Traffic Safety Administration (“NHTSA”)’s Notice of Proposed Rulemaking regarding the mandating of Dedicated Short-Range Communications (“DSRC”) for Vehicle-to-Vehicle (“V2V”) communications. We write to express concerns about the implementation of DSRC as currently proposed in the NPRM. Specifically, we raise concerns regarding the potential for non-safety uses of DSRC spectrum and radios, cybersecurity, and privacy risks associated with DSRC, and the implications this mandate may have for ongoing efforts to find ways to share the 5.9 GHz band with Wi-Fi and other non-DSRC unlicensed users. As consumer advocates we believe DOT and FCC shouldconclude that the re-channelization approach to sharing the ITS band strikes the best balance between NHTSA’s legitimate interest in promoting crash avoidance and the Commission’s interest in promoting more fast and affordable broadband connectivity. A re-channelization of DSRC that physically separates life-and-safety DSRC channels from other channels shared with unlicensed operations can best address agency and automaker concerns about potential interference with V2V and other time-critical safety applications, while allowing both commercial DSRC applications and unlicensed uses to share the lower portion of the band in the most efficient and productive manner.
Download the full comments to NHTSA here.