CAGW Leads Coalition to FCC Supporting a Review of 5.9 GHz Spectrum | Council For Citizens Against Government Waste

CAGW Leads Coalition to FCC Supporting a Review of 5.9 GHz Spectrum

June 13, 2019

Chairman Ajit Pai                                                         
Federal Communications Commission   
445 12th Street, SW                                                 
Washington, D.C.  20554

Commissioner Jessica Rosenworcel
Federal Communications Commission
445 12th Street, SW
Washington, D.C.  20554

Commissioner Michael O’Rielly            
Federal Communications Commission           
445 12th Street, SW                         
Washington, D.C.  20554             

Commissioner Brendan Carr
Federal Communications Commission
445 12th Street, SW
Washington, D.C.  20554

Commission Geoffrey Starks
Federal Communications Commission
445 12th Street, SW
Washington, D.C.  20554

Re:  National Highway Traffic Safety Administration, Federal Motor Vehicle Safety Standards No. 150, Vehicle-to-Vehicle Communications, Docket No. NHTSA-2016-0126; Revision of Part 15 of the Commission Rules, ET Docket No. 13-49; Office of Engineering and Technology and Wireless Telecommunications Bureau Seek Comment on 5GAA Petition Waiver to Allow Deployment of Cellular Vehicle-To-Everything (C-V2X) Technology in the 5.9 GHz Band, GN Docket 18-357.

Dear Chairman Pai, Commissioners Rosenworcel, O’Rielly, Starks, and Carr,

The undersigned organizations, on behalf of our millions of members and supporters across the country, write to provide our support for the Federal Communications Commission’s (FCC) review of current and future use of mid-band spectrum in the 5.9 GHz band.

In 1999, the Department of Transportation (DOT) was allocated spectrum in the 5.9 GHz band to develop dedicated short-range communications (DSRC) for vehicle-to-vehicle (V2V) communications.  In December 2016, the National Highway Traffic Safety Administration proposed a rule requiring auto manufacturers to deploy DSRC in all light vehicles by 2023.  In December 2017, General Motors deployed DSRC only in the Cadillac CTS, which will be eliminated from its fleet after the 2019 model year.  Toyota, which announced on April 16, 2018 that it would use DSRC in all vehicles beginning in 2021, has put those plans on hold. 

While the DOT has tied up the use of the 5.9 GHz band, which could have been and should be used for critical expansion of faster broadband, the rest of the auto industry did not stand still.  Sensors, cameras, and radar-based technologies are alerting drivers to impending dangers and blind spots.  Many cars have and will have innovative features to improve highway traffic management and allow automated parking and auto-pilot.  According to the Auto Alliance, automobile manufacturers spend more than $100 billion each year on research and development worldwide and are actively working on new safety and V2V communications technologies that do not rely on DSRC.[1]  

We are supportive of the vibrant marketplace filled with safety technology and innovation but preserving spectrum for DSRC technology that is outdated and incompatible with current advanced safety technologies before it has been fully deployed is a waste of extremely valuable spectrum.  According to a November 29, 2018 RAND study, opening the 5.9 GHz spectrum for unlicensed use will unleash broadband capabilities for gigabit services and deliver $100 billion of economic impact to the GDP.[2]  It will also create a bridge between the existing U-NII-3 Wi-Fi band and the 6 GHz band, for a total of 1400 MHz, that the FCC is currently considering for expanded unlicensed use under its Proposed Rulemaking on Unlicensed Use of the 6 GHz Band (ET Docket No. 18-295; GN Docket No. 17-183). 

The time for action is now.  This valuable spectrum has lain fallow for 20 years, at great expense to the country.  The commission should open this inquiry and ensure the spectrum is put to use expeditiously.  The spectrum in the 5.9 GHz frequency would bridge the gap between the U-NII-3 band and the 6 GHz band for unlicensed Wi-Fi use, and we urge you to continue to work with the DOT to ensure it is used for that purpose.

Click for PDF and List of Signatories

[1] “Innovation,” Auto Alliance, https://autoalliance.org/innovation/.
[2] Diana Gehlhaus Carew, Nicholas Martin, Marjory S. Blumenthal, Philip Armour, Jesse Lastunen, “The Potential Economic Value of Unlicensed Spectrum in the 5.9 GHz Frequency Band,” RAND Corporation, November 29, 2018, http://www.rand.org/t/RR2720.

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