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September 7, 2017

The Honorable Elaine Chao
Secretary
U.S. Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, D.C. 20590

Ref: Federal Motor Vehicle Safety Standards: V2V Communications
Docket No. NHTSA-2016-0126

Dear Secretary Chao:

On behalf of the more than one million members and supporters of Citizens Against Government Waste, I urge you to direct the National Highway Traffic Safety Administration (NHTSA) to withdraw the Notice of Proposed Rulemaking (NPRM) on Federal Motor Vehicle Safety Standards: Vehicle-to-Vehicle (V2V) Communications (Docket No. NHTSA-2016-0126).

This regulation, issued in the waning days of the previous administration, is an unfunded mandate on automobile manufacturers that requires them to install Dedicated Short Range Communications (DSRC) devices on all light vehicles sold in the United States by 2023. DSRC is an outdated technology that has already been overtaken by newer, more reliable technologies that provide many safety features that DSRC would take years to achieve, if at all. These technologies include the use of cameras and Light Detection and Ranging (LIDAR) sensors to provide blind spot information, automatic lane controls, highway traffic management systems, and automated parking assistance. Requiring DSRC in every new vehicle will divert money and interest away from these proven technologies, and slow investment and innovation in autonomous vehicle technology of the future.

On April 12, 2017, the Mercatus Center of George Mason University filed public interest comments in the docket raising several concerns with the technology-specific mandate described in NHTSA’s NPRM, including the potential for cybersecurity threats to DSRC, concerns about the reliability of DSRC technology, and issues with safety when DSRC is used for V2V communications. CAGW would like to associate itself with these comments, which are attached for your further review.

Withdrawing NHTSA-2016-0126 and closing the rulemaking process will also allow the FCC to move forward with its pending proceeding to examine how the 5.9 GHz band, currently allocated for DSRC, can be most efficiently used.

Thank you for your consideration of my request that you direct NHTSA to withdraw the NPRM on Federal Motor Vehicle Safety Standards: V2V Communications (Docket No. NHTSA-2016-0126).

Sincerely,
Thomas A. Schatz