Summary of V2V Comments

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Vehicle-to-Vehicle (“V2V”) Proposed Mandate Draws 477 Comments
OmniAir Supports V2V Mandate and Provides Summary of Relevant Respondent Comments

 

On April 12, OmniAir Consortium filed comments in support of the Notice of Proposed Rulemaking issued by the U.S. Department of Transportation and the National Highway Traffic Safety Administration requiring newly-manufactured light vehicles be equipped with Vehicle-to-Vehicle (“V2V”) communication technology. OmniAir’s comments.

“Our comments focused on the importance of device certification in DSRC-based V2V Communications,” said Jason Conley executive director for OmniAir.   “We also announced OmniAir’s intention to launch its program to provide certification for Connected Vehicle devices this year.”

In total, 447 comments were submitted.  Comments were received from vehicle OEMs and their trade associations, cellular carriers and their trade associations, V2V technology and equipment developers and manufacturers, AASHTO and several State DOTs, local governments, and public interest groups and think tanks.

In addition to OmniAir, nine other commenters discussed the need for certification of V2V equipment:  UL, Cisco Systems, Panasonic, Wi-Fi Alliance, DanLaw, Auto Care Association, NAFA Fleet Management Association, and Russ Shields/Ygomi, LLC.

Below is a summary of the most relevant comments (in no particular order):

  1. General Motors – Supports mandate, including DSRC; concerned that deployment timeline is too aggressive; DSRC spectrum needs to be free from interference; includes technical comments.
  2. Alliance of Automobile Manufacturers – Indicates that full 75 MHz of 5.9 GHz Band must be available and the SCMS is operational before NHTSA issues final rule; calls for NHTSA to release a Supplemental NPRM regarding test criteria, the SCMS and definitions of the BSM; certain portions of proposed rule’s requirements are not stated in “objective” terms and need to be remedied; 5.9 GHz Band must be free of interference; calls for “standard criteria” to ensure interoperability; includes two appendices dealing with technical issues (data privacy, cybersecurity, message transmission and authentication, etc.); two-year lead time for deployment is too aggressive.
  3. Global Automakers – Supports mandate and rejects “if-equipped” deployment standard; don’t limit safety to one channel; concerns about cybersecurity; concerned about spectrum and current device testing; provides specific comments on proposed regulatory text of FMVSSS #150.
  4. Qualcomm – Helped developed DSRC and supports its, but argues that NHTSA shouldn’t define interoperability as DSRC, thus picking this technology over others; also should consider 4G LTE and 5G; 5G will provide better performance than DSRC; cellular V2X trials will begin shortly; let FCC decide spectrum sharing issue.
  5. ITS America – Supports mandate; however, mandate should be open to other wireless technologies and not just DSRC; define interoperability more broadly; don’t limit V2V only to on channel; other channels in band place are available and designed for safety applications; cost benefits estimates in NPRM are low.
  6. Toyota – Supports mandate; supports Global Automaker’s comments; provides specific technical comments on NPRM.
  7. UL – Supports mandate; need for international harmonization; calls for third-party entities to develop independent certification programs; includes technical comments.
  8. Car 2 Car Communication Consortium – Supports mandate and DSRC (particularly MAC and PHY layers); full 75 MHz of spectrum needed for safety messages; includes multiple technical comments
  9. BMW Group – Generally supports mandate except for DSRC; concerned that mandate be “technology neutral,” provides technical comments on security, V2V communications; 5G V2V technologies
  10. Mercedes-Benz USA – Supports comments of Auto Alliance, 5G Automotive Association (5GAA) and Car-to-Car Communication Consortium (C2C-CC); suggests that mandate should be revised to an “if-equipped” standard (like EDRs); also includes some technical comments
  11. 5G Automobile Alliance – Opposes DSRC; NHTSA must consider cellular V2X technologies; technology neutral.
  12. Verizon – Generally supports a mandate but don’t limit to DSRC; other technologies can meet messaging specifications, including existing LTE and coming 4G and 5G applications; aftermarket devices will be important for enabling V2V.
  13. Cisco Systems – Supports mandate; supports DSRC; believes that cellular technologies will be able to provide V2V in the future; final rule should contemplate non-DSRC technologies; supports spectrum sharing so long as no interference to safety messages; promotes its “detect and vacate” sharing proposal; asks for clarification on DOT certification efforts and plans; supports requiring certification both for original and aftermarket equipment; includes technical comments and also on data privacy and cybersecurity.
  14. Panasonic – Supports mandate; cities need for international harmonization of certification requirements based on accepted standards; calls for certification for devices to operate on SCMS.
  15. EPIC – Generally supports NHTSA’s attempts to addresses data privacy and cybersecurity implications, but raises some specific concerns; does not categorically oppose technology or mandate; need consumer opt-in and consumer access to collected data
  16. Honda – Supports mandate; raises some specific concerns and spectrum availability.
  17. DENSO – Supports mandate; provides technical comments.
  18. BMW – Mandate should be more technology neutral, including consideration of cellular V2V solultions; mandate only transmission requirements for BSM; provides some technical comments.
  19. 5G Americas – Opposes mandate for DSRC; also submitted a white paper on V2X cellular solutions.
  20. Subaru – Supports mandate.
  21. National Electrical Manufacturers Association — Supports mandate
  22. IEEE 1609 Working Group – supports mandate; supports non-DSRC technologies but must be interoperable with DSRC; requests that FMVSS specifically reference standards, including 1609; provides technical comments.
  23. FCA – General support for mandate; cites Auto Alliance comments; includes some technical comments.
  24. Delphi – Supports mandate; ready to deploy DSRC devices.
  25. Peloton Technology – Supports mandate; using DSRC for commercial truck platooning.
  26. AT&T Services – Does not oppose DSRC, but mandate must be open to other wireless technologies.
  27. Wi-Fi Alliance – Takes no position on mandate; preparing 802.11p certification for DSRC.
  28. Danlaw – Supports mandate; proposes extend mandate to light-duty and heavy commercial vehicles; certification of systems is necessary; technical comments on GNSS location and security certificates.
  29. Systems Research Associates – supports mandate; calls for interference-free spectrum for V2V.
  30. NXP Semiconductors – Supports mandate; do not wait for cellular 5G; provides some technical comment.
  31. Niskanen Center – Opposes mandate; concerned regarding technological “lock-in” with DSRC.
  32. Cogenia Partners  – Provides limited technical comments only.
  33. Savari – Comments that it expected to see more references in NPRM to SAE J2945 and J2735; provides some technical comments.
  34. Illinois Tollway – Supports mandate; provides some technical comments.
  35. Safety Spectrum Coalition – Supports mandate.
  36. Broadcom Corporation – NHTSA should wait until FCC resolves spectrum sharing issue.
  37. Continental – Supports mandate; some technical comments.
  38. Tesla – Opposes mandate; instead, let industry develop V2V; should adopt an “if-equipped” standard because of security and data privacy concerns; data privacy not sufficiently addressed in NPRM; consumers should be able to disable V2V.
  39. Cohda Wireless – Supports mandate.
  40. AAA – Supports mandate.
  41. Inmarsat – Supports DSRC as the enabling technology for V2V; indicates that CVs will also utilize satellite communications and networks.
  42. Electronic Frontier Foundation – Emphasizes need to address privacy implications.
  43. Motor & Equipment Association – Supports mandate; provides some technical comments.
  44. National Automobile Dealers Association – General support for mandate; raises some concerns on privacy, cybersecurity and point-of-sale information to consumers.
  45. Public Knowledge, Consumer Federal of America, New America’s Open Technology Institute – Concerns about commercial applications using DSRC; raises privacy, cybersecurity concerns; proposes rechannelization of 5.9 GHz band.
  46. National Public Safety Telecommunications Council – Supports mandate.
  47. Oregon DOT – Supports mandate.
  48. Virginia DOT – Supports mandate; provides technical comments.
  49. NCTA – Leave spectrum sharing issue to FCC.
  50. Future of Privacy Forum – Provides comments on privacy by design, etc.
  51. FICOSA North America -Supports mandate.
  52. Competitive Enterprise Institute – NHTSA fails to consider alternatives to DSRC
  53. Klear-View Camera – Supports mandate.
  54. Autotalks – Supports mandate.
  55. Volkswagen Group of America – Opposes mandate (has not been sufficient testing with respect to performance requirements).
  56. Texas DOT – Supports mandate; discusses V2I benefits, notes importance of V2X data for transportation agencies; cites AASHTO comments.
  57. Laird Technology – Supports mandate.
  58. Ford Motor Co. – Generally supports mandate but raises questions about implementation timing and availability of cellular V2V in same timeframe; includes technical comments.
  59. Transportation Trade Department AFL-CIO – Primarily concerned that these technologies will result in worker displacement.
  60. Pennsylvania DOT – Supports mandate; cites AASHTO comments
  61. Massachusetts DOT – Supports mandate.
  62. National Association of State EMS Officials – Supports mandate.
  63. Auto Care Association – Comments on PKI; security, data privacy; proposes NIST-led developing certification and “V2V certification stations.”
  64. Sirius XM Radio – Supports mandate.
  65. Consumer Technology Association – Favors V2V generally; advises NHTSA that it has no jurisdiction over personal electronic devices that are brought into vehicles.
  66. Visteon – Technical comments only.
  67. CTIA – Supports V2V but not DSRC; calls for consideration of cellular V2V technologies, including 5G; comments on privacy and security protections in cellular networks; advocates a “technology neutral approach” to V2V message authentication.
  68. HAAS Alert – Opposes mandate for DSRC; prefers cellular V2V.
  69. Automotive Safety Council – Supports mandate.
  70. Insurance Institute for Highway Safety – Supports mandate.
  71. ZF TRW – Supports mandate.
  72. Robert Bosch – Supports mandate.
  73. Truck & Engine Manufacturers Association – Supports mandate; cites truck platooning using DSRC; addresses spectrum sharing.
  74. American Trucking Associations – Supports mandate.
  75. National Association of State EMS Officials – Supports mandate.
  76. Association of Metropolitan Planning Organizations (AMPO) – Supports mandate; attaches AASHTO comments.
  77. National Volunteer Fire Council – Supports mandate.
  78. Next Generation Mobile Networks Alliance – Opposes mandating DSRC; should be technology neutral; 3G applications can provide V2V.
  79. American Motorcyclist Association – Asks NHTSA to ensure that V2V can detect and prevent accidents with motorcycles.
  80. u-blox AG – Supports mandate.
  81. Mazda – Cites Auto Alliance comments; general support for mandate; provides technical and other comments on implementation, including on SCMS
  82. AASHTO – strongly supports mandate; includes summary of several DSRC/V2V/V2I projects in an appendix.
  83. Institute of Transportation Engineers – Supports mandate; envisions DSRC and a suite of communications technologies providing V2V.
  84. Utah DOT – Supports mandate; includes some technical comments.
  85. Cato Institute – Opposes mandate; supports industry development of cellular V2V instead.
  86. NAFA Fleet Management Association – Supports mandate; supports certification of aftermarket installations.
  87. Consumers Union – Supports mandate; mandated standard should account for future developments; deployers should have to meet enforceable, baseline standards for cybersecurity and data privacy.
  88. HERE North America – Advises NHTSA not to adopt rule that neither mandates or promotes a single technology; expects that 4G/5G will be able to provide V2V.
  89. Nexar (CV software developer) – Supports DSRC but prefers cellular V2V.
  90. National Transportation Safety Board – Supports mandate.
  91. SecureSet – Provides technical comments on cybersecurity implications.
  92. International Association of Fire Chiefs – Supports mandate.
  93. Association of Public Safety Communications Officials (APCO) – Acknowledges potential benefits of DSRC but does not address mandate specifically.
  94. National Safety Council – Supports mandate.
  95. Specialty Equipment Market Association – Supports mandate; indicates that aftermarket equipment will be important for V2V deployment.
  96. Rider Systems  – Supports DSRC in conjunction with cellular V2V.
  97. Russ Shields/Ygomi LLC – Advocates LTE-V for V2V, which will also enable sharing in 5.9 GHz Band; using IEEE 802.11p is out-of-date; LTE-V is already being implemented in current production light vehicles; questions effectiveness of certification of equipment as it does not address equipment that may be illegally imported into U.S. and deployed.
  98. City of Los Angeles – Supports mandate.
  99. San Diego Association of Governments – Supports mandate.