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The intention of Dedicated Short Range Communications (DSRC) systems in the 5.9 GHz spectrum band is to promote the safety of life of automobile drivers, passengers and possibly even pedestrians.  If there are ubiquitous deployments of this equipment and everything works correctly, these systems could help prevent car crashes from happening. This is a noble and important purpose, but a number of key questions remain. In particular, one missing piece is a common understanding of what falls under the term “safety of life.”  

Given the Commission’s current proceeding on 5.9 GHz, this is a perfect time for the FCC to define what is and is not included within the safety-of-life category. Clarifying which DSRC functions are worthy of protection would provide certainty to automobile manufacturers and ensure the efficient use of the spectrum band.

Update on Commission’s Latest Efforts

The Commission is in the midst of determining the best mechanism to bring spectrum sharing to the 5.9 GHz band.  Specifically, the Commission is refreshing the record in order to obtain greater specificity regarding the two leading proposals for sharing the band, one submitted by Qualcomm and the other by Cisco. This process shouldn’t take long, and will allow the Commission to evaluate the science and engineering behind these sharing technologies and determine which best serves the American public. If all goes as intended, the Commission will receive prototypes for testing this year.  And, with good luck and timing, the FCC could permit unlicensed services in the band by late next year.

5.9 GHz & Safety of Life

Fundamentally, the benefits of allowing unlicensed services in the 5.9 GHz band could be considerable. The proximity to other unlicensed spectrum means the possibility of huge advancements in functionality, including gigabit Wi-Fi. Providing non-safety-of-life DSRC applications the same protection as safety-of-life uses, however, would unnecessarily restrict the use of unlicensed devices, if and when the Commission approves sharing in the band. In fact, the Commission’s 1999 DSRC item (1999 Order) contemplated, and reserved for later judgment, that non-safety functions could operate on an unlicensed basis separate from the safety-of-life DSRC.[1]  It seems fair to believe that if non-safety functions were appropriate for unlicensed treatment in 1999, they are even more so now.

Some may try to claim that the 1999 Order allocating the 75 MHz for DRSC and the 2004 order adopting licensing and service rules contemplated a number of uses beyond safety-of-life purposes.[2]  While partially true, that was more than 15 years ago and in the intervening time, the neighboring bands have become home to successful consumer use of unlicensed services and devices. A reasonable comparison may be a local city council reconsidering the placement of an industrial park if the surrounding area blossomed from urban blight to a residential hotbed.

As expected, the auto companies haven’t been shy in trying to preserve the DSRC allocation. But in doing so, they have made clear in their advocacy of this issue that their need for this band centers on the DSRC safety-of-life purposes, not the side applications.  For example, in their recent letter to President Obama, the auto company signatories state, “We support spectrum sharing in areas where it is technically feasible and will preserve both life-saving DSRC technology and ensure the protection of the existing Fixed Satellite Service operations in the 5.9 GHz band.” (emphasis added). This is also consistent with the fact that there would be little need to be so concerned over testing the potential disruption or timeliness of communications between vehicle-to-vehicle and vehicle-to-infrastructure if not for the safety-of-life portion of DSRC. Hypothetical interference by an unlicensed device with a DSRC parking spot locator application should not generate similar angst because the information is not time critical, meaning there are no dire consequences if the information is delayed for a few moments.

Safety of Life vs. Non-Safety of Life Functions

At least three important principles should guide the Commission’s consideration of whether a function qualifies for safety-of-life status. Together, these limitations will prevent the inefficient use of spectrum.  First, the feature should not be already available or readily expected in the near future.  If the marketplace has already produced or is soon to introduce a feature, then using DSRC spectrum would be unnecessary, a waste of effort and/or potentially harmful (certainly to free market competitors).  Second, if the feature or function will or can be used for the purposes of monetizing or generating revenues for the automobile companies without any improvement in auto safety for drivers, riders or nearby pedestrians, then it is a non-safety-of-life matter.  Lastly, to the extent that the feature could result in distracted driving or undermine automobile safety in any way, it should not qualify as a safety-of-life function.

Based on the above principles, the following list of features and functions, which is not exhaustive, are not safety-of-life applications and thus should not be protected by the Commission.  

  • Parking spots: locating and paying
  • Electronic tolling
  • Mapping
  • Navigating or driving directions
  • Advertising
  • Social media
  • Entertainment
  • Driving notifications
  • Traffic updates

*             *             *

At the same time as the Commission considers the means to share the 5.9 GHz spectrum band, it should consider carefully defining DSRC safety-of-life features and applications.  This will ensure the protection of those DSRC functions that are truly critical to its safety operations, but nothing more.  The Commission’s quest for greater spectrum efficiency demands nothing less.  

[1] Amendment of Parts 2 and 90 of the Commission’s Rules to Allocate the 5.850-5.925 GHz Band to the Mobile Service for Dedicated Short Range Communications of Intelligent Transportation Systems, ET Docket No. 98-95, Report and Order, 14 FCC Rcd 18221, ¶¶ 28-30 (1999).

[2] Amendment of the Commission’s Rules Regarding Dedicated Short-Range Communication Services in the 5.850-5.925 GHz Band (5.9 GHz Band); Amendment of Parts 2 and 90 of the Commission’s Rules to Allocate the 5.850-5.925 GHz Band to the Mobile Service for Dedicated Short Range Communications of Intelligent Transportation Systems, ET Docket No. 98-95, WT Docket No. 01-90, ET Docket No. 98-95, Report and Order, FCC 03-324 (rel. Feb. 10, 2004).