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FCC: Use Your Authority to Improve Safety on U.S. Roads and Prevent Needless Tragedies


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Release date: 7/21/2020

FCC: Use Your Authority to Improve Safety on U.S. Roads and Prevent Needless Tragedies
 
NAFA Fleet Management Association
 
Each year, far too many American lives are lost in traffic crashes on our nation’s roadways. Many of these lives can be saved in the future through the use of vehicle-to-everything (V2X) technologies – groundbreaking innovations that allow vehicles to communicate with each other and the world around them. Critical to the expanded use of V2X technologies is continued availability of dedicated space on the 5.9 GHz band --the communication spectrum which is reserved for transportation communications. Unfortunately, the Federal Communications Commission (FCC) is preparing to give away this spectrum. NAFA Fleet Management Association’s membership believes there is enormous potential for this technology to save the lives of fleet drivers and the public.
 
Safety is a significant issue for fleet managers. In the business world, safe driving means fewer crashes, lower insurance premiums, and the use of less fuel, but it also means the protection of a company’s greatest assets – its employees. NAFA and its members have always understood the far-reaching implications vehicle crashes can have as fleet vehicles interact with the other vehicles on the road. For the general welfare of employees and those with whom they share the road, safety and risk management are a must.

Each crash on our roadways is associated with real-world costs – physical, emotional, and financial – for the families, friends, and neighbors of those who are killed and injured. Working to prevent such loss is an important priority to NAFA and should be a top priority of Federal policymakers.
 
According to the U.S. Department of Transportation (USDOT), in 2017, there were more than six million police-reported vehicle crashes in the United States that resulted in 37,133 lives lost, as well as 2,746,000 injuries. These crashes also resulted in economic harm - approximately $250 billion in direct costs and more than $800 billion when the loss of life, injuries, and other quality of life factors are put into dollars.
 
One of the best tools we have to increase the safety of our transportation network and reduce fatalities is V2X technology. This technology allows vehicles, infrastructure, and pedestrians to communicate with each other instantaneously, alerting drivers to potential threats, obstacles, and vulnerable road users. It also enables or supports numerous safety features, including collision avoidance, emergency response priority, pedestrian in crosswalk notification, red light warnings, roadway safety alerts, work zone warnings, reduced speed zone warnings, and weather impact warnings, that help prevent associated traffic crashes. V2X will also allow vehicles to see beyond their line of sight, providing advance warning of a bicycle, pedestrian, or vehicle coming around a corner. The National Highway Transportation Safety Administration estimates that V2X applications could reduce the frequency and severity of unimpaired motor vehicle crashes by up to 80 percent.
 
In the midst of this tremendous promise and potential, the FCC is moving to undermine V2X technologies by reallocating these vital airwaves to the Wi-Fi industry.V2X safety technologies fully utilize the 75 MHz in the 5.9 GHz “safety band” spectrum to communicate, and the technologies must have sufficient dedicated spectrum to ensure uninterrupted high-speed communication. For V2X communications to work safely, the messages must travel fast and without interference. A delay in a vehicle receiving a crash-avoidance message due to signal interference can mean the difference between a crash and a close call and the difference between life and death.
 
Expert analysis has determined that the FCC’s proposal does not leave enough spectrum for V2X technologies and would likely result in significant interference for any V2X technologies operating in the remaining spectrum. The FCC’s approach is short-sighted and, if implemented, would impede the deployment of this promising new technology.   That is why the USDOT, every state department of transportation, and road safety and public safety advocates are united in opposing the FCC’s proposal to give away the majority of the 5.9 GHz “safety band” spectrum.
 
We should fully deploy this tool to significantly reduce traffic deaths and injuries in our communities. When our families are on our roads, we want to know that every tool available is being employed to keep them safe. Let’s tell the FCC and Congress that we need to keep this spectrum working for our safety and to preserve it for V2X technologies.
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Comments of U.S. Department of Transportation, ET Docket No. 19-138, at 8 (filed Mar. 13, 2020).
 
Proposed rule would mandate vehicle-to-vehicle (V2V) communication on light vehicles, allowing cars to 'talk' to each other to avoid crashes, NHTSA, December, 2016. Available at: https://one.nhtsa.gov/About-NHTSA/Press-Releases/ci.nhtsa_v2v_proposed_rule_12132016.print
 
Letter from Secretary Elaine Chao, U.S. Department of Transportation, to Chairman Ajit Pai, FCC (Nov. 20,
2019); available at: https://www.highways.org/wp-content/uploads/2019/12/sec-chao-letter-5.9-11-20-19.pdf.

Letter from Carlos Braceras and Jim Tymon to Chairman Pai, August 19, 2019; available at: https://www.transportation.org/wp-content/uploads/2019/08/2019-08-19-AASHTO-52-CEO-Letter-to-FCC-on-5.9GHz-Safety-Band.pdf. Alliance of Automobile Manufacturers, ITS America, and Seven Organizations Issue Joint Statement on Preservation of the Road Safety Spectrum, November 20, 2019; available at: https://static1.squarespace.com/static/596fb16003596e0fa70a232f/t/5dd594333580434ee4c97af3/1574278195144/S_2019_MultiAssocSpectrumFinal20NOV2019+%28003%29.pdf