Volkswagen urges U.S. to consider ‘human issues’ in 5.9 GHz spectrum

Echoing a lot of transportation organizations submitting comments this week, Volkswagen Group of America is urging the Federal Communications Commission (FCC) to allocate the full 75 MHz in the 5.9 GHz band for Intelligent Transportation Services (ITS).

The commission is contemplating updates to its rules for the 5.9 GHz band, shrinking the vehicle-safety allocation from 75 MHz to the upper 30 MHz while also making room for a full 160-MHz-wide channel for Wi-Fi 6 in the bottom 45 MHz. The FCC voted on the Notice of Proposed Rulemaking (NPRM) last year.

Right now, the full 75 MHz of the 5.9 GHz band is allocated for vehicle safety, and a lot of transportation industry officials want to keep it that way.

“We cannot support the proposal to restructure parts of the ITS spectrum for unlicensed services,” Volkswagen told the commission. “Without the full 75 MHz, it will become impossible to also account for future technologies and developments, which will be required for future use cases. An available bandwidth of only 30 MHz limits the deployment to simplistic day-one use cases only, blocking the way to more advanced lifesaving functions.”

Volkswagen Group said it’s eager to go to market in the U.S. with safety applications in the near future, and it continues to develop a range of systems and use cases aimed at Vehicle to Everything (V2X) deployment.

“We ask you to consider the oft-overlooked, yet undeniable, human issues involved with the traffic safety spectrum,” the company said. “In the end it is these human elements that drive our strategic preparations and intensive research efforts.”

Traffic fatalities and serious injuries remain stubbornly high despite advances in safety. "In very real terms, roughly 100 motorists, passengers, pedestrians and cyclists die in American traffic collisions every day," Volkswagen said. 

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Volkswagen is just one of the stakeholders submitting comments in a round that was due Monday. Others want to see the band opened up for Wi-Fi.

NCTA – The Internet & Television Association (NCTA) supports the FCC's NPRM and said (PDF) the continued success of Wi-Fi depends on the commission’s opening additional mid-band spectrum for unlicensed use, particularly in the 5.9 and 6 GHz bands.

One of the benefits of the 5.9 GHz spectrum is devices in the field could be readily available to use it with software or firmware upgrades. “Combining U-NII-3 and U-NII-4 spectrum will create the first widely available, contiguous 160-megahertz channel that next-generation Wi-Fi requires,” NCTA said.

R Street Institute, a non-profit public policy research organization, noted that since the 5.9 GHz band was set aside exclusively for vehicle safety use since 1999, the communications and transportation marketplaces have evolved in some unexpected ways. Dedicated short range communications (DSRC), the lone technology authorized in the 5.9 GHz band, did not take off as projected.

“Allowing unlicensed services like Wi-Fi and LTE-U to coexist with vehicle safety services in a portion of the 5.9 GHz band could also help maximize the utility of the band,” the institute told the commission (PDF). 

In this proceeding, "the FCC should focus on vehicle safety, decide how much of the 5.9 GHz band is needed to support vehicle-safety services, and then reallocate any remaining spectrum for unlicensed services," R Street said. 

Another round of comments will be due in April.