To mandate or not to mandate? That is the question facing the US Department of Transportation (USDOT), as public Comments were filed yesterday in response to its December 2016 proposal to mandate a specific technology that cars must use to send safety messages to each other, also known as vehicle-to-vehicle (V2V) communications. To characterize this proposed technology mandate as an increasingly “sticky wicket” over recent years might be an understatement. Indeed, this proposed USDOT mandate has elicited diverse – and increasingly evolving – reactions across the automotive, technology and telecommunications industries, as well as from consumer advocates, public safety groups, policy experts, and policymakers themselves.The “why” bears some history: Back in 1999, USDOT chose a specific technology called Dedicated Short Range Communications (DSRC) for future V2V safety communications. At that time, cellular technology was in its early stages – 2G to be exact – and not designed to meet the strict requirements needed to transit safety messages. (Recall your cell phone before it had a QWERTY keyboard. That is 2G.) In short, DSRC was the only technology envisioned to be capable of V2V communications. To date, USDOT has invested roughly $1 billion of federal taxpayer dollars in DSRC development and, more recently, testing. Yet, DSRC is still in the pilot phase and has yet to be widely deployed in the US. Meanwhile, over the last two decades, cellular communications technology has advanced at a rapid pace – from 2G in 1999 to 3G (the start of mobile broadband) to 4G/LTE (on our smartphones today) to the widely anticipated global deployment of 5G in the next few years. This advancement builds upon decades and hundreds of billions of dollars of private sector investment in Cellular research, testing and deployment. Additionally, there have been brisk advancements in automated driving safety technologies that were only seen on "The Jetsons" when DSRC was first envisioned.
Fast forward to today … USDOT’s National Highway Traffic Safety Administration (NHTSA) is proposing a direct mandate of DSRC technology in all cars for V2V safety communications or, alternatively, a de facto mandate of DSRC technology whereby any other V2V technology would have to be compatible with DSRC, but not vice versa. NHTSA dubs the latter the “if equipped” proposal. This brings us to the question at hand: While DSRC may have been the right technology path for V2V safety communications two decades ago, is it still the right path today and is a mandate necessary? These are not easy questions, and ones that Intel has wrestled with from a vehicle safety, engineering and regulatory perspective.
At Intel, improving vehicle safety is, and will remain, the consistent top priority and foundation for our automotive and transportation efforts. Vehicle safety is core to every project we undertake with our auto industry partners across the hardware, software and security landscape. So, while some may question why cars should be able to talk to each other at all, especially in light of the rapid advancements in automated driving in recent years, Intel believes this is a critical capability. We believe that future V2V communication – although not necessary for the safe operation of automated vehicles – could provide an additional source of data, if the message can be authenticated and transmitted securely. Accordingly, this debate is not about whether cars should be able to talk to each other (we support NHTSA’s safety objective), but rather the “right” technology and policy path to enable the safest vehicles possible as soon as possible, thus saving the most lives as soon as possible. This dedication to vehicle safety and innovating the future of driving is at the heart of why we created our Automated Driving Group last year.
As Intel’s top expert on automotive policy, I had the pleasure of collaborating on Comments filed yesterday by the 5G Automotive Association (5GAA) in response to NHTSA’s proposal to mandate DSRC for V2V communications. 5GAA is a global organization, launched last September, that brings together preeminent automotive, technology and telecommunications companies across the US, Europe, APAC and China. We are collaborating around the world to accelerate vehicle communications solutions that address society’s connected mobility and road safety needs. Specifically, 5GAA is focused on enabling Cellular 4G/LTE and next generation 5G technology to enable cars to “talk” to each other, roadside infrastructure, pedestrians, and more – aptly encapsulated as Cellular Vehicle-to-Everything (V2X) communications. 5GAA currently has 42 members, with 12 Board members including AUDI AG, BMW Group, China Mobile, Daimler AG, Ericsson, Ford Motor Co., Huawei, Intel, Nokia, Qualcomm, SAIC and Vodafone.
With this breadth of 5GAA membership – including companies from various sectors and geographies, and representatives from both technical and policy domains – we had a unique opportunity to have the robust debates that are essential when bringing a diverse group of stakeholders together to arrive at a consensus position. Of course, one point on which there was immediate consensus and no need for debate is the following: 5GAA, like USDOT and NHTSA, prioritize safety first and foremost. Ultimately, we also agreed on the following consensus position: Despite great respect for NHTSA’s efforts to date, 5GAA cannot support the proposed V2V mandate of DSRC technology. Rather, 5GAA supports a technology neutral, market-based solution.
Our Comments address these key points:
- Technology Neutrality. Technology mandates, whether direct or de facto, problematically freeze technology solutions to a past point in time – in this case, a technology designed in the 2G, pre-mobile broadband era. The proposed direct DSRC mandate is on its face not technology neutral. Similarly, NHTSA’s alternative “if equipped” proposal – where non-DSRC V2V technologies would be required to be interoperable with DSRC but not vice versa – is de facto not technology neutral and would create the same non-level playing field in the US V2V marketplace as a direct DSRC mandate.
- Market Evolution. The technology and communications markets are evolving very fast, such that any V2V technology USDOT mandates today will already be outdated by the time the mandate goes into effect, if not already outdated. This would significantly impedes the technology innovation and evolution path for V2V safety in the US, and position the US to lag behind the rest of the world in V2V communications specifically as well as V2X broadly.
- Global Outlook. No other country is imposing a V2V technology safety mandate, or picking technology winners and losers in this way. Other countries instead recognize that the global trend is toward Cellular V2X for V2V safety applications. Therefore, a V2V technology mandate in the US would put the nation at a competitive disadvantage and prevent US consumers from benefitting from the best and most advanced V2V safety solutions.
- Performance. Cellular V2X technology for V2V safety meets or exceeds the proposed performance requirements of DSRC. Similar to DSRC, Cellular technology can transmit in an ad hoc manner without network coverage; operate without a SIM card; and adopt, evolve or innovate any privacy-preserving security management system. Cellular also can operate at twice the range of DSRC, with higher reliability; support more safety messages in a given time period than DSRC, with far less latency; and leverage widespread national cellular network coverage, unlike DSRC which lacks any meaningful network infrastructure. Moreover, the impending launch of 5G will only further widen the performance gap between Cellular and DSRC.
- Safety Applications. Cellular V2X technology for V2V safety also can address important safety applications like Intersection Movement Assist, Left Turn Assist, Emergency Electronic Brake Light, Forward Collision Warning, Blind Spot Warning, Lane Change Warning and Do Not Pass Warning – some of which cannot be addressed by DSRC.
- Road Tests. There are a growing number of road tests around the globe where 5GAA members and other stakeholders are demonstrating Cellular V2X for V2V safety applications. These real-world tests are occurring in competitive countries like Germany and China, and most recently at the Mobile World Congress in Spain. 5GAA members also will be conducting Cellular V2V safety trials in the US this year.
- Deployment Timing. NHTSA’s proposal would require 50% of new vehicles to be equipped with DSRC technology by 2021, 75% by 2022, and 100% by 2023 – pursuant to a mandate, as it recognizes that the marketplace is otherwise unlikely to adopt DSRC. Cellular technology, on other hand, will be widely deployed in US vehicles and capable of V2V safety messaging in the next few years, without any mandate. Automobile manufacturers are planning to voluntarily equip nearly all new models with embedded cellular connectivity by 2023. Further, even with the proposed mandate, NHTSA does not expect DSRC penetration to hit the 90% level needed for V2V to have a meaningful impact until 2040, and 100% until 2060. In that same 2040-60 timeframe, cellular will have evolved multiple iterations even beyond 5G, further widening the gap.
- Automated Vehicles. While V2V is by no means a prerequisite to the safe deployment of automated vehicles (self-driving cars), Cellular V2X has distinct capabilities that can be complementary to automated vehicle technologies. DSRC, on the other hand, cannot support certain advanced features of automated driving.
- Regulatory Cost. The proposed DSRC mandate would impose enormous and unnecessary costs on US taxpayers. The proposed mandate is estimated to be the second most expensive regulation in more than a decade, with total costs reaching $108 billion. Unique road-side infrastructure for DSRC is estimated to be approximately $7,000 per intersection. Consumers also will shoulder an extra $350 for their new vehicle to be equipped with DSRC. By comparison, deployment of Cellular V2X for V2V safety is being achieved at a fraction of the cost by leveraging decades and hundreds of billions of dollars of private industry investment in cellular LTE networks and new investment in 5G. And cellular LTE and 5G are being adopted globally, which enables significant economies of scale that do not and will not exist for DSRC.
For all of these reasons, 5GAA recommends – and Intel concurs – that USDOT should not move forward with the proposed DSRC mandate. Rather, NHTSA should undertake an updated, comprehensive technology neutral analysis of V2V solutions, including both DSRC and Cellular. If this review indicates that regulatory action is necessary, it should move forward with a technology neutral regulation that sets forth minimum V2V safety performance requirements only, and does not require one-way interoperability with a specific technology or in any way pick technology winners and losers.
Intel looks forward to working with the USDOT, Congress and the White House to continue to advance vehicle safety in America, and position the US to lead the world in 21st century automotive innovation and transportation infrastructure.
Global Director & Managing Counsel, Internet of Things Policy