The Association of Global Automakers (Global Automakers) joined with the Alliance of Automobile Manufacturers, Intelligent Transportation Society of America, and Denso International America, Inc. to file reply comments with the Federal Communications Commission (FCC) in regard to ET Docket No.13-49. The reply comments are submitted in response to the Public Notice issued by the FCC pertaining to Revision of Part 15 of the Commission's Rules to Permit Unlicensed National Information INfrastructure (U-NII) Devices in the 5GHz Band.
The comments in the attached proceeding underscore the tremendous potential of Dedicated Short Range Communications ("DSRC") to significantly improve safety on our nation's roadways and the need to ensure that operations on all DSRC channels are protected from harmful interference. Consistent with our comments, the comments of others establish that DSRC is no longer in pre-deployment mode, but is being deployed significantly in a number of jurisdictions across the country. These deployments include vehicle-to-vehicle (“V2V”), vehicle-to-infrastructure (“V2I”), and vehicle-to-pedestrian (“V2P”) applications and depend on reliable, interference-free use of all DSRC channels, not just the channel limited to V2V communications.
The comments also compellingly demonstrate why, of the two sharing approaches beingconsidered, “detect and avoid” is superior to “re-channelization.” Detect and avoid will more likely protect DSRC from harmful interference and will not require any changes to DSRC’s system design or the Federal Communications Commission’s (“Commission” or “FCC”) DSRC rules. Because no changes to the DSRC system, broader DSRC ecosystem, or DSRC rules will be required, implementation of the detect and avoid approach will not delay the roll-out of this important safety technology.