Consumer and Auto Safety Groups Call for Non-Commercial Use of the Auto-Safety Spectrum and Strong Privacy and Security Protections

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CFA-CU-AHAS-CAS-Spectrum-Comment.pdf | 69.0 KB

Following are the Comments Filed Today with the FCC by the Consumer Federation of America, Consumers Union, the Center for Auto Safety and Advocates for Highway and Auto Safety on the Proper Use of Spectrum by the Auto Industry

Washington, D.C. August 24, 2016 — Stakeholders have raised many questions, concerns and issues surrounding the allocation of 75 MHz of spectrum to the auto industry for uses related to intelligent transportation services, including Dedicated Short Range Communications (DSRC). The intent of this allocation is to facilitate the implementation of technology designed to stem the tragic and expensive toll that vehicle crashes take on both individuals and public health. To that end, we support its use for non-commercial, safety-related communications.

As various technological issues are worked out for the use of the 5.9 GHz band, we make the following recommendations:

  1. There should be dedicated and adequate spectrum available exclusively for safety purposes. The current allocation of 75 MHz may be more than is necessary, and an impartial determination should be made as to what amount is needed solely for safety purposes.
  2. Auto manufacturers must be required to meet baseline, enforceable standards to protect the privacy and security of communications technologies using this dedicated band as they deploy them.
  3. The commercial use of this dedicated safety spectrum must be prohibited. We are concerned that the use of commercial applications in this band could:
    – Threaten safety by increasing driver distractions, which are already a leading cause of auto crashes;
    – Increase the risk of privacy violations and security compromises; and
    – Be anti-competitive and counter to public ownership principles and the efficiency and flexibility of the spectrum.