CASE Files Comments in Support of FCC Proposal to Portion Part of 5.9 GHz Band for New Technologies

March 9, 2020

Today CASE filed the following comments with the FCC regarding their Notice of Proposed Rulemaking (NPRM) to reallocate a portion of the 5.9 GHz band to clear the way for new breakthrough wireless technologies:

At this time of rapid and unprecedented advancement in technology throughout our nation and across the globe, it is only fitting that our government keep pace by re-evaluating the resources and regulatory structures under which this technology operates. For this reason, Consumer Action for a Strong Economy enthusiastically supports the FCC’s NPRM seeking to allocate a portion of the 5.9 GHz band to include unlicensed devices that will largely be committed to expanding America’s access to next generation Wi-Fi technology. To do otherwise would be wholly irresponsible, and represent the squandering of an immense and invaluable resource that could otherwise be utilized to provide enormous economic and consumer benefits.

The proposed rule recognizes it is time to reallocate the 5.9 GHz band in a way that will not only pave the way for the development of new services making use of breakthrough technologies, but will further seek innovative answers that will make the best use of bandwidth for auto safety that is currently being untapped. For the two decades that the 5.9 GHz band has been designated for Designated Short Range Communications (DSRC) little progress has been made for consumer benefit. The uncertainty of both the application of this technology and the regulatory structure under which it sits has prevented a commitment of investment and development that otherwise had the potential to enhance auto safety. The problem of uncertainty and lack of development will be resolved by amending the rules on how this band is allocated. Much needed bandwidth for Wi-Fi applications will be freed for cutting-edge technologies that can be utilized for next-generation vehicle communications (C2VX), while leaving ample megahertz for Intelligent Transportation Systems (ITS) dedicated to vehicle safety systems.

As Chairman Pai and numerous tech and industry leaders have stated, it is a false choice that consumers must decide between vehicle safety and enhanced wireless broadband. Not only is it a false choice, but the 5.9 GHz allocation proposed by the NPRM will actually lead to a complimentary improvement across all developing technologies. Wireless broadband utilized by C2VX services will not only play a critical role in adapted vehicles for accident avoidance, but as devices, vehicles and roadway infrastructure become more interconnected through 5G wireless applications, a host of other benefits will accrue. These benefits include but are not limited to lessening congestion, autonomous driving, less fuel consumption, fewer human-hours wasted in traffic, as well as greater traffic safety.

The record is unfortunately clear that the 5.9 GHz band for Intelligent Traffic Systems (ITS) has largely sat stagnant since it was set aside for this dedicated purpose. Meanwhile it has been more than a decade since added bandwidth capacity has been made available for Wi-Fi, despite rapidly growing demand and use of available capacity. The FCC proposed rule presents a rare opportunity to not only apply more band spectrum to wireless technologies at a crucial time in the development of next-generation services and applications, but to finally maximize an enormously valuable resource that has for too long sat untapped. This proposed rule will inevitably lead to new innovations that will provide solutions currently not possible under the current regulatory scheme. Only by keeping regulatory rules on pace with the technology they regulate can consumers and our nation realize the enormous benefits before us, both for greater public safety, and enhanced wireless broadband.