April 24, 2020
Ms. Marlene Dortch
Secretary, Federal Communications Commission 445 12th Street SW
Washington, DC 20554
Re: Use of the 5.850-5.925 GHz Band Proposed Rulemaking
Dear Secretary Dortch,
The Center for Auto Safety (“the Center”) appreciates the opportunity to provide reply comments on the Federal Communications Commission (FCC) proposed rule on Use of the 5.850-5.925 GHz Band (FCC 19-138).
The Center, founded in 1970, is an independent, member supported, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy. On behalf of our members, and all drivers, passengers, and pedestrians nationwide, the Center continues to support an exclusive non-commercialized, dedicated safety bandwidth that will allow vehicles to communicate with other vehicles, pedestrians, and infrastructure in a manner that has the potential to drastically reduce fatalities, injuries, and costs on American roads as it continues to be deployed.
The Center remains opposed to reallocation of the 5.9 GHz band (5.850-5.925 GHz) that has been reserved by Congress for use by Dedicated Short Range Communications (DSRC), the currently dedicated automotive safety spectrum, as previously documented in our February 25, 2019 response to the Department of Transportation Request for Comment DOT-OST-2018-0210, vehicle-to-everything (V2X) Communication, and March 20, 2020 response to Use of the 5.850- 5.95 GHz Brand; FCC-CIRC1912-YY, Notice of Proposed Rulemaking – ET Docket No. 19- 138, incorporated here by reference.1 The FCC’s proposed rule would permit unlicensed devices to operate in the lower 45 megahertz (MHz) portion of the band at 5.850-5.895 gigahertz (GHz). This spectrum is presently reserved for transportation safety technologies, which would no longer have access to the 5.850-5.895 GHz band.