Center for Auto Safety Response to FCC comment request on Docket No. 19-138

March 5, 2020
The Honorable Ajit Pai, Chairman Federal Communications Commission 445 12th Street, SW
Washington, DC 2055
Submitted electronically via
Dear Chairman Pai:
The Center for Auto Safety (“the Center”) appreciates the opportunity to comment on the Commission’s request for comments on Notice of Proposed Rulemaking – ET Docket No. 19- 138, Use of the 5.850-5.925 GHz Band.1
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 and injuries on American roads as soon as it is deployed.
The Center reiterates its opposition 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). As you know, DSRC is an enabling service component of the Intelligent Transportation System (ITS). DSRC is designed to enable vehicle-related communications while preserving user privacy at no cost to the user. The Center remains opposed to reallocation of the currently dedicated automotive safety spectrum as previously documented in its February 25, 2019 response to the Department of Transportation Request for Comment DOT-OST-2018-0210, V2X Communication, incorporated here by reference.2 Spectrum reallocation would inevitably further delay and imperil deployment of life-saving ITS technologies.