The independent, non-profit member organization Consumer Reports welcomes the opportunity to comment on the U.S. Department of Transportation (DOT) request for comments regarding vehicle-to-everything or “V2X” communications, the collective name to refer to vehicle-to-vehicle, vehicle-to-infrastructure, and vehicle-to-pedestrian communications technologies that allow different participants in and parts of the transportation system to share important safety-related information through wireless transmissions. While improvements to crash protection for vehicle occupants are far from exhausted, the continued development and adoption of crash prevention technologies, including V2X communications, will play a major role in countering deaths and injuries on our roads.
Consumer Reports has followed the research and testing of crash prevention technologies based on V2X communications, and on the basis of our observations and analysis, we consider the technology to have the potential to significantly reduce the number and severity of motor vehicle crashes. This potential comes from addressing crashes that cannot be mitigated by current in-vehicle camera- and sensor-based technologies, but also from augmenting sensor-based systems as an additional part of sensor fusion. Overall, because these systems involve the use of radio signals and can transmit safety-related data without a direct line of sight, they have significant potential to improve traffic safety in a manner complementary to other crash avoidance technologies, including by giving drivers and vehicle software an early warning of yet-unseen crash hazards posed by other vehicles, weather, or road conditions. We continue to support the establishment of mandatory safety standards governing the use of wireless communications for crash prevention purposes, provided that they reasonably account for potential future developments and that manufacturers and suppliers meet baseline, enforceable standards to protect consumer privacy and data security.
DOT’s request for comments addresses recent developments in V2X technologies, and how these developments impact both V2X in general and the Department’s role in encouraging its integration. As part of a series of questions, the Department asks whether focusing on Dedicated Short-Range Communications (DSRC) technology and DSRC-based systems as the primary means of V2V communications—as envisioned by the National Highway Traffic Safety Administration’s (NHTSA) notice of proposed rulemaking of January 12, 2017—still makes sense. DOT also asks about how to ensure that alternatives to DSRC, if supported by the evidence, would be interoperable with each other and DSRC.
DOT Should Heed Several Key Principles As V2X Communications Technologies Emerge
First, as V2X is rolled out, everyone on the road should be able to benefit from interoperable wireless safety communications among cars, trucks, pedestrians, and infrastructure. New cars should be required to be able to send and receive safety messages in a mutually intelligible manner so that safety benefits reach all consumers, not just those who can afford to buy expensive add-ons. If it is to maximize crash prevention benefits, DOT will need to ensure this interoperability and the broadest possible application of V2V and other V2X standards—and the best way to accomplish this will be through mandatory standards. In 2017, the crash population identified by NHTSA as potentially addressable by V2V communications alone was significant, including 3.4 million light-vehicle to light-vehicle crashes every year, or 62% of the total, involving an estimated 7,000 fatalities and 1.8 million injuries annually. By contrast, “if-equipped” mandates applying only to the operation of V2X systems optionally included by manufacturers in new vehicles would be likely to inhibit potential safety benefits by leading to greater uncertainty in development, delayed deployment, and ultimately an insufficient fraction of the vehicle fleet being equipped with V2X capability.
Second, as various technologies are being developed, there still should be dedicated and adequate spectrum available exclusively for vehicle safety purposes. Non-safety commercial use of this dedicated safety spectrum should be prohibited, including because it would be anti-competitive and run counter to public ownership principles and the efficiency and flexibility of the spectrum. At the same time, while maintaining dedicated spectrum, any DOT standards should be flexible and allow the Federal Communications Commission (FCC) to make future decisions regarding spectrum that would align with the public interest.
Third, as V2X moves forward, DOT must recognize that consumers deserve to know what their car is transmitting, and who has access to this information. Ultimately, consumers should be able to trust that companies are legally obligated to protect the privacy and security of V2X communications as the technology is deployed. DOT should follow through on efforts to protect privacy and security in any required V2X systems, and—more broadly, in coordination with the Federal Trade Commission (FTC)—should require all vehicle and equipment manufacturers to meet baseline, enforceable standards for privacy and security, as this is the most appropriate and straightforward way to address consumers’ concerns on these subjects. At a minimum, manufacturers should be required to adhere to the Fair Information Practice Principles (FIPPs), but DOT also should work closely with Congress and other federal agencies to ensure consumers have meaningful transparency, choice, control, and security for their personal data that is associated with a motor vehicle. Alternative approaches that would rely primarily on opt-out provisions would undermine important safety technology.
Finally, the Department should set implementation time frames for V2X standards that recognize the urgency of bringing lifesaving technology to consumers’ vehicles. DOT should set relevant performance standards and test methods within the next 18 months, building on its past work in this area, and require the technology to be standard on all new vehicles no later than 2025. Since it possesses the necessary data showing the benefit to safety of these systems, there is no reason to wait until an arbitrary time after a final rule is issued before protecting the public.
For the full comments, click here.