March 9, 2020

Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554

Re: Use of the 5.850-5.925 GHz Band (ET Docket No. 19-138)

Volvo Group North America (“VGNA”) respectfully submits its comments on the Federal Communications Commission’s (“FCC’s”) public notice on the use of the 5.850-5.925 GHz band (ET Docket No. 19-138), dated February 6, 2020. According to the notice, the FCC will amend its rules for the 5.850-5.925 GHz band by allowing unlicensed Wi-Fi users to operate in the lower 45 MHz of the band and Intelligent Transportation System (“ITS”) operations in the upper 30 MHz. Additionally, ITS operations would consist of Cellular Vehicle-to- Everything (“C-V2X”) devices at 5.905-5.925 GHz (20 MHz), and C-V2X and/or Dedicated Short-Range Communication (“DSRC”) devices at 5.895-5.905 GHz (10 MHz).

The Volvo Group is one of the world’s leading manufacturers of trucks, buses, construction equipment and marine and industrial engines. Volvo Group develops, manufactures, and sells heavy-duty trucks, buses, contruction equipment, and motor coaches and their powertrains in the U.S. under the brand names of Volvo Trucks, Mack Trucks, Volvo Construction Equipment, Nova Bus, Volvo Bus, and Prevost. The Volvo Group has been manufacturing in the U.S. since 1903 and directly employs nearly 13,000 Americans. We indirectly employ tens of thousands more Americans through our supply chain and dealer networks. Our major facilities are in North Carolina, Pennsylvania, Virginia, Maryland, and New York. We have invested nearly $2 billion in our nine manufacturing facilities since 2002 and spend more than $250 million in R&D in the U.S. every year.

A summary of the Volvo Group comments follows on page 2 with more detailed comments on page 6.

Summary of Volvo Group comments • VGNA supports preserving the entire 5.9 GHz band for ITS safety operations (i.e. V2X safety applications). The FCC spectrum reallocation plan will reduce the available spectrum for V2X safety applications by 60%, thereby reducing the societal benefits of ITS operations by at least 60%. This is not in the interest of the general public1. V2X applications designed to use 75 MHz of spectrum cannot be compressed to operate in only 30 MHz2. The FCC should not take any action that would risk jeopardizing a revolutionary tool in mitigating fatalities on our roads and loss in our communities, and should support development and deployment of V2X technologies in the full 75 MHz of the 5.9 GHz band.

• VGNA requests comprehensive testing and clarity on the subject of interference from unlicensed Wi-Fi operations. Without a high level of reliability, transportation safety will be negatively impacted. Results from the United States Department of Transportation (USDOT) investigation3 suggest that the FCC spectrum reallocation plan will result in significant signal interference and render the remaining 30 MHz useless for V2X collision-avoidance applications.

1 Letter from Sec. Chao; Letter from Carlos Braceras and Jim Tymon to Chairman Pai, August 19, 2019. Available at: https://www.transportation.org/wp-content/uploads/2019/08/2019-08-19-AASHTO-52-CEO- Letter-to-FCC-on-5.9GHz-Safety-Band.pdf; and Alliance of Automobile Manufacturers, ITS America, and Seven Organizations Issue Joint Statement on Preservation of the Road Safety Spectrum, November 20, 2019. Available at: https://static1.squarespace.com/static/596fb16003596e0fa70a232f/t/5dd594333580434ee4c97af3/1574278195 144/S_2019_MultiAssocSpectrumFinal20NOV2019+%28003%29.pdf

2 Concerns with Draft FCC NPRM: Use of the 5.850-5.925 GHz Band [ET Docket No. 19-138], USDOT Spectrum Team, December 5, 2019. Available at: https://www.transportation.gov/sites/dot.gov/files/docs/research-and-technology/359811/preliminary- technical-assessment-fcc-59-ghz-nprm-05dec2019-final.pdf

3 https://www.transportation.gov/sites/dot.gov/files/docs/research-and-technology/360181/oobe-energy-59- safety-band-final-120619.pdf

• VGNA has concerns with how the FCC proposed rule will negatively impact incumbent “DSRC” operations today, rendering the technology and ongoing infrastructure investments4,5 wasted and unusable.

• The proposed rule calls for major changes to the use of the 5.9 GHz band, and will delay the roll out of V2X technology on Volvo Group products in the U.S. market. Given the significant concerns noted below (see page 6) and the need for a full process to properly address these matters, we request the FCC not proceed with the rule making until it can be proven beyond a reasonable doubt that introducing unlicensed Wi-Fi users will not compromise the incumbent V2X safety operations being developed and deployed around the nation.

Volvo Group activities related to connectivity and automated transport solutions

Vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2I) communications (collectively known as V2X) have received much attention during the last decade worldwide since V2X enables new types of services in the fields of active safety, fuel efficiency, and higher levels of automated driving. V2X technologies using the 5.9 GHz frequency band are referred to as cooperative intelligent transport systems (C-ITS) in Europe, and connected vehicle technology in the U.S. A minimum set of protocols for supporting initial deployment of C- ITS have been developed, approved, and published. Volvo Group is contributing actively to ETSI and SAE, and follows the work within CEN/ISO.

Real-time connectivity allows vehicles to become connected to one other, to the infrastructure, and to other parts of the transportation network, thereby enhancing awareness

4 https://policy.transportation.org/wp-content/uploads/sites/59/2019/12/AASHTO-Letter-to-Congress-on- 5.9GHz-Safety-Band-2019-12-16-FINAL.pdf

5https://static1.squarespace.com/static/596fb16003596e0fa70a232f/t/5e17a24b8c51e1103bd593d1/157860717 9524/V2X+Fact+Sheet+2020.pdf

of the surroundings. In addition to what drivers can immediately see around them, and what vehicle sensors can detect, all parts of the transport system will increasingly be able to exchange information to improve decision-making. Thus, connectivity can improve road safety by detecting and acting on risks beyond the capability of the driver and radar/lidar sensors based on direct line of sight. Deployment of these technologies will not only improve safety by avoiding collisions, but also by reducing congestion and improving traffic flow, while also reducing environmental impacts.

With the belief that connectivity and automated driving will allow for cleaner and safer cities to grow and prosper, the Volvo Group has engaged in many flagship projects, both globally and in the U.S. Volvo Group has been a member of an automotive consortium funded by USDOT to pre-competitively assess, design, develop, and demonstrate advanced prototype vehicle-to-infrastructure (V2I) applications to enhance safety at intersections, on an approaching curve, and at work zones with lane closures. In 2016 and 2017, Volvo Group demonstrated three V2I safety applications – curve speed warning, red light violation warning, and reduced speed zone warning – using data from the infrastructure to increase driver awareness of the approaching hazard. Along with the largest light duty automobile manufacturers (“OEM”) in the world, Volvo Group was the sole heavy-duty truck manufacturer involved in this important DOT partnership. The consortium has also been investigating other V2I applications to provide real-time traffic information, remote monitoring, and communication between vehicles that can be used to reduce vehicle congestion and emissions.

Volvo Group has long supported truck platooning because it benefits freight companies and professional drivers alike through safer, more fuel-efficient operations. In fact, platooning presents the best near-term opportunity for leveraging any level of autonomous technology for on-highway operations, where a skilled professional driver remains vitally important. From 2014-2018, the Volvo Group teamed up with USDOT, Caltrans, California Partners for Advanced Transportation Technology and others to successfully demonstrate truck

platooning in real traffic on public roads inspiring dialogues between policymakers, law enforcement officials, and the entire trucking community. In another USDOT-sponsored project, the Volvo Group teamed up with eight other light duty OEMs, Tier-1 suppliers, and academic institutions for systematically extending the capabilities of a common adaptive cruise control (ACC) to cooperative adaptive cruise control (CACC) using vehicles of different makes and models. Most recently, together with FedEx and the North Carolina Turnpike Authority, Volvo Trucks demonstrated advanced driver assistance system (ADAS) technology to conduct on-highway truck platooning as part of ongoing research collaboration.

Volvo Group has engaged in several other truck platooning initiatives around the world. On the heels of the “European Truck Platooning Challenge” (of which the Volvo Group was a part), the same truck OEMs (including the Volvo Group) have been part of the EU-funded “ENSEMBLE” project to bring multi-brand truck platooning to European roads. In a Swedish public agency-funded “Sweden4Platooning” project, Volvo Group teamed up with DB Schenker, Scania, the Royal Institute of Technology, Research Institutes of Sweden (RISE) and the Swedish Transport Administration to demonstrate multi-brand truck platooning in customer operations. In early 2018, UD Trucks (part of the Volvo Group) participated in Japan’s first truck-platooning operation test on a section of the Shin-Tomei Expressway in Shizuoka Prefecture.

We continue preparing for deployment of trucks with greater V2X capabilities that support higher levels of ADAS. We know these technologies are a part of our future, but exact timing depends on many things, namely regulations, infrastructure, safety standards, and market demand. Furthermore, increasing momentum around technology policies and deployment guidelines is needed for widescale deployment. With this in mind below are our comments.

Detailed comments on the use of the 5.850-5.925 GHz band

The Volvo Group would like to take this opportunity to stress some important points responding to the request for comments.

• V2X technologies have the potential to enhance situational awareness and can greatly enhance vehicle safety. DSRC is currently a key component of our autonomous solutions plans. Advances in radar/lidar/cameras do not render V2X technology moot. • The regulatory uncertainties have delayed our ITS commercialization plans in Europe and the U.S. However, over the next three years, Volvo Group is planning to offer V2X solutions globally where the required frequency allocation is in place. The proposed channel plan from the FCC will negatively impact our commercialization plans and delay V2X technology rollout in the U.S. market. • The testing from the USDOT investigation6 on emissions from adjacent channels has revealed that the reliability of V2X communications in the proposed FCC channel configuration will be compromised. Therefore, FCC should not rush the rule making decision without addressing this critical technical challenge. • The rate of V2X technology (such as DSRC, and more recently, C-V2X) development (i.e., affordable chipsets, portable communication kits, etc.) and deployment (e.g., efforts undertaken by Federal, State, and many regional public agencies) has tremendously increased over the last few years7. The transportation industry operates on a different timeline from the consumer electronics industry and requires coordination among a larger number of stakeholders. Harmful interferences or any unexpected channel reassignment strategies as a result of any channel reassignment will significantly disrupt the ongoing deployments and innovations within the current

6 https://www.transportation.gov/sites/dot.gov/files/docs/research-and-technology/360181/oobe-energy-59- safety-band-final-120619.pdf

7 https://policy.transportation.org/wp-content/uploads/sites/59/2019/12/AASHTO-Letter-to-Congress-on- 5.9GHz-Safety-Band-2019-12-16-FINAL.pdf

established FCC framework. This will impact the Day 1 and Day 1.5 applications that are being developed and tested today. • We request the FCC to ensure that by 2021, the peer-to-peer mode in C-V2X radios will function with no SIM/cellular subscription, seamlessly and dynamically with no market driven restrictions or settings changes. This is the critical piece that supports safety of all road users on our national highways when this V2X technology is deployed. • Keeping in mind the many ongoing DSRC-based initiatives across our nation8, limiting the spectrum to just 10 MHz and allowing C-V2X to operate in the same band will essentially make this technology and the infrastructure investments unusable. Potential rule changes should ensure compatibility with V2X systems, so safety data can freely be exchanged among V2X-equipped vehicles, regardless of which V2X communications technology is on each vehicle. • We agree with NHTSA that the entire band should be protected, and that no decision on re-allocating any portion of the band should be made until the entire 3-phase test plan is completed9. We, therefore, encourage the FCC and DOT to work together toward completing the 3-phase test plan. • We are encouraged by the work being done by the IEEE 802 LAN/MAN Standards Committee10 to produce a Next Generation V2X (NGV) standard to provide a seamless evolution path for DSRC that guarantees device interoperability, same-channel coexistence, and backward compatibility. This will stimulate further near-term investments in DSRC by ensuring that those investments will be protected and enhanced in the years to come. Avoiding band fragmentation achieves an evolution that is both spectrally efficient (no duplicated services) and cost efficient (no need to invest

8https://static1.squarespace.com/static/596fb16003596e0fa70a232f/t/5e17a24b8c51e1103bd593d1/157860717 9524/V2X+Fact+Sheet+2020.pdf

9 https://www.nhtsa.gov/press-releases/us-department-transportations-national-highway-traffic-safety- administration-issues

10 See comments of IEEE 802 LAN/MAN Standards Committee on http://www.ieee802.org/11/Reports/tgbd_update.htm.

in multiple technologies). The changes proposed by the FCC will eliminate any incentive to continue development on NGV V2X.

Volvo Group North America appreciates the opportunity to submit these comments, and looks forward to working with the FCC and other government agencies, as well as industry partners and other stakeholders, in the development of safe and reliable practices associated with the application of the 5.9GHz band.

Please do not hesitate to contact us if additional information is needed.

Aravind Kailas, PhD Advaced Technology Policy Director Public Affairs Volvo Group North America

575 Anton Blvd, Ste 860 Costa Mesa, CA 92626

E-mail - [email protected] Phone - +1 714-277-8172