February 22, 2021
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February 22, 2021 Via E-Mail Innovation, Science and Economic Development Canada Senior Director, Spectrum Planning and Engineering Engineering, Planning and Standards Branch 235 Queen Street, (6th Floor, East Tower) Ottawa ON K1A 0H5 [email protected] Re: Reply Comments to Consultation on the Technical and Policy Framework for Licence-Exempt Use in the 6 GHz Band, SMSE-014-20, Canada Gazette, Part I, November 2020 Dear Madam/Sir: The 5G Automotive Association (“5GAA”) hereby submits these reply comments in response to the Consultation on the Technical and Policy Framework for Licence-Exempt Use in the 6 GHz Band recently launched by Innovation, Science and Economic Development Canada (“ISED”). In a recent unanimous decision, the Federal Communications Commission (“FCC”) designated the 5895-5925 MHz band for Cellular Vehicle-to-Everything (“C-V2X”), a state-of- the-art connected vehicle platform that is quickly gaining momentum throughout the automotive industry. As ISED considers opening the 5925-7125 MHz (“6 GHz”) band for possible licence- exempt operations, it should implement measures to protect adjacent band C-V2X operations, especially with respect to 6 GHz licence-exempt devices that could operate inside of a moving vehicle. I. The Federal Communications Commission Recently Designated the 5895-5925 MHz Band for Cellular Vehicle-to-Everything, a State-of-the-Art Connected Vehicle Platform that Improves Transportation Safety and Efficiency Built on decades of work to develop Intelligent Transportation System (“ITS”) services and more recent cellular technology advancements, C-V2X is a state-of-the-art connected vehicle platform that supports two modes of communications: direct (“C-V2X Direct”) and network communications.1 C-V2X Direct enables (1) vehicle-to-vehicle communications; (2) vehicle-to- roadside infrastructure communications (e.g., traffic signals, variable message signs), and (3) vehicle-to-pedestrian/bicyclist/vulnerable road user communications. C-V2X’s network mode allows vehicles to communicate with the rest of the world through cellular networks. Initial C- 1 More specifically, C-V2X is comprised of two complementary communications modes for vehicular operations: direct (called PC5 in Third Generation Partnership Project (“3GPP”) specifications) communications and network (called Uu in the 3GPP specifications) communications. This filing uses the term “C-V2X Direct” to describe direct communications based on the PC5 interface. V2X applications will enable improved ITS safety and efficiency services, while emerging 5G- powered C-V2X will enable advanced applications that support automated driving capabilities and enhanced pedestrian safety. The global market momentum for C-V2X Direct is increasing at a rapid rate. China allocated its 5905-5925 MHz band for C-V2X Direct in 2018,2 and major automakers such as Ford Motor Company and General Motors are already selling vehicles there equipped with the technology.3 In the United States, the FCC recently designated the 5895-5925 MHz band for C- V2X Direct services.4 Even before that decision, Ford had announced its intention to begin deploying C-V2X Direct in its vehicles in America as early as next year.5 And other automakers such as BMW of North America, Fiat Chrysler, Jaguar Land Rover and Tesla have recently endorsed the technology.6 5GAA is actively working to ensure that global regulations are conducive to the widespread deployment of C-V2X Direct and, to that end, will likely soon request that ISED initiate a consultation to review its regulations for the 5.9 GHz band. In the meantime, 5GAA supports the comments of Qualcomm in urging ISED to avoid permitting any licence-exempt operations in the 6 GHz band that would impact future C-V2X Direct safety services in the adjacent 5.9 GHz band.7 2 See Ministry of Industry and Information Technology of the People’s Republic of China, MIIT No. 203 regulation (Nov. 2018). 3 See, e.g., GM Corporate Newsroom, Buick Revolutionizes GL8 MPV Family in China with Elevated Intelligent Driving Technology (Dec. 10, 2020), https://media.gm.com/media/cn/en/gm/news.detail.html/content/Pages/news/cn/en/2020/Dec/121 0-Buick.html; TheNewsWheel.com, Ford Launches V2I Technologies in China (Jan. 15, 2021), https://thenewswheel.com/ford-v2i-technologies-debut-china. 4 See Use of the 5.850-5.925 GHz Band, First Report and Order, Further Notice of Proposed Rulemaking, and Order of Proposed Modification, 35 FCC Rcd 13440, FCC 20-164, ET Docket No. 19-138 (Nov. 20, 2020). 5 See Don Butler, How ‘Talking’ and ‘Listening’ Vehicles Could Make Roads Safer, Cities Better, Medium (Jan. 7, 2019), https://medium.com/cityoftomorrow/how-talking-and-listening- vehicles-could-make-roads-safer-cities-better-f215c68f376f. 6 See Comments of The BMW Group, ET Docket No. 19-138, at 1-2 (filed Mar. 9, 2020); Comments of FCA US LLC, ET Docket No. 19-138, at 2 (filed Mar. 9, 2020); Comments of Jaguar Land Rover Limited, ET Docket No. 19-138, at 3 (filed Mar. 9, 2020); Comments of Tesla, Inc., DOT-OST-2018-0210, at 1-2 (filed Jan. 31, 2019) (expressing to the U.S. Department of Transportation that Tesla’s vehicles are positioned to utilize C-V2X Direct because the technology “inherently builds on 4G LTE and the likely eventual migration to 5G.”). 7 See Letter from Dean R. Brenner et al., Senior Vice President, Spectrum Strategy & Technology Policy, Qualcomm Incorporated, to Innovation, Science and Economic Development, at 3 (Jan. 19, 2021). 2 II. ISED Should Adopt Reasonable Unwanted Emissions Limits for Licence-Exempt Operations To the extent ISED is inclined to authorize low-power-indoor and fixed standard-power licence-exempt operations in the 6 GHz band, 5GAA supports the comments of Qualcomm that a -27 dBm/MHz out-of-band emissions (“OOBE”) limit should apply at the 5925 MHz lower band edge for such operations.8 These limits would be consistent with those adopted by the FCC for such operations, and 5GAA believes that C-V2X Direct safety services should be able to withstand unwanted emissions from such devices at these levels. However, as Qualcomm also notes, additional protections—beyond the -27 dBm/MHz limit—are necessary to protect C-V2X Direct from portable Very Lower Power (“VLP”) devices and any other mobile devices permitted in the 6 GHz band. Even if meeting a -27 dBm/MHz limit at the band edge, real-world testing shows that in-vehicle adjacent band operations by licence-exempt devices will cause significant interference to C-V2X Direct. This interference, which degrades the effectiveness of C-V2X Direct safety services,9 is primarily caused by two factors: (1) insufficient isolation between the C-V2X receiver and in-vehicle licence-exempt device transmissions and (2) the fact that the interferer travels with the vehicle—in continuous close range of the C-V2X receiver—causing sustained interference. To protect C-V2X Direct safety services from interference caused by in-vehicle 6 GHz VLP and other licence-exempt mobile devices, 5GAA supports the protections Qualcomm requests. First, ISED should require such portable VLP licence-exempt devices to avoid the lowermost 6 GHz U-NII-5 channels, which would be defined as any channel with a center frequency below 5925 MHz + BW*3/2, where BW equals the bandwidth of the channel. Second, ISED should impose a power spectral density limit on VLP operations in the U-NII-5 band to encourage licence-exempt use of channels 160 MHz and wider. These two protections will help to provide sufficient frequency separation between in-vehicle VLP operations and C- V2X Direct services. Moreover, to the extent ISED authorizes portable VLP operations in the 6 8 Id. 9 In the context of the FCC’s 5.9 GHz proceeding, a group of 5GAA members conducted real- world testing to assess the adequacy of an OOBE limit proposed by one of the parties in that proceeding. See Cellular V2X Device-to-Device Communication Consortium, Task 8: Assessment of Wi-Fi Interference to C-V2X Communications Based on Proposed FCC 5.9 NPRM, https://pronto-core-cdn.prontomarketing.com/2/wp- content/uploads/sites/2896/2020/04/CAMP-CV2X_Project_Task_8_Final_04242020.pdf. 5GAA subsequently translated those results to assess the adequacy of a -27 dBm/MHz root mean squared OOBE limit at 5925 MHz to protect C-V2X Direct from in-vehicle portable operations in the adjacent 6 GHz band. 5GAA presented its methodology and the results of that translation to staff at the FCC last year, and that presentation is attached hereto. See 5GAA, Protecting 5.9 GHz C-V2X operations from 6 GHz unlicensed In-Vehicle VLP and Mobile Hotspots in the U- NII-5 band, ET Docket No. 18-295 (Nov. 12, 2020), attached as Attachment 3 to Letter from Sean T. Conway, Counsel to the 5G Automotive Association, to Marlene H. Dortch, Secretary, Federal Communications Commission, ET Docket No. 18-295 & GN Docket No. 17-183 (filed Nov. 16, 2020). 3 GHz band, the proposed protection will not meaningfully curtail VLP applications because the remainder of the 1200-MHz-wide 6 GHz band would presumably be available for such uses. III. Conclusion As the global market momentum accelerates for C-V2X Direct, 5GAA respectfully requests that ISED consider the measures identified herein to protect C-V2X Direct safety services from interference. Respectfully submitted, /s/ John F. Kwant John F. Kwant Global Director Government Relations, Mobility and Advanced Technologies Ford Motor Company Chair, 5GAA North American Task Force /s/ Dean R. Brenner Dean R. Brenner Senior Vice President, Spectrum Strategy and Technology Policy Qualcomm Incorporated Vice Chair, 5GAA North American Task Force Attachment 4 Protecting 5.9 GHz C-V2X operations from 6 GHz unlicensed In-Vehicle VLP and Mobile Hotspots in the U-NII-5 band ET Docket No.