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).

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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).

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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

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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

November 12, 2020

1 Overview and Summary

• 5GAA has filed studies demonstrating that the -27 dBm/MHz OOBE level applicable to 6 GHz fixed outdoor APs1 and indoor unlicensed equipment will render unusable 5.9 GHz C-V2X reception if that level is radiated from in-vehicle unlicensed U-NII-5 equipment1 • In-vehicle U-NII-5 operations provide key VLP and mobile AFC use cases as unlicensed advocates explain • 33 dB additional isolation beyond the -27 dBm/MHz level is needed to protect C-V2X reception, and can be accomplished by requiring unlicensed in-vehicle devices to avoid the lowermost U-NII-5 channel or by imposing a 33 dB more stringent OOBE level on in-vehicle U-NII-5 operations • The CAMP C-V2X Consortium Test Results using actual V2V communications (which 5GAA previously filed in the 5.9 GHz docket) further augment the 6 GHz record built by 5GAA and its members and support the need for much greater protection of C-V2X receivers from 6 GHz U-NII-5 in-vehicle operations, including VLP portables, peer-to-peer operations, and mobile AFC operations

1. See, e.g., 5GAA Dec. 9, 2019 ex parte letter; 5GAA Jan. 9, 2020 ex parte letter; and 5GAA Jan. 24, 2020 ex parte letter, all filed in ET Docket No. 18-295. 2 C-V2X Consortium Test Results Show In-Vehicle Unlicensed U-NII-5 Equipment Meeting a -27 dBm/MHz OOBE Level Will Interfere With C-V2X Reception in the 5.9 GHz Band • The analysis here compares the interference to C-V2X receivers caused by the Wi-Fi Alliance (WFA) proposed outdoor OOBE levels -- published by the CAMP C-V2X Consortium1,2 and presented by 5GAA to the FCC in the 5.9 GHz proceeding3 -- to the -27 dBm/MHz rms OOBE level that applies to 6 GHz LPI and fixed outdoor standard power APs • C-V2X Consortium testing with the WFA proposed outdoor mask (based on peak levels) demonstrates harmful interference to C-V2X • The average OOBE signal power into 5905-5925 MHz C-V2X channel is comparable between the two masks with the -27 dBm/MHz flat OOBE mask having a slightly greater impact and similarly rendering the C-V2X service unreliable • The impact of a flat OOBE signal mask of -27 dBm/MHz rms produces about the same harmful impact to C-V2X operations in 5905-5925 MHz as the WFA proposed OOBE outdoor mask that the CAMP C-V2X Consortium analyzed

1 https://pronto-core-cdn.prontomarketing.com/2/wp-content/uploads/sites/2896/2020/04/CAMP-CV2X_Project_Task_8_Final_04242020.pdf 2 https://pronto-core-cdn.prontomarketing.com/2/wp-content/uploads/sites/2896/2020/09/CAMP-CV2X-WiFi-Interference-Testing-Results-v6.11.3.pdf

3 5GAA C-V2X Consortium Testing Presentation w Attachment.pdf 38 3 Wi-Fi Signal Interference OOBE Comparison

• The figure shows the two emissions masks expressed in peak EIRP density

• A 10 dB peak to average ratio (p/a) is assumed for the interfering Wi-Fi signals, which translates the -27 dBm/MHz rms level to a -17 dBm/MHz peak level

• The -27 dBm/MHz OOBE signal mask equals the -17 dBm/MHz (peak) level depicted as the orange line

• The WFA outdoor OOBE mask is the blue dotted line in the graph and is the same as Proposal 1 depicted on slide 8 of the CAMP C- V2X Consortium Test Report1

1 https://pronto-core-cdn.prontomarketing.com/2/wp-content/uploads/sites/2896/2020/04/CAMP-CV2X_Project_Task_8_Final_04242020.pdf 4 WFA proposed 5.9 GHz OOBE mask vs -27 dBm/MHz rms • CAMP C-V2X Consortium test results show: • WFA proposed 5.9 GHz outdoor OOBE mask results in lower average power in CH 183 as compared to an interferer with -17dBm/MHz peak OOBE profile (which translates to -27dBm/MHz rms assuming 10 dB peak to average ratio) (Slide 19 of C-V2X Consortium Test Results1) • The C-V2X receiver has up to 2 dB better sensitivity (10% PER) performance in presence of an interferer with WFA mask as compared to interferer with -17 dBm/MHz peak (or -27dBm/MHz rms) (Slides 26 & 28) • At least 80 dB isolation is required to protect C-V2X from harmful interference from either the WFA proposed outdoor mask or the -17 dBm/MHz peak (or -27dBm/MHz rms level). • As noted above, the WFA proposed outdoor mask radiates less unwanted noise into the 5.9 GHz C-V2X band than the -27 dBm/MHz rms level that applies to fixed outdoor U-NII-5 equipment 80 dB isolation is impossible to guarantee within the vehicle depending upon C-V2X antenna location and portable device location which can be within a meter of each other

Source: 1 CAMP C-V2X Consortium Test Report available at https://pronto-core-cdn.prontomarketing.com/2/wp-content/uploads/sites/2896/2020/04/CAMP- CV2X_Project_Task_8_Final_04242020.pdf 5 CH 183 Impacts with the WFA Proposed Outdoor Mask

• In-Vehicle unlicensed U-NII-4 operations field test results published by the CAMP C-V2X Consortium show harmful interference to C-V2X operations in CH 183 from interferer meeting the WFA proposed outdoor mask (Slide 26 of C-V2X Consortium Interference Field Testing Results) • Up to 47% range reduction in V2V NLOS scenarios • Up to 71% range reduction in I2V NLOS scenarios • Up to 81% range reduction in V2V Intersection NLOS scenarios • Impact to V2V Safety Applications in CH 183 has been noted (Slide 19 of deck linked above) • Depending upon the relative positioning of the interferer and C-V2X antennas, the interference impact to C-V2X can be even worse

6 Conclusion • The interference from an unlicensed interferer compliant with the OOBE outdoor mask proposed by the WFA in the 5.9 GHz proceeding is comparable to -- but less harmful than -- the interference caused by -27dBm/MHz rms OOBE that applies to fixed outdoor APs in the 6 GHz U-NII-5 band • In-vehicle operations of U-NII-5 equipment meeting a -27 dBm/MHz rms OOBE level reduces V2V communications range by 81% in some use cases, rendering it unusable for vehicle safety communications; this confirms 5GAA’s prior 6 GHz band advocacy and request for additional protection • 5GAA requests that the FCC impose additional requirements on portable VLP and mobile AFC operations to ensure reliable reception of C-V2X safety messages if such operations are authorized • The FCC should require that the lowermost U-NII-5 channel be avoided by these portable/mobile devices and impose a Power Spectral Density Limit on U-NII-5 portables/mobiles to encourage the use of wideband channels (of 160 MHz and wider). Alternatively, the FCC can impose a -60 dBm/MHz OOBE level on these new U-NII-5 operations • The FCC should implement one of these protections now and could explore via an FNPRM potential means of allowing greater portable/mobile access to the U-NII-5 band while protecting the 5.9 GHz C-V2X band • Some potential solutions to study via an FNPRM include requiring unlicensed U-NII-5 devices to detect one or more of the following: (i) energy from adjacent channel C-V2X operations, (ii) in-vehicle motion, and (iii) location on or close to an active roadway – before beginning portable/mobile operations in the lower portion of the U-NII-5 band.

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