Why automated vehicle advocates say the FCC dealt the nation a setback on safety

On this week’s Talking Michigan Transportation podcast, experts in intelligent transportation systems and connected and automated vehicle research react to Wednesday’s Federal Communications Commission (FCC) action. Guests include Debra Bezzina, managing director of the Center for Connected and Automated Transportation at the University of Michigan Transportation Research Institute (UMTRI), and Collin Castle, MDOT Intelligent Transportation Systems program manager.

The background: The five FCC members voted unanimously Wednesday to free up more spectrum for Wi-Fi, despite strong protests from all 50 state transportation departments, leading university research institutions and other national leaders. The vote allows for Wi-Fi usage in what's known as the 5.9 GHz band of spectrum. For more than 20 years, the spectrum has been set aside for vehicle-to-vehicle and vehicle-to-infrastructure communications using Dedicated Short-Range Communications (DSRC) technology.

"On Nov. 18, the FCC unanimously voted to value streaming video entertainment above human life," Bezzina said.

Later, Bezzina explains why the decision could ultimately devalue technology investments from UMTRI, MDOT and other agencies.

ITS America President and CEO Shailen Bhatt was among those who reacted strongly to the commission's action. "ITS America is but one of dozens of transportation safety organizations that have been sounding the alarm about the implications of this action… In a time in which we are rightly focused on following science and data, it is inexplicable that the FCC is willfully disregarding the advice of experts," he told Traffic Technology Today. 

Bezzina also questions the legality of the FCC action and predicts multiple lawsuits.

MDOT's Castle talks about why this represents a "pause" for progress in researching and supporting connected and automated vehicle development and what a transition to other technologies would look like and how to adapt devices. He also explains how DSRC works.

Connected vehicle photo courtesy of the U.S.  Department of Transportation.

Transcript

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Narrator: It's time for Talking Michigan Transportation, a podcast devoted to the conversations with people at the forefront of the ongoing mobility revolution. In the state that put the world on wheels, here's your host, MDOT Communications Director Jeff Cranson.

Jeff Cranson: Hi, welcome again to the Talking Michigan Transportation podcast. I'm Jeff Cranson, and today I'm happy to be talking with Debra Bezzina from the University of Michigan Transportation Research Institute, and we're going to be talking about the FCC ruling this week that grants--basically allocates spectrum for Wi-Fi use to what's known as the 5.9 gigahertz band of spectrum. It'll be used for unlicensed indoor use. The proponents would say it'll improve speeds and reduce congestion on five gigahertz Wi-Fi. This has been reserved for, I think, more than 20 years for vehicle the vehicle and vehicle to infrastructure communications, V2V, V2X, as we call it, and using a technology known as dedicated short-range communications, DSRC. So, Debra, I know you followed this issue very closely. I guess, give me your thoughts on the FCC ruling.

Debra Bezzina: My first thought is that on November 18, the FCC unanimously voted to value streaming video and entertainment above human life, and to me that is the whole crux of their decision was to be able to stream. That's what they're talking about, the indoor usage is streaming more video instead of saving human lives that are being killed needlessly on the roads today. So, you know, we have over 37,000 fatalities on the roads, but that doesn't even address the accidents that are causing debilitating injuries and life-changing injuries for our citizens.

Jeff Cranson: Yeah, I've often thought when you hear skeptics and people that still kind of, you know, worry out loud about the various developments and automated vehicles and the, you know, the incremental things that we're doing already with auto braking and lane assist, and you think about the lives that can be saved just by those things. When you eventually put it all together you really are going to cut drastically into those numbers that we accept as a society, that 35 to 40,000 people are killed in car crashes every year. How are we going to look back at this 100 years from now, at this period in our in our time? You know, because we wouldn't accept that if they were plane crashes, so—

Debra Bezzina: Exactly and I–we're still scratching our head, let me put it that way. It was overwhelmingly negative responses to the NPRM and yet the FCC went ahead based on this small sliver of people that thought it was a good idea, and those people are really looking at making more money on streaming video and I just cannot justify that. The FCC doesn't have the data to back them on saying that this is a good thing, or this will even work. There's a lot of skepticism in the technology arena to say, “hey, this doesn't—this won't be enough,” and in reality, you know, when we go from, they call it, you know, release 14 is in this band, but when they go to release 16, which is going to be using the 5g technology, this band won't even be adequate. So, what are you really doing? You're really just not using the band at all, and, you know, legally it doesn't seem that they really can do this either, yet they have. So, I think the first thing that we're going to see is some lawsuits coming out from OEMs, or from USDOT itself, or other interested parties like IOOs, such as MDOT, or the consortium of IOOs, AASHTO, because there has been previous rulings by the supreme court that says the FCC's power is really to modify existing licensing moderately or minorly, and this is neither moderate nor minor. That is huge. We have 50 million dollars invested in Ann Arbor alone, and this is just one deployment in the United States. There's over 200 deployments in the United States, not all of them are as large, but there are several very large deployments and MDOT is one of those. MDOT has deployed hundreds of units throughout Michigan and that's not free. So, being miner—and all of our deployments are DSRC, as well as MDOT, so saying that this is minor, is not. It's saying that you cannot broadcast DSRC. The ruling is in one year you need to vacate the lower portion of the band, which we all broadcast in. In Ann Arbor, we use the full band, and secondly, in two years you have to discontinue use of DSRC. All of us are DSRC, so I don't know how that could be moderate or minor.

Jeff Cranson: So, before we get into that a little bit more, the research component of this and the impact it's going to have on the research that you're doing there, would the advocates for this—I assume they would say that, you know, this isn't just about streaming cat videos. This is about providing better access. I mean, we're all in favor of better broadband especially in rural areas and in areas that are underserved now, and that's why it was unanimous vote, even the democrats on the commission voted for this. I mean, is that an argument?

Debra Bezzina: I'm not really sure that it is. I think that it is an argument that we do need to get better Wi-Fi for rural areas or better connectivity for rural areas. I don't think that this is the only solution to do that, and I don't even know if it's really going to help those areas. What I’m seeing is that they're not talking about getting more Wi-Fi for the rural areas. That may be what they say, but what I’m seeing is they just want more streaming for the people that already have it.

Jeff Cranson: And are willing to pay for it.

Debra Bezzina: Exactly.

Jeff Cranson: So, talk about a little bit more—you talked about the DSRC and what it means to the RSUs that you already have deployed in the Ann Arbor area and the campus at U of M and what MDOT's done. Does it make all those investments worthless?

Debra Bezzina: Absolutely, yeah, totally worthless, and again we're talking 50 million dollars right out the window. I don't know how much MDOT is spent but I’m sure it was significant as well. Yeah, we're going to have to start pretty much from scratch. I mean, we do have fiber cables and communication lines, you know, that go to those sites so that'll save us a little bit of money, but, you know, really all the devices will have to be taken down.

Jeff Cranson: So, later I’ll be talking with Collin Castle who's the ITS program manager at MDOT, but I know he's told me that that this is a major stall. It's a major setback for the progress that we were making in research and development of ways for vehicles to communicate with each other and really all the things that we know need to happen. This is a major setback in that progress it sounds like you feel that way, too

Debra Bezzina: Oh, I agree 100 percent, you know, I think that the FCC's move will in effect render what's left of the safety spectrum useless for preventing crashes in the U.S. So, I think that even narrowing it to the 30 megahertz is not going to be adequate in the long run, and, so, it'll be just useless.

Jeff Cranson: Well, so, somebody who's studied these kinds of things and dealt with other issues at the state and federal level, can you think of a parallel for this where 50 DOTs and so many organizations, research, universities were so unanimous in something and yet the federal agency went the other way?

Debra Bezzina: I do not have an example of that, and I’m still, again, scratching my head going I don't quite understand. If everyone, 90 percent of the people, are against it then how are we letting the 10 rule?

Jeff Cranson: Well, and you probably heard, you know, what the chairman had to say. I think his exact quote was, ‘today, at long last, we say in the unified, bipartisan voice: Time's up.’

Debra Bezzina: So, I’m more in alignment with Shailen Bhatt, the ITS America President, and he just outright says that Chairman Pai’s statement is wrong. It is corporate interests that are cheering the reallocation of the safety spectrum away from public interests.

Jeff Cranson: Yeah, I saw what Shailen said and I plan to include that in the show notes. So, well, you guys haven't had time to— I mean, you anticipated this is a possibility  but you haven't had time to really reset and rethink everything at UMTRI and what you're going to do, probably.

Debra Bezzina: No, and in fact it brings in a new level of uncertainty. You know, we just did a proposal to USDOT on converting the environment to a dual DSRT CVDX environment to show that you can have both, and we can provide a solution so that OEMs don't have to choose between DSRC and C-V2X. That they can go ahead and deploy either, so instead of saying, you know, put all your eggs in one basket or another that it's mitigating the risk for the OEMs and Tier 1’s.

Jeff Cranson: And that's flexibility that industry wanted.

Debra Bezzina: Exactly, and so now I’m unsure on how that will pan out, if anything, which I thought was a very valuable deployment for USDOT. Maybe it's going to need to look a little bit different, but it's really just hard to say what we're going to end up looking like in Ann Arbor, and it will be a matter of funding. Like I said, we've already spent a lot of money. It’s nothing that we can recoup, and so how do we move on from here to secure additional funds? It's not like, you know, everyone here is just making a ton of money and they’re just giving it away.

Jeff Cranson: Right, well—

Debra Bezzina: We're in the middle of a pandemic and things are a little bit bleak.

Jeff Cranson: Well, talk a little bit about UMTRI and your work, I guess, at a high level what UMTRI does.

Debra Bezzina: So, UMTRI was founded in 1965 and it focuses on anything to do with transportation, so we've been doing transportation research for 55, almost 56 years this year. What I do at the university is connected vehicle technology. So, we've had a connected deployment since safety pilot model deployment was launched in 2012, and we have been upgrading the environment and just maintaining and operating in the environment of the last few years. So, we currently have 75 roadside unit sites and 1,750 vehicles deployed in the environment. All of those are DSRC. The environment does include four pedestrian sites, so along Plymouth Road we have midblock crosswalks. We have a vision system and a phone app that we're testing to see how effective that is. So, when there's a pedestrian in the crosswalk either the vision system or if they have a phone app will communicate with the roadside unit and they will generate a message that vehicles in the vicinity that are equipped can hear, and then that on board unit will determine if they need to warn the driver about the pedestrian in the crosswalk.

Jeff Cranson: And maybe just stop the vehicle without even warning the driver.

Debra Bezzina: That is the next step, so ours is a warning only system at the moment, but, yeah, there's nothing there's nothing stopping OEMs from doing that next step of taking control of the vehicle.

Jeff Cranson: Yeah.

Debra Bezzina: You know, as we know, too, pedestrian fatalities are on the rise.

Jeff Cranson: Yes.

Debra Bezzina: Across the country and so this was very important work to be done—

Jeff Cranson: Yeah, do you have a theory on why that is? I mean, is it because, you know, more urban living, more people are walking, or is it, you know, distracted walking just like distracted driving? I mean, is it all those things?

Debra Bezzina: I think it's actually both of those, but I don't have any data to back up my opinions.

Jeff Cranson: Yeah.

Debra Bezzina: So, right now, it's just an opinion, but I think a lot of it is people are trying to do healthy living and walking more when they can and then the distraction factor.

Jeff Cranson: Yeah, I know the folks—

Debra Bezzina: And then phones—

Jeff Cranson: Right, exactly and the folks at MDOT—

Debra Bezzina: And the people in the cars. Yeah, so, a lot more pedestrian traffic and then more distraction.

Jeff Cranson: Yeah, that's it's very concerning. Yeah, our folks that study those things are very concerned, too, about what's going on with pedestrians and cyclists because there's more cyclists on the road and, you know, obviously they're not protected so—

Debra Bezzina: Yeah, typically I just say vulnerable road users.

Jeff Cranson: Yeah.

Debra Bezzina: Just in general, and the system does detect both.

Jeff Cranson: Yeah, that's great. Well, thank you, Debra, for taking time to do this. Your thoughts are very helpful.

Debra Bezzina: My pleasure.

Jeff Cranson: Alright, so, once again we're still talking about the FCC ruling Wednesday that decided to give up about half of the lower portion of the spectrum, and now I’ve got Collin Castle who is the ITS program manager at MDOT. He has been following this issue very closely. Collin, talk, I guess, high level first about what this means to MDOT and other DOTs.

Collin Castle: Yeah, thanks, Jeff. So, the ruling in the first report and order kind of has three components, so the first part of it takes of the 75 megahertz, 45 megahertz of that spectrum on the lower end and allows for unlicensed wireless uses, so you can think of that as, you know, any wireless device that you would, you know, stream videos or, you know, stream music, for example, so non-transportation safety purposes. The second part of this is it takes the upper 30 megahertz of that spectrum and allows for a new technology to be applied, which is called cellular VDX. It's foundationally a different technology than what's currently used in the spectrum, so currently there's a technology called dedicated short-range communications which is Wi-Fi based. This new technology is cellular based, so they're incompatible by design. Then, the third piece of this is there's a transition period that would occur, so all of the current license devices that are DSRC based they have to transition into that upper 30 megahertz within a year. Then there's a longer kind of implementation period where those technologies have to completely vacate the spectrum and then cellular VDX technologies can use that 30 megahertz.

Jeff Cranson: So, to make this really basic, why is there only a finite amount of bandwidth?

Collin Castle: Yeah, so, a number of years ago the FCC allocated a specific amount of bandwidth, 75 megahertz specifically, for transportation safety purposes, and, you know, the spectrum is very crowded, obviously, with a number of interests related to, you know, growing the wireless economy, a number of things. So, that spectrum was allocated. It's been sitting there for a number of years and it's been being used by the transportation industry specifically around research and development and development of safety applications. So, it's a very finite resource that we had for a number of years and now a portion of it is being given away to other purposes.

Jeff Cranson: What limits it though, I guess is what I’m wondering from, you know, the electromagnetic standard?

Collin Castle: Well, yeah, I mean, think of it as almost like bandwidth is like a pipe, okay? So, there's only so much water that can flow through a pipe and it's a similar situation when it comes to these bandwidths. There's only so much data that can be pushed through that bandwidth or that pipe. Does that make sense?

Jeff Cranson: Yep, I think that's a good way to explain it. That's a good metaphor. So, I guess, you know, we know that the most severe critics, ITS America and others, say that this is strictly a business decision. This is all about, you know, where the money is and that there's money to be made in in more Wi-Fi, more devices, more of those kinds of uses versus vehicles, but we're talking about safety. I mean, they're framing it very much as, you know, people's safety versus the business interests. I think the proponents of this would also say that there is another component of that. If we talk about, you know, increased broadband in rural areas and just giving more people access to the internet. I mean, is that a fair argument?

Collin Castle: Yeah, I would say that obviously the need to, you know, grow the wireless economy and give you know folks access to, you know, broadband are all important topics. However, there's a lot of spectrum that's available for those use cases. I think the biggest thing that's frustrating is that, you know, 75 megahertz is not a lot of spectrum. There really over the last several years had been a number of, you know, efforts underway to take advantage of that spectrum. I know all 50 state DOTs supported keeping all 75 megahertz for transportation safety. So, while I understand, you know, those uses and I think they're relevant, I think that transportation safety and the use of the that entire spectrum should be the number one priority, particularly knowing that it's a technology that we know can save lives today, so, yeah.

Jeff Cranson: Well, that's the thing. I think it's made, you know, believers out of you and me. You're in the trenches on this and I’ve been watching this now for a few years from a different perspective, high-level. I’m totally convinced that the more we research we're doing, the more we develop AI for driverless vehicles, that the fewer crashes there's going to be, and the fewer people are going to die. If we're going to accept 35 to 40,000 people a year dying on the highways when we would never accept that if they were plane crashes, I mean, it really seems absurd. I think someday our children and children's children are going to look back on the era of the automobile and wonder what the heck we were thinking. So, if you look at it that way that this is all about safety, where do you think this is eventually going? I mean, this is a setback, but do you think this really kind of derails or stalls the progress that we've made with V2V?

Collin Castle: You know, it definitely puts a moment of pause for folks, so, for example, from an MDOT perspective we have hundreds of roadside units out there that are DSRC based, so we now have to kind of take a step back and look at, you know, what is our approach going to be strategically to potentially either retrofit or replace the existing infrastructure knowing that we have limited resources. Then, you know, the future conversation around planned infrastructure knowing that we're limited to only, you know, 30 megahertz of the spectrum, which a lot of folks believe is not enough to really accomplish all of the safety use cases that folks have identified. There's also a lot of potential for interference within that band, so a number of folks are saying that they believe that that 30 megahertz may be much less usable than what is being described by the FCC. So, I think it's going to be a really interesting time for MDOT to decide how they want to proceed forward on utilizing these technologies.

Jeff Cranson: So, break that down a little more, I guess. In practical terms, what does the FCC decision block us from doing at MDOT?

Collin Castle: So, what it does is it, you know, currently we're operating these roadside units, all seven channels, a number of different types of safety applications. For example, at signalized intersections we're broadcasting signal phase and timing information in a map and vehicles can take advantage of that for, you know, red light violation warning applications, for example. So, what they're doing is they're saying, okay, now you have to not use those channels. You have to move all of your operations into the upper portion which now squeezes the amount of available bandwidth. You also introduce potential interference from these unlicensed devices. Then, it says, well, okay, now that you've transitioned into a smaller, you know, piece of spectrum, now you have to completely transition to a brand new technology. So, what it does is it severely impacts our current operations and then it changes our decision making into the future because we don't necessarily know how usable that spectrum is.

Jeff Cranson: So, that's a very real example. You talk about how those signals would communicate with a vehicle. Basically, you're saying that it could tell the vehicle that the light is red, and you better stop.

Collin Castle: Correct, and that's one of the day one use cases when we've been working with, you know, the automotive industry, the OEMs, and suppliers. That's one of the first kind of cooperative applications that we've really worked to try and standardize across, you know, really the entire U.S., and yeah, so it will be impacted.

Jeff Cranson: Yeah, so, when people—I mean, I’m sure you've had these conversations and these thoughts when people say they're still skeptical of the automated driving technology and you see, you know, a commercial for one of the automakers that has auto braking now, and somebody's dropping off their child at school and they're distracted and suddenly their car stops on its own because they would have run into somebody or something. I mean, that's got to make a believer out of you, doesn't it?

Collin Castle: Yeah, I think, you know, folks almost don't even realize that it's happening. Similar to when you think about adaptive cruise control and that was something that folks were kind of a little bit frightened of it first, but now you think about adaptive cruise control and lane keeping together. So, we're kind of seeing increased automation over time to the point where I think eventually folks are just going to get into a vehicle and, you know, it's going to drive itself and they were part of that whole transition all along.

Jeff Cranson: Yeah, I think that's exactly right. It's just going to happen gradually. You like each of these, you know, taken apart but then you realize that put all together it makes your car much safer, and being able to communicate with what you call V2X, communicate with all of the infrastructure, is going to be important, too. So, I guess the bottom line what you're telling us is that this will probably end up taking more resources, costing more money, requiring more research, and just it will take more time to get where we need to be .

Collin Castle: That is 100 percent correct.

Jeff Cranson: Yeah, so, when does this take effect? Is this like immediate?

Collin Castle: Yeah, so, the way it works is the ruling is allowing for immediate use of these unlicensed devices in an indoor setting in the 45 megahertz, and then users of the spectrum, the incumbent licensees who are using DSRC, have a year to transition into that upper 30 megahertz. Then there's still some discussion around and future comment around the transition completely out of the spectrum to all V2X operations. So, yeah, we have to start planning and deciding how we're going to, you know, repurpose our devices today.

Jeff Cranson: So, as if your job wasn't challenging enough.

Collin Castle: Yeah, I mean, it's, you know, all in a day's work.

Jeff Cranson: Well, thanks, Collin. I think we'll be talking about this more as this evolves and progresses, and we'll see how it goes, but thanks for taking time to help explain it.

Collin Castle: Alright, no problem. Thanks, Jeff.

Narrator: That's a wrap for this edition of Talking Michigan Transportation. Check out show notes and more by subscribing on Apple podcast.

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