The U.S. Department of Transportation issued a proposed rule this week which may ultimately require the installation of a communications box in every car manufactured or sold as new in the U.S. The U.S. is alone in the world in pursuing such a mandate and the proposal, which requires years of additional evaluation, testing and definition before adoption, is based on 12-year-old technology that is rapidly being superseded by emerging cellular wireless and sensor-based systems.
http://tinyurl.com/h46kl6t – Notice of Proposed Rule Making – NHTSA
Coming at the end of the Obama Administration, the Notice of Proposed Rule Making, which is the official designation of the announcement, is something of a Hail Mary (i.e. last minute or desperate attempt) to find a solution to the rising toll of highway fatalities now approaching 100 lives lost every day. The announcement also reflects the reality that the U.S. DOT and the National Highway Traffic Safety Administration have no other solutions or policy plans in development to stem the tide of death – with the possible exception of the suggested expansion of the use of ignition interlocks for impaired drivers.
The proposed vehicle-to-vehicle technology is based on dedicated short range communication technology (DSRC) which is a form of Wi-Fi and provides for inter-vehicle communications between appropriately equipped vehicles. The concept is compelling and exciting, but the messaging regarding its efficacy and effectiveness is misleading.
Let’s take a look at the statements of the leaders at the USDOT regarding this technology:
From Transportation Secretary Anthony Foxx we have this relatively reasonable statement of fact:
“We are carrying the ball as far as we can to realize the potential of transportation technology to save lives. This long promised V2V rule is the next step in that progression. Once deployed, V2V will provide 360-degree situational awareness on the road and will help us enhance vehicle safety.”
The exaggeration begins with NHTSA Administrator Mark Rosekind:
“Advanced vehicle technologies may well prove to be the silver bullet in saving lives on our roadways. V2V and automated vehicle technologies each hold great potential to make our roads safer, and when combined, their potential is untold.”
Rosekind’s somewhat breathless enthusiasm overlooks the disconnect between the agency’s claimed capacity for V2V to help eliminate or reduce the severity of up to 80% of all crashes (once the technology reaches near full deployment) and the anticipated saving of lives – estimated to be between 955 and 1,321 in the 30th year of deployment or 2051. With an estimated annual cost of deployment of between $2.2B and $5B (based on NHTSA’s own estimates) that is $2.2M per life saved excluding the billions of dollars to be spent on infrastructure.
The agency emphasizes the fact that the V2V mandate is nothing more than an automated vehicle beacon combining GPS and Wi-Fi information to broadcast vehicle location data (location, heading, speed) at 10x/sec. The mandate does not require reception of the vehicle signals nor does it require in-vehicle displays or interfaces and it does not require implementation of the applications that might actually prevent crashes.
V2V informational videos on the NHTSA Website, point out that drivers must remain in control and that the beacon signals are nothing more than warnings which may be conveyed to the driver via tones, displays or seat vibrations – none of which are specified or required by the mandate – nor are they included in the projected cost per vehicle estimated at more than $300 at launch. The NHTSA announcement also glosses over the fact that the mandate is not expected to be finalized until 2019 with initial deployment commencing in 2021.
The significance of the 2019/2021 timeframe is the fact that by that time the first 5G cellular networks will have begun being installed around the world using some of the same wireless spectrum as DSRC and offering the same or superior communication capabilities. The importance of that reality is borne out by the informational videos on the NHTSA.gov Website.
The videos describe four applications: do not pass (DNP), intersection movement assist (IMA), emergency electronic brake light, and blind spot warning. (The videos also show cross-traffic alert technology already available in existing advanced driver assistance systems.) All of these applications can be fulfilled today with sensor-based technologies or, in the near future, with cellular LTE-V2V or 5G technology.
The key difference between DSRC and cellular-based technologies is the fact that car companies are already building cellular connections into cars. And those cellular connections have commercially motivated and business model justifying applications.
The USDOT is essentially proposing that an entirely new wireless network be built from scratch without any commercial purposes other than safety, though the agency is quick to note in its press release:
Separately, the Department’s Federal Highway Administration plans to soon issue guidance for Vehicle-to-Infrastructure (V2I) communications, which will help transportation planners integrate the technologies to allow vehicles to “talk” to roadway infrastructure such as traffic lights, stop signs and work zones to improve mobility, reduce congestion and improve safety.
Here, too, cellular communications are already being employed to communicate traffic light information to cars – as shown recently by Audi and introduced two years ago by BMW. BMW, Daimler and Volvo are already deploying inter-vehicle road hazard communications using cellular.
Again, the key differentiator is that the cellular infrastructure is already in place, the investments have already been made. At a time when the U.S. is wrestling with crumbling bridges and tunnels, there is precious little money left to stand-up a new wireless network to potentially enhance driving safety in the interest of saving 1,000 lives out of 35,000 annually. Bigger life-saving gains can be made sooner with existing technology.
In the Notice of Proposed Rule Making the agency notes that it considered two regulatory alternatives:
- An “if-equipped” standard with performance requirements. The agency says it felt that “anything short of a mandate for universal V2V capability on all new vehicles would not lead a sufficient fraction of the vehicle fleet to be equipped with V2V to enable full realization of the technology’s potential safety benefits.”
- Requiring that V2V-capable vehicles also be equipped with the two safety applications analyzed in this proposed rule – Intersection Movement Assist (IMA) and Left Turn Assist (LTA) – in addition to V2V capability. But the agency felt these two applications were not ready for deployment
What is obviously missing from the USDOT’s deliberations is the potential for cellular technology to be used as an alternative to DSRC. The determined myopia of the USDOT after more than 12 years of work on DSRC is stunning and suggests that the time is indeed ripe for new leadership.
Yet unresolved is the definition and creation of the Secure Credential Management System (SCMS) required to support the inter-vehicle and vehicle-to-infrastructure communications. In the words of one anonymous V2V skeptic: “Someone needs to ante up the funds to build and operate the SCMS and while the (USDOT) guidance addressed the needs and some technical issues, there are still some significant unknowns regarding the SCMS (who operates, how they operate, governance, funding, etc.) and it’s a big complex system so it won’t be easy to build. And nothing works without the SCMS.”
The USDOT and its supporters have also suggested that V2V will be an essential element of automated driving. But in none of the official USDOT materials is there any suggestion that V2V technology is intended to enable self-driving cars. The USDOT is quite clear on this point: the driver remains in control. V2V is intended solely to provide driver alerts.
Finally, General Motors is still the only car company with announced plans to deploy V2V technology in 2017 which will be in advance of a completed standard or mandate. No other car company has followed GM, suggesting lingering skepticism throughout the OEM community in spite of the official stated support of the Alliance of Automobile Manufacturers.
V2V is not the answer to the car-inflicted carnage on U.S. highways. No other government anywhere else in the world has come to the conclusion that V2V is the solution. V2V a clever protocol that is most likely to see adoption within the existing cellular network. But the Notice of Proposed Rule Making ensures ongoing funding ($700M-$800M already spent by the government alone) and Federal support into the incoming Trump Administration. It is highly unlikely that Trump will pump the brakes on DSRC. See you at the inauguration.
Roger C. Lanctot is Associate Director in the Global Automotive Practice at Strategy Analytics. More details about Strategy Analytics can be found here: https://www.strategyanalytics.com/access-services/automotive#.VuGdXfkrKUk