big one here that likely resulted in negation if nhtsa decided to move forward with the mpr f. they left a large pool where the regulatory management system was. we were going to clip the basic safety message between the costs and we would have to have a way to replenish the city theory -- security certificate

over time. nhtsa we will figure this out between now and the final rule but we won't give you anything to evaluate so lawyers can't look at this, engineers couldn't look at this to see what may be going wrong so to avoid litigation this would have derailed their proposed rollout and likely would need to issue a supplemental notice of proposed rulemaking and opened up another comment. go to evaluate the cybersecurity text submitted from the proposal. another problem, nhtsa noted that it doesn't have the authority to mandate that users accept critical updates or replenishment of a security certificate. what that would mean is if a user refuses critical updates

the device becomes inoperative, no longer receiving or broadcasting. they said they could've tried to mitigate that with not including an off switch but also installing a light or a chime that would provide users, annoy users into accepting wireless updates but another problem, they can't mandate that users accept the updates the privacy conscience, or the apathy rating, given we have 10% of cars on the road today that display a check engine telltale, mostly people who just don't care, they have taken the meaning of that telltale not to mean much in terms of safety or operation of

the vehicle but if you have privacy conscious people actively hostile to this and forced connectivity all they would have to do is refuse updates and the device on their vehicle becomes inoperative. the problem is easily solved in. and then finally the deficiencies, what michael was saying, the trump administration has staked out at the regulatory approach. executive order 13771 requires cost neutrality and given the regulatory impact analysis published along with this proposed rule estimated a $5 billion annual cost in $108 billion cost by 2060, that would give the trump dot a lot less maneuverability in

pursuing other goals at this gigantic new cost, would have been by far the most costly auto safety regulation in a number of years. part of it is practical because if they were to continue pursuing this they would have an issue in pursuing the things that are there priorities as well so limits their flexibility and i hope to touch on this more, automated vehicle developers, the google self driving car project, they all weighed in and were strongly negative of this proposal. from the perspective of an automated vehicle when they were looking at this this is only hazard warnings. they don't alert the driver of an imminent hazard.

it will not actively intervene to stop a crash like automatic emergency braking would. so the best alternative would be they have to install this useless device that may display some annoying telltales riders in their vehicles can't respond to. if you are in a self driving vehicle and receive this alert you might realize a car is about to hit you but you can't do anything about it so you are terrified going into a crash but the worst-case scenario, they repeatedly weighed in on this in the comments. go, was if they didn't resolve the cybersecurity issue what happens if there's a link between the device and the technology, automated technology that corrected core vehicle functions, what if there's a malicious attack on that? without any additional information from the federal

government. all they were doing was increasing the number of attack vectors and there is no point increasing the attack surface if you are trying to promote safety, when cutting against another technology. and finally i would say a top-down ds rc mandate would convert resources automakers are currently spending on automation technology which would save more lives than the best case scenario under the hazard warning shifting into this so i like to think of ds rc as the mini cell of vehicle technologies. it sounded great. they may have had a case back in 2005 mandating this but the time is long past with 5g, far

more promising connected vehicle technologies. >> i just want to mention i love returning to this idea of consumers having to update the system and i just imagine some government entity forcing people to update their iphones. the country would collapse. the check engine light, do we all ignore those? let's hear from you. >> thanks to new america for having me today. i think it is because everyone involved in this debate is a customer or a partner and we are trying to figure out what is going to happen.

this is one of the oddest issues i have worked on in my 35 year career in public policy. two decades ago the department of transportation had the bright idea that you could take radio technology and introduce them in the transportation sector to generate sufficiency's, make us more safe and renders some environmental benefits to boot. and today what the transportation department has done is by any measure somewhat complete but not complete. with every passing year the views about what should happen to the idea of using radio to make a saver has become increasingly different and i count five mutually exclusive views, some of which you have heard today. the first, ds rc is and should

remain the transportation technology of choice. some auto manufacturers, but public transportation itself, national highway transportation safety administration, the highway department have added their voice to the chorus that said nhtsa has not mandated the use of vehicle to vehicle technology yet if you look at their website it remains a key part of the department of transportation strategic plan and more infrastructure deployments are happening at the state level funded by technology. equipment is being introduced by vendors and just last week there was a new study group to look at the standard. it doesn't feel dead to me. second position, cellular vehicles, everything should be the designated technology of choice. the technology challenger uses

exactly the same spectrum but is not interoperable with it as we heard earlier. by definition this is a winner take all proposal. it was created by the global cellular industry in response to china's decision to move to a cellular based system to do that. we are still in the united states in the very early days. it has not been tested anywhere near the level of ds rc, it may be a great technology. it might be a better technology but the point that needs to be developed along with some explanations of what the business model might look like because that may have different implications for auto manufacturers, the state highway department and consumers. third position, too much

spectrum to it in favor of repurposing the spectrum for more wi-fi. and that has not been used. that has been sitting fallow today. some are urging nhtsa not to mandate any radio technology because they say autonomous technologies are good enough. my own view based on the engineering studies i have seen is whatever radio technology you are talking about, both of them see beyond autonomous technology giving the car more information to help keep passengers in the vehicle safe and the auto manufacturers can contemplate whatever system that is that comes into use that would be integrated into the autonomous system. lastly, others argue leave the

radio solution to the market. what is less clear is how would the market solve real network affect problems, namely we all have to be on the same interoperable radio technology to see the benefits. splintering is never good. ideally you want to bring parties together. i see this debate going in the opposite direction and i hope we can discuss more about the implications of all this. >> let's hear from you. >> in keeping with michael's theme of change i want to talk about changes in the marketplace and something that happened changed, when the fcc opened the proceeding.

in the automotive marketplace i want to talk about changes in spectrum requirements, the need for more wi-fi spectrum in the last five years, the need is becoming more acute, we are seeing fast-paced growth and consumer demand for wi-fi to enable next-generation wi-fi speeds. there have been a couple important studies using different methodologies, consumers need over a gigahertz of unlikely spectrum in the next few years and that supports growing demand for technologies like wi-fi, we may need more than that to enable new unlicensed technologies. i have 9 ghz remaining, the best near-term option for unlicensed spectrum suitable for wi-fi, it is immediately adjacent to the most important wi-fi band in the world and manufacturers will experience important economies of scale

and bring more broadband to the market and despite the promise that it is just around the corner, these incumbent services remain in the pilot phase and may never see control by commercial deployment. there is no spectrum that is so underutilized. today broadband providers are delivering broadband to homes and businesses but without access to 5.9 we think it is a bottleneck, 160 mhz to consumers which is how many of us experience the internet. we think 5.9 is a critical band for wi-fi there has been a lot of change in the last few years, there has been a shift as others have mentioned. this is shifting to more cellular technologies.

that means the arguments about costs that might need to be maintained are now suspect. we have heard from a couple folks suggesting the 5.9 ghz band could be used for other applications but this is a new technology that may not need to be the case and that there is a path forward to 5g and it is appropriate to think of the 5g bucket to think about spectrum allocation. that doesn't mean less spectrum but we should take a fresh look, step back, think about the spectrum needs, the shifting landscape in automotive technologies. what is the right spectrum for these different options. i see a better choice for

safety applications. and i want to talk about changes in the spectrum environment, and automate of technology band 20 years ago. in that time you need 3 bands for wi-fi, widespread deployment for devices in the united states. and the upper adjacent band, right now adjacent to the high-powered fixed link there are satellite communication systems and they opened the proceeding to look at authorizing 6 ghz spectrum. michael mentioned it may not be appropriate to have a good engineering choice to have an automotive safety band. it may be time to take a step back and take a fresh look. and issue a further notice of

proposed rulemaking for unlicensed use and comment on what the spectrum needs are for the automotive applications since 1999 in the last 5 years and examine whether there might be more suitable spectrums for that technology. >> i will go to you next. >> i did want to comment on the statements that i made. i want to highlight what michael was saying. there are a lot of technologies that haven't entered the market since the conversation started. cameras in particular did not exist on cars and safety tools and radar in the early stages in most cases. as an industry i can tell you we have gone from one lidar

provider to 50 lidar providers and we will talk about scalability and delivery of technology to enhance driving safety without any wireless connection on the car. what we haven't talked about on the panel is autonomous driving, enabling the autonomous experience and it is likely to play a major role, you may have seen in newspapers today the need for remote control of the vehicle. we have seen hackers do that but now not only an sae standard defined for yet another level of autonomy but a requirement that if something goes wrong you want a fallback of some kind but the wireless

connection provides precisely the bandwidth you would need to do that. i'm as skeptical as anybody about the scalability of the remote control of large numbers of vehicles, it may well be a required standard. autonomous driving law provides that there must be a driver but the driver doesn't have to be in the car. draw your own conclusions. i would be the first person to say the autonomous vehicles on the road today do not have a wireless connection and are perfectly safe but the future, we are going to want to have all the technology at our disposal that we possibly can

have, a different approach to autonomous driving and wireless technology will play the critical role and will likely be cellular. at the 2018 conference, satellite wants to play a role in this game as well. the points were covered very nicely with little overlap by the other speakers. >> it is important to talk about the role of autonomous vehicles. i wonder if we will keep using the phrase behind the wheel to refer to someone controlling something after we are no longer behind the wheel literally the of our cars but moving on it is clear this debate in some ways is quite old, that some idea of intelligent transportation has been in the works for decades

but it is very new with things like self driving cars. i want to shift gears, pun partly intended and ask, should there be a band-aid at all? >> we haven't focused, we are not claiming to be safety experts to weigh in on that. some of the considerations i mentioned at the beginning are very important, given the cost and given how long it would take to become effective the administration really needs to look at how much of a difference it would make. we mentioned the trajectory of

driver assist safety technology, the radars, lazar and lidar cameras are only improving and makes each car savoring the whole driving environment safer for everyone. a big problem that nhtsa was frank about in its notice of rulemaking is it will take at least a few years, even if they adopted it tomorrow it will be a few years before they start doing it and it will take 15 years even though -- to know if it is effective because you have a turnover in the vehicle fleet that takes 15 years and it seems we are changing the nature of driving so radically over the same time. go, these

things are so interactive as somebody mentioned, it probably is better to leave it to the market within certain bounds. from a mandate perspective, even if we were going to go forward it will probably between 8 years before anything took affect. if you look at the backup camera man, that is eight years and there's an amazing amount of lightning research that has to be done on top of the research that has gone before to determine exactly how it would be implemented and all sorts of comment. copes and phase ins. what we saw in the obama administration was a shift to a voluntary system. i would say we should mandate

automatic emergency braking at low speed, if we pursue a mandated approach is ten years before saving lights number one. they are taking a voluntary approach, if you are going to put this on the cars by a certain date, there seems to be something about the regulatory process where there is a flaw, i could be mistaken, in commercial vehicle industries, nhtsa has more authority to implement mandates more rapidly and we might be having a different conversation today if the approach is not been the commercial segment. and today we would have commercial vehicles with the src technology and in the car the advantage of protecting

large vehicles around you and immediately have a valuable proposition. there is something fundamentally flawed in the process to get to a life-saving proposition. >> i went to point out the notion about the amount of time to roll radio based technologies into the fleets, all the cars we brought. and for about ten years, for any new technology to be deployed, the autonomous radio based. to me the question is radio based capability for safety, the increment of safety you are

going to get off of that from semi autonomous technologies in new cars today, is that worth the cost? what we saw in the notice of proposed rulemaking by 2016 and they were concluding yes. i will be the first to say technology moves fast and before we go to a final rule we would have to use that analysis to find out regardless of this radio technology, the benefit cost. >> 1200 lives would be saved. >> 1400 -- >> assuming connection for

vehicle controls. >> just assuming -- >> the auto manufacturers would integrate the data into semi autonomous technology. >> regardless, if you assume radio technology - >> the automated safety technology on the radio, you can start providing safety benefits immediately once the automated technology is deployed. doesn't matter what other cars are equipped with. in the case of the vita v mandate from nhtsa it is a breakeven point after the phase in. a decade after the mandate started. many argue that was overly optimistic. the lower levels of automation

technology breaking, incredibly promising right now as we see this being deployed, we can save as many lives as overly optimistic, the the src in a couple years. the benefits under nhtsa's vision. i don't disagree, cooperative automated vehicles, that isn't what nhtsa is talking about right now and if we look at all the discussions, and with

hazard warnings. even though we have this rulemaking designated as long-term action. maybe not as clear as regulatory shift but the 2018, 2022 report that got all references to e src compared to the 2014-18 strategic plan and we have seen guidance pool back, and infrastructure. i don't think the administration has finished its work on this topic but there are additions to the designation of rulemaking status, we have seen other indications from the department publicly that they are moving

in a different direction. >> anybody else want to weigh in? >> the regulatory overhang perspective, the proposed mandate relegated to the back burner. it is problematic for everyone involved, the automotive sector where it is headed with technology, problematic from a political perspective to move forward and get to a place where regardless what the decision is we get more efficient use for too long. >> what we are looking at which i alluded to in my opening comments which is for the first time we are talking about using cellular for an active safety function in the vehicle which is quite radical, the cellular

industry by the automaker, automatic crash, vehicle diagnostics, a whole different group of guys who take a dim view of the wireless industry and i am curious how the rest of the panels think about that fundamental shift. >> a great question. do you have any thoughts? >> we are lacking a couple things, we are lacking an administrator who can clearly articulate which way the wind is blowing. we don't have one. we don't have anybody who decides an acting person to pursue the agenda but on this question there has been complete lack of clarity around

the business model of a cellular veto system. who would run it, do the carriers want to accept the liability of being the providers of the vehicle system, would they prefer the auto manufacturers to take that liability, what would the business relationship be from the perspective of how is the band used, to what end is the greater throughput going to be used for data. what are the business relationships there and i think we don't have clarity and i would be curious to know if anyone else has seen this. i haven't seen any clarity out of the carriers. they are interested in exploring the technology to see what the technology can do which is good but i haven't seen how the business model

actually works. one thing i will say, there is a clear business model involving the consumer paying nothing once you buy the car. that you don't pay anything anymore. >> you make a great point about the liability. once the network has every part of the consumer's life on it, who is liable when that device doesn't work or something like that happens. >> in my opening, the fcc commissioners over the past couple years, they have been emphasizing a distinction

between vita v as real-time safety, what you need for safety, very low latency, available to everyone or it is not going to work that is completely dependent on the network effect on every car having this, every car talking the same language. a big distinction between that and all the other applications, using alternative radios on the same chip. what i have been hearing recently from mobile carriers is an acknowledgment of that distinction. the government is going to have

to say that every car for safety purposes even if it is not just a mandate. if you are going to have a safety signaling it must have the same interface, it must be interoperable, that has to be appear go of communication, not the way it works on your smart phone. it is not going to each of the different networks. this has to be safety, basic safety message has to be directly between the cars and that can be using the same 5g radio but something automakers just put in and it operates, nobody knows who is in charge yet whereas all the other

things you would do our things each individual carrier innovates around and impedes on and it will go fastest through their own networks so it in a sense it is two different things. >> how much spectrum is needed? >> needed and required. >> the notice of rulemaking is in the shelf. the requirement that all vehicle to vehicle signaling must be on a dedicated channel of 10 mhz so the band of 75 mhz they require the real-time safety signaling beyond 10 mhz and they have the notion to set

aside a second channel for first responders because it is at a higher power level and in europe they had a proceeding, they said 20 mhz but we have a third channel, there is a contingency because it might be useful to have cars communicating with stoplights. even though it is not always time critical it could be on this third channel so europe is going up to 30 mhz which is why one of the proposals when it looked like it was going to be mandated, one of the leading proposals, qualcomm had a separate proposal, 30 mhz at the top of the band so wi-fi

could share the rest and commercial applications could share wi-fi. the emergence of cellular throws in the wildcard, an aspect of can we still do it the same way? should we do it the same way? on the one hand starting from scratch, it would be easy to use the top of the band for safety but on the other hand it is not clear how well they can coexist with wi-fi or whether that even make sense but the mobile carriers have their own 5g networks. >> how much control will nhtsa have over the entire 75 and how they were divided up.

>> and the vehicle mandate. and and the federal communications commission and an important role to play, and safety technology when it comes to spectrum decisions and other things congress has committed to. that is why it is time to step up and step forward with changes in the marketplace and think about what the spectrum needs are in this new environment.

>> the dsr see. it was dependent on an infrastructure channel so they can obtain a security certificate we heard about earlier and the control channel at the top of the band, channel they were going to use for their own purposes but in the dsr see proposal you can't isolate 10 mhz. they need something else to communicate with that radio. when the cellular came along they took that same model but put in cellular technology. they also need some way to communicate a radio on board the vehicle, whether that

absolutely needs to do that or communication link could be in another band is a valid question but that is how it was designed. it was designed as a cellular version. >> roger had a slide up from qualcomm earlier in the discussion in his presentation that highlighted - an automotive piece they were thinking about and operating over carriers existing licensing spectrum. given the unique nature developing now is the right time to think about that. >> using the same spectrum and the same protocol and value

proposition fundamentally. >> we had a white paper released this week that says the cellular vendor in the same spectrum. >> we mentioned wi-fi. i want to focus and talk about the spectrum policy discussion. >> take the first crack. and reiterate we are still seeing a great demand and growing demand for wi-fi technologies and increased consumer demand and peak hours, the need for additional wi-fi standard, in development for the next one and both of those

rely on wide 160 mhz channels and we have one for everybody. i should say it is not restricted by the collection rules. under the most favorable wi-fi rules but to get to the country's first contiguous 160 mhz wi-fi channel 5.9 is the place to do that. this is particularly important for wi-fi, the carriers are delivering. >> if wi-fi is going to keep

pace in a 5g world, more spectrum. we often talk about 5g as if it is just a mobile carrier technology and network but it will be even more diverse and decentralized than 4g wireless so currently we have 4g but i'm sure all of you on your smart phones are sending 80% roughly of your mobile data traffic, not touching the carrier spectrum or network at all but unlicensed spectrum via wi-fi.

everyone thinks they have far less data that went to the carrier. and in the wireline in a few hundred feet, 80% of the traffic, that makes your mobile broadband more available, faster indoors and more affordable. when 5g comes along the mobile carriers getting more spectrum, wider channels for faster networks and we will all enjoy that except that will be too expensive unless wi-fi can keep pace with that and the only place for wide channels is the 5 ghz band which is immediately

below and adjacent to what we are talking about but unfortunately the fcc though it proposes to make as much is 750 mhz available for wi-fi it found among other problems that the military said you can't share with a certain kind of radar and now we are running into this issue of 5.9 so that is the only place we know of in the 5 ghz band where you can get these wide channels so the entire 5g system is robust. >> i concur with what michael

said but i will also elaborate further, 5g is the first time the cellular industry is going to have a radio access network that is agnostic to technology. one of those technologies is wi-fi. anyone who thinks wi-fi is not part of 5g is a technical matter, it is not part of the system. and the demand michael raised. i personally, many of us in the wi-fi industry have become it is painful to watch the 59 activities not advancing as quickly as we would like because the spectrum is sitting there largely unused. there was a proposal several years ago when dsr see was the only force to share and now we

are not even sure if it will eventually end up prevailing but still sitting in the incumbent's chair but it is painful to watch and i think at least at cisco we are spending far more time opening up the spectrum at 6 ghz because we don't see a way to move along for any resolution whether it be the cellular vida blog or how much spectrum it would be, there doesn't seem to be a way to move forward. >> we are hopeful we can move forward, so underutilized. 6 ghz is interesting. we haven't cut a satellite link with the discussion code distance for another panel.

we are hopeful to find a way to share, why we are not saying 6 ghz is the best near-term option for wi-fi, the advancement kicking off last summer, i am not willing to give up on it yet. there may be technical rules or restrictions that may not be present. hopefully optimistic about this but 5.9 is the option. >> this is an awkward conversation to be taking place within nhtsa so i am taking an education on this issue. it becomes emotional,

political, religious and then it comes to we have spent $700 million on this technology. have come this far which takes it beyond the business model discussion and the real technical issues and implications that such everybody, not just hard drives. what everybody heard is the untold story. >> shed some light on the untold story. >> final thoughts quickly before -

>> i thought the conversation - >> what the conversation had, the substitute. >> television needs a microphone. >> my point was simply wouldn't it be helpful first to establish moving toward the objectives of dsr see, and then discuss bandwidth.

>> the main problem is what danielle referred to is this regulatory overhang at nhtsa that not only is presenting this regulatory uncertainty in the automotive industry over what technology is going to be used but also having negative impact on the wireless industry on equipment manufacturers. until they get their act together it is moving in a good direction but until it chooses the path and does so clearly, all the other stuff is going to be left unresolved. >> the resolution we had suggested, what to do about safety first. and what to do about spectrum

consequences. one of the issues is still early days. there was a recent announcement by qualcomm and other players did set up a testbed in california. i hope they share the data off that so people begin to see technology living up to the marketing hype we are hearing about for a month or a year, that would be helpful and it would be important for folks to tell us what they think this looks like. we don't have that information today and don't have clarity around those issues but that i

federal communications commission faces often because they are in a position needing to designate bandwidth and allocate bandwidth before technology takes off. it shouldn't take 20 years but for technology to take off it needs to have spectrum technology in place, the technology is on the table. >> i should add this is where it got stalled at the fcc. they have been waiting for the department of transportation to make a fundamental decision about what safety is needed. not so much a choice between dsr see and cellular veto x as the air interface technology,

it will use the same spectrum for the purpose of safety but is there going to be a mandate and what are they mandating? already in europe they decided 30 mhz it is as much as would ultimately be needed for the safety side of this and that i think would allow the fcc to have more confidence in the other spectrum that might on non-real-time safety. >> speaking of which, any more?

>> go ahead. >> i am unaffiliated. on the safety angle what do the insurance companies think of this? is a really big deal for him or it is not a big deal at all? >> lane the parts are warning, they may have recently come to the conclusion that that was the case. and very slowly they focus on history. and paying a fortune. and the underwriting on

historical data. >> don't think the insurance, you see the car manufacturers, or whatever year it was. they are trying to move in that direction, the auto industry itself, and that is in good faith, to illuminate fatalities as a whole. >> it is related, with automated technology. not only does it have far more dramatic implications for crash

numbers for hazard warnings, and weapons business models shifting more liability toward manufacturers if the end user is no longer directing the vehicle and traffic and where they talk about this they are concerned about cybersecurity related to automated technology as a hazard warning. >> one more quick one. >> we had a section that talked about privacy protections that could come into play that would not be in play for dsr see.

the mandate for privacy protection, why exactly is it that cellular technology would wind up being more privacy protected? >> the community has prided itself on privacy protection. the message that they had challenges to see if they could identify a car from anonymous data. i believe my sense of it as it would be equivalent except you would have more consumer control to opt in or opt out because it would be more wireless service based based on dismantled protocol announcing your location but again, my understanding of the ultimate rollout of dsr see would be

anonymous. that is my understanding, anyway. presumably you could argue it would be superior to cellular in the preservation of privacy. that can only be in the context of cellular, and opt in or opt out proposition. for the safety it would be the same protocol so it should be identical. that shouldn't show a difference. >> thank you for great conversation and thank you for participating. [applause] ♪ .. ..

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