 Good afternoon, everyone. Welcome to New America. We'll get started, but certainly feel free to go out for any additional sandwiches or drinks, as you please. My name is Michael Calabrese. I direct the Wireless Feature Project here at New America, which is part of our Open Technology Institute. And of course, we focus on our wireless feature, and particularly on encouraging more efficient use of the airwaves, more on licensed spectrum, Wi-Fi, and so on. And actually, as we approach a 5G world, all connecting everything else, including cars, is becoming increasingly relevant. So this event, talking cars, 5G and Wi-Fi, time to get more mileage from the car band, is very timely. I was just at Mobile World Congress, and there was an incredible focus on 5G, as well as on connected cars, how that will happen, and that means also how we will use the public airwaves for that purpose, as well as for all the other purposes we have. So as the invitation indicated, the Obama administration's proposal to mandate vehicle-to-vehicle communication system, a particular type of one in all new vehicles, which would go in effect over the next 15 to 20 years, is reportedly on life support at the far more deregulatory Trump Department of Transportation. The notice of rulemaking has been essentially put in a limbo status, and the conventional wisdom right now is that the new administration has no appetite for a $100 billion mandate for talking cars. And I hope, of course, that everyone watching will realize we're simply about the technological advance from talking horses to talking cars, but literally about a new type of auto safety, vehicle-to-vehicle safety signaling, vehicle-to-infrastructure, as well as a way to bring lots of new commercial services to cars. But part of that debate has also been between the, which you might call the high-tech sector broadly, and the auto industry that focuses on access to the increasingly valuable, but still vacant, spectrum that was set aside back in 1999 for intelligent transportation services. And just a couple of years after that, the FCC actually put in a channel plan and designated that dedicated short-range communication DSRC would be the technology to do to use in this band, and that's what the DOT was proposing to mandate. And although V2V safety signaling, DSRC, will use only a portion of this five gigahertz, this upper five gigahertz band, DOT's indecision has now stalled the Federal Communications Commission's proposal to pave the road for superfast Wi-Fi by allowing unlicensed devices to share the large but still unused ITS band. So today's event will really kind of touch on both ends of that. It's the new safety technology. What is the trajectory of new auto safety technology, particularly using communications? But then how much spectrum, how much of the airwaves does it need and is there room for Wi-Fi which is filling up the adjacent band and is necessary for more ubiquitous, affordable mobile device use that you all are so fond of? So with that, we're going to first have Roger Langtatt, who is Director of Automotive Connected Mobility at Strategy Analytics, is going to do a lead-off presentation to give us background on this, kind of where we are, because there's been some recent developments with cellular V2X, cellular vehicle to everything, as a potential substitute for DSRC that's a very important development that really potentially changes the debate. So Roger is going to give us an introductory presentation and then the rest of the panel will come up and Tara Jeffries, who is the tech and telecom reporter for Bloomberg Law, will guide us in a discussion about where we go from here. So, oh, and then after that interactive discussion, we'll open it to the audience. So please be thinking about, you know, what questions this all raises in your mind. And at the end, we'll have some time for audience, Q&A, certainly at that point tell us, you know, who you are, who you're with and make your question or comment, you know, we really invite audience participation. So with that, I will, and you have, you should have bios for everyone, so we're not going to spend a lot of time, you know, on long introductions, but again, Roger is Director of Automotive Connected Mobility at Strategy Analytics, a real expert in this field. Roger? Thank you very much, Michael. I was told I just had to hit this button and we'd be good to go. There we go. All right, I'll let the mystery cursor advance the slides, maybe. Should I keep trying here? Yeah, that's not working. Left button. So, I'm with, I'm the Director of Automotive Connected Mobility at Strategy Analytics. Strategy Analytics, we look at the connected home, we look at the mobile and wireless market, and we look at the automotive industry, and we look at technology adoption and deployment in vehicles, and we advise our clients, the car makers, the wireless carriers, and the very broad ecosystems supplying the automotive industry, including semiconductor companies, content providers, etc. And this is a hot button issue our clients are asking about DSRC and CV2X on a daily basis. It's touching all of them and they're making very significant decisions right now, and it's kind of a situation that's up in the air. Michael gave a good characterization of the status of this discussion about vehicle-to-vehicle communications. So as I thought about what I would talk about in setting the stage for our conversation today, the first question is, why are we connecting cars? Okay, because I think the average person isn't necessarily insisting on or even looking for a car with a wireless connection. Some people today may even be looking for a car without a wireless connection. Okay, now if you're a car company, you want to have wireless connection in there today because you probably have tens of millions of lines of software code in there, if not more than 100 million lines of code, and that code is ripe with errors and vulnerabilities, and you want to be able to manage that data, manage that software, keep it up to date, as well as being able to detect if there are any sort of cybersecurity vulnerabilities or intrusions and have the ability to respond. And I probably don't have to tell anybody here that we have a huge vehicle recall problem in this country, and a growing proportion of those recalls are for software flaws in the car. And if the car companies can correct those flaws remotely with a software update along the lines of what Tesla is doing, then billions of dollars could be saved by the industry. So increasingly, the automakers are recognizing that this is in their favor, it's a requirement, they need to connect cars. Now, this is happening in the context of an automotive industry and a wireless industry that really don't get along very well, okay? I like to say wireless carriers don't understand car companies and car companies can't stand wireless carriers, okay? They really don't, it's not a kumbaya kind of experience between these two organizations. And so, because there's a lot of cost if you're going to put a connection in the car, a lot of liability and a lot of issues that are unclear value propositions to the consumer, especially in this age of the smartphone. So there was a time when GM could differentiate itself and sell cars with OnStar as a value proposition. If you get in a crash, we're going to call for help, it's going to come, don't worry, even if you're unconscious. Now I think most people think, I'm just going to use my phone. So that OnStar capability never became a requirement across all the other car companies. People, other competing car companies did not follow GM, only a handful did. At the time they actually licensed the technology and then they changed their mind and pulled the licenses back. Interestingly, in a month or two, Europe will implement an e-call mandate, which will require all new type-approved vehicles to have an OnStar-like function built in. So that's just new type-approved cars and it's OnStar for all cars basically in Europe. So we're going in different directions. But just to give you an idea, a large volume of cars are going out of dealer lots with a wireless connection. This is just the subscription so many of them are leaving lots without that device being provisioned and many of them are sort of inert on the road. We have a lot of zombie cars that have wireless connections that are not activated. The free period has expired and people have not renewed. So we really haven't sold this value proposition to the consumer quite yet, but it is becoming almost a standard. Why are we connecting cars to each other? So just as a wireless connection in the car, a regular cellular connection, isn't an obvious value proposition, why does my car have to talk to the other cars along the road? Why is that happening? And I think the analogy to an inter-vehicle communication would be ways. And that's just based on the smartphone. So most people, I think, would look at this vehicle-to-vehicle communication conversation and say, well, I've got ways. I'm already communicating with the other drivers. It's going to the server and coming back and the data is being aggregated and interpreted. It's a great help for my navigation. But what we're talking about today is collision avoidance. So that is a direct communication with cars to help them avoid running into one another. So cars notifying all-surrounding vehicles of their position in real-time, I think it's eight times a second. So what kind of progress have we made in the early 20 years of development, as Michael mentioned? Well, not a whole lot, all right? So GM, a couple of years ago, started putting B2V modules in their Cadillac CTS vehicles, which is probably their single lowest-volume vehicle. And the volume has continued to go down since they made that decision. But it was a way for GM to say, look, we want this spectrum, DOT, so don't take it away from us. We're actually putting it in our cars. Come to find out. I think GM was a little bit surprised that nobody followed their lead in this approach. Volkswagen, meanwhile, has been the next car maker to step up. I will say Toyota was before everybody in deploying in a large number of cars, millions of cars in Japan, but on a different spectrum and with a different value proposition. And a completely different marketplace. Volkswagen has said, beginning in 2019, their new cars will get B2V connections. This is only for Europe, though, okay? And it's important to understand the context here, which is Europe does not have a mandate, and the mandate's been fought off and beaten back by the industry, essentially both the automotive industry and the wireless industry. And interestingly, Volkswagen's biggest market is China, and China is not going to deploy DSRC. They're going to use CB2X, which you'll hear a lot about today. Oh, and please note the energizer bunny. So DSRC just won't go away. Okay, so no one here is going to tell you it's dead, even though I've been quoted saying that. It's not going away. Not dead yet, I guess you'd say. NDY on DSRC. So the news in this space is the voices coming from DGMove in Europe and USDOT in the US is technology neutrality. So we're not going to put our thumb on the scale anymore. The significance of that is that when we had the Smart City Challenge in the US, for example, all of the proposals required DSRC. If you were trying to get a Smart City grant, you had to include DSRC in your proposal. It looks like that's going to kind of go away. The USDOT is going to stop pushing DSRC. Some states have said, state level USDOTs have said they're going to continue to push it, but not all 50, maybe about 18. But it's not a unified front on DSRC at this time, and so the regulators and government is taking a step back and saying, maybe the quicker path to market is for us to get out of the way and let the market forces take over. This is a little technical. I'm not going to get into too much of the details here, but I did want to highlight a couple of things about CB2X, which many of you may be hearing about for the first time, although I hope not. CB2X is using the same spectrum and offering almost identical, if not superior capability. So you're having the same low latency, and it's also high bandwidth. In addition, it can operate without network assistance. I can't tell you how many senior industry engineer executives with far more advanced degrees than I'll ever see in my life telling me, well, the carriers will never allow direct communications without access to the network. You're going to have to communicate with the network, and there's going to be too much latency for this to be a safety relevant application. It's simply not true, and I don't know why the confusion persists, but I wanted to emphasize it with this audience to make sure we're all on the same page. This is direct vehicle-to-vehicle communication without the network on CB2X. And finally, again, they're using the same spectrum. And there's some other relevant issues here, and there's a little bit of Qualcomm's snark there in the lower left saying that there's no evolutionary path forward from DSRC, so this comparison was sourced from Qualcomm. So what are we seeing? How does this unfold in the market, and what does it mean to the average consumer? Well, hopefully it means we're going to save lives, because vehicles will be able to communicate with each other in the early days. Now, the problem, as you've probably surmised by now, is that if a Cadillac CTS has this technology and no other car has it, the only car the CTS can avoid colliding with is another Model Year 2018 Cadillac CTS. This is a problem, and Volkswagen's going to have the same problem. A Volkswagen so-equipped Model Year 2018 or Model Year 2019, I suppose, will only be able to avoid colliding with another Volkswagen Model Year 2019. So the value proposition really only works once all cars, or as some would say, a certain percentage of cars are so-equipped. There is a day one capability that would be relevant, though, and that is vehicle to infrastructure. So if you have traffic lights that are enabled with DSRC technology, they would be able to communicate with the Cadillac CTS, but that application would have to be developed, and the likelihood is that it would be a very small number of traffic lights because deploying CV to X for this application, instead of using existing cellular technology, is way more expensive. So if you're a local USDOT, you're not going to go with the more expensive route, but that would be a day one application. Ford has said 2019 they will do CV to X, which is significant because Ford was one of the early and hardcore developers and advocates of DSRC. So for them to say they're doing CV to X is a big deal, a very big deal, and others very likely are behind them, but they've come out in particular in the forefront and said, we're doing this. I was just at the Mobile World Congress and talking with Samsung and Qualcomm, who say awards have already taken place for car companies adopting 5G. Well, 5G doesn't even exist yet, right? How are they doing that? The significance of that information is that typically car companies have been three or four years behind each evolution of the wireless network. So when we were getting 3G, cars were getting 2G. We were getting 4G, cars were getting 3G until they discovered like GM when we went from analog to digital that when analog got turned off, all their cars got turned off and suddenly they had a class action lawsuit on their hands. So the automotive industry is now working hand in glove with the wireless industry on this implementation of this next generation and they want to have cars with the latest technology at day one, especially because that device will be in there for 15 years. You don't want to be saving pennies on an old network topology that's not going to be around in 15 years. So the evolutionary path though, so this is the Qualcomm snark, so they're saying CB2X will be forward compatible with 5G, release 16, whereas DSRC is only compatible with DSRC. And to clear up another, I haven't heard this confusion a lot, but there is a little bit of confusion about interoperability. There's no interoperability between these two technologies. So the industry has to make a choice. The automakers have to decide one or the other. They won't communicate with each other, but CB2X, if implemented now, will work on a 5G network in the future. And you'll have capability with this kind of technology for edge computing and much more sophisticated vehicle connectivity solutions around traffic and other value propositions that are taking advantage of the network as well as working where there is no network. So the key is, I just want to double down on this message, the PC5 interface that allows that direct communication between vehicles or between vehicles and infrastructure, which is not present in our current wireless network, but will be available in a network that's been evolved to CB2X and eventually 5G. And so we have many issues to talk about today, and I just put some of them here, but this is not a comprehensive list, so the outlook for the mandate in the US, functional equivalence between the two technologies, wider spectrum allocation implications, business model, cost, consumer acceptance. So these are the issues we'll be discussing today, and that's my table setting contribution. Michael? Great background. So we'll invite the panel to come up, and Tiara will take over. Let's be over there. Thank you all, panelists, for joining the conversation. I'm just going to briefly introduce each person and let them give their own introduction of what they're working on and where they are on this topic. We've got Michael Calabres, director of the Wireless Future Project here at New America's OTI. We have got Mark Kripner with the Competitive Enterprise Institute. He's a senior fellow. We've got Mary Brown with Cisco, senior director of government affairs. We've got Danielle Pinieres with NCTA, the Internet and Television Association. She's vice president and associate general counsel with them. And finally, we've got Roger, who has just generously given us a great backgrounder on the subject. So Michael, I'll start with you. Thanks, Tiara, for doing this, and as Roger said, it's looking increasingly unlikely that there will be a mandate for DSRC as the specific technology or really any mandate for vehicle-to-vehicle safety signaling. And particularly if there's no mandate, the FCC should use the opportunity to take an immediate fresh look at the highest and best use of this fairly large and now increasingly valuable band of spectrum, which lays empty. Because, and this should be fairly obvious, quite a bit has changed since 1999 when it was first allocated. And I'll mention a few of those first. This is a revolutionary new auto safety technology to avoid most serious accidents. It's just not radio communications technology. As automakers develop automated vehicles, they are already incorporating and rapidly improving sophisticated crash avoidance technologies that include radar, LiDAR, automatic braking, ultrasonic sensing, and onboard sensors such as drowsiness detection. NHTSA itself said V2V signaling won't be proven or effective for 15 to 20 years or longer, even if it's mandated, because it takes at least 15 years for the entire vehicle fleet in the United States to turn over. And by then we'll be living in a very different transportation world. Second, cars will be connected just not by DSRC. So even if DSRC was mandated for vehicle to vehicle signaling, soon all new cars will be connected to the general purpose, mobile networks, for all kinds of other purposes. That should make V2X safety more cost effective if it's simply part of the general purpose network rather than being a standalone proprietary DSRC network. But it also means the band can be reorganized to maximize the public interest, since this would be starting afresh. Third, whichever technology is used, there remains a critical distinction between real time safety of life applications, which are narrow band, which must be uniform and interoperable, and commercial or informational applications, such as getting an advertising flash, an ad flashed on your windshield when you stop at a red light near McDonald's or downloading maps or swapping videos with other cars. And we can use other spectrum for that purpose or share the commercial part of the band with Wi-Fi. When commissioners O'Reilly and Rosenwurzel spoke here on this topic two years ago, believe it or not, and nothing has really changed since then, Commissioner O'Reilly in particular emphasized that the non-critical safety use of this band should be shared with Wi-Fi. Fourth, cellular V2X is starting from scratch today. So they're just going to begin some validation testing this spring in Southern California. So now is the time to decide how it will use the public airwaves. There is likely spectrum with better propagation and closer to core mobile carrier bands that could be used. And at a minimum, there's no reason that V2V safety channels using 5G radios cannot operate at the top of the band and allow Wi-Fi, which is adjacent at the bottom of the band, to share the rest. Finally, the public interest must factor in the enormous and growing value of Wi-Fi. Wi-Fi bands are congested in busy places, and in a 5G world, consumers will need much wider channels of shared spectrum that appear available only in the 5G and 6GHz bands. Right now, the car band is a vacant desert island smacking the middle of what will be the core band needed to make Wi-Fi more available, fast, and affordable for consumers. So it really is time for a fresh look. Thanks, Tara, and thanks, Michael, and thanks to New America for hosting us here today. So I'm going to cover, I guess we could say two categories here. First are, I'm going to discuss some specific problems in the National Highway Traffic Safety Administration's V2V Notice of Proposed Rulemaking that was published about a week before President Trump took office and then has since been mothballed as a long-term action, as Michael and Roger have discussed. First, so NHTSA's two radio DSRC exclusive approach would have required, they estimated, nearly 20,000 roadside equipment units to be built out along the National Highway system. But as NHTSA quickly noted, they don't have funds to build out a network. They don't have authority to regulate and manage the network. So when they were talking about mandating this specific vehicle technology that would have required a brand-new nationwide network, they basically said, we'll figure this out later. And you'll see this is sort of a theme that NHTSA thought it could just figure this out later rather than actually presenting an actual proposal to the public to comment on. Big one here, and this is likely would have resulted in litigation if NHTSA had decided to continue forward with the MPRM, but they left a large glaring, bracketed hole where the regulatory text discussing the secure credential management system. So obviously we were going to encrypt the basic safety messages that would be transmitted between the cars. And also you would have to have a way to replenish security certificates over time. NHTSA just said, we'll figure this out sometime between now and the final rule, but we're not going to give you anything to evaluate. So lawyers can't look at this, and most importantly, engineers couldn't look at this to see what may be going wrong with their approach toward cybersecurity. So to avoid litigation, and this would have derailed their proposed rollout, they likely would have needed to issue a supplemental notice of proposed rulemaking and opened up another comment period so commenters could evaluate that cybersecurity text that was omitted from the proposal. Another problem, NHTSA also noted that it likely doesn't have the authority to mandate that users accept critical updates or the replenishment of the security certificates. So what that would mean is that if a user refuses critical updates, the V2V device just becomes an operative. It's no longer receiving or broadcasting. Now they said they could have tried to mitigate that this kind of thing with not including an off switch, but also installing a telltale, a light or a chime that would prod users, annoy users into accepting these wireless updates. But another problem, since they can't mandate that users accept these updates, the privacy conscious or even just the apathetic, I like to call this the apathy rate that was not considered in the NPRM, but given that we have about 10% of cars on the road today that display a check engine telltale, now, so that's mostly people who just don't care and they've taken the meaning of that telltale to not be worth very much in terms of their safety or the operation of their vehicle. But if you have privacy conscious people who may be hostile, actively hostile to this forced connectivity, all they would have to do is refuse updates and then the device on their vehicle becomes an operative. So the problem is easily solved, you just don't do anything. And then finally, on these sort of deficiencies and really sort of as what Michael was saying, the Trump administration, you know, has staked out a deregulatory approach. Executive order 13771, which is the two out one in order, also requires cost neutrality and given that the regulatory impact analysis that was published along with this proposed rule estimated a $5 billion annual cost and a $108 billion total cost by 2060, that would give the Trump DOT a lot less maneuverability in pursuing other goals if they were going to add this gigantic new cost, would have been by far the most costly auto safety regulation in a number of years. So I think part of it is practical because if they were to continue pursuing this, we would have, they would have an issue in pursuing the things that are their priorities as well. So it would limit their flexibility. And then quickly, and I hope to touch on this more, but automated vehicle developers and many of the leading ones, such as Waymo, formerly the Google self-driving car project, Tesla, Mercedes-Benz, BMW, all weighed in and were strongly negative of this v2v proposal. And I think from the perspective of an automated vehicle, when they were looking at this and remember, this is only hazard warnings. This is going to alert the driver of an imminent hazard. It's not going to actively intervene to stop a crash like automatic emergency braking would. So the best case scenario for automated vehicle developers, self-driving car developers, would be, well, they have to install this useless device that may display some annoying tell tales that riders in their vehicles can't respond to. So you might, you know, if you're in a full self-driving vehicle and you receive this alert, well, you might realize that a car is about to hit you, but you can't do anything about it. So you'll be terrified going into a crash. But the worst case scenario that they, and they repeatedly weighed in on this in the comment period, was, well, if they didn't resolve the cybersecurity issues, what happens if there is some sort of a link between the v2v device and the technology, the automated technology that is directing the core vehicle functions? What if we somehow have a malicious attack on that? Their point was that without any additional information from the federal government, all they were doing was increasing the number of attack vectors and there's really no point of increasing the attack surface if you're trying to promote safety when you're then also cutting against another, I think, far more promising safety technology. And then finally, I would say that a top-down DSRC mandate could divert resources that automakers are currently spending and these upstart developers are currently spending on automation technology, which could save far more lives than even the best-case scenario under a v2v DSRC hazard warning shifting into this. So I like to think of DSRC v2v, at least as envisioned by NHTSA, as sort of the mini-tel of connected vehicle technologies. This sounded really great, they may have had a case back in 2005 to mandate this, but I think the time has long passed and we're going to see with CVDX and then 5G, far more promising connected vehicle technologies. So with that, I'll let Mary go. Before I hear Mary's top-line thoughts, I just want to mention I'd love to return to this idea of consumers having to update the system and I just imagine some government entity forcing people to update their iPhones. I mean, the country would collapse, right? Nobody does those on time. So I'd like to return to that and just in the check engine light in people's cars, how often do we all, you know, ignore those? Probably too often. So I'd love to return to that. Mary, let's hear from you. I'm from New America for having me today. First, why is Cisco Systems here sitting in front of you? And I think it's because everyone involved in this debate is either 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 use these technologies and you could introduce them in the transportation sector to generate efficiencies, make us more safe and probably render 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 this idea of using radio to make us safer has become increasingly splintered and I now count five mutually exclusive views, some of which you've already heard today. The first, DSRC is and should remain the intelligent transportation technology of choice. Some auto manufacturers, the Department of Transportation itself, the National Highway Transportation Safety Administration appear to agree. More recently, State Highway departments have added their voice to this chorus that said NHTSA has not mandated the use of vehicle-to-vehicle technology, has not mandated DSRC. Yet, if you look on their website, it remains the significant rulemaking. It's a key part of the U.S. Department of Transportation ITS Strategic Plan and more infrastructure deployments are happening at the level funded by tax dollars. New equipment is being introduced by vendors and just last week the IEEE Standards Body stood up a new study group to refresh and update the standard. It doesn't feel dead to me. Second position, cellular vehicle to everything should be the designated technology of choice. This late-to-the-party technology challenger uses exactly the same spectrum as DSRC but is not interoperable with it, as we heard earlier. By definition, then, 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 this. We're still in the United States in very early days. It has not been tested anywhere near the level of DSRC and certainly has not been tested by government. It may well be a great technology. It may well be a better technology than DSRC, but that's a proof point that needs to be developed, along with some explanation of what the business model might look like because that may have very different implications for both auto manufacturers as well as state highway departments and, most importantly, for consumers. Third position, ITS has too much spectrum devoted to it to be reduced in favor of repurposing the spectrum for more Wi-Fi. It is certainly true that Wi-Fi needs more spectrum, and that spectrum has not been used and is just sitting there fallow today. Some parties are urging NHTSA not to mandate any radio technology for safety because they say autonomous technologies are good enough. My own view on that, based on the engineering studies I've seen, is that whatever radio technology that DSRC or cellular-based system, both of them see beyond autonomous technologies and would give the car more information to help keep the passengers in that vehicle safe. And I think the auto manufacturers would contemplate whatever system that is that ultimately comes into use that information would be integrated into the autonomous system, so it would become another data input. And lastly, others argue, leave the radio solution to the market. But what's less clear is how would the market resolve the very real network effects problem. Namely, we all have to be on the same or interoperable radio technology to obtain the benefits. Splintering is never good for public policy decision-making. 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 of this as we move through the discussion in Q&A. Thanks. Great. Thanks, Mary. Danielle, let's hear from you. So in keeping with Michael's theme of change, I also wanted to talk a little bit about some changes in the marketplace and maybe also some things that haven't changed either since 1999 or more recently about five years ago when the FCC first opened the 5 GHz proceeding. So I've heard a little bit about changes in the automotive marketplace. I'd like to talk a little bit about some changes in the spectrum environment. But I'd like to start by highlighting that the need for more Wi-Fi spectrum, as Mary said, has not diminished in the last five years. In fact, that need is becoming more acute. We're seeing fast-paced growth and consumer demand for Wi-Fi and we'll also need additional Wi-Fi spectrum to enable next-generation gigabit Wi-Fi speeds. A couple of important studies using different methodologies that both conclude that consumers will need over a GHz of new unlicensed spectrum in just the next few years, and that's just to support growing demand for technologies like Wi-Fi. We may need more than that when it comes to enabling new and innovative unlicensed technologies. From NCTA's perspective, 5.9 GHz remains the best near-term option for additional mid-band unlicensed spectrum suitable for Wi-Fi. The 5.9 GHz band is immediately adjacent to the Uni3 band, which is the most important Wi-Fi band in the world. By opening this band to Wi-Fi, we think that manufacturers will experience important economies of scale and providers will be able to bring more broadband to the market more quickly. Despite this rhetoric that DSRC deployment is just around the corner after nearly 20 years as others have highlighted, these incumbent DSRC services remain in the pilot phase and they may never see widespread commercial deployment. There really is no other mid-band spectrum today that's so underutilized and has so few incumbent operations. Today, broadband providers are delivering gigabit broadband to homes and businesses, but without access to 5.9, we think that Wi-Fi could become the bottleneck. Broadband providers will lack the wide 160 MHz channels that they need to deliver next-generation broadband to consumers, which is how many of us experience the internet. While we think that 5.9 remains a critical band for Wi-Fi, as has been noted, there's been a lot of change in the last few years. There's been this shift from DSRC to Cellular V2X. As others have mentioned, this is really shifting industry interest away from DSRC to these more cellular technologies. From our perspective, that means that arguments about sunk costs or the current channelization that might need to be maintained are really now suspect. Now, we've heard from a couple of folks that although the CV2X spec suggests the 5.9 GHz band could be used for CV2X applications, but as this is a new technology that may not need to be the case, we've also heard that CV2X has a path forward to 5G, and it may be that it's appropriate to think about CV2X more in the 5G bucket and think about spectrum allocations accordingly. It doesn't necessarily mean less spectrum, but I do think the time's right for the FCC to take a fresh look, step back, think about what are the spectrum needs for this kind of shifting landscape in automotive communications technologies, and what is the right spectrum home for these different options. In fact, we've heard some in the community suggest that exclusive license spectrum might be a better choice for safety applications than the DSRC model for CV2X. I also wanted to talk a little bit about changes in the spectrum environment since the FCC first conceived of the 5.9 band as an automotive communications technology band 20 years ago. So in that time, the lower-adjacent Uni3 band, which I mentioned is widely used for Wi-Fi, has seen widespread deployment, millions upon millions of unlicensed devices here in the United States. What hasn't been talked about too much yet here today is that upper-adjacent band to 5.9, the 6GHz band. Right now, immediately adjacent to DSRC, there are high-powered fixed links, there are satellite communications systems, and the FCC has opened a proceeding and a notice of inquiry to look at authorizing unlicensed use of that adjacent 6GHz spectrum. So as Michael mentioned, it may no longer be appropriate to have sort of an island of auto safety that might not be a good engineering choice to have an automotive safety band there. It may be time for the FCC to just simply take a step back, take a fresh look. So the FCC proposes that the FCC issue a further notice of proposed rulemaking that would propose to designate a 9GHz spectrum for unlicensed use to help meet that growing demand for Wi-Fi, and then seeking comment on what the spectrum needs are for the automotive applications that have changed in nature since 1999 and even in the last five years, and to examine whether there might be other more suitable spectrum for those automotive communications technologies. Thanks, Danielle. Roger, I'll go to you next. Well, I already sound it up, but I did want to comment on some of the statements that were made here, and some of the things I didn't mention, so I did want to highlight what Michael was saying about the fact that there are a lot of technologies that have entered into the market since the conversation about DSRC started, so cameras in particular more or less did not exist on cars as a safety tool, and radar was in very early stages and certainly too expensive in most cases, and we certainly weren't hearing a lot about LiDAR, so in the industry I can tell you right now we've gone from one LiDAR provider to 50 LiDAR providers, and I don't have to tell you what that means for scalability, cost reduction, and the delivery of that technology to vehicles to enhance driving safety, dare I say without any wireless connection on the car. What we haven't talked a lot about on the panel here is what we're working toward in the industry, which is autonomous driving, all of this safety technology enabling an autonomous driver, and 5G is very likely to play a major role in that, what some of you may have seen in some of your newspapers today or in recent weeks and months is the need for remote control of the vehicle, okay? Now we've seen hackers do that, but now it may become not only an SAE standard, which is being defined for yet another level of autonomy, remote control, but a requirement, it may actually become a requirement if the vehicle, something goes wrong, you want to have a fallback of some kind of remote control, while I can tell you the wireless connection 5G provides precisely the bandwidth and low latency you would need to do that, although companies are doing it today with LTE. Believe me, I'm as skeptical as anybody about the scalability of remote control of large numbers of vehicles, but it is not only being contemplated, it very may well be a required standard. In fact Finland's autonomous driving law provides for the driver, there must be a driver, but the driver doesn't have to be in the car, so draw your own conclusions where this is leading. So I'd be the first person to say most of the autonomous vehicles that are operating on the road today do not have a wireless connection and they are perfectly safe, but in the future we're going to want to have all of the technology at our disposal that we possibly can have, you know, a belts and suspenders kind of approach to autonomous driving, and wireless technology will play that critical role and it very likely will be cellular, although I will say I was at the satellite 2018 conference here in DC yesterday and certainly satellite wants to play a role in this game as well, but I think the points were covered very nicely and with very little overlap by the other speakers, so back to you. Well, Roger, thanks for that, and I do think it's important to talk about the role of autonomous vehicles today in these policy discussions. I for one wonder if we'll keep using the phrase behind the wheel to refer to somebody who's in control of something after we're no longer behind the wheel, literally, of our cars. But moving on, you know, it's clear that this debate in some ways is quite old in the sense that some idea of intelligent transportation and spectrum has been in the works for decades, but it's also very new with things like self-driving cars. So I want to shift gears, pun partly intended, and ask Michael, should there be a mandate at all for vehicle-to-vehicle communication? Okay. Well, we haven't focused on that on the safety, you know, we're not claiming to be safety experts exactly and Mark should definitely weigh in on that. I think, you know, really some of the considerations I mentioned at the beginning are very important, which is given the cost and given how long it would take to become effective, I think the administration really needs to look at how much of a difference will it make. And I think it was just mentioned, you know, Roger just mentioned the trajectory of driver assist safety technologies. Again, you know, the radars, lasers, LiDAR cameras and all that is only improving and it makes each car safer and makes, you know, the whole driving environment for everyone, for each new car. A big problem with DSRC that was fairly frank about in its notice of rulemaking is that it will take at least first of all, it will be a few years even if they adopted it tomorrow, it would be a few years before they start really doing it and then it will take at least 15 years for they said even though if it will be effective because you have to have a turnover in the vehicle fleet which takes about 15 years and it just seems that we're changing the nature of driving so radically over that same time period and these things are so interactive with each other as somebody mentioned that it probably is better to leave it to the market but within certain bounds. From a mandate perspective I thought you were going to say even if we were going to go forward it would probably be eight years before anything took effect. If you look at the backup camera mandate I think that was in the neighborhood of about eight years and there's an amazing amount of very enlightening research that had to be done on top of the research that was done before to determine exactly how it would be implemented etc etc and there's all sorts of comment periods and then there's a phase in etc etc what we saw in the Obama administration was a shift to more of a voluntary relationship with the industry so I would say boy we should mandate automatic emergency braking at low speed but again if we pursued a mandated approach it would be eight to ten years saving life number one and so they took a voluntary approach to get everybody to commit to we're going to put this on the cars by a certain date so there seems to be something fundamentally flawed in the regulatory process, the mandating process where there isn't a flaw I think and I could be mistaken because I'm not a fleet commercial vehicle industry expert however I think NHTSA has more authority mandates in that sector much more rapidly and we might be having a very different conversation today if the approach had not been to see DSRC implemented in large volume passenger vehicle segments but in the commercial segment and then today we'd have commercial vehicles with DSRC technology and then if you put it in the car you'd have the added advantage of being able to detect large vehicles around you you'd immediately have a valuable proposition but I think there's something fundamentally flawed in the regulatory process to get to a life-saving proposition Mary? Yes so I just want to point out that the notion that Michael raised about the amount of time it's going to take to roll radio based technologies into the fleet that is all the cars that we drive is a concern regardless of what radio technology you pick right the average American is now holding onto their vehicle for more than 10 years and so it takes time for any new technology to be deployed whether it's semi-autonomous autonomous radio based to me the question is does radio based capability for safety does that is the increment of safety you're going to get off that from semi-autonomous technologies that are in new cars today or from autonomous technologies is the incremental benefit you're going to get from that worth the cost and what we saw in the NHTSA notice of proposed rulemaking from the end of 2016 when they did their cost benefit analysis was they were concluding yes but I will be the first to say that the technology moves fast and obviously before you go to a final rule you would have to do that analysis again to find out regardless of the radio technology you pick is the benefit worth the cost 1200 lives would be saved or something the high end was 1400 but that was at 2060 I don't know if that was a ride that assuming a connection between the RF solution and the vehicle controls that was just assuming that was just assuming hazard warnings although the auto manufacturers all say that they would integrate that data into their semi-autonomous and autonomous technologies regardless of what technology if you assume a radio technology it's going to become part of that system I think the main difference between an automated safety technology and a radio technology is that you can start providing safety benefits immediately once that automated technology is deployed it doesn't matter it doesn't matter what other cars are equipped with and in the case of the V2V mandate from NHTSA they were looking at a cost benefit break even point around a decade after the phase in began a decade after the mandate started to take effect and I argue that that was overly optimistic but I think the point is that some of the lower levels of automation technology take automatic emergency braking which is incredibly promising right now and we're starting to see this being deployed in the vehicle fleet today we could save just as many lives as the probably overly optimistic regulatory impact analysis from NHTSA says we could with V2V DSRC in just a couple of years as opposed to decades to reap those benefits under the NHTSA's vision for V2V I don't disagree that in the future we're going to see automated connectivity, connected automated vehicles cooperative automated vehicles but that isn't what NHTSA is talking about right now and if you look at all the discussion everything that's in that rulemaking proceeding that's still open very little next to nothing on automated vehicles it's all focused on hazard warnings but then finally just to point out I think there's been even though we still have this rulemaking it's sitting out there open it's now it's been re-designated as a long-term action which means that NHTSA didn't expect to work on this for at least 12 months but I think we've seen other things maybe not as clear as a regulatory shift but we saw the 2018 to 2022 U.S. DOT strategic report basically got all references to DSRC V2X compared to what was in the 2014 to 2018 strategic plan and also we've seen guidance pulled back at federal highway administration on vehicle to infrastructure DSRC based system so I think there is I don't think the administration has finished its work on this topic but I think there are in addition to the re-designation of the rulemaking proceeding status I think we've seen other indications from the department publicly that they are moving in a different direction than the previous administration Anybody else want to weigh in on what Mark just said? I might just add that from a regulatory overhang perspective with this proposed mandate still sort of out there even though it's relegated to the back burner I think that's really problematic for everyone involved I think it's problematic for the automotive sector that sort of sorts out where it's headed with vehicle connectivity technologies I think also it's problematic from sort of a political perspective in trying to permit the FCC to move forward here and to try to finally get to a place where regardless of what the decision is we get some more efficient use of that 5.9 gigahertz band that's Lane Fallow for far too long I'm interested in the perspectives here on what we're fundamentally looking at which I alluded to in my opening comments which is that we're for the first time talking about using cellular for an active safety function in the vehicle which is quite radical typically the cellular interaction with the cellular industry by the automakers has been for things like infotainment automatic crash notification sure maybe vehicle diagnostics but safety that's a whole different group of guys who take a very dim view of the wireless industry generally and I'm curious how the rest of the panelists think about that fundamental shift yeah that's a great question Roger Mary do you have any thoughts yeah I as I said in my opening I think what we're lacking a couple things obviously we're lacking an NHTSA administrator who can clearly articulate which way is the wind blowing inside that agency right just we don't have one we don't have any buddy sitting in the decision seat beside it besides an acting person who in good faith is just pursuing the agenda she's been given but on this question I think there has been a complete lack of clarity around the business model of a cellular Vita X system who would run it do the carriers want to accept the liability of being the providers of a vehicle to vehicle crash avoidance system would they prefer the auto manufacturers to take that liability what would the business relationships be for the from the perspective of how is the band used to what end is the is the greater throughput of the CV to X system going to be used for data what are the business relationships there and I think we don't have clarity and I'd be curious to know if anybody else has seen this I haven't seen any clarity yet coming out of the carriers they're all very interested in exploring the technology to see what the technology can do which is good right but I haven't seen any clarity about how the business model actually works the one thing I will say is DSRC there is a very clear business model and it involves the consumer paying nothing once you buy the car once you buy the car with the radio in it you don't pay anything anymore so I think there's a consumer angle here too that needs to be clarified Mary you make a great point about the liability I think that's kind of a running theme in 5G is that you know once the network has every part of the consumer's life on it who's liable when that device doesn't work or when something bad happens I know Michael wanted to make a point one thing I mentioned in my opening was that the FCC commissioners who have been speaking out on this issue over the past couple years commissioners O'Reilly and Rosenberg in particular you know they've been emphasizing that there is a distinction between V2V as or V2X as as real time safety you know what you need for safety which needs to be has to have very low latency it has to be completely interoperable and available to everyone where it's not going to work remember this is a technology that's completely dependent on the network effect on every car having this and it all being the same language so there's a big distinction between that and all the other connected car applications that you might do whether they perhaps you know using alternative radios on the same chip and what I've been hearing recently from mobile carriers is an acknowledgement of that distinction it's a very important distinction they're saying that oh look or you know the government is going to have to tell us is going to have to say that there's a that every car for safety purposes every car has to have even if there's not a mandate they'll still have to say that if you are going to have a safety signaling that it must all be the same interface it has to be interoperable and they're saying that that has to be a peer to peer communication it's not going through their so we're not talking for safety we're not talking about the way it works on your smartphone it's not going to go through the cloud it's not going to go back to each of the competing carriers different networks this has to be for safety the basic safety message has to be peer to peer it has to be directly between the cars and they are saying that that can be the same basically use the same sort of 5G new radio but probably it's something the automakers just put in and it operates and nobody knows who's in charge of it yet whereas all the other things that you would do with cellular V2X will be things that each individual carrier innovates around and competes on and that will probably go back through their own networks for the most part so it's really in a sense two different things Michael I wanted to follow up and on safety how much spectrum is needed well it's not well needed and then also required so what NHTSA Department of Transportation has in their notice of rulemaking which is now on the shelf and this has been true from the beginning the requirement that all vehicle to vehicle signalling must be dedicated single channel of 10 MHz so the band is 75 MHz and they require that all that vehicle that real time safety signalling be on 10 MHz they also have this notion to set aside a second channel for first responders because it could be at a much higher power level and and in Europe what the European Union decided years ago they had a proceeding they said well we think that safety requires 20 MHz but we're going to have a third channel so up to 30 MHz as a contingency because it might be useful to have for example cars communicating with stop lights and things like that even though that's not always time critical it could be on this third channel so Europe still is going with up to 30 MHz which is why one of the proposals when it looked like DSRC was going to be mandated one of the leading proposals Cisco had a proposal but also Qualcomm had a separate proposal to segment the band to say well let's give safety its own exclusive 30 MHz at the top of the band so that Wi-Fi can share the rest so that commercial applications can share between DSRC and Wi-Fi what the emergence of cellular V2X throws in this wildcard this new aspect of well can we still do it the same way should we still do it the same way on the one hand since CV2X is starting from scratch it would be easy for them to use the top of the band for safety but on the other hand it's less clear how well they can coexist with Wi-Fi or whether that even makes sense because each of these mobile carriers will have their own 5G networks and their own separate spectrum and how much control I'm not clear exactly how much control NHTSA would have over the entire 75 MHz in this situation and how the pi is sort of divided up spectrum needs is important to remember that for the vehicle to vehicle the proposed vehicle to vehicle mandate and the MHz channel for safety signaling I also want to highlight I think there's sometimes a misperception that this is DOT spectrum but in fact this is commercial spectrum that's governed by the Federal Communications Commission and so well NHTSA has a very important role to play I think in this debate about CV2X and DSRC and safety technology it's not the expert agency when it comes to spectrum decisions those are things that Congress has committed to the FCC to decide I think that's why it's time for the FCC to step up, to step forward giving all these changes in the marketplace and really start thinking about exactly what the spectrum needs are in this new environment and just take a fresh and holistic look at that 5.9 band Mary go ahead Just to apply some technology gloss to the statements here the DSRC technology was designed with a vehicle to vehicle channel 10MHz that is dependent upon the existence of a vehicle to infrastructure channel so they can obtain their security certificates that we heard about earlier there's also a control channel at the top of the band there was a channel that state highway departments were going to use for their own purposes but you can't in a DSRC proposal you can't isolate 10MHz so they can communicate with that radio similarly when the cellular V2X came along they took that same model but put in cellular technology so they also need some way to communicate with the radio that's on board the vehicle whether that absolutely needs to be in the band whether that communication link could be in another band is a question it's a valid question but that's how it was designed it was essentially designed as a cellular version of DSRC yeah interestingly so Roger had a slide up I think taken from Qualcomm in this discussion during his presentation that sort of highlighted the various sides of CV2X and I'm no CV2X expert it's a automotive piece that they're thinking about the 5.9 band for and then they already contemplate CV2X operating over the carrier's existing license spectrum in part to do kind of the network communication so you know again I think given that kind of unique nature and the fact that things are still developing I think now is the right time to be thinking about those spectrum needs and to DSRC to take a look most of the advocates of CV2X will say that's using the same spectrum it can use the same protocols and deliver the same value proposition fundamentally so that seems to be the intent and we just had a white paper from 5G America's release this week that says exactly that so that's cellular vendors and cellular operators saying it's the same spectrum where does Wi-Fi fit into this whole equation we've mentioned Wi-Fi several of you have I want to focus in on it for a second and talk about where it fits into this spectrum policy discussion Michael do you want to take a first crack or do you want me to dump it I think I pretty much said my piece on this but you know we'll reiterate that I think you know we're still seeing a great demand and growing demand for Wi-Fi technologies so you're seeing increased consumer demand some congestion on the networks as Michael had mentioned and kind of peak hour scenarios we've got several studies forecasting in need for additional unlicensed spectrum and you've got a great new Wi-Fi standard 802.11ac which is now in development for the next one 802.11ax and both of those rely on really wide 160 megahertz channels right now in the US we have one 160 megahertz channel to support everybody it's really I should say it's not restricted by dynamic frequency selection rules most favorable Wi-Fi rules you've got one 160 megahertz channel 80 megahertz at uni1 80 megahertz at uni3 but to get the country's first contiguous 160 megahertz Wi-Fi channel 5.9 is really the place to do that really the only place that's been teed up here yesterday so I think this band is particularly important for Wi-Fi use and to meet that growing demand enable those gigabit Wi-Fi speeds that carriers are delivering that wired broadband providers are delivering into the home I would just add that it's if Wi-Fi is going to keep pace in a 5G world then it's going to need wider channels, more spectrum so we often talk when misnomers we often talk about 5G as if it's a mobile just a mobile carrier technology and network but it will be even more diverse and decentralized than the current 4G wireless world so currently we currently have 4G I'm sure all of you on your smartphones are actually sending about 80% roughly that's what even some of the carriers of roughly 80% of your mobile device data traffic is not touching the carrier's spectrum or network at all it's going a short distance over unlicensed spectrum via Wi-Fi and that's what's keeping your everyone thinks they pay too much but believe me you would have far less data if everything you were using actually went to the carrier network but because it's going via Wi-Fi you know into the wire line that's within a few hundred feet about 80% of the traffic you know then that makes your mobile broadband more available considerably faster particularly indoors and a lot more affordable so when 5G comes along the same process needs to happen so the mobile carriers are using millimeter waves they're getting more spectrum to have wider channels for faster networks and we'll all enjoy that except that that will be too expensive unless Wi-Fi can keep pace with that and right now the only place for wide channels is in the 5GHz band which is immediately below and adjacent to this car band that we're talking about but unfortunately the FCC although it proposed to make as much as 750 MHz contiguous MHz available for Wi-Fi back in 2013 it found among other problems that the military said you can't share with a certain kind of radar in the middle of the band and now we're running into this issue of this band we're talking about today 5GHz so that is really the only place we know of right now in the upper 5GHz band and possibly into the 6GHz band where you can get these wide channels so that the entire 5G ecosystem will be robust both the licensed side of it and the unlicensed side Mary, so I I concur with a substantial part of what Michael said 5G is the first time that the cellular industry is going to have a radio access network which is the edge radio that is agnostic to technology and one of those technologies is going to be Wi-Fi so anyone who thinks Wi-Fi is not part of 5G as a technical matter misinformed Wi-Fi is going to be part of the 5G system and desperately needs more spectrum for all the demand reasons Michael raised I personally and many of us in the Wi-Fi industry have become it is painful to watch the 5G9 proceeding and the 5G9 activities not advance as quickly as we like because that spectrum is sitting there largely unused Cisco had a proposal some years ago when DSRC was the only horse in the race to try to share DSRC now we're not even sure if DSRC will eventually end up prevailing although it's certainly still as I said sitting in the incumbents chair but it is painful to watch and I think at least at Cisco we are spending far more of our time, energy and mind share on opening up spectrum at 6 GHz because we don't see a way to move the 5G9 wrong toward any kind of resolution whether it be DSRC whether it be cellular V to X how much spectrum will it need there just doesn't seem to be any way to move that forward I think we're still hopeful that we can move forward on 5G9 it is painful to see it sitting there so underutilized and I think from NCTA's perspective I think 6 GHz is really interesting we have some incumbent satellite our members have incumbent satellite links it may be a discussion coexistence there may be a discussion for another panel but certainly we're hopeful that unlicensed will find a way to share in those 6 GHz frequencies as well I think that they don't why aren't we saying 6 GHz is the best near-term option for Wi-Fi, why is that still 5.9 I think one reason is that the proceeding just isn't as advanced yet the FCC started to kick this off with an NOI last summer but we've got five years of record developed on 5.9 and we haven't done a lot of work on it yet in addition I think there may be obviously technical rules are yet to be worked out but there may be some restrictions in 6 GHz that might not be present in 5.9 in terms of Wi-Fi's ability to operate so hopefully optimistic about 6 GHz provided incumbents can be protected but still believe 5.9 is the best near-term option this is a little bit of an awkward conversation to be taking place within NHTSA so I'm frankly getting an education on the Wi-Fi side of this issue so what we're left with it's not a rational discussion usually it becomes emotional political, religious and then it comes to we've spent $700 million on this technology we've come this far which takes it completely beyond a business model discussion as Mary's trying to bring it back to and the real technical issues that are at stake and implications that touch everybody not just car drivers so this is what everybody has just heard is the untold story of this debate which is what the Wi-Fi piece is all about well I'm certainly glad we could shed some light on an untold story should we move to Q&A or running a bit short on time any final thoughts quickly from anyone before we we run out of questions we should probably see you sir so my point was simply wouldn't it be helpful first to establish if we ought to be moving toward the objectives of DSRC whether it be with DSRC or cellular V2X and then discuss bandwidth second the main problem that we have right now is that and what Danielle referred to earlier is that we have this regulatory overhang at NHTSA that not only is presenting this regulatory uncertainty in the automotive industry over what kind of connected vehicle technology is going to be used to bring negative impacts over at the FCC and on the wireless industry and the equipment manufacturers so until DOT really gets its act together and I think it's moving in a good direction at least from my perspective but until it chooses a path and does so clearly all of this other stuff is still going to be left unresolved and it should be resolved so I think the logical order of resolution is the one you suggested which we ought to figure out what do we need to do about safety first and then figure out the spectrum consequences I completely agree with that one of the issues with cellular V2X as I said is still early days there was a recent announcement by Ford and Qualcomm and some other players that they were going to set up a test bed in California I certainly hope they share the data off that and begin to see is this technology living up to the marketing hype that we've been hearing about for six months or a year that would be helpful and I think it would be really important for folks to start telling us what they think the business model looks like so that could be compared to DSRC we don't have that information today we don't have those data proof points and we don't have clarity around those two issues but I think that's the right logical intellectual pursuit the challenge that the Federal Communications Commission faces often in this environment because they're in a position of needing to designate bandwidth and allocate bandwidth many years in some cases before a technology takes off it shouldn't take 20 years but certainly in order for a technology to take off it needs to have some spectrum security in place so the FCC needs to make some of these decisions I think fairly quickly for some of the technologies on the table and it appears I should add that this is where this got stalled at the FCC I believe they have been waiting for Department of Transportation to make at least a fundamental decision about what safety is needed because it's not even so much a choice between DSRC and Cellular V2x as the AR interface technology because they probably will use about the same spectrum for the same amount of spectrum for the purpose of safety but they really just need to decide is there going to be a mandate and what are they mandating so already in Europe as I mentioned earlier they've decided that 30 megahertz about as much as would ultimately be needed for the safety side of this and if they could at least make a decision like that then that would I think allow the FCC to have more confidence in allowing sharing of the of the other spectrum that might be for non-real-time safety applications certainly a lot of open questions and speaking of which any more from the audience we'll thank you go ahead one more hi my name is Jack Kropansky on Affiliated would it on the safety angle what do the insurance companies think of all this do they see this as something that's going to be a really big deal for them or they just not see it as a big deal at all the insurance companies are still trying to figure out whether blind spot detection or not your warning are reducing claims I think they may have just recently come to the conclusion that that is the case the insurance company the insurance industry moves very slowly and they they focus on history so they don't forecast the efficacy of different safety technologies so as far as Tesla was concerned for example he weren't paying a fortune you know taking some risks because the underwriting was based on historical data so the insurance industry will be very careful and slow to react I don't actually think the insurance industry is really going to play in this debate you already see the car manufacturers competing on safety right Volvo's famous goal get to zero fatalities by whatever year it was and they're all trying to move in that direction so I think the auto industry itself is trying in various ways all in good faith to try to eliminate fatalities and reduce accidents as a whole by whatever technology means they think is best where I've heard insurers expressed interest about this it's related to how this may eventually interact with automated technology insurers have been very engaged on that because not only does it have far more dramatic implications for crash numbers when compared to V2V DSRC hazard warnings it also has the potential to upend their business models shifting more liability toward manufacturers and away from the end users if the end user is no longer actually directing the vehicle and traffic so where they talk about this they would obviously be concerned about cybersecurity aspects but as it relates to automated technology they're less interested in it as a hazard warning I think we have time for one more very very quick one ma'am Lauren Smith from the Future Privacy Forum one of the early slides Roger you had a section that talked about the privacy protections that could come into play for cvtax that wouldn't necessarily be in play for DSRC but heard this discussed often you know the V2V mandate was built to be privacy protective but also creates risks but why exactly is it that cellular technologies would wind up or 5G would wind up being more privacy protective I was just going to say the DSRC community has prided itself on privacy protection it's an anonymous message they've had challenges to see if people could find and identify a car from provided anonymized data so I believe my sense of it is they would be equivalent except with cellular you would have maybe more consumer control either opt in or opt out because it would be more wireless service based as opposed to this mandated protocol that's announcing your location 10 times a second but again my understanding of the ultimate roll out of DSRC would be completely anonymized and that's my understanding anyway so presumably it should be would be superior to cellular in terms of the preservation of privacy but that would only be in the context of cellular would have presumably an opt in or opt out proposition but for the safety I suspect it would be the same protocol as DSRC so it should be identical so I'll have to check the slide again because it shouldn't really show a difference I don't think thank you all for a great conversation and thank you guys for joining us