The Intelligent Transportation Society of America is aggressively involved in advocacy efforts related to the most vital telecommunciations issues, including policy related to public safety, spectrum, and regulation related to transportation, homeland security, energy and the environment.
Telecom Spectrum Policy and Safe and Agile Transportation
ITS America has played a major role in laying the groundwork at the Federal Communications Commission (FCC) and other agencies for the use of spectrum and other telecommunications infrastructure as the foundation for almost all Intelligent Transportation Systems.
ITS America has been active before the Commission for 15 years in proceedings impact the deployment of public and private ITS services, including establishment of electronic toll and location and monitoring systems in the 900 MHz band, Dedicated Short Range Communications Systems (DSRC) in the 5.9 GHz band and millimeter wave collision avoidance radars in the 76-77 GHz band, among others.
ITS America is the leader for advocating for the continued unimpeded use of spectrum for transportation before the federal regulators. In 2013, the FCC opened a rulemaking process to address the issue of spectrum sharing between transportation safety use of the 5.9GHz band and unlicensed Wi-Fi devices. ITS America has taken a leadership position in advocating on behalf of the transportation community to preserve 5.9 GHz usefulness for transportation safety and mobility.
Vehicle radar devices already deployed and operating in the 76-77 GHz Band provide important safety benefits to the traveling public. We encouraged the FCC in 2009 to open a rulemaking proceeding to consider whether and how to amend current rules to reflect advances in this emerging technology and the need and benefits of vehicular radar devices (URL).
Telcomms Regulation of Intelligent Transportation Systems (ITS)
The taxation of ITS technologies is of particular interest to ITS America and its members because the market for these systems is still emerging and highly cost-sensitive. Additional cost burdens, such as increased or unpredictable federal or state taxation, could retard the development of a robust ITS infrastructure, along with the social, environmental, and economic benefits that come with it.
In 2008 and 2012, ITS America filed Reply Comments in the FCC’s Universal Service Fund (USF) reform proceeding regarding a proposed new methodology to require that telematics providers directly pay into the USF program via a fixed, monthly fee ($1.00 or $0.85) per assigned telephone number. ITS America opposed these efforts and submitted its comments to the FCC in support of its members (PDF) in 2008.
In 2012, ITS America along with Global Automakers took the position in a letter to the FCC that the commission “…should exempt in-vehicle connectivity services and M2M connections from USF contribution requirements, or adopt an equitable compensation method applicable to such services.” (PDF). The USF, established in 1997, is a mechanism to subsidize telephone service to low-income households and high-cost areas.
ITS America is also advocated to reducing the cost burden of state taxation for smart technologies. In 2010, ITS America submitted an Amicus Brief to the Washigton State Supreme Court in support of Qualcomm against the State of Washington Department of Revenue (PDF). Qualcomm OmniTRACS Service is subject to retail sales tax as a “network telephone service.” Qualcomm challenged the Revenue Department’s ruling claiming OmniTRACS Service is properly classified as an "information service." Qualcomm’s appeal succeeded and the case was overturned by the Supreme Court of the State of Washington in 2011. (PDF)
Traffic Safety, Security and Privacy in Intelligent Transportation Systems
ITS America has been supportive of the wireless industry in promoting connectivity to vehicles in general. As wireless hand-held devices, aftermarket and embedded "telematics" based applications are appearing in vehicles, ITS America believes that more education, research and technology is needed to reduce the risks of "driver distraction" and its impact on transportation safety. Our members include a large number of prominent experts on driver behavior, technology and human factors from industry and academia. (See our Policy Statement on Driver Distraction (PDF), ITS America Safety Forum (URL)).
In 2010, ITS America published its position statement (URL) on the issue of driver distraction. ITS America is also working with National Highway Transportation Safety Administration (NHTSA) to address their proposed guidelines for safe consumer device interfaces for in-vehicle use. These recommendations to be provided by NHTSA to encourage manufacturers to develop 'less distracting' in-vehicle electronic devices.
ITS America has also focused on the issue of Privacy and Fair Information Practices (PDF) and Cybersecurity (URL) and has been supportive of policies and management practices that promote security-by-design and privacy-by-design. ITS America believes more emphasis should be placed on securing transportation systems to maintain critical assurance requirements - maintaining transportation systems that ensure the preservation of human safety, the environment, critical economic infrastructure, and the viability of commerce and maintenance of personal privacy. .
Road operators need access to First Responder Communications. Evacuations and road closures, responses to major traffic incidents or emergency 911 calls, and natural and man-made disasters, require coordination and communications across a number of public safety organizations. The creation of a public private partnerships to provide new nationwide inter-operable public safety mobile broadband services to first responders is also important to the safety, security and reliabilty of our transportation infrastructure.
ITS America has advocated that road operators and other transportation authorities be allowed access to a future new FirstNet broadband network to be able to coordinate with critical public safety personnel such as police, fire, and emergency medical services on our nations roadways. ITS America published its position on nationwide inter-operable public safety broadband in reference to FCC rulemakings in 2008 (URL) and 2011 (URL).
Lastly, drivers need access to critical mobility and safety information services that are simple and universal to access. ITS America has been supportive in investing and upgrading Wireless Emergency 911 to allow for location, SMS, and other mult-media data to be sent to Public Safety Access Points (PSAPS) through individuals' mobile devices. ITS America has advocated creation and expansion of the Traveler Information 511 system, which provides traffic conditions, as well as critical road weather safety and police highway advisories through a simple, universally accessible telephone interface. ITS America has encouraged development of information services that provide navigation, traffic, weather, freight logistics/credentialing, and "smart" parking.
Fourth generation (4G) wireless represents an enormous opportunity in transportation. ITS America has been supportive of efforts by the FCC and others to expand broadband and improve access to transportation right-of-way to host of wireless infrastructure.
For more information on DSRC, visit our Connected Vehicle or the Technology Scan and Assessment page. A complete list of ITS America filings, and more details of ITS America's Activities can be found on our Cross-Cutting Forum Wikispace - Telecommunications Policy page (URL) Also see ITS America's supported Traffic Safety Advancement Group (TSAG).
ITS America's Advocacy Contacts:
Steven H. Bayless, Senior Director, Telecommunications and Telematics
Quentin Kelly, Campaign Director