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. ITS America has been active in advocating before the Federal Communications Commission (FCC) and other agencies.
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 taxation, could retard the development of a robust ITS infrastructure, along with the social, environmental, and economic benefits that come with it.
In 2008, ITS America filed Reply Comments in the FCC’s Universal Service Program 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).
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)
Wireless Communications, Spectrum Policy and Safe, 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.
In 1997, the ITS America filed a Petition for Rulemaking requesting that the FCC allocate 75 megahertz of spectrum in the 5.9 GHz band for ITS services. In 1999, the Commission allocated the 5.9 GHz band for DSRC-based ITS applications and adopted basic technical rules for DSRC operations. After the allocation was made, the ITS America worked to develop a consensus in the ITS community on licensing and service rules for ITS and, in July 2002, presented a recommendation to the Commission for service rules for DSRC operations in the 5.9 GHz band. DSRC will be critical in the development of cooperative vehicle-to-vehicle, vehicle-to-infrastructure crash prevention systems likely to be implemented within the next five years.
ITS America has been supportive of development of other wireless vehicle crash prevention technologies, such vehicular safety radar and navigation sensors. ITS America endorsed a number of our members efforts in reforming rules regarding operation of vehicle radar such as 77 GHz systems. Vehicular sensors such as radar and GPS will enable the introduction of new vehicular safety technologies, and also contribute to mobility and driver convenience. ITS America believes that these technologies, if allowed to flourish, will prevent most crashes in the future, not just mitigate their destructive impact on property and life which has been the approach pursued the last hundred years. 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)
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. In 2010, ITS America published its position statement (URL) on the issue of driver distraction.
Road operators and first responders need reliable 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 this new 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.
For more information on DSRC, visit our Connected Vehicle 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, Director, Telecommunications and Telematics
Paul Feenstra, Vice President of Government Affairs