The Department of Transportation Should Maintain Strict Tech Neutrality for V2X Devices
Thank you for the opportunity to comment about this important development in auto safety and technology. The Fourth Branch Program of the Mercatus Center at George Mason University is dedicated to advancing knowledge about the effects of regulation on society, commerce, and innovation. As part of its mission, the program conducts independent legal and economic analyses to assess agency rulemakings and proposals from the perspective of consumers and the public.
The US Department of Transportation (DOT) requested comments regarding vehicle-to-anything (V2X) communications technology. The attached public interest comment was filed with the National Highway Traffic Safety Administration in April 2017 regarding the proposed mandate of dedicated short-range communications (DSRC) technology for new vehicles. The attachment is responsive to the recent notice on the issues of V2X deployment timelines, interoperability, and DSRC safety data.
Prior predictions of DSRC deployment have been unreasonably optimistic. For instance, in January 2004, DOT officials told reporters they expected DSRC services to be commercially available sometime in 2005. In fact, it took until 2017 before a car manufacturer installed DSRC in a vehicle. The attached comment notes that there “is a significant likelihood that DSRC will be eclipsed by competing technologies, like lidar, radar, and cameras.”
Nevertheless, DSRC very well could win consumer and commercial adoption in the end if vendors develop compelling and safe services. For now, as the attached comment explains, DOT should avoid favoring any V2X technology because the safety benefits are uncertain, the device market is competitive, and the technology advances rapidly.
 Paul Kirby, FCC Adopts Regulations for Highway Communications, 70 Telecomm. Reports 1, 24 (2004). (“The agency said it had been working cooperatively with the auto industry in hopes of making the technology commercially available by 2005.”)
 See John R. Quain, Cars Will Talk to One Another. Exactly How is Less Certain., N.Y. Times, Mar. 9, 2017, https://www.nytimes.com/2017/03/09/business/cars-v2v-dsrc-communication….
 Brent Skorup, The Department of Transportation’s Proposed Vehicle-to-Vehicle Technology Mandate is Unprecedented and Hasty, 2 (2017).
Notice of Request for Comments: V2X Communications
Agency: US Department of Transportation
Comment Period Opens: December 26, 2018
Comment Period Closes: January 25, 2019
Comment Submitted: January 24, 2019
Docket No. DOT-OST-2018-0210