Washington, D.C. — Stakeholders have raised many questions, concerns and issues surrounding the allocation of 75 MHz of spectrum to the auto industry for uses related to intelligent transportation services, including Dedicated Short Range Communications (DSRC).  The intent of this allocation is to facilitate the implementation of technology designed to stem the tragic and expensive toll that vehicle crashes take on both individuals and public health.  To that end, we support its use for non-commercial, safety-related communications.

As various technological issues are worked out for the use of the 5.9 GHz band, we make the following recommendations:

1. There should be dedicated and adequate spectrum available exclusively for safety purposes. The current allocation of 75 MHz may be more than is necessary, and an impartial determination should be made as to what amount is needed solely for safety purposes.
2. Auto manufacturers must be required to meet baseline, enforceable standards to protect the privacy and security of communications technologies using this dedicated band as they deploy them.
3. The commercial use of this dedicated safety spectrum must be prohibited. We are concerned that the use of commercial applications in this band could:
   1. Threaten safety by increasing driver distractions, which are already a leading cause of auto crashes;
   2. Increase the risk of privacy violations and security compromises; and
   3. Be anti-competitive and counter to public ownership principles and the efficiency and flexibility of the spectrum.

The Consumer Federation of America is a national organization of more than 250 nonprofit consumer groups that was founded in 1968 to advance the consumer interest through research, advocacy, and education.