The NMA Foundation presents the Car of the Future weekly feature:
The National Highway Traffic Safety Administration’s (NHTSA) deadline for comments on the Federal Motor Vehicle Safety Standards: V2V Communications was April 13. In the two weeks before the deadline, a flurry of auto industry groups, privacy NGO’s and safety advocates made haste with comments and released them publically. Over 400 individuals and organizations filed formal opinions with the NHTSA reflecting a wide array of viewpoints. In reading these comments, there are still far too many questions that need answering before V2V regulations can stand on their own.
V2V communications is one of the most important components for the car of the future. Without V2V, the car of the future would be the dud of the future. Connected and driverless cars need to talk to each other and to the Internet of Things (V2X communications) such as traffic lights and street lamps. V2V messages need to be sent between cars at a minimum of 10 times per second using dedicated short range communications (DSRC) on airwaves that have been reserved by the Federal Communications Commission (FCC) since 1999. Interoperability is critical to the success of V2V communications.
Some industry groups believe that the designation of a single language such as DSCR would solve the problem of dueling protocols, but opponents argue that DSRC is already outdated and shouldn’t be mandated. In fact, many commenters don’t want to see any specific technology mandated at all. Privacy and cybersecurity are also two major important elements of concern.
The stakes are quite high. Major automakers such as General Motors, and Toyota have spent over a decade developing V2V communication systems and have a great deal to lose if V2V regulations are not put into commission.
The Association of Global Automakers (AGA), representing Toyota, Honda, and Hyundai, says that more than $1 billion in private and public funds have already been spent developing the technology. The AGA commented that the proposed V2V regulations are “the best way to ensure nationwide deployment” as soon as possible.
The Alliance of Automobile Manufacturers (Alliance), representing GM, Ford and VW, says the proposed mandate needs more clarity on several issues including security. The Alliance asked that more time was needed to implement the mandate than the proposal provides.
Tesla said policy guidance and industry cooperation would be a better approach for encouraging V2V. Tesla called the NHTSA’s V2V strategy “too antiquated and vague” to protect the privacy of V2V messages.
The 5G Automotive Association (5GAA), is a new global cross-industry association of automotive, technology and telecommunication companies includes 42 members (8 founding member companies include Audi AG, BMW Group, Daimler AG, Ericsson, Huawei, Intel, Nokia and Qualcomm. 5GAA’s mission is to enable communication solutions that address society’s connected mobility and road safety needs. In written comments, 5GAA urged the NHTSA to not consider just the best technology of today, but also consider the best technologies of tomorrow. Rigid technology mandates freeze technology solutions to a past point in time and would impede innovation and evolution for both V2V communications and V2X (vehicle to Internet of Things communications). They asked that the NHTSA move forward with technology neutral regulations that set forth minimum V2V safety performance requirements only.
Consumers Union, the policy arm of Consumer Reports, supports the establishment of a mandatory safety standard governing the use of wireless communications for crash prevention purposes, provided that the rule reasonably accounts for potential future developments and that both manufacturers and suppliers meet baseline, enforceable standards to protect the privacy and security of communications.
The Future of Privacy Forum commented that they were encouraged by NHTSA’s “privacy by design” approach to building this system, by taking privacy into account throughout the entire engineering process. The FPF recommends six additional steps the NHTSA should consider to ensure privacy:
1) Improve the privacy notice and undertake proposed consumer education efforts.
2) Retain the proposed rule’s approach to defining Personally Identifiable Information—this approach is consistent with the Federal Trade Commission.
3) Work with partners and regulators to identify any protective and legal control that could limit third party collection, aggregation, or sale of V2V data.
4) Consider appropriateness of the sorts of consumer privacy controls (e.g. opt-out), and how choices can be presented in the context of the operator’s relationship with vehicles and service providers.
5) Ensure oversight and accountability mechanisms for the security entity within the proposed rule’s credential management system.
6) Continue to study and mitigate the residual privacy risks created by any proposed rules.
Public Knowledge wrote comments outlining concerns for mandated Direct Short Range Communication (DSRC) service for V2V communications. Public Knowledge supports the goal of using DSRC for reducing vehicular crashes but advises against commercializing DSRC service. This would leave the door open for non-safety uses of the DSRC spectrum, introducing increased cybersecurity risks and overall consumer privacy concerns.
National Public Safety Telecommunications Council put cybersecurity issues front and center in their comments to the NHTSA. “Empirical security research already shows the general lack of security in vehicles,” said the comments. “DSRC, as presently conceived, would make matters worse. It presents a new attack surface with special considerations, given its integration into critical control systems. The absence of security frameworks or a compliance regime risks life and safety. Providing a basic standard of care cannot be left to the market for safety-of-life systems—it is not in the case of PCI DSS, HIPPA, and a number of other standards. Without a framework, the ills of the broader IT market will be realized in vehicles, privacy and security will be risked, and the costs of security will not be easily controlled, disproportionately harming those with the least amount of economic agency.
“It is necessary for the industry to ensure that the use of DSRC is predicated on the compliance with a reasonable security framework, which it currently lacks,” the paper added. “This approach supports both motorists and automotive OEMs.”
Is V2V Communications at a crossroads? The car of the future is still a tangible idea but more time is indeed needed to work out the many areas of concern before consumers ride away.
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