GSMA letter to the European Parliament on Delegated Act C-ITS

Dear Members of the European Parliament,

I am writing to you concerning the Delegated Act on C-ITS, which will be discussed at next week’s plenary session of the European Parliament. Yesterday, the Transport Committee supported the objection of MEP Riquet to the Delegated Act. I would like to urge you also to vote in favour of his objection, so that this piece of legislation goes back to the Commission. Approving the Delegated Act in its current form would be a grave disservice to European citizens and their safety on the roads.

The main problem with the Delegated Act is that it fails fundamentally to deliver on our shared goal to make Europe’s roads safer and smarter. The Delegated Act makes a very clear choice in favour of wi-fi technology as the standard to connect cars and infrastructure. This choice is now widely opposed by key stakeholders. The car industry is divided, as well as the Member States – and even the Commission. To date, only one car manufacturer in Europe is planning to equip one of their models with this wi-fi technology by 2020. Many others in Europe – and globally – are opting for a more recent and efficient cellular technology innovation, known as C-V2X. It is therefore understandable why a number of Member States are heavily opposed to this antiquated technology choice, and why Vice-President Ansip and the Council Legal Services have objected to the Delegated Act.

The disregard for the principle of technology neutrality makes even less sense when you consider that the wi-fi standard (802.11p or ITS-G5) supported by the Commission is so outdated. There are new technologies, widely supported by industry globally, that will do a far better job at ensuring citizen safety. This wi-fi standard was developed over a decade ago for the ITS-G5 framework. Despite being ready for many years, it has seen very little commercial deployment so far. To be clear, 802.11p has demonstrably poorer performance than C-V2X in terms of security, reliability, range and latency. Moreover, 802.11p functions as a standalone network, while other solutions would better allow for the seamless interchange of data. The safety of drivers can be greatly enhanced when cars can ‘talk’ to people (V2P), for example alerting pedestrians of an incoming vehicle. C-V2X can do this because it uses existing (3G and 4G) networks, will be fully compatible with 5G, and can easily be integrated in smart city environments.

The Delegated Act tries to overcome its obvious shortcomings by including a review clause that allows for other technologies to become part of the C-ITS ecosystem. This is simply not possible. To be added to C-ITS, there are demands of ‘interoperability’ and ‘backwards compatibility’ between 802.11p and future communication infrastructure. C-V2X cannot ‘talk’ to 802.11p, as they are different technologies that use radio waves incompatibly. It is like putting a DVD into a VHS player and trying to make it work. Therefore, even if the technology of choice of many telecommunications networks and automobile manufacturers – C-V2X – tried to eventually be recognised as a communication layer for C-ITS, it would de facto be locked out.

The Delegated Act also fails to recognise the reality that the vehicle market is global. Since 2018, C-V2X is commercially available globally and is already becoming the standard for short- and long-range communications. This year, infrastructure and aftermarket devices are set to begin deployment. Roadside units with C-V2X are already available. A range of OEMs plan to equip their automobile models with C-V2X, including BMW, PSA and Ford. In the United States, the mandate for DSRC (similar to 802.11p) has never been adopted and regulators are keeping the market technology neutral (which has led to Ford spurring its deployment commitment for C-V2X). The technology choice that Europe is making towards 802.11p goes in a backwards direction, ignoring market developments and isolating itself further.

Lastly, and a crucial point for the GSMA, the Delegated Act directly undercuts Europe’s stated 5G ambitions. The EU’s 5G Action Plan calls for all “major terrestrial transport paths [to] have uninterrupted 5G coverage by 2025.” Rather than incentivising this outcome, the new legislation deals a blow to 5G rollout plans across Europe. As C-V2X is a key building block for future 5G networks, and as connected cars are one of the most important 5G use cases, this decision to prioritise 802.11p will hinder 5G deployment in Europe.

There is so much well-founded objection to the Delegated Act on C-ITS, that it is simply the wrong choice for Europe to make. We fully understand that the Commission wants to use technology to reduce the unacceptable amount of road fatalities. Our industry shares that goal. But this Delegated Act fails to achieve that. If adopted, Europe will find itself on a dead-end road, locked into an antiquated technology choice to connect cars and infrastructure. We therefore urge you to the reject the Delegated Act, which is bad for competition, bad for innovation, bad for road safety and bad for European citizens.

Yours sincerely,

Mats Granryd, GSMA Director-General

Also read:

GSMA-ETNO letter on safe and competitive Connected and Automated Driving in Europe

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