Feedback reference
F25936
Submitted by
Johannes Springer
User type
Business association
Organisation
5G Automotive Association Board
Organisation size
Small (10 to 49 employees)
Transparency register number
Country of origin
Germany

5GAA advocates for a forward-looking regulatory framework for C-ITS, which endorses market-led solutions and supports technological evolution. 5GAA considers that the future C-ITS regulatory framework must abide wholly by the principle of technology neutrality to prevent unfair market distortion and enable unhindered technological development thus maximizing C-ITS safety and traffic efficiency for the benefit of EU citizens.
Regrettably, the draft Delegated Regulation contradicts the Commission’s commitment to an open and future-proof approach to standards and legislation, by exclusively embracing ITS-G5 (IEEE 802.11p – derived from Wi-Fi) based communications, excluding other available and mature technologies such as LTE-V2X (both for direct short-range or long-range communications).
As 5GAA, we reiterate our position that the Delegated Regulation should not be picking technology winners, but should allow the creation of a landscape with equal opportunities for all automakers, suppliers and other stakeholders aiming to support the deployment of C-ITS. We emphasise that LTE-V2X is the only platform which offers a clear evolutionary roadmap towards 5G for connected vehicles and road infrastructure
While the 5GAA considers that LTE-V2X should be included in the Delegated Regulation, we welcome the incorporation of a fast-track update process of the Delegated Regulation as described in Art. 33.
However, the draft text still imposes discriminatory obligations which would require technologies other than ITS-G5, such as LTE-V2X, to bear the full responsibility of ensuring interoperability. We believe interoperability should be a shared duty between ITS-G5 and LTE-V2X. In addition, a minimum market penetration threshold should be specified before considering any technology as “existing” under this Regulation.
5GAA, therefore, call upon the Commission to:
•Amend the draft Delegated Regulation to include LTE-V2X both short-range and long-range communications, via the related ETSI approved specifications and profiles on an equal footing with ITS-G5;
•Define interoperability as a “mutual” requirement among mature C-ITS technologies, namely ITS-G5 and LTE-V2X for short & long-range communications;
•Avoid legal uncertainty on the “fast-track” update process by:
-Introducing a 6-month deadline for the Commission to make its decision publicly known as regards the initiation of an amendment procedure to include new technologies (e.g., 5G-V2X) or new C-ITS services;
-Specifying clearly the terms, conditions and processes for the inclusion of other technologies (e.g. 5G-V2X) or C-ITS services, including unambiguous definitions of terms such as “existing”, “maturity” or “migration path”, etc.;
-Include as an Annex to the Delegated Regulation a template for the “technical file” to be submitted.
-Open up participation in the future C-ITS Expert Group to representatives of technology segments that are not within the scope of the draft Delegated Regulation today
We note that all elements required in the proposed process for updating the draft Regulation are already met by LTE-V2X:
- All required profiles/technical specifications for LTE-V2X have been adopted by European SDOs;
-Multiple vendors have already commercialised LTE-V2X short-range hardware and software solutions in Q1 2019 (and more are announced for Q2 2019);
We also underline that many of the C-ITS priority services listed in Annex I of the draft Delegated Regulation have already been implemented using 3G and 4G (LTE) cellular networks for long-range communications (e.g. traffic jams, weather conditions, road works, etc.). Yet, this reality is not accounted for by the draft text which still only foresees the initial deployment of these services exclusively via ITS-G5 for short-range communications.
We elaborate further on the above items in the attached contribution, with proposals for specific amendments to the draft Delegated Regulation and supporting materials.

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