 
         
There are furrowed brows in Brussels and Strasbourg as 
     
The idea is to create a regulatory framework to harmonise cooperative ITS deployment through secondary legislation based on ITS Directive 2010/40/EU. The C-ITS Delegated Act - a leaked draft of which had circulated widely within the ITS industry – was put before the European Parliament and European Council on 13 March.
     
The idea behind this is eminently sensible: to ensure that C-ITS services – which are already being deployed anyway – work coherently with one another now, and in the future. In a joint letter to 
     
The Car 2 Car Communication Consortium points to research which shows that C-ITS-based warning systems can reduce intersection collisions by more than 50%. It welcomes the advent of a regulatory framework “because it is providing interoperable and predictable boundary conditions. Those conditions will secure investment in road safety and enable long-term planning for all the relevant stakeholders, like vehicle and infrastructure manufacturers, including their supply base, and the road authorities”. 
     
So far, so good. There is broad agreement for what the EC is trying to do because it does not make sense to have a patchwork of diverging, non-interoperable solutions across Europe, and because no-one wants to make multi-million euro investments now which will be wasted in a decade’s time. But there are many competing communications protocols and a variety of differing thoughts about the proposals. “It has got a little tribal recently,” one industry insider told ITS International.
     
 
Tech neutrality
     
Every vehicle is meant to be able to speak to another vehicle plus relevant infrastructure. That means the legislation must take into account what is being deployed now – so even if today’s cars last 15 years, today’s roadside equipment will still be able to communicate with their replacements in 15 years’ time.
     
As far as one can see, the C-ITS Delegated Act will not exclude any future technology because being tech-neutral is vital for the legislation to make sense. The European Commission’s own 5G Action Plan has already made this clear: “Where appropriate, 5G will operate in seamless co-existence with technologies already being deployed.”
     
The 5G Automotive Association (5GAA) does not see it that way, however, voicing concern about the status of cellular Vehicle to Everything (C-V2X or LTE-V2X). “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-based (IEEE 802.11p – derived from Wi-Fi) communications, excluding other available and mature technologies such as LTE-V2X (both for direct short-range or long-range communications),” it said in a submission.
     
5GAA insists that the Act “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”.
     
Above all, it emphasises that LTE-V2X is the only platform which offers a “clear evolutionary roadmap” towards 5G for connected vehicles and road infrastructure. 
     
At present, the organisation is concerned that the text of the regulation “still only foresees the initial deployment of these services exclusively via ITS-G5 for short-range communication”.
 
     
 
Potential concerns
     
But  5GAA is concerned that “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”. 
     
It  wants that responsibility to be shared and says the regulation should  include LTE-V2X short-range and long-range communications “on an equal  footing with ITS-G5”.
     
But,  of necessity, it seems logical that the Act will have to reference  standards of available and proven technologies. Car makers such as VW,  and ITS providers like Kapsch, are obviously looking into the  possibilities of 5G. As things stand, C-V2X, for instance, would be  included for C-ITS – but only when it is tested and standardised.
     
Among  the other potential concerns for operators when it comes to the scope  of the legislation are potential interference with radio signals and  loss of tolling revenue.
     
On  the subject of spectrum, for example, the European Automobile  Manufacturers Association (ACEA) thinks C-V2X should run on 3.4-3.8 GHz  as a redundancy system, backing up ITS-G5. “ITS-G5 and LTE-V2V interfere  with each other if operated on the same frequency channel because there  are differences between the wireless systems,” it says in a position  paper. “To foster ITS applications using the 5.9 GHz frequency band  regardless of technology, coexistence methods between available  technologies should be developed (i.e. several technologies can be  co-located on the same frequency channel).”
     
This  would be in line with the EC’s technology-neutral principle and would  be the “most spectral efficient”. The European Telecommunications  Standards Institute (ETSI) has made “significant efforts in finding a  coexistence method”, it continues, adding that installation of 5.9 GHz  equipment including antennas in vehicles is crucial regardless of  wireless technology. 
     
LTE-V2X  and/or ITS-G5 in the 3.4-3.8 GHz and/or 5.9 GHz bands can introduce  redundancy for serving connected and automated vehicles (C/AVs), while  V2X applications in need of redundancy can run applications on one or  two technologies on well-separated frequency channels, ACEA says.  Furthermore, it suggests that using two different frequency bands will  provide extra robustness to the overall V2X system, pointing out that  line-of-sight sensors such as radar and camera provide such back-up for  different applications.
     
In  short, Europe’s car manufacturers support investigation and research  into additional use of V2X technologies at a carrier frequency between  3.4 and 3.8 GHz, ACEA concludes.
     
 
Future updates
     
Meanwhile,  
     
The  organisation insists that future updates to the Delegated Act must  ensure that C-ITS and electronic road charging systems “can co-exist  without harmful radio interference”. Outlining the responsibilities of  motorway operators – primarily to ensure road safety for users – it  urges EU institutions “to only consider reliable technologies, once they  have been publicly tested, in order to guarantee compliance with  existing legislation (road charging, drive and rest time, weights and  dimensions)”. 
     
ASECAP  concludes: “Road charging is essential for the financing of motorway  development and maintenance and keeping Europe’s road network safe. Only  proven technology can assure that we can keep our roads safe.”
     
The  C-ITS Delegated Act might be best thought of as the start of a major  debate over where the ITS industry – and C/AVs in particular – are  headed in Europe. Yes, there is disagreement around specifics, but there  is also significant common ground. “We welcome any mature short-range  technology into the C-ITS communication ecosystem,” the industry source  told ITS International. “It’s not about freezing things out, it’s  enabling existing technology to be deployed in a secure, interoperable  and backward-compatible manner, which simply is necessary if we talk  road safety and long product cycles.”
 
     
         
         
        



