In this document sections, the NGMN V2X Task-Force team has outlined its feedback on the "Notice of Proposed Rule Making of US Department of Transportation / NHTSA". This feedback provides information on elements of NHTSA’s proposed rules that are supported by NGMN as well as improvements and changes to other elements of the proposed rules.
As elaborated in the following sections, the NGMN V2X Task Force recommends USDOT be technology neutral in the rule making as cellular technologies beginning with 3GPP Release 14 could offer a technical and market-driven solution with a clear evolution path. We view this capability as a technology option that could be deployed well within the deployment horizon envisioned in NHTSA’s proposal and also be compatible with 5G as that deployment matures. This solution appears preferable by many measures including better technical performance, improved cost-efficiencies, and its flexibility to adapt to a variety of business models.