Industry Canada is proposing to allocate the 5850-5925 MHz band for intelligent transportation systems, but the 407 ETR Concession Company Ltd. has some reservations about the proposed move. While the group generally supports such an allocation, it wants the department to address some of its concerns. The following is an edited excerpt of the group’s submission to Industry Canada as part of a larger review of the 3-30 GHz band (DGTP 001-02) launched earlier this month. Currently 407 ETR operates an all-electronic tolling operation on the Ontario Canada Highway 407. This tolling system is fully open road with no plazas or toll stations. It is our understanding that one of the proposed uses for the new band is a replacement for the current 915 MHz Electronic Toll Collection (ETC) systems. While new intelligent transportation system (ITS) applications may be ideally suited for this new frequency allocation, its use in ETC applications has not been demonstrated to our satisfaction. Before the new DSRC ITS can be considered for use, it must provide the same level of security protection of customer identity and privacy, and the same level of communication performance as the existing system. Currently 407 ETR uses the American Society for Testing and Materials version 6 protocol DSRC at 915 MHz, indeed our entire business model and legal requirements rely on its integrity. Impact on Highway 407 Tolling The 407 ETR is not alone in its concerns about the impact of a switch from the 915 MHz band to the 5900 MHz band. All ETC systems in North America operate in the 915 MHz band. If these systems are required to move to the band at 5900 MHz, all toll operators and toll equipment manufacturers will be affected. In North America, there are over 10 million 915 MHz transponders in use and over 140 tolling agencies that operate ETC systems that use these devices. In addition to the agencies, the manufacturers of equipment used in this band are also concerned about a potential band change. The toll agencies’ representative, IBTTA, formed a task force to address the concerns. IBTTA in turn hired Highway Electronics to develop a specification defining the ETC requirements that must be met in the 5900 MHz devices and its interface with ETC support equipment (loops, treadles, cameras, light curtains, lane controllers). Highway Electronics also represents IBTTA at the ASTM 5900 MHz meetings where writing groups are creating standards for the new band. The toll equipment manufacturers (Mark IV, Sirit, Amtech, Tanscore, Raytheon) formed a DSRC manufacturer’s consortium to address the performance requirements for ETC equipment. All members of the consortium regularly attend the ASTM 5900 MHz meetings. These groups and representatives are tasked with minimizing the impact on ETC systems that would occur with a band switch. Highway Electronics, the DSRC Consortium, and the IBTTA have met with the Department of Transportation’s Federal Highway Administration (FHWA) and has been assured that the FHWA will not support any ITS band standard that does not support ETC operations. Further the FHWA is requiring that the ASTM writing groups define an industry acceptable migration path and method that can be used if and when the band switch occurs. Since this migration path and method has not been completed it is not possible to fully define the impact on 407 ETR. However, one requirement being placed on the ASTM writing group is to provide a migration method wherein only the communications devices are changed and no change is required to the tolling support equipment use in the lanes. Also, they require that a backward compatibility method be defined so that existing 915 MHz transponders can be used until they are replaced, because of age (battery failure) or when the tolling customer purchases a vehicle that contains the ITS band on-board unit and the 915 MHz transponder is no longer required. 407 ETR also subscribes to these requirements. The full 407 ETR Concession Company Ltd. submission, along with several others on the 3-30 GHz consultation, can be accessed here.