Protect Your Privacy and Save Money by Telling NHTSA No to the Vehicle-to-Vehicle Communications Mandate

Comments on the National Highway Traffic Safety Administration’s proposed vehicle-to-vehicle communications mandate are due next on Wednesday, April 12. This is one of the rules that was published just before President Trump was inaugurated. If approved, it will be one of the most expensive vehicle safety rules ever, adding around $300 dollars to the price of every car, or (at recent car sales rates) well over $5 billion per year. 

Despite the high cost, the NHTSA predicts the rule will save no more than 31 lives in 2025, mainly because it will do little good until most cars have it. Yet even by 2060, after consumers have spent well over $200 billion so that virtually all cars would have it, NHTSA predicts it will save no more than 1,365 lives per year. 

The danger is not that it will cost too much per life saved but that mandating one technology will inhibit the development and use of better technologies that could save even more lives at a lower cost. The technology the NHTSA wants to mandate is known as dedicated short-range communications (DSRC), a form of radio. Yet advancements in cell phones, wifi, and other technologies could do the same thing better for less money and probably without a mandate.

For example, your smartphone already has all the hardware needed for vehicle-to-vehicle communications. Since more than three-fourths of Americans already have smartphones, mandating similar technology in new cars is redundant. Since that mandate will take more than a decade to have a significant impact on highway safety, NHTSA could see faster implementation using smartphones instead. It could do so by developing an app that could communicate with cars and provide extra features on the app that would encourage people to download and use it.  

All of the benefits claimed for the DSRC mandate assume that no other technology improvements take place. In fact, self-driving cars (which will work just as well with or without vehicle-to-vehicle systems) will greatly reduce auto fatalities, rendering the projected savings from vehicle-to-vehicle communications moot.

A mandate that one technology be used in all cars also opens the transportation system to potential hackers. The communications would necessarily be tied to automobile controls, which means that anyone who understands it could take control of every car in a city at once. If individual manufacturers were allowed to develop their own technologies, the use of multiple systems would make an attack both more difficult and less attractive.

There is also a privacy issue: vehicle-to-vehicle also means infrastructure-to-vehicle communications, raising the possibility that the government could monitor and even turn off your car if you were doing something it didn’t like, such as drive “too many” miles per year. That’s a very real concern because the Washington legislature has mandated a 50 percent reduction in per capita driving by 2050. Oregon and possibly other states have passed similar rules.

Comments on the proposed rule can be submitted on line or mailed to:

Docket Management Facility, M–30
U.S. Department of Transportation
West Building, Ground Floor, Rm. W12–140
1200 New Jersey Avenue SE.
Washington, DC 20590.