On August 16, 2024, the U.S. Department of Transportation (the “USDOT”) announced the Saving Lives with Connectivity: A Plan to Accelerate V2X Deployment plan (the “Plan”). The Plan is intended to “accelerate the deployment” of vehicle-to-everything (“V2X”) technology and support USDOT’s goal of establishing a comprehensive approach to roadway fatality reduction. The Plan states that USDOT is “pursuing a comprehensive approach to reduce the number of roadway fatalities to the only acceptable number: zero.”

The Plan describes V2X technology as technology that “enables vehicles to communicate with each other, with road users such as pedestrians, cyclists, individuals with disabilities, and other vulnerable road users, and with roadside infrastructure, through wirelessly exchanged messages.” Such messages may contain information about vehicles’ location and actions and traffic conditions like weather, pavement conditions, work zones, and more. The Plan notes that currently deployed V2X technology has already demonstrated safety benefits on a small scale and calls for expanded deployment of such technology.

In a press release accompanying the Plan, U.S. Secretary of Transportation Pete Buttigieg said, “The Department has reached a key milestone today in laying out a national plan for the transportation industry that has the power to save lives and transform the way we travel … The Department recognizes the potential safety benefits of V2X, and this plan will move us closer to nationwide adoption of this technology.”

The Plan’s key points are summarized below:

  • Mission: The Plan states that its mission is to “[a]ccelerate the deployment of secure, interoperable V2X connectivity…through collaboration across the federal government, public sector, and private industry.”
  • Goals and Targets: The Plan lays out short-, medium-, and long-term goals covering the next twelve years.
    • The short-term goals, intended to be addressed by 2028, include deploying V2X technology across 20% of the National Highway System and enabling V2X technology in 25% of the top 75 metro areas’ signalized intersections. The short term goals also establish initial steps for establishing spectrum commitment, interoperability standards, and programs for technical assistance.
    • The medium term goals, intended to be addressed between 2029 and 2031, include increasing the coverage of both the National Highway System and top 75 metro areas’ signalized intersections to 50%, finalizing spectrum rules and provisions with the Federal Communications Commission, and further progress on interoperability standards and technical assistance plans.
    • The long-term goals, intended to be addressed between 2032 and 2036, include further increases to coverage numbers, use cases across broader parts of the spectrum, expanded interoperability use cases, and more.
  • Secure Deployment: The Plan notes that successful V2X deployment requires “cyber resilience” to ensure that communications services remain available and that users trust the technology. The Plan advocates for “secure by design” principles, meaning that cyber and privacy risks should be considered from the outset when developing and deploying V2X technology. The Plan references the USDOT’s ITS Cybersecurity Research Program’s resources for guidance on implementing cybersecurity and privacy principles in a clear and practical way.
  • Interoperable Deployment: The Plan states that interoperability – or the ability for a range of mobile, in-vehicle, and roadside devices to communicate with each other – is “crucial” to the V2X vision. The Plan notes that the USDOT’s standards and architecture includes the National ITS Reference Architecture, which provides a framework for safe, secure, and effective interoperable systems. The Plan states that the USDOT is committed to defining and demonstrating V2X interoperability testing procedures.
  • Benefits and Challenges: The Plan states that the benefits of V2X technology have been “widely documented,” including NHTSA estimates about the ability of vehicle-to-vehicle technology (a subset of V2X technology) to prevent crashes and save lives. The plan also cites studies showing that the technology prevented crashes and can reduce CO2 emissions. However, the Plan notes that V2X technology faces challenges related to spectrum use, private industry participation, public agency capacity and funding, and the ability to document benefits from near term deployments.

As next steps, the USDOT plans to coordinate resources from across federal agencies, including the Federal Highway Administration, the Intelligent Transportation Systems Joint Programing Office, the Federal Transit Administration, and others to support government deployment of V2X technology. The Plan also states that the USDOT will develop V2X technical assistance and supporting documentation to assist deployers like original equipment manufacturers and infrastructure owner-operators.

Photo of Jennifer Johnson Jennifer Johnson

Jennifer Johnson is a partner specializing in communications, media and technology matters who serves as Co-Chair of Covington’s Technology Industry Group and its global and multi-disciplinary Artificial Intelligence (AI) and Internet of Things (IoT) Groups. She represents and advises technology companies, content distributors…

Jennifer Johnson is a partner specializing in communications, media and technology matters who serves as Co-Chair of Covington’s Technology Industry Group and its global and multi-disciplinary Artificial Intelligence (AI) and Internet of Things (IoT) Groups. She represents and advises technology companies, content distributors, television companies, trade associations, and other entities on a wide range of media and technology matters. Jennifer has almost three decades of experience advising clients in the communications, media and technology sectors, and has held leadership roles in these practices for almost twenty years. On technology issues, she collaborates with Covington’s global, multi-disciplinary team to assist companies navigating the complex statutory and regulatory constructs surrounding this evolving area, including product counseling and technology transactions related to connected and autonomous vehicles, internet connected devices, artificial intelligence, smart ecosystems, and other IoT products and services. Jennifer serves on the Board of Editors of The Journal of Robotics, Artificial Intelligence & Law.

Jennifer assists clients in developing and pursuing strategic business and policy objectives before the Federal Communications Commission (FCC) and Congress and through transactions and other business arrangements. She regularly advises clients on FCC regulatory matters and advocates frequently before the FCC. Jennifer has extensive experience negotiating content acquisition and distribution agreements for media and technology companies, including program distribution agreements, network affiliation and other program rights agreements, and agreements providing for the aggregation and distribution of content on over-the-top app-based platforms. She also assists investment clients in structuring, evaluating, and pursuing potential investments in media and technology companies.

Photo of Andrew Longhi Andrew Longhi

Andrew Longhi advises national and multinational companies across industries on a wide range of regulatory, compliance, and enforcement matters involving data privacy, telecommunications, and emerging technologies.

Andrew’s practice focuses on advising clients on how to navigate the rapidly evolving legal landscape of state…

Andrew Longhi advises national and multinational companies across industries on a wide range of regulatory, compliance, and enforcement matters involving data privacy, telecommunications, and emerging technologies.

Andrew’s practice focuses on advising clients on how to navigate the rapidly evolving legal landscape of state, federal, and international data protection laws. He proactively counsels clients on the substantive requirements introduced by new laws and shifting enforcement priorities. In particular, Andrew routinely supports clients in their efforts to launch new products and services that implicate the laws governing the use of data, connected devices, biometrics, and telephone and email marketing.

Andrew assesses privacy and cybersecurity risk as a part of diligence in complex corporate transactions where personal data is a key asset or data processing issues are otherwise material. He also provides guidance on generative AI issues, including privacy, Section 230, age-gating, product liability, and litigation risk, and has drafted standards and guidelines for large-language machine-learning models to follow. Andrew focuses on providing risk-based guidance that can keep pace with evolving legal frameworks.

Photo of Conor Kane Conor Kane

Conor Kane advises clients on a broad range of privacy, artificial intelligence, telecommunications, and emerging technology matters. He assists clients with complying with state privacy laws, developing AI governance structures, and engaging with the Federal Communications Commission.

Before joining Covington, Conor worked in…

Conor Kane advises clients on a broad range of privacy, artificial intelligence, telecommunications, and emerging technology matters. He assists clients with complying with state privacy laws, developing AI governance structures, and engaging with the Federal Communications Commission.

Before joining Covington, Conor worked in digital advertising helping teams develop large consumer data collection and analytics platforms. He uses this experience to advise clients on matters related to digital advertising and advertising technology.