Gazette Notice SMSE 007-12 Consultation on a Policy, Technical and Licensing Framework for Use of the Public Safety Broadband Spectrum in the Bands 758-763 MHz and 788-793 MHz (D Block) and 763-768 MHz and 793-798 MHz (PSBB Block) Published in the Canada Gazette, Part 1 dated 24 August 2012 Comments of Bell Mobility Inc. 24 October 2012
1.0 EXECUTIVE SUMMARY 1. In accordance with the procedure set out in Industry Canada (or the Department) Notice No. SMSE-007-12, Consultation on a Policy, Technical and Licensing Framework for Use of the Public Safety Broadband Spectrum in the Bands 758-763 MHz and 788-793 MHz (D Block) and 763-768 MHz and 793-798 MHz (PSBB Block), as published in the Canada Gazette, Part 1, 24 August 2012 (the Notice), Bell Mobility (Bell or the Company) is pleased to provide the following comments in response to the Notice. 2. Bell appreciates and welcomes the opportunity to provide comments on such an important matter. 3. Bell supports access to additional public safety broadband spectrum as this will enable the public safety community to ensure that a robust interoperable network is available in times of emergencies. Further, access to additional spectrum could afford public safety agencies with wireless broadband capability providing them with needed reliable and secure wireless data/video broadband capability when responding to given high impact emergency situations. 4. Bell offers the following key points for the Department s consideration: - Bell fully supports the allocation of the 700 MHz D Block to public safety for broadband use. - As the U.S. has made the decision to allocate the D Block spectrum to public safety for broadband use, Bell believes that Canada should follow suit. - Interoperability, priority access and pre-emption remain key considerations for public safety entities in Canada. - A single public safety entity should hold the 700 MHz licence. Adoption of such a licensing approach would ensure that interoperability as well as priority access and pre emption capabilities for public safety entities are addressed. - IC should encourage these entities to deploy the LTE technology/standard that has been adopted in the U.S. Use of the LTE standard would also serve to ensure that technical issues related to interoperability, priority access and pre-emption would be effectively dealt with. - In order to ensure that the network is available to first responders in times of emergencies, the network should only be made available to Category 1 and 2 users.
- 2 - Lower priority users such as those captured in the Department s Category 3 definition should only have access to the network in times of emergencies. - The D Block spectrum should be assigned for use by a single public safety network entity and not auctioned. - Public safety should be held to similar deployment roll-out obligations as commercial operators and if unfulfilled the spectrum should be returned to Industry Canada for competitive licensing. 5. For convenience and ease of reference Bell will address the issues raised by the Department for comment in the order of their appearance in the Notice. PART A POLICY AND TECHNICAL FRAMEWORK FOR USE OF THE D BLOCK 4. Designation of Use for the D Block A-1 Comments are being sought on Industry Canada s proposal to designate the D Block (758-763 MHz and 788-793 MHz) for public safety broadband use. 6. In Bell s response to Industry Canada s Notice No. SMSE 018-10, Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects related to Commercial Mobile Spectrum the Company recommended that Industry Canada defer its consideration, decision and licensing of D Block spectrum until the situation in the U.S. had been resolved and a firm decision rendered. The rationale being, that due to the key issue of cross-border interoperability between first responders and due to our close proximity/relationship and size of the U.S. market, that public safety equipment and device development within the 700 MHz band would be driven primarily by the U.S. 7. As the U.S. has since rendered its decision (22 February 2012) and decided to allocate the D Block spectrum for public safety broadband use Bell believes that the Department should follow suit. The consultation further seeks comments as to whether the previously allocated 763-768 MHz 793-798 MHz PSBB should be combined with the D Block spectrum to allow public safety to utilize the entire 10 + 10 MHz block for broadband applications. 8. Bell remains of the view, that the 10 MHz allocation (D Block - 5 + 5 MHz) at 700 MHz should be able to satisfy future public safety mission critical broadband requirements. The
- 3 - PSBB band 793 798 MHz should also be made available to public safety for broadband deployment. A-2 Comments are being sought on Industry Canada s assumptions concerning the commercial equipment availability for the D Block (i.e. that consumer devices will not be readily available). 9. As far as the availability of commercial base station equipment is concerned, Bell does not anticipate that this would be an issue, although getting a vendor to do production runs on small quantities may pose an economic penalty. 10. Bell expects that user equipment (UE) devices will be of most concern. 11. The major chipset vendors have indicated that support of LTE Band 14 will not be available for some time, primarily due to required inherent changes in the hardware. While they indicate that minimal changes would be required to current modem hardware and software, the redesign of RF chipsets, filters and antennas would be more problematic. Support for multiple 700 MHz bands on one device would be particularly challenging, and you are more likely to see 700 MHz D Block mixed with some other band (such as 850, AWS or PCS). 12. Generally speaking manufacturers are going to develop devices in the band where there is demand. This will most likely be driven by the commercial carriers and their related spectrum. 13. Due to device economics, the selection of devices will be much smaller, they will arrive later to market, and they will cost more than their commercial equivalents. This will drive a need to aggregate handset volume across all public safety users through a centrally managed entity. More specifically this group should be responsible for device specification and Original Equipment Manufacturer (OEM) procurement, product development, product qualification and a maintenance support process. 14. Given the limited amount of available public safety spectrum the result will be significantly higher prices for equipment using this band than the portion of 700 MHz spectrum being used by commercial carriers. 15. The public safety space devices are/will be available in the next 12 to 24 months that will support operability in the D Block. These devices will be consumer-like, but initially geared
- 4 - specifically to public safety/mission critical users. They will not be available in store front locations for the general consumer and they will have proprietary implementations of some features that will not be part of the LTE standard. 16. Bell s view is that the first true LTE products will be USB sticks available commercially in the first half of 2014. Smartphones would not appear until the end of 2014 or early 2015 in very limited selection, and we would not expect to see an iphone supporting this RF combo as it is too much of a niche market for Apple. 17. One challenge that should be considered when deploying and managing an LTE network is SIM card management. SIM cards must be supplied, programmed and activated. Manufacturers for these devices move large volumes (100K plus at a time) - much more than what would be required for public safety nationally. Getting access to these at a reasonable price point may be difficult. A-3 As stated above, responses to the 700 MHz consultation indicated that there was no support for the option of designating spectrum for commercial use with obligations to serve public safety. Does this view still apply for the D Block? 18. The option of designating the D Block spectrum for commercial use wherein the commercial entity would be required to construct and operate a shared wireless broadband network that would be used by public safety users as well as commercial users with obligations to serve public safety on a pre-emptible basis is in Bell s view not feasible. Such an approach was not accepted as a viable option in the U.S. as there were too many variables and uncertainties associated with the use of the spectrum. 19. Therefore, Bell believes that as is the case in the U.S. that the D Block should be allocated to public safety for broadband based applications and services.
- 5 - PART B USE OF THE 700 MHZ SPECTRUM DESIGNATED FOR PUBLIC SAFETY BROADBAND 5. Access to the Spectrum Designated for Public Safety (Categories of Users) B-1 Under what circumstances should Category 2 users have access to the 700 MHz public safety broadband network (e.g. for day-to-day operations, only in emergencies)? B-2 In the context of the 700 MHz public safety broadband network, which entities/organizations should be covered under Category 3? 20. Bell believes that the 700 MHz broadband network should only be accessible to Category 1 and 2 users on a regular basis. Category 3 users, which are made up of other government agencies and certain non-governmental organizations or entities, should be directed to use commercial facilities for their day-to-day operation. This would ensure that the 700 MHz broadband network is available to Category 1 and 2 users in the event of an emergency. Further, limiting access to key Category 1 and 2 users will also ensure that the network has sufficient capacity available to fully meet present and future public safety needs. B-3 Under what circumstances should Category 3 users have access to that network (e.g. for day-to-day operations, only in emergencies)? 21. Bell believes, that Category 3 users should only be allowed to use the network in the event of emergencies. 6. Commercial Use of Spectrum in the 700 MHz Band Designated for Public Safety B-4 Should Industry Canada permit any commercial use of unused capacity in the 700 MHz spectrum designated for public safety broadband? 22. In Bell s view, Industry Canada should not permit any commercial use of unused capacity in the 700 MHz spectrum designated for public safety broadband. 23. Should the Department allow the commercial use of unused capacity in the 700 MHz public safety band, this spectrum should be made available through a competitive licensing process and held by commercial operators directly. This will insure that a clear distinction is made between commercial and public safety uses.
- 6 - B-5 Whose needs must be met before 700 MHz spectrum designated for public safety broadband can be used for commercial services? 24. Bell does not believe that commercial services should be allowed in this spectrum see response to Question B-4. B-6 Should commercial services, i.e. services with purposes other than protection of life and property, be restricted to users that fall under the public safety categories described in Section 5? 25. Bell does not believe that commercial services should be allowed in this spectrum see response to Question B-4. B-7 Should the licensee or licensees be permitted to provide commercial services directly to the public? 26. Bell does not support the notion of a licensee or licensees to be permitted to provide commercial services to the public. Such a situation provides an unlevel playing field for which spectrum awarded to a licensee can compete with those licensees who have had to acquire spectrum through competitive auction licensing processes. The designation of the 700 MHz public safety broadband should restrict its use to public safety activities only. B-8 Should the licensee or licensees be permitted to wholesale unused capacity to a commercial operator? 27. Bell believes that the licensee or licensees should not be permitted to wholesale unused capacity to a commercial operator. Bell is of the view, that allowing public safety to wholesale any unused capacity creates an unlevel playing field. One of the main reasons that this spectrum is being made available to public safety is to ensure that first responders have access to a state of the art interoperable wireless network operating in a prime piece of spectrum in times of emergencies. The 700 MHz band is considered to be extremely valuable spectrum and if the spectrum is not being used for its intended purpose of serving the public safety community, the spectrum should returned to Industry Canada for competitive licensing. 28. Bell is of the view, that the network should be utilized for its intended purpose and there is no requirement to wholesale any unused capacity to a commercial operator as this requirement is currently being filled by existing commercial systems.
- 7 - B-9 Should there be other limits to any commercial use (e.g. should such use be limited to particular amounts of time and throughput, or to specific geographic areas)? 29. As outlined in our responses above, Bell does not support the concept of commercial use of the 700 MHz public safety broadband spectrum. 7. Priority Access and Pre-emption If Industry Canada decides to allow some commercial use in the 700 MHz spectrum designated for public safety broadband use, then: B-10 Which mechanism or mechanisms (e.g. priority access, pre-emption, or others), if any, would have to be in place to ensure that the public safety community s communications requirements are met? 30. Although Bell believes that commercial use should not be allowed in this band, the question of mechanisms for providing priority is still relevant to manage user levels within the public safety community on the public safety network or on a commercial network. Two mechanisms exist within LTE to manage access to the radio resources: - Access class barring provides the ability to grant priority access to users during mobile originations only. This will allow for priority handling during initial setup. - Once initial setup is achieved, then priority can be given to the allocation of bearer resources through the use of the Allocation and Retention Priority parameter. Fifteen levels of priority can be defined that can grant priority on a per user, per service or a per user/per service basis. Higher priority users/services would be assigned a lower ARP value and given pre-emption abilities. Conversely, lower priority users/services would be assigned a higher ARP value with pre-emption vulnerabilities. B-11 Should Industry Canada mandate such a mechanism or mechanisms? 31. Rather than mandating a specific mechanism, an alternative would be to insure the efficient use of spectrum which would encompass best practices related to radio congestion mitigation techniques such as priority access as well as deployment. 32. A single entity holding the licence and governing how the spectrum is utilized would serve to ensure interoperability as well as priority access and pre-emption.
- 8-8. Radio Interoperability 33. Communications interoperability to enable various public safety entities to communicate across various jurisdictions, in order to exchange voice and data with one another, via a radio communication system, continues to be a key issue and a critical requirement for public safety in both Canada and the U.S. 34. While Bell does not have any specific technical measures to suggest that Industry Canada consider mandating to address the issue of interoperability, we do offer the following for the Department s consideration: - Bell notes that Canadian public safety entities are making extremely good progress in this regard as is evident in the ongoing work being carried out in the Canadian Interoperability Technology Interest Group (CITIG). - The U.S. has also tasked the Emergency Response Interoperability Center (ERIC) with studying and making recommendations on the issue of interoperability between public safety entities. - The U.S. has recently decided and designated the use of the LTE-FDD technology standard for all public safety users proposing to use the 700 MHz band. - The Canadian public safety community has made the concerted effort to obtain spectrum which matches the U.S., and it is in their best interest to likewise match technologies. Adoption of the same standard as the U.S., would allow public safety entities to have interoperability capability when dealing with any given emergency situation (both at the Canada/U.S. border and during any domestic event). - Bell believes that existing interoperability issues could be minimized by the adoption of the same LTE technology standard in Canada, and that any technical and organizational impediments and shortcomings of the standard would best be resolved by representation to standards bodies through joint Canadian/U.S. public safety contributions. 35. Bell does not believe that technical standards should ever be mandated as this restricts innovation. However, given the organizational complexity of the public safety community, Bell would suggest that the Department strongly encourage public safety entities planning to use the 700 MHz band to adopt the same standard as in the U.S.
- 9 - B-12 Which technical measure or measures, if any, should Industry Canada consider mandating to address radio interoperability requirements? 36. Bell is of the view, that licensing of a single public safety governing body for the 700 MHz broadband spectrum should ensure interoperability and that there should be no requirement to mandate further technical measures. B-13 Should Industry Canada mandate a specific technology? If so, under which standard or standards? 37. Bell believes that licensing of a single public safety governing body for the 700 MHz broadband spectrum should ensure interoperability and meet the priority access and preemption requirements of the public safety community. There should be no requirement to mandate further technical standards. PART C LICENSING OPTIONS FOR THE 700 MHZ SPECTRUM DESIGNATED FOR PUBLIC SAFETY BROADBAND USE (PSBB BLOCK AND D BLOCK) 9. Licensing of 700 MHz Spectrum Designated for Public Safety Broadband Use C-1 Comments are being sought on Industry Canada s proposal to assign the 700 MHz broadband public safety licences (the PSBB block and potentially the D Block) directly to one or more PSNEs, rather than via an auction with obligation to serve public safety. 38. Bell believes that the 700 MHz broadband public safety licences (PSBB and potentially the D Block) be assigned directly to a single Public Safety Network Entity (PSNE) and, if required, subordinated to regional public service entities rather than via an auction process with the overarching obligation to serve the public safety community within a reasonable period of time. 39. In the event that the spectrum is subordinated, we believe that the PSNE must ensure that these regional entities will abide by the requirements of the PSNE and deploy the spectrum in a manner that will ensure timely deployment of the network along with complete interoperability for all public safety users under their purview.
- 10-40. Further, public safety should be held to similar deployment roll-out obligations as commercial operators and if unfulfilled, the spectrum should be returned back to Industry Canada for competitive licensing. This provides the necessary governance to insure that valuable spectrum is not being wasted. C-2 If capacity for commercial use were allowed, would this change the response to Question C-1? 41. Bell remains of the view, that given the U.S. experience with the auction of the D Block/commercial use of the spectrum, that the spectrum be allocated and used exclusively for public safety broadband users. C-3 If assigned via auction, given the U.S. experience with the auction of the D Block, what considerations are critical to increase the likelihood of timely deployment of a public safety network? 42. See response to Question C-2 above. 10. Eligibility C-4 Based on the proposal in Section 9.3, should Industry Canada assign a single licence to a national PSNE or multiple licenses to provincial, territorial and or regional (e.g. multiple provinces? PSNEs? 43. Bell believes that in order to ensure the successful deployment of the 700 MHz public safety spectrum that Industry Canada should assign a single licence to a national PSNE. The national PSNE should in turn, then be able to subordinate the licence with the condition and responsibility to deploy the spectrum to each of the 13 regional entities. This would ensure that sufficient controls exist to ensure that the spectrum is deployed and utilized in a timely manner. 44. Bell further believes, that any further sub-licensing would carry the added risk that the spectrum would not be utilized and deployed efficiently, effectively or in a timely manner. C-5 Which criteria should be used to assess whether a PSNE is eligible to hold a licence? (A) Should the PSNE be required to represent the permitted categories of users, taking into consideration that the categories include municipal, provincial, territorial and national agencies?(see Section 5 for discussion on categories of
- 11 - users.) Specifically, should the PSNE represent Category 1 users only? Category 1 and 2 users only? Category 1, 2 and 3 users? 45. Bell is of the view that the PSNE should endeavour to represent the widest possible users. Such representation would ensure that the PSNE has buy-in from those entities that are engaged in public safety activities. Representation by a single PSNE should promote the consistent implementation of technology and lessen the need to mandate a given technology. 46. It should further be noted, that in terms of which of the Department s category of users should specifically be represented by the PSNE, it is our view that the public safety broadband spectrum be used primarily by Category 1 or 2 users. Lower priority users/traffic should be carried on commercial systems. This would ensure sufficient broadband spectrum capacity is available for first responders for both day-to-day activities and emergency situations. (B) Should the PSNE be required to demonstrate how it will represent the permitted categories of users? 47. It seems reasonable that the PSNE would need to demonstrate how it will be representing the permitted categories of users. (C) Must the PSNE be endorsed by certain national, federal, provincial and territorial organizations responsible for public safety and emergency management (e.g. Public Safety Canada, Senior Officials Responsible for Emergency Management [SOREM], provincial and territorial emergency management organizations [EMO], the Federation of Canadian Municipalities)? If so, which ones? 48. No comment. All of which is respectfully submitted. *** End of Document ***