Answering the Call. CATAAlliance Comments on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Spectrum for.

Answering the Call CATAAlliance Comments on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Spectrum for Public Safety and Commercial Systems In response to: Canada Gazette, Part 1 Notice No. SMSE-018-10 November 30 2010 February 2011 K. Wennekes & S. Cohn-Sfetcu Canadian Advanced Technology Alliance

Table of Contents Executive Summary... 1 Background... 6 700 MHz Band Plan Issues and Considerations... 9 Responses to SMSE-018-10 Questions in Section 5: 700 MHz Band Plan Issues and Considerations... 12 Conclusions... 35 Appendix A Survey Respondents Appendix B Public Consultation Attendees Appendix C National Teleforum Participants Appendix D U.S.A Wireless Nation Initiative This document, along with the separately included CATAAlliance stakeholder survey report (PDF file titled Answering the Call Broadband for PS Survey Report Feb 2011 ) forms the full basis of our response. Canadian Advanced Technology Alliance i

Executive Summary 1. The Canadian Advanced Technology Alliance (CATAAlliance) 1, Canada s largest hightech association has cooperated with the Tri-Services Special Purpose Committee on 700 MHz Broadband for Mission Critical Public Safety Data representing the Canadian Association of Chiefs of Police (CACP) 2, the Canadian Association of Fire Chiefs (CAFC) 3 and the Emergency Medical Services Chiefs of Canada (EMSCC) 4 in matters of public safety services and has undertaken an extensive series of consultations (online survey, half-day public consultation in Ottawa, National Teleforum) in order to arrive at a judicious and representative industry position on the issues raised by Industry Canada in its SMSE-018-10 Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum. CATAAlliance has also consulted with its umbrella organization member, the Canadian Association of Internet Providers (CAIP) 5 on this submission: formed in 1996, CAIP's Mission is to foster the growth of a healthy and competitive Internet service industry in Canada through collective and cooperative action on Canadian and international issues of mutual interest. 2. Public safety in Canada is threatened by the inability of public safety agency personnel to have reliable access to multi-media information and communicate readily with one another as the situation demands it. Situations demanding such informationcommunication services and coordinated emergency response fires, toxic 1 www.cata.ca 2 http://www.cacp.ca/intro/ 3 http://www.cafc.ca/ 4 http://www.emscc.ca/ 5 http://www.cata.ca/communities/caip/ Canadian Advanced Technology Alliance 1

environmental spills, traffic accidents, acts of terrorism, missing people, etc. - occur daily in all regions of the country and often result in unnecessary loss of life and property. 3. In the Digital Age, loss of life and property may be diminished considerably if public safety agencies could reliably and securely utilize dedicated broadband services. Bandwidth is a finite resource of wireless networks, and its immediate availability for public safety services is a critical issue in times of emergency for police, medical emergency organizations, firefighters and all the other government agencies and civic organizations involved in safeguarding Canadian lives and property. 4. Canada needs adequate broadband radio communication services for public safety operations and it behoves Industry Canada to allocate a nationwide contiguous band of spectrum dedicated to public safety broadband services that (i) provides unimpeded access to authorized public safety personnel throughout the nation and (ii) enables effective and coordinated emergency response through interoperability between various public safety organizations and other emergency services agencies. 5. Public safety requirements for adequate services must govern indubitably the spectrum allocated for its use without dependence on commercial interests to make resource allocations in times of emergencies and crises. 6. The only spectrum available and suitable for public safety broadband radio services is in the 700 MHz band vacated through the conversion of TV broadcasting from analog to digital. This is the only spectrum available in the immediate future with the propagation Canadian Advanced Technology Alliance 2

characteristics suitable for the coverage range and the building penetration required for adequate public safety services. 7. At a minimum, the spectrum band dedicated for public safety broadband radio services should be 20 MHz or more, composed of two separated bands of 10 MHz or more each, collocated with the proposed spectrum allocation for United States public services. Such an allocation stands to achieve two major necessities for effective and efficient public safety services in Canada: Interoperability between Canadian and U.S. public safety agencies along the border regions, some of which are densely populated and economically critical; Much lower costs of equipment and services for Canadian public safety agencies thanks to the significant economies of scale resulting from using the same technical standards throughout the entire North American market. 8. All efforts should be made to adopt the advanced technology platforms of 4 th generation wireless commercial systems updated with the additional proviso of technical standards aimed at ensuring the performance and grade of service (reliability, ruggedness, survivability, immediacy, etc.) necessary for critical public safety operations. 9. Consumer oriented commercial systems do not have the business justification or the technical and operational capabilities necessary to meet public safety mission critical requirements in terms of coverage, availability, reliability, survivability and ruggedness. Therefore, CATAAlliance does not recommend that commercial operators be mandated to support public safety services, as there are no acceptable rules which would make a Canadian Advanced Technology Alliance 3

consumer-oriented commercial system viable for public safety operations in times of large scale emergencies. 10. CATAAlliance proposes that a spectrum band of 20 MHz (10 + 10 MHz) be fully dedicated in the 700 MHz range to public safety broadband radio communications outside of any commercial interests or auction activities. The governance and management of this spectrum band should be undertaken to ensure effective and efficient services in support of public safety organizations throughout Canada. 11. CATAAlliance strongly believes from its work with its membership and Canada's First Responder communities that there will be a need to assign the entire 10 + 10 MHz of spectrum in the 700 MHz band for public safety broadband uses. While the entire 10+10 MHz would not be immediately required, experience with the growth rates in other areas of wireless use has shown how quickly demand picks up once the technology and spectrum are available. CATAAlliance does not believe that the normal commercial service rules, if applied by the group assigned use of the public safety broadband portions of the 700 MHz block, would provide a viable public safety service. In short, a consumer oriented commercial system isn't a viable approach for public safety operations. 12. In the spirit of searching for optimal solutions for the economic and timely deployment of public safety broadband radio services, CATAAlliance is suggesting a potential trade-off approach based on a quasi-commercial usage of the 20MHz public safety spectrum band, which we feel constructively answers the Governance, Technical and Operational Canadian Advanced Technology Alliance 4

issues of public safety operations, while meeting certain advantages in terms of Capital Costs, Timing, Equality of Service and Auction Proceeds. 13. In the same context, CATAAlliance proposes that the dedication of a 20 MHz band of 700 MHz spectrum be associated with a specific policy for enabling effective and efficient usage of the spectrum though enablement of access for the installation of radio equipment on and within public and private infrastructure buildings. 14. CATAAlliance considers that every region (locality, province, etc.) requires presence of an effective and efficient broadband network providing access to all public safety agencies. Such local networks should be part of a nation-wide network characterized by uniform and consistent access to its services thus providing full interoperability among agencies as well as enabling personnel from one region of the country operate in support of emergency activities in another. 15. CATAAlliance considers that interoperability along the border between United States and Canada is of paramount importance and therefore recommends that everything be done to achieve identical collocation of spectrum by the two countries and adoption of same technical standards. 16. CATAAlliance and its members fully understand the issues faced by Industry Canada in the matter of 700 MHz band policy, and appreciate the efforts made to date by Industry Canada to address judiciously both public safety as well as auction-commercial opportunities opened by the migration from analog to digital TV broadcasting. Canadian Advanced Technology Alliance 5

Background 17. Canada is at an important juncture in the development of the country s infrastructure necessary for ensuring the safety of its citizens in the 21st century. Public safety organizations police, fire and medical emergency services must have access anytime anywhere to adequate information and communication tools enabling them to respond timely, effectively, efficiently and safely to calls for action. This requires the availability of broadband wireless digital communications with all the necessary features for public safety operations: priority, reliability, ruggedness, and survival in times of man-made and natural disasters. To achieve this desideratum it is necessary to dedicate adequate spectrum for public safety operations. 18. To respond to the unique opportunity provided by the Industry Canada decision to reassign the 700 MHz band previously dedicated to analog TV broadcasting, the Canadian Association of Chiefs of Police (CACP), the Canadian Association of Fire Chiefs (CAFC), and the Emergency Medical Services Chiefs of Canada (EMSCC) have decided on an unprecedented degree of collaboration among themselves and with Canadian industry represented by the Canadian Advanced Technology Alliance (CATAAlliance) in order to ensure proper consideration of Canadian public safety needs in the dynamic and complex world of the 21st century and to safeguard Canadian economic interests. Ineffective allocation of spectrum poses significant risk as the lack of reliable broadband communication capabilities will directly impact Police, Fire, EMS and other responder agencies and government s ability to fulfill their most important mission over the coming decades. Public safety s needs for the right tools to protect and save lives must be addressed effectively and without hesitation. 19. To date, public safety organizations have been using the old Land Mobile Radio systems which provide basic voice communications. These systems are made by different manufacturers employing proprietary technologies and are not interoperable, thus leading to very serious issues whenever there is need of collaboration between diverse public safety organizations. Police, fire and medical emergency agencies often can t talk with neighbouring services, or the RCMP, the coast guard or the military, not Canadian Advanced Technology Alliance 6

to mention aviation and transport officials, utility crews or the security guards in office and apartment towers. 20. Public safety organizations need a nation-wide strategy to plan and operate public safety communications services having a national governance structure and using common technology standards enabling interoperability and cooperation among emergency organizations at all levels: municipal, regional, provincial, national and cross-border international when necessary. In addition they need clearly marked and dedicated spectrum substantial enough for the implementation of broadband wireless services so necessary for effective public safety in a world beset by climate changes, terrorism and dynamic upheavals. Substantial in the digital world of today and tomorrow means at least 20 MHz of spectrum to enable: Police having access to video surveillance networks of a quality sufficient for effective video analytics, biometric identification, automated recognition of auto plates or people; Medical Emergency organizations having access to high-resolution video telemedicine, patient records, blueprints of disaster areas, etc; Firefighters having ability to view the insides of burning buildings, locate their comrades and monitor their vital signs, and determine the sensitive points of building structures; Any one of them to communicate and share critical information about their tasks at hand, cooperate in progressing them and ensure the safety of the public as well as that of their comrades. 21. A minimum spectrum of 10+10 MHz is necessary in the 700 MHz band to allow the quality, performance (grade of service) and immediacy of public safety services mentioned above. It is quite fortuitous that the spectrum made available by the digitization of TV broadcasting is particularly useful for public service operations as it allows much better service penetration into buildings, longer range and higher quality services at reduced costs of network and device implementations. Canadian Advanced Technology Alliance 7

22. Faced with a global tsunami of traffic generated by on-line search, video applications, banking, voice communications and texting, the wireless industry is embarking on the deployment of the 4th generation wireless networks capable of handling the high service growth predicted for the future. Canadian public safety organizations and CATAAlliance believe that usage of high-volume 4th generation wireless technology combined with the dedication of a minimum of 20 MHz in the 700 MHz band represents a unique opportunity to begin building the next generation of emergency data, video and voice communications for effective and efficient public safety services and continued Canadian leadership in the world. 23. In the meantime, public safety organizations will continue to rely on the aging narrowband Land Mobile Radio systems complementing them whenever possible by other radio systems, including those operating in the 700 MHz band already allocated for voice communications and low-speed data. Canadian Advanced Technology Alliance 8

700 MHz Band Plan Issues and Considerations 24. With more and more complex urbanization, higher sophistication of daily public activities and increased natural and man-made threats to public safety, Canadian agencies will have an increasing need to access data and video networks during all emergency incidents. Government agencies at all levels will need to access broadband data networks during large-scale incidents to coordinate Federal assistance with Provincial/Territorial and local response and recovery operations. Law enforcement organizations will need access to video surveillance networks capable of identifying people through the use of video analytics, extensive criminal records and biometric technologies to prevent and respond to criminal activities. Fire services will need access to building blue prints, health-monitoring sensors and GPS tracking systems in order to save lives and material goods. Emergency medical services will need access to telemedicine, high-resolution video and patient records to reduce the time it takes to deliver medical services at the scene of an incident such as a car crash on a highway. Critical-infrastructure service providers will need to coordinate their activities to restore power and telecommunications services during large-scale incidents. Such services are impossible without an adequate amount of spectrum dedicated to (and capable to sustain) public safety commensurate with the demands and expectation of Canadians and their elected governments. 25. Towards the ends of engaging and allowing as many voices to contribute to this consultation as possible, CATAAlliance worked in collaboration with the tri-service association advisory committee to develop an outreach campaign that included: 1) an open public consultation in Ottawa 6 ; 2) a national Teleforum 7 in February; and, 3) an online consultation survey. The results of these consultations are being used to formulate the present responses to the questions posed by Industry Canada in its SMSE-018-10 consultation paper, and the separately provided CATAAlliance survey results report has been made available as a separate document as added support of 6 http://www.cata.ca/media_and_events/press_releases/cata_pr01111101.html 7 http://www.cata.ca/media_and_events/press_releases/cata_pr02171101.html Canadian Advanced Technology Alliance 9

this submission. The survey report allows an analysis of opinions from different sectors of the industry emergency responders, industry, NGO, and others with vested interests in this issue. 26. It is considered advantageous to ride the commercial wave of 4th generation Long Term Evolution (LTE) wireless technology provided that supplementary measures are taken to ensure that the networks and equipment (including portable devices) operating in the Public Safety dedicated spectrum meet the stringent requirements for anytime anywhere effective public safety services for Canadians. Such requirements include the following, among others: 27. Reliability of the order of 99.9999%; i.e. only a few seconds of downtime during a year because Canada cannot afford to have its firefighters reviving heart attack victims through communication with emergency medical services having their links dropped, nor can Canada afford to have its police officers lose their critical services in times of crisis simply because a commercial service provider decides to do maintenance unaware of the situation. 28. Ruggedness is critical as no public safety officer would rely on a commercial cell phone for communications. The heat, water and toxicity of a fire environment would quickly destroy such equipment, whereas most public safety radios do survive being dropped repeatedly on the ground or being immersed on water for 30 minutes or more. 29. Immediacy of action is essential for public safety. It requires priority of access to the spectrum for public safety officers, which is not possible in the case of commercial systems that treat all customers equally on a first-served basis. Achieving effective public service is not possible if networks get busy and the spectrum gets clogged for other reasons. 30. Survivability; i.e. continued operation in case of disasters is specifically critical for public safety organizations, who cannot afford to use networks which collapse because everyone is on the phone talking or sending pictures/videos of the disaster Canadian Advanced Technology Alliance 10

be it man-made (a shootout at a school, an act of terrorism) or natural (an earthquake or hurricane or floods, etc.). Likewise, if the disaster is affecting the physical integrity of the network (collapse of antenna towers and/or buildings with radio systems, or fire taking network systems out of operation), it should be still possible for public safety organizations to communicate and take action something that is not done by commercial systems but is achieved for emergency services thanks to automatic meshing of the emergency devices or simplex modes of operation ( walkie-talkie ) in the zone of the disaster. 31. None of the above requirements can be met in a consumer oriented commercially controlled spectrum. This is why it is necessary that an adequate portion of the 700 MHz spectrum be dedicated to broadband radio communication services for public safety agencies, which would have exclusive rights to use of this spectrum band or, at a minimum, have pre-emptive priority for its use. 32. CATAAlliance and its members fully understand the issues faced by Industry Canada in the matter of 700 MHz band policy, and appreciate the efforts made to date by Industry Canada to address judiciously both public safety as well as auction-commercial opportunities opened by the migration from analog to digital TV broadcasting. 33. This is why we are suggesting a potential trade-off approach which we feel answers constructively the Governance, Technical and Operational issues, while meeting certain advantages in terms of Capital Costs, Timing, Equality of Service and Auction Proceeds. This option is described in detail as part of our answer to Question 5.6.c. 34. As the CATAAlliance is fully preoccupied with the critical issue of dedicated 700 MHz spectrum for broadband public safety services, we shall focus our attention to the questions you have raised in Section 5 of the SMSE-018-10 Consultation paper. Canadian Advanced Technology Alliance 11

Responses to SMSE-018-10 Questions in Section 5: 700 MHz Band Plan Issues and Considerations 35. Question 5.1 Based on the criteria listed above, which of the four band plan options should be adopted in Canada? Why is this option preferred over other options? If Option 3 (APT band plan) is selected, what should the block sizes be? 36. CATAAlliance considers that a minimum of 20 MHz (i.e. 10 + 10 Mhz) must be dedicated in the 700 MHz band for public safety broadband radio communication services in a manner that allows interoperability between various local, provincial and federal public agencies involved in operations for saving Canadian lives and property. It is also desirable that interoperability can be achieved between Canadian and Unites States public agencies within the border regions. Therefore, CATAAlliance prefers adoption of Industry Canada Option 1with the inclusion of the D block for ensuring 20 MHz of spectrum dedicated to public safety. 37. Such a measure is convergent with the plans of the United States administration as identified in President Obama s National Wireless Initiative launched on February 10 of this year [see Appendix D], and therefore will enable both Canada-U.S. interoperability as well as significant economies of scale as the necessary equipment will be manufactured homogeneously for the entire North American market. 38. By contrast, Options 2a and 2b would impose significant financial burdens on Canada and its public safety agencies, as they require equipment manufactured solely for the small Canadian market. As well, such options may lead to cross-border interference issues which would hamper proper public safety operations in some of the most populated and economically critical areas of the country. 39. Likewise, Option 3 (the APT band plan) would inhibit interoperability between Canadian and U.S. public safety agencies and may lead to cross-border interference affecting public safety operations in some of the most populated and economically critical areas of Canada. Canadian Advanced Technology Alliance 12

40. Question 5.2 The band plans presented in the options above include guardbands. Should the Department auction the guardbands, or should these frequencies be held in reserve for future use such that they are technically compatible with services in the adjacent bands? 41. CATAAlliance considers that the guardbands should not be auctioned in the immediate future, as such guardbands are necessary to protect against interference from commercial services in adjacent spectrum blocks. Such interference is unacceptable for proper public safety operations, especially in areas of high population density, where they would have to operate in the vicinity of commercial tower or microcell sites. 42. At a later time, when public safety broadband radio systems are securely installed and operational and the technology has evolved sufficiently for ensuring non-interference with public safety operations, it may become acceptable to allow careful usage of portions of these guardbands, which then can be put to auction. 43. Question 5.3 Do public safety agencies need spectrum for broadband applications? If so: (a) How much and for which type of applications? (b) What are the anticipated deployment plans and the possible constraints, if any, in implementing these plans? (c) Is there suitable alternate spectrum to the 700 MHz to meet these broadband requirements? 44. (a) CATAAlliance considers that a minimum of 20 MHz (i.e. 10 + 10 MHz) of the 700 MHz band be fully dedicated for Public Safety use in Canada to implement a wide variety of broadband wireless services; e.g. 45. Police having access to video surveillance networks of a quality sufficient for effective video analytics, biometric identification, and automated recognition of auto plates or people. 46. Medical Emergency organizations having access to high-resolution video telemedicine, patient records, blueprints of disaster areas, etc; Canadian Advanced Technology Alliance 13

47. Firefighters having ability to view the insides of burning buildings, locate their comrades and monitor their vital signs, and determine the sensitive points of building structures; 48. Any one of them to communicate and share critical information about their tasks at hand, cooperate in progressing them and ensure the safety of the public as well as that of their colleagues; 49. Other public emergency response organizations being enabled to operate fully and interconnect in coordinates activities with the first response organizations mentioned above. Among such other emergency response organizations one can enumerate Transportation agencies, Search and Rescue Air, Ground, Marine organizations, National Resource organizations (forestry, mining, oil, environmental response, etc.), Border Enforcement agencies, Utilities emergency operations (electricity, gas, water, etc.), Public Works officers, Correction and Sheriff s services, some Health service providers (e.g. hospitals, clinics, etc), Emergency Management organizations, and so on. 50. A minimum of 20 MHz (10 + 10 MHz) in the 700 MHz band appears to be the conclusion of several industry studies of broadband capacity requirements for public safety operations in our age. The results of other independent analysis of broadband capacity requirements including Motorola 8 and Andrew Seybold 9 conclude that a 5+5MHz broadband allocation is insufficient to generally meet the requirements of public safety systems. 51. Multimedia presentations from the Public Safety Alliance in the U.S. are available outlining their own request for additional D Block allocation 10. A video 11 by Alcatel- 8 Based on Motorola analysis results presented to the FCC Office of Engineering and Technology, the Public Safety and Homeland Security Bureau and the Wireless Telecommunications Bureau on April 9, 2010. Presentation filed as public record in Ex Parte by Motorola on April 12, 2010 on WT Docket 06-150 and PS Docket 06-229 9 Comments on FCC White Paper: Federal Communications Commission Ominbus Broadband Initiative, Andrew M. Seybold, Inc., April 26, 2010 10 http://www.psafirst.org/videos 11 http://www.youtube.com/watch?v=cvsqcrwwq48 Canadian Advanced Technology Alliance 14

Lucent in cooperation with the Alexandria Police Department demonstrates data capabilities for first responders using the LTE Public Safety Broadband (PSBB) spectrum in Alexandria, VA. 52. The CATAAlliance survey has overwhelmingly backed the above assertions, with a strong alignment between First Responder groups and Industry, NGO and Other groups concluding that it would be to the detriment of Canada if no action is taken to (i) dedicate at least 20 MHz of the 700 MHz band to public safety and (ii) implement a cross-canada broadband interoperable network supporting public safety operations: 53. Over 80% of both respondent groups either Disagreed or Strongly Disagreed that currently, public safety agencies possessed sufficient broadband capability; 54. While both groups did feel that public safety agencies should have complete control over the governance of dedicated 700 MHz broadband, this was a much more strongly expressed sentiment among the Emergency Response group, with 84% either Strongly Agreeing or Agreeing as compared to 67% among the Industry, NGO and Other groups. This could be explained by the fact that industry respondents felt that governance should not be confused with operating. Canadian Advanced Technology Alliance 15

55. In the context of the Digital Economy and the fast rate of technology change characterizing it, nobody can predict what specific applications will become dominant and sine qua non for public safety operations in the future, increasing the demand for more and more spectrum to be dedicated to such essential services. The recent U.S. Administration National Wireless Initiative calls for freeing up an additional 500 MHz of spectrum for wireless broadband connectivity within a decade, with a commensurate subset to be provided for public safety. In this context, having 20 MHz dedicated in the 700 MHz band to broadband radio communications for public safety is a minimum need that should be satisfied without delay. 56. (b) CATAAlliance per se does not have any plans for deployment, but its members do, some of them within a relatively short time from the date of spectrum availability, as identified in the recent stakeholder consultation survey. These results revealed that a majority of emergency respondents and industry respondents are ready to deploy immediately with new products designed specifically to work over the 700 MHz frequencies within two years, as illustrated in the following two charts: Canadian Advanced Technology Alliance 16

57. To achieve timely, affordable and effective deployment of adequate public safety broadband radio services will require overcoming a variety of governance, financial, technical and operational challenges: 58. Governance: Spectrum governance must be ensured in reference to the Government of Canada s Communications Interoperability Strategy for Canada 12 which envisions a national system based on open standards and common user requirements adequate for public safety operations. Such a system may be built as a system of systems, where the elemental components are local (municipal, regional, or provincial) operational systems geared for overlapping and roaming interoperability. CATAAlliance recommends the creation of an effective national entity authorized to oversee the public safety band governance in accordance with national imperatives for public safety and the expertise of leading first responder associations. 59. Financial: Funding the development, deployment and operations of a network of networks capable of 24/7 services of public-safety quality and performance is a formidable but not an insurmountable challenge. First of all, such interoperable networks will benefit from the economies of scale associated with equipment manufactured for the entire North American market on the basis of 4G (LTE) technologies. Secondly, the shared operational model will lower the individual burden on each specific public safety agency which would not need to cover the costs of a network dedicated solely to its own use. Thirdly, there is the option of 12 http://www.citig.ca/data/sites/1/newsfiles/nsci-eng.pdf Canadian Advanced Technology Alliance 17

adopting a quasi-commercial modus operandi, in which the entity authorized to operate in the dedicated public safety band would bear the costs of implementing the network and charge on a per-usage (subscription) basis the agencies accepted for service. In addition, such a public safety oriented commercial system may be allowed to offer secondary priority services to other public organizations or businesses interested in using the high quality and performance services typical of public safety operations. 60. Technical: There are, and there will be, significant technical challenges to ensure the necessary performance and quality (availability, survivability, ruggedness, immediacy, etc.) at affordable costs. In addition, the stringent requirements for secure and controlled access will have to be addressed and adequate technical solutions found. 61. Operational: A shared (interoperable) mode of operation within a network imposes significant operational challenges. Such challenges would be manifold greater in the case of a commercial mode of operation, when due consideration must be given to various users priorities and regional/national interests. 62. (c) There is no suitable spectrum for broadband Public Safety services alternative to the 700 MHz band, as propagation characteristics are poorer at higher frequencies: lower penetration within buildings and smaller radio coverage, which requires much more expensive network implementations in order to ensure the minimum range necessary for emergency services typical for Public Safety operation. Nor are there any realistic opportunities for sufficient amount of spectrum to be made available for Public Safety in the 1 MHz to 1000 MHz range. 63. None of the spectrum bands presently available for public safety services is adequate for the necessary broadband radio services described above. The 4.9 GHz spectrum has poor propagation characteristics which limit its use to only small hot-spot areas and is beset by high infrastructure costs. The other public safety spectrum is not suitable for Canadian Advanced Technology Alliance 18

broadband services as it is fragmented and licensed in separate 12.5 or 25 khz channels operational only for narrow-band voice services. 64. Question 5.4 Comments are sought on the need for public safety broadband radio systems to be interoperable: (a) between various Canadian public safety agencies; (b) between Canadian and U.S. public safety agencies. 65. (a) CATAAlliance considers that the question of interoperability has significant political, operational and technical implications. 66. Ultimately, the decision on interoperability between distinct public service agencies is political in nature and must be made by the appropriate political powers the Parliament, the Federal Cabinet, Provincial Governments, etc. 67. There is no debate on the operational necessity for interoperability between police, fire, medical emergency and other public safety agencies at most times, but especially in cases of major events endangering the safety of Canadians and Canadian institutions. This has been reinforced by the diligent work of the Canadian Association of the Chiefs of Police (CAPS), the Canadian Association of Fire Chiefs (CAFC), and the Emergency Medical Services Chiefs of Canada (EMSCC) which led to the development of a Canadian Communications Interoperability Continuum as depicted in the figure on the following page. Canadian Advanced Technology Alliance 19

Limited leadership, planning and collaboration among areas with minimal investment in the sustainability of systems and documentation High degree of leadership, planning and collaboration among areas with commitment to and investment in the sustainability of systems and documentation 68. This operational necessity for interoperability was also recognized as an item of utmost priority in the CATAAlliance survey, as illustrated below: Canadian Advanced Technology Alliance 20

69. When respondents were asked about the importance of interoperability between regional (local, provincial) networks, 94% of respondents identified they either Strongly Agreed or Agreed this was critical. 70. The above requirements for operational interoperability, imposes spectrum and technical solutions that ensure full interoperability between distinct Canadian public safety with the corresponding security of access and of information particular to the work of such agencies. Specifically, the spectrum utilization should permit such interoperability in principle. At the same time, the actual implementation must allow for control on the level of interoperability enabled for each agency. 71. (b) CATAAlliance considers that the interoperability between Canadian and U.S. public safety agencies has been already proven to be a critical requirement for the safeguarding of Canadian lives and property along the border, especially in the densely populated and economically critical areas. This issue of interoperability between U.S. and Canada should be treated in the manner described above in answer to Question 5.4.a, with the additional proviso of a bi-lateral governance structure covering judicial, technical and operational aspects. 72. The allocation of the same 20 MHz block in the 700 MHz spectrum band by U.S. and Canada associated with a spectrum governance enabling secure and controlled interoperability without undue interference will be of great benefit to Canada as it will allow Canadian public safety agencies to take advantage of the lower cost of equipment manufactured for the entire North American market as well as provide more effective response to emergencies in the border regions thanks to coordination of efforts with U.S. agencies. 73. These considerations have been addressed in the CATAAlliance survey: 80% of respondents agreed that Canada must align its 700 MHz spectrum allocation for public safety with U.S. initiatives. However, 60% also identified that Canada should not wait for the U.S. but instead blaze its own trail and take this opportunity to define Canada as a global leader in this space. See charts on following page. Canadian Advanced Technology Alliance 21

74. Question 5.5 What are the challenges faced today by public safety agencies to have cross-border radio interoperability in other frequency bands? 75. Today there are no dedicated spectrum bands for public safety broadband radio systems either in the United States or in Canada. 76. As for existing public safety frequencies and systems today, they are (i) concerned exclusively with voice and low-rate data, (ii) are governed by different licensing rules, and (iii) many of them are used with proprietary technologies which do not permit interoperability of equipment from different manufacturers. 77. This is why CATAAlliance is in favour of enabling the necessary interoperability across border through allocation of the same 20 MHz block in the 700 MHz spectrum band, an appropriate spectrum governance, and the adoption of technical methodologies capable of providing secure and safe interoperability between designated public safety agencies irrespective of nationality, equipment vendor or place of operation along the border. Canadian Advanced Technology Alliance 22

78. Question 5.6 Notwithstanding your responses to questions 5-3 to 5-5, the Department seeks comments on whether public safety broadband needs can be met by using commercial systems with priority access rights for public safety, at commercial rates. (a) Your views and comments are invited on priority access rights, including preemption, and on the feasibility of such a system. (b) What public safety technical and operational requirements cannot be met by commercial systems, from either a public safety or commercial operator point of view? (c) What specific rules, if any, should be mandated by the Department to make such a system viable? 79. (a) CATAAlliance considers that consumer oriented commercial systems are inherently incapable of providing satisfactory service to public safety organizations exactly when and where it is most needed: in times of crisis, when situations are getting out of hand and commercial systems are getting significantly congested. Consumeroriented commercial systems are known to have outages and their restoration times are incompatible with the requirements for public safety operations. 80. In principle, radio systems may be engineered to operate with varying degree of priority access rights including pre-emption. But this is expensive and contrary to the business model of any consumer-oriented commercial operator for whom there is no financial justification to engineer priority rights or to ensure the grade of service, reliability, survivability and ruggedness necessary for adequate public safety operations. 81. (b) Consumer-oriented commercial systems cannot meet public safety cannot meet public safety requirements for a variety of technical and operational reasons: 82. First and foremost, consumer commercial systems cannot respond with immediacy to the needs of public safety agencies. First responders in the field need instant access to their colleagues and to the information necessary for saving lives and property. Consumer commercial systems cannot guarantee immediate access to all public safety personnel in times of crisis as it takes Canadian Advanced Technology Alliance 23

commercial management time to decide on priorities and then it takes them time to unclog the network of consumer users in favour of public safety ones. 83. Secondly, commercial systems are usually built for profitability which requires trade-offs between coverage, quality, resilience, reliability and costs of both capital and operations. Consumers and business users of commercial systems have been conditioned to accept busy networks, slow transmission or dropped calls as an unavoidable inconvenience, whereas such performance may lead to injury and death for public safety personnel and the citizens they are serving. Commercial systems built for competitive consumer services cannot afford to build the grade of service and the levels of reliability and resilience mandated by public safety service needs. Such needs require expensive network equipment solutions with sufficient built-in capacity for the busiest periods typical of disasters and sophisticated operational procedures which would make such a system noncompetitive commercially for consumer and most business type customers. While public safety may take advantage of large volume 4G (LTE) technology developments, it will have to impose additional technical standard requirements in order to meet the service standards of public safety operations. It would be unfair for commercial operators with a majority of consumer and business type customers to be forced to adopt expensive technology standards for the small minority of public safety customers. 84. Thirdly, the implementation of pre-emption features in a consumer oriented commercial system raises certain procedural, liability and legal issues which may preclude a private operator from entering into such mixed commercial-public safety modes of operation. 85. (c) Given the above considerations, CATAAlliance does not believe that there are any rules which would make a consumer oriented commercial system viable for public safety operations. Canadian Advanced Technology Alliance 24

86. On the other hand, it is conceivable that a system can be legislated and engineered to meet the requirements for proper public safety services in a quasi-commercial sense, taking advantage of the significant capabilities of Canadian companies to build and maintain such a system, while entering into partnership agreements whereby the overall control of usage, including procedures for approving and managing access and operational procedures will rest with the federal and provincial agencies responsible for public safety, working in concert with the provincial and national First Responder organizations. The feasibility of such a public safety oriented commercial (PS-commercial) system is predicated on the following factors: 87. (1) Governance: The spectrum (at least 10 + 10 MHz in the 700 MHz band) must be dedicated for public safety operations first and foremost. The governance of the spectrum must reflect all regulatory, operational and technical aspects typical of public safety needs. Spectrum governance should remain within Industry Canada, with system management governance provided through public-privatepartnerships, and operational access and usage governance managed within the federal and provincial public safety agencies and the provincial and national First Responder organizations. 88. (2) Technical: The rules for spectrum utilization and the technical solutions allowed to operate within this spectrum must meet the stringent performance requirements (e.g. availability, resilience, survivability, ruggedness, etc.) necessary for adequate public safety services. 89. (3) Operational: The entity (or entities, be they public, mixed public-private or purely private) authorized to operate in this band must provide broadband radio communications services on a priority basis to all agencies in their territory involved in public safety operations on a subscription basis commensurate with levels of returns pre-agreed by all parties. This will be necessary to ensure that the system will be financially viable for the organization/company, while still financially reasonable for the First Responder and provincial organizations. Optionally, a PS commercial system may be allowed to offer second priority Canadian Advanced Technology Alliance 25

services to other customers interested in using the services of a highperformance broadband network in full knowledge of their secondary status. 90. To enable a more timely, effective and cost-efficient deployment and operation of a system dedicated to public safety, CATAAlliance proposes that the dedication of a 20 MHz band of 700 MHz spectrum be associated with a specific policy for enabling effective and efficient usage of the spectrum through enablement of access for the installation of radio equipment on and within public and private buildings. Specifically, Industry Canada, together with appropriate provincial authorities, should establish a policy and agreements leading to: (i) the mandatory acceptance by public infrastructure owners to permit deployment of public safety network equipment on their premises, and (ii) non-mandatory incentives for acceptance by private infrastructure owners to permit deployment of public safety network equipment on their premises, supported as favourable options in the stakeholder survey results as illustrated by the two diagrams below. Canadian Advanced Technology Alliance 26

91. CATAAlliance believes that a form of public-private partnerships, whereby provincial governments negotiate contractual provisions for public safety broadband service with one or more competent private sector operators, who would then be 'qualified' to apply/bid for the aforementioned 10 + 10 MHz broadband 700 MHz spectrum, would provide a feasible alternative to the strictly commercial, consumer focused, mobile services licensed to date. The provision of public safety broadband radio communication services on a subscription (operational) basis may bring certain advantages: 92. (1) Capital Costs: Such a system operating on a subscription basis would not burden public safety agencies with the capital costs involved in building and installing such systems, whereas provincial governments could fund the capital construction costs if they so negotiated, so as to reduce subscription costs for public safety organizations. Conversely, if provincial capital funding is not available so that public safety organizations are not be able to acquire the budgets necessary to fund the build and install costs of such systems in the immediate future, it may take many years until they would be able to take advantage of the necessary broadband radio services. Therefore, the ability to pay on a subscription basis may be preferred by some provinces to ensure timely service. 93. (2) Timing: As public safety organizations may not be able to acquire the budgets necessary to purchase and install such systems in the immediate future, it may take many years until they would be able to take advantage of the necessary broadband radio services. It is likely that the full 10 + 10 MHz will not be required within the first five to eight years of licensing. It is therefore suggested that Industry Canada could, if the responsible provincial government agreed, support purely commercial usage on a portion of the band by the selected operators for this initial start-up phase. The willingness of prospective operators to fund a significant share of the network on the basis of expected commercial revenues from such use of a portion of the spectrum should be a consideration of the Canadian Advanced Technology Alliance 27

negotiations between the provincial governments and bidders in selecting the 'qualifying' operators who would be permitted to bid with industry Canada. Also, as suggested above, a suitable policy on acceptance of public safety network equipment within or on the buildings and other infrastructure of public and/or private organizations would be beneficial to the timely and cost-efficient deployment of public safety broadband radio communications in Canada. 94. (3) Equality of Service: The deployment of broadband radio systems for public safety will be unequal across the country, conditioned by issues such as available funding and population density. If public safety organizations must themselves find the initial capital to build an enhanced broadband network for their needs, only the largest cities could afford (in time) to install and operate their own narrowly defined broadband systems, while other regions would be able to afford only a sparse and inefficient usage of the allocated spectrum. Encouraging a choice between provincially funded capital construction or higher subscription fees would provide greater choice and speed deployment. And ensuring that service coverage and standards are the subject of a contractual agreement with the respective provinces prior to licensing will ensure broader coverage than would be the case for a commercial-only system. 95. (4) Auction Proceeds: In the context of a spectrum band dedicated to public safety on a quasi-commercial basis, it is expected that the spectrum usage would still be auctioned to 'qualified' bidders for the rights to install and operate public safety oriented commercial systems as described above. However, Industry Canada & Finance Canada should consider the possibility that all or a significant proportion of the auction proceeds be used as the public component contribution to the public-private partnership bidding for the rights to operate in the public safety dedicated spectrum. Canadian Advanced Technology Alliance 28