Advancing Canada’s Public Safety Broadband Network

Advancing Canada’s Public Safety
Broadband Network
The Canadian Advanced Technology Alliance
response to a 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)
Reference: Notice No. SMSE-007-12 — 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 on Industry Canada website: August 24, 2012
Publication date in Canada Gazette: August 25, 2012
Response due: October 24, 2012.
Part A — Policy and Technical Framework for Use of the D Block
Note: this submission is complemented by the attached report: Advancing Canada’s
Public Safety Broadband Network: National Survey Results. This report provides directed
responses to this submission and much of the findings support our submission here.
Part A — Policy and Technical Framework
for Use of the D Block
Designation of Use for the D Block
Response 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
The Canadian Advanced Technology Alliance (CATA) commends the decision to commit the
763-768 MHz and 793-798 MHz spectrum as the Public Safety Broadband (PSBB) block and
propose that it is critical that bands 758-763 MHz and 788-793 MHz (hereinafter referred to as
the D Block) also be provided to the public safety community.
In the six plus years that CATA has been committed to helping advance emergency responder
technology challenges and opportunities, we have come to understand how critical the
communications challenges are among them and how this proposed national network can help
address many of the life-threatening aspects of their work when communications break down.
The images and lessons of the United States` painful experiences in the Katrina and 9/11
disasters should serve as a warning for this nation to be better prepared and reflect on the fact
that the U.S. have committed the 20 MHz for their own public safety network, as well as billions
of dollars in funding to advance it.
We feel this is a historic, once-in-a-lifetime opportunity that cannot be passed by for the sake of
purely fiscal gains that might otherwise be obtained through a commercial auction of this
spectrum. An auction to commercial interests would be a very short-sighted decision in that any
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Part A — Policy and Technical Framework for Use of the D Block
immediate monetary gains realized through an auction will be easily consumed over time
through the long-term costs of leasing spectrum back from the carriers at what would be higher
comparable costs and lesser quality and rigour of service.
Providing the public safety community with this spectrum will allow them to ‘own the beachfront’
and become the developers of the solutions they require and put into place the terms and
conditions required of any commercial entities seeking to provide these services.
In short, we strongly support and encourage Industry Canada to continue demonstrating its
leadership, vision and commitment to every Canadian’s safety and security through providing
the D Block to our public safety community.
CATA has been instrumentally involved in the consultations that have taken place among the
public safety community and are aware of, contributed to, and endorse in its entirety the
submission being made to this consultation on their collective behalf; namely, the Joint
Response by Federal, Provincial, Territorial Authorities, Federation of Canadian
Municipalities and the Tri-Services Chiefs Associations on behalf of the First Responder
and Emergency Management Communities.
Response 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).
This assumption is unfounded and in fact companies have and are developing technology to
deploy on this spectrum.
In our survey report, 60% of vendors identified that they are currently developing technologies
for the D Block. Further, these same 60% related they are developing these technologies for
use even if the client base were Category 1 clients only.
In fact, at the International Wireless Communications Expo in Las Vegas this year, Motorola
unveiled its first mission-critical handheld device to utilize the new US public safety network, the
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Part A — Policy and Technical Framework for Use of the D Block
LEX 700. Intended for law enforcement, this smart phone is able to access and control live
video from security cameras, share real-time operational views, share images and video, view
incident location history and even take finger prints.
First responders in Miami-Dade County, Florida are on the air with 700 MHz Band 14 LTE and
are poised to take advantage of the benefits of next generation wireless broadband technology.
The program, one of the first of its kind, demonstrates the potential for real-time access to
databases and video for the 35 municipalities of Miami-Dade – putting integrated, missionspecific information into the hands of Miami-Dade County police officers. Harris Corporation is
providing the Miami Dade Police Department a pilot program that delivers LTE to vehicular
modems installed in department vehicles. Miami-Dade is investigating and testing the
possibilities of LTE-enabled public safety communications, with Harris and the department
working together to determine the best applications to capitalize on LTE’s capacity and
capability.
CATA, in partnership with the Networked Vehicle Association, the Canada Safety and Security
Program, Alcatel-Lucent, the City of Ottawa, the Canadian Interoperability Technology Interest
Group, Communications Research Centre and many others have launched an LTE testbed in
Ottawa capable of providing a future testing and development platform for the public safety
network.
The U.S. will ultimately help drive the immediate market demand for these devices and
Canada’s harmonization with the U.S. will only help spur these developments. The Middle Class
Tax Relief and Job Creation Act of 2012 requires FirstNet (First Responder Network Authority)
to assure nationwide standards for use of and access to the network it is tasked with
developing. The act specifies the use of commercial standards for some of the network
components. In consultation with NIST, the FCC and the Public Safety Advisory Committee,
FirstNet is to represent the networks and its users before standards-setting organizations
regarding standards related to interoperability. To promote competition, devices for public safety
network radios and other wireless devices are required to be built to open, non-proprietary,
commercially available standards, “capable of being used by any public safety entity and by
multiple vendors across all broadband networks operating in the 700 MHz band” and backward
compatible with existing commercial networks where necessary and feasible.
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Part A — Policy and Technical Framework for Use of the D Block
If vendors are provided with a market and clear standards to work towards, the products will be
built.
Response 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?
Our survey clearly demonstrates there is no support for this option.
We asked respondents to indicate whether they agreed, disagreed or had no opinion on the
following statement: The D Block Spectrum should be auctioned for commercial use with
Industry Canada mandated obligations to serve the public safety community.
Overall, 78% disagreed. Breaking down this response: Category 1 were 83% against, Category
2 & 3 were 79% against, and Industry respondents were 59% against this idea.
Matters of the public interest often times are not compatible with those of business. Historically,
First Responders have relayed the impression they have not been well-served by commercial
carriers and worry this trend will continue should the carriers gain this spectrum through an
auction process and be able to then sell access to the general public. Hence, under times of
competing demand, even with regulation in place, there is concern that priority service and preemption would remain an issue.
With public safety as owners and exclusive users of the network, these matters are more or less
resolved through having appropriate priority of access designations in place and using
technology available today with which to manage network access and flow. Furthermore, it is
anticipated that a PSNE would clearly have the appropriate authority to negotiate these terms
with their carriers of choice through clear service level agreements.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Part B — Use of the 700 MHz Spectrum
Designated for Public Safety Broadband
Access to the Spectrum Designated for Public
Safety (Categories of Users)
Response 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)?
Our study reveals that most respondents agreed that both Category 2 & 3 users should have
access to the network on a day-to-day basis.
Again, the technologies exist to allow for prioritization of service that would be afforded
Category 1 users in times of possible network congestion.
Having Category 2 & 3 users trained and familiar with the use of the network will be critical
during a time of crises and often Category 2 & 3 users can be as important to managing a crises
as the Category 1 responders.
Furthermore, expanding the user base adds greater incentive to vendors to develop technology
and applications for this community.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Response B-2: In the context of the 700 MHz public safety broadband network,
which entities/organizations should be covered under Category 3?
The precise definition of these user groups should be left to the discretion of the proposed
public safety network entity to decide.
As a starting point, provincial and municipal emergency management offices could be included,
as could border services, coast guard, search and rescue, utilities, port authorities, perhaps
even groups such as the Red Cross and Salvation Army.
There is no question that building this network for Category 1 responders alone is not sufficient,
and counter to the Communications Interoperability Strategy for Canada’s vision which states:
In the event of a large-scale, complex emergency in Canada, no single agency at any level of
government would have the required capacity and expertise to act unilaterally. Responding to
such incidents would require cross-jurisdictional and potentially cross-border coordination
amongst emergency responders which would require a level of emergency communications
interoperability, that currently does not exist. The CISC, therefore, promotes the vision of a
comprehensive and integrated capability for communications interoperability across Canada
and coordinated with United States (U.S.) partners as required.
In this context, emergency responders must be defined as greater than those captured in the
Category 1 and even Category 2 organizations as set out in this consultation.
Response B-3: Under what circumstances should Category 3 users have access to
that network (e.g. for day-to-day operations, only in emergencies)
Please see answers in B1 & B2.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Commercial Use of Spectrum in the 700 MHz Band
Designated for Public Safety
Response B-4: Should Industry Canada permit any commercial use of unused
capacity in the 700 MHz spectrum designated for public safety broadband?
While our survey showed that most respondents were against this idea, it cannot be ignored
that commercial use of the network constitutes an important revenue generating opportunity that
could help offset the costs to the various public funders of this network and further create a
means by which the PSNE can seek funding mechanisms to achieve the goal of being a selfsustaining organization.
While it is expected that this will not be an option in heavy urban centres as much of the
spectrum will likely be used to maximum capacity, outlying regions with less intensive demands
could realize the means to generate revenue from their under-utilized bandwidth.
In these instances, it is expected that the proper identity management, security protocols, and
pre-emption agreements be in place to allow for this spectrum to be reclaimed for legitimate
public safety users in times of crises or need.
Clear partnership models and service level agreements will need to be in place with commercial
carriers and the provision of best practice examples and templates could be another role for the
PSNE to adopt towards assisting in regional build-outs.
Response B-5: Whose needs must be met before 700 MHz spectrum designated for
public safety broadband can be used for commercial services?
The categories of public safety users as defined by the PSNE.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Response 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?
No. One of the key challenges for viability of this network is having a large enough user base.
Except in the major cities, the user base if restricted to only Category 1-3 users may not suffice
if looked at as being the commercial user.
It is anticipated that the PSNE will require the autonomy to decide how to best make any surplus
spectrum capacity available for commercial use outside of the Category 1-3 user groups.
Response B-7: Should the licensee or licensees be permitted to provide commercial
services directly to the public?
No. Whereby it is expected that the PSNE will need to employ and/or build some capacity in
network management, it will not have the ability to provide these services directly to the public
nor should it as this is not its mandate. Partnerships with commercial carriers will be required to
pursue these ends.
Response B-8: Should the licensee or licensees be permitted to wholesale unused
capacity to a commercial operator?
Yes. As it is anticipated the lessened demand in smaller communities and remote areas would
allow for unused capacity save for times of crises, and as funding mechanisms will be required,
the PSNE could lease capacity to commercial operators on a shared-use basis with negotiated
agreements for priority access, quality of service, and pre-emption rights in place.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Response 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)?
The only limit should be the inviolable conditions of priority access and pre-emption when and
as required for public safety users. The PSNE could create the necessary service level
agreements with the commercial carriers in the regions deemed optimal for these types of
commercial access agreements and ensure these conditions are in place.
Priority Access and Pre-emption
Response 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?
Priority service and pre-emption would be key areas of concern. Our survey results
demonstrated that on average, more than 80% of all respondent groups identified these
mechanisms as key needs for the network.
Ultimately, it is anticipated the PSNE would be the recognized authority for establishing the
requirements of their user base and ensuring these standards are in place in any commercial
bandwidth sharing agreements.
Response B-11: Should Industry Canada mandate such a mechanism or
mechanisms?
CATA does not believe that mandating these mechanisms will be required as it is anticipated
that the PSNE or sub-licensees would have these conditions contractually-bound within the
service level agreements they create with their commercial carrier.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
Our survey responses demonstrate that the majority of respondents believe Industry Canada
should mandate these mechanisms. And certainly this would be required under a scenario
where the spectrum is auctioned off with provisos to carriers requiring them to provide a public
safety network.
However in the preferred scenario where a PSNE (and/or regional PSNEs) negotiate these
terms contractually as the spectrum owners, there would be no need for an Industry Canada
mandate for these mechanisms.
Radio Interoperability
Response B-12: Which technical measure or measures, if any, should Industry
Canada consider mandating to address radio interoperability requirements?
As this is not CATA’s area of expertise, we would defer to the recommendations of the PSNE
regarding the need to mandate radio interoperability requirements.
Response B-13: Should Industry Canada mandate a specific technology? Is so,
under which standard or standards?
It is reasonably cautioned against mandating a certain technology for the network as technology
is ever-evolving and mandates could in fact prove detrimental to the long term agility of the
network to capitalize on newer technologies or updated standards.
Clearly LTE is the most obvious short-term solution upon which to build the foundation of this
network but should not come at the expense or exclusion of others that may ultimately be
deemed necessary by the PSNE.
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Part B — Use of the 700 MHz Spectrum Designated for Public Safety Broadband
It is clearly worth monitoring developments in the U.S. as their decisions will drive market
growth in related products and services that could also then be used in the Canadian network if
technology standards are mirrored. There are also the obvious impacts to cross-border
interoperability should Canada not align with U.S. decisions.
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Part C — Licensing Options for the 700 MHz Spectrum Designated for Public Safety
Broadband Use (PSBB block and D block)
Part C — Licensing Options for the 700
MHz Spectrum Designated for Public
Safety Broadband Use (PSBB block and D
block)
Licensing of 700 MHz Spectrum Designated for
Public Safety Broadband Use
Response 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
CATA supports the decision to assign the 700 MHz broadband public safety licences directly to
a PSNE(s).
Unlike the typical circumstances commercial consumers face in their use of communication
networks, for first responders and the broader public safety community at large, the ability to
communicate through voice and data channels when and as needed can frequently mean the
difference between life and death.
As such, their needs are uniquely different and are not compatible with for-profit enterprise
services where they are essentially treated today no different than any other consumer in that
they cannot obtain priority services and have never had pre-emption options made available.
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Part C — Licensing Options for the 700 MHz Spectrum Designated for Public Safety
Broadband Use (PSBB block and D block)
While the public safety community user base is small compared to general consumer use, their
consumption demands are usually much higher than your average citizen and can peak with
great alacrity during a time of crises.
Commercial carriers are wont to provide services but typically at premium rates and to the
minimum achievable standards as they are forced through their shareholders to find every
means necessary to be profitable.
It is anticipated that by owning the spectrum, the public safety community can free itself of
onerous premiums currently charged them and be able to set the terms for a robust, reliable
network that can, under the right conditions, not be seen purely as a cost centre, but generate
financial returns that help offset public sector investment and ultimately ease the burden on the
Canadian taxpayer.
Furthermore, whereas in the past new commercial entrants with an innovative communicationsbased public safety technology would have little choice but to work with one of the established
commercial providers for testing and evaluation purposes, the PSBN could act as the sandbox
for these companies to safely conduct their trials freer of the fear of IP leakage or exposure to
competition that could come from the carriers themselves.
Ultimately, the carriers will still earn dividends through their tendered bids to help build the
regional networks and provide required services. And should the PSNE be allowed to wholesale
spectrum in underutilized regions, the carriers again stand to gain through their ability to expand
their service offering and potentially grow their client base in these areas.
Response C-2: If capacity for commercial use were allowed, would this change the
response to Question C-1?
No. The PSNE would negotiate terms with commercial providers through recognized service
level and other contractual agreements.
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Part C — Licensing Options for the 700 MHz Spectrum Designated for Public Safety
Broadband Use (PSBB block and D block)
Response 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?
CATA does not believe an auction is the best approach and given the U.S. failure in that regard
and their ultimate decision to award the D Block to public safety, the important lesson here is to
ensure we don`t repeat their original mistake of attempting to auction it.
Towards the ends of cross-border interoperability and the ability to enjoy similar commercial
products and services as those that will be developed for the US markets, Canada must follow
the U.S. lead.
Eligibility
Response C-4: Based on the proposal in Section 9.3, should Industry Canada assign
a single licence to a national PSNE or multiple licences to provincial, territorial
and/or regional (e.g. multiple provinces) PSNEs?
CATA understands that a senior body of public safety representatives have jointly expressed
the intent to form a national non-profit entity to govern a public safety broadband data system
using 700 MHz spectrum to establish infrastructure, standards and policies that will ensure
interoperability across Canada and with U.S. public safety partners.
CATA has worked with this body since its earliest formation and support their vision and
burgeoning development of governance models, operating models and technology architecture
planning that is currently underway.
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Part C — Licensing Options for the 700 MHz Spectrum Designated for Public Safety
Broadband Use (PSBB block and D block)
Response C-5 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
users.) Specifically, should the PSNE represent: Category 1 users only? Category 1
and 2 users only? Category 1, 2 and 3 users?
Yes. The PSNE should represent Category 1, 2 and 3 users as defined, and those users they
identify as needed to be included who currently are not.
Response C-5 B: Should the PSNE be required to demonstrate how it will represent
the permitted categories of users?
Yes. This should be reflected in their governance model, published mandate, and any advisory
boards they develop.
Response C-5 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 [EMOs], the Federation of Canadian Municipalities)? If so, which
ones?
It is CATA’s understanding that a very strong list of organizations are already endorsing and
support the proposed PSNE.
Our survey report offers a comprehensive list of organizations that should be involved as
determined by the respondents.
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