Nova Scotia Response to SMSE-004-08
Proposed Revision to the Frequency Plan for Public Safety in 700MHz Band
Canada Gazette, Part I, January 19, 2008
Introduction
This response regarding SMSE-004-08, Proposed Revision to the Frequency Plan for Public
Safety in 700 Mhz Band, is from the Public Safety & Field Communications office of the
Nova Scotia Department of Transportation & Infrastructure Renewal representing all
Province of Nova Scotia public safety users of Land Mobile Radio. In Nova Scotia, all
public safety radio users are either full clients of the province-wide 800 MHZ trunked
radio system or have interoperability with it through 'seeded' radios provided by the
province to volunteer fire services, ground search and rescue teams, municipal
emergency measures coordinators, Red Cross disaster relief, and small municipal police
departments. Because of this relationship, this response will represent the issues of these
agencies, which will probably be a larger party to the next generation provincial public
safety radio system in 700 Mhz anticipated to be implemented in 2010/11.
Other parties from Nova Scotia have contributed to the responses of their respective
representative organizations (IE. CAFC, CACP, RABC, CITIG, APCO, etc.) to SMSE-004-08.
Because the province of Nova Scotia has been directed by Industry Canada regional
personnel to plan to implement the next provincial public safety radio system in the 700
MHz band we have a particular vested interest in the outcome of this deliberation. We
will be specifying an APCO P25 compliant digital trunked system on approximately 7075 sites covering the entire province at hip level portable radio quality. Back-haul will be
IP primarily on microwave with some fibre-optic hops for redundancy and there will be
very limited use of data at implementation; it is anticipated that data capacity, as a
secondary service may be added at a later date.
The Province of Nova Scotia is a strong supporter of wireless voice interoperability and
actively supports the efforts of the Canadian Interoperability Technology Interest Group
(CITIG) and its objectives. We have measured our current system and invited our client
groups to measure against the SAFECOM Interoperability Continuum; both processes
found us well to the right of centre and making steady progress to the right. We also
acknowledge the FCC attempt to create an environment conducive to interoperability
among public safety groups. Furthermore we support the Industry Canada move in this
consultation to realign the Canadian spectrum to more closely align with that of the
USA. The economies of scale that the US market represents will help accelerate the
development and sale of products to facilitate interoperability here in Canada. With
the contractual time frame that Nova Scotia is faced with for implementation of a next
generation radio system, it is imperative that we move to the new spectrum plan
forthwith.
We share the concerns of other like minded organizations and will reiterate those here
for clarity:
1. The amount of spectrum allocated for future public safety broadband
applications is minimal compared to that in the USA. We understand that this
topic will be the subject of a future Industry Canada Consultation and agree
with this approach.
2. Television broadcasters currently operating in channels 64 and 69 have been
given to understand that a CRTC directive regarding future license issues in this
band allows them to continue to operate in this spectrum until August, 2011. We
feel that there are two issues with this: a) the jurisdiction of spectrum licensing is
that of Industry Canada not CRTC; b) allowing the television broadcasters to
remain on channels 64 and 69 until 2011 places the Canadian and US public
safety communities in spectrum conflict for over two years, particularly in the
areas of overlap along the international border. We recommend that IC
promptly roll-out the new spectrum plan for the TV broadcast industry and then
direct the TV broadcasters to vacate the channel 64 and 69 spectrum by
February 2009 as in the USA or within a very short time after that date.
For ease of reference, this response maintains the section formatting used in the
Consultation Paper.
Section 1.0
The Department highlights a number of observations stemming from informal discussions with service providers and equipment
manufacturers. These are:
1.
Harmonization of the 700 MHz band with the United States is critical for radio equipment economies of scale and
interoperability.
2.
There is an immediate need to continue to deploy narrowband public safety systems.
3.
Although broadband public safety systems are an important matter, the accommodation of narrowband systems should
take priority, as a number of public safety organizations are making plans to deploy these systems in the 700 MHz
band.
4.
Deployment under the existing band plan has just begun and the number of existing systems is low: therefore,
considering a new band plan is timely.
Comments: In general, we agree with Industry Canada and the harmonization of the
public safety band with that of the USA. We also agree that there is an immediate need
to deploy narrowband systems immediately as Canadian public safety agencies (Nova
Scotia in particular) have real requirements for narrowband communications in the
near time frame. We also support the 6.25kHz channel plan mandated by the FCC but
recommend that Industry Canada permit consolidation to allow licenses of 12.5 kHz
and 25kHz channels where required to support P25 Phase 2 or legacy equipment.
Although we agree that 700 MHz deployment has just begun, with the delayed
availability of the eventual 700 MHz allocation for public safety we must pose the
question of who will pay for the relocation of those Canadian public safety agencies
who have deployed, or are in the final throes of deploying, a system in the existing
band plan to the new plan? Certainly this issue must be addressed by Industry Canada
when making the necessary decisions on the 700 MHz spectrum.
2.0 Background
The department highlights their decision to take a two-step approach as follows:
1.
Consider restructuring the narrowband spectrum. This would include the issue of future wideband applications.
2.
Consider the public safety broadband requirements in Canada and the possibility of identifying spectrum for this use.
Comments: Given the urgency of availability of narrowband spectrum for public safety,
we support the Industry Canada two phase approach, but encourage expediency
with both phases.
3.0 Proposed Designation of the Band 770-776 MHz and 800-806 MHz for Public Safety and Revisions to the Band
The Department is proposing the following and is seeking comments on the approach:
1.
In addition to the bands 764-770 MHz (TV channel 63) and 794-800 MHz (TV channel 68), to designate the bands 770776 MHz (TV channel 64) and 800-806 MHz (TV channel 69) for public safety in the land mobile service.
2.
To adopt the band plan as follows in Figure 4 and Figure 5 that accommodates licensing of the narrowband systems in
the bands 769-775 MHz and 799-805 MHz.
Comments. The Province of Nova Scotia concurs in general with the proposed new 700
MHz band plan for public safety deployment, however we note that there must be a
flexible approach by Industry Canada (IC) to the licensing of this spectrum as indicated
and limited by the geographical location of the proposed licensee(s). There may be
opportunities in certain jurisdictions that do not exist in other jurisdictions; the one should
not be restricted by local application of a national policy that unreasonably restricts the
initiatives of one or more cooperating jurisdictions.
We further note that in order to be fully aligned with the USA revised 700 MHz band
plan, additional spectrum will need to be made available for public safety in the bands
immediately adjacent to the lower end of both ‘A’ blocks.
4.0 Proposed Continued Accommodation of Wideband Operations
The Department indicates its intent to continue to allow limited wideband operation under the proposed band plan and proposes
for consideration the following options:
Option 1: Allow aggregation of the narrowband channels in the bands 769-775 MHz and 799-805 MHz
Option 2: Allow wideband operations in Blocks B and/or C as identified in Figures 4 and 5.
Comments. Voice communications must take priority in narrowband block(s). Licensing
of wideband communications in this block must only be permitted in regions where it
has been determined that channel consolidation will not impact the ability to fully
support public safety voice services.
We acknowledge that circumstances may arise where wideband deployments are
necessary or desirable, particularly in lower population density areas. For these
situations, agencies should be allowed to aggregate narrowband channels into
wideband channels in the 769-775 MHz and 799-805 MHz blocks. These systems should
however, be licensed as an exception and only in regions where the channel
aggregation will not cause a spectrum shortage for public safety voice deployments. In
Nova Scotia, it is anticipated that the next generation trunked radio system in 700 MHz
will be all public safety inclusive and province-wide, thus we do not expect spectrum
shortage to be an issue.
Option 1: Supported. Wideband systems should, however, be licensed as exceptions
and only in regions where the channel aggregation will not cause a spectrum shortage
for public safety voice deployments.
Option 2: Supported. We do not categorically reject operation of wideband
applications within blocks B and/or C if the potential for interference can be mitigated
particularly in jurisdictions where it is not an issue. Locational flexibility on the part of
Industry Canada should be the norm.
5.0 Proposed Transition from the Current Band Plan to the Proposed Band Plan
The Department is proposing a number of measures as a means of transition between the current band plan to the proposed band
plan. These are:
1.
Existing public safety radiocommunication systems may remain in operation as licensed under the current band plan.
However, they will have to be returned to the new band plan no later that two years after the new band plan comes into
effect.
Comments: We support the relocation of operators to the new band plan for future
interoperability considerations and to take advantage of economies of scale. However,
as noted previously, Nova Scotia can not support the concept that public safety
agencies would have to pay for the relocation.
2.
New public safety radiocommunication systems may continue to be licensed under the current band plan if the
spectrum in the new band plan is not available due to television use or DTV allotments in TV channels 64 and 69.
However, the public safety licensee will have up to one year to move to the new band plan after television spectrum
becomes available.
Comments: Television channel clearance is critical to the full implementation of the
proposed spectrum allocation for public safety. TV broadcasters were given
approximately 18 months to achieve the required clearances in the USA; it can be no
more complicated in Canada than in the USA , thus we would maintain that a similar
time frame be established by IC for Canadian TV broadcasters. Further, if more time
than that is required for TV broadcasters, how can public safety agencies be expected
to make the migration in one year?
3.
Replacement channels will be held in reserve in the new band plan for these licensees in the lower portion of the band
(i.e. 769-772 and 799-802 MHz). The licensing of new radiocommunication systems according to the new band plan
will begin at the upper portion of the band (772-775 MHz and 802-805 MHz).
Comments. Agreed.