Public Safety Canada Response to Industry Canadaâ€™s Consultation

Public Safety Canada Response to Industry Canada’s Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum (SMSE-018-10)

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DRAFT CONSULTATION RESPONSE

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Manager, Mobile Technology and Services DGEPS Industry Canada 300 Slater Street Ottawa Ontario K1A 0C8 To be sent electronically to: [email protected] Software specifications: Microsoft Office Word, version 2003, SP3 Operating System: Windows Windows XP, version 2002, SP3

mailto:[email protected]�

700 MHz CONSULTATION RESPONSE (Public Safety Canada)

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Table of Contents

Executive Summary 6

Notice 8

Commercial Mobile Spectrum Needs 9 Stakeholder Holdings, Demand and Business Considerations 9

4-1. What is the general need for additional commercial mobile spectrum at this time 9 4-2 Provide general deployment information on the current use of your existing holdings 10 4-3. Indicate your need for additional spectrum 10 4-4. Do you plan to use 700 MHz spectrum acquired in the auction 10 4-5. Provide comments on the extent to which alternate spectrum access arrangements 10

700 MHz Band Plan Issues and Considerations 12 700 MHz Band Plan Architecture for Commercial Mobile Systems 12

5-1. Based on the criteria listed above, which of the four band plan options should be adopted in Canada? 12 5-2. The band plans presented in the options above include guardbands. 12

Options for use of 758-768 MHz Paired with 788-798 MHz for Public Safety and/or Commercial Systems 13

5-3. Do public safety agencies need spectrum for broadband applications? 13 a) Spectrum Required for Broadband Applications 13 b) Deployment plans and constraints 15 c) Alternate spectrum 16

5-4. Comments are sought on the need for public safety broadband radio systems to be interoperable 17 a) Interoperability Between Canadian Public Safety Agencies 17 b) Interoperability Between U.S. and Canadian Public Safety Agencies 18

5-5. What are the challenges faced today by public safety agencies 18 5-6. Notwithstanding your responses to questions 5-3 to 5-5, 19

a) Priority Access Rights 20 b) Technical and Operational Requirements Not Met by Commercial Systems 20 c) Mandated Rules to make Viable 21

5-7. Comments are sought on the need for regional (local, provincial, etc.) dedicated 21 5-8. Is there a need for a dedicated national interoperable broadband network 22 5-9. If band plan Option 1, 2a, or 2b in Section 5.1 is chosen, 22 5-10. If commercial operators are mandated to support public safety services, 23 5-11. If the APT band plan (See Option 3 in Section 5.1) is adopted: 23

Tier Sizes for 700 MHz Auction of Commercial Spectrum 23 5-12. The Department seeks comments on whether the auction of 700 MHz 23 5-13. Based on your answer above, what tier size(s) should be adopted? 23

Treatment of Existing Spectrum Users 24 5-14. Effective immediately, no new broadcasting certificates will be issued for LPTV stations 24 5-15. The Department seeks comments regarding its proposal to permit low-power licensed devices 24

Changes to Canadian Table of Frequency Allocations 25 6-1. The Department seeks comments on its proposed changes to the Canadian Table of Frequency Allocations for the

band 698-806 MHz. 25 6-2. The Department seeks comments on the spectrum utilization policy proposed above. 25

Competition 26 Possible Need to Promote Competition 26

7-1. The Department seeks comments on the current state of competition 26 7-2. Provide views, and any supporting evidence, on the impacts of government measures adopted in the AWS auctions, 26 7-3. In light of the current conditions in the Canadian wireless service market(s), 26 7-4. The Government of Canada has undertaken a consultation on potential changes 26

Specific Mechanisms Applicable to the 700 MHz and 2500 MHz Auctions 27 7-5. If the Department determines that there is a need for measures to promote competition, 27 7-6. If the Department were to implement spectrum aggregation limits (caps): 27 7-7. Are there other mechanisms that should be considered and, if so, how should these be applied? 28 7-8. The Government of Canada has undertaken a consultation on potential changes 28

Service Deployment in Rural Areas 29 8-1. In the above context, the Department seeks comments on challenges 29 8-2. Is there a need for further regulatory measures or changes to existing regulatory rules 29

700 MHz CONSULTATION RESPONSE (Public Safety Canada)

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8-3. Should the Department decide that measures are necessary, 29 Open Access 30

9-1 The Department seeks comments on whether there is a need for government intervention to promote open access, by increasing access by users to handsets and/or applications. 30

9-2. If government intervention is needed, which of the following options should be implemented? 30 Auction Timing 31

10-1. The Department is considering three options to proceed with the 700 MHz and 2500 MHz bands auction processes:31 References 32


Page 6 of 32 Restricted Distribution- Internal Use Only

Executive Summary The conversion of broadcast television from analog to digital signals and the resulting re-allocation of the channels has attracted significant interest for the vacated Radio Frequency (RF) spectrum on the part of commercial, private, and public entities. In particular, the Canadian public safety community has a strong interest in the 700MHz spectrum. Given the excellent propagation properties of this frequency band, it views this as a unique opportunity to lay the foundation for a national mobile broadband communications network that will allow various public safety agencies to better plan, coordinate, and execute their missions for their day-to-day operations and when responding to crisis events.

New technologies and applications are at hand that can enhance situational awareness and improve coordination between public safety personnel. The mobile broadband wireless network must have suitable bandwidth to provide the data throughput required by the many applications required by today’s public safety personnel, such as real-time video surveillance, vehicle and blue force tracking devices and ambulance patient video. The nature of operations being conducted will vary bandwidth requirements between the day-to-day routine calls, crowd control, or major emergency situations. Since the network must be designed to provide connectivity that responders can rely on at all times, the bandwidth requirements must be addressed in the context of how responders intend to use the mobile broadband network during emergencies.

In response to a request for technical advice by Public Safety Canada, and on behalf of the national public safety community, the Defence Research and Development Canada Centre for Security Science (DRDC CSS), with technical oversight by the Communications Research Center, conducted a scientific assessment of the 700 MHz spectrum requirements for broadband mobile data communications.

In order to assess the requirement with appropriate context and relevance, public safety stakeholders were consulted across the nation. Three incident scenarios were selected as case studies to develop the incident-response profiles. The profiles consisted of establishing how many resources and assets would be assigned to each incident and what applications would they make use of during each incident. The incidents that were chosen as case studies represent major, but commonly re-occurring, events (such as a sports event). An assumption was made that catastrophic events of the scale of a major earthquake or a concerted terrorist attack (such as September 11, 2001) would create demands that would far exceed any available spectrum and so such situations were not considered in the analysis.

The data throughput for each application was derived from empirical studies conducted by public safety agencies, support organizations, and research labs. Thus, the Data Demand Model (DDM) is derived from the incident-response profiles and application throughput requirements, in addition to growth assumptions over a 20-year horizon. Particular attention was paid to tactical video as it is expected to prevail in enhancing situational awareness and is often critical, particularly to security operations. It is also the largest consumer of bandwidth. As such, various techniques are considered in the DDM to reduce the preserve bandwidth requirement in the presence of video traffic.



Because of the large push by the commercial sector to deploy Long Term Evolution (LTE) networks as the 4th generation of cellular system and since the United States has selected LTE as the technology for public safety mobile broadband, using the same technology in Canada would leverage the economies of scale and enhance interoperability between Canadian and United States (U.S.) public safety agencies. LTE was therefore selected as the basis to develop the Capacity Model. There are substantial research efforts underway to enhance the capacity of LTE and therefore the Capacity Model introduces a factor to account for a number of anticipated enhancements in spectral efficiency at various intervals over the 20-year horizon of the model.

Finally, the required bandwidth is revealed by correlating the data demand with the capacity. Several fundamental assumptions are used in the models such as the rate at which research into spectral efficiency is transformed into reality and the number of users accessing the same applications simultaneously. The effect of varying these assumptions on required bandwidth is examined, as is the effect of uncertainty in predictions, which increases with time particularly as we look into the future 15-20 years.

The result of the modeling, taking into account uncertainty factors, shows that the amount of bandwidth required to satisfy the needs of public safety to conduct their missions during commonly re-occurring major emergency situations with modern tools and applications is greater than 20MHz in the near-to-mid term; and likely to exceed 20MHz in the long term despite advances in technology. Clearly even if the full 20 MHz is allocated for its use, the public safety community will need to take measures to efficiently manage broadband data communications carefully during periods of peak demand.

Public Safety Canada recognizes the economic advantages of reducing or removing restrictions on foreign investment in the Canadian telecommunications sector. From a national security perspective, an increasing number of new service providers operating in Canada, as well as the continuous rapid roll-out of increasingly complex new and possibly untrusted technologies can create challenges for law enforcement and national security agencies in their ability to carry out lawful investigations and protect public safety and national security. Any subsequent consultation on the licensing framework for the auction of the 700MHz and 2500MHz should consider the application of the interception requirement as a condition of license.

For the above reasons, Public Safety Canada recommends that part of the 700MHz spectrum be allocated for public safety use and that Option 1: Harmonise with the United States band plan (as defined in the consultation) be adopted for that purpose.



Notice

Canada Gazette Part I Notice No. SMSE-018-10

Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum

Published in the Canada Gazette, Part I

dated December 4, 2010

Reply Comments of

Public Safety Canada

February 28, 2011



Consultation Responses

Commercial Mobile Spectrum Needs Stakeholder Holdings, Demand and Business Considerations

4-1. What is the general need for additional commercial mobile spectrum at this time and what do you anticipate the future needs to be?

Response 1. The continuous proliferation of wireless devices and the development of supporting

applications mean that the amount of wireless broadband data traffic is continuing to increase and that anticipated future demand will be unprecedented. Similarly, the demand for mobile broadband applications will increase for emergency response. For this reason, Public Safety Canada recommends that part of the 700MHz spectrum be allocated for public safety use and that Option 1 – Harmonisation with the United States band plan (as defined in the Consultation) be adopted for that purpose.

2. Mobile broadband data services will give rise to new applications and innovative uses for data communications by the public safety community. It is envisaged that access to a mobile broadband network will extend to a user-group that is peripheral to first responders and those that occupy supporting roles. As such, the data demands will be driven by the use of new tools, new users, and new applications which, in turn, will foster greater reliance by first responders on the tools and supporting community in the response to incidents.

3. A recent technical evaluation and study of the public safety community’s current use of broadband spectrum (see the appended DRDC CSS technical assessment of public safety 700 MHz spectrum requirements for broadband mobile data communications) shows that on predictable, regularly occurring incidents (e.g. series 400 road way multi-vehicle accident), emergency responder’s requirements for mobile wireless broadband services already exceed the maximum 20 MHz spectrum allocation being considered. The study showed that only with the development in technology (i.e., Long Term Evolution or LTE), would spectral efficiency increase to the point where the demand requirements would be met by a 20 MHz spectrum allocation, however, this would not occur for another 12 years in the model studied which required the least amount of bandwidth. The study determined that within a 10-year horizon, 20 MHz is insufficient to meet the needs of public safety for mobile wireless broadband services on predictable, regularly occurring events and within a 20-year horizon, 5+5 MHz is insufficient.

4. The study concluded that when responding to incidents within the first 10 years of LTE technology implementation, public safety would need to manage the use of an LTE network through governance policies and services prioritization. Beyond year-10, they may be able to loosen the restrictions of the bandwidth management policies and procedures.

5. Public safety will continue to utilize and grow its use of data intensive broadband applications - from health care applications to mobile wireless video - in efforts to enhance the emergency responder’s ability to respond more effectively. With the timely use of this



information, decisions and actions taken by the emergency responders will greatly improve response and recovery efforts during emergencies.

4-2 Provide general deployment information on the current use of your existing holdings in each mobile spectrum band. In the case where current holdings are not being used, provide information on its planned use, including timelines.

Response 1. Public safety makes use of spectrum in the 100 / 200 / 400 / 700 / 800 and 4900 MHz

spectrum ranges. The spectrum in these deployments is generally fully utilized and used to meet the requirements of various emergency responder organizations including fire, police and emergency medical services.

4-3. Indicate your need for additional spectrum for commercial mobile service applications and how much spectrum is required. (a) What deployment timelines are being considered? (b) What types of applications/uses are envisioned? (c) To what degree will your business’ anticipated spectrum needs be addressed by having access to the 700 MHz and/or 2500 MHz spectrum?

Response 1. Public Safety Canada’s technical study of the need for additional spectrum to support mobile

wireless broadband services showed that in various predictable events involving emergency responders, the need for spectrum far exceeded the 20 MHz allocation being considered. The requirement for a 20 MHz allocation is primarily driven by the use of video and the 700 MHz spectrum has favourable propagation characteristics in comparison to 2500 MHz band. In considering an effectively designed network with a multi-cell environment to support the use of video applications, a 20 MHz spectrum allocation is the minimum spectrum required to ensure maximum use of video channels with minimum co-channel interference.

4-4. Do you plan to use 700 MHz spectrum acquired in the auction with, or on behalf of, another entity, which may participate in the auction? If yes, with which entity?

Response 1. The spectrum allocated to public safety will find use beyond the traditional emergency

responder community. To properly address a safety or security incident, other entities including healthcare providers, utilities, airport authorities, and non-governmental organisations must be involved. A public safety consortium comprised of representatives from federal, provincial, territorial and related agencies can administer access to authorised emergency use entities, coordinate spectrum use, and oversee the development of infrastructure to support access.

4-5. Provide comments on the extent to which alternate spectrum access arrangements have been investigated/considered to respond to your need for additional spectrum. In addition, provide specific efficiency measures investigated or implemented for current holdings.

Response



1. The public safety community’s use of the 4GHz spectrum range has been considered to respond to their need for broadband spectrum. As there is a requirement for additional spectrum for mobile wireless broadband data services, evidenced in the DRDC CSS technical assessment, the 4GHz spectrum range is not considered suitable due to penetration and line of sight limitations.

2. The 700 MHz spectrum has excellent propagation characteristics for mobile wireless broadband services including the ability to travel extended distances and penetrate buildings and other obstacles. In rural areas, larger channels will allow for the deployment of higher power base stations thereby reducing the number of sites required and thus the cost.



700 MHz Band Plan Issues and Considerations 700 MHz Band Plan Architecture for Commercial Mobile Systems

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 the other options? If Option 3 (APT band plan) is selected, what should the block sizes be? In providing your responses, include supporting arguments, including potential benefits to wireless subscribers.

Response 1. Public Safety Canada supports Option 1, harmonisation with the U.S. band plan due to

advantages in enabling a coordinated and interoperable transcontinental strategy. Harmonisation enables interoperability between Canada and the U.S which is a critical requirement when responding to an event near or crossing the border. These same benefits of harmonisation will be realized by commercial interests who can take advantage of interoperability with U.S service providers and lower costs for both infrastructure and retail devices. Coordination and harmonisation with U.S. systems will also offer reduced costs on equipment for both public safety and commercial systems due to economies of scale realized by a common North American market.

2. Options 2a and 2b are only viable if they do not diminish the ability for public safety coordination with the U.S. Similarly, these options may be considered if it promotes the ability of a public-private partnership to establish infrastructure supporting the deployment of the public safety spectrum.

3. Public Safety Canada does not support Option 3 as it would make it impossible to achieve its mandate of protecting life and property, and defeat the objectives of coordination and interoperability with the U.S. The public safety community would also be confronted with additional costs and delays for infrastructure and equipment. This option would also impact existing services by requiring changes to current narrowband users and ultimately potentially jeopardising the public.

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?

Response 1. In April 2010, the band plan for blocks 768-769, 775-776 and 798-799MHz was defined as

potential 3x1 MHz guardbands to protect public safety narrow/wide band and future broadband communications from interference and interfering with the adjacent commercial spectrum. The 805-806MHz block is defined as a simplex block to isolate public safety spectrum from the adjacent land mobile radio spectrum and align with the U.S. guardband allocation.

2. Public Safety Canada believes that the band plan must consider the mutual interest of public safety operational requirements and commercial requirements. As such, it is recommending that the guardbands be held as initially intended as per the April 2010 band plan and be held



in reserve to allow for the evolution of future Canadian commercial and U.S. deployment plans.

3. If public safety is awarded 20 MHz of spectrum, Public Safety Canada will recommend that additional guardbands be put in place at 757-758 and 787-788 MHz to isolate public safety spectrum from potential interference from commercial systems. In the event that the award is 5+5 MHz, Public Safety Canada would recommend that additional guardbands be put in place at 762-763MHz and 792-793MHz.

Options for use of 758-768 MHz Paired with 788-798 MHz for Public Safety and/or Commercial Systems

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?

Response 1. Public safety agencies require their own high availability, reliable and secure spectrum to

support their critical mission of protecting and safeguarding public safety and national security. This can only be achieved by a robust system that is aligned with the U.S. and a transcontinental vision.

2. Access to the 700 MHz spectrum is a key part of the Communications Interoperability Strategy and Action Plan for Canada, which includes the establishment of appropriate governance, standard operating procedures, and interoperability. The Strategy provides a framework for jurisdictions within Canada to identify and strengthen communications interoperability through the development of common technical standards and standard operating procedures designed to enhance the safety of emergency personnel and improve the overall response to complex emergencies. Dedicated spectrum and a national public safety broadband network will allow the Strategy’s Federal/Provincial/Territorial Interoperability Working Group to fulfill the objectives of the Strategy’s action plan.

3. An allocation of 700 MHz spectrum will alleviate the technical issues experienced with the 4.9 GHz band. The 700 MHz band has greater range and building penetration, allowing broader use with less infrastructure and equipment resulting in cost savings. Public Safety Canada recommends that Industry Canada assign dedicated 700 MHz spectrum to public safety for the purpose of building a national, interoperable wireless broadband system of systems for providing services for the safety of life and property.

a) Spectrum Required for Broadband Applications

1. The technical study appended to this response identifies capacity requirements that are driven by the broadband applications use of information rich multimedia content. The amount of bandwidth required is dependent upon the incident variables and the size of the response. Sufficient capacity must be available for daily, steady-state, operations as well as incident



response. The results of the study showed that in three different predictable events, the need for bandwidth exceeded the maximum 20 MHz allocation being considered. Therefore, the full 20 MHz spectrum allocation is the minimum requirement assessed as being necessary to support the public safety community’s communication needs.

2. In addition to existing applications, many new applications become viable with the use of the 700 MHz spectrum and advances in LTE technologies. The Government of Canada and other federal agencies will have an increasing need to access data and video networks during large-scale incidents to coordinate federal assistance with Provinces, Territories and local response and recovery operations.

3. The public safety community will take advantage of these new technologies to enhance their capabilities by employing collaborative tools (e.g. electronic command, records management, etc.), database access and records upload (e.g. building plans, hazmat information, medical records, etc.), messaging, video applications (e.g. surveillance, tactical feeds, conferencing, etc.), and monitoring (e.g. vehicle location, personnel tracking, etc.).

4. Examples of broadband applications that will be used include:

• Computer Aided Dispatch (CAD) systems access • Automatic Vehicle Location (AVL) and tracking • Emergency responder personnel tracking • Streaming of live video feeds to and from the field for a variety of purposes

o Tactical surveillance o Incident recording o Distribution of Next-Generation 911 video information from the public to first

responders and other field personnel • Field access to GIS/mapping systems with dynamic, tagged information for enhanced

situational awareness o Weather o Road closures o Power outage o Earthquake feeds o Emergency alert (hazard) information o Incident information o Health hazard and disease outbreak case information

• Electronic incident command systems and “Common Operating Picture” applications • Access to on-line databases of multimedia content:

o Records and case management systems access (fire, police, etc.) o Building plans, Hazardous Material (HAZMAT)/Chemical, Biological,

Radiological, Nuclear, and Explosives (CBRNE) and other hazard inventories o Resource inventory databases o Still image database access (e.g. facial recognition) o Canadian Police Information Centre access o Biometric analysis



o Insurance record and registry databases (vehicles, vessels, aircraft) • Telemedicine applications within emergency medical services:

o Vital signs telemetry o Patient records access o Future video/audio feeds for remote emergency mobile consultation/assessment o Future high resolution mobile imaging and diagnostic applications o Possible future mobile robotic applications and procedures

• Human tracking systems: o Evacuee tracking o Mobile patient/client telemetry monitoring and alerting systems o Corrections mobile monitoring and alerting systems

• Access to enterprise networks o Email and office automation systems o Unified messaging and communications (e.g. Voice Over Internet Protocol

(VoIP) telephony) o Intranet and Internet access o Enterprise applications (e.g. personnel systems, etc.)

• Vehicle telemetry and control • User device software updates and maintenance/downloads • Licence plate recognition • E-ticketing • Robot control • Sensor and machine-to-machine communications (fixed and portable)

b) Deployment plans and constraints

1. Although there is a long list of potential applications that could utilize a public safety wireless broadband network, deployment of advanced services is also constrained by public safety’s ability to address issues related to funding, resources, security, business process transformation and user training. For this reason, deployment plans for many advanced services are not well developed at this time.

2. It is Public Safety Canada’s view that demand from public safety and public service agencies for wireless broadband services and the mission critical applications they support will experience growth rates similar to those observed for consumer and business users. Deployment plans will therefore be dependent on the availability of suitable and cost effective broadband wireless networks on which these applications will depend.

3. The Communications Interoperability Strategy and Action Plan for Canada provides a foundation upon which a public safety broadband network in the 700 MHz band could be developed. The Strategy calls for a system of systems based on standards determined by the Federal/Provincial/Territorial Interoperability Working Group. The public safety community will work with industry to establish partnerships that can identify and develop the infrastructure needed to implement those broadband capabilities.



4. Public Safety Canada, through its Interoperability Development Office, has developed a three phase concept of operations to ensure the timely launch of the 700 MHz program:

Phase 1 - Departmental response to Industry Canada Consultation (completed)

Phase 2 – (March - December 2011) o PS to work with partners and private industry to identify and confirm business

models o Further develop and consult on identification and evaluation of associated factors

Phase 3 - Phase Three (Starting December 2011)

o Develop roll-out plan

5. Building the supporting infrastructure requires additional funding. This will be derived from a variety of sources including public-private partnerships that are mutually beneficial to industry and the needs of Canadians. The partnerships will achieve the needs of public safety communications while contributing to economic development and the health of Canada’s economy.

6. Some of the applications described above are already in use and performance could be augmented by additional spectrum in a short timeframe. Other applications would be prioritised and deployed as soon as possible, subject to available resources.

7. Implementation to remote areas can be more challenging. Partnerships and mutually beneficial arrangements will be developed to reach these areas with the help of industry providers, utilities, and provincial infrastructure programs like Alberta SuperNet.

8. It should be noted that the 20 MHz allocation is the minimum required in order to effectively design and deploy a multi-cell network for a nationwide strategy for public safety coordination and interoperability. A contiguous block, although not strictly required with new technologies, does provide greater efficiency of deployment and eliminates many technical issues associated with separate blocks.

c) Alternate spectrum

1. Public Safety Canada considers the other spectrum allocations, referred to below, to be unsuitable for public safety broadband requirements.

2. For example, the 4.5 – 4.9 GHz spectrum is not suitable due to the technical and practical restrictions of the higher frequencies. The 4.5 – 4.9 GHz range requires line of sight, has a shorter range and cannot penetrate buildings. It also requires more specialised and more costly equipment. The mobile broadband applications used by responders require the range and accessibility afforded by the 700 MHz spectrum.

3. The advantageous characteristics of the 700 MHz spectrum make it ideal for public safety applications. No other spectrum provides the combination of range, building penetration, channel bandwidth, and potential for nationwide and U.S. harmonisation. Public safety services for the protection of life and property are best met by the contiguous 20 MHz block available in the 700 MHz band.



4. Furthermore, the public safety community is ensuring appropriate use of the spectrum by using facilities appropriate to the application needs. Other facilities (e.g. wired for fixed video) can and will be used for some services to ensure the capacity of the 700 MHz spectrum is used for critical mobile applications in an efficient manner. All these applications and services depend greatly on the amount of spectrum that is available for public safety broadband services — they require considerable bandwidth and speed that is currently not available. Future networks must be built with public safety requirements in mind.

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.

Response 1. The consequence of not being able to exchange on-scene information was never more

evident than on September 11, 2001. The lack of communications interoperability was a major finding of the Commission which investigated the September 11th World Trade Center attack. (Citation: http://www.9-11commission.gov/report/911Report_Ch9.htm)

2. Public safety broadband radio systems must be interoperable to work in a coordinated manner to respond to emergency situations involving a response by more than one jurisdiction, while respecting federal, provincial and territorial laws, regulations and existing plans. Interoperability is a critical part of the emergency response capability to effectively respond to events and fulfil the mandate of the public safety agencies.

3. Responding to a large scale or complex emergency requires cross-jurisdictional and potentially cross-border coordination amongst emergency responders. This requires a level of emergency communications interoperability that currently does not exist, especially in the main markets and remote border locations, and has a direct impact on community and responder safety. Interoperability is the ability of emergency personnel to communicate between jurisdictions, disciplines, and levels of government, using a variety of systems, as needed and as authorised. Emergency communications interoperability is being addressed by the Communications Interoperability Strategy and Action Plan for Canada that promotes the vision of a comprehensive and integrated capability for communications interoperability across Canada and coordinated with U.S. partners as required.

4. An appropriate allocation in the 700 MHz band provides a unique opportunity to address and eliminate many challenges to achieving effective interoperability. It will enable the various Federal, Provincial, and Territorial levels of government to work collaboratively and in an integrated manner, with all those agencies having a role in the emergency.

a) Interoperability Between Canadian Public Safety Agencies

1. The need for interoperability between Canadian public safety agencies has been identified by governments at all levels, first responders across the country, and the public.

2. For example, the 2009 Fall Report of the Auditor General of Canada (http://www.oag-bvg.gc.ca/internet/English/parl_oag_200911_e_33252.html) identified communications interoperability as a key area that needs to be addressed.

http://www.9-11commission.gov/report/911Report_Ch9.htm�

http://www.oag-bvg.gc.ca/internet/English/parl_oag_200911_e_33252.html�

http://www.oag-bvg.gc.ca/internet/English/parl_oag_200911_e_33252.html�



3. In accordance with the Communications Interoperability Strategy and Action Plan for Canada , “the desired end-state is that emergency responders can communicate as needed and as authorized across all disciplines and between all levels, on demand. By promoting day-to-day usage of interoperability tools, the response to large scale events can be more readily accomplished. Existing technical and organizational impediments would be resolved by the development of common, open technical standards and standard operating procedures, which would then be used in day-to-day operations to enhance emergency personnel safety and improve efficacy.” (http://www.publicsafety.gc.ca/prg/em/cisapc-scicpa-eng.aspx).

4. An important measure to ensure that requirements are met efficiently is by establishing a consortium of Federal/Provincial/Territorial stakeholders to ensure a common air interface is available. The Strategy outlines a structure to create a technical and operational framework to support and encourage nationwide operability and interoperability in public safety wireless broadband communications.

b) Interoperability Between U.S. and Canadian Public Safety Agencies

1. The need for alignment with the U.S. and a transcontinental vision is supported in the report, Cross Border Data Exchange: Comparison of Data Standards, Version 1.0, Cross-Border Crime Forum Committee (April 2007). The report highlights that the adoption of a common standard of information exchange would provide a benefit to Canadian and U.S. law enforcement agencies.

2. Alignment of spectrum in the 700 MHz band will help in the development and use of common standards for information exchange with U.S. partners. For example, Public Safety Canada and the Department of Homeland Security’s Office of Emergency Communications have worked with stakeholders to identify priorities for joint work to improve responder communications interoperability. To that effect, a Canada-U.S. Communications Interoperability Working Group was recently formed between the two organizations to address communications issues of common interest to both parties.

3. Interoperable networks have other benefits beyond coordination and operations. Vendors are able to address similar integrated markets and consequently can produce handsets and equipment made for similar frequency sets. This alignment will increase the amount of interoperability in responder equipment and can lead to lower equipment acquisition costs for the emergency responder community.

5-5. What are the challenges faced today by public safety agencies to have cross-border radio interoperability in other frequency bands?

Response 1. Existing systems are aging, operate on different frequencies, and are made by different

manufacturers, some with proprietary technology that is often not compatible. Police, fire and emergency medical services often cannot communicate effectively with neighbouring services, the Royal Canadian Mounted Police, coast guard or military, let alone with utility crews, aviation and transport officials or contracted security officials, as a result of these



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 pre-emption, and on the feasibility of such a system. [PS Group- priority access not feasible] (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?

Response 1. During day-to-day operations, and especially during major events, responders need timely

access to data — seconds can save lives. The public safety community needs to own and control dedicated spectrum so responders have access to this critical resource without the risk of contention by commercial use. Ownership is critical. Spectrum dedicated to public safety can be built to the more stringent standards of emergency response and ensure interoperability with other networks. By design, public safety networks must have more reliability, availability and functionality to support emergency response operations.

2. Public safety operations cannot depend solely on commercial carrier resource allocation decisions or infrastructure design during emergency events. Commercial systems are not engineered to handle the capacity needs of a large emergency incident. Commercial networks, where oversubscription can be 100:1, do not meet the steady-state requirements of the public safety community, let alone the capacity demands during an incident. Rural capacities are often even lower due to lower aggregate retail demand.

3. Pre-emption of users in a commercial model does not align with the required user experience. Consequently, it is unreasonable for commercial networks to provide this for public safety. Congestion will occur during an event and prioritisation cannot provide access to emergency responders if others do not release the channels.

4. Requirements for coverage can also differ between public safety and commercial needs for some areas. Public safety communications must operate with 99.999% + reliability. The public safety radio networks handle significant call volumes every day. Commercial cell phone networks do not provide that level of reliability as evidenced by consumers experiencing “no service” or “call dropped” situations

5. Availability is also critical. A small event can cause a loss of service in a local cell or a cell network to go down due to a sudden peak in consumer usage. A larger disaster can result in commercial networks being physically destroyed or overloaded by people trying to communicate with others in the affected areas.

6. The costs of using a commercial network at commercial rates may also present an element of risk for the public safety community that operates with limited funding resources. Commercial operators are naturally inclined to offer services to customers that maximize usage and result in the best Average Revenue Per User (ARPU) margin and profitability. This can result in a conflict of divergent interests. The result of the U.S. D block auction in 2008 indicates that commercial operators also realise this conflict between the needs of public safety and the needs of their consumer and business markets.



7. Although commercial networks are not recommended for primary public safety communications, they could be used to supplement capacity to help reach remote areas. Public safety responders could use their primary networks when they are within range and roam to a commercial network when necessary.

a) Priority Access Rights

1. Although technologies permit the use of pre-emption and prioritisation, there are several issues associated with implementing this principle on a commercial network. For example, one cannot pre-empt a commercial user entirely, as that would eliminate the ability to make 911 calls. The conditions under which a commercial entity would have to operate for pre-emption and prioritisation would make it very difficult for them to provide a commercial service. This is illustrated by the difficulties noted by operators with the original structure of the D block in the U.S.

2. Commercial cellular networks do not currently prioritise their users or traffic. Mandating the establishment of a mechanism for priority access to commercial networks is not a satisfactory answer for either the public safety agency or the service provider. Use of the commercial network still carries an element of risk that the responder does not get timely access to the network – an unacceptable position. The service provider would be impacting its user base which can be an unacceptable business consideration.

3. The application of priority must carry beyond the spectrum to the underlying networks as well. The issues of guaranteed access, performance, reliability, availability are compounded when considering the carriage on the commercial backbone or internet connections available.

b) Technical and Operational Requirements Not Met by Commercial Systems

1. A commercial network presents many technical challenges that do not, by themselves, provide the assurance of accessibility, reliability and availability needed for public safety. Commercial networks would need to be subject to more stringent security and privacy requirements for use by public safety. Personal health information and proprietary information on buildings and resources need to be protected. The security of the transmissions within the public safety community is also critical and requires a network designed to meet those needs.

2. Commercial networks are typically oversubscribed. Consequently, a priority system by itself does not ensure that the capacity required actually becomes available. It can take more time, critical in a response, to free up the required capacity. In addition, there can be contention for priority channels causing further delays.

3. Furthermore, establishing priority on the air interface (e.g. with LTE technology) does not ensure that the end-to-end communication has priority. The prioritisation scheme must be consistent through all parts of the commercial network including backhaul, other facilities, devices, user type, and the end-user applications. This level of risk is unacceptable in emergency situations where lives are at risk. The public safety community is better served by having exclusive control of the spectrum and using their own segregated networks.



4. Communication networks for public safety require a high level of reliability and availability as noted earlier in this response. These standards typically exceed commercial requirements and are best met by a separate network dedicated to public safety use.

5. Alternatively, an inverse arrangement may be employed between the public safety community and another user. In this case, any instantaneously available public safety spectrum could be used by an alternate user (e.g. utility, education institution) until required for an emergency response. The public safety community can then pre-empt that user to gain access on a network that is also designed to suit their more stringent requirements.

c) Mandated Rules to make Viable

1. Rules mandating conditions on the use of the spectrum would be insufficient to make a commercial network viable due to the additional considerations and complexities noted above. Alternatively, the public safety community can establish partnerships and agreements with industry for access to supplemental capacity during major events. Similarly, partnerships can be created to mutually benefit by sharing other parts of the communications infrastructure for diverse operations and other needs.

5-7. Comments are sought on the need for regional (local, provincial, etc.) dedicated broadband networks to provide access to all public safety agencies, and the institutional feasibility of implementing such a system.

Response 1. Public Safety Canada recommends that a national, provincial and municipal dedicated

broadband system of systems be developed and built to support the needs of each jurisdiction. Public Safety Canada is currently working on the establishment of a consortium of Federal, Provincial, Territorial and Regional/Local emergency response organizations to lay the foundation for a national mobile broadband communications system of systems that will allow various public safety agencies to better plan, coordinate, and execute their missions, whether it is for their day-to-day operations or responding to crisis events.

2. This consortium will establish a governance structure in alignment with the governance model identified in the Communications Interoperability Strategy and Action Plan for Canada. This structure will include coordination of spectrum use, administer bandwidth management policies and procedures, and have decision making authority for all aspects of technology, standard operating procedures, training and exercises and use of the network for national interoperability. Such a system would enable interoperable broadband communications for all Canadian public safety entities and with international agencies during joint operations, such as with the U.S. Department of Homeland Security.

3. In planning for this use of spectrum, Public Safety Canada has considered to what extent it will be used on a day-to-day basis and not just for predictable, regularly occurring incidents or catastrophic events such as an earthquake on Canada’s west coast. As such, if the public safety community was awarded a 20 MHz allocation of 700MHz spectrum, then the public safety consortium would pursue specific business models and partnerships that would maximize the use of resources including the sharing of infrastructure. Collaboration with partners is important to public safety organisations for financial and technical reasons, and to utilize their skills and knowledge in the development of an interoperable national, provincial



and municipal public safety wireless broadband system of systems. With the public safety organisations being the owner of the spectrum, the consortium and its partners would ensure that governance; technology and standard operating procedures are in place to ensure that the requirements of public safety responders are fully met.

5-8. Is there a need for a dedicated national interoperable broadband network to provide access to all public safety agencies? The Department seeks comments on the institutional feasibility of implementing such a system

Response 1. Public Safety Canada believes that a national coordinated system is required, but this does

not necessitate a single national dedicated network. Instead, this would best be served by a national system of systems that will ensure U.S. border coordination through connectivity with regional systems.

2. Implementing a national dedicated network would face many challenges in satisfying all regional requirements, infrastructure, technical coordination, governance, etc. The Governance Framework identified in the Communications Interoperability Strategy and Action Plan for Canada can be used to coordinate the creation of new fourth generation networks, incorporating the redundancy and hardening requirements of the public safety community. All regions including all first and second responders from all agencies will be able to participate.

5-9. If band plan Option 1, 2a, or 2b in Section 5.1 is chosen, which one of the three options described above should be adopted and why is this option preferred over the other options? Provide supporting rationale.

Response 1. As mentioned in Response 5-1, Public Safety Canada recommends Option 1, harmonisation

with the U.S. band plan, be adopted and that Industry Canada allocate 20 MHz of spectrum for public safety use.

2. Utilisation and deployment of two 10 MHz channels offer remarkable advantages over two 5MHz channels. A 10 MHz channel is more spectrally efficient as it allows for greater capacity in urban environments, higher throughput and higher peak power data rates. It is also cost equivalent to deploy in that a network consisting of two 10 MHz channels is approximately the same cost as the cost to deploy two 5 MHz channels. Furthermore, as noted in response 4-3, an effectively designed network with a multi-cell environment designed to support the use of video requires a minimum of 20 MHz spectrum to ensure maximum use of video channels with minimum co-channel interference.

3. The 700 MHz D Block is the only available spectrum adjacent to the public safety current 4 MHz broadband allocation. If 5+5 MHz is auctioned for commercial use rather than being assigned for public safety use, then provincial, territorial and local governments will pay a much higher price in the future to support public safety communications than any short term revenue received through a second auction.

4. If the 20 MHz spectrum was allocated for commercial systems and public safety systems were to use commercial networks, there would be no guarantee that the commercial networks



would be built to public safety standards of uptime, availability, and redundancy. During a major incident when the network would be most needed, the commercial networks would be congested. Even with priority access, there would be no guarantee that public safety responders would be able to use all the applications they identified, nor in the manner in which they expected to use them, potentially putting lives at risk.

5-10. If commercial operators are mandated to support public safety services, what tier size should be applied in order to ensure adequate public safety coverage?

Response 1. As mentioned in 5-9 above, Public Safety Canada does not believe that the use of

commercial networks would support the needs of public safety requirements. As well, if the entire 20 MHz spectrum was not allocated for public safety systems but rather auctioned for commercial systems, then Public Safety Canada is concerned that commercial service providers may not bid for the spectrum, delaying any public safety roll-out of mobile wireless broadband services.

5-11. If the APT band plan (See Option 3 in Section 5.1) is adopted: (a) Given that the APT band plan requires a 55 MHz duplexing separation, can Canadian public safety services operate their current narrowband systems in this band plan configuration? If not, what are possible alternatives to address public safety needs? (b) Should spectrum be designated for dedicated public safety broadband systems, and how much? You are also invited to comment on any related aspects that are not addressed above, including whether the decision should be delayed until the U.S. situation is known.

Response 1. Public safety Canada does not recommend the APT band plan, as discussed in the response to

5-1.

2. The U.S government is investigating the allocation of the D block for public safety use and the funding of the infrastructure for deployment. Although this has not been finalised, we recommend that the corresponding frequencies be reserved for public safety in Canada in anticipation of the completion of the U.S. plan. This will enable harmonisation of the Canadian system with the U.S. and facilitate the coordination and interoperability discussions recently launched between Canadian and U.S. public safety agencies.

Tier Sizes for 700 MHz Auction of Commercial Spectrum

5-12. The Department seeks comments on whether the auction of 700 MHz commercial spectrum should be based on uniform tier sizes across all spectrum blocks, or a mixture of tier sizes.

Response 1. Public Safety Canada believes that Industry Canada should allocate the entire 20 MHz to

public safety systems as noted in Response 5-9 and has no comment on Tier sizes as it ertains to other 700 MHz spectrum that will be auctioned for commercial systems.

5-13. Based on your answer above, what tier size(s) should be adopted?

Response



1. Public Safety Canada has no comment on tier sizes.

Treatment of Existing Spectrum Users

5-14. Effective immediately, no new broadcasting certificates will be issued for LPTV stations in TV channels 52-59 (698-746 MHz). The Department proposes that the displacement of the incumbent LPTV stations be subject to a notification period of one year for LPTV stations located in urban areas25 or in specific geographic areas, such as along highway corridors; and a period of two years for LPTV stations in all other areas. A displacement notification can be issued only after technical determination is made concluding that continued operation of the incumbent LPTV station would impede the deployment of new licensed systems in the 700 MHz band. The Department seeks comments on the transition policy proposed above.

Response 1. Public Safety Canada supports the proposed transition policy.

5-15. The Department seeks comments regarding its proposal to permit low-power licensed devices including wireless microphones, to operate in the band 698-764 MHz and 776-794 MHz only until March 31, 2012.

Response 1. Public Safety Canada supports the proposed policy.



Changes to Canadian Table of Frequency Allocations 6-1. The Department seeks comments on its proposed changes to the Canadian Table of

Frequency Allocations for the band 698-806 MHz.

Response 1. Public Safety Canada supports the proposed changes as described in the Consultation.

6-2. The Department seeks comments on the spectrum utilization policy proposed above.

Response 1. Public Safety Canada has no comment.



Competition Possible Need to Promote Competition

7-1. The Department seeks comments on the current state of competition and its anticipated evolution, including the impact on consumers in the Canadian wireless services market: (a) in general; (b) in terms of its contributions and interaction to the broader Canadian telecommunications service market; a (c) in comparison with the wireless markets of other jurisdictions.

Response 1. Public Safety Canada has no comment on the current state of competition.

7-2. Provide views, and any supporting evidence, on the impacts of government measures adopted in the AWS auctions, including the impacts on consumers and on the state of competition. In particular, what has been the impact, if any, of such measures on industry concentration, barriers to entry or expansion of services, and the availability of new or improved service offerings and pricing plans?


7-3. In light of the current conditions in the Canadian wireless service market(s), is there a need for specific measures in the 700 MHz and/or 2500 MHz auction to increase or sustain competition?


7-4. The Government of Canada has undertaken a consultation on potential changes to the foreign investment restrictions that apply to the telecommunications sector. How would the adoption of any of these proposed changes impact your responses to the questions above?

Response 1. Public Safety Canada recognizes the economic advantages of reducing or removing

restrictions on foreign investment in the Canadian telecommunications sector. Telecommunications systems are the backbone of all critical infrastructure systems in Canada and represent a key component of Canada’s National Strategy and Action Plan for Critical Infrastructure. The Internet, computers, mobile devices and cyber technologies are part of the daily lives of Canadians and are essential to the economic prosperity of this country. As such, protecting these systems is crucial both to preventing essential services (e.g. water, health, energy, defence and security, transportation and financial and information technology) from being compromised or disrupted, and to building investor and consumer confidence in Canada’s telecommunications sector.



2. It is important to fully appreciate the scope of the potential impact of reducing or removing restrictions on foreign investment in Canada’s telecommunications sector. The lessening of current restrictions could create new, and increase existing vulnerabilities in our telecommunications networks, further exposing them and the users and services that rely on them, to an increased threat of cyber espionage and denial of service attacks. It could also impede law enforcement and national security investigations by further challenging the ability of authorities to execute judicially authorized warrants to intercept telecommunications.

3. As options are considered to maximize Canada's competitiveness in the telecommunications sector, Public Safety officials will work with Industry Canada to further develop options to help ensure that any change to the telecommunications market will be accompanied by necessary security safeguards. These measures are required to help address threats to the integrity of Canadian telecommunications networks, thereby protecting Canada’s economic prosperity and wellbeing, our critical infrastructure, and our national defence and security.

Specific Mechanisms Applicable to the 700 MHz and 2500 MHz Auctions

7-5. If the Department determines that there is a need for measures to promote competition, which of the above mechanisms would be most appropriate and why should this mechanism be considered over the other? Comments should also indicate if further restrictions should apply so that policy objectives are met, for example, over a given time period? In light of your response above, and recognizing that pending decisions on the specific band plan, spectrum for public safety system, tier sizes and open access requirements could influence your response:


7-6. If the Department were to implement spectrum aggregation limits (caps): (i) Should the cap apply to the 700 MHz band only or be broader? (ii) What should the size of the cap be? (iii) Should bidders and their affiliates or associates share the cap? (iv) How long should the cap remain in effect? (b) If the Department were to implement a set-aside in the 700 MHz auction: (i) Who should be entitled to bid in the set-aside block(s) and should the entitled bidders be restricted to bidding on the set-aside only? (ii) How much spectrum should be set-aside and which block(s) should be set-aside? (iii) If the set-aside were to include multiple blocks of spectrum, should they be contiguous? (iv) What restrictions should be put in place to ensure that policy objectives are met (for example, should trading of the set-aside spectrum be restricted for a given time period)?




7-7. Are there other mechanisms that should be considered and, if so, how should these be applied?

Response 1. Public Safety Canada recognizes the effect of a set-aside component to bolster competition

by encouraging the development of products and services and offering more choices to Canadian consumers and businesses.

2. Nonetheless, an increasing number of new service providers operating in Canada, as well as the continuous rapid roll-out of increasingly complex new and possibly untrusted technologies can create challenges for law enforcement and national security agencies in their ability to carry out lawful investigations and protect public safety and national security. For example, powers to intercept communications are provided for in legislation such as the Criminal Code of Canada and the Canadian Security Intelligence Service Act and are essential for the investigation and prosecution of serious offences. However, there is currently no legislation requiring service providers to build or maintain intercept-capable equipment. As such, even after authorities have obtained judicial authorization to intercept telecommunications, the service providers may not have the technical ability to effect the authorization.

3. Today, with a limited number of companies and all with Canadian ownership, authorities and service providers often work together to develop and implement network solutions to support investigative requirements. With market diversification and an increased number of service providers, the need for legislation requiring intercept-capable networks becomes paramount in ensuring the investigative and intelligence gathering capabilities of law enforcement agencies and national security agencies are appropriately maintained.

4. Through Bill C-52, the Investigating and Preventing Criminal Electronic Communications Act, the Government is pursuing legislation that will help keep Canadians safe by equipping the police and national security agencies with the tools they need to combat crime and terrorism in the digital age. This legislation would help mitigate against possible threats from hostile foreign entities that would seek to exploit a possible future relaxation of the foreign ownership restrictions in the telecommunications market.

7-8. The Government of Canada has undertaken a consultation on potential changes to the foreign investment restrictions that apply to the telecommunications sector. How would the adoption of any of the proposed changes affect your responses to the questions above?




Service Deployment in Rural Areas 8-1. In the above context, the Department seeks comments on challenges

and specific problems affecting the deployment of broadband mobile services to low-density rural and remote areas.

Response 1. In implementing a public safety 700 MHz mobile wireless broadband national system of

systems, Public Safety Canada anticipates there will be challenges, both technically and financially, to deploying service in rural and underserved markets. In doing so, Public Safety Canada will be looking to utilise various partners to serve these areas. As the density of population does not make it always financially feasible to serve these areas, Public Safety Canada believes that Industry Canada should make use of roll-out licence conditions specifically targeting deployment in rural areas and include some financial incentives to support the cost of implementing and deploying systems in these areas. The advantage of doing this will create better commercial and public safety mobile wireless broadband availability in rural and underserved areas. Investigations are currently under way to look at ways to deliver 700 MHz LTE “in a box” for both rural and far northern deployments such as major incidents and search and rescue.

8-2. Is there a need for further regulatory measures or changes to existing regulatory rules (e.g. RP-19) to facilitate service deployments in rural and remote areas that remain unserved and/or underserved?


8-3. Should the Department decide that measures are necessary, comments are sought on specific measures that could be adopted within the 700 MHz spectrum auction process to ensure further deployment of advanced mobile services in rural and remote areas (e.g. roll-out conditions, tier structure, etc.).




Open Access 9-1 The Department seeks comments on whether there is a need for government intervention

to promote open access, by increasing access by users to handsets and/or applications.


9-2. If government intervention is needed, which of the following options should be implemented? Option 1: Mandated open access requirements across all future commercial mobile bands Option 2: Mandated open access requirements for the entire commercial mobile spectrum in the 700 MHz band. Option 3: Mandated open access requirements for the “C Block” (746-757/776-787 MHz) as in the United States.




Auction Timing 10-1. The Department is considering three options to proceed with the 700 MHz and 2500 MHz

bands auction processes: Option 1: to conduct an auction for licences in the 700 MHz band first, followed by an auction for licences in the 2500 MHz band approximately one year later; Option 2: to conduct an auction for licences in the 2500 MHz band first, followed by an auction for licences in the 700 MHz band approximately one year later; Option 3: to conduct one combined auction for licences in both the 700 MHz and 2500 MHz bands, which would be six months later than the first auction in the case of separate auctions. Industry Canada is seeking views on the merits or disadvantages of proceeding with each of the various options stated above. The Department seeks to understand the magnitude of interdependencies between the two bands from a business/operational perspective. Specifically, comments are sought as to the extent spectrum in these bands is interchangeable or complementary from both a technological and a strategic perspective. In addition, views on the business and financial capabilities of participating in a joint auction for both bands are sought. Comments should include the rationale for selecting one option rather than another.

Response 1. Any subsequent consultation on the licensing framework for the auction of the 700MHz and

2500MHz should consider the application of the interception requirement as a condition of license.

2. Public Safety Canada will seek to modernize the framework guiding interception requirements as a condition of licence. This may include the Solicitor General’s Enforcement Standards for Lawful Interception of Telecommunications, as well as the language of the interception requirement clause so that is technologically neutral and reflects the current technological environment. The inclusion of the interception requirement as a condition of licence would support the needs of law enforcement and national security agencies’ until legislation compelling intercept-capability comes into force.



References 700MHz Spectrum Requirements for Canadian Public Safety Interoperable Mobile Broadband Data Communications. Defence Research and Development Canada Centre for Security Science (DRDC CSS). DRDC CSS CR 2011-01. February 28, 2011. Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum. SMSE-018-10, Industry Canada, November 30, 2010. Canada Gazette Part I dated December 4, 2010. Cross Border Data Exchange: Comparison of Data Standards, Version 1.0. Cross-Border Crime Forum Committee (April 16, 2007).

Documents

Public Safety Canada Response to Industry Canadaâ€™s Consultation