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City of Toronto Emergency Services Is in Agreement with the Introductory Statements and Observations

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City of Toronto Emergency Services Is in Agreement with the Introductory Statements and Observations Frank Pappone Division Chief William A. Stewart Emergency Services Tel: 416 338-9401 Fire Chief Head Quarters Fax: 416 338-9404 4330 Dufferin St. William Blair Toronto ON M3H 5R9 Police Chief Bruce Farr Emergency Medical Services Chief April 4, 2008 Director General, Spectrum Engineering Branch, Industry Canada, 1943B, 300 Slater Street, Ottawa, Ontario, K1A 0C8. Canada Gazette Notice SMSE-004, Proposed Revisions to the Frequency Plan for Public Safety in the Band 700 MHz. The City of Toronto’s Emergency Services welcomes the opportunity to provide comment on Canada Gazette Notice SMSE-004, Proposed Revisions to the Frequency Plan for Public Safety in the Band 700 MHz. Since 2000 the City of Toronto has operated a common voice radio system infrastructure utilizing approximately 7000 terminals for its Emergency Services agencies. Collectively, Toronto Police Services, Toronto Fire Services and Toronto Emergency Medical Services form one of the country’s largest Public Safety groups representing over 10,000 first responders. Because of this common interest and the impact of the proposed revisions to the frequency plan we felt it best to provide comment as a single unified voice. The comments contained herein represent the consensus of the three agencies. The decision by the FCC in the United States, in August 2007, to amend the 700 MHz band plan to accommodate broadband services in that band has caused a great deal of concern and uncertainty for Toronto’s public safety agencies. Toronto is currently planning a radio system replacement with every intention of operating in the 700 Mhz band. It is imperative that revisions to this plan be finalized and implemented in the most expedient manner possible that recognizes and prioritizes the needs of the public safety community above other interest groups. For ease of reference, our comments below use the same section numbering format contained in the consultation paper. 1 1.0 Introduction The City of Toronto Emergency Services is in agreement with the introductory statements and observations. We acknowledge the admirable work the Department has done to recognize and accommodate the needs of public safety in Canada. 2.0 Background The background information provided, while accurate, did not present a number of important elements that impact the availability of spectrum for public safety use. Most notable is the lack of any reference to the September 2006 advisory letter of Assistant Deputy Minister Binder to the Canadian Radio-Television and Telecommunications Committee (CRTC). We will comment further on this in subsequent sections of our response. However, we feel that the advice provided to the CRTC regarding the shut down date for analogue television was rather ambiguous and did not sufficiently emphasize the urgency and importance of the required action. There is also no mention of the importance of a post transitional DTV allotment plan. Both of these have a significant impact on any proposed changes to the existing plan and were definitely worth mentioning as background for reference by anyone who wishes to submit comments. The Department has indicated a two step approach to resolve the existing band plan. We are in full agreement with this approach. 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 770-776 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. We are in agreement with the proposed band plan as illustrated in the consultation paper. We further encourage the Department to consider expanding block “A” by 1 Mhz to align it with the US plan (763 to 768 Mhz/793 to 798 Mhz) when appropriate. The department observes that for most of Canada channels 64 and 69 can be used immediately for narrow band public safety applications. The Department also pointed out that in Southern Ontario this is not the case. This has extremely serious implications for the Toronto Emergency Services as well as other public safety agencies that serve the Canada’s most populated region. With this in mind, we urge the Department to take immediate and decisive action to resolve the obvious contention between television and public safety demands for the same spectrum. 2 The department makes reference to CRTC Public Notice 2007-53 which sets August 31 2011 as the shut down date for analogue television. We have reviewed this Notice and find no reference indicating DTV transitional assignments will also cease by this date. We cannot over emphasize the need for the Department, not the CRTC, to clearly establish a firm date for the shut down of any and all TV services on channels 64 and 69 with the goal of doing so well in advance of the current 2011 date. In order to establish an aggressive date that recognizes the immediate needs of public safety to access channels 64 and 69 in critical areas, we further urge the Department to publish the final DTV allotment plan without delay so that broadcasters can finalize plans to vacate public safety spectrum. 4.0 Proposed Continued Accommodation of Wideband Operations We are encouraged that the Department has recognized the need to allow wideband operations in the proposed plan. Toronto, as well as other Public Safety agencies, has a genuine need for wideband applications to help meet operational requirements. This becomes even more evident for rural public safety agencies where wideband is better suited to regional or larger area coverage. The Department has asked for consideration of 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. Option 1 raises concerns that in congested areas like the GTA the number of available narrowband channels could be diminished to unacceptable levels. Interleaved wideband and narrow operation would also be challenging to manage. It would be preferable to designate a section of available spectrum specifically for wideband operation. The Department should investigate the feasibility of assigning narrowband use and wide band use at opposite ends of the proposed 6 Mhz narrowband block. As wideband systems are deployed the amount of spectrum required will be better understood and this approach would allow for the evolution of suitable proportioning of services based on regional requirements. It is import to allow for regional flexibility to accommodate increased demand for narrowband in some areas. As for Option 2, we do not support the use of Blocks B and/or C for wideband operation. The potential for destructive interference is dependant on the type of technology deployed adjacent to the guardband. It would be inconsistent with best practices to assign use of this spectrum at this point. The use and/or size of Blocks B and C should be revisited upon consultation for broadband. 5.0 Proposed Transition from the Current Band Plan to the Proposed Band Plan The Department is proposing the following points to facilitate transition from the current to the proposed band plan. 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. 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 3 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. 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). We appreciate the Departments efforts to provide a mechanism to address transition. We are in agreement with the basic principles outlined in the points above. While holding channels in reserve is a strategy that we concur with, the actual placement of those channels for existing or new systems may be dependant on wideband deployment as previously discussed and should be coordinated accordingly. Currently deployed systems must be allowed to continue operating in order for effected public safety agencies to deliver emergency services to the public, there is no alternative. Public safety agencies will find it challenging to get budgets in place to support this unplanned initiative. The Department should be prepared to create a funding model to sustain this effort. Transition and retuning represent significant logistical and financial challenges to the public safety sector and should be avoided wherever possible. We feel that the Department has not adequately comprehended the risk, effort and cost associated with a public safety radio system retune. Tables A1 and A2 show a total of 3 on air TV transmitters and 4 DTV allotments in Southern Ontario that broadcasters have indicated require significant planning and costs to accommodate transition. As a point of comparison, the Toronto Emergency Service radio system has in excess of 200 transmitters, or more accurately, repeaters, spread out over 18 sites with multi-coupling and RF filtering to consider at each site.
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