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Adequate spectrum for public safety agencies
This chapter considers the provision of spectrum for PSAs. Case studies
and recent policing and emergency incidents are considered to explore the
difference in capability of both 10 MHz and 20 MHz and the impact and
consequences for PSAs.
Without exception, witnesses to the inquiry agreed that adequate
spectrum for PSAs will enable them to leverage new and emerging technological
advances to ensure the greatest protection of the community.
However, there was considerable difference in opinion as to what constitutes
'adequate' spectrum for the purposes of a PSMB network. This chapter explores
these respective positions and the evidence that underpins them.
Operational scenarios considered by the ACMA
The ACMA provided evidence that the PSMBSC surveyed the needs and views
of PSAs in relation to their potential mobile broadband data demand to the year
2020 and collated those responses into a range of five operational scenarios. The
ACMA reported that those scenarios included day-to-day non-emergency use
(business-as-usual); various emergency scenarios including natural disasters;
and a major inner-metro (worst case) threat response.
Mr Cheah, Authority Member of the ACMA, informed the committee that the
ACMA's analysis identified a total of 10 MHz of spectrum (5 MHz + 5 MHz) as
sufficient to meet the demands of agencies in four of the five scenarios which
included business-as-usual, planned major events and natural disaster
Spectrum allocated to PSAs was considered sufficient for all scenarios modelled
except for the worst case scenario which the ACMA argued would not be served
solely by a PSMB network even if 20 MHz were offered.
The large scale incidents modelled by the PSMBSC were based on two
natural disasters including one based on actual events and the other on an
extreme inner-urban threat response. On the worst case scenario, Mr Cheah added
that the key issue in such a situation was not having large amounts of 'valuable
spectrum unused on standby but, rather, having arrangements in place so that
the agencies are able to get access to quickly-scalable communications
The ACMA argued that there were other means available to PSAs for serving large
amounts of highly-concentrated and localised traffic such as 4.9 GHz,
deployment of cells on wheels (COWs) and the potential for increased use of
In an October 2012 publication regarding its initiatives and decisions,
the ACMA noted the following in relation to the provision of spectrum:
Throughout the PSMBSC process, it has been recognised that no
amount of spectrum used by a conventional cellular network is likely to satisfy
a localised, short-notice spike in demand that might result from a major
incident such as a terrorist attack in a central business district or major
urban centre. Furthermore, it would be highly economically inefficient to try
and dimension spectrum provisions around what might be a once-in-a-generation
event. Instead, the ACMA has identified other ways to increase capacity that
are likely to be more effective in practice.
The same publication noted that the ACMA did not consider it appropriate
to provide high value spectrum for rare contingencies such as worst case events.
Mr Cheah of the ACMA noted its opinion in March 2013 that 10 MHz was
sufficient for the scenarios modelled including regional disaster responses. He
continued that if the ACMA provided double the spectrum for the worst case
contingency, 'the evidence shows that in the absence of such an event
occurring, the additional 10 MHz of spectrum would be largely underutilised'.
Mr Cheah concluded that:
Given the rarity of this event occurring, this could mean
that 10 MHz of spectrum in the 800 MHz band would effectively lie fallow
The ACMA's allocation of 10 MHz was supported by other witnesses to the
inquiry including the Australian Mobile Telecommunications Association (AMTA)
which recognised that 10 MHz as likely to exceed the modelled requirements of a
nationally interoperable PSMB capability.
AMTA held the view that as the ACMA's modelling showed that 20 MHz would not be
sufficient for a 'once-in-a-generation' event, the likelihood of such an event
'means that it would be ineffective and irresponsible to allocate more than 10
MHz of spectrum to cater for such a worst case scenario'.
Concerns raised with the scenarios considered by the ACMA
The governments of Western Australia, the ACT, Victoria and NSW
highlighted that a PSMB capability must meet both business-as-usual operational
needs and support responders effectively when crisis events occur.
These jurisdictions, as well as the NSW Police Service and the PFA, were
consistent in their position that the ACMA's proposed allocation was based on a
business-as-usual approach which had not taken into account the growth in
demand for PSA services, rapid technological change including the development
of PSMB applications, as well as large-scale or major events such as a
terrorist incident or serious natural disaster.
The involved jurisdictions urged the allocation of an additional spectrum to
the current 10 MHz reservation as soon as practicable and no later than 2020.
In their February 2013 joint submission to the SCPEM and the ACMA, the
governments of NSW, ACT, Queensland, South Australia, Tasmania, Victoria and
Western Australia identified three factors that would result in a greater PSA
demand for business-as-usual mobile broadband including growth in PSA numbers,
operational demand for PSA applications, and the likely evolution of PSA mobile
broadband applications and their associated users. The following section
details these considerations as well as other evidence which raised concerns
regarding the ACMA's allocation of 10 MHz of spectrum and the consequences for
Business-as-usual demands and
According to the submissions of the WA, ACT, Victorian and NSW
governments, experience in the United States of America (USA), Canada and parts
of Europe indicates that 10 MHz of spectrum does not provide sufficient
bandwidth for incidents that occur 'on a daily basis'.
The PFA raised concerns that the 10 MHz provides for spectrum for
day-to-day work when nothing goes wrong.
PFA Consultant, Mr Robert Waites argued that 10 MHz will provide
agencies who seek to conduct their day-to-day business at the same time with
'insufficient broadband spectrum'. Mr Waites provided an example of New Year's
Already if you look at the major events in any capital city
in Australia, and I talk personally because I was the commander of the city in
Sydney for five years, on New Year's Eve data systems collapse currently. They
collapse because of congestion.
If you have the same sort of scenario with the emergency
services working on New Year's Eve, just in the inner city of Sydney, again,
they will not be able to operate.
Mr Waites of the PFA explained that from an operational perspective, the
provision of 10 MHz would also mean that many first responders will not be able
to get the data they require to make predictions regarding security at public
events. Mr Jim Hewitt, Representative of the NCCGR, who noted that most
people have 10 to 20 MHz coming into their own homes on their own asymmetric
digital subscriber line (ADSL) accounts, explained that every responder who
turns up to deal with a public safety incident has to share four to five MHz.
Thereafter, once that share is divided up into video streams and moving GIS
files (geographical information) which are substantial, the capability is going
to get used up quickly. Mr Hewitt provided an example of an industrial fire
that occurred in North Canberra in September 2011 whereby:
In that sort of situation you are moving mapping products out
to the people in the field. You are designating where roadblocks are going to
be. You are designating where plumes of smoke, possibly poisonous smoke, are
going. You are designating evacuation areas. Met data is being pumped into
those sorts of products. It is all going backwards and forwards from the
responders and from our headquarters in Fairbairn.
By contrast, however, Mr Waites of the PFA argued that 20 MHz would
enable all responders to get the same sort of data level at all times. Furthermore,
he asserted that 20 MHz would enable PSAs to effectively utilise
technology such as body cameras which enable the recording of facial
recognition, numberplates and building location information. Similarly, the
utilisation of body biometrics would enable PSAs to monitor the wellbeing of
first responders such as police officers as well as fire officers under stress
during emergencies. Without the capacity to apply such technology in a timely
way, agencies will not be able to understand the difficulties and stresses that
their officers are undergoing.
Assistant Commissioner Peter Barrie of the NSW Police Force explained that
there were two key operational capability considerations:
The first and foremost is that to restrict to five plus five
will have a significant impact on anything you want to do other than business
as usual. That makes it very difficult to rely on that kind of service in terms
of response to mission critical events...The second...is perhaps the difference in
the quality of images that might be reasonably obtained without massive
investment in infrastructure. An image of poor quality is going to be of very
limited value to you, for example in the scenario...of the bank robber. In one
image you might not be able to see a firearm and in the other image you would
quite clearly see the firearm and the nature of it. That can have a significant
value to us in being able to assess what the capability of that person is and
what threat they pose—is it a .22 or is it a more significant firearm of high
capacity, but also in terms of our ability to bring in experts into a scene
from a virtual perspective. There would be limited value, I would suggest, in
bringing a forensic expert in to assess a scene based on a poor quality image.
It is certainly going to be difficult to produce that in evidence because there
would be some conjecture about what that image actually depicted, and certainly
there would by some difficulty in the expert giving a rational position based
on what they could see.
Assistant Commissioner Barrie held the view that by considering business
as usual and once-in-a-generation events, the ACMA had excluded events that
occur in between. He maintained that it is the response to all of the events
that occur 'in between' that provides the evidence to support the consistent
argument of the police force sustained over the past three years that PSAs
require 20 MHz to be able to respond.
The PFA argued that business-as-usual activities assume that only a
limited number of police response teams and personnel are involved in
communications, including between incident control centres and the incident
Yet, the business-as-usual mobile demands of PSAs will continue to grow as
demand for the services of PSAs increase for reasons including population growth,
increased adoption of mobile data services by PSAs and the evolution of PSA
mobile broadband applications. The WA Government and other jurisdictions noted
that this growth is reflected in international comparisons, particularly in the
USA, Canada and parts of Europe.
The jurisdictions argued that there will be a natural growth in the
number of PSA units as Australia's population grows and demand for public
safety services subsequently increases.
In the ten years to 30 June 2007, the average annual population growth rate in
Australia was 1.4 per cent while in the 2011–12 financial year, Australia's
population increased by 1.6 per cent to approximately 22.68 million.
The Australian Bureau of Statistics projects that by 2026, the Australian
population will have grown to between 25.9 million and 28.7 million.
While the size of PSAs will grow to meet the needs of the growing
Australian population, respective Australian governments may also create new
PSAs (in the future) which will need access to the PSMB network.
Development of PSMB applications
Law enforcement and other PSAs are in the early stages of mobile
broadband use. Growth factors not only include increasing demand for public
safety services but also the take-up of mobile data services as well as the
development of new PSMB applications for law enforcement and other emergency
Gibson Quai-AAS noted that that once new mobile data services become available
in operational environments, 'the demand increases rapidly and often
significantly exceeds the original estimates of demand'.
Similarly, Mr Greg Bouwmeester, Southern Area Sales Manager of Motorola
Solutions, explained that a 2012 practical demonstration of spectrum capacity
set up by Motorola and the Western Australian Police in Perth proved that once
PSAs have the opportunity to see what the technology was capable of, and to
look at the applications, their understanding and appreciation of how such
capabilities could operate in real circumstances 'tended to evolve and change'.
Mr Hewitt of the NCCGR further observed that while extensive modelling and
engineering can be carried out, it was not until PSAs are in the field that
they discover that they have inadequate bandwidth.
In their joint submission to the SCPEM and the ACMA in February 2013,
the states and territories noted that the data demand figures considered by the
ACMA were estimates derived from data provided by PSAs in 2011 which projected
their operational requirements for mobile broadband to 2020. The Gibson Quai-AAS
report, which drew on the evidence provided by the PSAs, recognised that PSAs
were in the early stages of developing operational models and business plans
that can leverage off the capabilities of mobile broadband services and
particularly services such as video.
As these projections were likely to evolve and change over time, Gibson Quai-AAS
noted that such changes should be taken into account.
Consideration of projected demand was noted by a 2011 Canadian study
which projected public safety data demand 20 years ahead. The study's authors
argued that 10 + 10 MHz was insufficient to support the needs of PSAs in the ten
to fifteen year horizon.
It was observed that:
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 also exceed 20MHz in the long term,
despite advances in technology. Clearly even with the full 10 + 10 MHz
allocated, the community will need to take measures to efficiently manage
broadband data communications carefully during periods of peak demand.
Mr Tony Sheehan, Deputy Secretary of the AGD acknowledged the
difficulties in judging what further efficiencies will be achieved in 2015–16 through
the lens of 2012–13 technology.
Similarly, Mr Keith Besgrove, First Assistant Secretary, DBCDE explained that:
The whole purpose of this work is to develop a future
capability that does not currently exist in Australia.
In an article in CommsWire dated 14 March 2013, Mr Graeme
Philipson stated that a 'consensus is emerging' that the allocation of 10 MHz
of bandwidth in the ACMA's spectrum allocation is 'insufficient' for
Australia's emergency services. He argued that more will be needed to handle
new applications such as predictive policing which rely on large volumes of
data (called Big Data) and high bandwidth applications such as video monitoring
to work effectively. The article cites Motorola's Senior Vice President for
Government, Mr Bob Schassler who stated that 20 MHz was needed to address the
wireless data explosion in emergency services.
Mr Schassler was quoted as stating that:
We see a tenfold increase in bandwidth growth in emergency
services in the next few years. Public safety and emergency services have a
very different usage profile than most other users of high bandwidth. There are
hotspots geographically and peaks by time, both of which vary enormously. And
upload is as important as download.
Deputy Commissioner Phelan of the AFP also emphasised that the growth of
potential to reach well beyond the capacity of a 10 + 10 MHz spectrum
provision. He explained that:
The amount of information that is going to be available to us
in terms of the size of files, the amount of information that is available to
transmit, we will need that capability into the future, and if we do not take
the opportunity to harvest it now we will be back here in five years time
asking someone else to reharmonise another spectrum again so we can find some
spectrum just so we can keep the country safe. It seems to me that while we
have the opportunity we should be doing it now.
The joint states and territories submission to the SCPEM and the ACMA
also highlighted the evolution of PSA mobile broadband applications and their
associated usage. In 2011, the ACMA estimated that between 2007 and 2014, there
would be a 30–fold increase in mobile broadband demand in Australia.
Drawing on this evidence, the states and territories argued that the PSA's
business-as-usual demand profile could increase at the same rate as that for
the commercial sector. Moreover:
Even a modest sustained growth rate in data demand would
impact on the adequacy of the ACMA's PSMB spectrum decision for PSAs' future
needs. If, for example, PSAs' business-as-usual demand profiles increases by 5
per cent per annum, LTE technology advances are unlikely to keep pace with such
growth year on year and future bandwidth allocation will be necessary.
In terms of the rapid growth and usage of mobile technology, Ericsson stated
that globally, the number of mobile broadband subscriptions had grown by an
estimated 45 per cent over the past twelve months, amounting to around 1.7
billion at present. Furthermore, mobile broadband continues to drive strong
traffic growth with mobile data expected to grow at a compound annual growth
rate of approximately 50 per cent which will mean that data will grow by twelve
times between 2012 and 2018.
This evidence was supported by a Deloitte study which noted that the demand for
bandwidth will be tested further by exponential growth rates in mobile data
usage across the community and the PSAs.
Orange Horizons Pty Ltd made the point that while the PSAs have not had experience
with the facilities offered by mobile broadband and or any substantive understanding
of how it will be used in the future, public carriers have been forecasting on
their predicted needs for years. According to Orange Horizons, however, each
time they prepare forecasts of usage they have found that the actual demand has
far exceeded their initial estimates and that there is no reason to believe
that the situation will by different with emergency services.
At the same time, Orange Horizons noted that present estimates of usage are
most likely to be 'well short' of the actual requirements in the years to
It would be a very short-sighted view to limit the amount of
spectrum to the proposed 2 x 5 MHz blocks based on meeting current usage
without having sufficient spectrum in reserve to meet actual demands in the future;
this decision could have a serious impact on future emergency management
As the applications field is very fluid and as the PSMB networks are
installed around the world, more specific applications will become available,
many of which will involve actual users influencing the software and its
Ericsson noted in this regard that LTE is the first truly global mobile
technology and has achieved vast global scale in a few short years since being
launched in Norway and Sweden in December 2009. According to Ericsson, it is
widely acknowledged that 'LTE is the fastest growing ecosystem, ever'.
Mr Hewitt of the NCCGR highlighted the rapid changes in demand for data
by drawing on the example of hard drives whereby 20 years ago, the expectation
was that 'we would never fill one meg hard drive' and yet now terabytes are
sitting on our personal computers.
He noted that a similar phenomenon has taken place with regard to data series
on mobile phones and so:
Once people understand what they can do with this technology,
and the fact that they have a bearer they case use, applications will start
popping up all over the place and they will chew the capacity up quickly.
The Association of Public-Safety Communications Officials (APCO)
Australasia expressed the view that the communications capability of the
general public has, for the first time, exceeded that of the PSAs largely on
the basis of the availability of broadband technologies and a willingness to
exchange information through various channels on a 'real time always connected
basis'. APCO Australasia further highlighted that the environment was one in
which the rate of change in technologies, need to share infrastructure and risk
allocation as well as the potential use of different procurement models and
need to at least keep pace with the communication capabilities of the public
will have an impact on the PSAs and their budgets which is yet to be
Similarly, Mr Schassler of Motorola Solutions was cited as acknowledging that
once the bandwidth was allocated, it can never be taken back while:
As it is, at the moment our kids have better technology than
our emergency services. We need to prioritise public safety, and make sure it
doesn’t miss out on the mobile and Big Data revolution. Every dollar spent on
public safety returns five dollars to the community.
Major urban incidents and 'once-in-a-generation'
Submitters voiced concern with the ACMA's analysis of major urban
incidents and 'once-in-a-generation' events. In particular, they pointed to the
increasing frequency of natural disaster and growing terrorism threat. The WA
Government, for example, asserted that spectrum allocation must take into
account demand for major urban incidents including the likelihood of a major
urban incident such as a terrorist attack, natural disaster (particularly given
the growing frequency of such events) or security operation for an
The WA Government argued that the ACMA did not provide sufficient spectrum for
these types of events on the basis that it is not appropriate to provide high
value spectrum for 'rare' contingencies. However, many state and territory
jurisdictions did not support the ACMA's view that such incidents were rare
contingencies or once-in-a-generation events.
The joint February 2013 submission of states and territories requested that the
ACMA revisit its assessment and consider further evidence in relation to
natural disasters, terrorist attacks, security operations for international events,
and small and medium-scale incidents.
Evidence also suggested that, what ACMA considered once-in-a-generation
events, in fact occur far more frequently. The National Strategy for Disaster
Resilience highlighted that Australian communities face devastating losses
caused by disasters every year.
COAG's National Disaster Resilience Statement of December 2009 noted the
'increasing regularity and severity of natural disasters'.
Furthermore, the National Framework to Improve Government Radiocommunications
Interoperability endorsed by COAG, noted that the 'impacts of climate
change and the continuing threat of terrorism are likely to increase the trend
towards inter-jurisdictional operations'.
In support of this finding, the AGD noted that in the fifteen years since 1994,
inter-jurisdictional responses had been required on average every 2.5 years.
The PFA and the NSW Police Force observed that the once-in-a-generation
scenario has already taken place six times in the last four years.
This evidence was also supported by Deloitte which noted that research has
shown that large scale disasters are no longer once-in-a-generation events, but
rather 'growing in frequency and severity'.
During various natural disasters which occurred between November 2010 and
February 2011, more than 99 per cent of Queensland was disaster-declared
while all other states and the Northern Territory experienced severe weather
events or other natural disasters such as bushfires.
According to the joint states and territories submission to the SCPEM and the
The evidence of increasing frequency and severity of natural
disasters appears to be at variance with the ACMA's assessment that demand
profiles for such incidents should be excluded from 800 MHz band decisions as
such events might only occur in major urban areas "once in a
In relation to terrorism, the Australian Government has recognised the
threat of terrorism as a persistent and permanent feature of Australia's
The 2013 National Security Strategy identified terrorism as a 'persistent
threat' and key national security risk.
According to the Victorian Government, ACT Government and other states,
however, the threat assessments and respective investment in counter-terrorism
capability development and maintenance by Australian governments 'appears
inconsistent with the ACMA's determination that it would be inappropriate to
provide high value spectrum' for these worst case events.
The jurisdictions further noted that there are other security-related tasks
which are expected to impose high demands on mobile broadband including the
future G20 security operation. They argued that while it is possible to provide
for such events through 'detailed planning and engagement with commercial
carriers', an appropriately resourced PSMB network will reduce the reliance
upon commercial carriers to 'deploy additional infrastructure to meet demand
and mitigate the associated operational risks'.
The jurisdictions also raised concern that by not considering
large-scale incidents, the ACMA had 'effectively disregarded' the demand
profiles of small and medium-scale incidents as the revised upper demand limit
became those of the business-as-usual and planned event demand profiles. They
noted in this regard that:
The demand profiles for small and medium-scale incidents are
expected to exceed those of business-as-usual operations but to be less than
those of large-scale incidents (i.e. a middle range). Additional data demand of
planned events will be able to be more readily addressed through pre-deployment
of COWS than is possible during emergencies. The omission of these demand
profiles is of concern to jurisdictions as small and medium-scale incidents
regularly occur—for example, PSAs respond to numerous small-scale emergencies
The NSW Police Force explained that this will significantly restrict the
capacity of operational communications in responding to a range of common
scenarios in a timely and effective manner.
To support their argument further, the jurisdictions cited the findings of a
2011 Canadian PSMB study which concluded that, with spectral efficiency
improvements, a 20 MHz allocation could be sufficient for a PSA response to
small-scale incidents such as severe multi-vehicle accidents, train derailments
and aircraft emergency landings.
Motorola Solutions and Western Australia Police LTE mobile network
As previously noted, the Gibson Quai-AAS report found that once new
mobile data services become available in operational environments, 'the demand
increases rapidly and often significantly exceeds the original demand
In light of this evidence, the committee considered the importance of
operational testing. It drew on the evidence from Motorola Solutions which, in
cooperation with the Western Australian Police, established a single-site LTE
mobile network in Perth in mid-2012.
Motorola secured a temporary licence for the 700 MHz spectrum band from
North America in Midland, Perth to run a field demonstration of its emergency
service network equipment. Motorola Solutions explained that as PSAs were still
trying to understand the usability of the technology, what it enabled and how
it could be used in an operational sense, the demonstration provided an
opportunity to set up a live network to run scenarios with equipment based on
input given from PSAs.
The emergency scenarios including bush fires, floods, car accidents and other
incidents and the staged area was approximately 1.5 kilometres from the site
(or tower) because it represented the middle of the cell coverage, a typical
type of scenario rather than on the edge of the cell coverage under the maximum
Mr Greg Bouwmeester, Southern Area Sales Manager for Motorola Solutions
explained the tests:
We ran a number of predictions based on the site in
Mainlands, which were run both at 10 megahertz and at five megahertz. It was
operated at a particular loading. The assumption on those plots is that you are
constantly streaming data at about 700 kilobits per second—the sort of
bandwidth you would require when transmitting video. We were able to
demonstrate running that video at the various bandwidths. What you find is that
when you switch from a 10 megahertz bandwidth—or a 10 plus 10, a 20 megahertz;
I need to be careful with my terminology here—you have a bigger pipe. You can
send more data. In the last scenario we ran, which was a multi-agency scenario,
where we had video going between police, fire and ambulance, when we chose to
switch it down to five megahertz, effectively the capacity dropped down and you
started having images freezing or not coming through.
ZDNet reported that:
In a single scenario, the company demonstrated multiple users
accessing varying degrees of video streaming from different locations over an
LTE network. With more users on the network, congestion became a major issue.
For this reason, the company said that, not only should
emergency services have their own dedicated network, it should also utilise
20MHz of spectrum (as has been done in the US) rather than just 10MHz.
Motorola Solutions noted that where PSAs are trying to run video and
related applications either greater bandwidth or more sites is required.
However, Mr Bouwmeester explained that:
By having a 10 plus 10, you have access to that bandwidth and
you can actually achieve these things. If you reduce to five plus five, either
you will not get the bandwidth through or you will have to put more sites in.
Mr Bouwmeester also noted that if an incident is in a localised area
then having multiple sites does not necessary provide greater capacity if PSAs
are accessing only one site. He asserted that where fifteen agencies or
applications are accessing one site, whether or not they have another site next
door makes no difference, as they are still limited in the capacity that they
The PFA provided four maps of the exercise.
Maps 1 and 2 depicted 20 subscribers and 15 subscribers at 5 MHz + 5 MHz
whereas maps 3 and 4 depicted 20 and 15 subscribers at 10 + 10 MHz. Mr Waites
of the PFA explained that 20 subscribers is not unusual for a major
traffic accident. For example, police, fire and ambulance officers will attend
an accident such as the rollover of a petrol tanker or chemical tanker. During
such an event, 20 first responders will be trying to access data from their own
service databases (or gazeteer) which contain relevant information such as
maps, details about chemicals, utilities and related matters which are required
to respond effectively and safely. The maps revealed that a total of 20 MHz (10
+ 10 MHz) makes what Mr Waites described as a 'massive difference' to those
responding, both in the area of coverage and in terms of the power of coverage.
The demonstrations revealed a 'noticeable jump in quality' when public
safety agencies were allocated a 10 MHz + 10 MHz chunk of bandwidth, as opposed
to 5 MHz + 5 MHz. Of the results, Mr Starr argued that:
A purpose-built broadband network gives the coverage and
capacity required, but also the ability to control and prioritise traffic.
Motorola Solutions has consistently argued that the 700 MHz spectrum
should be reserved for public safety organisations as video streaming becomes
increasingly important for dealing with crisis situations.
Resourcing law enforcement
Evidence to the committee from law enforcement underscored the
importance of accessing accurate, timely and coherent audio and visual
information. This concern was clearly demonstrated in two images provided by
Motorola Solutions (below). The images reveal the difference between 10 and 20
MHz from the perspective of law enforcement operations.
Figure 4.1: 10 MHz of Spectrum and
20 MHz of Spectrum
Source: Motorola Solutions, Submission
10, p. .
Mr Bouwmeester from Motorola Solutions explained that the quality of the
image will dependent on bandwidth and data throughput. Furthermore:
The best way to explain the five versus 10 is in relation to
the size of a pipe that you can put stuff down. If you have a pipe of a
particular size and you have full access to that, yes, you can put high-quality
video or image through. The reality, in the real world, is that you do not have
one single user on a pipe; you have multiple users. The demonstration there was
to say: if I had a pipe of a defined size—let us say it was a five-megahertz
pipe—and I had lots of data going through it and I wanted to try and transmit
that image, in five megahertz, because I am restricted by that pipe, I can only
get that sort of resolution. If I had a bigger pipe, I could send a higher
Mr Bouwmeester noted that regardless of the size of the pipe, it can
overload and overflow will occur and users may be kicked off. The underlying
premise, however, is that if the pipe is small to start with then capacity will
be exceeded significantly faster.
Police agencies noted that the information provided of such a scene
could be critical to determining how best to respond. Mr Waites from the PFA
explained that the difference for policing operations between the two images
was that of facial technology, the ability to identify the weapon as well as to
recognise who had it and what they were doing with it. Mr Waites noted that:
The same sort of detail does not exist in the left-hand side.
In fact, the left-hand side could be somebody doing anything. Unless you are
already aware of some other information, you would not really be able to
recognise exactly what that was, whereas on the right, you certainly can.
Mr Waites further highlighted that access to such information would
ensure that there was no 'unnecessary reaction in the wrong way'. Without the
detail made available in the photograph on the right, it would be difficult to
determine whether the most appropriate response would be immediate action
rather than 'contain and negotiate'.
Costs including infrastructure considerations
Another matter considered by the committee was the costs associated with
the decision to allocate 10 MHz rather than 20 MHz of spectrum. In particular,
it was noted that there may be greater infrastructure costs associated with a
10 MHz allocation. For example, the NSW Police Force expressed concern that the
ACMA's multi-layered proposal provides added capacity through additional
infrastructure which is costly and inconsistent with the operating environment
of public safety agencies.
In their joint submission to the SCPEM and the ACMA of February 2013,
the ACT, NSW, Queensland, South Australia, Victoria and WA governments noted
that, in relation to the option of network 'densification', there would be a
significant cost trade-off in designing, building and operating a PSMB 10 MHz
spectrum network compared to a network on a greater allocation of spectrum.
The jurisdictions argued that the estimated increase in network costs (to
achieve equivalent capacity with a network dimensioned on 20 MHz of spectrum)
is likely to be substantially more than the commercial value of the additional
spectrum and would represent a significant cost shift from the Commonwealth to
the states and territories.
Evidence from the Western Australian Government estimated an increase in
capital and operating costs to provide, in the greater central business
district area only, comparable total data capacity through a 10 MHz network
rather than a 20 MHz network. The jurisdictions provided the following
indicative cost differentials to make the point while noting that they are
subject to refinement following further planning.
Figure 4.2: Indicative cost
differentials over 15 years – selected jurisdictions
Indicative cost differential over 15 years (increase in costs
for a 10 MHz network in comparison with a 20 MHz network)
40 per cent – 50 per cent
23 per cent
25 per cent – 50 per cent
20 per cent
Source: Western Australian Government, Submission 4,
Attachment 2, p. 16.
The jurisdictions further explained that the indicative cost
differentials for a 10 MHz network do not necessarily assume that jurisdictions
will attain an equivalent data capacity throughout the entire coverage area to
that of a 20 MHz network. They argued that to achieve an equivalent data
capacity, the number of network sites would have to be approximately doubled
and additional costs could be greater.
Mr Sheehan of the AGD acknowledged that the potential for greater costs
in the construction of a dedicated capability in relation to a 10 MHz spectrum
allocation as opposed to 20 MHz was understood but noted that the ACMA was best
placed to canvas cost questions.
The ACMA recognised that as a spectrum allocation grows, fewer base
stations are needed. At the same time, however, it highlighted that as high
value spectrum below 1 GHz is scarce, a trade off where spectrum is
sacrificed to save on infrastructure should be avoided.
Furthermore, the ACMA highlighted that:
...the argument that spectrum and cell size can be traded
against each other only applies to appropriate dense network topologies,
ie. networks with reasonably closed spaced base stations, and not...large cell
However, the states and territories held the view that the estimated
increase in network costs (to achieve equivalent capacity with a network
dimensioned on 20 MHz of spectrum) is likely to be 'substantially more than the
commercial value of the additional spectrum' which would represent a 'significant
cost shift from the Commonwealth to the States and Territories'.
In terms of costs, Ericsson noted that the construction of physical
infrastructure by way of towers and the sites themselves represent 80 per cent
of the overall radio network costs compared to the 20 per cent on equipment.
According to the jurisdictions, an approach requiring greater infrastructure
density is suitable for market-oriented organisations such as commercial
carriers which generate financial profits from their use of spectrum which can
be reinvested in additional infrastructure and whose networks are designed for
average usage throughout the network. In contrast, PSAs are focused on
providing public services in order to protect lives and property and require,
according to the jurisdictions, networks designed for peak usage in
concentrated areas with a critical grade of service that exceeds that of
commercial entities. Furthermore:
PSAs do not generate profits that can be reinvested in
additional infrastructure. Any additional investment would need to come from
State and Territory Governments and would involve diverting investment away
from other community services that also produce a public benefit.
The ACMA is reported to have advised the PSAs that in order to ensure
the data capacity required to support operations on a 10 MHz spectrum
allocation, owners will need to increase the density of their fixed network
sites and that a balance between the size of spectrum allocations and
infrastructure investments is required.
The joint submission of the states and territories recognised, however, that
any approach requiring greater infrastructure density would be better suited to
commercial organisations which generate profit from their use of spectrum.
Furthermore, while commercial networks are designed for average use throughout
the network, PSA networks are designed for peak usage in concentrated areas.
The jurisdictions also noted that:
Across the same coverage area, increasing fixed
infrastructure density with a 10 MHz allocation can result in a comparable
total data capacity as a greater allocation (e.g., in comparison to a 20 MHz
allocation, through the doubling of network sites). However, multiple PSA
responders at the point of operational need in a specific cell (or part of the
cell) will not necessarily have access to the equivalent level of data capacity
as they would with a greater spectrum allocation.
According to the jurisdictions, the Gibson Quai-AAS spectrum
calculations across all demand profiles assume that PSA responders and demand were
evenly distributed across the coverage area. However, the operational
experience of PSAs indicates that responders more commonly operate in a cluster
or series of clusters around the most critical point(s) of response. During
mission-critical operations where the primary response of PSAs is concentrated
around a relatively small area such as a train crash site, a greater allocation
of spectrum is likely to better meet the operational needs of PSAs even if the
infrastructure density has been increased. To achieve the equivalent total data
capacity as a 20 MHz network site, two 10 MHz sites covering the same area
would be required. According to the jurisdictions:
This would however, mean that the total data capacity is divided
between 6, as opposed to 3, cell sectors, which reduces the amount of data
accessible by responders at any given point. From a PSMB network perspective
the clustering of responders around the incident site may well occur within a
single cell sector—if this does occur responders could have immediate access to
only 50 per cent of the data capacity with a 10 MHz network compared to a 20
Motorola Solutions made the point that while additional towers involve
costs, there are other considerations including environmental impact as the
community will resist densely populated towers.
Moreover, Motorola noted that if 5 + 5 MHz were allocated to PSAs, as a
technology manufacturer, the company would actually sell more equipment.
The PFA argued that, while the Radiocommunications Act requires
the ACMA to consider the needs of PSAs for the mission critical work they
perform to protect life and property in times of disaster and emergencies, it
is exactly when their needs are most acute in the performance of this function
that the spectrum proposed will be half of what is needed.
The PFA further argued that:
We believe that it is precisely the PSA needs in time of
emergencies and natural disasters that the Act is directed at, and where the
ACMA proposal falls seriously short.
Similarly, the Victorian Government, NSW Government, ACT Government and
WA Government argued that due consideration should be given to the concerns of
jurisdictions when the overall value of spectrum for PSMB is calculated. Such
- the higher level of operational risks to PSAs should spectrum
allocation be insufficient;
- the opportunity costs of additional investments by state and
territory governments in building a PSMB capability with a lower spectrum
- the public safety benefit that a PSMB capability will provide to
Another matter raised during the inquiry which was the subject of
competing claims was that of contiguous spectrum. Mr Hewitt of the NCCGR
informed the committee that contiguous spectrum was required by PSAs.
However, according to the ACMA, multi-carrier aggregation (notionally pairing a
lower and higher band) is supported by the LTE standard. Yet, the ACMA noted
that achieving multi-carrier aggregation would require 'additional complexity
in the handset and base stations'.
Extraordinary access to additional spectrum
The ACMA raised the possibility of providing extraordinary access to
additional spectrum under section 27 and Part 4.4 of the Radiocommunications Act.
However, such a prospect raises questions regarding the resourcing of PSAs. The
ACMA noted for example that under such an eventuality, PSAs would need to
ensure that they have procured suitable equipment and infrastructure including
handsets with appropriate chipsets and additional transmit and receive cards
installed in base stations in order to enable the operation of additional
The jurisdictions and law enforcement agencies raised concerns that the
extreme circumstances provisions in the Radiocommunications Act are untested
and unlikely to be able to provide surge capacity in the first few hours of
response to a sudden-onset emergency when that capacity is most needed.
The NSW Police Force further noted that the legislative provisions are not a
realistic mitigation strategy for addressing network capacity issues arising
from periods of peak demand.
Motorola Solutions highlighted that the allocation of 20 MHz (10 + 10
MHz) is the standard globally while the PFA noted that 20 MHz for law
enforcement is the prevailing minimum.
Similarly, Mr Hewitt of the NCCGR held that, based on overseas cases where such
systems are currently being deployed, the universal understanding was that 20
MHz is the 'absolute minimum' that PSAs need to run a system effectively.
A number of European countries, for example, have concluded that a 10 MHz
spectrum allocation will not provide sufficient bandwidth for incidents that
occur on a daily basis and have either allocated or are considering the
allocation of greater spectrum accordingly.
At the same time, it should be noted that countries such as the USA and Canada
commenced with an allocation of 5 + 5 MHz for PSMB but had to revisit the
allocation and provide a total allocation of 10 + 10 MHz 'based on subsequent
analysis of operational requirements'.
Motorola Solutions noted that early in the development of LTE and a
spectrum allocation to public safety organisations, the USA allocated what it
thought to be an adequate amount of spectrum for LTE public safety broadband
communications. The USA allocated 5 MHz (for uplink) + 5 MHz (for downlink). However,
as the specifications for LTE were further developed and public safety agencies
became more aware of the capabilities of LTE, the limitations of the 5 MHz + 5
MHz allocation became apparent.
Similarly, the PFA and various jurisdictions gave evidence that the allocated
10 MHz fell short of what they needed to communicate effectively.
According to Motorola Solutions, after years of lobbying, an additional
allocation for use by public safety agencies was provided with the USA allocating
a total of 10 MHz + 10 MHz of spectrum to PSBB.
However, evidence to the committee from the ACMA suggested that
Australia differed to the USA, Europe and Canada in terms of population density
and the number of first responders.
Mrs Cahill of the ACMA further argued that the approach taken in Australia and
the model applied to identify the spectrum needs of PSAs is specific to
Australian conditions which do not provide for like-for-like comparisons.
Yet, Orange Horizons challenged this evidence by noting that Australia's major
cities rank in size as comparable to many of the larger cities in the United
States which means that 'the demand for mobile broadband in our cities will be
similar'. It noted that as data requirements are a result more of population
density than national population, a similar location in Australia to the USA
would be justified.
Orange Horizons stated that where Australia diverts from the USA is in relation
to data usage given that in Australia, most jurisdictions are state-based,
requiring the need for data to be shared over larger areas and provided to
state operation centres. According to Orange Horizons, this wider area of
operations will result in a higher data usage in many areas as it is operated
in parallel with other operational areas and agencies.
Canada is following the lead of the USA and allocated 5 + 5 MHz. An
ensuing public safety campaign generated debate on increasing the allocation of
an additional 5 MHz + 5 MHz. The conclusions of a paper developed by Defence
Research and Development Canada indicated support for the allocation of
10 MHz + 10 MHz of 700 MHz spectrum for PSMB and the Canadian Government
is currently considering a proposal to increase the allocation to 20 MHz.
In Europe, a working group has been established under the European
Conference of Postal and Telecommunications Administrations to consider the
allocation of spectrum for public protection and disaster relief mobile
broadband. According to the Western Australian Government, the working group
concluded that a minimum of 15 MHz (7.5 + 7.5 MHz) was required for everyday
scenarios with at least 20 MHz (10 + 10 MHz) necessary for large-scale planned
Motorola Solutions noted that a separate study for the German Federal Ministry
of Economics and Technology found that a spectrum allocation of 15 MHz + 10 MHz
The committee acknowledges the concerns of a number of states and
territories and their law enforcement bodies that if spectrum allocation is
insufficient, there are high operational risks involved to PSAs which may
impact the safety and security of the Australian public.
Conversely, the committee recognises the substantial public safety benefit that
could be derived from a PSMB capability which is efficient and provides for all
Australians. In this regard, the committee welcomes the comments from Mr Cheah
of the ACMA that if the actual demand from a real world PSMB network proved to
be materially higher than predicted then the ACMA would be prepared to reopen
consideration of the issue.
The committee appreciates that the ACMA undertook a process with PSAs in
2012 to identify their spectrum requirements. As part of this process,
agreement was reached regarding the methodology that would be applied and PSAs
contributed data to inform the process which led the ACMA to identify 10 MHz as
sufficient in four out of five emergency scenarios.
However, the committee also recognises that the PSAs are in the early stages of
developing systems and understanding their requirements in this fast growing area.
Such developments have led various jurisdictions and law enforcement
authorities to recognise that 10 MHz is inadequate for the purposes of responding
to natural disasters and other emergencies in an effective and timely manner both
now and into the future. As the ACMA consistently highlighted that it has taken
an evidence-based approach
to determining the spectrum allocation requirements of PSAs in 2012, available
evidence before the committee (which is also currently under the consideration
of the ACMA) upholds a position underpinned by evidence that 10 MHz is
inadequate and that at 20 MHz is the absolute minimum required.
The ACMA argued that the appropriate allocation of spectrum to PSAs does
not constitute a once-in-a-lifetime opportunity because spectrum is repurposed
every 15 years.
However, the committee recognises that the allocation of sufficient and
appropriate spectrum to PSAs to enable the deployment and growth of a dedicated
mission-critical mobile broadband capability is a once-in-a-lifetime
opportunity. The risks of reverse engineering a solution based on the limited
availability of spectrum should be avoided. Such technology will underpin the
next generation of policing operations into the next decade and beyond. To this
end, the committee recognises that it is reasonable to expect that PSAs will
require 20 MHz of spectrum to provide for a national PSMB network under a
fifteen year licence. The committee recognises that 20 MHz of spectrum will
meet current PSA requirements while providing for expected growth in and demand
for PSAs services into the future.
Furthermore, in order to meet additional PSA demands for spectrum into
the future, the committee takes the view that such agencies should be provided
priority access to an additional 10 MHz spectrum for public safety
PSA priority access could be achieved through the introduction of a licence
condition. Alternatively, contractual arrangements could be negotiated with the
commercial purchaser or the provisions for declarations of emergency in the
Radiocommunications Act may be relied upon.
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