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This chapter considers the evidence in relation to the 700 MHz band and
800 MHz band. In exploring the most appropriate band for public safety
agencies, the chapter considers technical, cost, timeliness and risk factors, and
contextualises international harmonisation efforts.
Allocation of spectrum in the 800 MHz band
According to the ACMA, the original terms of reference for the PSMBSC established
to consider spectrum requirements was to consider an 'allocation if needed from
spectrum in the 800 megahertz'.
Mrs Cahill from the ACMA explained that the focus remained on the 800 MHz band
for three reasons as follows:
First, because the technical characteristics of 800 are well
suited to deployment required by public safety agencies. Secondly because the
timing in terms of when it could be made available and the work that the ACMA
was doing coalesced and it will be made available in the time that is needed
for a roll-out. Thirdly, because it was identified as a potentially harmonised
band in our region. So the actual terms of reference for the Public Safety
Mobile Broadband Steering Committee, which has been in place since May 2011,
have been focused on the 800 megahertz band.
Dr Kerans from the ACMA went on to comment that the spectrum estimation was
undertaken in the ACMA's Spectrum Planning Branch which is made up almost
exclusively of engineers. He noted that the process entailed considering the
data demand methodologies or the data flow required for the operational needs of
PSAs and considering how much spectrum would be required. Dr Kerans elaborated
We did not at any time consider the commercial value of the
spectrum we were allocating. At the moment in the spectrum that we are talking
about—the 800-megahertz block—no decision on the allocation of that spectrum
has been made. We have not finished the review of the 800 band yet. So,
basically, a portion of that was set aside before any of those decisions were
made, based purely on an engineering analysis of the data presented to us.
However, the governments of WA, the ACT, Victoria and NSW held an
alternative view on the allocation. They asserted that spectrum was both
considered and offered in the 800 MHz band on the basis of the following three considerations:
- the importance of regional harmonisation as the 800 MHz band is
being promoted in the Asia-Pacific region as the band for public protection and
- the commercial value of the 700 MHz band which was estimated by
the ACMA to be valued at approximately 28 per cent higher per MHz than the 800
MHz band; and
- the assumption that there would be no 700 MHz band spectrum
available following the April 2013 auction. However, as noted in Chapter 2, two
paired 15 MHz segments, or 30 MHz in total, failed to sell and remain available
in the 700 MHz band.
Stakeholders also held differing views on how the commercial value of
spectrum informed the decision making process. Telstra noted that the
continuing growth in demand for commercial mobile broadband services was one of
the reasons why spectrum in the 700 MHz band was not appropriate for a PSMB
Assistant Commissioner Peter Barrie of the NSW Police Force took the view that
the work of the PSMBSC was restricted by a 'strategic view' of how the 700 MHz
harmonised spectrum would be made available through auction. Furthermore, he
If you exclude that or take it off the table and look at
opportunities in the 800 band, which is quite congested, there is a large
portion of the 800 band that is currently used by the carriers that was
specifically excluded from consideration. There is also a large number of
incumbent users in that 800 band.
The difficulty then becomes, if senior officers have provided
advice that public safety can be accommodated in the 800, going through a
process which clearly defines what those requirements look like in terms of
their capacity, and then finding that they are in a very difficult situation as
to how they are going to achieve that.
The NSW Police Force also argued that the focus had remained on satisfying
the requirements of the ACMA to justify an appropriate allocation of spectrum
rather than the development of the wider scope of requirements needed to
develop and implement the information and communication technology required. It
argued that such an approach had not afforded the PSAs the opportunity to draw
on existing science and innovation capabilities as promoted in the National
Security and Innovation Strategy.
Similarly, Mr Burgess of the PFA noted that as there was an expectation that
the 700 MHz band spectrum would sell, the PSMBSC was set up on the basis of
reviewing the 800 'because there was an expectation that there would be no 700
The DBCDE issued a fact sheet in December 2012 which stated that the
spectrum in the 800 MHz band had almost identical characteristics to that of
the 700 MHz band in terms of:
- data-carrying capacity and ability to support video applications;
- distance covered; and
- ability to penetrate buildings.
Orange Horizons argued that from a technical viewpoint, the transmission
characteristics are effectively the same for both the 700 MHz band and 800 MHz
band as there is 'no technical advantage between them'.
Similarly, Ericsson noted that there was 'negligible difference in coverage
characteristics' between the 700 and 800 MHz bands.
This evidence was supported by the ACMA which stated that the two bands have
'almost identical characteristics'.
However, the PFA put a different view and stated that the 700 MHz
band is the perfect spectrum for PSAs because it is not affected by atmospheric
Mr Waites from the PFA noted that the 700 MHz band was often called the 'sweet
spot' by radio technicians for this reason.
PSAs also raised concerns regarding penetration in relation to the
ACMA's provision of spectrum in the 4.9 GHz band. This evidence was confirmed
by Dr Kerans of the ACMA who acknowledged that the 4.9 GHz band does not
have the same penetrating ability as that of the 700 or 800 MHz bands. However,
he stated that it would be used to offload the data from the network that does
have the penetration.
Costs differences and economies of scale
The committee received evidence from a number of states and territories
which noted that provision of spectrum in the 700 MHz band is expected to
reduce the costs of a PSMB network. The Western Australian Government stated
The reduction in cost is due to the 700 MHz band's ability to
support commercially available public safety grade equipment and systems
integration solutions (whereas the 800 MHz band currently does not).
Similarly, in a joint letter to the Prime Minister of July 2012, the
Premiers of NSW, Victoria, Queensland and Western Australia stated that the
costs arising from building a capability on the 800 MHz spectrum would result
in additional costs incurred by the jurisdictions, 'particularly to purchase
and maintain equipment to establish a public safety capability on this
The ACMA was of a different view, explaining that the only currently
available equipment worldwide is for the USA band plan which both the USA and
Canada have committed to.
However, the ACMA's Mrs Cahill argued that the move to harmonisation or a
standardised approach in the Asia-Pacific region including 'potentially, for
equipment to be standardised' would provide for economies of
There was considerable debate during the inquiry regarding harmonisation
and its potential impact on economies of scale. Mr Abul Rizvi, Deputy Secretary
of the DBCDE, acknowledged that the international community could be divided in
terms of commercial production between the USA and Canada on the 700 MHz band
and others, potentially countries in the Asia-Pacific including Australia,
which might choose to allocate spectrum in the 800 MHz band to PSAs.
Motorola Solutions clarified that, were spectrum to be allocated in the lower
part of the 800 MHz band, then it and other manufacturers would have to start
customising chipsets for what would amount to a relatively small market
resulting in a higher cost per unit.
Mr David Hill, Area North Manager, Government and Public Safety, Motorola Solutions
The chipsets have to be developed for a specific band set, or
set of bands, depending on the particular region. Here, in Australia, chipsets
are developed harmonised for all of the spectrum that is currently being used
by the commercial operators. Similarly, there is a much larger potential market
in the 700 megahertz band in the Asia-Pacific. I should clarify that point,
too: we are not advocating using the North American band plan here, in
Australia. We are advocating using the harmonised. When we are talking about
the 700 megahertz spectrum we are talking about the harmonised Asia-Pacific
spectrum, which has already been agreed by all the countries in the region.
Mr Hewitt of the NCCGR argued that there is a significance difference
between the 700 and 800 MHz spectrum: there is a 'clear and free chunk of
spectrum' now available in the 700 MHz band which is going to be used
internationally for LTE and that in terms of commercial risks, the 700 MHz band
is less of a risk than the 800 MHz band. Mr Hewitt noted that:
The choices of spectrum in 800 should be looked at quite
carefully. If the chunk at the bottom of the 800 is used, the capacity for
expansion is quite limited because you are sitting on top of the 700 megahertz
allocation, which has already been allocated to commercial operators. It would,
basically, snooker you into a corner.
Mr Hewitt further explained that as there is only 10 MHz available in
the 800 MHz to PSAs, it leaves 'nowhere to go after that'. Therefore, he
concluded, PSAs should not be using that piece of spectrum if they wanted to
expand their contiguous spectrum allocation at any stage.
In response to this argument, Dr Kerans of the ACMA stated that if more
data is required then PSAs can increase the density of their networks. In this
regard, he noted that this is what commercial carriers do in cities and what
the ACMA expects PSAs to do as their data needs increase into the future.
However, PSAs emphasised to the committee that they do not, and cannot, operate
in the same way as commercial carriers.
They provide a service to the community largely free of charge and cannot,
therefore, reinvest profits into infrastructure to meet data needs as they
arise. Given their mandate to save lives and protect the community, PSAs must
respond to emergencies and disasters in a timely and effective manner in order
to meet community needs and fulfil community expectations. Their operational
decisions are based on saving lives rather than maximising return. For these
reasons alone, PSAs cannot be expected to operate in the same way as commercial
Securing the necessary spectrum in a timely manner
According to the ACMA, its offer of 5 MHz + 5 MHz of spectrum for public
safety mobile broadband will be made available in 2015 in areas where PSAs advise
that it is required. Dr Kerans from the ACMA explained that while the top 5 MHz
(820 – 825 MHz) which is paired with 865–870 MHz is currently occupied,
the block below (810 – 820 MHz) is clear as a result of the digital
dividend and will be available in the same timeframe as the 700 MHz band. Dr
Kerans further noted that the ACMA had given an undertaking to the PSAs that,
'provided they undertake to build a network' which he noted they have not done
to date, 'we will commence the clearance of the band'.
However, the PFA noted that while 10 MHz of spectrum in the 800 MHz band
might be cleared by 2015, it would be 'exceedingly difficult to make 20 MHz of
cleared spectrum available in that timeframe'.
Similarly, Motorola Solutions made the point that the 700 MHz network and the
services to the PSAs would probably become available from 2014 whereas in the
800 MHz band, it might be available from 2017.
Motorola Solutions noted that:
Given the high level of incumbency in the 803–960 MHz band
and the requirement to potentially relocate a significant number of users from
parts of the band, it is envisaged that implementation will occur over an
Motorola Solutions explained that the allocation of an additional 5 + 5
MHz (above the current offer of 5 + 5 MHz) in the 800 MHz band would take more
than five years as it will require the clearing of currently occupied spectrum
before any re-allocation was possible.
The PFA also noted that it could take five to ten years to clear out 20 MHz in
the 800 MHZ band 'depending on the current licences that exist there'.
Motorola Solutions cited evidence from the ACMA which held the view that
the timeframe for availability in relation to this option of 10 + 10 MHz
would be 2017 at the earliest and amount to an allocation between 814 MHz
and 824 MHz paired with 859–869 MHz.
Evidence to the committee suggested, however, that the challenges in
relation to clearing the 800 MHz band do not apply to the 700 MHz band which is
'ready to go'.
The recent auction of 700 MHz spectrum which is being made available through
the digital dividend process left 30 MHz (15 + 15 MHz) of unallocated spectrum.
Motorola Solutions noted that sufficient spectrum could be allocated from this
band 'almost immediately' and would become available for use after the
television re-stack process is completed at the end of 2014.
Similarly, the Western Australian Government noted that in contrast to the
uncertainty surrounding the availability of the 800 MHz band, provision in the
700 MHz band could be made when analogue television is switched off across
Australia by the end of 2013.
The International Telecommunications Union (ITU) has divided the world
into three zones. During the World Radiocommunication Conference 2012, the 3GPP
band 27 (807 – 824 / 852 – 869 MHz) was amongst the bands recommended for PSAs
within the Asia-Pacific region (Region 3).
ITU Resolution 646 concerning public protection and disaster relief states
...to encourage administrations for the purposes of achieving
regional harmonized frequency bands/ranges for advanced public protection and
disaster relief solutions, to consider the following identified frequency
bands/regions or parts thereof when undertaking their national planning:
– in Region 3: 406.1–430 MHz, 440–470 MHz, 806–824/851–869 MHz, 4 940 4
990 MHz and 5 850–5 925 MHz.
A footnote regarding Region 3 notes that some countries in the region
have also identified the bands 380–400 MHz and 746–806 MHz for PPDR applications.
The ACMA's Senior Engineer, Mr Christopher Worley, informed the
committee that there is no equivalent listing for PPDR for the 700 MHz band in
Similarly, AMTA Chief Executive Officer, Mr Chris Althaus, argued that if PSAs were
insistent on a standalone network, the 700 MHz band was the wrong spectrum band
because the ITU had earmarked the 806–824 MHz and 851–869 MHz bands for Public
Protection and Disaster Relief in the Asia-Pacific region.
Mrs Cahill of the ACMA also noted that the ACMA was working toward
harmonisation in the 800 MHz band for public safety agencies across the region
through the Asia-Pacific Telecommunity. She explained that:
We have been working very closely through the Asia-Pacific
Telecommunity to have 800 as the spectrum identified for equipment
manufacturers for public safety agency needs. It is, in our view, the optimal
spectrum to enable economies of scale in terms of cost of equipment for the
public safety agencies, and also in term of interoperability within the
Similarly, Orange Horizons noted that it would appear that the ITU was
moving towards utilising 800 MHz spectrum in the Asia-Pacific region and that
there was justification in maintaining compatibility with the ITU.
The ACMA held that 'international harmonisation' is highly important to
Australia domestically and internationally, providing for equipment economies
of scale, interoperability and cross-border roaming, as well as spectrum
efficiency, while ensuring that the myriad of radio technologies used in all
aspects of society can coexist without interfering with each other.
Noting, however, that the harmonisation in question concerns the
Asia-Pacific region rather than the international community as a whole, the
committee received contrary evidence to that of the ACMA. Mr Hewitt of the
NCCGR made the point that while the 800 MHz spectrum had been identified as the
band for PPDR, it was used in Asia by police and emergency services for
narrowband voice rather than broadband data.
Motorola Solutions also noted that ITU Resolution 646 was originally drafted to
harmonise spectrum for narrowband operations or voice operations for two-way
radio types of operations. The ACMA acknowledged that the resolution initially
focused on narrowband radio and cited the resolution which stated that:
e) that current public protection and disaster relief
applications are mostly narrow-band supporting voice and low data-rate
applications, typically in channel bandwidths of 25 kHz or less;
f) that, although there will continue to be narrow-band
requirements, many future applications will be wideband (indicative data rates
in the order of 384-500 kbit/s) and/or broadband (indicative data rates in the
order of 1 100 Mbit/s) with channel bandwidths dependent on the use of
spectrally efficient technologies.
The ACMA stated that it was engaged in the technical and operational
considerations relating to broadband PPDR so that ITU-R Resolution 646 'can be
amended to better reflect the trend in PPDR applications towards higher
However, Mr Hill of Motorola Solutions stated that:
In our region at the moment there is no agreement and that is
part of the work that ACMA is doing with the APT and the ITU and to which we
are also helping to contribute. But there is currently no agreement in the
region as to what part of spectrum is to be used for public safety for
Mr Hewitt of the NCCGR explained that while Australia might move to
harmonise that spectrum as broadband data, the question remained as to whether
the rest of the region would be prepared to 'push out all their own voice
systems and replace them with the broadband data at some cost to themselves'.
Therefore, as Mr Hewitt explained, while harmonisation was a key
consideration of the ACMA in its announcement that public safety agencies
should operate on the 800 MHz band, there are no assurances that the region
will undertake the necessary configuration to move from voice to data and
purchase the compatible chipsets. The possibility remains, therefore, that
Australia could, be left on its own with no commercial advantage.
The committee notes in this regard, ITU Resolution 646 which states that some
countries in Region 3 have already identified the band 746–806 MHz for PPDR
The ACMA acknowledged that while the ITU identified the 800 MHz band,
there is no country in the Asia-Pacific region operating the 800 MHz band for
broadband data at present.
Indeed, the ACMA's Dr Kerans explained that Australia is probably leading the
region 'when it comes to allocating a band for public safety agencies and a
number of the other regions were watching to see what we do'.
The ACMA emphasised that significant progress within Region 3 had been made on
the development of a regionally harmonised plan while acknowledging that 'no
endorsed plan is yet in place'.
Submitters noted that decisions regarding the PPDR spectrum were expected
to be taken at the World Radio Congress in 2015.
Therefore, the suggestion from the ACMA that ongoing alignment of Australian
spectrum allocations with international regulations will benefit Australian
PSAs from 'improved economies of scale in equipment manufacture and enhanced
interoperability with overseas counterparts' is premature at best.
The NSW Police Force noted, for example, that it appears 'unlikely that there
will be a significant demand for LTE equipment operating in the proposed harmonised
PPDR 800 MHz band in the immediate future'. The NSW Police Force highlighted
the views of the jurisdictions and law enforcement across Australia that:
There is still no certainty that international
representations for an allocation of harmonised spectrum for PPDR in the 800
MHz band will come to fruition or that there will be sufficient demand
generated for broadband equipment to generate competition, improve product
availability and reduce development costs. The opportunities highlighted by the
ACMA in previous submissions have not been realised.
The committee supports the allocation of spectrum in the 700 MHz band for
the purposes of a national PSMB network. The committee notes that the 700 MHz
band is the preferred band of Australian PSAs themselves which have diligently examined
and reported on their own requirements to the ACMA over the past three years.
Notwithstanding this point, as the spectrum allocation process focused on the
800 MHz band for inception, the possibilities for PSAs in the 700 MHz band were
not fully explored. However, the 2013 auction of spectrum in the 700 MHz band
has provided a once-in-a-lifetime opportunity for the PSAs which cannot be
While the committee appreciates the efforts of the ACMA in relation to
international harmonisation, the evidence has demonstrated that there are
considerable obstacles to harmonisation in the Asia-Pacific region. Such
obstacles make harmonisation across the region, as well as the flow-on benefits
including interoperability and potentially economies of scale, an extremely
unlikely prospect. This prospect is made more improbable given that some
countries in Region 3 have already identified the 746–806 MHz band for PPDR
applications. Allocation of spectrum to PSAs in the 700 MHz band will,
therefore, enable Australia to harmonise with at least some countries in the
The committee holds the view that it is imperative that Australian PSAs
are resourced adequately to operate in an effectively, timely and efficient
manner. Indeed, it is an expectation of the Australian public. As there remains
30 MHz of unallocated spectrum, the committee can foresee no reason as to why
the ACMA cannot allocate 20 MHz of remaining spectrum in the 700 MHz band with
The committee recommends, therefore that the Minister for Broadband,
Communications and the Digital Economy issue a Ministerial Direction to the
ACMA to allocate 20 MHz of contiguous spectrum in the 700 MHz band for the
purposes of a national PSMB network. Furthermore, the recommended 10 MHz of
additional spectrum for PSA purposes should be provided in the 700 MHz band.
In the event that the committee's recommendation for 20 MHz of spectrum for
PSAs in the 700 MHz band is not supported by the Australian Government, however,
the committee recommends the reservation of 20 MHz in the 800 MHz band as
the minimum requirement for a PSMB network.
The committee recommends that the Minister for Broadband, Communications
and the Digital Economy issue a Ministerial Direction to the Australian
Communications and Media Authority to allocate 20 MHz of contiguous spectrum in
the 700 MHz band for the purposes of a public safety mobile broadband network.
The committee recommends that the Minister for Broadband, Communications
and the Digital Economy take appropriate measures to secure, for public service
agencies, priority access to an additional 10 MHz of spectrum in the
700 MHz band for public safety purposes.
If recommendation 1 is not supported by the Australian Government, the
committee recommends that the Minister for Broadband, Communications and the
Digital Economy issue a Ministerial Direction to the Australian Communications
and Media Authority to allocate as a minimum requirement, 20 MHz in the
800 MHz band for the purposes of a public safety mobile broadband network.
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