Sub 11 Telstra
Sub 11 Telstra
Law Enforcement
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 1/14 PAGE 1/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Contents
1 Executive Summary 3
2 How much broadband spectrum do law enforcement agencies need to be
able to communicate safely and effectively during mission-critical events
such as natural disasters and potential terrorist incidents? 5
3 Which of the 700 or 800 MHz bands is the most appropriate for law
enforcement agencies given the current licensees occupying spectrum? 6
4 How the necessary spectrum for public safety should be secured in a timely
manner? 7
5 What arrangements should be put in place to ensure that, in extreme
circumstances, law enforcement agencies can effectively use spectrum of
commercial carriers to protect public safety and maintain public order? 8
6 What applications dependent on broadband spectrum will contribute
significantly to saving lives and property? 8
7 The impact on law enforcement agencies which utilise the available spectrum
in relation to budgets, implementation strategies, current infrastructure and
existing technology 9
8 Any other related matters 10
9 Attachment 1: Telstra Whitepaper - Delivering 4G/LTE Mobile Broadband for
Emergency Services 14
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 2/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
1 Executive Summary
Introductory comments
Telstra welcomes the opportunity to provide this submission to the Parliamentary Joint Committee on
Law Enforcement (“the Committee”) in response to its inquiry into the spectrum arrangements for public
1
safety mobile broadband (PSMB).
Telstra believes mobile technologies offer an important opportunity to enhance the delivery of public
safety services and the company is proud of the contribution it already makes in this regard, for example
through the provision of the Triple Zero service. Telstra is keen to contribute to a policy discussion that
seeks to utilise mobile broadband to improve public safety outcomes in a manner that is cost effective
and utilises existing investments and infrastructure.
Telstra would welcome the opportunity to further discuss the material in this submission with the
Committee.
Key issues
Here is a summary of the key issues identified by Telstra in this submission.
Telstra believes that the Australian Communications and Media Authority (ACMA) is well placed to
advise the Government on the quantity of spectrum required to be reserved for PSMB use.
Telstra believes that the 800 MHz band is best suited for any PSMB spectrum requirements. The
spectrum in the 700 MHz band that was not allocated in the ACMA’s recent spectrum auction is not
appropriate for this purpose because of the continuing growth in demand for commercial mobile
broadband services, it is not compatible with international planning, and offers no significant
advantage in terms of how early it can be accessed for public safety use.
Telstra recommends that the LANES Strategy be adopted as outlined in Attachment 1 to this
submission. The LANES Strategy involves integrating the PSMB spectrum into the architecture of a
commercial carrier network so that it can form a dedicated and seamless national service for first
responders. Such a carrier network can be suitably “hardened” through Government investment to
provide additional resilience where required. Telstra considers that such a strategy is the only
realistic approach for public safety agencies to be able to effectively overflow traffic to the additional
capacity and coverage of a commercial network.
The LANES strategy also has the advantage of allowing the PSMB capability to be introduced (using
partitioned commercial spectrum) before the 800 MHz spectrum is cleared. Indeed, Telstra believes
it could commence a PSMB network based on the LANES strategy by 2015, which would provide
public safety agencies with substantial additional capacity when required by providing priority access
to infrastructure using Telstra’s expansive commercial spectrum portfolio (which has a value of
several billion dollars and consists of approximately 217 MHz of spectrum in metropolitan and
regional areas, and 167 MHz in remote areas).
Telstra believes that a broader Community Centric Approach to Public Safety and Security Mobile
Broadband should be adopted in lieu of the agency model. The current model being pursued by the
public safety agencies appears to be focused solely on emergency services organisations and does
not consider the broader benefits that the LANES approach can bring to citizens, first responders,
the public sector, and industry. The LANES strategy would harden and enhance a commercial
network so that benefits of the enhancement flow to a much wider community of users and not only
to the emergency services organisations. For example, the majority of citizens who use mobile
phones to contact the Triple Zero service for assistance, especially in natural disaster prone areas in
1
Refer
http://www.aph.gov.au/Parliamentary_Business/Committees/Senate_Committees?url=le_ctte/spectrum_mobile_broadband/index.ht
m
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 3/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
regional and rural Australia, would be able to use the hardened and enhanced commercial network
for improved access to this service.
The remainder of this submission sets out Telstra’s comments in response to the various points that are
considered under the Terms of Reference for the Inquiry.
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 4/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
The LANES Strategy is the most economic and effective approach to delivering PSMB
capability
Telstra agrees with the ACMA view that the design of a public safety mobile broadband network needs
to be predicated on using the resources of commercial mobile broadband networks. Telstra contends
that the most economic and effective manner in which to provide a truly national PSMB capability is not
to attempt to build separate PSMB networks and overflow to commercial networks for coverage and
supplementary capacity, but rather to integrate the capability within a commercial network.
Telstra’s White Paper ‘Delivering 4G/LTE Mobile Broadband for Emergency Services’ (in Attachment 1)
explains how a commercial LTE network can be partitioned to provide emergency services users with
dedicated capacity using 800 MHz spectrum and also give them priority access to additional capacity
using other spectrum in the event of a special event or emergency. Telstra refers to this approach as the
“LANES Strategy” because it is analogous to the arrangements on a major highway where dedicated
transit lanes provide preferential access for emergency service/public transport vehicles, and traffic in
other lanes must give way to emergency vehicles in the event of transit lanes not being available. Such a
strategy complements the prioritised voice mobile broadband services already operating on Telstra’s
Next G® network on behalf of the Commonwealth Government - namely Triple Zero and the Australian
5
Wireless Priority Service System (WPSS) .
2
The ACMA, Spectrum for public safety radiocommunications - Current ACMA initiatives and decisions, October 2012
3
Ibid, p14
4
Ibid, p10
5
http://www.ag.gov.au/Publications/Budgets/Budget2009-10/Pages/StrengtheningourNationalSecurity.aspx
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 5/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Telstra has a substantial portfolio of spectrum assets available upon which it can draw to augment the
ACMA 800 MHz allocation and implement the LANES Strategy. These holdings have a value of several
billion dollars and consist of approximately 217 MHz of spectrum in metropolitan and regional areas, and
167 MHz in remote areas.
3 Which of the 700 or 800 MHz bands is the most appropriate for law
enforcement agencies given the current licensees occupying spectrum?
As explained below, Telstra believes that the 800 MHz band continues to be the most appropriate band
for the deployment of a public safety mobile broadband network. The unsold spectrum in the 700 MHz
band is not appropriate for this purpose because of the continued growth in demand for commercial
mobile broadband services; it is not compatible with international PSMB planning; and it offers no
significant advantage in terms of how early it can be accessed.
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 6/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Further, Australian public safety agencies are unable to take advantage of the equipment designed for
the large US market because the equipment is not technically compatible with the 700 MHz frequency
plan for Region 3. In particular, the 700 MHz frequencies that have been assigned to US public safety
agencies for “uplink” and “downlink” communications coincide with frequencies that can only be used for
9
“downlink” mobile communications in the Region 3 plan . This means that devices designed for
operation in the US will not work in Australia without substantial and costly customisation.
Telstra is aware of some informal discussions concerning the potential use of the 693-703/748-758 MHz
frequency range for PPDR applications in Europe. This frequency range is not compatible with the
arrangements in Australia as it is outside the Region 3 plan. It would require at least one additional
television broadcasting channel to be cleared, as well as changes to the filtering in 700 MHz mobile
networks and devices.
4 How the necessary spectrum for public safety should be secured in a timely
manner?
9
The Region 3 700 MHz frequency plan has been adopted by Australia, most other Asia-Pacific countries, the majority of South
American countries, and is also expected to be adopted by African countries.
10
The ACMA, Spectrum for public safety radiocommunications - Current ACMA initiatives and decisions, October 2012, p19
11
Ibid, p19
12
Refer to http://www.acma.gov.au/theACMA/Newsroom/Newsroom/Media-releases/new-spectrum-for-emergency-services
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 7/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Telstra notes that the ITU report ITU-R M.2033 sets out the various types of PPDR applications that can
14
be supported by existing or future generations of LTE technology. The applications considered in this
report are summarised in Table 1 below. Note that legacy narrowband and wideband applications are
generally expected, over time, to be subsumed within the aggregate data-stream capacity of a future
mobile broadband system.
13
Refer http://www.comlaw.gov.au/Details/C2012C00818
14
Available at http://www.itu.int/dms_pub/itu-r/opb/rep/R-REP-M.2033-2003-PDF-E.pdf
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 8/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Telstra has implemented a broad cross section of these services with Australia’s emergency services
15
organisations . Some examples are shown in Figure 1 below.
7 The impact on law enforcement agencies which utilise the available spectrum
in relation to budgets, implementation strategies, current infrastructure and
existing technology
There would be a number of serious challenges associated with public safety agencies designing, rolling
out and operating a dedicated mobile broadband network that is nationwide and interoperable across
state borders. The key reasons are as follows:
The cost of rolling out such a network would be significant, almost certainly several billion dollars.
For example, Telstra understands that the US public safety network is expected to cost
approximately $US19 billion, with $US7 billion being funded by the federal government (from
spectrum auction proceeds) and the remainder being funded by state governments and private
sector investors.
Telstra understands that individual States and Territories are likely to be required to fund and build
their own networks. This approach has the potential to result in a fragmented approach to network
implementation and coverage.
Funding constraints are likely to result in priority being given to the coverage of metropolitan areas.
This would leave regional and remote areas underserved, and would fail to enhance the capability of
emergency services in these areas to deal with natural disasters such as bush fires and flooding.
The consequence will be a “digital divide” between public safety agencies in metropolitan areas and
those in regional and remote areas.
Building and operating large scale LTE networks is a complicated and specialised business. It is not
the core business of governments or public safety agencies and they are not resourced to undertake
such activity. Telstra considers that there will be a high risk of project failure if the network design,
build and operation is not shared with a commercial network provider.
Telstra believes that the only realistic approach to addressing these issues is for the public safety
agencies to form a national partnership with a commercial mobile network provider. This would reduce
the cost of the project by allowing the public safety agencies to leverage the resources of a commercial
15
http://www.telstra.com.au/business-enterprise/enterprise-solutions/industries/public-safety/
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Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
network, including suitably hardened commercial infrastructure, augmentation with commercial spectrum
and nationwide seamless operations management. It would also assist to ensure that the rollout is
interoperable across state boundaries and not create a divide between metropolitan, regional and
remote Australia. Such an approach is also necessary to provide a seamless user experience when
roaming between public safety and commercial spectrum.
More detail about Telstra’s proposed approach to delivering such a partnership solution is discussed in
Attachment 1 of this report.
700000
600000
500000
400000
200000
100000
0
Nov-11
Nov-12
Jan-12
Jan-13
Apr-12
Apr-13
Aug-11
Feb-12
May-12
Jun-12
Feb-13
Jul-11
Jul-12
Aug-12
Sep-11
Sep-12
Mar-12
Mar-13
Oct-11
Oct-12
Dec-11
Dec-12
16
The Productivity Commission, Report on Government Services 2013
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Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
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Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
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Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
Telstra observes that Australia is still struggling to deliver what might be termed a Public Safety Radio
Network (PSRN), based on legacy land mobile radio network technology. The ACMA has provided new
spectrum in the 400MHz range to the emergency services agencies to contribute to achieving
interoperability in the radio domain. However, a truly national interoperable PSRN appears to be many
years away as a consequence of differing technologies, versions of equipment and different operating
procedures and processes existing across Australia.
In order to ensure that the wider Australian public will benefit from the reality of a truly national and
interoperable PSMB network rather than capability, Telstra strongly recommends that Australian
governments seriously consider adopting a nationwide partnership approach, based on the LANES
strategy, with a commercial network to achieve this outcome.
TELSTRA CORPORATION LIMITED (ABN 33 051 775 556) | PRINTED 13/06/13 PAGE 13/14
Submission to the Parliamentary Joint Committee on Law Enforcement
Inquiry into the spectrum for public safety mobile broadband
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