Policy and Technical Framework
Mobile Broadband Services (MBS) — 700 MHzBand
Broadband Radio Service (BRS) — 2500 MHz Band
PART B — Decisions on a Policy and Technical Framework for Commercial Mobile Broadband Spectrum in the 700 MHz Band
41. In November 2010, Industry Canada released SMSE-018-10 — Consultation on a Policy and Technical Framework for the 700 MHz Band and Aspects Related to Commercial Mobile Spectrum, (herein referred to as the “700 MHz consultation”). In this document, Industry Canada sought comments on general policy considerations related to commercial mobile broadband spectrum use, competition issues and the potential use of the 700 MHz band.
42. Key topics included whether measures to support competition are needed in the auction process and, if so, what specific measure(s) would be most appropriate; whether there is a need for measures to support rural and remote mobile broadband rollout; how to address public safety mobile broadband spectrum needs and whether the auction of the 700 MHz and 2500 MHz bands should be held separately or jointly.
43. In addition, the 700 MHz consultation document sought comments on the proposed band plan options; the transition policy for the licensees remaining in the band subsequent to the transition to digital television; whether open access requirements should be imposed; and the necessary updates to the Canadian Table of Frequency Allocations.
Comments and reply comments were received from various entities (see Annex 1).
B1. Band Plan Architecture for Commercial Mobile Systems
44. In order to deploy commercial mobile services in the 700 MHz band, an appropriate band plan must be adopted which takes into account current national needs, global uses and equipment availability.
45. Recent technological evolution and market trends enabling multimedia applications over broadband access systems have resulted in a significant increase in spectrum demand for mobile broadband wireless applications. In order to support such growth in spectrum demand, the selection of a 700 MHz band plan should consider the following factors:
- availability of equipment and associated economies of scale;
- reduced cross-border interference and facilitation of cross-border frequency agreements;
- international interoperability and roaming; and
- continuation of public safety operations (in their designated frequencies).
46. In the past, when implementing new radio services, Canada has often adopted harmonized spectrum allocations, band plans and radio equipment specifications with the United States. Such harmonization typically presented the following advantages over other alternatives:
- a wide selection of low-cost equipment due to the size of the U.S. market;
- facilitation of cross-border roaming as a result of interoperable equipment; and
- simplified cross-border frequency coordination procedures due to harmonized frequency arrangements.
B1.1 Band Plan and Block Sizes
47. In the 700 MHz consultation, Industry Canada proposed four band plan options for consideration:
- Option 1: Harmonization with the U.S. band plan;
- Option 2a: Modified U.S. band plan with slight adjustments — 8 and 10 MHz channel blocks in the Lower 700 MHz band;
- Option 2b: Modified U.S. band plan with slight adjustments — mix of 3 and 5 MHz channel blocks in the Lower 700 MHz band; and
- Option 3: Harmonization with the Asia-Pacific Telecommunity (APT) band plan.
These band plan options are illustrated in Annex 2.
48. In the U.S. band plan (Option 1), the Lower and Upper portions of the 700 MHz band are treated as two separate bands by the U.S. Federal Communications Commission (FCC). In the Upper 700 MHz band, the FCC allocated a paired block of 11+11 MHz (Upper C block) with open access requirements, 12+12 MHz for narrowband and broadband public safety operations, and a paired block of 5+5 MHz (D block), which was intended for a private-public partnership between commercial service providers and public safety entities in the adjacent block. However, the D block was not successfully auctioned and discussions about whether to designate this spectrum for public safety use have recently concluded in the United States (see Section B2 of this document for further details). In the Lower 700 MHz band, the FCC auctioned three 6+6 MHz paired blocks and two 6 MHz unpaired blocks of spectrum.
49. Options 2a and 2b represent slight variations of the U.S. band plan; the first option would enable the use of multiple 10+10 MHz channels, whereas the second would include 5+5 MHz and 3+3 MHz blocks in the paired spectrum, thus allowing at least five paired blocks to be auctioned.
50. Option 3, the APT band plan, consists of a 45+45 MHz FDD12 configuration over the entire 700 MHz band.
Summary of comments
51. Of the comments received regarding which band plan to adopt in Canada, the majority of respondents supported the adoption of Option 1, harmonization with the U.S. band plan.
52. Mobilicity preferred the adoption of the Option 2b band plan, as it provides bidders with the greatest flexibility for acquiring and packaging spectrum blocks and does not prevent AWS entrants “from bidding on smaller spectrum blocks that might meet their capacity needs.”
53. The Canadian Media Guild, Niagara Networks and Mr. Brendan Howley (an individual respondent) supported the adoption of Option 3, harmonization with the APT band plan. In their view, Option 3 was the most spectrally efficient and would allow for the greatest number of licensees to gain access to this spectrum. Furthermore, these respondents considered that this band plan may eventually have greater equipment availability at lower costs, as that band plan will be used in heavily populated Asian markets.
54. Although some respondents initially considered options 2a, 2b or 3 to be more desirable, most supported Option 1 after analyzing the potential equipment availability for options 2a and 2b, and the lack of public safety designated spectrum in the Option 3 band plan.
55. Barrett Xplore Inc. and Barrett Broadband Networks Inc. (Xplornet), Quebecor Media Inc. (QMI), Rogers and TELUS proposed subdividing the Upper C block into two separate blocks. This proposal was generally supported by others in the reply comment phase. Respondents maintained that subdividing the Upper C block into two separate blocks would maximize the amount of useable spectrum and increase the number of blocks which would be available for all bidders while maintaining full alignment with the U.S. band plan.
56. The 700 MHz band plan. Harmonization with the U.S. band plan, as proposed in Option 1, would promote economies of scale by allowing the Canadian market access to a wide selection of low-cost equipment. This option would also enable cross-border roaming and allow simpler cross-border frequency arrangements and coordination procedures for both public safety and commercial mobile services.
57. Adoption of the Option 1 band plan, however, could affect Canadian deployments due to potential interference issues which have been experienced in the United States. These include:
- interference from digital TV operations in TV channel 51; and
- interference from operations in the unpaired blocks (blocks D and E).
As such, the use of guardbands may be necessary to minimize these potential impacts.
58. Although options 2a and 2b would increase the spectral efficiency by matching the proposed block sizes to the radio channel size of modern technologies, these options were not supported by the majority of respondents due to equipment availability concerns.
59. Option 3, the APT band plan adopted by administrations in Asia, does not include provisions for public safety services in the 700 MHz band. The adoption of this band plan would thus require the displacement of Canadian public safety operations from current frequencies. Moreover, significant issues related to cross-border interoperability, interference, frequency coordination and equipment availability would arise and affect both public safety and future commercial mobile systems.
60. Taking into consideration the constraints related to potential cross-border interference, the necessity to support public safety systems and equipment ecosystem availability, Industry Canada has concluded that Option 1 (harmonization with the U.S. band plan) should be adopted.
61. The U.S. band plan provides for the following block structure for auction:
- 3 paired blocks (6+6 MHz each): blocks A, B, C (Lower 700 MHz band);
- 2 unpaired blocks (6 MHz each): blocks D, E (Lower 700 MHz band);
- 1 paired block (11+11 MHz): block C (Upper 700 MHz band); and
- 4 guardbands (1 MHz each):13 Upper 700 MHz band.
62. Block C in Upper 700 MHz band. As previously mentioned, Industry Canada received comments proposing that the Upper C block be subdivided into two blocks. As most service providers supported this proposal and given that there are no technical reasons against it, Industry Canada has determined that the Upper C block will be subdivided and auctioned as two separate blocks. These blocks will be referred to as blocks C1 and C2 and will result in the following blocks being available in the Upper 700 MHz band:
- 2 paired blocks (5+5 MHz each): blocks C1, C2; and
- 2 blocks (1 MHz each).
63. As the current technical equipment specifications14 established by the 3rd Generation Partnership Project (3GPP15) support a paired block of 10+10 MHz in the bands 746-756 MHz and 777-787 MHz (also known as Band 13), block C will be evenly divided as two paired blocks of 5+5 MHz each, namely blocks C1 and C2. Block C1 will be 746-751 MHz, paired with 777-782 MHz; block C2 will be 751-756 MHz, paired with 782-787 MHz. This subdivision is illustrated in Figure B1 below.
64. As a result, two blocks of 1 MHz (756-757 MHz and 776-777 MHz) will be “orphaned” with a frequency separation of 20 MHz. At this time, there are no known uses for these blocks, in either a paired or unpaired configuration. Therefore, these blocks will be held in reserve by Industry Canada.
*In Canada, the bands 775-776 MHz and 805-806 MHz are designated for public safety.
65. Interference from TV channel 51. The potential for interference between TV broadcasting systems operating on channel 51 and mobile broadband systems in block A may be addressed by retuning the TV stations (i.e. changing the operational broadcasting channel) operating on channel 51 to other available TV channels. Such changes need only be implemented when and where required, and only after technical determination has concluded that continued operation of the TV station would impede the deployment of new licensed systems in block A in the Lower 700 MHz band. In such cases, licensees in block A are encouraged to enter into arrangements with the relevant broadcasters for a mutually acceptable solution. Furthermore, to avoid the addition of new broadcasting stations that may need to be altered later in order to prevent interference into mobile operations, Industry Canada will no longer accept applications for broadcasting certificates for TV stations on channel 51. The list of full power TV stations currently operating on TV channel 51, or for which applications were received for channel 51, is available in Annex 3.
66. Issues related to the D block in the Upper 700 MHz band and the spectrum designated for public safety are discussed in Section B2.
Decisions related to the band plan and block sizes
B1-1: The band plan shown in Figure B2 below will be adopted for the 700 MHz auction, with the Upper C block subdivided into two separate blocks, namely C1 and C2. The following figure shows the band plan architecture for commercial mobile spectrum use.
*Decisions regarding D block (in the Upper 700 MHz band) and frequency ranges designated for public safety are discussed in Section B2.
The following frequency blocks will be available for the 700 MHz auction:
|A||698-704 MHz/728-734 MHz||paired||6+6 MHz|
|B||704-710 MHz/734-740 MHz||paired||6+6 MHz|
|C||710-716 MHz/740-746 MHz||paired||6+6 MHz|
|D||716-722 MHz||unpaired||6 MHz|
|E||722-728 MHz||unpaired||6 MHz|
|C1||777-782 MHz/746-751 MHz||paired||5+5 MHz|
|C2||782-787 MHz/751-756 MHz||paired||5+5 MHz|
A Standard Radio Systems Plan (SRSP) and a Radio Standards Specification (RSS) will be released before the auction to establish the technical rules for systems operating in the commercial mobile spectrum in the 700 MHz band.
B1-2: The two 1 MHz blocks (the frequency bands 756-757 MHz and 776-777 MHz resulting from subdividing the Upper C block into blocks C1 and C2) will be held in reserve, and will thus not be part of the upcoming auction.
B1-3: As per the letter addressed to the CRTC, no new applications for broadcasting certificates will be accepted for TV stations operating on channel 51 (692-698 MHz). Block A licensees, in areas where mobile deployments are affected by TV broadcasting on channel 51, are encouraged to enter into mutually acceptable arrangements with the relevant broadcasters.
67. In conjunction with questions posed about the band plan, comments were sought on how to treat the two 1 MHz guardbands (757-758 MHz and 787-788 MHz) between the public safety and commercial mobile blocks (see Figure B2).
68. Comments were also sought on whether the guardbands between adjacent services within the 700 MHz band should be auctioned or whether they should be held in reserve for future use. In the United States, the FCC auctioned the guardband licences to Band Managers,16 who could lease their spectrum to service providers or directly to end-users through secondary market trading.
Summary of comments
69. Most respondents considered that the guardbands should not be licensed. Some were of the view that these blocks should be held in reserve until a use can be identified which is technically compatible with services in the adjacent bands. Other respondents maintained that guardbands should remain unused indefinitely.
70. Many respondents suggested waiting for the FCC’s decision on the use of the D block in the Upper 700 MHz band before taking any steps to auction the guardbands, as this would facilitate continued cross-border harmonization. If Industry Canada decides to license the guardbands at a later date, a few respondents suggested that the spectrum be licensed on a no-interference, no-protection basis.
71. On the other hand, other respondents, which were predominantly large service providers, insisted that the use of the guardbands for any purpose other than to prevent harmful interference to licensed commercial mobile systems would be counterproductive to the objective of licensing the 700 MHz band. As a result, they recommended that the guardbands remain unused indefinitely.
72. SSi Micro Ltd. (SSi) was the only respondent to suggest auctioning the guardbands given that in its view, “auctioning the guardbands would give licensees flexibility to maximize use of the spectrum.”
73. As noted above, there are no known uses for the guardbands at this time, nor did respondents to the consultation request specific uses for them. Given the significant potential for interference and the unknown availability of equipment for this spectrum, Industry Canada has determined that these frequencies will be held in reserve until further notice.
Decision related to guardbands between adjacent services
B1-4: The two guardbands (i.e. the frequency bands 757-758 MHz and 787-788 MHz) between adjacent services in the Upper 700 MHz band will be held in reserve until further notice.
B1.3 Tier Sizes
74. Industry Canada has established standard service areas that are used in a spectrum auction to set licence boundaries. These areas, called tiers, are based on Statistics Canada’s Census Divisions and Subdivisions. Four tier sizes, as outlined in the document Service Areas for Competitive Licensing,17 have been established to accommodate various wireless services, applications and frequency bands.
- Tier 1 is a single national service area;
- Tier 2 consists of 14 large service areas;
- Tier 3 consists of 59 smaller regional service areas; and
- Tier 4 comprises 172 localized service areas.
75. These tier areas are illustrated in Annex 4. In general, Tier 1 and Tier 2 licences have traditionally been used for mobile services, whereas Tier 3 and 4 have been used for licensing fixed services.
76. In the 700 MHz consultation, comments were sought on whether the auction for the 700 MHz commercial spectrum should be based on uniform tier sizes or a mixture of tier sizes across all spectrum blocks, and on which tier size(s) should be adopted.
Summary of comments
77. Uniform tier size. The British Columbia Broadband Association (BCBA), the Peace Region Internet Society (PRIS) and SSi proposed using uniform Tier 4 service areas. Mobilicity and Rogers proposed Tier 3 service areas, whereas Bell, QMI, Shaw Communications Inc. (Shaw) and Drs. Gregory Taylor and Catherine Middleton (from Ryerson University) proposed uniform Tier 2 service areas. Bragg Communications Inc. (EastLink) originally proposed the adoption of Tier 4 service areas, but later revised its proposal for the use of a larger tier, either a Tier 2 or Tier 3, across the entire band.
78. Mixture of tier sizes. Many respondents proposed a mixture of tier sizes. Xplornet and the Government of British Columbia proposed a mixture of tiers 2, 3 and 4, with the latter suggesting a mixture of tiers 3 and 4 for small urban areas. In its reply comments, Xplornet further suggested that two paired blocks and two unpaired blocks be reserved for rural deployment and be licensed on a modified Tier 4 level with “rural unbundling.”18
79. Niagara Networks also proposed a mixture of Tier 1, 2 and 3 service areas. Others, including Globalive Wireless Management Corp. (WIND), MTS Allstream and Public Mobile, suggested a mixture of Tier 2 and Tier 3 service areas. The Canadian Association of Community Television Users and Stations (CACTUS) also suggested a mixture of two tiers, with Tier 3 and Tier 4 as the most appropriate for the 700 MHz commercial spectrum.
80. TELUS suggested auctioning the 700 MHz commercial spectrum in Tier 1 and/or Tier 2 service areas, with the exception of one block (or at most three blocks), which could be auctioned using a Tier 3 service area. In TELUS’ view, this would “facilitate potential entry by smaller regional/rural operators” and would allow for “urban-focused providers that may be pursuing more targeted business plans.”
81. Some respondents, including WIND and Mobilicity, opposed the adoption of a Tier 1 service area given that it would effectively preclude at least the regional service providers, if not all small service providers, from participating effectively in the auction.
82. Mobile services typically use low frequency bands where radio waves propagate farther and users are mobile and roam over wide areas. As a result, the antennas used in mobile applications transmit in all directions to cover these wide areas and, consequently, mobile service areas are generally large. This is especially true for high mobility applications, such as for services onboard trains and vehicles travelling on highways.
83. The 700 MHz band will be the lowest frequency band allocated so far for commercial mobile services. In this band, radio waves will carry the desired signals, as well as the interference, at significantly higher distances compared with higher frequency bands such as AWS and PCS.
84. Previously, other commercial mobile bands were licensed using national Tier 1 (e.g. Cellular and PCS), provincial Tier 2 (e.g. Cellular, PCS and AWS) and regional Tier 3 (e.g. portions of the AWS spectrum) areas. In the 700 MHz band, a national licence area (i.e. Tier 1) would allow a single service provider access to the same block of 700 MHz spectrum across the entire country. A Tier 1 licence would, however, exceed the scope and interest of small or regional service providers.
85. While both Tier 1 and Tier 2 service areas enable the provision of high mobility services, Tier 2 service areas would provide licensees with province-wide coverage.19 As many service providers operate on a regional basis, use of Tier 2 allows these bidders to acquire spectrum where they operate today. Aggregation of multiple Tier 2 licences up to the national level is also possible.
86. Licensing based on smaller tier sizes, such as Tier 3 or a Tier 4, provides flexibility for licensees whose business plans are concentrated in specific geographic markets, or who choose to aggregate smaller service areas into larger regions corresponding to their business needs. Smaller tier sizes may result in lower costs for bidders interested only in smaller markets. However, in many areas, dividing the service areas into smaller sizes (i.e. Tier 3, 4), or a modified Tier 4 as proposed by Xplornet, could result in deployment challenges such as increased interference coordination with neighbouring service providers at the edge of their licence areas. This could also create uncertainty, delays and additional costs to service providers. The fewer borders there are between licence areas, the more efficiently service providers can use their spectrum.
87. Moreover, Industry Canada is of the view that the use of homogenous tier sizes for both paired and unpaired spectrum will facilitate the auction process by reducing complexity for the bidders who may need to devise strategies for bidding across multiple frequency blocks over multiple geographic areas.
Decision related to Tier Sizes
B1-5: Tier 2 service areas will be used to license all frequency blocks for the auction of 700 MHz spectrum licences.
B2. D Block in the Upper 700 MHz and Public Safety Spectrum
88. The 700 MHz consultation considered the issue of how much spectrum, if any, should be designated for public safety broadband use. In the Upper 700 MHz band, there are two paired 5+5 MHz blocks which could be used for this purpose. As shown in Figure B3 below, the public safety broadband (PSBB) block consists of 763-768 MHz and 793-798 MHz, whereas the D block (not to be confused with the unpaired block D in Lower 700 MHz) consists of 758-763 MHz and 788-793 MHz.
[Description of Figure B3]
89. The following three options were considered for public safety systems in Canada:
- Option 1: Designate 5+5 MHz (PSBB block) to public safety systems and auction 5+5 MHz (D block) for commercial systems;
- Option 2: Designate the entire 10+10 MHz of spectrum for commercial systems, with possible provisions for priority access for public safety systems; or
- Option 3: Designate the entire 10+10 MHz of spectrum for public safety systems.
90. Comments were also sought on whether Industry Canada’s decision regarding spectrum for public safety broadband should be delayed until the United States has made a decision on the use of the D block.
Summary of comments
91. Not all respondents commented on public safety issues. Of those who did, most supported the immediate designation of 5+5 MHz (PSBB block) for public safety broadband use.
92. Comments were varied, however, with respect to the use of the other 5+5 MHz block (D block in the Upper 700 MHz band). Public safety organizations and provincial respondents unanimously recommended that the D block be designated for public safety purposes. This was also supported by the Federation of Canadian Municipalities, la Ville de Québec, the City of Calgary, the Canadian Advanced Technology Alliance, the Utilities Telecom Council of Canada, Motorola Canada Limited and Harris Canada Systems Inc. The comments from commercial service providers were varied. Most smaller service providers were of the view that the D block should be auctioned for commercial mobile services without any obligation to serve public safety. Of the major national and regional service providers, only SaskTel supported a public safety designation. Bell, TELUS, Rogers, MTS Allstream and many other respondents recommended that Industry Canada initiate a further consultation on whether to designate the D block for public safety broadband use once the intended use of the D block in the United States has been determined. Xplornet further proposed that Industry Canada make the D block available to rural Internet service providers (ISPs) to deploy commercial fixed and mobile services while awaiting a U.S. decision, recognizing that, if this was allowed, rural ISPs operations would later have to move to other spectrum or operate in cooperation with public safety systems depending on the final D block decision.
93. The public safety community and other respondents listed above who supported the designation of a block of 10+10 MHz of the 700 MHz spectrum for public safety argued that it would be required in order to deploy a robust public safety broadband network across Canada and meet the growing demand for mobile data communications. They pointed to the unique requirements of public safety communications in terms of high reliability and coverage deep into buildings and underground as compared with commercial systems. Possible applications would include database access, imaging (e.g. building blueprints and mug shots), tracking (e.g. oxygen tank monitors on firefighters and licence plate recognition), Internet access and video streaming.
94. A public safety broadband network in the 700 MHz band could facilitate a coordinated response among various Canadian public safety agencies when responding to emergency situations. In addition, harmonizing the use of the PSBB block with the United States would enable economies of scale for equipment and allow for cross-border interoperability between public safety agencies in the United States and Canada. Furthermore, the majority of the Canadian stakeholders supported designating the PSBB block for public safety broadband use. Therefore, Industry Canada has decided to designate the bands 763-768 MHz and 793-798 MHz (PSBB block) for public safety broadband use.
95. Comments varied greatly with respect to whether to designate the D block for public safety or to auction it for commercial use. Most respondents stressed the importance of harmonization with the United States; however, there was no consensus on its use since most public safety entities supported designating it to public safety while many commercial entities supported waiting for the U.S. decision. Some commercial entities proposed that Industry Canada consult further on the D block once the U.S. had made a decision. On February 22, 2012, the United States enacted Bill H.R. 3630,20 which designates the D block for public safety broadband use.
96. From a technical point of view, interoperability with the United States will not be affected if there is a difference in the amount of spectrum designated to public safety on each side of the border, as the equipment available will support both 5+5 MHz and 10+10 MHz bandwidths through software configuration. Since the D block is now designated for public safety broadband use in the United States, it is unclear whether consumer devices such as tablets and smart phones would be available for commercial use in the D block in Canada.
97. Consequently, Industry Canada has decided to launch a further consultation to establish a policy framework for the use of the spectrum in the 758-763 MHz and 788-793 MHz bands (D block) in light of the U.S. decision.
98. Regardless of the final amount of spectrum that will ultimately be designated for public safety broadband use, a further round of consultation will be required. This future consultation will focus on the technical, operational and licensing issues related to the 700 MHz spectrum designated for public safety broadband use. Such issues will include whether a specific technology should be mandated, the identification of categories of users, the determination of licence fees, the possible role of a co-ordinating body in licensing of the spectrum, licence conditions (e.g. interoperability, as stipulated in Section 7 of RP-2521) and the use of public safety broadband spectrum in rural areas.
Decisions related to the public safety spectrum
B2-1: The bands 763-768 MHz and 793-798 MHz (PSBB block) are designated for public safety broadband use. Consequently, these bands will not be part of the 700 MHz auction.
B2-2: A decision on the use of the bands 758-763 MHz and 788-793 MHz (the D block in the Upper 700 MHz band) will be made following a separate consultation.
99. Industry Canada will initiate a further consultation on the technical, operational and licensing issues related to the spectrum designated for public safety broadband use in the 700 MHz band.
- 12 Frequency division duplex — allows bidirectional communication, where the transmit and receive links are deployed over different frequency bands.
- 13 In Canada, SP-768 MHz (issued in 2009) designated the frequency ranges within two of these four guardbands (775-776 MHz and 805-806 MHz) for public safety use, as shown in yellow in Figure B2. The technical rules for these frequency ranges will ensure compatibility with commercial services in the adjacent frequency blocks.
- 14 See 3GPP TS 36.104 v9.9.0 (2011-09): 3GPP Technical Specification Group Radio Access Network; Evolved Universal.
- 15 Terrestrial Radio Access (E-UTRA); Base Station (BS) radio transmission and reception (Release 9). See http://www.3gpp.org/About-3GPP.
- 16 For further details regarding the FCC’s guardband licensee requirements, refer to the FCC’s website at http://wireless.fcc.gov/services/index.htm?job=service_home&id=700_guard.
- 17 For further information, refer to Service Areas for Competitive Licensing at http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/h_sf01627.html.
- 18 Xplornet defines rural unbundling as the separation of “the rural population in the Tier 4 urban licences with populations above 100,000, so that the rural population can be properly served with broadband.”
- 19 Ontario and Quebec each have three Tier 2 service areas.
- 20Bill H.R. 3630 — Middle Class Tax Relief and Job Creation Act of 2012. For further details, see http://www.gpo.gov/fdsys/pkg/BILLS-112hr3630enr/pdf/BILLS-112hr3630enr.pdf.
- 21 See RP-25 — Policy Principles for Public Safety Radio Interoperability, at http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09554.html.
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