DRAFT REPORT – NOT PUBLISHED
Crowded Border Spectrum – An Indicator for the Future
of Cross-Border Interoperability
Executive Summary
The indirect process that U.S. public safety (PS) communications systems managers on
our border with Canada must use to coordinate requests for new spectrum through the
U.S. Federal Communications Commission (FCC) and Industry Canada (IC), and other
process problems contribute to, and help to explain why initial applications for spectrum
may be rejected. Additionally, the lack of transparency in the IC process and differing
spectrum management philosophies help to explain the need for multiple attempts to clear
a request. 85% of Canadians live in the zone where frequency coordination is required
compared to approximately 6% of Americans that live in the zone on the U.S. side. The
intensive Canadian use of spectrum in their part of the zone means that it is challenging
for U.S. PS agencies to get access to the spectrum they need to improve PS
communications systems operability along the border. It is unlikely that significant relief
will occur until actions underway to free up spectrum in the U.S. and Canada take effect,
and long-term solutions to address cross-border interoperability are put in place.
However, a reminder to everyone to keep asking for improvements in the international
frequency coordination process can produce results in the near-term that will help reduce
costs and speed improvements for PS communications systems managers that need to
address their current system requirements. The progress of improvements to the
international frequency coordination process will be an important indicator for the future
of cross-border interoperability.
Introduction
At a time when much of the public safety (PS) communications community focuses on
interoperability and the convergence of information and communications technologies,
fundamental barriers to basic operable communication still exist in a region along the
U.S.-Canadian border that is defined and governed by treaty-level agreements. To
perform the most routine and basic elements of their jobs, PS practitioners in law
enforcement, fire and emergency management services, and allied disciplines must have
spectrum and operable communications as a prerequisite to interoperable
communications.
These practitioners require sufficient wireless communications
capabilities to meet their everyday internal requirements (operability), which frequently
requires them to be able to work with other agencies on both sides of the border
(interoperability). Compared to convergence and interoperability, persisting problems of
operability along the border may not be as exciting, but they still demand our attention.
One of these “old business” items is the role that international considerations has in
managing the radio frequency (RF) spectrum to support the operability of new and
existing PS communications system. Some progress can still be made on the margins, in
spectrum management, but it is unlikely that significant relief will occur until actions
Page 1 of 11
underway to free up spectrum in the U.S. and Canada take effect. A reminder to
everyone to keep the “old business” moving forward will help speed progress.
Spectrum for Border Operability
Problems with spectrum management in the border region are usually characterized by a
PS communications system manager saying, “I can’t get the frequencies I need” to:
 Address coverage gaps in my jurisdiction
 Upgrade or build out my new system
 Comply with U.S. narrowbanding requirements
As an example, the State of Vermont has been working for many years to develop a
statewide communications system that would support the replacement of aging
communications systems, improve coverage, and address regional interoperability issues.
Because of mountainous terrain and low population density, Vermont needs to use parts
of the PS spectrum that are heavily used in the nearby Canadian population center of
Montreal. Knowing that obtaining the required authorization to use this part of the
spectrum is virtually impossible, Vermont has to look at using alternative parts of the
spectrum in ways that will drive up systems costs. In an era of tight budgets, this is
unwelcome news for the taxpayers of Vermont, and all the citizens and PS stakeholders
that would benefit from the new system – at all levels of government on both sides of the
border. To add to the irony, the current design has already had to be modified from its
original proposed configuration to accommodate spectrum issues related to Vermont’s
proximity to Montreal. The resulting delays and increases to system costs are
experienced in many U.S. communities that border Canada, particularly those near
Canadian population centers.
Spectrum Primer So what is spectrum? From school we remember that visible light is the only part of the
electromagnetic spectrum that we can see, and that it travels in waves. We see different
wavelengths of light as the individual colors of the rainbow. Violet has the shortest
wavelength and red has the longest. When all the waves are mixed together, they make
white light, which is essentially noise. Two-way radios use and respond to longer or
lower frequency1 radio waves in a part of the spectrum that cannot be seen by the naked
eye (see Figure 1).
Radio and microwave spectrum is governed and allocated as a limited natural resource to
prevent the mixing or interference of emissions among systems that generate
electromagnetic radiation in this part of the spectrum.
In the U.S. the National
Telecommunications and Information Administration (NTIA) manages the spectrum used
by the Federal Government, and the Federal Communications Commission (FCC)
manages and regulates all domestic non-federal spectrum use. In Canada the Office of
1
Remember frequency (f) and wavelength (λ) are inversely proportional relative to the speed of light (c, a
constant) I.e. in free air c=f* λ
Page 2 of 11
Spectrum Management and Telecommunications, in Industry Canada (IC) is the agency
responsible for spectrum management.
Different parts or bands of the radio spectrum (see Table 1) are valued for different
propagation characteristics that affect the ability to send and receive voice
communications. Radio wave propagation is the behavior of radio waves when they are
transmitted from one point on the earth or sky to another. Because of favorable
propagation characteristics, PS land mobile radio (LMR) systems operate in the very high
and ultra high frequency (VHF and UHF) bands. In general, the longer wavelengths in
VHF bands propagate more favorably over rural terrain and require fewer towers to cover
a given area. In the case of Vermont, the system design calls for using towers on the tops
of mountains operating in VHF and low-band UHF frequencies to maximize coverage.
Transmitters operating in the UHF high-bands around 700 and 800 Megahertz (106
cycles/second or MHz) won’t provide necessary coverage from mountaintop locations.
As UHF high-band radio waves travel away from a tower, the signal strength drops off
more quickly as they propagate over the terrain than in lower UHF and VHF frequency
bands. Increasing the radiated power for transmissions would compensate for this dropoff, but the maximum power level at a tower is regulated to minimize interference, and
the system design must also consider the maximum power that handheld and mobile units
can use to transmit back to an antenna on a tower. To operate in the higher frequency
700 and 800 MHz bands Vermont’s system, which currently calls for 40 fixed sites,
would need to add over 100 fixed-site locations. This makes sense when you think about
putting towers at lower altitudes in a mountainous terrain to reduce the distance to a
handheld or mobile unit. Because the mountain creates a shadow effect with no coverage
behind the mountain, a system designer is required to add more towers around the
mountain to fill in the shadowed areas.
Page 3 of 11
Figure 1 Electromagnetic Spectrum2
VHF and UHF systems also propagate differently in built up areas where the
performance of signals with shorter wavelengths reflecting in urban canyons and
penetrating into buildings can be more favorable. UHF frequencies in the 800 MHz band
are often used for PS communications systems in urban or built-up areas. PS systems in
built-up areas that use this UHF high-band can mitigate the need for a greater number of
antennas by placing them on existing towers. These towers have typically been erected
by telecommunications companies that can provide profitable cell service to a larger
customer base than what is typically found in sparsely-populated rural areas.
PS spectrum use has evolved over time as technology and needs have changed. Initially,
almost all two-way communications were confined to the frequency range of 30-50 MHz.
As technology advanced, however, transmission at higher frequencies became possible,
offering a temporary solution for spectrum congestion and crowding. Now, PS users
operate in a wide variety of bands, including 150 MHz, 450 MHz, and 800 MHz
spectrum. While these additional allocations enabled the development of more
communications capacity, they also resulted in the fragmentation of PS spectrum across
multiple bands. Radios that operate in multiple bands are only now becoming more
widely available, but they are currently very expensive relative to standard PS radios. As
a result, agencies that use two or more frequency bands in a single system have had to
equip their practitioners with multiple radios. Fragmented PS spectrum is also a
significant contributor to a lack of interoperability among agencies.
Radio Frequency Band Ranges and Names
Band Range and Name
Frequency
ELF
Extremely Low
Frequency
3–300 Hz
1000100,000 km
VLF
Very Low Frequency
3–30 kHz
100–10 km
LF
Low Frequency
30–300 kHz
10–1 km
MF
Medium Frequency
300–3000 kHz
1000–100 m
HF
High Frequency (Short
3–30 MHz
Wave)
100–10 m
VHF
Very High Frequency
30–300 MHz
10–1 m
UHF
Ultra High Frequency
300–3000 MHz
100–10 cm
SHF
Super High Frequency 3–30 GHz
10–1 cm
EHF
Extremely High
Frequency
10–1 mm
30–300 GHz
Table 1 RF Bands and Ranges
2
Wavelength
http://www.lbl.gov/MicroWorlds/ALSTool/EMSpec/EMSpec2.html
Page 4 of 11
Spectrum Management Most Canadians live within 100 miles of the border with the U.S.(see Figure 2). The
inability of U.S. PS agencies to obtain VHF and UHF frequencies in the border region is
in large part a direct consequence of this concentration of Canada’s population along the
border. Canada’s regulatory and public safety agencies have long recognized a critical
shortage of spectrum for land mobile radio (LMR) services in Canada’s urban centers.3
Trying to increase the amount of spectrum available for PS agencies on the U.S. side to
address operability issues has a significant potential for affecting a large part of their
population, and both sides recognize the need to coordinate with each other to make the
required spectrum available for their PS practitioners. To manage the allocation and use
of spectrum, the U.S. and Canada have defined the border region through an agreement
known as the “Exchange of Notes between the Government of the United States of
America and the Government of Canada Concerning the Coordination and Use of Radio
Frequencies Above Thirty Megacycles per Second, with Annexes, or the “Above 30 MHz
Agreement.” The Above 30 MHz Agreement entered into force on 24 October, 1962,
and specifies a zone of approximately 75 miles (120 km) on both sides of the border
where international spectrum coordination is required. The coordination zones for the
VHF and UHF bands are defined by Lines A, B, C, and D, as shown in Figure 3.
Figure 2 Distribution of U.S. and Canadian Population4
3
See for example, http://192.197.180.71/eic/site/smt-gst.nsf/eng/sf05504.html and
http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/apco.pdf/$FILE/apco.pdf
4
http://www.roebuckclasses.com/105/regions/namer/namericahuman/humannamer.htm
Page 5 of 11
Figure 3 International VHF and UHF Frequency Coordination Zones5
In an era of converging information and communications technology Canada is actively
pursuing communications strategies to rethink their regulatory environment,6 free up
spectrum, and address PS communications operability and interoperability issues. Many
of these activities are occurring in parallel with similar activities happening south of the
border. Several high profile management actions that address PS spectrum congestion
are currently underway and coming to fruition in both the U.S and Canada. One is the
transition from analog or waveform-based TV to digital TV, which is based on the
transmission of words and numbers encoded as on- and RF off-pulses. Another key
spectrum management activity is reducing the spectral footprint or bandwidth of existing
RF channels, called narrowbanding.
The advent of digital communications technology allows less spectrum or bandwidth to
be used to transmit broadcast TV, LMR, and other communications signals. The idea of
moving TV stations to smaller spectral footprints has already been implemented in the
U.S. and in many markets in Canada. The difference between the old and new channel
spectral footprints, called the digital dividend, has been reclaimed by federal regulatory
agencies and some of this spectrum has been set aside for public safety agencies. Other
parts of the newly available spectrum have been sold to meet the needs of commercial
service providers and to generate revenue.
In this country, spectrum from the digital dividend has already been set aside for public
safety narrowband, which is suitable for LMR digital voice transmission, and broadband,
which is suitable for digital voice and high speed data transmission. This includes action
to set aside the D Block in the 700 MHz band, which has been in the news recently. The
Canadians are currently completing the shut down of the Canadian Broadcasting
Company's (CBC) analog broadcasting transmitters a year ahead of schedule in 2012 and
5
6
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-1064A1.pdf
See for example http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09862.html
Page 6 of 11
deciding what to do with their digital dividend. The Canadian PS community is making a
concerted effort to harmonize the use of the Canadian digital dividend with the activities
on U.S. side. In anticipation of Canadian action, the public safety communications
community of both nations is now turning its attention to developing a new, nationwide
and international broadband PS communications architecture and system for the long
term. Under this architecture digital information and voice technologies will converge
and provide a seamless system for communicating mission critical voice and data for PS
practitioners. Estimates range from 10-20 years for this system to be ready to meet
demanding PS requirements and replace LMR. Both rural and urban PS communications
systems on both sides of the border should be able to benefit from the fruits of crossborder coordination and the U.S. and Canadian transition from analog to digital TV in
this timeframe.
As the Canadian transition to digital TV happens and U.S. and Canadian band plans in
high band UHF are aligned, the additional spectrum that it frees up for Canadian
communications systems may allow for some near- to mid-term relief for PS agencies in
urban and built-up areas facing each other on both sides of the border. This part of the
spectrum is best suited for these U.S. PS agencies that operate in the highly congested
UHF high-band and their Canadian neighbors dealing with similar congestion on their
side of the border. If the Canadians look at aligning VHF and low-band UHF band plans
with the U.S. as they adjust their spectrum management policies and procedures, some
additional spectrum might become available in the mid-term for U.S. PS agencies
operating in more rural regions of the coordination zone as well.
In general, the Canadian land mobile bands align with the U.S. land mobile bands.
Although the bands themselves are aligned, the way that the bands are used may not. For
the most part, the United States has set aside sections of the land mobile bands for
different classes of users, and PS users are limited to using designated channels within a
specific range of frequencies. In Canada, because channels are licensed on a first-come,
first-served basis in the VHF and UHF low-bands, PS and commercial LMR users may
occupy adjacent channels within a band that is set aside for PS users in the U.S. As a
result, U.S. PS agencies along the border find they share their band with taxi companies
or other kinds of users. In the U.S., while frequency coordinators try to ensure that PS
licensees are the only operator in a channel, this is not always achieved. The FCC
assumes and requires that frequencies below 470 MHz will be shared between multiple
users. In Canada, each licensee is assumed to have an exclusive use of a channel which
adds to the problem of spectrum congestion. The U.S. and Canada are not likely to
achieve significant alignment in these PS bands though because of the lengthy process
required in Canada to relocate or displace incumbent licensees, and the limited
availability of replacement frequencies. The highest priority for focusing on alignment
would most likely be for the U.S. national interoperability channels, the VHF and UHF
talk-around channels (VTAC and UTAC), which would provide a baseline level of
interoperability along the border in both rural and urban areas.
The efforts of both nations to implement these and other activities will free up spectrum
that can be used by each country’s PS practitioners, but the timeframe and scope for their
Page 7 of 11
completion is different in each nation. The methods for coordinating the pace and impact
of these changes in the border region are managed under a complex international
frequency coordination process, which in turn is governed by treaty-level agreements
under the Above 30 MHz Agreement. The international frequency coordination process
has come under increasing scrutiny from the PS communications community, due in part
to long standing issues that have attracted greater attention as the U.S. approaches the
deadline for narrowbanding. Looking at the widespread impact that international
frequency coordination has had on narrowbanding will help to show how it affects PS
communications operability on the U.S. side of the border, and highlight areas where
progress could be made in the near-term.
International Frequency Coordination Under narrowbanding federal regulatory agencies require LMR service providers,
including PS agencies, to reduce the bandwidth of the channels that they currently use.
In the U.S. all LMR license-holders in the 150-512 MHz, VHF high-band and UHF lowband, are required to narrowband by 1 January 2013. In Canada, narrowbanding is only
required for the 138-174, 406.1-430, and 450-470 MHz bands, and is ongoing in areas of
high spectrum congestion at the discretion of regional IC offices. Under the minimum
requirements for narrowbanding in the U.S., the frequency on which a channel is
centered, and the maximum power levels do not have to be modified, and international
frequency coordination is not required. However, a PS agency may wish to upgrade their
communications system to leverage expenditures that narrowbanding may require.
Examples may range from upgrading a system from analog to digital, to using
narrowbanding to help justify a new statewide interoperable communications system.
Depending on how a U.S. PS agency decides to comply with requirements, a license
change associated with narrowbanding may require international frequency coordination
with Industry Canada (IC). International frequency coordination is at the heart of many
of the current difficulties associated with trying to improve the operability of PS
communications systems in the border region, and narrowbanding provides a good
example of how this plays out.
For U.S. PS agencies within the A or C Lines, any changes to a license beyond simply
implementing narrowbanding with existing equipment will trigger a requirement for
international frequency coordination. In the case of a completely new statewide system,
such Vermont’s or Maine’s, international frequency coordination and consequential
system design changes can add significant delays and drive up system costs substantially.
Upgrading from analog to digital and taking advantage of added channels within the
same bandwidth may simply add delay. In all cases the initial request to IC for
international frequency coordination will fall under extreme scrutiny and the timeframe
for dealing with this may range from one month to three years.7 A general description of
the process may help explain why.
International frequency coordination for a U.S. state, tribal or local agency begins by
submitting a request for a license change to the FCC, which is filed with the FCC’s
7
p.85, http://wirelessradio.net/pdfs/VHF-UHF%20Narrowbanding%20Guide%202012.pdf
Page 8 of 11
Universal Licensing System (ULS). These requests are forwarded to IC for coordination.
Unfortunately the FCC’s ULS is not set up to forward interference studies that an agency
and its engineers may have already conducted and submitted with the original license
change request. There is also a 10% chance (where did the 10% come from) that the
applicant’s interference studies did not include all of the potentially affected Canadian
stations. The IC database that is available to search for these stations contains 90% of
Canadian stations. This protects confidential information about sensitive communications
systems that are not included in the publicly accessible database. Unfortunately it also
adds a level of uncertainty for U.S. stations requesting service through the international
frequency coordination process that does not become apparent until the requester receives
their first rejection. IC services 15,000 international frequency coordination requests per
year, including 10,000 requests from the U.S. They report that their average turnaround
time for a request from the U.S. is 35 days.
In the next part of the process, local IC spectrum management offices conduct an
individual analysis of the U.S. frequency coordination requests for potential harmful
interference with the operation of Canadian stations. IC has five regional offices, twenty
district offices, and fourteen branches or sub-offices. This evaluation is performed by
spectrum managers who are aware of local terrain and Canadian client stations, and have
experience in frequency analysis. The analysis of the technical information associated
with a request is based on sound engineering practices, similar to procedures used by the
FCC. As noted above though, interference studies that the requestor may have already
performed and submitted through the FCC ULS do not get forwarded to the IC spectrum
manager, and are thus not part of the technical information associated with the request.
IC reports that each spectrum manager has their own methods for conducting the analysis
for potentially harmful interference, but their tools are standardized. The public safety
communications community in the U.S. has asked for clarification of these methods and
standards, which IC has promised to capture and clarify the coordination evaluation
methodology in a white paper, which is currently being drafted. The analysis determines
the power level for signals from the requestor's U.S. station that would encroach on the
Canadian station's coverage area. The Canadian spectrum manager then renders an
individual consideration based on their knowledge of the area and a comparison of the
results of a terrain-based propagation model of the U.S. emitter's signal and a threshold
received power level that would cause harmful interference with the Canadian station's
signal. These threshold power levels for signals from a U.S. station that could potentially
interfere with the Canadian station are lower in Canada than what would be deemed to
interfere in the U.S. These thresholds have been characterized to be on the level of
background noise, meaning no interference at all will be tolerated. This reflects the
difference in management philosophy as noted previously. On the U.S. side, the FCC
assumes and requires that frequencies below 470 MHz will be shared between multiple
users.
In summary the indirection in the process of submitting requests to IC through the FCC
and other process problems contribute to, and help explain an initial IC rejection.
Additionally, the lack of transparency in the IC process and differing spectrum
Page 9 of 11
management philosophies help to explain the need for multiple attempts to clear a
request. 85% of Canadians live in the zone where frequency coordination is required
compared to approximately 6% of Americans that live in the zone on the U.S. side. The
intensive Canadian use of spectrum in their part of the zone means that it is virtually
impossible for U.S. PS agencies to get access to the PS spectrum bands they need to
improve operability. This has led U.S. PS communications managers to develop creative
approaches to obtaining needed spectrum. The State of Maine has petitioned the FCC to
allow them to use parts of the spectrum set aside for railroad operators. Vermont has
asked to use spectrum designated for land mobile paging services. Unfortunately the
process required to gain access to this spectrum adds cost and schedule risk to PS
communications system development. Requests to use spectrum that is not designated
for PS use is highly likely to be challenged by representatives of the designated spectrum
users. In Maine, the representatives of railroad users are challenging Maine's request.
This process will require time to be resolved, and there is no assurance that it will be
resolved in the State's favor. In the case of Vermont, the requested frequencies are
already owned by a commercial firm. Vermont can use these frequencies if it can come
to terms with the incumbent owner which can potentially add cost to the development of
their statewide PS communications system.
Recommendations
Issues regarding the international frequency coordination process have been aired in
several forums,8 and it is clear that the process itself, is only a small part of a much larger
picture. Lack of spectrum, differences in spectrum management practices, rapidly
changing technology, and coordination of international communications policy and
practice in ways that are respectful of sovereignty all play a role in the unique operability
problems that PS communications systems managers face on the border. It is also clear
that these local, state, provincial, and tribal managers need help to fix these problems that
can only be provided through federal governments carrying out their responsibilities.
The current system provides a cautionary tale as we look at building a new broadband
system that will work seamlessly across the border. If we can’t get the current process
right, what will the future hold for a cross-border interoperable PS broadband enterprise?
The Number 1 recommendation of the 2010 Cross-Border Interoperable Communications
Workshop is to create a Canadian/American interoperability coordinating body. The
need to address both the long-term and short-term problems that affect basic operability,
and the timely development and maintenance of day-to-day processes for implementing
and managing mutually-agreed PS communications issues on the border would assuredly
be at the heart of making this body meaningful and effective. Successful examples of
working cross-border management collaborations that are founded in treaty-level
document already exist, and we can look to these and other examples for the way
forward. To organizations such as the International Joint Commission and the St.
8
See
http://npstc.org/download.jsp?tableId=37&column=217&id=917&file=2010CanUSCrossBorderWorkshop
Proceedings101130.pdf and
http://npstc.org/download.jsp?tableId=37&column=217&id=936&file=InsideWashingtonHaller110104.pdf
Page 10 of 11
Lawrence Seaway, the development of processes for day-to-day management are as
important to their successful operations as the air we breathe. As the PS communications
community establishes an interoperability coordinating body, fixing a fundamental
process for any future cross-border interoperable communications enterprise can provide
an opportunity to demonstrate how such a collaborative effort will either stand or fall.
Some ideas about how to fix the international frequency coordination process have been
suggested in the references cited earlier in this section, and they include:








Create a time limit for the FCC and IC approve or deny requests
Canada move to narrow banding to improve spectrum efficiency
IC and FCC develop a more efficient exchange of information so that license
applications are not needlessly rejected
Agreement on a common propagation model
Agreement on band plans, especially for interoperability channels
Easier access to the Canadian database for better pre-coordination
The provision of interference studies to Canada with the initial application
Greater Canadian acceptance of only emission changes for U.S. incumbent
stations
In response to earlier requests for more information about their review process, IC is
developing a white-paper on their coordination evaluation methodology. The Canadian
Centre for Security Science has also conducted a study9 to model radio coverage gaps
across the border, which included field measurements to validate the models and
recommendations on technical solutions to address the gaps. The FCC has published
guidance10 that is intended to help applicants requesting frequencies along the border.
These important first steps should be used to look at operability and international
frequency coordination process in the broader interoperability context. They can be
leveraged to achieve quick-fixes for process problems that can be addressed in the nearterm, and as a basis for longer-term solutions.
As in so many other activities across our border with Canada, information-sharing that
respects the security, privacy, and sovereignty concerns of each nation is key. PS
communications is not the first domain, nor will it be the last where requirements,
resources, capabilities, and priorities must be shared across the border to produce
effective action. As the community works to turn visions of PS interoperability and
broadband into reality, a gentle reminder that operability is the basis for interoperability
can perhaps help to transform a imperfect process into a showpiece for things to come.
9
See Canada-United States Border Radio Coverage at
http://www.npstc.org/newsletter.jsp?vol=11&issue=1
10
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-1064A1.pdf
Page 11 of 11