The Police Federation of Australia (PFA) has criticised the Productivity Commission's draft report into allocating spectrum to law-enforcement and emergency services, saying the results of the commission's examination of the costs, risks, and benefits inherent in delivering a Public Safety Mobile Broadband (PSMB) capability were "short-sighted".
Public service agencies (PSAs) -- which include police agencies, fire service organisations, ambulance services, the State Emergency Service (SES), and marine rescue and coast guard -- have been pushing for their own spectrum for years, saying they need to be able to access high-speed video, high-quality images, geolocation tools, and biometric capabilities wherever they are working.
In November, the government tasked the Productivity Commission with undertaking a costs-based analysis of the best way to deliver a mobile broadband for PSAs.
"The commonwealth, state, and territory governments all recognise the potential benefits of an effective national public safety mobile broadband capability for agencies such as police, fire, and ambulance services," then-Communications Minister Malcolm Turnbull and Justice Minister Michael Keenan said in a joint statement.
"A mobile broadband capability for public safety agencies would allow for an improved response to emergency events and enable better communication within and between jurisdictions."
In the Public Safety Mobile Broadband Productivity Commission Draft Report [PDF], published by the Productivity Commission on September 22, the commission identified three options: Constructing a dedicated PSA network with their own allocated spectrum; taking a purely commercial approach, which would involve mobile carriers providing contractual services to PSAs; or a hybrid of the two, such as Telstra's LANES.
Allocating a dedicated network was estimated by the commission to cost AU$6.1 billion over a 20-year period, while the commercial option would only cost AU$2.1 billion and the hybrid solution around AU$4 billion. The substantial cost saving in the latter two options would be due to the PSAs being able to leverage and share existing infrastructure.
A dedicated network also runs the risk of taking longer to build out and deploy, and would provide less flexibility and scalability for the short term. However, the commission also noted that going with a commercial or hybrid option could result in a lack of competition, as well as lock-in.
"A commercial approach represents the most efficient, effective, and economical way of delivering a PSMB capability to PSAs," the commission concluded in its report.
PSAs would therefore be sent directly to telecommunications carriers and equipment manufacturers without any dealings with government in order to gain their mobile broadband services.
The PFA has criticised this approach, with CEO Mark Burgess telling ZDNet that PSAs do not agree with the Productivity Commission's conclusion, as it is based solely on economics rather than also taking into consideration public safety.
"Historically, every incident that has arisen where there's been some form of either coronial inquiry or other inquiry or a royal commission into natural disasters in particular, but a whole range of things in that space, every one of them has found a problem with communications. And this is just condemning us to have the same problem over and over and over again," Burgess said.
"It's very, very short-sighted on the part of the Productivity Commission, but understandably, they're not experts in this area; they're basically economists. They're looking at the costs aspect of it. Our key concern is the safety of the public."
Burgess suggested that rather than palming off emergency and law-enforcement agencies to telcos, the government's best course of action would be to allocate 20MHz of spectrum to the PSAs, with the agencies to then go to the telcos and equipment providers to negotiate how to roll out the network.
"The outcome should be an allocation to public safety, and then public safety will work with the private sector -- that is, the telcos and other providers -- to provide the best possible outcome for the Australian community. What that might look like at the end of the day is obviously still subject to negotiation and discussion," he said.
The government should be careful of what it decides, Burgess pointed out, because putting economic concerns above public safety would be a dangerous course of action.
"Any government that believes that it's not in the best interests of the public to provide them with the best possible outcome -- well, then, they'll suffer the consequences politically. If they try to short-change the public, and to maximise the government's return on the spectrum, then they'll suffer the fate that they should suffer in the eyes of the public."
The government has been considering emergency services spectrum allocation for several years, with the Australian Communications and Media Authority (ACMA) announcing in 2012 that it would designate 2x 5MHz slots in the 800MHz spectrum band, along with 50MHz of spectrum in the 4.9GHz spectrum band for the deployment of temporary cells on wheels.
The emergency services groups had wanted double this -- 2x 10MHz spectrum in either the 700MHz or 800MHz band -- and the government was consequently accused of risking lives by providing only half the spectrum necessary for PSAs to respond to emergencies.
The federal parliamentary joint committee on law enforcement launched a fresh inquiry the following year to examine how much broadband spectrum PSAs require, and whether the 700MHz or 800MHz band would be more suitable.
The PSAs and state governments made submissions to this inquiry, with all recommending being given the leftover 2x 15MHz spectrum from the 700MHz band, following the completion of the digital dividend auction in May 2013. This would circumvent the cost of building out a new network, as well as harmonising Australia's emergency services network with those from other countries that make use of the 700MHz band, such as the United States.
Telstra, however, argued that the leftover 700MHz would be "inappropriate" for PSA use, as it is needed to support the continuing growth in commercial broadband services nationwide. Instead, Telstra advocated its LANES approach, by signing a deal with Motorola in October 2014 wherein it would allocate specific "lanes" of its spectrum to PSAs on its 4G network.
This was the hybrid approach also put forward by the Productivity Commission's draft paper, which would see PSAs sign a contract with Telstra to lease dedicated spectrum owned by the telco. In circumstances where demand exceeded the capacity of the specific emergency spectrum, the PSAs would be moved onto Telstra's commercial 4G network and given priority over other users.
"This allows the network capacity available to PSAs to be scaled up instantly," the report noted.
"Telstra LANES has been trialled in Queensland and Western Australia in 2013, and for the G20 Leaders' Summit in Brisbane in November 2014 (in both cases, using spectrum licensed to Telstra for the dedicated network component). Telstra has reported that these trials showed that PSAs could be given preferential data treatment over a shared network, and that users suffered no disruption of service while moving between the dedicated PSA capacity and the broader network capacity."
Burgess and the PFA, however, remain unimpressed with Telstra's LANES, saying it needs more testing before the decision is made.
"Even the report itself says that whilst it recommends the process through Telstra and the LANES model, it says itself that it's not fully tested. So it's a bit presumptuous to say, 'we'll just throw all our eggs in one basket' for something that's not even tested," Burgess argued.
For now, the Productivity Commission has recommended small-scale trials of commercial and hybrid services to properly judge the efficiency, cost, benefits, and risks. It also said that tenders will have to be submitted for any service provider to gain a contract with a PSA, in order to encourage competition.
Burgess, however, said that the PSAs will not give up the fight for their own spectrum to be allocated.
"We will not be going away until we get 20MHz of spectrum allocated to public safety."
The Productivity Commission is accepting submissions on its draft report until October 28.