Motorola Solutions’ response to the ACMA’s paper:

Five-year spectrum outlook 2013-2017

The ACMA’s spectrum demand analysis and strategic direction for the next five years SEPTEMBER 2013

Prepared by: Michael.Hill@motorolasolutions.com

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Context

Radiocommunications are vital to Australia’s diversified and growing economy.

Radiocommunications are essential for agencies involved in the defence or national security of Australia, law enforcement or the provision of emergency services. Two-way radio also provides the communication infrastructure for a wide range of industries ranging from agriculture, mining & construction through to transportation & hospitality.

Within Australia and internationally Motorola Solutions (Motorola) is a major supplier of radiocommunications equipment and services to governments, emergency services organisations, the mining industry, the energy industry, manufacturing sectors, transportation, tourism, telecommunications carriers and telecommunications service providers.

Motorola is a strong supporter of standards based technology and spectrum harmonisation with Australia’s major markets in Asia, Europe and the Americas. This support helps to ensure that up-to-date radiocommunications equipment is readily available. Use of standards based technology and spectrum harmonisation with other major markets reduces costs for manufacturers and service providers, maximises competition, and results in lower costs for consumers.

Motorola supports the ACMA and its requirement to fulfil the object of the Radiocommunications Act 1992 and congratulates the ACMA on its continued efforts to seek industry feedback and participation in the spectrum planning processes.

Motorola has been a leader in the field of two way radiocommunications for 85 years, excelling in the research and development, production, marketing and efficient operation of radiocommunications equipment and systems all over the world. Motorola’s brand is indeed synonymous with high quality radiocommunication products and services. As a world-wide operation with close operator links Motorola believes that its accumulated experience qualifies it well to comment on this discussion paper.

The primary commercial interest of Motorola has been, and will continue to be, in the provision of solutions encompassing the design, manufacture and supply of communications equipment, systems and services. Motorola knows that issues relating to the allocation of radio frequency spectrum impact directly on the demand

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for its communications products and the issues discussed here are particularly relevant.

Motorola is therefore pleased to have the opportunity to comment on what it considers to be the critical issues raised by the Australian Communications and Media Authority’s invitation to comment. Motorola especially welcomes the Government’s commitment to a full consultation process.

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Motorola has responded to the ACMA’s discussion topics and project descriptions which are related to the following subjects and frequency bands:

Review of the 803–960 MHz band .................................................................................................... 5

Spectrum for public safety agencies ................................................................................................. 7

Wireless access services (WAS)...................................................................................................... 17

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Review of the 803–960 MHz band

The replan of the 803–825 MHz, 845–870 MHz band, including consideration of expanding two-frequency services in the 800 MHz band are very important to Australia’s radiocommunications industry.

The internationally adopted 800 MHz land mobile PPDR and trunking band segment is 806-824 MHz paired with 851-869 MHz. The International Telecommunications Union (ITU) Resolution 646 (Rev. WRC-12) which is a part of the International Radio Regulations that has the status of a global treaty has identified this band as a harmonized band for Region 3 of the Radio Regulations which includes Australia. Further, ITU Radio Recommendation M.2015 provides frequency arrangements for the bands 806 to 824 and 851 to 869 MHz for narrow band public protection and disaster relief operations. Many equipment manufacturers provide radiocommunications equipment meeting international standards in this band segment. National regulators have chosen all or some of this segment to meet the needs of their domestic markets. Australia has adopted the segment 820-825 MHz paired with 865-870 MHz for land mobile networks.

This band is critical for use with spectrum efficient trunking and data radiocommunications. This has been especially true in the spectrum high demand areas in and around Brisbane, Sydney and Melbourne. The band is also important in lower demand areas in mining, industrial processing and in-building environments where 800 MHz transmission performance is superior to that offered in lower frequency bands.

Radiocommunications in this band has become increasingly important to:

Minerals and energy mining: for exploration, construction and production

State government public safety: for law enforcement data communications

Airport passenger movement management at major airports

Transportation: for passenger transport, freight transportation, highway incident response and towing services

Local government: for personnel security, public passenger transportation, public works, and disaster management

Security: for locations like art galleries, railway stations, retail outlets, banks, museums and DoD facilities.

Volunteer ambulance communications

Stevedoring operations at major port facilities

Waste collection and management

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Whilst the channel bandwidth in this spectrum segment is set at 25 kHz per channel the industry trend is for the deployment of technologies which offer up to four time division multiple access (TDMA) time slots per channel. This provides an equivalent spectrum efficiency of 6.25 kHz per active user.

The ACMA’s 2011 announcement of a review of this band has had an immediate and continuing negative effect on user confidence in the short term viability of investments in radiocommunications infrastructure and equipment in this band. This lack of confidence applies to both government and non-government users.

The prospect of being required to relocate to another band in the foreseeable future and the inevitable costs associated with new equipment and the disruptions to operations are of great concern to the users. Motorola is aware that many new investments have been postponed until band certainty is re-established.

As a minimum, the existing 5 + 5 MHz amount of 800 MHz narrow band trunking spectrum needs to be preserved within the internationally assigned 800 MHz band to support the existing users. An additional amount of at least 1 MHz of paired spectrum will be required to meet the growing demand within the scope of this five year outlook.

No comparable, alternative spectrum outside of the 800 MHz band is available in spectrum high demand areas for the essential services provided for by the current assignments.

If spectrum is to be allocated to the public safety agencies (PSA’s) in the 800 MHz band it should be allocated in international mobile telecommunications (IMT) band 26. A more detailed discussion on this topic is provided later in this paper.

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Spectrum for public safety agencies

Motorola acknowledges the fact that over the past several years the ACMA has provided exclusive access to spectrum for Australia’s public safety agencies for use with narrowband voice and data services in the 403-470 MHz band and for broadband hot-spot and linking services in the 4.9 GHz band.

Currently there exists a continuing debate about the exclusive allocation of mobile broadband spectrum for use by Australia’s public safety agencies. Much of the recent debate has been generated by the recommendations of the Parliamentary Joint Committee on Law Enforcement, Spectrum for public safety mobile broadband, July 2013 and by the change in Federal Government in September 2013.

Motorola believes that the two most important considerations relating to broadband spectrum for public safety agencies are:

1 How much spectrum should be allocated; and 2 In which band should the spectrum be allocated?

How much spectrum should be allocated?

Based on its participation in live LTE systems trials and demonstrations with public protection and disaster relief (PPDR) agencies, in North and South America, Australia, and Asia, Motorola has advocated and continues to recommend a minimum allocation of 10 + 10 MHz of dedicated public safety mobile broadband (PSMB) spectrum.

Through its close cooperation with international and local PPDR agencies Motorola has found that routine day-to-day public safety user uplink bandwidth requirements exceed those of commercial carrier users because of the need to share data from the scene of a typical level 1 incident. This level of data sharing exceeds the capacity of a 5 + 5 MHz channel. Typical level 1, level 2 and level 3 incident data requirements can be seen below in Diagram 1. Public-safety users are working on medium severity or level 2 incidents on a regular basis. Incidents like hostage situations, multi-car crashes, and smaller scale natural or man-made disasters. These medium severity incidents require responses from multiple public-safety and other agencies and require the use of multi-agency applications that involve essential data and video services. They can also involve

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data dispatch functions, location and mapping, incident and status reports, records & database lookups, access to manuals, building plans, image downloads, tactical video from select vehicles, personnel, and hot zone asset deployment. With the large number of agencies, users, and broadband data and video requirements these medium severity incidents also exceed the downlink capacity of a 5 + 5 MHz channel. Typical level 1, level 2 and level 3 incident data requirements can be seen below in Diagram 1. High severity, level 3, public safety incidents would be expected to exceed the uplink and down link capacity of a 10 + 10 MHz channel. To manage this situation dedicated PPDR networks provide public-safety users with dynamic user prioritisation, pre-emption, and quality of service (QoS) guarantees for their users and applications. Typical level 1, level 2 and level 3 incident data requirements can be seen below in Diagram 1.

Diagram 1: Typical level 1, level 2 and level 3 incident data requirements High-definition video has become the standard for mobile video content intended for use by both commercial and specialist users. The resulting bandwidth demands are straining commercial networks to their limit. The amount of data passing over mobile networks almost doubles every year – consuming three quarters of mobile systems bandwidth. So it’s no surprise that first responders are clamouring for more and better data device and network capabilities. Some PSA users are using their

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own devices as workarounds while they wait for their departments to catch up with what’s happening in the community. Meeting the expectations of frontline responders, who need data to do their jobs better and more safely, is clearly becoming more urgent. Mobile video is a consumable, a daily staple, and it is therefore increasingly unacceptable from the public’s point of view that public safety officers are not able to access the same technology to provide improved service to the community. An allocation of a 10 + 10 MHz channel for the deployment of a private LTE system with in-built dynamic user prioritisation, pre-emption, and quality of service (QoS) guarantees will ensure that public-safety agencies are better equipped to meet the increasing need to access and to share data during emergency situations.

There has been significant research undertaken on this topic in the United States (US), Canada, Hong Kong and Germany.

After years of deliberation the US has allocated 10 + 10 MHz of PSMB spectrum.

Canada has already allocated 5 + 5 MHz of PSMB spectrum and is currently debating whether to increase this to 10 + 10 MHz.

In 2011 Defence Research and Development Canada published a report entitled: 700MHz Spectrum Requirements for Canadian Public Safety Interoperable Mobile Broadband Data Communications

The report found that “[t]he result of the modeling, taking into account uncertainty factors, shows that the amount of bandwidth required to satisfy the needs of public safety to conduct their missions during commonly re-occurring major emergency situations with modern tools and applications is greater than 20MHz in the near-to-mid term, and likely to also exceed 20MHz in the long term, despite advances in technology. Clearly even with the full 10 + 10 MHz allocated, the community will need to take measures to efficiently manage broadband data communications carefully during periods of peak demand.”

The report is available at: http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/smse-018-10-public-safety-sub2.pdf/$FILE/smse-018-10-public-safety-sub2.pdf

At the end of 2010 a report entitled: PPDR Spectrum Harmonisation in Germany, Europe and Globally was published by WIK-Consult on behalf of the German Federal Ministry of Economics and Technology (BMWi).

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The report found that “Assuming that one of the technologies recognised by the ITU as a future IMTAdvanced standard (presently there are two candidate technologies, LTE Advanced and Mobile WiMAX) is deployed, minimum spectrum requirements below 1 GHz for Germany are estimated to be 15 MHz uplink and 10 MHz downlink.”

The report is available at: http://www.bmwi.de/English/Redaktion/Pdf/ppdr-spectrum-harmonisation-germany-europe-globally,property=pdf,bereich=bmwi2012,sprache=en,rwb=true.pdf

A study carried out by Prof John Ure, Director of the Technology Research Project, University of Hong Kong, and Director of TRPC Pte Ltd. (Singapore) on Public Protection and Disaster Relief (PPDR) Services and Broadband in Asia and the Pacific: A Study of Value and Opportunity Cost in the Assignment of Radio Spectrum ( www.trpc.biz/ppdr-and-broadband-in-asia-pacific ) has indicated that the opportunity cost per capita of 10+10 MHz to the Australian economy is about $33 as compared to annual losses of about $300 per capita due to PPDR incidents as shown in the table 10 of the report:

Opportunity costs versus PPDR losses on a per capita basis Country

Opportunity cost of 20MHz

Annual losses per capita

Australia $33.39 $299.04 China $8.65 $54.47 Indonesia $1.82 $505.01 Malaysia $5.53 $268.94 New Zealand $19.69 $279.78 Singapore $19.44 $36.06 South Korea $13.26 $181.52 Thailand $6.70 $345.16

In Australia there has been interest and debate on these issues for the past several years. One of the more recent debates included a Parliamentary Committee. The outcome was published in a report called: Parliamentary Joint Committee on Law Enforcement, Spectrum for public safety mobile broadband, July 2013.

Information about the Committee’s hearings, including the terms of reference, the submissions received and the report, is available at: http://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Law_Enforcement/Completed_inquiries/2010-13/spectrummobilebroadband/index

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1.1 On 28 May 2013, the Parliamentary Joint Committee on Law Enforcement (the committee) self-referred an inquiry into spectrum for public safety mobile broadband. The terms of reference are as follows: Pursuant to the committee's functions set out in subsection 7(1)(e) of the Parliamentary Joint Committee on Law Enforcement Act 2010, the committee will inquire into and report on: (a) how much broadband spectrum law enforcement agencies need to be able to communicate safely and effectively during mission-critical events such as natural disasters and potential terrorist incidents; (b) which of the 700 or 800 megahertz (MHz) bands is the most appropriate for law enforcement agencies given the current licensees occupying spectrum; (c) how the necessary spectrum for public safety should be secured in a timely manner; (d) 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; and (e) what applications dependent on broadband spectrum will contribute significantly to saving lives and property. Excerpt from the report of the Parliamentary Joint Committee on Law Enforcement, Spectrum for public safety mobile broadband, July 2013

The Australian Parliamentary Joint Committee (PJC) made five recommendations the first of which was as follows:

“Recommendation 1

5.39 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 [10 + 10 MHz] of contiguous spectrum in the 700 MHz band for the purposes of a public safety mobile broadband network.”

In which band should the spectrum be allocated?

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Motorola has advised the ACMA on many occasions that there is little, if any, technical difference between the 700 MHz and 800 MHz bands when looking at broadband system performance.

The relative advantage of one over the other only becomes apparent when considering equipment choice and pricing. The more widely used band will attract more manufactures and hence have greater equipment choice, increased competition and lower equipment prices.

An allocation in the 700 MHz band (the APT band), as recommended by the PJC (above), is the most suitable in terms of spectrum availability, equipment availability and pricing in terms of equipment and the opportunity cost of the spectrum. Sufficient unallocated spectrum is available in this band. 15 + 15 MHz of spectrum was not sold at the Digital Dividend auction conducted earlier this year. Equipment for this band will be produced for most countries in the Asia Pacific region. In other PPDR broadband spectrum segments proposed for Australia the equipment is likely to be produced by fewer manufactures and in smaller quantities. Consequently equipment choice is expected to be more limited and it is likely to be more expensive than equipment produced for the 700 MHz APT band (IMT band 28).

In a further boost to the dominance of the 700 MHz band for PPDR LTE systems it was recently announced that Brazilian public safety, national defence and infrastructure would be allocated spectrum in this band. Significantly, in a departure from the common South American practice of adopting US spectrum planning arrangements, the announcement stated that the APT 700 MHz band (IMT band 28) would be used.

The original Portuguese language announcement can be read at: http://telesintese.com.br/index.php/plantao/24644-seguranca-publica-tambem-vai-ganhar-espectro-de-700-mhz

Soon after this announcement the ORGANIZACION DE LOS ESTADOS AMERICANOS ORGANIZATION OF AMERICAN STATES (CITEL) recommended to its member states across North, Central and South America that PPDR broadband spectrum allocations be made from the 700 MHz band. The recommended bands included the APT 700 MHz band (IMT band 28) and the US band (IMT band 14).

The CITEL document making the recommendations was:

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The recommendation section was:

If spectrum is to be allocated to the PSA’s in the less favourable 800 MHz band, 10 + 10 MHz should be allocated at the lower end of IMT band 26. The allocated segment should be 814-824 MHz paired with 859-869 MHz. There are no users in the segment from 814-820 MHz which is currently being cleared of broadcast television transmitters as a part of the digital dividend project and the ACMA has already indicated in its recent 800 MHz discussion papers that the segment from 820-825 MHz, which is currently allocated to land mobile services may be reallocated. Other segments in this band are already occupied by commercial IMT services.

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If spectrum is to be allocated to PSA’s in the 800 MHz band it should not be allocated at the lower end of the band. The lower end of the 800 MHz band (between 807 MHz and 814 MHz) is designated as part of IMT band 27. The 3GPP designed, specified and designated band 27 for use in one country in South America and its technical specifications do not take into consideration the use of LTE in the top portion of the 700 MHz band. A 10+10 MHz LTE allocation at the lower end of the 800 MHz band is expected to cause interference issues with the top end of the APT 700 MHz band. It is worthwhile noting that in the recent 700 MHz auctions, the upper part of APT 700 MHz band was not sold. Studies submitted to the Asia Pacific Telecommunity (APT) have shown that a minimum separation of about 10 MHz is needed between the upper end of 700 MHz APT band (IMT band 28) and the lower edge of 800 MHz band (IMT band 27) when LTE is deployed in both bands.

In many countries across the Asia Pacific region the lower part of the 800 MHz band (below 824 MHz) is extensively used for narrow and wide band voice and data communications. PPDR agencies throughout the area are well established users of this band. This will restrict the Asia Pacific deployment of LTE equipment in this band segment.

Why commercial networks cannot meet public-safety requirements

Commercial networks and systems such as those operated by carriers (in Australia and internationally) are not suitable for PSA use during Public Protection and Disaster Relief (PPDR) operations. Commercial systems and PPDR systems are different. They are each designed to provide for very different grades of capacity and reliability.

Commercial network availability.

Every user of a commercial carrier grade network knows there are times when the network is congested or unavailable – examples include: Christmas Day, New Year’s Eve, extreme weather, natural and man-made disasters – and there are times when simple text messaging and data transfers are delivered very slowly.

During these periods of network unavailability the causes can be many and varied. The number of people trying to make calls or send data, damage to network sites,

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the availability of power and backup power or fuel for generators all contribute to the widely experienced commercial network failures.

It is also during many of these same scenarios that the public requires additional support from the PPDR agencies.

PPDR networks are designed to better cope with these situations. PPDR networks require sufficient dedicated spectrum to better cope with the extraordinarily high levels of traffic generated by these situations.

Recent examples of commercial network failures caused by emergency situations include: the earthquakes in Christchurch, New Zealand, the Boston Marathon, the Brisbane floods the Burnley Tunnel crash in Victoria and the fire at the communications hub in Victoria’s West. These all serve as examples of commercial network failures exacerbated because of the way the networks (wireless or wired) were designed. In most of these situations the amount of traffic generated by the users was more than the respective systems could cope with during the period of restricted service availability. Networks were either overloaded or not available at all. These were also the very times when the public needed assistance from PPDR agencies. Public access was delayed and contact with family, friends, emergency services and businesses was difficult or impossible. When commercial networks are adversely impacted in these situations public-safety agencies have no control over service restoration. Terrorist, or suspected terrorist incidents also bring with them the added possibility of commercial network closures for security reasons.

Emergencies and natural disasters are the times when public-safety agencies most need the ability to communicate and to share large amount of data including live streaming video from incident and disaster areas.

PPDR networks are designed to better cope with these scenarios.

Public-safety User Prioritization and Application Quality of Service.

If PSA agencies were required to share commercial networks during PPDR emergencies, the limited communications made available to the everyday users would, by definition, be further limited.

There are approximately 150,000 public-safety users in Australia compared to about 23 million commercial cellular devices/users. During emergency situations there will

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be broadband network access contention between public-safety users and the commercial cellular devices/users. An emergency is no time to find out you cannot get your mission critical data to your front line responders. Public-safety users need dynamic user prioritisation, pre-emption, and quality of service (QoS) guarantees for their users and applications. Dynamic user prioritisation and pre-emption will ensure that the appropriate public-safety officers/users will get access to the broadband network under any network load so that they can get their data/video through the network. QoS settings in a network provides the ability for the network to enforce different service priorities for different application types, users or data sessions, whilst guaranteeing a certain level of performance to a data session. QoS classes ensure that networks can prioritise certain types of data for immediate and secure delivery. This is an extremely important feature and one which has a major impact on agency operations. Without a QoS implementation on a loaded network, users will experience choppy videos and delays for time-sensitive data. The circumstances of a disaster dramatically determine the requirements for public-safety agencies that need information. Where, when, what type of data is dependent on their specialised needs and timing. To meet the level of service expected of them public-safety agencies need to be able to guarantee to their teams that they will be able to access the vital information needed to protect the public and themselves with the same level of confidence that they have today for the mission critical voice networks. They can do this with private public-safety broadband network access. Commercial cellular networks are designed for more for downlink data usage. Public-safety agencies put more strain on uplink due to their need to share information, particularly during the initial phases of a crisis.

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Wireless access services (WAS)

WAS spectrum demand is increasing globally. This is an indisputable fact. There is a continuous push within Australia and internationally for additional WAS spectrum in existing bands and for the inclusion of new bands.

The growing demands from existing and new users of WAS spectrum to facilitate access to more data with faster transfer speeds will continue.

Australia’s public safety agencies, like those of other nations, also need access to WAS spectrum to facilitate the transfer of data between officers in the field and their command and control centres. The data required in the field and at the command and control centres includes information like video services, data dispatch functions, location and mapping, incident and status reporting, records & database lookups, access to manuals, building plans, image downloads, tactical video from select vehicles, personnel, and hot zone asset deployment. This type of data transfer in emergency situations requires dedicated access to WAS spectrum. Advanced nations, like Australia, are moving towards satisfying this requirement.

For many years international consultants and government committees have been gathering and studying evidence in an effort to determine how much spectrum should be allocated to PSA’s and in which WAS bands.

As pointed out by the ACMA in the Five-year spectrum outlook 2013-2017 ...

A total of 890 MHz of spectrum is allocated, or planned to be allocated, to WAS services in Australia, though not available in all regions and the spectrum used is limited to below 4 GHz. Frequency bands up to 4 GHz are in high demand for WAS applications because they offer advantages that cannot be achieved at higher frequencies such as coverage, power and form factor.

From this allocation of 890 MHz of WAS spectrum Australia’s PSA’s require 20 MHz (10 + 10 MHz) to meet their needs for data transfer capabilities between in the field officers and their command and control centres. See the Spectrum for public safety agencies section of the document for details.

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To take advantage of the internationally available equipment and to provide for coverage, power and form factor the PSA’s should ideally be allocated their spectrum from the un-allocated 30 MHz (15 + 15 MHz) which is available in the 694–803 MHz band segment. The spectrum at the upper end of this segment did not attract any bidders in the Digital Dividend spectrum auction held earlier this year and remains unsold.

From: Five-year spectrum outlook 2013-2017, Table 5.5 Spectrum bands that provide for WAS services

Band Spectrum Type Current usage 694–820 MHz

2 x 45 MHz

Spectrum licence

Analog/digital TV to be cleared to realise digital dividend

Allocation of PSA spectrum from the un-sold 700 MHz portions of the 694-803 MHz Digital Dividend band would fulfil recommendation one (1) of the Parliamentary Joint Committee on Law Enforcement, Spectrum for public safety mobile broadband.

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Table of abbreviations and terms

Abbreviation or term Meaning 3GPP 3rd Generation Partnership Project ACMA Australian Communications and Media Authority DL Down link (from base station transmitters) DoD Department of Defence IMT International Mobile Telecommunications ITU International Telecommunication Union kHz kilohertz LTE Long Term Evolution (3GPP system) MHz Megahertz PJC Parliamentary Joint Committee PPDR Public Protection and Disaster Relief PSA Public safety agency PSMB Public safety mobile broadband QoS Quality of service TDMA Time division multiple access UL Up link (to base station receivers)

End of response