WHEREAS Industry Canada proposes to provide private users access to 150 MHz bandwidth as shown in their Notice Reference Number : DGTP-004-05; andWHEREAS the bandwidth from 151.820 MHz to 154.600 MHz is used in Canada almost exclusively by the fire service, and the vast majority of the over 400 fire departments in Alberta are using this bandwidth; andWHEREAS the bandwidth has the capability of penetrating through building walls and through glass, thus the 150 MHz bandwidth serves as an ideal way for firefighters to communicate when they have entered burning structures to save lives; andWHEREAS for years the 150 MHz bandwidth has been set aside for emergency communications within defined and quite small geographical areas and in fact, only five years ago Industry Canada encouraged the fire service to migrate to that location in addition to reducing the split available from 24 kHz to 12 kHz within the 150 MHz bandwidth; andWHEREAS to no purpose that the five 150 MHz bandwidths be opened to multi-use radio service (MURS) will create significant hardship to fire services across Canada; andWHEREAS Industry Canada’s rationalization that “Canadians are large consumers of electronic devices and radio technologies and want similar radio products as those available in the U.S. market” is very alarming, suggesting that consumer interests of this nature take precedence over public safety and reflects a very narrow focus, one that does not even consider the ramifications of such a change on fire departments, firefighters and the safety of Canadians; andWHEREAS this resolution was endorsed by the Alberta Fire Chiefs Association;

THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties write the Honorable Maxime Bernier, Minister of Industry Canada, strongly recommending that Industry Canada discontinue its attempt to force Canadian fire departments to abandon their 150 MHz bandwidths, identifying concerns over the costs involved, the limited proposed transition period, and the concern for the potential increased risks to firefighters, increased potential losses, and ultimately the safety of those who we are trying to help.

There are recreation/commercial (unlicensed) portable radios being sold in the US on several frequencies within the 150MGz band interleaved with (or overlapping) Canadian public safety users. IC has sent letters to several VFDs in Nova Scotia with radios licensed on or near the affected frequencies basically telling them that they will likely be negatively impacted by these radios when (no if) IC allows them to be sold in Canada. The real bone of contention is that the licensed public safety user is expected to move to another frequency, which IC will generously make efforts to accommodate. There are over 1500 licensed mobile and base radios affected in the Atlantic region which means there are at least double that number of portable radios affected and even more pagers receiving VFD notifications on those frequencies. In a letter to Reeve Myler Savill of the Municipal District of Big Lakes, Maxime Bernier of the Ministry of Industry writes in part:- Several departmental representatives met with members of the Canadian Association of Fire Chiefs in a series of meetings held in Ottawa on April 25 and 25, 2006. These meetings provided the opportunity to discuss the CAFC’s concerns and achieve a great mutual understanding of the proposals being made at 150 MHz. Although the 150 MHz band is not exclusively public safety spectrum, CAFC members were fully apprised of the department’s upcoming initiatives to open significant amount of exclusive public safety spectrum at 700 MHz and at 4.9 GHz.Departmental officials are currently reviewing comments on this spectrum policy consultation -From Proposals and Changes to the Spectrum in Certain Bands Below 1.7 GHz DGTP-004-05: (available online at http://strategis.ic.gc.ca/epic/internet/insmt-gst.nsf/vwapj/dgtp-004-05-e.pdf)6. Multi-use radios in the 150 MHz Band Multi-use radio Service (MURS) devices have been available in the U.S. to provide consumer and business two-way, short-distance voice and data communications. 6.1 Discussion MURS devices have been permitted since 2002 to operate using five VHF frequencies known by users as the VHF ‘colour dot’ frequencies. These frequencies are 151.820 MHz, 151.880 MHz, 151.940 MHz, 154.570 MHz and 154.600 MHz. MURS are premitted to emit no more than 2 watts maximum transmitter output. MURS may operate in an authorized bandwidth of 11.25 kHz (on frequencies 151.820 MHz, 151.880 MHz, and 151.940 MHz) and of 20.0 kHz (on 154.570 and 154.600 MHz). MURS are stand-alone consumer/business devices and as such are not permitted to interconnect to the public switched telephone network, may not have an antenna that can be modified and cannot be operated in continuous carrier mode. In Canada, many commercial/industrial mobile and public safety licensees are authorized on these five frequencies. A large number of these frequencies are licensed on a private/commercial basis. The remaining users are made up of government (i.e. municipal, provincial or federal government) and public safety (i.e. police, fire and ambulance). It is expected that the operation of MURS devices will cause, in certain situations, harmful interference to land mobile use. Also, operation of MURS devices could, in certain situations cause interference to users on adjacent land mobile frequencies, as set out in the suballocation channelling plan in Standard Radio System Plan 500, Technical Requirements for Land Mobile and Fixed Radio Services Operating in the Bands 138-144 MHz and 148-174 MHz (SRSP-500). Table 2 below estimates the number of stations that could be affected by MURS operation. Table 2 – Number of Stations by Region Using the Five MURS Frequencies Base Mobile Total Atlantic 164 1344 1508Quebec 113 2577 2690Ontario 238 5756 5994Prairie & Northern 368 10112 10480Pacific 148 8177 8325Five frequencies are used by MURS. Some of these frequencies include those for government operations, public safety and commercial/industrial operations. It is noted that some stations are authorized on a province-wide basis. The Department is of the view that MURS use could significantly affect both existing radio stations on the five MURS frequencies and on adjacent frequencies. For MURS frequencies in the 151 MHz range, the U.S. permits an 11.25 kHz authorized bandwidth with 12.5 kHz channel spacing. Canada follows a 30/15/7.5 kHz channel plan, so this could have a potential impact on one 15 kHz channel and three 7.5 kHz channels for each MURS frequency. For the two MURS frequencies in the 154 MHz range, the U.S. permits a 20 kHz authorized bandwidth with 25 kHz channel spacing. Again, in Canada a 30/15/7.5 kHz channel plan is followed and a number of 30/15 and 7.5 kHz channels could be affected depending on the licensee and the equipment used. Table 3 illustrates the 5 frequencies and adjacent frequencies that could be potentially affected by permitting MURS in Canada. Table 3 – Adjacent Channels Potentially Affected by MURS Frequency (MHz) Bandwidth (kHz) Affected Frequencies MURS Channel 30 kHz (7.5) 15 kHz (7.5) 7.5 kHz (3.75) Frequency (MHz) 151.820 NA NA C1287 151.8125 NA B643 C1288 151.8200 NA NA C1289 151.8275 151.880 (11.25 kHz) NA NA C1295 151.8725 NA B647 C1296 151.8800 NA NA C1297 151.8875 151.940 (11.25 kHz) NA NA C1303 151.9325 NA B651 C1304 151.9400 NA NA C1305 151.9475 154.570 (20 kHz) NA NA C1653 154.5575 A414 B826 C1654 154.5650 NA NA C1655 154.5725 NA B827 C1656 154.5800 NA NA C1657 154.5875 154.600(20 kHz) A415 B828 C1658 154.5950 NA NA C1659 154.6025 NA NA C1660 154.6125 A416 NA NA 154.6200 NA – Not applicable 6.2 Considerations Canadians are large consumers of electronic devices and radio technologies and want similar radio products as those available in the U.S. market. In the past, the Department has moved quickly to provide access to family radio and general mobile radio devices in response to industry-led programs to accommodate incumbent radio users in the affected bands. The Department opened the market for new consumer radio devices over a short transition period for incumbents with the full participation of the distributors/manufacturers. This has greatly assisted the Department in countering the importation of illegal radio devices. In this spectrum policy initiative and in recent policies, the Department has taken specific steps to free up spectrum below 1.0 GHz to meet the demands of mobile and fixed services. For example, new mobile spectrum is being designated in the bands 216-220 MHz, 220-222 MHz and in unused spectrum around 900 MHz. Also, the spectrum redeployment plan for bands in the 150 MHz and 450 MHz ranges, in a post 2006/2007 time frame, will free up new frequencies. This will be due to the Phase II (of the plan) efficiencies for narrow band radio equipment of 7.5kHz and 6.25 kHz channel bandwidths. These spectrum policies will also help provide alternative frequencies and a migration for currently licensed radio users in the band 150 MHz, who may need to be accommodated in order to permit the sale and distribution of MURS products in Canada. However, given the large number of licensed users that could potentially be affected in the MURS frequencies, the Department must develop a longer transition plan before potentially opening the Canadian market to MURS devices. 6.3 Proposed Transition Plan to Permit MURS The Department is of the view that establishing a long transition period for licensed incumbents before permitting the sale and distribution of MURS devices for consumers is a reasonable approach. Therefore, in accordance with Spectrum Utilization Policy Gen, General Information Related to Spectrum Utilization and Radio Systems Policies (SP-Gen), a five-year transition period from the issuance of the spectrum policy is proposed. Notification would be provided to licensed incumbents at the start of the transition period (Year 0) and two years before the end of the transition period (starting at Year 4). In this regard the Department proposes for the frequency bands 151.820 MHz, 151.880 MHz, 151.940 MHz, 154.570 MHz, 154.600 MHz and in affected adjacent spectrum that: (i) a five-year transition period be established after a spectrum policy is released to permit the distribution and sale of MURS devices; (ii) all licensees be served formal notification letters on the publication date of the spectrum policy (Year 0) and two years before the end of the transition period (starting at Year 4); (iii) the Department will seek to accommodate affected licensees that wish to move in other frequency bands; and (iv) incumbent licensees electing to stay in these frequencies could do so on a secondary basis, but may be subjected to interference from the operation of MURS devices and would have to accept such interference. A moratorium The Department invites comment on this proposed transition plan to permit the distribution, sale and use of MURS devices in Canada.

The AAMDC has no resolutions currently in effect with respect to this issue.However, resolution 8-06S regarding support for the commercial vehicle inspection program urges the AAMDC to support the initiative of the Alberta Fire Chiefs Association with Alberta Infrastructure and Transportation to permit vehicle inspection extensions to three (3) years for emergency vehicles.The allocation of bandwidths for radios is exclusively the responsibility of the federal government. Proposed changes to the 150 MHz band are a result of the increased sales and use in North America of multi-use radio service (MURS).The federal government has indicated that only five bandwidths (151.820 MHz, 151.880 MHz, 151.940 MHz, 154.570 MHz, 154.600 MHz) were being considered within the 150 MHz spectrum, and not the entire spectrum.The Alberta Fire Commissioner’s Office, a branch of Alberta Municipal Affairs and Housing, has been in consultation with fire departments and municipalities that may be impacted by the proposed changes.Alberta Municipal Affairs and Housing has previously conducted research on this subject on behalf of the Fire Services Advisory Committee. Further research indicated that expansion into the identified bandwidths would have almost no impact on municipal fire service operations, as only three fire departments in the province (all located in Clearwater County) use frequencies that could experience interference. The Fire Commissioner’s Office contacted county officials to inform them about the situation and offer assistance, but no requests for assistance from the county have been received.The bandwidth expansion could affect 134 licences used by Alberta Sustainable Resource Development (SRD) for province-wide firebases. SRD staff have been advised about the potential impact that the bandwidth expansion could have on their ministry’s operations.We thank the AAMDC for raising awareness about this issue. Further information about the proposed changes can be obtained by contacting Industry Canada’s Spectrum Management and Telecommunications at http://strategis.ic.gc.ca/epic/site/smt-gst.nsf/en/Home.The AAMDC has no resolutions currently in effect with respect to this issue.However, resolution 8-06S regarding support for the commercial vehicle inspection program urges the AAMDC to support the initiative of the Alberta Fire Chiefs Association with Alberta Infrastructure and Transportation to permit vehicle inspection extensions to three (3) years for emergency vehicles.

The Government of Alberta has undertaken the development of a shared radio network, the Alberta First Responders Radio Communication System (AFRRCS). AFRRCS will replace the existing Government of Alberta and RCMP province-wide radio communications systems by 2014. A contractor should be chosen in the summer of 2009 and development will continue from there. Municipalities will have the option of participating in the radio system. The AAMDC will continue to work to ensure costs for municipalities are manageable level.