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ENA submission—Industry wide position on the spectrum needs of smart electricity networks 13 July 2011

ENA submission—Industry wide position on the …/media/Spectrum Transformation and... · Dedicated utility grade vs commercial carrier networks 22 ... A report prepared for ENA

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ENA submission—Industry wide position on the spectrum needs of smart electricity networks 13 July 2011

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

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Contents

1. 4 Executive Summary

2. 6 Introduction

The ENA 6

ENA members represented by this submission 6

Purpose of submission 6

Submission preparation 7

Structure of submission 7

Previous submissions by ENA and ENA members 7

3. 8 Smart electricity networks

What is a smart electricity network? 8

Objectives of a smart electricity network 9

National Strategy for Smart Electricity Networks 10

4. 11 Communications requirements of smart electricity networks

Functional communications requirements 11

Critical functional requirements 12

Highly important functional requirements 12

Regular functional requirements 15

Communications network architecture 16

5. 19 Communications technology options

Wireless technologies 19

Technology standards 21

Dedicated utility grade vs commercial carrier networks 22

6. 24 Spectrum needs of smart electricity networks

Need for harmonised spectrum 24

Suitable spectrum options 25

Spectrum bandwidth requirements 27

Licence tenure 28

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

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ENA industry-wide multi-band spectrum strategy 28

7. 29 Spectrum allocation

Public benefits of smart electricity networks 30

8. 33 Spectrum for national smart infrastructure

9. 34 Conclusion and recommendations

Attachment A 35

ENA, National Strategy for Smart Electricity Networks 35

Attachment B 36

Assessment of spectrum bands 36

Attachment C 41

Smart Grid Bandwidth Requirements, A report prepared for ENA by Ericsson 41

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

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1. Executive Summary This submission presents the case for the allocation of radiofrequency spectrum to electricity distribution businesses so they can deploy their own wireless communications networks to underpin smart electricity networks, which will deliver significant benefits to the Australian community, economy and the environment.

Electricity businesses around the world are facing a challenge—to supply increasing amounts of electricity while meeting community and government calls for more reliable, environmentally-sustainable and affordable energy supplies. Electricity distribution businesses are meeting these challenges by changing the way they operate and gradually modernising their networks with smarter technologies—in essence integrating information and communications technologies (ICT) into existing electricity network infrastructure and business systems to create a smart electricity network (or smart grid). This will enable distribution businesses to perform a range of highly important new network functions such as improved network and demand management, distribution monitoring, control and automation; the integration of renewable and distributed electricity supplies, energy storage and electric vehicles; and to provide field staff with access to network and outage managements systems, which is crucial during times of network failure (such as natural disasters).

The Energy Network Association and its members consider that the main objectives of smart electricity networks are to: improve the cost-effectiveness of network operations and investments, provide a platform for improved customer service offerings, improve the reliability, quality and security of electricity supplies, and facilitate reductions in carbon dioxide emissions.

Smart electricity networks will require fit-for-purpose, dedicated, utility grade communications networks that are ubiquitous, secure, reliable, cost-effective and interoperable. Commercial carrier networks are generally unsuitable for a number of reasons including limitations in coverage, availability, latency and security especially during times of network failures (such as natural disasters) when electricity distribution businesses need to rely on their communications systems the most. These are the very times when commercial grade communications services and equipment are likely to fail, which makes it difficult and takes longer for the distribution business to restore power supplies. The inadequacy of commercial carrier networks in natural disaster and emergency situations has also been raised by other organisations, for example in the recent Senate Inquiry into the capacity of communications networks and emergency warnings to deal with emergencies and natural disasters.1 In addition, experience has shown that commercial carrier networks are generally cost prohibitive as a widespread communications solution underpinning the deployment of smart network devices.

Given that commercial carriers have been unable to deliver services that meet the industry’s service level and cost requirements, electricity distribution businesses are pursuing the option of building and operating their own wireless communications networks and hence require radio frequency spectrum.

While each electricity distribution business is at a different stage of determining their own communications needs, it is clear that there is no one communications technology that is suitable for all functions or in all service areas. The industry is, however, committed to developing a harmonised approach to their spectrum needs for smart electricity networks to ensure efficient spectrum usage and efficient investments in communications networks. The industry has developed a multi-band strategy that reflects:

the need for paired spectrum that supports a migration to LTE technologies

1 For example, see the submission by the Police Federation of Australia to the Senate Standing Committee on Communications and Environment inquiry into the capacity of communications networks and emergency warnings to deal with emergencies and natural disasters, http://www.pfa.org.au/files/uploads/PFA_Submission_Emergency_Communications_0.pdf

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

the need for unpaired spectrum that supports mesh radio technologies

the spectrum bands that are increasingly being used or considered for smart grid deployments internationally, which will deliver cost efficiencies through access to standardised and future proof technologies and equipment. This is particularly important given that Australia is a small market and therefore generally a technology and standards taker, and

the fact that some distribution businesses have deployed/ are planning to deploy mesh radio or WiMAX communications networks and hence migration to dedicated utility bands may not occur until the end of these asset’s lives.

The ENA urges the Australian Communications and Media Authority (ACMA) and the Department of Broadband Communications and the Digital Economy (DBCDE) to recognise the significant public benefits of smart electricity networks, through the allocation of the following spectrum for these purposes:

5-10 MHz of paired spectrum in the 700 MHz–900 MHz band in rural areas, to support a migration to LTE technology

8-15 MHz of paired spectrum in the 1800 MHz band in urban areas, to support a migration to LTE technology, and

Continued access to the 915 – 928 MHz band in accordance with the Radiocommunications (Low Interference Potential Devices) Class Licences 2000 (the LIPD Class Licence) for the entire asset life of current and planned mesh radio investments (approximately 15 years from the completion of deployment); with a longer term transition to a dedicated unpaired band of similar bandwidth to support mesh radio technologies.

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2. Introduction

The ENA

The Energy Networks Association (ENA) is the peak national body for Australia’s energy networks. ENA represents electricity distribution and transmission network businesses and gas distribution network businesses on economic, technical and safety regulation and energy policy issues.

Energy network businesses deliver electricity and gas to over 13 million customer connections across Australia through approximately 48 000 kilometres of electricity transmission lines, 800 000 kilometres of electricity distribution lines and 80 000 kilometres of gas distribution pipelines. These network assets are valued at more than $70 billion and energy network businesses are planning to undertake investment of approximately $38 billion over the next 5 years, in part to replace aging assets and meet growing demand.

ENA members represented by this submission

Given the high importance of securing radio spectrum to support the electricity distribution businesses’ wireless broadband communications needs, the following electricity distribution members of ENA formed the Smart Networks Communications Working Group, which has developed this industry-wide position on the spectrum needs of smart electricity networks:

ActewAGL

Aurora Energy

CitiPower/ Powercor

Essential Energy (formerly Country Energy)

Energex

Ausgrid (formerly EnergyAustralia)

Ergon Energy

ETSA Utilities

Endeavour Energy (formerly Integral Energy)

Jemena

SP AusNet, and

WesternPower.

Purpose of submission

Electricity distribution businesses have a growing need for radiofrequency spectrum for the wireless broadband communications systems that will underpin their smart electricity networks. Given the current and impending review processes for various radio frequency spectrum bands, including the reallocation of digital dividend spectrum and the renewal of spectrum licences in the next few years, the ENA considered it important to advise the ACMA and DBCDE of the future spectrum needs of smart electricity networks.

The ENA and its members have developed this industry-wide submission, which sets out the functional, technological and spectrum requirements of smart electricity networks, evaluates various spectrum options and presents a multi-band strategy to meet the industry’s spectrum needs. The ENA looks forward to

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

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discussing this submission with both the ACMA and DBCDE and working together to address the industry’s requirements.

Submission preparation

In late 2010, ENA undertook a survey of its electricity distribution members to ascertain the functional, technological and spectrum requirements of the communications networks that will underpin their future smart electricity networks.

ENA engaged Gibson Quai-AAS Pty Ltd to compile the results of the survey into a list of the common functional and technological requirements of smart electricity networks. Gibson Quai-AAS also undertook an evaluation of the suitability of various spectrum options that could meet these requirements.

ENA engaged Ericsson to undertake modelling to determine the indicative spectrum bandwidth required in both rural and urban areas.

In preparing this submission, ENA has drawn on the work undertaken by Gibson Quai-AAS, Ericsson and the ENA Smart Networks Communications Working Group.

Structure of submission

This submission presents:

a consolidated view of the distribution businesses’ functional communications requirements

an analysis of the communications technologies that could support these requirements

an evaluation of the suitable spectrum bands

results from modelling that provides an indication of the spectrum bandwidth required in both rural and urban areas

a multi-band spectrum strategy that reflects the different communications needs of the various electricity network businesses, and

an overview of some of the public benefits of smart electricity networks.

Previous submissions by ENA and ENA members

On behalf of the electricity distribution businesses listed above, the ENA has previously lodged submissions with the ACMA in response to the following reviews:

Spectrum reallocation in the 700 MHz digital dividend band (17 December 2010)

Spectrum for national smart infrastructure (17 December 2010), and

The 900 MHz band – exploring new opportunities (24 June 2011).

As indicated at the time, these earlier submissions were a preliminary position, with this current submission providing more comprehensive information and a final position.

In addition to the ENA’s submissions, several of ENA’s members have, from time to time, provided individual responses to ACMA and DBCDE discussion papers. The recommendations in these previous submissions reflected individual company requirements at that time, which have now been replaced by this industry wide submission.

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3. Smart electricity networks Electricity businesses around the world are facing a challenge—to supply increasing amounts of electricity while meeting community and government calls for more reliable, environmentally-sustainable and affordable energy supplies. The demand for increasing supplies of electricity is primarily driven by a growing population, combined with lifestyle choices to live in larger houses with fewer residents and an increasing number of appliances. In particular, the level of peak demand (the maximum demanded at any given time) is growing significantly and, in some areas, already exceeds the capacity of the electricity network for a few short periods each year.

More specifically, the challenges faced by electricity network businesses include the need to:

meet growing energy demand, especially at peak times

improve the reliability and quality of electricity supplies

ensure the electricity network is secure against threats such as terrorism or natural disasters

moderate electricity cost increases and address equity issues

respond and adapt to climate change

facilitate a reduction in carbon emissions

manage and respond to the increased risk of faults/outages from higher temperatures, storm activity and bushfires

integrate increasing amounts of renewable and distributed electricity generation into the electricity network, while ensuring that reliability and power quality are not adversely affected

integrate energy storage and electric vehicles into the electricity network

replace ageing electricity network assets, and

deliver electricity in a more efficient and cost effective manner.

Electricity network (poles and wires) businesses are meeting these challenges by changing the way they operate and gradually modernising their networks with smarter technologies—in essence integrating information and communications technologies (ICT) into existing electricity network infrastructure and business systems to create a smart electricity network (or smart grid).

Smart networks will give electricity distribution businesses a better understanding and control of power flows within their networks, allowing them to automatically detect and repair faults, re-route power flows and undertake a more targeted response to avoid or reduce power disruptions to customers.

The associated changes in the functionality of electricity networks provide the opportunity for electricity distribution businesses of the future to enable the provision of a greater range of services than in the past. In addition to delivering an ‘essential service’, smart electricity networks will be an enabler of a range of other products and services that will benefit customers, the Australian community and the environment. These include customers’ energy management systems, renewable energy supplies, electric vehicles and energy storage technologies.

What is a smart electricity network?

The technologies, devices and systems that make up a smart network will vary across electricity distribution businesses, just as existing electricity networks vary according to the geographic, climatic, ownership and business parameters that the businesses operate within. Examples of smart network components include:

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integrated communications infrastructure that enables near real-time, two-way exchanges of information and power

advanced measurement devices (including advanced metering infrastructure (AMI)) that record and communicate more detailed information about energy usage and power quality

sensors and monitoring systems throughout the network that keep a check on the flow of energy in the system and the performance of network assets

automatic controls that detect and repair network problems and provide self-healing solutions

advanced switches and cables that improve network performance, and

IT systems with integrated applications and data analysis.

There are a range of other technologies, devices and applications that are enabled by smart networks. These include customers’ energy management systems, renewable energy supplies, electric vehicles and energy storage technologies.

Objectives of a smart electricity network

The National Electricity Market is guided by the overarching National Electricity Objective, which is to ‘promote efficient investment in, and efficient operation and use of, electricity services for the long-term interests of customers of electricity with respect to:

price, quality, safety, reliability, and security of supply of electricity, and

the reliability, safety and security of the national electricity system’.

This objective is intended to ensure the efficient operation of the National Electricity Market, efficient investment, and the effective regulation of electricity networks.

The objectives of smart networks are consistent with the National Electricity Objective, however they also focus on the facilitation of improved environmental and customer choice outcomes.

As indicated, there are several challenges that can be met through smart network investments. However, ENA and its members consider that, ultimately, the objectives of smart networks can be distilled into four categories. These are to:

1. Improve the cost-effectiveness of network operations and investments

The addition of smart technologies such as sensors, monitoring devices and information technologies into the existing electricity distribution network can improve the utilisation of existing network assets by deploying a least cost model incorporating optimum supply and demand-side initiatives. In addition, smart networks can improve the overall cost-effectiveness of network operations. These changes can contribute to more efficient long term investment decisions and will help moderate future price increases.

2. Create a platform for customer choice

Smart electricity networks will provide the technology platforms to enable improved customer service offerings, allowing customers to make more informed choices regarding the amount of electricity they consume, when they consume it and the environmental and financial impacts of their decision.

In the long term, smart networks will facilitate the convergence of other services currently being provided to customers, and the delivery of services through a single technology platform, which has the potential to further reduce the overall costs to the customer and the economy.

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3. Improve the reliability, quality and security of electricity supplies

Smart electricity networks can benefit customers through meeting their 21st century lifestyle and economic expectations around reliability, quality and security of energy supplies. This can be achieved through the integration of new technologies and dynamic information into conventional electricity supply systems, in order to achieve a reduction in the number and duration of power interruptions, power dips or power surges and a reduction in the number of customers that are affected by these events. Electricity distribution businesses will have the ability to manage and respond to increased risks of faults and outages that result from higher temperatures, storm activity and bushfires; as well as more effectively manage the network to avoid stress on assets at peak times. Smart electricity networks will also improve the distribution network businesses’ ability to protect their networks from threats such as terrorism or natural disasters.

4. Facilitate a reduction in carbon emissions

Smart electricity networks can play an important role in facilitating the shift to a low carbon economy. This can occur through the integration of widely distributed and renewable energy sources, energy storage technologies and electric vehicles into the distribution network; the management of network losses; and enabling the development of tools that allow customers to make decisions that potentially reduce the environmental impact of their electricity consumption.

National Strategy for Smart Electricity Networks

Attachment A contains the ENA’s National Strategy for Smart Electricity Networks, which provides a more detailed explanation of the drivers, objectives and components of smart electricity networks, as well as the priority areas of action for the ENA and electricity distribution businesses. The ENA’s National Strategy for Smart Electricity Networks should be read in conjunction with this submission.

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4. Communications requirements of smart electricity networks

Common across all the elements of a smart electricity network is a requirement for:

millions of sensors and intelligent electronic devices (IED) throughout the electricity network, and

a two-way broadband communications network that is ubiquitous, secure, reliable, cost-effective and interoperable.

Machine-to-machine (M2M) communications is a fundamental component of smart electricity networks, enabling the collection and distribution of data between terminal devices and their respective management and control systems.

The nature of M2M communication traffic is very different to the normal traffic generated in traditional telecommunications networks, as it consists of both infrequent large data transfers, and frequent small data transfers. This places loads on the data transport networks that are quite different to those generated in traditional telecommunication networks, and requires careful analysis and design to accommodate.

Each electricity distribution business is at a different stage of determining its communications needs in terms of both network architecture and suitable technologies. This decision will be primarily driven by the distribution business’s functional requirements, which incorporate traditional functions, such as SCADA and asset protection, through to new smart network functions. These include improved network and demand management, distribution monitoring, control and automation, the integration of renewable and distributed electricity supplies, energy storage and electric vehicles; and providing field staff with access to network and outage managements systems, which is crucial during times of network failure (such as natural disasters). Each of these functions has varying service level and bandwidth requirements.

Both the network architecture and technologies selected by each distribution business will also reflect the geographic, population density and business parameters that each business operates within.

While assessments and trials of the various options are underway, it is evident that electricity distribution businesses will generally require a vertically and horizontally layered communications network architecture that supports the distributed intelligence and control throughout the electricity network, as well as the interrelationships between the various applications. This is significantly more complex than the vertically layered networks that operate traditional SCADA systems. It is also evident that there is no one communications network architecture or communications technology that is suitable for each function, layer or in each location.

The following sections of this submission explain the distribution businesses’ functional communications requirements, a hypothetical communications network architecture for smart electricity networks and the communications technology options being considered.

Functional communications requirements

Based on survey responses and a workshop among the electricity distribution businesses, a comprehensive list of functional requirements was developed and grouped according to whether they are critical to the delivery of secure, reliable and safe electricity network operations; highly important to the delivery of network and demand management; or are part of regular business operations.

This distinction is important in order to identify those functions that require such high levels of reliability and low latency that they require fit-for-purpose, dedicated, utility grade communications networks rather than access to commercial carrier networks. In turn this helps to identify those functions for which utility owned wireless networks and hence radio frequency spectrum are required.

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With all of these functions it should be noted that the necessary service levels are different in different circumstances. For example, during extreme temperatures or natural disaster situations there is generally a need for higher reliability and lower latencies as these are the critical times when the communications networks are needed in order to restore power systems in a timely and least disruptive manner.

Critical functional requirements

Critical functional requirements are those traditional functions that are central to the distribution businesses' network operations and are generally provided by communications systems designed, built and operated by the distribution businesses in order to meet their extremely high service level requirements. The critical network functions are as follows:

a. Network protection

Network protection systems are a highly critical part of electricity distribution networks. These systems include monitoring equipment, protective relays, circuit breakers and auto-reclosers that automatically detect, isolate and repair electrical network faults so as to minimise disruptions spreading to the rest of the electricity distribution network.

The communications requirements for this function are for extremely high security, extremely high availability (>99.999%), extremely low latency (less than 20 ms), low bandwidth (<10 Kbps) point to point connections.

The communications technologies that are currently used for this function are optical fibre (including optical ground wire (OPGW), which consists of optical fibres in electrical cables), copper and microwave networks.

b. Network management - SCADA

Network management systems traditionally rely on supervisory control and data acquisition (SCADA) to provide real time monitoring and control of devices throughout the electricity network through communication with Remote Terminal Units (RTUs) located at distribution substations, transformers and other locations in the electricity network.

The communications requirements for this function are for very high security, high availability (99.8%), low latency (<1 sec) and low bandwidth connections (<100kbps).

The communications technologies that are currently used for this function are optical fibre, wireless, microwave and aging copper networks.

Some electricity distribution businesses are reviewing technologies such as MPLS over optical fibre to support this requirement. Others are considering an increased use of wireless technologies (3G/ 4G), particularly on the edge of electrical distribution networks, where this is a more cost-effective solution than optical fibre.

Where wireless networks are used for SCADA functions, electricity distribution businesses have acquired spectrum in the 400 MHz band through apparatus licences.

Highly important functional requirements

The highly important functional requirements are those new functions enabled by a smart electricity network, which are aimed at achieving the objectives as set out in section 3 of this submission. As is discussed further in this submission, these functions require fit-for-purpose, dedicated, utility grade communications networks in order to meet their high service level requirements and to be cost-effective. The highly important network functions are as follows:

a. Network and demand management - AMI

In addition to performing a metrology function for the purpose of market settlements and customer billing, AMI can provide electricity distribution businesses with near real time information about consumption and power quality at the customer’s premise. This information is highly important to the management of the network, especially during peak and emergency situations. For example, AMI can record and transmit

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information about the maximum demand, power factor, reactive power and voltage levels at a residential premises, and can also relay safety information regarding the customer’s connection.

AMI can also be used by distribution businesses for demand management purposes, via direct load control (DLC). This involves the distribution businesses offering customers a rebate or tariff reduction in return for the ability to undertake short term interruptions to, or a reduction in energy use from certain controllable appliances such as water heaters, air-conditioners, refrigerators and pool pumps. This functionality is only used when necessary to preserve system security and integrity during an emergency or peak load situation, and is an alternative to costly network augmentation. Demand management allows the distribution businesses to undertake a more targeted response in peak or emergency situations, potentially reducing the number of customers affected by a disruption to their power supplies. In NSW, Queensland and South Australia, demand management through AMI would be a replacement of other DLC systems such as ripple control (low frequency signalling over the power line) that are near their end of life.

AMI can also facilitate the provision of energy consumption information to customers (eg by the meter communicating with a home area network or in home display) and to third parties, including retailers. This information can facilitate the development of dynamic pricing mechanisms (such as time of use pricing). In response to information and price signals, customers can shift or reduce their demand either directly or via the services of a third party. AMI can also facilitate automated demand response (ADR), whereby customers will be able to pre-program appliances so that their consumption is shifted in certain situations (eg during peak network loading, or in response to dynamic prices).

At the aggregated access and core network layers, this function requires high security, high availability (99.8%), low latency and high bandwidth connections (>10 Mbps). At the residential premises level, the communications requirements are generally lower, except during peak and emergency situations. At the residential premise level, only low bandwidth connections are required (10 Kbps to 100 Kbps).

The communications technologies that are being considered for this function are optical fibre and wireless (3G/4G and mesh radio) networks.

b. Distribution monitoring, control and automation

A major area of change for network businesses is a gradual move from network monitoring and remote control towards the automation of network functions. This will incorporate a number of applications, such as fault detection, isolation and restoration, substation and feeder monitoring and control, and remote switching capabilities. These applications will improve the reliability of energy supplies through real time monitoring of operating conditions and network loading so that failure risks are minimised, and the automated control of network assets, which will minimize the duration of any outage. They will also improve the cost efficiency of business operations.

The communications technologies that are currently used for this function are wireless, microwave and aging copper networks. As these services are extended throughout the network, distribution businesses are considering using optical fibre between substations and wireless technologies (3G/ 4G and mesh), particularly on the edge of electricity distribution networks where this is a more cost-effective solution than deploying fibre.

c. Connection of distributed energy resources

The connection of a large number of distributed energy resources (DER - small scale generators connected to the distribution network) has the potential to negatively impact on power quality and threaten the reliability and security of electricity supplies. It is therefore essential that these resources are interoperable with the electricity distribution network.

This impact is exacerbated where the DER are intermittent power supplies, such as wind and solar power generation. For example, the recent large scale uptake of small scale solar PV’s, as a result of subsidies and feed-in tariffs, has raised power quality issues, such as voltage fluctuations, for several distribution companies.

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A large scale deployment of intermittent DER requires the ability for distribution businesses to communicate and control non-essential loads (for example through direct load control discussed above), so that load can be shed in the event of a loss of supply from DER (for example if wind currents and hence wind power output drops); and other sources of distributed generation (such as gas fired combined heat and power plants) that can be quickly brought online for network support.

Standards for communication with DER are emerging (IEC standard 61850), to support the integration of DER into distribution substation automation systems, which can regulate voltage levels.

The communications requirement and technologies that are being considered for this function are optical fibre and wireless networks (3G/4G).

d. Connection of electric vehicles

In the future, drivers of electric vehicles will be able to program how and when their vehicles will be charged, for example, selecting particular times that the charging must be completed by or a certain tariff above which charging should not occur. This is akin to ADR for other pre-programmable appliances such as washing machines and dishwashers. Drivers will also be able to export the excess electricity stored in their car battery into the electricity network.

With each electric vehicle consuming or able to inject into the network an amount of electricity equivalent to a household, the large scale uptake of electric vehicles has the potential to negatively impact on the electricity network’s voltage and frequency levels, thereby impacting on power quality and potentially threatening network reliability and security, leading to outages. It is therefore important that the electricity network can communicate with vehicles through the AMI in order to attain information that will assist with the planning and operation of the electricity network. If the network business has visibility of the load from electric vehicles, then it can undertake demand management or network monitoring and reinforcement where necessary to avoid problems occurring.

The communications requirement and technologies that are being considered for this function are optical fibre and wireless networks (3G/4G).2

e. Mobile communications for field staff

Electricity distribution businesses employ a large field-based workforce that carry out construction, maintenance and operational activities on the power network on a daily basis. Reliable and efficient (mobile voice and data) communications are essential in being able to safely carry out the necessary work activities.

In addition it is highly important for field staff to access data from network and outage management systems to be ale to restore power supplies, for example in times natural disasters and emergency situations. In these situations there is also need for mobile push to X communications (such as push to talk, push to view and instant messaging) and a need for interoperable handsets between electricity network businesses so that staff from an out of area distribution business can provide effective assistance to restore power supplies.

The communications requirements for this function are for high security, high availability (99.98%) mobile voice and data connections. The bandwidth needs are moderate (2Mbps).

2 Note: The following article regarding electric vehicle to grid communications systems notes that this infrastructure needs to be in place in order to support the widespread adoption of electric vehicles, http://green.autoblog.com/2009/08/18/ford-announces-electric-vehicle-to-grid-communications-system/

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Given the high importance of this function, especially to the safety of field staff, electricity distribution businesses rely on more than one communications platform. This diversity ensures a backup system is available, for example in emergency situations.

The communications technologies that are currently used for this function include the distribution business’s own private mobile radio networks (PMR), though for several distribution businesses, these existing systems are near their end of life and in need of replacement, for example with a fit for purpose, dedicated, utility grade 3G/ 4G network. Public mobile telephony services (GSM/3G) are used in areas not covered by the distribution business’s own network. In some states, government operated trunk radio networks or satellite phones provide backup to these services.

Regular functional requirements

Regular functional requirements are those that support normal business operations and do not generally impinge on the provision of safe, secure and reliable electricity supplies. Communications for regular functions could be provided as services by commercial carriers or by the distribution businesses own enterprise grade (rather than utility grade) communications networks. However, it should be noted that where businesses are planning to deploy utility grade networks (such as LTE networks) for critical and highly important electricity network functions, it would be more economic to use those networks for some of these functions, such as advanced metrology and site security.

a. Corporate mobile communications for office staff

This function supports mobile telephony between office staff away from their desks. Data services are used by office staff when secure access is required from home or from a site that does not allow casual connections into the network (such as a data centre).

The communications requirements for this function are for commercial carrier grade mobile telecommunications services, however there may be a need to use utility infrastructure in areas where coverage is not available on public mobile telephony networks.

b. Advanced metrology

AMI supports the automated measurement and communication of customers’ energy consumption for the purpose of market settlements by the Australian Energy Market Operator (AEMO) and the billing of customers.

The availability of an individual meter is not critical when considering billing operations, so an availability of 99.8% and a latency of <1 minute is acceptable.

While the metrology functions of the AMI could be carried over a commercial 3G/ 4G network, it doesn’t make practical or economic sense to do so when a fit-for-purpose, dedicated AMI communications network is needed for the demand management functions, and hence this network could serve both purposes.

The communications technologies that are currently used or being investigated for this function include optical fibre and wireless (3G/4G and mesh radio) networks.

c. Site security

This function involves the relay of closed circuit television (CCTV) feeds from substations back to control rooms to remotely manage security and site access. It can also be used for perimeter and access security by enabling remote alarm monitoring and management.

The communications requirements for this function are for reliable, commercial grade, high bandwidth connections to major electricity distribution network infrastructure locations.

The communications technologies that are currently used or being investigated for this function include optical fibre and wireless (3G/4G) networks.

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

Box 1: Summary of functions requiring new communications networks

connection of electric vehicles

connection of distributed energy resources

mobile voice and data communications with field staff

advanced metrology, and

site security

In summary, the main new or expanded functions for which distribution businesses require wireless communications networks, and hence radio frequency spectrum, are:

network and demand management

distribution monitoring, control and automation,

Communications network architecture

A major component of a smart electricity network will be the deployment of ‘last mile’ communications, which connect the electricity distribution businesses’ core network to millions of network monitoring and control devices, distributed energy resources and customers home area networks and/ or smart meters – either directly, or via a neighbourhood area network and/ or an access network.

As discussed, this will require a vertically and horizontally layered communications network architecture. While the actual layers and the terminology used to describe them will vary between electricity distribution businesses, the communications architecture for a smart electricity network will generally consist of:

a high bandwidth core network, which communicates between the distribution businesses’ control centre and various elements of their distribution service areas (primarily substations). In some areas, the core network may also aggregate data from access networks, or directly from network or customer devices. The core network is the primary communications network for the critical functions detailed above. The distribution businesses own optical fibre and microwave networks are the main communications technologies for this layer.

a medium bandwidth access network, which transmits data between the core network and distribution devices (eg pole top monitoring devices or meter aggregators), distributed renewable energy generation, network energy storage devices, vehicle charging stations and field staff. Access networks may aggregate data from a neighbourhood area network (NAN). This layer uses a mix of wired technologies (such as fibre and copper) and wireless technologies (such as microwave, 3G/4G and mesh radio) networks.

a low bandwidth neighbourhood area network, which aggregates data from residential devices (such as meters, home area networks, distributed energy resources and energy storage devices, electric vehicles). This layer uses a mix of wired technologies (such as fibre and copper) and wireless technologies (such as microwave, 3G/ 4G and mesh radio) networks.

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ENA submission—Industry wide position on the spectrum needs of smart electricity networks

As the following diagram illustrates, some functions have the option of being connected at multiple layers, and this will vary depending on factors such as population density and geography of the area served. For example, in urban areas with a greater number of devices to connect, there may be greater aggregation of data through NANs and access networks than in rural areas where some devices might link directly to the core network at the substation.

Source: Communication Network Architecture and Design Principles for Smart Grids, Alcatel Lucent

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ENA submission—Industry wide position on the spectrum needs of smart electricity networks

The following diagram is another simplified example of a possible communications architecture for a smart electricity network.

Source: http://www.trilliantinc.com/solutions/multi-tier-architecture/

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5. Communications technology options There are various wired and wireless communications technologies that can be considered for smart network communications; however the suitability of individual technologies will vary according to each distribution business’s functional needs and the characteristics of each distribution service area. While distribution businesses would ideally like to keep the number of technologies to a minimum (to gain economies in purchasing equipment and to reduce ongoing operational support costs), it is likely that many businesses will need a mix of technologies to fulfill their diverse needs, especially those businesses whose service area extends to rural areas.

While power line carrier (PLC)/ broadband over power line (BPL) technology has been trialled by some electricity distribution businesses, it is not generally considered feasible for highly important network functions due to interference problems. In addition, although this technology is being deployed in the United States of America, the design of Australian electricity networks is such that many more repeaters would be required to make it technically feasible to use for such network functions, making it cost prohibitive. PLC for low voltage networks only is however being considered by some distribution businesses for last mile communications for AMI at residential premises.

The main communications technologies that electricity distribution businesses are considering as a platform for the functions set out in Box 1 are a mix of optical fibre (utility own and the NBN) and wireless (3G/ 4G and mesh radio) networks.

Electricity distribution businesses will generally only deploy fibre networks in areas with a high population density, where the high costs can be justified, for example communications to urban substations. Wireless networks are typically cheaper than fibre for NAN and access networks (WAN), particularly towards the edge of the electricity network’s service area.

Given the large number of devices that need to be connected as part of a smart network, the broad communications coverage that is required, and the need for a timely and cost-effective deployment of smart networks, distribution businesses will need to rely on wireless broadband technologies to a considerable degree for both residential and network applications for at least the next 10 years.

Over time, the reliance on wireless broadband communications for providing smart network communications may be diminished, though not eliminated, if the NBN is able to deliver the electricity industry’s requirements for ubiquitous, secure, reliable, cost-effective and interoperable communications. While the electricity industry is working with NBN Co to investigate the potential for using the NBN for some smart network communications, it should be noted that there is considerable uncertainty regarding the technical and economic feasibility of using the NBN for smart electricity network communications functions (for both residential and network applications) and uncertainty regarding the timing of the NBN’s deployment in any given area.

In the longer term, electricity distribution businesses will have an ongoing need for wireless broadband technologies, at a minimum to support mission critical mobile voice and data communications with field staff, and for those functions/ areas for which the NBN and commercial carrier networks are not suitable or available, particularly during emergency situations.

Wireless technologies

As with other technology choices, there is no single wireless communications technology that will be suitable for all smart network functions or for all service areas. In particular, the population sparsity of some areas will render some architecture and technology options uneconomic.

For the short to medium term some electricity distribution businesses have deployed or are considering mesh radio technology; some have deployed or are considering 4G WiMAX technology; and others are considering a mix of these technologies for their smart network communications.

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In the longer term, the electricity distribution businesses covered by this submission are interested in adopting long-term evolution (LTE) and mesh radio technologies as the main communications platforms upon which to base their smart electricity networks.

For some distribution businesses LTE technologies may be able to meet all of the communications requirements summarised in Box 1, while other businesses may use LTE for the access and core network layers, in conjunction with other technologies such as mesh radio networks or the NBN, for example, for AMI to residential premises and within neighbourhood area networks. To this extent it is noted that LTE Advanced is interoperable with mesh radio networks.

In the short term (until LTE network infrastructure and terminal equipment becomes widely available), most electricity distribution businesses are considering using mesh radio and/or WiMAX platforms with an upgrade path to LTE. This approach is in line with the major carriers’ progression path from GSM (2G) and WCDMA/ UMTS (3G) to LTE.

a. LTE

LTE is a standardised (3GPP) 4G technology being adopted globally by major carriers, guaranteeing device availability into the future, reduced cost of terminals and other equipment and ongoing development and support for LTE (for example 4G LTE Advanced). LTE is expected to become the technology of choice for M2M applications, due to its capacity to provide secure, high speed services and penetration to large populations of devices requiring data transfer capability.

In addition, LTE is ideally suited to scenarios where large populations of devices require concurrent data communication within a sector. This is a key requirement during scenarios such as soft starting a network after a blackout (remotely disconnecting a large volume of residences and then turning them on in smaller groups so as not to overload the systems with high start up current), suburb-by-suburb off-peak tariff control, street light control, distributed generation and so on.

The following is a list of the many existing and proposed LTE features that support smart grids:

Dual-stack IPv4/IPv6 support – IPv6 addressing is essential for large “machine communities”, and allows applications to work seamlessly across mobile and fixed broadband connections.

Very low latency on user plane, control plane and scheduling (short setup time & short transfer delay, short transmit time intervals (TTI)) are essential for M2M applications handling thousands of devices within a cell. Previous generation technologies have slower radio reestablishment procedures and require larger overheads.

Support of variable and scalable bandwidth (1.4, 3, 5, 10, 15 and 20 MHz) to effectively address capacity issues whilst optimising spectrum utilisation by legacy applications (GSM/UMTS). This is essential in enabling efficient and simple spectrum sharing with rail network operators, and allows a smooth migration, increasing bandwidth as the demands on the network increases (as the number of devices increases, or data requirements increase).

Simple protocol architecture (shared channel based, packet switched optimised with VoIP capability). M2M applications will be data based and LTE is a network made especially to handle data as first priority.

Simple architecture (eNodeB as the only E-UTRAN node) – reduces system complexity, reduces latency and enhances scalability.

Efficient multicast/broadcast. This is a desirable feature for future deployment of applications intended to make use of broadcast data.

Support of self-organising network (SON) operation – reduces the need for operations and maintenance tasks through automatic neighbour optimisation and automatic interference management. This saves costs associated with manually configuring and tuning the network.

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Guard bands are part of the LTE specification, meaning that no extra consideration needs to be taken in calculating spectrum requirements. LTE can be put right next to GSM/HSPA without any extra guard band required.

Increased spectrum efficiency in DL from 15bps/Hz to 30bps/Hz. This provides capacity expansion into the future to meet the needs of new applications and faster downlink data transfer rates.

Support for non-contiguous bandwidth scalability, allowing aggregation of non-adjacent bandwidth allocations (increasing capacity). This provides greater flexibility for capacity expansion into the future without the need to secure contiguous spectrum.

Improved support for heterogeneous deployments and relaying, reducing the cost of network coverage expansion.

b. Mesh radio

Mesh Radio is a wireless, cooperative communication infrastructure that allows data to be routed from one node to another to reach its final destination. Each node need only transmit as far as the next node. Nodes act as repeaters to transmit data from nearby nodes to peers that are too far away to reach, resulting in a network that can span large distances, especially over rough or difficult terrain.

As a result, mesh radio is often seen as a cost effective mechanism for achieving high coverage (typically in excess of 99%) for applications with moderate bandwidth (20 to 200kbps) requirements.

Mesh networks come in a number of forms, including proprietary implementations and (more recently) standardised implementations such as ZigBee (which is based on IEEE 802.14.5).

The following is a summary of the features of typical mesh technologies that support smart grids:

High reliability - multiple routes for each communication nodes result in a highly redundant communication infrastructure.

High scalability – expanding the mesh is achieved through the addition of low cost access points. A typical access point can serve on average 5,000 end nodes.

Low risk - mesh radio deployments for AMI and smart network applications have tens of millions of end nodes already in operation.

Dual-stack IPv4/IPv6 support – IPv6 addressing is essential for large “machine communities”, and allows applications to work seamlessly across mobile and fixed broadband connections.

High tolerance for interference – mesh radio is designed to operate in shared spectrum and employs multiple techniques to overcome interference.

Technology standards

There are various global standards (either existing or under development) that apply to M2M communications and smart electricity networks. These apply to the application interfaces, network interfaces, data structures and communication protocols.

It is essential for electricity distribution businesses to align with global M2M communication standards in order to ensure compatibility of devices, networks and control systems. Development and adherence to standards also means that electricity distribution businesses will have greater choice when selecting infrastructure and device suppliers, and have a much greater certainty of support into the future than if non-standard proprietary solutions are deployed. The risks associated with adopting proprietary standards and deviating from common standards is well documented.

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An illustration of this risk was given by ACMA chairman Chris Chapman in his 2010 speech Developing a nationwide approach to smart grid spectrum, where he recounted how Australia decided to adopt a solution for distance measuring equipment (DME) in aircraft that used a frequency band that did not align with the rest of the world. This band was ultimately allocated for GSM mobile phone systems, and resulted in having to decommission thousands of DMEs at enormous expense.

Standards for M2M communication ensure a uniform way in which devices are identified, connect and communicate. The following is a list of some of the relevant smart grid standards. LTE technologies are consistent with these standards.

IEC 61970 (energy management systems application program interface)

IEC 61968 (Information exchange between electrical distribution systems)

IEC 61850 (design of electrical substation automation)

IEC 62056-21 (device language message specification for energy metering)

ANSI C12.19 (utility industry end device data tables), and

ANSI C12.22 (protocol for transporting ANSI C12.19 table data over networks).

Dedicated utility grade vs commercial carrier networks

Electricity distribution businesses need to rely on their communications systems the most in times of network failures, for example as a result of natural disasters, when harsh electrical and climatic conditions put stresses on the networks. These are the very times when commercial grade communications services and equipment are likely to fail, which makes it difficult and takes longer for the distribution business to restore power supplies. Having a fit-for-purpose, dedicated, utility grade communications network means that distribution businesses are better able to control their electricity networks and this means less frequent and shorter power outages.

The inadequacy of commercial carrier networks in natural disaster and emergency situations has also been raised by other organisations, for example in the recent Senate Inquiry into the capacity of communications networks and emergency warnings to deal with emergencies and natural disasters.3 In addition, experience has shown that commercial carrier networks are generally cost prohibitive as a widespread communications solution underpinning the deployment of smart network devices.

The following discussion elaborates on the reasons why distribution businesses require a fit-for-purpose, dedicated, utility grade communications network.

Resilience

Commercial grade communications equipment is not hardened to deal with harsh electrical and climatic conditions, which put stresses on communications networks.

As evidenced recently, natural disasters such as bushfire, cyclone and flood events are the very times when commercial grade communications services and equipment are likely to fail, which makes it difficult and takes longer for the electricity distribution business to restore power supplies. Following

3 For example, see the submission by the Police Federation of Australia to the Senate Standing Committee on Communications and Environment inquiry into the capacity of communications networks and emergency warnings to deal with emergencies and natural disasters, http://www.pfa.org.au/files/uploads/PFA_Submission_Emergency_Communications_0.pdf

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the floods and cyclone Yasi in Queensland, much of the mobile infrastructure survived intact, however it failed a few hours later due to minimal battery storage capacity.

Fit-for-purpose, dedicated, utility grade communications networks would be provisioned with far more rigorous reliability metrics, which means more resilient communications that enable distribution businesses to detect and repair problems and hence restore power supplies more quickly.

Control over network design

The typical location of devices in an electricity network may differ from what commercial carriers target in their network plans (e.g. energy meters in areas of buildings not accessed by building staff). This may present network planning conflicts between a commercial carrier’s typical traffic and a distribution business’s requirements. These conflicts would not arise if the electricity distribution business has a fit-for-purpose, dedicated, utility grade communications network.

Network management

If a commercial carrier decides to cease support for a particular communications technology, the impacts to electricity distribution businesses would be enormous. This exposure to the network management practices of commercial carriers would be eliminated if the electricity distribution business has a fit-for-purpose, dedicated, utility grade communications network. This applies to managing technology changes as well as day-to-day network operations.

Minimised impact from other users

On a commercial carrier’s network, the capacity and service quality available to an electricity distribution business can be negatively impacted by traffic loads from other users and planned and unplanned outages. This is of critical importance during times of disaster and emergency, when full availability of the network is paramount.

Avoid congestion

It is important to note that the communications network must be able to support event storms (events that trigger large numbers of devices to attempt to access the network and send messages). These storms require large amounts of capacity to handle the expected signalling volume (location updates) and subsequent data transmissions. Leased capacity from commercial carriers will typically be unable to support the volume and intensity of traffic that occurs during these event storms. The network congestion experienced during the 2011 flood events in Queensland illustrates how easily commercial networks can be overloaded at times of critical events. That is, the times when reliance on the smart grid network is at its greatest coincide with the same times when the availability of a commercial network is likely to be at its lowest due to congestion.

Cost

Experience has shown that the use of commercial carriers’ networks is generally cost prohibitive as a widespread communications solution underpinning the deployment of smart network devices. Distribution businesses often find that they can deploy their own communications infrastructure at a lower price per device than can be obtained from a commercial carrier.

For these reasons, electricity distribution businesses’ use of commercial carriers’ networks for highly important network functions is generally limited to small scale pilots and trials and as infill in areas beyond the reach of the distribution business’s own communications networks.

Given that commercial carriers have been unable to deliver services that meet these requirements, electricity distribution businesses are pursuing the option of building and operating their own wireless communications networks.

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6. Spectrum needs of smart electricity networks

Need for harmonised spectrum

The electricity distribution industry considers that there are benefits in harmonising the spectrum bands used for smart electricity networks in Australia and internationally as this will:

deliver cost efficiencies through access to low cost, standardised and future-proof technologies

provide certainty of investment consistent with the nature of utility investment cycles, and

allow for interoperability of equipment between electricity distribution businesses, for example out of area support crews would be able to use their own handsets when assisting in emergency or disaster recovery situations, which would improve the responsiveness and effectiveness of these crews. This is similar to the harmonisation of spectrum for Federal and State emergency services.

Internationally, electricity utilities are seeking access to spectrum to support the deployment of their own wireless communications for smart electricity networks, with significant interest in the sub 1 GHz bands and 1800 MHz band for these purposes. There is also increasing recognition of the benefits of smart electricity networks in spectrum policies and regulatory decisions.

For example, the Canadian spectrum regulator, Industry Canada, has allocated 30 MHz of spectrum in the 1800 MHz band to electricity businesses for various applications including telemetry, mobile radio and smart grid development.4 Canadian utilities are now seeking additional access to sub 1 GHz spectrum.5

The United States of America, the Utilities Telecom Council is seeking access to 30 MHz of spectrum in the 1800 MHz band for smart grid use by electricity, gas and water utilities. The UTC is seeking access to this band to provide a harmonised allocation with Canada. The UTC is also seeking access to 700 MHz public safety spectrum.6

In the United States of America, the Federal Communications Commission (FCC) has recognised the importance of smart electricity networks in its National Broadband Plan, which contains the following recommendations:

Recommendation 12.4: Congress should consider amending the Communications Act to enable utilities to use the proposed public safety 700 MHz wireless broadband network.

Recommendation 12.5: The National Telecommunication and Information Administration (NTIA) and the FCC should continue their joint efforts to identify new uses for federal spectrum and should consider the requirements of the Smart Grid.

In Europe, the European Utilities Telecom Council is advocating for access to 15-30 MHz of spectrum below 1 GHz for smart grids.7 The EUTC has also indicated that paired spectrum in the 1800 MHz band would be

4 Canadian Electricity Association, The Smart Grid: A Pragmatic Approach http://www.electricity.ca/media/SmartGrid/SmartGridpaperEN.pdf 5 http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/smse-018-10-cea-submission.pdf/$FILE/smse-018-10-cea-submission.pdf 6 Utilities Telecom Council, The utility spectrum crisis: a critical need to enable smart grids http://www.utc.org/utc/utility-spectrum-crisis-critical-need-enable-smart-grids. See also Kilbourne and Bender (Utilities Telecom Council) , Spectrum for smart grid: policy recommendations enabling current and future applications http://www.acma.gov.au/webwr/_assets/main/lib311973/ena_attch4_ifc34-2010.pdf 7 Study for the European Utilities Telecom Council, Options for a harmonised allocation to support utility operations (smart grids): Final report

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suitable and has suggested that some 1800 bandwidth could be released following the anticipated movement of mobile carriers to lower bands.

In September 2010, the European Commission developed a proposal for the European Parliament and Council to establish a radio spectrum policy program for planning and harmonisation of use of spectrum across Europe. Article 7(2) of this proposal recognises the spectrum needs of smart grids

In cooperation with the Member States, the Commission shall conduct studies and examine the possibility to design authorisation schemes which would contribute to a low-carbon policy, by saving energy in the use of spectrum as well as by making spectrum available for wireless technologies with a potential for improving energy saving, including smart energy grids and smart metering systems. 8

Suitable spectrum options

The distribution businesses preferred technology choice is one of the main determinants of the spectrum options available to implement wireless communications networks.

As indicated, ENA members are interested in adopting LTE and mesh radio technologies to meet their smart network requirements. The ENA has therefore focused its assessment of spectrum options on those bands that are, or may in the future be, suitable for these technologies.

Spectrum for LTE technologies

The internationally recognised, primary LTE bands are 700 MHz, 2100 MHz and 2600 MHz. However, LTE technology has been proposed and some equipment made available by a number of manufacturers for other spectrum bands, including 900 MHz, 1800 MHz and 2300 MHz. Several telecommunications carriers have conducted trials of LTE in the 1800 MHz band and Telstra has now committed to a deployment of LTE technology in this band.9

The 900 MHz, 1800 MHz and 2300 MHz bands are still currently recognised as primary GSM (900 MHz and 1800 MHz) and WiMAX (2300 MHZ) bands. Consequently, volume production of LTE equipment for these bands is likely to follow after equipment for the primary LTE bands. In this case, electricity distribution businesses could deploy other technologies in these bands and transition to LTE. Ultimately, the availability of LTE equipment in these bands will depend on the demand from mobile communications carriers.10

The 2100 MHz band, while satisfying the LTE criterion, was not considered realistic due to the fact that large segments of this band are spectrum licensed to mobile phone carriers until 2017 for their 3G mobile networks. The prospect of gaining access to this spectrum was considered low.

The suitable spectrum options – 700 MHz, 900 MHz, 1800 MHz, 2300 MHz and 2600 MHz – were assessed using a framework developed by Gibson Quai-AAS, with the assistance of ENA members. This framework assessed these spectrum options for both urban and rural areas in terms of the strategic fit for ENA members (for example, spectrum coverage and availability, and equipment cost and availability).

Each spectrum option was rated according to key decision making criteria and weighting factors to determine the options that best meet the electricity network businesses’ functional and technological requirements.

8 European Commission, Proposal for a decision of the European Parliament and of the Council establishing the first radio spectrum policy program http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0471:FIN:EN:PDF 9 Telstra has released plans to commercially deploy LTE technology in the 1800 MHz band and http://www.arnnet.com.au/article/376561/telstra_rollout_4g_lte_network/ 10Telstra has set up an 1800 MHz LTE special interest group to show equipment manufacturers that mobile operators are interested in the production of LTE devices in the 1800 MHz band. See http://www.itnews.com.au/News/250432,telstra-sets-up-1800-mhz-lte-interest-group.aspx

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The ranking of the five spectrum options identified for further analysis for urban and rural areas are summarised in the following tables. Attachment B contains the detailed assessment of these bands. It should be noted that the scores for each option are relative, rather than absolute scores.

Options ranking Rating

Strategic Fit for ENA Members

Option 1: 700 MHz Digital Dividend LTE 4.2

Option 2: 900 MHz LTE 3.9

Option 3: 1700 to 1800 MHz LTE 3.5

Option 4: 2300 MHz WiMAX 3.3

Option 5: 2500 to 2600 MHz LTE 2.7

Table 1: Urban ranking summary

Options ranking Rating

Strategic Fit for ENA Members

Option 1: 700 MHz Digital Dividend LTE 4.3

Option 2: 900 MHz LTE 4.0

Option 3: 1700 to 1800 MHz LTE 3.4

Option 4: 2300 MHz WiMAX 3.0

Option 5: 2500 to 2600 MHz LTE 2.7

Table 2: Rural ranking summary

The ranking based on the strategic fit for ENA members indicates that the lower frequency bands are preferred over the higher frequency bands in both urban and rural areas. From a technical perspective, this result is to be expected as the deeper and wider coverage provided by lower frequency networks for the same infrastructure investment compared to other bands makes them particularly attractive for smart electricity networks. In addition, these low frequency bands offer good building penetration in urban areas.

It is evident that the 700 MHZ band is the most suitable band to meet the technological and functional requirements of the electricity distribution businesses, particularly in rural areas. The wide signal coverage of the 700 MHz band also allows for a more cost-effective deployment of wireless communications infrastructure compared to higher spectrum bands that would be a significantly more expensive option, given the combined effect of higher infrastructure costs and a smaller population base.

For similar reasons, the 900 MHz band is of high interest to ENA members, particularly in rural areas despite the fact that it may take longer for LTE equipment to become available in this band. The ENA notes with interest that the ACMA is undertaking a review of the 900MHz band. As indicated in the ENA’s submission to the ACMA’s discussion paper The 900 MHz band – exploring new opportunities, the ENA considers that the replanning of the 900 MHz band (820 MHz–960 MHz) and the anticipated move of mobile telecommunications carriers into the digital dividend 700MHz band (694–820 MHz) provides an opportunity for the ACMA to dedicate a small amount of paired spectrum within the 900 MHz band to utilities for the operation of 3G/ 4G networks in rural areas.

While the 700 MHz and 900 MHz bands also have the highest strategic fit for ENA members in urban areas, it is acknowledged that the likelihood of acquiring access to these bands is very low in urban areas, due to competition from mobile telecommunications carriers. The ENA has therefore chosen to focus its needs in urban areas on higher frequency bands that offer a more realistic option for an allocation of spectrum.

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ENA’s preferred option for urban areas is the 1800 MHz band, which has spectrum licences due for renewal in 2013 and 2015. ENA encourages the ACMA to consider restacking this band to allow for a greater use of LTE technologies that require contiguous blocks of spectrum. This band is of interest to ENA members in urban areas as it aligns with the emerging international interest in allocating 1800 MHz spectrum for smart electricity networks, as discussed above.

The ENA’s second preference for urban areas is the 2300 MHz band, which has spectrum licences due for renewal in 2015. However ENA members do not see as great potential for international harmonisation or for the adoption of LTE technologies in this band as in the 1800 MHz band. It is noted however that while this band is predominantly a WiMAX band it may be possible in the future to migrate to LTE.

While some electricity distribution businesses have either acquired or leased spectrum in the 2300 MHz band, it should be noted that these businesses have indicated support for migration to a harmonised 1800 MHz band. For some individual businesses, this may be a longer term outcome once existing assets are due for replacement.

The 2600 MHz band offers the potential to support LTE technology for smart electricity networks, however this option is also a lower preference than the 1800 MHz band, for similar reasons to the 2300 MHz band; combined with the fact that it would require higher infrastructure deployment costs and it is likely to be sought after by mobile telephony carriers.

Within the preferred spectrum bands, electricity distribution businesses have a requirement for paired spectrum to support frequency division duplex (FDD) transmission for LTE networks. This would enable greater cell ranges and hence reduce infrastructure costs. Unlike FDD, time division duplexing requires guard time slots between the inbound and outbound streams of data which makes it difficult to use for smart electricity networks.

Spectrum for mesh radio technologies

Several electricity distribution businesses have made/ planned significant investments in not only mesh radio devices and systems but also electricity network devices and systems that are contingent on the use of the 915–928 MHz Radiocommunications (Low Interference Potential Devices) Class Licence 2000 (the LIPD Class Licence).

The ENA welcomes the fact the ACMA is considering the needs of smart infrastructure in its discussion paper The 900 MHz band – exploring new opportunities. However, in assessing the ACMA’s preliminary option for the 928–933 MHz band to be used for mesh radio networks for smart infrastructure it is important to recognise that this option is not feasible for existing/ planned deployments as it would result in significant unforeseen costs and reduced performance, which could impact on the utilities ability to meet their required service levels.

It is therefore vital that there is an appropriate regulatory mechanism to protect current and planned mesh radio investments, through continued use of the existing 915–928 MHz LIPD Class Licence for the entire asset life of current and planned investments (approximately 15 years from the completion of deployment), while at the same time allowing for a longer term transition to a harmonised band for these technologies.

Further detail on the ENA’s position in relation to spectrum to support mesh radio networks is contained in the ENA’s submission in response to The 900 MHz band – exploring new opportunities, which was lodged with the ACMA on 24 June 2011. The ENA looks forward to further engagement with the ACMA on this issue.

Spectrum bandwidth requirements

ENA engaged Ericsson to undertake modeling to give an indication of the spectrum bandwidth required for smart network applications in both urban and rural areas (see Attachment C, which is confidential). This modeling assumed the use of contiguous blocks of spectrum for LTE technologies, and relied on device traffic profiles, performance requirements and cell coverage estimates provided by distribution businesses.

ENA submission—Industry wide position on the spectrum needs of smart electricity networks

This work indicates that, based on the requirements provided by the various distribution businesses and the various assumptions listed in the attached report, the indicative minimum LTE bandwidth required to support the average worst case network traffic scenarios is between 8-15 MHz in urban areas and 5-10 MHz in rural areas.

If less spectrum is available for smart electricity networks, the main impacts will be delays and a potential loss of traffic, which will lead to extended outages on the electricity network and delay in the integration of renewable resources such as solar PV and fuel cells. This will largely have an impact in the extreme traffic cases of emergency events where there are data transfers and large numbers of emergency personnel accessing the network simultaneously.

While there are some possible options for mitigating these impacts in affected areas, this will increase network complexity and costs to distribution businesses and hence to end customers.

Licence tenure

At this stage the ENA has not given detailed consideration to the appropriate type of licensing for the spectrum it requires. However, electricity distribution businesses are looking at potential communications solutions that will meet their requirements for at least a 15 year period. Unlike commercial carriers, it is not possible for distribution businesses to seek to recover their investment in a period of 5-10 years (or shorter). It is therefore important from a risk management perspective that access to spectrum be for a period of at least 15 years. This will provide investment certainty to the electricity distribution businesses, consistent with the long term nature of their investment cycles.

ENA industry-wide multi-band spectrum strategy

As discussed, the ideal spectrum bands for all smart electricity networks are the 700–900 MHz bands. However, ENA and its members are conscious of the likely high demand for spectrum in these bands and hence is proposing a compromise position that only seeks access to a small amount of paired 700–900 MHz spectrum in areas where it is most needed, that is to support a migration to LTE technologies in rural areas, and a small amount of unpaired spectrum for mesh radio technologies.

The ENA urges the ACMA and DBCDE to recognise the significant public benefits of smart electricity networks, through the allocation of the following spectrum for these purposes:

Box 2: Summary of functions requiring new communications networks

5-10 MHz of paired spectrum in the 700 MHz–900 MHz band in rural areas, to support a migration to LTE technology

8-15 MHz of paired spectrum in the 1800 MHz band in urban areas, to support a migration to LTE technology, and

Continued access to the 915 – 928 MHz band in accordance with the Radiocommunications (Low Interference Potential Devices) Class Licences 2000 (the LIPD Class Licence) for the entire asset life of current and planned mesh radio investments (approximately 15 years from the completion of deployment); with a longer term transition to a dedicated unpaired band of similar bandwidth to support mesh radio technologies.

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7. Spectrum allocation The ACMA is guided by the object of the Radiocommunications Act 1992 (Radiocommunications Act), which is to provide for the management of the radiofrequency spectrum in order to further the matters at paragraphs (a) to (h) of section 3 of the Radiocommunications Act.

The Radiocommunications Act and the ACMA acknowledge that in managing the radiofrequency spectrum, there is a need to take into consideration uses of spectrum that result in public (non-profitable) benefits, as well as commercial benefits.

In particular, the following objects of the Radiocommunications Act 1992 are of relevance:

(a) maximise, by ensuring the efficient allocation and use of the spectrum, the overall public benefit derived from using the radiofrequency spectrum

(h) provide an efficient, equitable and transparent system of charging for the use of spectrum, taking account of the value of both commercial and non-commercial use of spectrum

While ‘public benefit’ is not defined in the Radiocommunications Act, some guidance has been provided by the Department of Broadband Communications and the Digital Economy (DBCDE). In April 2009, DBCDE released a discussion paper in relation to the possible public interest criteria that could be used during consideration of whether 15 year spectrum licences should be reallocated through a price based method or renewed to incumbent licensees. DBCDE stated that:

The objective of the Radiocommunications Act 1992 provides for the management of the radiofrequency spectrum in order to, among other things, maximise the overall public benefit derived from using the radiofrequency spectrum. When discussing the overall public benefit uses that are not purely commercial are also a key consideration. 11 (emphasis added).

The ENA urges the ACMA and DBCDE to recognise the significant public benefits of smart electricity networks, through the allocation of spectrum for these purposes.

The distribution of electricity through smart electricity networks has many characteristics associated with a public good (service), as many of the benefits of these investments are positive externalities that accrue to the broader Australian community, economy and the environment. In particular, the environmental benefits of smart networks and the improved reliability and security of electricity supplies in times of disasters – both of which are significant benefits to the Australian community and economy, and support Australian Government objectives – cannot be attributed to individual customers. In addition, the operation of an overall safe electricity network is a benefit that is not attributed to particular customers.

The valuation that electricity distribution businesses place on spectrum at auction will not reflect the public benefits of smart electricity networks. Instead, the value electricity distribution businesses place on radio spectrum will be less than that of mobile telecommunications carriers, who use spectrum to provide communications services directly to customers and will derive a commercial return from the provision of these services. This invariably means that distribution businesses will be unable to compete commercially with mobile network operators or broadband providers in an auction situation.

It should be noted that recent commercial spectrum purchases by some ENA members from existing licensees is not a reflection of their, or others, ability to purchase longer term spectrum rights through

11 Department of Broadband Communications and the Digital Economy, Public Interest Criteria for Re-issue of Spectrum Licences, April 2009, p 4

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auctions, nor is it a reflection of the band that they would like longer term access to. Instead, these short term purchases reflect a pressing need to acquire spectrum to undertake pilots and trials of smart network technologies, including Smart Grid, Smart City, or to support a regulated roll-out of AMI.

In the short to medium term there is no technically or economically feasible alternative to the distribution businesses’ own wireless broadband communications networks, which rely on radio frequency spectrum, for the provision of highly important network applications. Therefore, if electricity distribution businesses are unable to gain access to suitable radiofrequency spectrum they will be limited in their ability to deliver significant public and environmental benefits, which would result in sub-optimal outcomes for society as services of significant value would not be produced or would be delayed.

The ENA therefore considers that there is a need for a separate allocation mechanism, other than auction or opportunity cost pricing, for entities such as electricity distribution businesses that provide highly valued public goods, and are unable to secure spectrum at market rates.

The following sections elaborate on the public benefits of smart electricity networks and the importance of these networks to achieving government policy objectives.

Public benefits of smart electricity networks

Safe electricity supplies

With electricity affecting almost every activity that we undertake in our everyday lives it is easy to forget that electricity is a potentially lethal product. The foremost consideration for electricity distribution utilities, therefore, is to ensure the safety of their staff and the general public. The primary use of telecommunications by electricity distribution businesses is for network protection signaling and providing a critical communications capability between field staff and network operation centres.

Network protection signalling is vital for ensuring that when a fault occurs on the high voltage network, that section of the network is automatically isolated and the network operations centre notified. This limits the impact of the fault (in terms of the time to isolate and the number of customer affected) and ensures isolation to remove potentially dangerous situations to members of the public (e.g. line down).

When working on the electrical network it is imperative that field crews have priority communications access to the network control centre for the purpose of coordinating the isolation of network assets and switching of load to ensure continuity of supply. The control centre, through the communications link, provides confirmation to field crews that a section of the network has been isolated and it is safe to prepare the work area for maintenance and/or repair. Communication links must also be extended to manage an expected large growth in distributed generation such as residential solar PV. In some circumstances there is a risk that the line may have been isolated from power flowing downstream; however, the line might still be ‘live’ due to the feed-in of electricity from distributed generation sources. The management of any power flow back into the grid from distributed generation is essential for the safety and well being of electricity field crews.

Similarly, when there is an instance of a low voltage electrical line that has been felled there is a serious risk to life for the general public. Having a robust communications system allows electricity distribution utilities to effectively coordinate emergency events and rapidly neutralise the threat to public safety and then restore power.

Secure electricity supplies

The importance that the Australian Government, community and economy place on reliable, secure electricity supplies is evident in the Australian Government’s Critical Infrastructure Resilience Strategy, which identifies the need to ensure the continuity of critical infrastructure, such as energy supplies, in the face of all hazards. The Critical Infrastructure Resilience Strategy states:

The Australian Government recognises the importance of critical infrastructure, including those parts that provide essential services for everyday life (such as energy, food, water, transport, communications, health and banking and finance). A disruption to critical infrastructure could have a

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range of serious implications for business (including other critical infrastructure), governments and the community.

The aim of this Strategy is the continued operation of critical infrastructure in the face of all hazards, as this critical infrastructure supports Australia’s national defence and national security, and underpins our economic prosperity and social wellbeing. More resilient critical infrastructure will also help to achieve the continued provision of essential services to the community. 12

The Critical Infrastructure Resilience Strategy also states that

Critical infrastructure in Australia is highly interdependent, so that failure or disruption in one sector can lead to disruptions in other sectors. For instance, owners and operators of water infrastructure rely on electricity for pumping and telecommunications for monitoring operations. Similarly, the communications industry needs electricity to run their networks, and the electricity industry needs telemetry services to run their operations and participate in the electricity market.13

…given the reliance of business, governments and the community on the essential services provided by many critical infrastructure organisations…the Government has a role to assist critical infrastructure organisations enhance their ability to manage unforeseen or unexpected hazards.14

During and following a disaster, it is essential that electricity network businesses are able to minimise disruptions to power supplies and restore affected power supplies as quickly as possible, not only to deliver electricity to communities and businesses but also to enable to restoration of other essential services identified by the Australian Government (such as communications, water supply, health care and banking).

As indicated elsewhere in this submission, in order to restore power supplies as quickly as possible following an emergency situation, electricity distribution businesses need to invest in significant monitoring and control devices throughout their networks, which require an underlying communications network.

ENA argues that the allocation of spectrum to electricity network businesses is consistent with the role of Government in assisting critical infrastructure organisations to enhance their ability to manage unforeseen or unexpected hazards.

Reliable electricity supplies

The average customer is becoming far more demanding of continuity of electricity supplies. The penetration of digital technologies into the home (both for home office and home entertainment) means that the impact of both momentary and sustained power network outages will increasingly inconvenience more electricity customers.

While it can be argued that traditionally capital expenditure levels reflect certain reliability standards, much more will need to be done in the future to maintain these reliability levels, particularly in the face of increased temperatures as well as bushfire and storm activities from climate change.

Electricity businesses are therefore not using smart electricity networks to achieve the same reliability standards in a more efficient way, but rather they will be operating in different conditions, while still needing to meet Government and community expectations around reliability levels.

12 Australian Government, Critical Infrastructure Resilience Strategy, p 8 13 ibid, p 18 14 ibid, p 13

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Facilitation of carbon reductions

The Australian Government has stated that it is committed to reduce Australia’s carbon pollution to 25 per cent below 2000 levels by 2020 if the world agrees to an ambitious global deal capable of delivering our 450 ppm or lower goal. If global ambition is insufficient to achieve stabilisation at 450 ppm, Australia will reduce its emissions by between 5 and 15 per cent below 2000 levels by 2020.15 In addition the Government has in place a Renewable Energy Target of 20 per cent by 2020.

In a cost benefit analysis for a national rollout of smart meters, CRA International found that the implementation of smart meters, home area networks and in-home displays could potentially reduce greenhouse gases by 31 million tonnes in aggregate to 2030.16

Looking beyond smart meters, there is the potential for significantly greater reductions in carbon emissions through smart electricity networks that integrate electric vehicles, distributed and renewable electricity generation and energy storage technologies.

In order to meet the Government’s emission and renewable energy targets, a considerable amount of renewable and distributed energy resources will need to be integrated into the electricity network, much of will be intermittent in nature and will be embedded at the distribution level. The existing electricity distribution network was not designed for the connection of such variable and intermittent technologies and, as a result, these technologies pose a material risk of reduced reliability through power surges and voltage and frequency fluctuations. An increase in these technologies will require electricity distribution businesses to invest in communications networks to support monitoring, protection and control equipment and systems.

This will allow, for example, non-essential loads to be removed promptly in response to a loss of generation such as from solar or wind sources; or for embedded generators or battery storage to be brought on-line promptly for network support.

In the absence of smart network investments, including communications networks, by electricity distribution businesses, it will be difficult for Australia to meet its renewable energy and carbon reduction targets.

15 http://www.climatechange.gov.au/en/government/reduce/national-targets.aspx 16 http://www.ret.gov.au/Documents/mce/_documents/Executive_Summary_of_NERA's_Phase2Report20080915085044.pdf

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8. Spectrum for national smart infrastructure The ACMA has indicated that it will be encouraging at least sector wide and, where possible, cross-sectoral approaches to spectrum where a common band or suit of bands can be used to support smart infrastructure, such as within the electricity, gas, water and rail industries.

In particular, the ACMA has indicated that there is the potential to share 1800 MHz spectrum amongst smart infrastructure users through the establishment of a class licensed public park. The ENA considers there is some merit in this approach provided issues surrounding property rights, spectrum management and interference can be adequately addressed.

Given the critical nature of the electricity network infrastructure and the underlying communications networks, it is essential that a unified approach to spectrum for smart infrastructure ensures:

there is no technical interference between technologies within the band, and

the rights of individual users are clearly defined and acceptable to all parties.

Individual ENA members and rail corporations have been discussing the feasibility of this option, with broader industry wide discussions now under way, including both the ENA and the Australasian Railways Association of Australasia (ARAA).

The ENA understands that the ACMA is preparing a discussion paper that will outline possible options for a smart infrastructure public park and will seek information and data. The ENA hopes that this submission goes someway to addressing the ACMA’s information needs in this regard and looks forward to providing further information required in response to the discussion paper.

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9. Conclusion and recommendations The ENA’s industry-wide position on the spectrum needs of smart electricity networks is based on a need for:

paired spectrum that supports a migration to LTE technology

unpaired spectrum that supports mesh radio technology

an allocation of spectrum that recognises the significant public benefits of smart network investments, and

at least 15 year licences to ensure investment certainty for not only the communications investments, but other significant smart electricity network investments.

Based on a review of the functional and technological requirements of ENA’s electricity distribution members and the potential spectrum options available to support smart electricity networks, ENA believes that a mix of spectrum bands is required for its distribution members.

With respect to a migration to LTE technologies, ENA members have identified the 1800 MHz band as the most likely to be available and suitable for ENA’s electricity distribution members’ use in urban areas. Analysis also indicates that spectrum in the 700-900 MHz bands is preferred for 3G/ 4G technologies in rural areas.

Several electricity distribution businesses already have made/ planned significant investments in not only mesh radio devices and systems but also electricity network devices and systems that are contingent on the use of the 915–928 MHz LIPD Class Licence. The ENA considers that there needs to be an appropriate regulatory mechanism to protect current and planned mesh radio investments, through continued use of the existing 915–928 MHz LIPD Class Licence for the life of these investments (approximately 15 years), while at the same time allowing for a transition to a longer term harmonised band for these technologies.

The ENA looks forward to working with the ACMA and DBCDE to find a solution that secures spectrum for smart electricity networks. The ENA undertakes to continue to inform the ACMA and DBCDE of relevant issues as they emerge and to provide additional supporting material if required.

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Attachment A

ENA, National Strategy for Smart Electricity Networks

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Attachment B

Assessment of spectrum bands

Option 1: 700 MHz Digital Dividend LTE

Rating Criteria Rating (1 – 5) Weighting Factor

Urban Rural

Strategic Fit for ENA Members

Wireless Functionality Alignment

LTE supports business needs 5 5 0.20

Spectrum Coverage Capability

Ideal for access networks in urban and rural areas

Good wide area coverage

5 5 0.15

Equipment Availability for Spectrum by 2015

LTE expected to be available after 2013 4 4 0.15

Timing- Commercially Accessible by 2015

Available within 5 years 2 2 0.15

Cost of Deployments at Core

High, minimum core > 1 mill subs 3 3 0.05

Cost of Deployments at Edge17

High, needs high capacity RAN 4 5 0.15

Cost of Terminals

Low cost, mass produced 5 5 0.15

Strategic Fit Weighed Rating 4.2/5 4.3/5

17 This rating reflects the lower number of base stations required to achieve the same coverage compared to other bands.

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Option 2: 900 MHz LTE

Rating Criteria Rating (1 – 5) Weighting Factor

Urban Rural

Strategic Fit for ENA Members

Wireless Functionality Alignment

LTE supports business needs 5 5 0.20

Spectrum Coverage Capability

Ideal for access networks in urban and rural areas

Good wide area coverage

5 5 0.15

Equipment Availability for Spectrum by 2015

GSM available, LTE expected 1 1 0.15

Timing- Commercially Accessible by 2015

Available within 5 years 5 5 0.15

Cost of Deployments at Core

High, minimum core > 1 mill subs 3 3 0.05

Cost of Deployments at Edge18

High, needs high capacity RAN 4 5 0.15

Cost of Terminals

Low cost, mass produced 3 3 0.15

Strategic Fit Weighed Rating 3.9/5 4/5

18 This rating reflects the lower number of base stations required to achieve the same coverage compared to other bands.

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Option 3: 1700 to 1800 MHz LTE

Rating Criteria Rating (1 – 5)

Urban Rural

Weighting Factor

Strategic Fit for ENA Members

Wireless Functionality Alignment

LTE supports business needs

5 5 0.20

Spectrum Coverage Capability

Best suited to overlay access

Small coverage area

4 3 0.15

Equipment Availability for Spectrum by 2015

GSM available, LTE expected

1 1 0.15

Timing – Commercially Accessible by 2015

Available within 5 years

5 5 0.15

Cost of deployments at core

High, minimum core > 1 mill subs

2 2 0.05

Cost of deployments at edge

High, needs high capacity RAN

3 3 0.15

Cost of terminals

Low cost, mass produced

3 3 0.15

Strategic Fit Weighed Rating 3.5/5 3.4/5

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Option 4: 2300 MHz WiMAX

Rating (1 – 5) Rating Criteria

Urban Rural

Weighting Factor

Strategic Fit for ENA Members

Wireless Functionality Alignment

WiMAX just supports business long term needs 1 1 0.20

Spectrum Coverage Capability

Best suited to overlay access in metro areas

Small coverage area per BTS

3 2 0.15

Equipment Availability

WiMAX available, LTE in future 5 5 0.15

Timing

Available within 5 years 5 5 0.15

Cost of Deployments at Core19

Medium, min core < 1 mill subs 5 5 0.05

Cost of Deployments at Edge5

Med, needs moderate capacity RAN 5 4 0.15

Cost of Terminals

Medium, high volume production 1 1 0.15

Strategic Fit Weighed Rating 3.3/5 3.0/5

19 Assumes use of WiMAX technology which is understood to have lower cost infrastructure compared to LTE.

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Option 5: 2500 to 2600 MHz LTE

Rating (1 – 5) Rating Criteria

Urban Rural

Weighting Factor

Strategic Fit for ENA Members

Wireless Functionality Alignment

LTE supports business needs

5 5 0.20

Spectrum Coverage Capability

Best suited to overlay access in urban areas only

Small coverage area per BTS

1 1 0.15

Equipment Availability for Spectrum by 2015

LTE expected to be available

4 4 0.15

Timing – Commercially Accessible by 2015

Available after 2013

1 1 0.15

Cost of Deployments at Core

High, minimum core > 1 mill subs

1 1 0.05

Cost of Deployments at Edge

High, needs high capacity RAN

1 1 0.15

Cost of Terminals

Low cost, mass produced

4 4 0.15

Strategic Fit Weighed Rating 2.7/5 2.7/5

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Attachment C

Smart Grid Bandwidth Requirements, A report prepared for ENA by Ericsson

CONFIDENTIAL