Opposition has emerged to an Industry Canada provisional policy proposal regarding the allocation of the 220-222 MHz band to fixed and mobile services. The band was previously used by amateur radio services and the reallocation has been opposed by the Radio Amateurs of Canada (RoW, Dec. 14/05).  Bell Canada has voiced its opposition to the department’s proposed plan in its comments to DGTP-004-05, noting that it is premature and contradictory. "The provisional policy does not set out how the department intends to manage the process nor what criteria are to be used to asses public interest, convenience or necessity," reads Bell’s submission to Industry Canada.  The company suggests that the first-come first-served (FCFS) process as outlined by the department in its proposal wouldn’t follow first-come first-served criteria. This, Bell asserts, means the criteria should be subjected to review. "It could be prejudicial to future licensing," writes Bell. "If the department ultimately intends to issue area licences, via an auction or on another basis, then it should not potentially prejudice this by issuing licences under a provisional policy.  For example, in the auction of 3.5 GHz area licences, a number of auction licence areas surrounded pre-existing FCFS site licensees creating a confusing ‘Swiss cheese’ situation fair neither to incumbent licensees nor to bidders."  The incumbent telephone company also questions Industry Canada’s timing of the provisional policy decision. "The department has already had the recommendations for over two years without acting on them and has not presented any rationale as to why a provisional utilization policy has become necessary at this particular point in time," reads its submission.  Bell therefore proposes "that the department include the question of utilization policy for the band 220-222 MHz in the policy proposals comment period for 19 April 2006; i.e., the same date as for the other policy proposals."  Despite the incumbent telco’s opposition to the Industry Canada plan, support for the provisional policy proposal came from some small hydro companies. They say they are implementing a number of communications efficiencies for which use of the 220-222 MHz band is critical.  "The need to improve utility operations is illustrated by the fact that most utilities are not of aware of a power outage until a customer calls to complain; this is an untenable situation in a modern society.  Hence utilities are actively look for pragmatic solutions to automate their systems, where such solutions involve a far-reaching, yet cost-effective communications network," reads submissions from Waterloo North Hydro Inc. and Chatham Kent Hydro.  "The 220-222 MHz frequency band is very well-suited to provide the aforementioned communications solution. The characteristics of the VHF band are conducive to providing broad, yet reliable coverage to both urban and rural service areas. And technologies are available today dedicated to utility applications and taking advantage of the 5 kHz channel spacing to optimize spectrum use," write the two companies in their respective submissions.  Both companies urge the department to implement its policies regarding the 220-222 MHz band without delay. "We further encourage Industry Canada to establish a pricing model for the 220-222 MHz band that ensures affordable telemetry solutions and promotes rapid adoption of automation and demand response programs," read their submissions.