August 19, 2022
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The intent of this notice is to seek comments regarding an application [PDF: 629 KB] received from Ligado Networks (Canada) Inc. (Ligado Canada) for authority to provide Ancillary Terrestrial Component (ATC) mobile services over a portion of its licensed Mobile Satellite Services (MSS) spectrum in the L-band (1526-1536 MHz in the MSS downlink, and 1627.5-1637.5 MHz and 1646.5-1656.5 MHz in the MSS uplink).
In its application, Ligado Canada is requesting that Innovation, Science and Economic Development Canada (ISED) adopt similar operational requirements and technical rules as identified by the U.S. Federal Communications Commission (FCC) in its 2020 Order and Authorization, FCC 20-48, Ligado Amendment to License Modification Applications (the 2020 FCC Order and Authorization). The operational requirements would allow Ligado Canada to provide ancillary terrestrial mobile services over specific portions of its licensed MSS spectrum.
2. Canadian ATC policy
The 2004 Radio Systems Policy RP-023, Spectrum and Licensing Policy to Permit Ancillary Terrestrial Mobile Services as Part of Mobile-Satellite Service Offerings, established a set of spectrum and licensing policy principles to oversee the implementation of ATC as an integral part of the MSS offering. The principles provided guidance for the deployment of ATC mobile applications in conjunction with any MSS network operating in the “L-band” (1525-1559 MHz and 1626.5-1660.5 MHz), the “2 GHz band” (2000-2020 MHz and 2180-2200 MHz) and the “Big LEO bands” (1610-1626.5 MHz and 2483.5-2500 MHz). RP-023 was updated in 2014 only to remove the 2 GHz band, reflecting the publishing of SLPB-008-14, Decision on a Policy, Technical and Licensing Framework for Mobile Satellite Service and Advanced Wireless Service (AWS-4) in the Bands 2000-2020 MHz and 2180-2200 MHz (the 2 GHz Decision), as a separate document. The 2014 revision of RP-023 did not update the ATC policy for the remaining frequency bands.
Under the current 2014 version of RP-023, issue 2, ATC systems are required to be offered as an integral part of the MSS within the assigned spectrum of the MSS network. ATC systems are also limited to operations within their satellite coverage and service areas in Canada. RP-023 also stipulates that ATC operations are to be subordinate to the MSS, and the ATC operator is required to offer only dual-mode terminals that are capable of communicating with both the mobile satellite network and the ATC network.
ISED recognizes that ATC applications have evolved significantly since the development of RP 023 in 2004. ATC, as originally envisioned, was intended to support extension of the primarily voice MSS to areas where MSS signals could not reach. Since then, technology, networks and applications have advanced considerably and newer, more data-focused ATC applications have emerged. These applications include higher speed voice and data, support of Internet-of-Things (IoT) deployments, deployment of small cells in support of other mobile networks, and private long-term evolution (LTE) networks. Many of these applications will support the deployment of innovative 5G services and provide an opportunity for improved services through additional capacity while remaining compatible with the ongoing delivery of the primary MSS. ISED previously indicated that as ATC development continues to mature, a more comprehensive review of RP-023 will be undertaken.
ISED is issuing this notice in advance of a comprehensive review of RP-023, similar to the approach taken with the August 2019 Notice on the request from Globalstar Canada for low-power ATC systems in the 2483.5-2495 MHz band.
3. Policy and technical considerations
Satellite communication continues to be an important component of the Canadian telecommunications infrastructure, contributing to communication and safety services in many dispersed and remote communities and areas in Canada. Ligado Canada has been a supplier of MSS communications in Canada since 1997. As per RP-023, Ligado Canada will be required to maintain its MSS in Canada.
3.1 The Ligado Canada ATC application
In its ATC application, Ligado Canada seeks an authorization to deploy ATC in Canada with technical parameters similar to those contained in the 2020 FCC Order and Authorization. Specifically, Ligado Canada requests to deploy and operate ATC in 30 MHz of its MSS spectrum, namely 1526-1536 MHz in the MSS downlink, and 1627.5-1637.5 MHz and 1646.5-1656.5 MHz in the MSS uplink bands. The proposed ATC system will operate in forward-band mode as defined in RP-023. The upper edge of the ATC base station downlink frequency band in the 1526-1536 MHz is 23 MHz away from the lower edge of the nearest radionavigation satellite service (RNSS) allocation.
Ligado Canada indicates that there has been active development of L-band ATC systems in the U.S. since the 2020 FCC Order and Authorization. In June 2021, Ligado Networks completed the process of establishing a standard for an equipment ecosystem in “Band 24” within 3rd Generation Partnership Project (3GPP), based on the technical rules specified in the 2020 FCC Order and Authorization, for use as 5G-New Radio (“NR”). Ligado Networks is also working on a trial deployment in the U.S.
ISED is seeking general comments on the Ligado Canada ATC application.
3.2 Specific proposals in the Ligado Canada ATC request
In Ligado Canada’s ATC request, there are a number of areas for which Ligado Canada proposes different conditions than those in the 2020 FCC Order and Authorization. Among these, Ligado Canada requests to be exempted from the dual-mode requirement; to operate ATC base stations at a higher equivalent isotropically radiated power (EIRP) level in the downlink direction in the 1526-1536 MHz band; and to have the out-of-band emission (OOBE) limits contained in sections 5.4.2 and 184.108.40.206 of Radio Standards Specification RSS-170, issue 3, Mobile Earth Stations (MESs) and Ancillary Terrestrial Component (ATC) Equipment Operating in the Mobile Satellite Service (MSS) Bands, apply to L-band ATC mobile equipment.
3.2.1 Exemption on dual-mode requirement
The current version of RP-023 requires the implementation of dual-mode user equipment. However, in recognition of the evolution of ATC technology, ISED removed this requirement for the 2 GHz band in the 2 GHz Decision and for the 2483.5-2495 MHz band in the Globalstar ATC authorization. The removal of this requirement was motivated by the fact that no cost-effective dual-mode user equipment ecosystem has emerged and that the imposition of MSS requirements would be sufficient to ensure the ongoing delivery of MSS in the absence of a dual-mode requirement. ISED notes that similar factors apply in the L-band.
ISED is seeking comments on the request to waive the dual-mode requirement.
3.2.2 Higher base station downlink EIRP
In the 2020 FCC Order and Authorization, base station EIRP is limited to 9.8 dBW in the 1526-1536 MHz band in order to protect the adjacent band certified helicopter terrain awareness warning system (HTAWS), which is mandatory in the U.S. The use of HTAWS is currently not mandatory in Canada; however, due to several recent accidents and incidents involving helicopters, the HTAWS requirement is currently under review at Transport Canada (Reassessment of the Response to TSB Recommendation A16-10, Transportation Safety Board of Canada [PDF: 259 KB]) to potentially be added as a requirement for helicopters.
In its ATC application, Ligado Canada requests a base station EIRP limit of 28.9 dBW in the 1526-1536 MHz band, on the basis that HTAWS is currently not mandatory in Canada. It stated in its application that such an EIRP level is sufficient to protect RNSS operations and limited use cases of certified HTAWS. ISED invites comments on this request.
ISED is seeking comments on the request for a base station EIRP limit of 28.9 dBW in the 1526-1536 MHz band.
3.2.3 Different OOBE limits for mobile user equipment
The existing OOBE limits for the L-band in RSS-170 were established in 2011, based on the decision to harmonize with the U.S. rules at that time. In 2020, U.S. OOBE limits were tightened in order to account for concerns from incumbents in the adjacent band; as provided in the 2020 FCC Order and Authorization, the current OOBE limits for Ligado Networks ATC operations in the U.S. vary over a range of frequencies and are more stringent than the current OOBE limits in RSS-170. It would be reasonable to expect similar concerns in Canada with the introduction of ATC in the L-band, given similar global navigation satellite system (GNSS) use in both countries.
Ligado Canada requests that its ATC user terminals transmitting in the 1627.5-1637.5 MHz and 1646.5-1656.5 MHz bands be allowed to follow the OOBE limits contained in the current version of RSS-170, namely at a level no more than -58 dBW/4 kHz at 1 MHz beyond the edge of the equipment channel bandwidth. ISED invites comments on this request.
ISED is seeking comments on the request to operate Ligado Canada’s ATC user equipment in accordance with the RSS-170 OOBE limits for 1627.5-1637.5 MHz and 1646.5-1656.5 MHz bands in lieu of the more stringent OOBE limits contained in the 2020 FCC Order and Authorization.
3.3 Other considerations
Given ongoing concerns regarding potential interference to adjacent band RNSS operations, Ligado Networks’ authorization in the United States is subject to a number of conditions (FCC 20-48, paragraphs 131-155), which are not addressed in Ligado Canada’s ATC application to ISED. In particular, in the U.S., Ligado Networks is required to support and coordinate with affected federal RNSS users, and to retrofit affected equipment consistent with their needs. There are also requirements for maintaining a base station database, testing and monitoring of transmit power levels, and reporting (such as ATC operation and interference complaints).
In Canada, the receivers used by the Canadian GPS users are similar to, if not the same as, those used by their U.S. counterparts. As such, conditions to support and coordinate with affected federal GPS users imposed by the FCC to Ligado Networks may be relevant to Canadian government GPS users. Conditions such as those for maintaining a base station database, testing and monitoring of transmit power levels, and reporting could also be necessary for spectrum management and interference mitigation purposes in Canada.
In addition to conditions intended to safeguard RNSS use, in the U.S., Ligado Networks is also required to ensure the availability of its MSS and commercially competitive 5G satellite/terrestrial services and devices. Ligado Networks must dedicate at least 6 MHz of its MSS L-band spectrum exclusively to satellite services across the U.S., and ensure both integrated MSS/ATC devices and satellite-only devices, as well as its satellite(s), are capable of operating across its L-band MSS spectrum. Finally, Ligado Networks is also required to make available dual-mode MSS/ATC capable L-band IoT devices by September 30, 2024.
As these conditions are not covered in the Ligado Canada’s ATC application, ISED invites comments on the applicability of these conditions and on any other issues or conditions not covered by the application.
ISED is seeking comments on any other considerations, including those mentioned above.
4. Submitting comments
ISED is soliciting comments and feedback on Ligado Canada’s application and on section 3 of this notice. Feedback on section 3 will be helpful in developing proposals for future consultations on comprehensive amendments to RP-023.
To ensure consideration, respondents should submit their comments by November 18, 2022. Respondents are requested to provide their comments in electronic format (Microsoft Word or Adobe PDF) by email to firstname.lastname@example.org.
All submissions should cite the publication date and the title of this notice. Soon after the close of the comment period, all comments received will be posted on ISED’s Spectrum Management and Telecommunications website.
As all comments will be posted on ISED’s Spectrum Management and Telecommunications website, respondents are asked to not include confidential or private information in their submissions.
All comments will be reviewed and considered by ISED in order to arrive at a decision regarding the above-mentioned request. The decision will be posted on ISED’s Spectrum Management and Telecommunications website.
Engineering Planning and Standards Branch