Decision on Amendments to Requirements for Spectrum Licensees to Submit Technical Information about Sites

1. Through the release of this document, Innovation, Science and Economic Development Canada (ISED), on behalf of the Minister of Innovation, Science and Industry (the Minister), announces decisions resulting from the consultation process undertaken in Canada Gazette Notice DGSO-001-22, Consultation on Amendments to Requirements for Spectrum Licensees to Submit Technical Information about Sites (the Consultation).

2. Comments and reply comments were received from:

• Bell Mobility Inc. (Bell Mobility)
• Bragg Communications Inc. (Eastlink)
• Radio Advisory Board of Canada (RABC)
• Rogers Communications Canada Inc. (Rogers)
• SSi Micro Ltd. (SSi Canada)
• TELUS Communications Inc. (TELUS)
• Xplornet Communications Inc (Xplornet)

3. The Minister, through the Department of Industry Act, the Radiocommunication Act and the Radiocommunication Regulations, with due regard to the objectives of the Telecommunications Act, is responsible for spectrum management in Canada. As such, the Minister is responsible for developing national goals and policies for spectrum utilization and for ensuring effective management of the radio frequency spectrum resource.

4. Under subparagraph 5(1)(a)(i.1) of the Radiocommunication Act, the Minister may issue spectrum licences in respect of the utilization of specified radio frequencies within a defined geographic area. The Minister may fix or amend the terms and conditions of any such licence. Furthermore, the Minister may, under subparagraphs 5(1)(h) and (i), require spectrum licence holders to disclose such information as is deemed appropriate respecting the present and proposed use of radio apparatus, as well as any material changes to the aforementioned information.

5. ISED issues spectrum licences to authorize the use of a specific frequency/frequencies or a frequency block(s) within a defined geographic area(s) under certain conditions. Once authorized, licensees are permitted to establish and modify their radiocommunication networks, while adhering to the conditions of the spectrum licence. Currently those conditions of licence require licensees to follow section 5.11 of Client Procedures Circular (CPC) CPC-2-1-23, Licensing Procedure for Spectrum Licences for Terrestrial Services. Under the CPC, licensees are required to submit technical information associated with radiocommunication installations covered by the spectrum licence (referred to hereafter as site data). The information collected through the submission of site data is used by ISED in support of compliance verifications, interference investigations, as well as international coordination efforts along shared borders. The information is also used by licensees in support of inter-operator domestic and international coordination, as well as tower and site sharing between licensees as per the requirements set out under CPC-2-0-17, Conditions of Licence for Mandatory Roaming and Antenna Tower and Site Sharing and to Prohibit Exclusive Site Arrangements.

6. In March 2022, ISED published its Consultation on Amendments to Requirements for Spectrum Licensees to Submit Technical Information about Sites, which sought comments on proposed changes to the reporting requirements set out in section 5.11 of CPC-2-1-23 and its associated conditions of licence, as well as changes to site data elements set out in annex B of CPC-2-1-23. Through these proposed changes, ISED sought to provide greater clarity to licensees on the technical information they must supply, and to improve ISED’s ability to carry out its spectrum management and enforcement responsibilities. ISED also sought to address industry concerns about the reliability of the technical data collected, as well as a number of suggestions meant to improve the efficiency and useability of the upload system.

7. In the Consultation, ISED proposed to make a series of modifications to the list of required site data elements set out in annex B of CPC-2-1-23. These changes are intended to ensure that ISED’s data collection practices remain relevant to its current information needs, capturing growing equipment diversity, adapting to reflect evolving 5G requirements and other new technologies, ensuring effective interference management and coordination amongst licensees, and facilitating mandatory tower and site sharing activities.

8. The decisions set out in this document are motivated by a growing need to substantially improve data quality, reliability and uniformity within the Spectrum Management System (SMS). High quality data is data that is complete, accurate and current. ISED has sought to prioritize changes to the site data database, which support its ability to conduct meaningful data validations, including the limiting of open text fields and the development of structured response systems. These changes can further streamline the data collection process, while still providing the necessary information for analysis and decision making. Furthermore, the decisions set out in this document recognize that licensees should not be required to submit information, which may be considered redundant, or which can be reasonably accessed through other means.

9. The full list of required site data elements, including the changes set through this decision, can be found in annex A of this Decision. Detailed field descriptions, including standard value formats and data validations will be made available on the SMS website.

5.1 Facilitating site identification and validation during field operations

10. In the Consultation, ISED proposed the introduction of the following four site data elements:

• Cell ID
• Physical Cell ID
• Site Type Code
• Site Structure Type Code

These new data elements are intended to facilitate the visual identification of sites, and differentiate between individual installations in densely deployed areas. This would support ISED’s field operations, including activities related to ISED’s role in interference management.

11. A number of changes to existing data elements were also proposed relating to site identification. ISED proposed to limit the reporting of Structure Height to outdoor sites only. It also proposed to permit the entry of negative values in Tx (transmission) and Rx (reception) Antenna Height to represent underground installations, with a generic input option available when the exact depth is unknown to the licensee. Finally, it proposed that licensees submit their Latitude and Longitude coordinates in decimal degree format, rather than in degrees-minutes-seconds format.

Summary of comments

12. Stakeholders were broadly supportive of these proposals. Bell additionally recommended that ISED expand Cell ID and Physical Cell ID to also accept data on non-3rd Generation Partnership Project (3GPP) radio technologies. While supportive of the Site Type Code element, Bell recommended an optional field be added for licensees to give a more detailed description of sites identified as “other.” It indicated that this would facilitate site sharing activities and capture future trends. It was supportive of the additional flexibility provided by ISED’s proposed changes to Tx and Rx Antenna Height meant to account for underground installations, including the ability to provide negative values and a generic input. Rogers supported these proposals made by Bell.

13. Bell, Rogers and TELUS supported the proposed change in Longitude and Latitude coordinates to a decimal degree format. Bell commented that this format would decrease the administrative burden on licensees, as it is a more commonly used format in location data sources. TELUS proposed that the site data database require a minimum precision of four and a maximum of six decimal places. TELUS also recommended the adoption of the standard convention of using a negative value to indicate longitudes in the Western Hemisphere. Both Bell and Rogers supported these recommendations.

14. The RABC was supportive of all of ISED’s proposals discussed in this section of the Consultation.

Discussion

15. Benefits could be gained from Bell’s proposal to expand the use of Cell ID and Physical Cell ID to include non-3GPP technologies. However, ISED is of the view that the lack of standard conventions between technologies would severely limit the system’s ability to validate data entries during the upload process. Consequently, the Cell ID and Physical Cell ID data elements will be introduced as described in the Consultation, only collecting data related to 3GPP technology. Similarly, ISED recognizes that the introduction of an open-text field attached to the Site Type Code element, as described by Bell, may capture future trends for that element. However, the use of an open-text field would compromise data uniformity and therefore undermine data validation. As such ISED will instead opt to monitor the use of “other,” and make adjustments to the list of accepted values as needed over time.

16. ISED considers precision in the reporting of location coordinates as key to facilitating site identification and field operations, particularly as the rollout of 5G services increases network densification across Canada. As such, licensees will be required to provide Longitude and Latitude coordinates in the decimal-degree format, and will be expected to adhere to the standard Cartesian coordinate system, reporting Longitudes in the Western Hemisphere as negative values. Licensees will be expected to provide at least four decimal places of precision (allowing for less if coordinates are exact). Where greater precision is required for site identification or to manage coordination, licensees may provide up to seven decimal places.

17. Recognizing that there was general support for the other proposals presented in this section of the Consultation, ISED will introduce the Site Structure Type Code as it was proposed in the Consultation and implement the proposed changes to the Tx and Rx Antenna Height data elements.

Decision

5.2 Facilitating identification and compliance of on-site radio technology

18. ISED consulted on certain proposals meant to ensure the SMS keeps pace with innovation in the radio equipment ecosystem. The Radio Technology field was proposed to facilitate the assessment of how radio equipment at a station is operated in the field. The Radio Certification Number was proposed to help with the identification of specific radio equipment (transmitters, receivers). ISED also proposed to modify the Tx and Rx Radio Model Number elements to collect the hardware version identification number (HVIN). Finally, ISED proposed to update the coding systems for the Tx and Rx Radio Manufacturer Code fields and the Tx and Rx Antenna Manufacturer Code fields to ensure that all manufacturers of authorized equipment could be captured within these fields. For the Tx and Rx Radio Manufacturer Codes, ISED proposed that licensees use the company number given by ISED’s Certification and Engineering Bureau (CEB). For the Tx and Rx Antenna Manufacturer Codes, ISED suggested that a new data extract containing an extensive list of manufacturers of authorized antenna equipment might be made available on the SMS website.

Summary of comments

19. Bell was supportive of the introduction of the Radio Technology data element, and recommended that ISED consider the addition of an optional descriptive field for entries indicated as "Other." It submitted that this would provide valuable information for the industry and reduce the need to continuously update the list of valid entries as new technologies emerge. Rogers supported this proposal by Bell, further noting that the descriptive field would reduce the need for inter-operator coordination.

20. Bell recommended that the SMS database be linked to ISED’s Radio Equipment List (REL) database such that licensees be required to provide only the Radio Certification Number, while Tx and Rx Radio HVIN and Tx and Rx Radio Manufacturer Code elements would be pre-populated by ISED. Both Rogers and Xplornet supported this proposal in their reply comments. Bell also supported the introduction of a new data extract made available on the SMS website for use in populating Tx and Rx Antenna Manufacturer Code.

21. TELUS commented that the current radio and antenna manufacturer code tables, available on the SMS website, are not comprehensive. It supported the use of manufacturer codes, HVIN, or certification numbers as forms of identification provided that a clear, complete and easily accessible radio and antenna equipment database is made available to the public. Rogers was supportive of TELUS’ proposal, adding that this would improve the accuracy of data uploaded to the SMS.

22. The RABC was supportive of all of ISED’s proposals in this section of the Consultation.

Discussion

23. To the extent possible, ISED will seek to prioritize the collection of data which can be validated automatically during the upload process. The use of an open-text field in the Radio Technology field would compromise data uniformity and therefore undermine data validation. As such, ISED will move forward with the Radio Technology data element as initially proposed, without an optional descriptive field, and will revise the list of valid entries as needed.

24. While there is a connection between the Radio Certification Number and the Radio HVIN, a single certification number may have multiple HVIN numbers attached to it. Similarly, multiple manufacturers could produce equipment with the same HVIN. This means that the Radio HVIN cannot be inferred from the Radio Certification Number, or vice versa. For these reasons, licensees will be required to provide both the Radio Certification Number and the Tx and Rx Radio HVIN. Licensees using equipment exempt from certification will be required to provide a generic entry for the Radio Certification Number, designated by ISED, identifying the equipment as being exempt from certification. Similarly, in instances where a licensee is operating equipment exempt from certification without an HVIN, they will need to supply the manufacturer’s radio model number.

25. The proposed changes to the Tx and Rx Radio Manufacturer Code fields and Tx and Rx Antenna Manufacturer Code fields were meant to ensure that data collected on radio and antenna equipment in the site data database is clear and comprehensive. For this reason, ISED proposed that licensees use the CEB’s company code as the manufacturer’s code in the Tx and Rx Radio Manufacturer code fields. Use of the CEB’s company code as a coding system will support the development of a more comprehensive list of radio equipment. The CEB’s company code is also found in the first half of the Radio Certification Number. As such, when licensees provide a Radio Certification Number they will not be required to also provide data for the Tx and Rx Radio Manufacturer Code. For equipment exempt from certification, licensees will be required to provide a generic entry, designated by ISED indicating the equipment is exempt from certification.

26. ISED also proposed that a new system be developed for the Tx and Rx Antenna Manufacturer Code fields. However, a comprehensive list of antenna manufacturers is not currently maintained by ISED. As such, these data elements will allow for open-text entries for the time being, ensuring that entries collected remain current and comprehensive moving forward. ISED will revisit the possibility of generating a codified list in the future.

Decision

5.3 Adapting site data collection requirements to the deployment of 5G networks and MIMO technology

27. ISED proposed a number of changes to reflect the increase in deployments of multiple input and multiple output (MIMO) and active antenna systems (AAS) technology with beam-forming and beam-steering capabilities. ISED proposed to introduce the Antenna Type Code, the Number of Tx and Number of Rx Antenna fields, as well as the Tx and Rx Antenna Vertical Beam and Tx and Rx Antenna Horizontal Beam fields. ISED proposed the introduction of the Downlink Resource Allocation element in support of GL-01, Guidelines for the Measurement of Radio Frequency Fields at Frequencies From 3 kHz to 300 GHz. ISED sought proposals on what an optional field related to Time Division Duplex (TDD) systems synchronization might look like. Finally, ISED proposed changes to the information collected in the Transmitter Output Power (to be renamed Transmitter TCP-TRP) and the Tx Antenna Gain and Rx Antenna Gain fields to accommodate the different types of technologies.

Summary of comments

28. Bell expressed support for many of these proposals, stating that they would provide useful information about both AAS and MIMO technology. Both Bell and TELUS were supportive of ISED’s proposal to repurpose the Transmitter Output Power element as Transmitter TCP-TRP, with TELUS recommending that ISED be very clear in its instructions about the exact intent of this element to ensure that the correct data is provided.

29. While TELUS agreed that the Number of Tx Antennas, Number of Rx Antennas, Tx Antenna Gain, Rx Antenna Gain, Tx Antenna Vertical Beam, and Tx Antenna Horizontal Beam elements would all potentially contain useful data, it felt it was unnecessary for licensees to be required to provide it. It put forward that these data elements were technical parameters associated with the system design and inherent to the radio equipment, rather than operational parameters configured by a licensee. As such, it asserted that the required information is already gathered by the CEB during the equipment certification process. TELUS suggested that ISED cross-reference the REL with the certification records associated with the Tx Radio HVIN and Radio Certification Number fields, and thereby auto-populate the site data database. Bell and Rogers supported these comments. Bell indicated that licensees should only be required to upload the radio model or manufacturer number, with ISED cross-referencing internal databases to detect the other relevant AAS parameters.

30. In response to ISED’s request for comments on how the site data upload might include the collection of data related to TDD systems, Bell proposed the introduction of three new elements: Downlink-Uplink Configuration, TDD Special Sub-frame, and Frame Offset. Together, according to Bell, they would facilitate coordination activities between licensees. Bell recommended that ISED make these fields mandatory as, in its view, the increasing use of TDD systems will make proper synchronization key to reducing interference issues and increasing spectral efficiency. Rogers supported this proposal.

31. The RABC was supportive of all of ISED’s proposals in this section of the Consultation. No comments were submitted about the proposed introduction of the Antenna Type Code element or the Downlink Resource Allocation element.

Discussion

32. The Number of Tx Antennas, Number of Rx Antennas, Tx Antenna Gain and Rx Antenna Gain for AAS are understood to be equipment parameters that cannot be changed by licensees during regular operation of the equipment. While a subset of these antenna specifications may be made available to ISED during the radio certification process performed by the CEB, it is not currently feasible for ISED to cross-reference and auto-populate this data within the SMS. This would also not account for uploads of non-AAS deployed by operators. As such, licensees will be required to provide the associated data for these elements as described in the Consultation. As ISED makes further improvements to data collection and storage in the future, the need for these requirements may be revisited.

33. ISED considers Tx Antenna Vertical Beam and Rx Antenna Vertical Beam, as well as Tx Antenna Horizontal Beam and Rx Antenna Horizontal Beam, to be operational parameters that may be adjusted by licensees when the equipment is put into use. As such, ISED will require that licensees report on these parameters as they are used in the field.

34. ISED takes note of the detailed proposal submitted by Bell on data collection related to TDD systems. As the use of TDD systems increases in Canada, so too will the possibility for licensees to coordinate via synchronization with other operators in order to maximize spectrum usage efficiency within their own networks. While acknowledging the benefits of facilitating operator-to-operator coordination through the three additional fields proposed (i.e. Downlink-Uplink Configuration, TDD Special Sub-frame, and Frame Offset), due to the variability and lack of standardization between different generations of technology, any data collected may not be validated to ensure its accuracy. For this reason, ISED will not introduce the additional site data elements proposed by respondents for synchronization of TDD systems at the current time.

35. ISED will proceed with the introduction of the Antenna Type Code and Downlink Resource Allocation data elements as they were initially proposed in the Consultation, as well as renaming Transmitter Output Power to Transmitter TCP-TRP, and changing the reporting format from Watts to dBm. ISED notes TELUS’ request for clarity about the exact intent of Transmitter TCP-TRP, and will publish updated detailed descriptions of all site data elements on the SMS website prior to the new requirements coming into effect.

Decision

5.4 Facilitating identification and coordination on matters related to mandatory antenna tower and site sharing

36. ISED proposed to introduce two new data elements, Site Control and Site ID, to facilitate the validation of antenna tower and site sharing processes under CPC-2-0-17, Conditions of Licence for Mandatory Roaming and Antenna Tower and Site Sharing and to Prohibit Exclusive Site Arrangements. ISED also proposed to include the Email Address data element in the site data download available on the SMS website.

Summary of comments

37. Bell, the RABC, Rogers, and TELUS all expressed concerns about the quantity and complexity of work that would be required of licensees to provide the Site Control and Site ID information. They asserted that the process of identifying, coordinating, and merging data, particularly data related to third-party (non-licensee) sites for these fields would be onerous and time consuming. While no submissions opposed to the introduction of the Site Control field, there were a number of questions and concerns about its specifications.

38. Bell and the RABC signaled that locating the required information for these two fields would be challenging, and that this might hinder a timely transition to the new reporting requirements. While TELUS supported the introduction of both Site ID and Site Control, it contended that ISED should allow sufficient time for licensees to undertake the information-gathering activities required for proper compliance. Bell recommended that ISED allow licensees a period of 24 months following the publication of the decision, to implement changes so as to be able to provide data for both the Site ID and Site Control data elements.

39. The RABC had no objections to the Site Control element, but cautioned that its administration may be onerous for some operators. Rogers expressed general support of the RABC’s views on both Site Control and Site ID, and proposed that non-licensee entities should be entered as such in Site Control, and Site IDs should be determined by licensees and not third-party site owners. Rogers also stated that licensees would require a longer transition period than that proposed by ISED, should Site ID or Site Control be introduced.

40. Bell and the RABC also expressed concerns about Site ID duplication, wherein two sites, controlled by two different entities, have the same Site ID. Bell suggested that industry-standard naming conventions may be required, and pointed out that where third parties do not have Site IDs, the licensee may require time to obtain a Site ID. TELUS, supported by Rogers, proposed appending a company identifier to each Site ID to eliminate the possibility of overlapping Site IDs. The RABC believed that the implementation of a coordinated Site ID system for shared sites would be unfeasible at this time, being onerous and potentially error-prone.

41. Respondents were generally supportive of proposed changes to the Email Address field. Bell requested that licensees be permitted to provide a new email address to ISED, if they choose, after the transition period. TELUS pointed out that the proposed purpose of the email element as a means of facilitating site sharing differs significantly from its current use facilitating the resolution of data upload issues. TELUS considered the current use of the field redundant given that licensees already provide an email address during the login process. As such, TELUS recommended ISED clearly communicate the change of intent to this field to ensure the correct information is entered. Rogers proposed that licensees be given an option to provide more than one email address, in order to better differentiate between the different possible uses of this field.

Discussion

42. ISED takes note of the concerns expressed by stakeholders about the introduction of both the Site Control and Site ID data elements. ISED acknowledges stakeholder concerns that the implementation of these data elements, as described in the Consultation, may be onerous for licensees and may require a longer transition period than that which ISED proposed in the Consultation.

43. Given these concerns, ISED will employ an alternative means of collecting some of the key information, which was to be provided through the Site Control data element. As such, ISED will not require licensees to report on Site Control.

44. ISED acknowledges that there were many concerns about the Site ID element, particularly related to the significant level of coordination, which would be required among licensees, as well as between licensees and third-party site owners.

45. However, ISED maintains that there is value in the introduction of a data element for the purpose of identifying individual installations with a greater level of precision than is presently possible within the SMS. Greater precision would facilitate communication between licensees as well as between licensees and ISED, including in the provision of validations and feedback during the upload process.

46. For these reasons, ISED has decided to revise the proposed Site ID field, renaming it Site Record ID. For this data element, licensees will be required to provide a unique identifier for each service (e.g. 4G PCS, 5G AWS, etc.) at a given location where radiocommunication equipment is installed. Each service will be identified by a Site Record ID, which is unique within that licensee’s network. Licensees will not be required to coordinate naming conventions with other licensees. This field will help with identification of installations and communication between ISED and licensees, as well as among licensees. It will also facilitate future data processing automation efforts.

47. As TELUS observed, the Email Address site data element has been used by ISED to provide a point of contact to aid in the resolution of data upload issues. ISED would like to maintain the use of this field to that end, while also providing a point of contact to facilitate communication between licensees on matters related to antenna tower and site sharing, and domestic and international frequency coordination. As such, ISED will allow licensees to provide multiple email addresses, as needed. Details will be provided in an upcoming specification of technical requirements on the SMS website.

Decision

5.5 Simplifying or phasing out reporting requirements

48. ISED proposed to remove the Administrative District Office of the Account Number, Zone Enhancer Indicator, Station Data, Tx Upper Frequency Limit, Rx Upper Frequency Limit and Date of Last Modification data elements. ISED also proposed to make the Upload Reference Number optional, and to remove the version or issue number portion of the Spectrum Licence Number.

49. ISED further proposed that the Company Code (Account Number) would be renamed Account Number, and the Telephone Number and Telephone Extension Number elements would be combined into a single field. It also proposed to change the Site Elevation element into an auto-populated field, using ISED’s internal terrain database. Finally, it proposed that the Tx Channel Frequency or Lower Frequency Limit and Rx Channel Frequency or Lower Frequency Limit be renamed as Tx Channel Frequency and Rx Channel Frequency and both elements would be scaled down to collect only the centre frequencies of the occupied bandwidth for a given licence.

Summary of comments

50. Licensees were generally supportive of ISED’s efforts to reduce or simplify reporting requirements where possible. Rogers and TELUS proposed that ISED also consider removing the Company Code (Account Number) field from the upload system entirely, as this information can be determined using the licence number.

51. Bell, Rogers and TELUS supported the use of a single method of specifying the transmission and reception of frequency ranges, as described in ISED’s proposal for the Tx Channel Frequency and Rx Channel Frequency fields. However, they believed that ISED should allow licensees to upload the centre frequencies and occupied bandwidths that correspond to their actual system configurations, rather than the centre frequencies of the occupied bandwidth for the licence with which the installation is associated. They suggested that this method would be simpler for licensees, and TELUS suggested that if this were implemented, licensees would no longer need to specify the licences or account numbers in their uploads.

52. No specific comments were submitted about the proposed changes to the following elements: Administrative District Office of the Account Number, Zone Enhancer Indicator, Station Data, Site Elevation, Upload Reference Number, Spectrum Licence Number, Telephone Number, Telephone Extension Number, Tx Upper Frequency Limit and Rx Upper Frequency Limit.

Discussion

53. ISED recognizes, as noted by Rogers and TELUS, that the Company Code (Account Number) can be inferred through the Spectrum Licence Number. As such, ISED will proceed to rename this element as Account Number and will also populate it within the site data download.

54. ISED is aware that licensees may have stations, which operate in frequencies that span multiple licence blocks, and as a result, a single station may have multiple entries, one for each block of licensed spectrum in use at that station. ISED recognizes that in these instances requiring licensees to provide the centre frequency of the occupied bandwidth for each licence during the data upload process may be a more complex process than providing the centre frequencies associated with their actual system configurations.

55. However, licences are the core unit on which the spectrum management system functions, and licensees have an obligation to account for all sites associated with each individual licence. In instances where a system configuration is authorized through multiple licences, each licence has a separate status within the SMS, including separate licence terms and associated conditions of licence. In order for ISED to conduct effective verification of licensees’ compliance with their conditions of licence, it is important that a strict relationship is maintained of one licence per record provided in the SMS, and that a separate record of an installation exists for each licence in use at that installation. ISED will therefore proceed with the changes proposed in the Consultation for the Tx Channel Frequency or Lower Frequency Limit and Rx Channel Frequency or Lower Frequency Limit elements.

56. ISED will also proceed with changes to the following site data elements as initially proposed in the Consultation: Administrative District Office of the Account Number, Zone Enhancer Indicator, Station Data, Site Elevation, Upload Reference Number, Spectrum Licence Number, Telephone Number, Telephone Extension Number, Tx Upper Frequency Limit and Rx Upper Frequency Limit.

57. The information collected by the Date of Last Modification field remains useful for matters of coordination and interference management for both ISED and licensees. For this reason, ISED will retain the Date of Last Modification field. Licensees will be required to provide ISED with the date at which last technically relevant change was made to the service parameters under which an installation is currently operating.

Decision

58. In the Consultation, ISED proposed to introduce a number of policy changes meant to standardize and clarify its expectations toward licensees, and also sought proposals on how to improve the site data collection process for licensees.

6.1 Upload frequency

59. ISED proposed to standardize its requirements regarding the frequency of site data uploads in order to improve the accuracy and timeliness of the information in its databases. It was proposed that all licensees should be required to provide technical information:

• within one month of the issuance of a licence
• on a monthly basis
• whenever changes are made to a radiocommunication installation, which modify the related data
• prior to each site becoming operational

60. ISED also requested comments on how licensees might distinguish between planned and operational radiocommunication installations within the site data upload.

Summary of comments

General Comments

61. SSi Canada expressed concerns that the combined proposed upload frequency requirements could prove quite onerous to some licensees. They asked that ISED review its proposal to ensure that the proposed requirements were all necessary. Eastlink indicated that the frequency timelines proposed by ISED seemed generally appropriate.

Upload within one month of the issuance of a licence

62. Bell, Rogers and Xplornet were opposed to ISED’s proposal. Bell contended that further reporting requirements would be burdensome and mark a significant departure from the current upload process, requiring licensees to provide data based on licences rather than based on sites. The RABC had no objection to the introduction of this requirement, so long as the required action was simple, straightforward, and quickly conducted.

63. TELUS supported ISED’s proposal, believing it would provide a useful check to licensees, highlighting licences for which they have not yet uploaded site data. They suggested the use of a separate tool containing a list of active licences with no recorded active deployments. Licensees would use this tool to validate their possession of one or more of licences and confirm the lack of initial deployments. Bell and Xplornet were opposed to the TELUS proposal, with Bell asserting that the development of such a process would require specific input from licensees.

Upload on a monthly basis

64. The majority of respondents were supportive of this requirement (Bell, Eastlink, TELUS, Rogers). Xplornet recommended different reporting frequency requirements for high frequency spectrum (6 GHz or higher) versus mid/low frequency spectrum (below 6 GHz). They contended that more frequent (monthly) reporting requirements would be appropriate for high frequency spectrum that is more likely to see rapid deployment. They claimed that low- and mid-band spectrum deployments were likely to progress more slowly, such that uploads were really only necessary every six months. Bell disagreed with Xplornet’s proposal, and maintained that monthly uploads would be appropriate across all types of sites.

Upload whenever changes are made to a site which affect the associated data

65. Bell, Rogers and Xplornet were opposed to this requirement. Bell and Rogers asserted that the monthly upload requirement would be sufficient to manage interference or other matters, and additional requirements would be both impractical and burdensome. Xplornet further submitted that such a requirement would be unverifiable and therefore unenforceable. TELUS supported this requirement, contending that it is critical that the site data database be both accurate and complete in order to facilitate coordination and support interference management.

Upload prior to each site becoming operational

66. Stakeholders who submitted comments on this requirement were opposed to it, with the exception of TELUS who held some reservations about the proposal as formulated in the Consultation. Respondents contended that the location and parameters of future sites are commercially sensitive information which, if shared publicly, would have potentially negative impacts on market competition. Furthermore, technical information on future sites would be of limited operational value, as these parameters are often subject to change up to the time of the site’s activation.

67. Bell and Rogers contended that these requirements would impose additional administrative burdens on licensees, while Xplornet submitted that it would be impossible to verify compliance, rendering these requirements unenforceable. Rogers further expressed concerns that certain licensees could misuse this feature to protect their own spectrum interests, and foresaw complications and building delays in the event that the SMS was unavailable for a prolonged period of time. Rogers also asserted that planned sites would not be a reliable indicator of spectrum availability for prospective access licensing, as entries may not paint an accurate picture of long-term deployment plans.

68. Eastlink proposed that the “prior to each site becoming operational” condition should be revised to require that reporting begin “prior to or within 5 days of each site becoming operational” to allow more flexibility for the licensee in meeting their reporting requirements. Bell disagreed with this proposal.

How to distinguish between planned and operational sites

69. Bell expressed concern about the confidentiality of commercially sensitive information and the potential effects on competition, if ISED were to implement the proposal regarding planned sites. To remedy this, Bell proposed the addition of a field to identify confidential records, removing them from the public database.

70. The RABC strongly objected to ISED’s proposal but indicated that it would support an option including three separate flags for records:

1. Private Data (do not publish), non-operational site
2. Public Data (may be published), non-operational site
3. Operational site (always public, always published)

It stressed that, to avoid the publication of commercially sensitive data, data publication should only occur if the licensee actively selected options b or c. TELUS proposed a similar identification system for distinguishing planned and operational sites. TELUS further posited that reporting on planned sites should be optional, and the resulting records should only appear publicly if a licensee expressly consented to their publication. Rogers similarly recommended that any field identifying planned sites should be optional and on a confidential basis only.

71. SSi Canada proposed that, if necessary, ISED could develop a separate tool for reporting on planned sites. The information provided could not be made publicly available, and the responsibility for identifying potentially conflicting plans and future interference management issues would then fall upon ISED.

Discussion

72. In order for the technical database of radiocommunication installations to be an effective tool for both ISED and licensees, the information it contains must be properly maintained and remain up-to-date. It is for this reason that ISED proposed to introduce a set of standard site data upload frequency requirements across spectrum licences.

73. A uniform approach to upload frequency requirements will provide licensees with clear and consistent expectations, while also simplifying the compliance verification process considerably. As such, ISED will not be adopting Xplornet’s recommendation to impose different requirements for different spectrum frequency ranges. Rather, all spectrum licences for terrestrial services containing a condition of licence related to the provision of technical information will have the same site data requirements, including upload frequency requirements, as will be set out in the site data CPC, as described in section 6.3 below.

74. In order to ensure timely and comprehensive data within the database, ISED is of the view that monthly uploads are an acceptable requirement for all spectrum licensees. This will strike an appropriate balance between the need for up-to-date data to support operational activities, and the need for licence conditions that are reasonable for licensees.

75. ISED agrees that a requirement to upload new site data immediately upon making a change to an existing site may, in practice, bring about certain challenges in its application. As such ISED will not move forward with introducing this requirement. The monthly upload will ensure sufficiently recent data in the system. Licensees may nonetheless choose to update their site data more frequently, and are encouraged to ensure that operational site listings are up-to-date at all times.

76. ISED notes the general concerns expressed by some stakeholders regarding the proposal to require reporting within one month of the issuance of a licence. However, ISED must be able to distinguish between whether a licensee has failed to comply with its site data reporting requirements or whether a licensee has made no deployments in the reporting period. For these reasons, ISED will require that site data reporting begin within one month of the issuance of any licence. In this context, this is understood to include new licences issued for the first time in a licence area, licences issued after a renewal process, or licences that have been issued as the result of transfer request, including subordinate licences. ISED agrees with the RABC that such a process should be simple and quick to complete, and more generally seeks to ensure that demands on licensees remain reasonable. As such, ISED is developing a functionality that will enable licensees to provide simple confirmations if there are no operational sites for a given licence.

77. ISED acknowledges the strong concerns raised by stakeholders about introducing a requirement to report on future or planned deployments. Consequently, licensees will not be required to provide data on sites prior to their operation.

Decision

6.2 Means of submitting technical information

78. ISED proposed to use the Comma Separated Values (.CSV) file format as the exclusive file format for the submission of technical information. It also proposed that licensees be required to use the upload system provided, unless ISED specifically approves another method under specific circumstances, with appropriate justification provided.

Summary of comments

79. Those that responded to this proposal were generally favourable to standardizing the exclusive use of the .CSV file format. Bell, the RABC, Rogers and TELUS stated their support for the proposal, and other respondents raised no objections.

80. The response to the required use of the upload system was also generally favourable. Bell agreed with the proposal, while Xplornet encouraged ISED to be flexible if accommodations are requested by licensees. TELUS objected on the grounds of past difficulties with the current upload system. It requested that ISED dedicate additional resources to support licensees experiencing difficulties with the upload process, should the existing system be maintained. TELUS stated they would support the use of an improved upload system as the sole means of uploading site data, should this system integrate TELUS’ proposed improvements.

Discussion

81. ISED considers that standardizing the submission of technical information will help support a more reliable and streamlined upload process for all licensees. As it is simple, widely accessible, and already the most commonly used format by the industry, it is appropriate to make .CSV the exclusively accepted file format for site data uploads at the present time. As technology advances, ISED may review the file format to be used in the future and will advise licensees through the SMS website.

82. ISED notes the technical challenges that some licensees face in using the SMS. ISED’s decision strikes a balance between the need for a more structured data collection process, and the need for appropriate flexibility for licensees encountering data upload challenges. ISED will continue to explore potential improvements to the process based on user feedback and, in limited circumstances, may consider permitting licensees to temporarily use alternate means of submitting site data.

Decision

6.3 Proposed introduction of a new CPC for site data

83. CPC-2-1-23 addresses a range of procedures concerning the licensing process and requirements of terrestrial licensees. Apart from section 5.11 and annex B of CPC-2-1-23, which concerns the provision of technical information and the list of required site data elements, the CPC2-1-23 also discusses licence fees, licence renewals, transfers and subordinations, coexistence agreements and other measures.

84. ISED proposed that a separate CPC on site data requirements would help licensees become more aware of their requirements and facilitate compliance. In the Consultation, it proposed to migrate the contents of section 5.11, Submission of Technical Information and annex B, Site Data Elements, from CPC-2-1-23 and into a new CPC that is solely focused on site data requirements.

85. In addition, ISED considered if a separate site data CPC might help to support conditions of licence related to site data requirements for certain new earth station spectrum licences, following the SMSE-008-22, Decision on Updates to the Licensing and Fee Framework for Earth Stations and Space Stations in Canada.

Summary of comments

86. TELUS expressed its support for ISED’s proposal to introduce a new CPC specifically for site data. It highlighted that the consolidation of site data requirements into a single, focused document would make it easier for licensees to identify and understand their upload requirements.

87. In its comments, Xplornet contended that current site data elements are designed with terrestrial wireless networks in mind, and earth station licensees should not be required to follow the same reporting requirements. If earth station operators were required to report on the same elements, in many cases, the options “other” or “not applicable” would need to be selected. It recommended that ISED should ensure that any data that earth station licensees are required to submit to the SMS website are consistent with the standard earth station parameters used by the industry and currently provided through the process established in GL-10, Interim Guideline for Licensing of Earth Stations in the Fixed-Satellite, Earth Exploration-Satellite and Space Research Services in the Frequency Bands 26.5-28.35 GHz and 37.5-40.0 GHz. Furthermore, it recommended that specific upload frequency intervals should also be established for earth station spectrum licensees. Finally, it recommended that if ISED determines that earth station licensees should be required to contribute site data, ISED should hold another consultation to assess what site data elements are relevant in relation to earth stations. SSi Canada supported Xplornet’s recommendation for a separate consultation on earth station requirements.

Discussion

88. The establishment of a separate CPC is an opportunity to clearly set out ISED’s expectations on site data to licensees as well as provide direction for compliance and enforcement measures. Furthermore, it will allow ISED to standardize the associated conditions of licence of affected spectrum licences. For these reasons, ISED will proceed with a new CPC as described above. This CPC will apply to all spectrum licences, unless otherwise specified in a spectrum licence’s condition of licence.

89. Technical requirements and related conditions of licence for spectrum licences for generic earth stations were established by ISED in SMSE-008-22, Decision on Updates to the Licensing and Fee Framework for Earth Stations and Space Stations in Canada. As part of that decision, ISED announced its intention to develop a related CPC prior to the implementation of the new earth station licensing regime. This CPC would provide additional direction to licensees on the licensing process, including conditions of licence.

90. ISED recognizes that the technical information needed to properly manage earth station installations is different from terrestrial stations, and that the appropriate list of required data elements for these generic earth stations will differ from terrestrial stations. The new CPC for spectrum licences for generic earth stations is an appropriate venue through which to establish the required site data elements for this specific type of licence. As such, this new CPC, to be established before the implementation of SMSE-008-22, will set out the list of required site data elements for these generic earth stations.

91. The same site data database will be used for both terrestrial stations and generic earth stations, but not all fields will be mandatory for generic earth stations. To accommodate this, ISED will introduce an additional data element that will identify the type of station for which site data is being uploaded.

Decision

6.4 Conditions of Licence

92. In addition to proposing the introduction of CPC-2-1-30, Technical Information Associated with Radiocommunication Installations, issue 1, which is solely focused on site data requirements, ISED also proposed that the related conditions of licence of affected spectrum licenses be updated in accordance with the requirements set out in this Decision.

Discussion

93. One of the objectives of the present consultation process is to improve the consistency with which site data requirements are applied to spectrum licensees. As such, all of the requirements set out in this Decision are intended to apply to all existing spectrum licences for terrestrial services also covered under CPC-2-1-23. By standardizing the condition of licence across different licence bands, compliance is simplified for both licensees and ISED.

94. As such, ISED will modify the associated conditions of licence of affected spectrum licences. The list of existing conditions of licence that will be amended to refer to the site data requirements in CPC-2-1-30 can be found in annex B of this Decision and on the Conditions of licence/Appendices webpage. Furthermore, conditions of licence for spectrum licences issued between the publication of this Decision and the coming into effect of CPC-2-1-30 will also be subject to the same changes, unless ISED specifies otherwise.

Decision

6.5 Improvements to site data upload process

95. ISED invited proposals of other measures which could streamline or improve the site data upload process.

Summary of comments

96. Bell proposed two improvements to the upload process. The first was that licensees have the ability to selectively delete certain records or flag specific records for deletion. The second was that the database be modified to automatically identify the licence associated with a site upload based on the centre frequency, bandwidth and location information.

97. TELUS recommended the creation of a representational state transfer (RESTful) application programming interface (API) that follows the latest Open API Specification and other industry best practices. The goal of this API would be to facilitate site data uploads, the download of site and spectrum licence information, and the deletion of records. Bell, the RABC and SSi Canada also supported an API solution to simplify licensees’ use of the database. Rogers was not convinced that an API would provide additional benefits if new Information Technology (IT) solutions needed to be researched and applied in order to implement new file formats for SMS uploads.

98. The RABC also made a number of proposals on how ISED could improve its current system. It proposed that ISED implement a system that would automatically detect the licence band and service area in an upload file. The RABC proposed that ISED publish geo-referenced files of service areas to resolve issues where coordinates have been rejected by the system, particularly in coastal areas and near service area boundaries. They further proposed that the system provide more specific error logs, as well as warning messages to flag unusual values.

99. SSi Canada urged ISED to invest additional resources into the development of better tools for the provision of robust and accurate data, and to support licensees in what SSi Canada considered a complex and labour-intensive task. TELUS recommended that ISED consider increasing the resources dedicated to supporting licensees that continue to experience difficulties with the current upload system.

Discussion

100. ISED notes the RABC’s request for the publication of additional geo-referenced files of service areas. Licensees wishing to access a copy of their specific licence boundaries, if not already publicly available through the Service areas for competitive licensing webpage, are invited to contact ISED directly (see section 8 of this document), and ISED will provide specific geo-referenced files of service areas upon request.

101. While there is potential value in TELUS’ proposal to develop an API, ISED notes that an API is a relatively complex system, requiring greater technical expertise on the part of licensees. Furthermore, it would require the adoption of specific technologies, rendering the process less accessible to some users than the current system, which only requires the use of a .CSV file. Overall, ISED considers that the use of an API would create a barrier to adoption, and as such, will not implement this proposal at this time.

102. ISED implements continuous improvements to the SMS to support data quality and reliability. For example, it is presently reviewing how and when it validates data within the SMS, and how to provide better feedback to licensees during the data upload process, particularly given the increased number of validations that will occur during the upload process.

103. ISED notes Bell’s request for a simpler and more reliable means of deleting records, and is currently exploring improvements to the upload process that would have the effect of deleting or replacing all previous records associated to a licence. Furthermore, ISED anticipates that the new Site Record ID data element might allow for a greater degree of control over record modification in the future.

104. Recognizing that many users of the SMS have identified several key areas of potential improvement, including error reporting, increased options for data validation or modification, and increased automation, ISED will continue to explore changes in these and other areas meant to improve the reliability and ease of use of the SMS.

105. In the Consultation, ISED proposed a transition period of at least six months following the publication of this Decision. During this period, legacy data would remain in use in the SMS while licensees become familiar with the new and modified site data elements. At the end of this transition period, the requirements set out in this Decision would come into effect and be mandatory for all spectrum licensees. ISED would not transfer legacy entries or data; licensees would be responsible for uploading information in accordance with the new requirements.

Summary of comments

106. The RABC and Rogers were in favour of a six-month transition period. Eastlink and SSi Canada commented that at least six months would be required, and SSi Canada believed that more time could be necessary to account for the development of new tools by ISED to support the transition. TELUS proposed an additional six-month grace period following the implementation of the new requirements in order for licensees to complete data cleanup activities. Bell initially supported a six-month transition period, but later supported TELUS’ proposal in its reply comments and proposed a 12-month implementation period. Xplornet requested a 12-month transition period in order to plan and execute IT development work needed to fully implement the proposed changes. Bell, the RABC, Rogers, and TELUS stated that additional time would be required if ISED implemented either the Site Control or Site ID data elements.

Discussion

107. One impetus for the proposed modifications to site data requirements is to ensure that the site database better reflects global trends, emerging 5G standards and the constantly evolving equipment ecosystem. As 5G deployments have already begun in many Canadian cities, there is a pressing need for ISED to collect accurate and timely data on deployments for the purposes of interference management, and compliance and enforcement.

108. ISED notes that the majority of stakeholders were initially amenable to a transition period of at least six months following the publication of this Decision. It also notes the request from some stakeholders for an additional grace period of up to six months for data cleanup activities. With regard to stakeholders’ requests for a longer transition period due to the proposed Site Control and Site ID data elements, ISED notes that Site Control will not be required and Site ID has since been simplified to favour timely implementation by licensees.

109. Shortly after the publication of this Decision, an updated site data upload system will be made available to licensees, reflecting the new site data requirements. This updated upload system is expected to run concurrently with the existing system for a transition period of six months. During this period, licensees will be able to submit site data using either upload system and follow the requirements set out in either section 5.11 of CPC-2-1-23 or CPC-2-1-30. Licensees should familiarize themselves with the system during this time, and adopt it prior to the end of the transition period.

110. At the end of the transition period, the requirements set out in this Decision will come into effect and the previous upload system will no longer be accessible. From that point on, licensees will be responsible for uploading information in accordance with the new requirements set out in CPC-2-1-30. ISED will not transfer any legacy entries or data. ISED will announce the date at which the new site data requirements come into effect via Spectrum Advisory Bulletin.

Decision

111. All ISED publications related to spectrum management and telecommunications are available on the Spectrum Management and Telecommunications website.

112. For further information concerning the process outlined in this Decision or related matters, contact:

Email: spectrumoperations-operationsduspectre@ised-isde.gc.ca

The following list of technical information will be required of licensees as per CPC-2-1-30, Technical Information Associated with Radiocommunication Installations. Detailed field descriptions, including standard value formats and data validations, will be made available through the Spectrum Management System website.

• Spectrum Licence Number
• Upload Reference Number (optional)
• Contact Name*
• Business Telephone Number*
• Email Address*
• Station Location
• Station Type
• Radio Technology
• Cell ID
• Physical Cell ID
• Province/Territory Code
• Latitude
• Longitude
• Site Type Code
• Structure Height
• Site Structure Type Code
• Date of Last Modification
• Site Record ID
• Tx Channel Frequency
• Rx Channel Frequency
• Tx Radio Hardware Version Identification Number (HVIN)
• Rx Radio Hardware Version Identification Number (HVIN)
• Tx Radio Manufacturer Code
• Rx Radio Manufacturer Code
• Tx Radio Certification Number
• Rx Radio Certification Number
• Bandwidth
• Class of Emission
• Transmitter TCP-TRP
• Downlink Resource Allocation
• Tx Antenna Type Code
• Rx Antenna Type Code
• Tx Number of Antennas
• Rx Number of Antennas
• Tx Antenna Model Number
• Rx Antenna Model Number
• Tx Antenna Manufacturer Code
• Rx Antenna Manufacturer Code
• Tx Antenna Height
• Rx Antenna Height
• Tx Omnidirectional Antenna Pattern Indicator
• Rx Omnidirectional Antenna Pattern Indicator
• Tx Antenna Horizontal Beam
• Rx Antenna Horizontal Beam
• Tx Antenna Vertical Beam
• Rx Antenna Vertical Beam
• Tx Antenna Azimuth
• Rx Antenna Azimuth
• Tx Antenna Elevation Angle
• Rx Antenna Elevation Angle
• Tx Antenna Gain
• Rx Antenna Gain
• Tx Line Loss
• Rx Line Loss

* Note: This contact information will be made publicly available.

The following list of conditions of licence can be found on ISED’s Conditions of licence/Appendices webpage. Generic Earth Station conditions of licence will be defined in an separate CPC.

• G2: 2.3/3.5 GHz Subordinate Spectrum Licences
• H1: Air-Ground Service Spectrum Licences issued via the 800 MHz auction
• H2: 24/38 GHz Spectrum Licences with Extended Term
• H4: Spectrum Licences issued via the 3500 MHz Residual Auction (2009)
• H6: 24/38 GHz - Subordinate Licences
• H9: Broadband Radio Service Subordinate Spectrum Licences
• I3: Personal Communications Services/Cellular long-term spectrum licences issued via the 2011 Renewal Process
• I4: Renewed PCS/cellular Subordinate Spectrum Licences issued via the 2011 Renewal Process
• I6: Interim Broadband Radio Service Spectrum Licences - SSi Micro
• I9: 38 GHz First Come - First Served Spectrum Licences
• J1: 800 MHz Air-ground Subordinate Spectrum Licences
• J6: Spectrum Licences issued via the AWS Auction (2008)
• J7: Broadband Radio Service Spectrum Licences issued via the Conversion From Multipoint Communication System Licences
• J9: Spectrum Licences issued via the 2300 MHz Residual Auction (2009)
• K1: Spectrum Licences issued under RP-019 (New Party Cellular)
• K2: Inukshuk Broadband Radio Service Licences
• K3: Personal Communications Services/Cellular Long-Term Spectrum Licences issued via the 2011 Renewal Process
• K4: PCS/Cellular Annual (interim) Spectrum Licences issued via the 2011 Renewal Process
• K5: PCS/Cellular Long-Term First-Come First-Served Spectrum Licences issued after the 2011 Renewal Process
• K6: Personal Communications Services spectrum licences (Interim) issued to certain members of the Ontario Telecommunications Association
• K7: Spectrum Licences issued via the 700 MHz Auction (2014)
• K8: Subordinate Spectrum Licences issued via the 700 MHz Auction (2014)
• L1: AWS Auction Subordinate Spectrum Licences
• L2: 2.3 GHz Spectrum Licences issued via the 2014 Renewal Process
• L3: 3.5 GHz Spectrum Licences issued via the 2014 Renewal Process
• L5: 3.5 GHz Subordinate Spectrum Licences issued after the 2014 Renewal Process
• L8: Spectrum Licences in 3.5 GHz issued on First-Come First-Served basis after the 2014 Renewal Process
• L9: AWS-4 (Ancillary Terrestrial Component) Spectrum Licences
• L10: 3.5 GHz Spectrum Licences issued via the 2021 Auction or Transition Process
• L12: 3.5 GHz Fixed Wireless Access Spectrum Licences issued after the 2021 Auction
• M1: Spectrum Licences issued via the AWS-3 Auction (2015)
• M2: Ruralcom Corporation Spectrum Licences issued under RP-019 (Updated February 2017)
• M3: Auction Licences - BRS
• M4: BWA 24 and 38 GHz Auction Licences issued as a result of the renewal process of 2014
• N4: Spectrum Licences issued via the AWS-3 Residual Auction (2015)
• N8: 24/38 GHz Subordinate Spectrum Licences Issued After the 2014 Renewal Process
• O2: Spectrum licences issued via the 700 MHz residual auction (2018)
• O3: Spectrum licences issued via the 2300 MHz residual auction (2018)
• O4: Spectrum licences issued via the 2500 MHz residual auction (2018)
• O5: Spectrum licences issued via the PCS-G residual auction (2018)
• P1: 600 MHz Spectrum Licences issued via the 2019 Auction
• P2: 600 MHz Spectrum Licences issued via the 2019 Auction
• P3: AWS-1 Spectrum Licences issued via the 2018 Renewal Process
• P4: PCS Block G Spectrum Licences issued via the 2018 Renewal Process
• P5: I Block Spectrum Licences issued via the 2018 Renewal Process
• P6: AWS-1 Subordinate Spectrum Licences issued via the 2018 Renewal Process
• P7: PCS Block G Subordinate Spectrum Licences issued via the 2018 Renewal Process
• P8: I Block Spectrum Subordinate Licences issued via the 2018 Renewal Process
• P9: AWS-4 (Ancillary Terrestrial Component) Subordinate Spectrum Licences
• Q5: AWS-3 Auction Subordinate Spectrum Licences
• Q6: Air-Ground Service Spectrum Licences issued via the 2018 Renewal Process
• Q8: 3.5 GHz Fixed Wireless Access Subordinate Spectrum Licences
• Q9: 2.5 GHz BRS Non-Auctioned Spectrum Licences issued via the 2020 Renewal Process