Decision on the Technical and Policy Framework for Radio Local Area Network Devices in the 5850-5895 MHz Band and for Intelligent Transportation Systems in the 5895-5925 MHz Band

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 the decisions resulting from the consultation process undertaken in Canada Gazette Notice SMSE-004-22, Consultation on the Technical and Policy Framework for Radio Local Area Network Devices in the 5850-5895 MHz Frequency Band and for Intelligent Transportation Systems in the 5895-5925 MHz Frequency Band (the Consultation).

2. Comments and reply comments were received from:

• 5G Automotive Association (5GAA)
• Agricultural Industry Electronics Foundation (AEF)
• BlackBerry
• Canadian Vehicle Manufacturers' Association (CVMA)
• Car 2 Car Communication Consortium (C2C-CC)
• Continental Automotive Systems, Inc. (Continental)
• Global Automakers of Canada (GAC)
• IBI Group
• Intel Corporation (Intel)
• Jaguar Land Rover
• Meta Platforms, Inc. (Meta)
• Ministère des Transports, Gouvernement du Québec
• Qualcomm
• Radio Advisory Board of Canada (RABC)
• Robert Bosch GmbH (Bosch)
• Rogers Communications Canada Inc. (Rogers)
• SES S.A. (SES)
• TELUS Communications Inc. (TELUS)
• University of British Columbia (UBC)
• Wi-Fi Alliance

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 policies for spectrum utilization and ensuring effective management of the radio frequency spectrum resource.

4. Wireless communication is an important mode of connectivity for Canadian businesses and public institutions, as well as for Canadians. The advances in wireless communications are enabling new high-quality services and technologies to become increasingly integrated into society and leveraged to enable innovative use cases, including safety-related applications. In this context, ISED is committed to the objective that businesses and public institutions have access to the latest, high-quality wireless services and technologies in a competitive market. A robust wireless telecommunications industry not only drives the adoption and use of digital technologies, it also enhances the productivity of the Canadian economy.

5. In making spectrum available, ISED allocates different frequency bands by taking into account factors such as the existing uses of the band and the objective of enhancing services and promoting connectivity in rural and remote areas. ISED also considers international band allocation, the evolution of wireless technology, current and emerging technical standards, and the ecosystem for network and end-user equipment. As a result, Canadians benefit from having access to a much larger global marketplace, economies of scale, high-quality services and innovative applications, and the timely introduction of these services and technologies across the country.

6. Licence-exempt spectrum has witnessed a significant increase in both use and innovative applications due to low barriers to entry and the low cost of licence-exempt devices, such as Radio Local Area Network (RLAN) devices. During the COVID-19 pandemic, Canadians have been increasingly reliant on RLANs (e.g. Wi-Fi routers and hotspots) to enable access to the Internet and other applications on their smartphones, tablets and laptops, as well as for data-intensive activities such as video streaming and multi-player gaming.

7. RLAN technology also plays an important role in supporting Canadian commercial wireless service providers. Commercial mobile service providers rely on RLAN technology to offload traffic from their mobile cellular networks, freeing up network capacity while continuing to provide customers with high-capacity and high-speed access. Rural broadband service providers, namely wireless Internet service providers (WISPs), leverage licence-exempt spectrum to deliver broadband services to residential and business customers in rural areas. Since the beginning of the pandemic, many WISPs have been dependent on additional RLAN spectrum to alleviate pressures on their networks due to an increased number of their subscribers working and/or studying from home. Further, additional spectrum for licence-exempt use has the potential to support the introduction of next-generation licence-exempt wireless technologies delivering increased capacity and improving reliability for existing and emerging use cases.

8. Wireless technologies also have the potential to impact the evolution of transportation systems in Canada. These technologies include support for Intelligent Transportation Systems (ITS), which will connect people, vehicles, roadside infrastructure and wide area networks to ensure safer and more efficient road transport and transportation infrastructure. For example, one feature of safety-related ITS applications enables drivers to quickly receive information about imminent obstructions or dangers, thereby allowing drivers to take action to prevent potential accidents.

9. Fifth generation (5G) mobile network technology is expected to enable the creation and expansion of future wireless applications in vertical industries, including ITS applications to support the transportation sector. As wireless equipment manufacturers and their partners in the automotive and transportation industry widely deploy vehicle safety applications, Canadians will be able to benefit from the economies of scale and from new applications and services that enhance their safety and security on roads. By ensuring that Canadian policies are developed in a timely fashion that reflect global trends, Canadians will be able to access advanced ITS services as they become available.

10. In developing this Decision, ISED was guided by the Spectrum Policy Framework for Canada (SPFC), which states that the spectrum program objective is to maximize the economic and social benefits that Canadians derive from the use of the radio frequency spectrum resource. This objective and the enabling guidelines listed in the SPFC remain relevant for guiding ISED in delivering its spectrum management mandate.

11. In May 2019, the Government of Canada released Canada's Digital Charter: Trust in a digital world (the Digital Charter). The Digital Charter lists universal access as the first of 10 principles that will lay the foundation for a made-in-Canada digital approach, and guide policy thinking and actions towards establishing an innovative, people-centred, inclusive digital and data economy built on trust. Universal access is the principle that all Canadians will have an equal opportunity to participate in the digital world and have the necessary tools to do so, including access, connectivity, literacy and skills.

12. The Government of Canada is also committed to connecting all Canadians to affordable, reliable high-speed Internet and improving access to the latest mobile services. In 2019, High-Speed Access for All: Canada's Connectivity Strategy set a national connectivity target to make broadband speeds of at least 50 megabits per second (Mbps) download and 10 Mbps upload available to all Canadian homes and businesses. As part of this commitment, ISED supports and encourages connectivity for rural and remote communities as it develops new policies and licensing processes for the 5850-5925 MHz band (collectively referred to as the 5.9 GHz band).

13. The decisions set out in this document support the objectives of the Telecommunications Act, the SPFC, the Digital Charter and Canada's Connectivity Strategy. These decisions will put Canada at the leading edge of the digital economy through the modernization of the 5.9 GHz band to support the development and deployment of emerging and innovative technologies, applications and services for all Canadians. Consequently, ISED’s policy objectives for the 5.9 GHz band are to:

• support the provision of wireless services and technologies so that businesses and public institutions, and by extension, Canadian consumers, benefit from greater choice
• enable the evolution of high-quality networks, including for transportation-related applications
• enhance innovation by enabling Canadian companies to develop innovative transportation use cases
• facilitate the deployment of wireless services across the country to promote broadband connectivity

14. Globally, the deployment of RLAN technology has experienced significant growth, not only to enable connectivity at home, but also to offload data traffic from commercial mobile networks. Today, subscribers are enjoying advanced data-rich applications, such as video streaming and multi-player gaming. Service providers are seeking ways to sustain these demands, which require large bandwidths of spectrum. As mentioned in the Consultation, advanced RLAN technologies such as Wi-Fi 6, are options that service providers may consider to support subscriber data needs.

15. In 2004, ISED published Spectrum Utilization Policy SP 3-30 GHz, Revisions to Spectrum Utilization Policies in the 3-30 GHz Frequency Range and Further Consultation, to enable the use of ITS applications using Dedicated Short-Range Communications (DSRC) technology in the 5850-5925 MHz band. These applications were intended to decrease vehicular traffic congestion, reduce fossil fuel reliance through traffic flow efficiency, and facilitate the reduction of air pollution.

16. Since then, DSRC-based ITS services have evolved slowly and have had limited deployments in Canada, as well as in the US. In November 2020, the US, through the Federal Communications Commission (FCC), announced its decision (FCC 20-164, ET Docket No. 19-138) to divide and designate the existing 5.9 GHz band as follows: the lower 45 MHz of this band (5850-5895 MHz) for RLAN use, and the upper 30 MHz (5895-5925 MHz) for ITS applications. In support of these changes, the FCC indicated in its rules (FCC Part 90 Subpart M) that by July 5, 2022, all ITS authorizations may only operate in the 5895-5925 MHz band.

17. With regard to ITS technology, the FCC also noted the limited deployment of DSRC-based ITS applications in the US and recognized the global shift toward a new technology enabling Vehicle-to-Everything (V2X) communications, called Cellular Vehicle-to-Everything (C-V2X). Consequently, it proposed the use of a single technology that would be most capable of rapid developments and deployment to not only support current transportation and vehicular safety-related applications but also achieve a robust and secure network into the future. The FCC ruled that C-V2X technology would eventually be exclusively used to deliver ITS services in the 5895-5925 MHz band and noted that a decision on the date and process for transitioning from DSRC to C-V2X-based ITS services is forthcoming. 

18. ISED continues to modernize its spectrum policies and seeks to harmonize spectrum use with international jurisdictions, such as those in the US. Equipment interoperability, minimizing barriers to market entry and reducing the risk of interference are key considerations in facilitating quick access and deployment of the latest technology and equipment. Moreover, taking into account the large number of vehicles crossing the Canada-US border on a daily and annual basis, aligning spectrum for ITS applications will be highly beneficial. 

19. In February 2022, ISED released the Consultation to seek comments on the technical and policy considerations for both RLAN and ITS operations in different portions of the 5850-5925 MHz band, closely aligning with the proposals recently adopted in the US.

20. In the Consultation, recognizing that sufficient and appropriate spectrum resources should be made available to ensure that Canadians continue to benefit from advancements in wireless technology, ISED sought comments on its proposal to establish a new spectrum policy and technical framework to enable licence-exempt RLAN operations in the 5850-5895 MHz band, on a no-protection, no-interference basis. In line with this proposal, ISED also sought comments on rescinding the ITS designation in the 5850-5895 MHz band. It was also proposed to make a consequential modification to the Canadian Table of Frequency Allocations (CTFA) to introduce the following footnote:

ADD Cxx The frequency band 5850-5895 MHz is designated for use by licence-exempt radio local area networks and devices with prescribed technical specifications and based upon not interfering with, or claiming protection from, primary and secondary services in this frequency band.

21. The proposed revision to the CTFA is shown in table 1 below.

Summary of comments

Proposed use of licence-exempt RLAN devices in the 5850-5895 MHz band

22. IBI Group, Intel, Meta, the RABC, SES, TELUS and the Wi-Fi Alliance generally supported the proposal to allow the use of licence-exempt RLAN devices in the 5850-5895 MHz band on a no-protection, no-interference basis. Some of these respondents indicated that making available the additional 45 MHz for RLAN use would relieve spectrum congestion and further enhance the ability of the existing 5 GHz Wi-Fi ecosystem to deliver much needed broadband connectivity in a timely manner. In their reply comments, Intel and Meta reiterated their support for making the 5850-5895 MHz band available to RLANs as it would both improve Wi-Fi channel availability and provide wider channel bandwidths to support next-generation gigabit connectivity with lower latency, better coverage, and enhanced energy efficiency.

23. IBI Group and the RABC highlighted their concerns regarding potential interference from RLAN devices to ITS operations in the adjacent band. Similarly, UBC highlighted their concern of the potential adjacent band interference from RLAN devices to connected vehicle devices, especially on safety-critical applications.

24. SES added that adequate interference protection to fixed-satellite service (FSS) operations in the same frequency band is necessary.

25. Rogers recommended that ISED defer the decision to allow RLANs in the 5.9 GHz band or, at a minimum, only allow low-power, indoor-only RLAN usage at this time. Rogers argued that it is unclear that there is an urgent need to make available 45 MHz of spectrum in the 5.9 GHz band for RLANs given the recently released 6 GHz licence-exempt spectrum for RLAN use. Further, C2C-CC and Rogers (supported by Continental in the reply comments) noted that it would be challenging to clear the band of RLAN use if it is determined in the future that more spectrum is needed to support ITS applications, particularly to support non-line-of-sight safety of life use.

26. 5GAA, Bosch, C2C-CC, CVMA, the GAC, Jaguar Land Rover and Qualcomm opposed the introduction of RLANs in the 5850-5895 MHz band. Some of these stakeholders cited their concern about the possible unwanted emissions into the 5895-5925 MHz band. 5GAA and Jaguar Land Rover indicated that the entire 5850‑5925 MHz band is best used for advanced ITS services.

Proposed rescinding of the ITS designation in 5850-5895 MHz, while maintaining the ITS designation in 5895-5925 MHz

27. In response to ISED’s proposal to rescind the ITS designation in the 5850‑5895 MHz band, IBI Group, Intel, Meta, TELUS and the Wi-Fi Alliance expressed their general support. Meta supported the decision to rescind the ITS designation, stating that by making the 5 GHz available to RLANs instead, Canadians can benefit from global advances in wireless technologies. TELUS stated that there is significant benefit in harmonizing with the FCC decision to split the 5850-5925 MHz band. Furthermore, TELUS and the Wi-Fi Alliance noted that the 5850-5925 MHz band has been available for DSRC deployment for a long time and that there has been limited deployment in the band. The Wi-Fi Alliance noted that segmenting the band will maximize the socio-economic benefits of the spectrum resource.

28. Several stakeholders, including 5GAA, AEF, Bosch, C2C-CC, Continental, CVMA, the GAC, IBI Group, Jaguar Land Rover, the RABC and Rogers, highlighted the negative impact of reducing spectrum available for ITS applications. AEF and C2C-CC stated that reducing the current ITS spectrum would limit potential applications for ITS, as well as negatively impact the positive effects of ITS on safety and efficiency. The GAC underscored the potential limitations to services intended to reduce traffic congestion and enhance road safety for vehicle occupants, cyclists, pedestrians and vulnerable road workers. The GAC also argued that the lack of available bandwidth to support ITS services could seriously undermine transportation safety, particularly in dense urban deployments. IBI Group noted that the lack of spectrum for ITS safety applications could create transmission delays and render operations-based applications ineffective.

29. Some stakeholders, including Bosch, 5GAA, Continental, Qualcomm and Jaguar Land Rover, requested that ISED retain the entire 5850-5925 MHz band for basic and advanced ITS applications as many countries have done globally. Continental and Qualcomm noted that other countries (except the US) have either made available or increased their amount of spectrum for V2X to either 70 MHz or 75 MHz. Bosch indicated further that it would not be possible for ITS to operate in parallel to RLAN deployments in the same band due to interference.

30. To counter the rescinding of the ITS designation in the 5850-5895 MHz band, Jaguar Land Rover and Qualcomm suggested that an additional 40 MHz of contiguous mid-band spectrum would be needed to support advanced ITS service applications. Such advanced applications, as highlighted by 5GAA, require burst transmissions of large quantities of data. Rogers emphasized that transportation services may ultimately require additional spectrum, so taking their spectrum away now and then subsequently trying to reintroduce the spectrum to support these services in a few years may be counterproductive. Rogers noted that international studies indicated that additional spectrum for ITS services is required. As a result, it suggested that ISED hold off on any decision on rescinding the ITS designation until technology developments and spectrum demands for ITS applications become more clear.

31. The GAC, IBI Group, the RABC and UBC also referred to the ongoing court challenge in the US, in which ITS stakeholders sought to reverse the FCC’s decision to reduce the spectrum available for ITS applications from 75 MHz to 30 MHz. These respondents advised ISED to be aware of the potential technical and legal challenges that could arise if the Canadian policy does not align with the potential modifications to the US policy. Despite their opposition to the reduction of spectrum available for ITS services, 5GAA, IBI Group and Qualcomm did, however, note that harmonization with the US would promote cross-border interoperability.

Proposed adoption of footnote Cxx and changes to the CTFA

32. In the Consultation, ISED also proposed the addition of footnote Cxx in the CTFA, as shown in table 1 above. The GAC, Intel, Meta, the RABC, Rogers, SES, TELUS, UBC and the Wi-Fi Alliance generally agreed with this proposal. The RABC added that if the footnote is adopted, ISED should confirm that licence-exempt RLAN devices do not adversely impact ITS operations.

33. Although Qualcomm requested the entire 75 MHz be retained for ITS, if the footnote is adopted, it recommended that ISED designate 40 MHz of mid-band spectrum elsewhere for advanced C-V2X applications.

Discussion

34. ISED recognizes the prominent role of RLANs and other licence-exempt technologies that support many aspects of the Canadian economy, as well as the role of ITS applications in enabling increased automation and improving ground transportation.

Use of licence-exempt RLAN devices in the 5850-5895 MHz band

35. ISED agrees with respondents that indicated there continues to be a growing need for additional licence-exempt spectrum to support Canadians’ connectivity needs, as this was highlighted with the heightened demand for additional broadband connectivity during the pandemic. The increasing pressure on wireless networks to support a wide variety of applications as Canadians continue to work, study and connect with friends and family remotely has been a particular challenge, and more so in rural areas where broadband connectivity continues to be limited. ISED has granted several short-term authorizations to Canadian WISPs to operate in the 5.9 GHz band to ensure Canadians can access the online services they need and stay connected with their community using low-cost wireless connectivity.

36. Although a few respondents, such as Rogers and 5GAA, indicated that there is already sufficient licence-exempt spectrum available, ISED is of the view that opportunities presented in the 5850-5895 MHz band for RLAN use may be leveraged to better support the increasing demand for RLAN connectivity. ISED notes that existing industry standards include specifications for wide channel bandwidths (e.g. 160 MHz) in the 5 GHz band. Advanced Wi-Fi technologies, such as Wi-Fi 6, can take advantage of such wide channel bandwidths to deliver high-speed connectivity and improved capacity to support various applications. When the 5725-5850 MHz and the 5850-5895 MHz bands are combined, wide channels can be formed to support such advanced technologies. Such wide bandwidths, without the need for mitigation measures, cannot be achieved in other currently available licence-exempt bands besides the 5.9 GHz band. Therefore, ISED is of the view that the extension of spectrum available for RLANs from the current 5725-5850 MHz into 5850-5895 MHz would further enable consumers to quickly take advantage of the wider bandwidths with devices that already have the built-in capability to operate in the extended band via software updates.

37. ISED is cognizant of the concerns expressed by some stakeholders regarding potential interference from RLANs into in-band FSS and adjacent band ITS operations. ISED is of the view that coexistence between RLAN devices and other in-band and adjacent band operations can be achieved through appropriate technical requirements imposed on RLAN devices. These technical requirements will be defined when developing the applicable technical standard for RLAN equipment operating in the 5850-5895 MHz band. The proposed technical standard will be publicly consulted on at a future date.

38. Consequently, ISED will allow the use of licence-exempt RLAN devices in the 5850-5895 MHz band on a no-protection, no-interference basis.

Rescinding the ITS designation in 5850-5895 MHz, while maintaining the ITS designation in 5895-5925 MHz

39. Regarding the proposal to rescind the ITS designation in the 5850-5895 MHz band, ISED notes the concerns raised by several respondents on the reduction of ITS spectrum. However, as highlighted in the Consultation, 75 MHz of spectrum in the 5.9 GHz band was allocated to the mobile service in 2004 to support ITS applications. Since then, ITS deployments have not significantly materialized in Canada; only 11 developmental licences have been issued for the use of ITS Roadside Unit (RSU) operations, and the only vehicle model to have installed an ITS On-Board Unit (OBU) that ISED is aware of, has been discontinued.

40. ISED acknowledges that there continues to be a need for spectrum for ITS applications. Core safety-related communications can continue to operate in the upper 30 MHz of the band, and this spectrum can provide the ITS community adequate spectrum to develop innovative uses to improve roadside safety and enhance the driver experience in conjunction with other advanced applications in other bands, such as the use of radar systems in the 76-81 GHz band for adaptive cruise control and automatic emergency braking systems. With regard to commenters’ proposal that alternate spectrum be identified in mid-band spectrum to support advanced ITS service applications, ISED notes that such consideration is beyond the scope of the present consultation. Therefore, at this time, no additional spectrum for ITS is identified. 

41. ISED is of the view that harmonization of spectrum use between Canada and the US would be highly beneficial and would enable consumers to access and leverage a larger set of equipment at a lower cost. Moreover, harmonization with the US would provide opportunities for Canadian and American automotive industries and their partners to work collaboratively to develop and deploy common vehicular applications and, more importantly, facilitate cross-border operations and interoperability between devices, contributing to overall vehicular safety.  

42. With regard to the comments on the court challenge in the US, the United States Court of Appeals for the District of Columbia Circuit upheld the FCC decision in August 2022 (U.S. Court of Appeals for the D.C. Circuit, Opinion No. 21-1130) to reassign 45 MHz of spectrum from ITS to RLAN use. ISED is of the view that this recent decision provides certainty on the harmonized use of the 5.9 GHz band between Canada and the US. Therefore, given the above considerations, ISED will rescind the ITS designation in the 5850-5895 MHz band.

Adoption of footnote Cxx and changes to the CTFA

43. Regarding the proposed inclusion of footnote Cxx and consequential changes to the CTFA, ISED acknowledges the support expressed by many stakeholders. ISED also notes the concerns raised by some respondents, particularly with regard to RLAN interference impact on ITS services and the need for appropriate technical rules. However, as these concerns are not related to the proposed modification to the CTFA nor to the phrasing of the footnote, ISED has addressed them in section 6 below.

44. Given the above decision to allow the use of licence-exempt RLAN devices in the 5850-5895 MHz band, changes to the CTFA will be adopted as proposed above.  

Decisions

45. In the Consultation, ISED sought comments on its proposal to allow indoor and outdoor licence-exempt RLAN devices to have immediate access to the 5850-5895 MHz band once appropriate technical standards are in place, as this would allow Canadians to have access to the latest licence-exempt technology with minimal delays. ISED also sought comments on its proposal to not impose a transition plan to displace existing ITS systems out of the 5850-5895 MHz band, but rather to allow the existing ITS systems to continue to operate in this band on a no-protection, no-interference basis. In addition, ISED sought comments to its proposal to no longer allow the certification of new ITS OBU devices in the 5850-5895 MHz band.

Summary of comments

Proposal to allow indoor and outdoor RLANs to have immediate access to the 5850-5895 MHz band

46. IBI Group, Intel, Meta, TELUS and the Wi-Fi Alliance supported the proposal to allow immediate access to the 5850-5895 MHz band for both indoor and outdoor RLAN use once appropriate technical standards are established. Some of these stakeholders repeated their observations that existing RLAN equipment can quickly leverage a new contiguous 160 MHz channel through a software or firmware upgrade, and that the sooner these devices are allowed to use the band, the sooner the benefits will be seen by Canadians.

47. In its reply comments, Intel noted that the Wi-Fi Alliance Wi-Fi 6 certification already covers this extended band and since Dynamic Frequency Selection (DFS) is not required for the 5850-5895 MHz band, simplified and streamlined certification and approval processes are possible. Intel further recommended that ISED harmonize its technical and operational rules with the FCC, to enable economies of scale including faster time to market.

48. TELUS contended that RLAN devices operating in indoor and outdoor environments can be designed to protect ITS from harmful interference by implementing suitable technical specifications including specific power and out-of-band emission (OOBE) limits.

49. IBI Group emphasized that safety-critical Vehicle-to-Infrastructure (V2I) requires very low latency for transfer of safety messages in order to provide feasible safety benefits to road users. This latency could increase as a result of interference from licence-exempt devices in the adjacent band, thereby making safety-based applications impractical.

50. On the other hand, Qualcomm, the RABC, Rogers, SES and UBC recommended that RLANs be limited to indoor-use only, as they had reservations regarding interference from outdoor RLAN operations. For instance, Qualcomm and SES elaborated that it would be prudent to allow only indoor use of RLANs as a first implementation pending further consideration of interference issues and remedial measures that may be required.

51. With regard to outdoor RLAN operations, several respondents raised concerns regarding potential interference to ITS devices in the adjacent band. The GAC, for example, noted that it has a concern with outdoor RLAN operations due to the lack of building attenuation and proposed the need for studies or appropriate technical specifications to address these concerns. The RABC had a similar view and recommended that ISED first carry out technical interference analyses before allowing outdoor RLAN use in Canada. Qualcomm added that ISED should permit outdoor RLAN operations only after ITS operations are deployed in Canada and the performance of C‑V2X applications are assessed in the presence of RLAN out-of-band emissions, in order to adopt the appropriate technical rules for outdoor RLANs.

52. SES emphasized that the risk of aggregate interference to FSS operations is especially acute if high-power licence-exempt devices are allowed to be deployed outdoors. As a result, it added that if ISED were to allow outdoor RLAN use, then the measures that were adopted in the 6 GHz band should also apply to the 5.9 GHz band, such as the inclusion of a vertical elevation mask limiting the maximum equivalent isotropically radiated power (e.i.r.p.) at elevation angles above 30 degrees above the horizon.

53. 5GAA stated that the absence of a spectral separation between the 5850-5895 MHz and 5895-5925 MHz bands only heightens the risk that C-V2X will suffer harmful interference from RLAN devices, particularly those operating outdoors. Additionally, 5GAA noted that outdoor RLAN operations will result in more frequent and widespread unwanted emissions due to a greater number of RLANs in the field. However, 5GAA stated that if ISED goes ahead with allowing RLANs in the 5850-5895 MHz band, ISED should adopt the proposed emission limits that 5GAA submitted to the FCC. These proposed OOBE limits were supported by Jaguar Land Rover and Qualcomm.

54. Additionally, 5GAA, Jaguar Land Rover and Qualcomm proposed that mobile hotspots and portable device-to-device operations in the 5850-5895 MHz band should be prohibited as they pose significant challenges to C-V2X performance.

55. By contrast, Rogers recommended deferring a decision on outdoor RLAN use altogether.

56. As noted in section 5 above, 5GAA, C2C-CC and CVMA generally opposed the introduction of RLANs in the 5850-5895 MHz band, and reiterated their concerns regarding the impact on ITS services should RLANs be allowed in this frequency band. 5GAA reiterated in their reply comments the concern that RLAN unwanted emissions, if permitted at high levels, pose a threat to the viability of safety services in the 5895-5925 MHz band. It also referred to Bosch's concerns of adjacent band interference, and IBI Group’s remark that interference was observed in both simulations and in-field testing performed in the US. Additionally, CVMA emphasized the importance of having strict limits and technical standards on RLANs to prevent interference with V2X safety applications in neighbouring bands and to enable and ensure the integrity of the safety uses of V2X.

Proposal on not imposing a transition plan to displace existing ITS systems in the 5850-5895 MHz band

57. Many stakeholders, including the GAC, IBI Group, Qualcomm, the RABC, TELUS and UBC, agreed with ISED’s proposal to not impose a transition plan to displace the existing ITS deployments in the 5850-5895 MHz band. Qualcomm, TELUS and UBC indicated that a formal transition plan is not needed due to the limited ITS deployments. The GAC supported this view and noted that its members do not presently install V2X devices in their vehicles for sale in Canada. IBI Group recommended that ISED work with the provinces and relevant project stakeholders to aid the transition and provide any necessary support.

58. Some stakeholders, including Rogers and the Wi-Fi Alliance, recommended the implementation of a transition plan to displace existing ITS deployments out of the 5850-5895 MHz band. Rogers suggested that while there has been very limited deployment of ITS in Canada, providing a transition date would eliminate potential sources of interference to new uses, notwithstanding the no-protection, no-interference operation basis proposed. Rogers suggested that a 10-year timeline could be mandated for existing ITS systems to either be fully displaced or transitioned to C-V2X-based technology, given that the average vehicle turnover time in Canada is under 13 years. However, if the C-V2X ecosystem does not mature in that timeframe, Rogers proposed that ISED may wish to consider a follow-up consultation.

59. The Wi-Fi Alliance noted that ISED may wish to consider the limited benefits of continuing existing ITS operations in the 5850-5895 MHz band, and therefore noted that a definitive transition plan would provide regulatory certainty and expedite RLAN deployments in the band.

Proposal to allow the continued operation of existing ITS operations on a no-protection, no-interference basis, and no longer allowing the certification of new ITS devices in the 5850-5895 MHz band

60. In the Consultation, ISED proposed to allow existing ITS deployments in the 5850-5895 MHz band to continue operating on a no-protection, no-interference basis. In line with the proposal to rescind the ITS designation in this range, it was also proposed to no longer allow the certification of new ITS OBU devices in the 5850-5895 MHz band.

61. The GAC, IBI Group, Qualcomm, the RABC, Rogers, TELUS, UBC and the Wi-Fi Alliance generally supported the proposal to allow the continued operation of existing ITS devices on a no-protection, no-interference basis, as well as ceasing the certification of new ITS devices in the 5850-5895 MHz band. The RABC noted that continued operation of existing ITS devices on a no-protection, no-interference basis may provide additional bandwidth for non-safety-related ITS applications to the extent that DSRC continues to be utilized. The Wi-Fi Alliance agreed with ISED’s two proposals, and further suggested that the existing ITS devices in the 5850-5895 MHz band should implement protocols such as “Listen Before Talk” and “Energy Detect” techniques to ensure coexistence with other users of the frequency band.

62. On the other hand, C2C-CC recommended that ITS devices using DSRC technology should remain in the band and be protected from interference.

Discussion

Allowing indoor and outdoor RLANs to have immediate access to the 5850‑5895 MHz band

63. Since the publication of Radio Standards Specification RSS-252, issue 1, Intelligent Transportation Systems – Dedicated Short Range Communications (DSRC) – On-Board Unit (OBU), which established the certification requirements of licence-exempt OBUs operating in the 5850-5925 MHz band on a no-protection, no-interference basis, only a limited number of OBUs have been certified for the Canadian market. To ISED's knowledge, only one automotive manufacturer had integrated OBUs in one vehicle model sold in Canada; however, that vehicle model has since been discontinued. As noted in the Consultation, there is currently no licensing framework in place to authorize the operation of RSUs in Canada. However, there are a few developmental licences making use of RSU devices on a no-protection, no-interference basis.

64. With the low number of OBU deployments in vehicles, the transmission and reception of signals between vehicles are consequently very limited. ISED agrees with stakeholders that the immediate introduction of indoor and outdoor RLANs in the 5850-5895 MHz band would pose minimal interference risk to incumbent ITS deployments.

65. In addition to ITS operations, there is currently a telemetry system deployment to support the Montréal subway system. This system operates exclusively underground and its operation is based on no-protection, no-interference. ISED does not anticipate interference risks to these incumbent deployments.

66. Other services allocated to the band are fixed, fixed satellite, amateur, and radiolocation services. As per Spectrum Advisory Bulletin SAB-001-17, Displacement of Existing Fixed Service Assignments in the Frequency Band 5850-5925 MHz, incumbent fixed service licensees are to cease operation in the band, and any existing stations may continue operation on a no-protection, no-interference basis. As for fixed satellite or radiolocation services, there are currently no deployments in this band. In the case of amateur service, due to the relatively low power of RLANs and given that amateur operators will operate at higher transmit powers, ISED is of the view that the risk of harmful interference is negligeable. Nevertheless, ISED will ensure that appropriate technical rules are developed so that the introduction of licence-exempt operations of RLAN devices will not impact current and future deployments of allocated services in the band.

67. ISED acknowledges the adjacent band interference concerns raised by various stakeholders. As noted above, ISED will develop appropriate technical standards for both indoor and outdoor use of RLANs to address these issues, and will give due consideration to RLAN OOBE limits to allow for the coexistence of adjacent ITS applications.

68. Equitable access and the efficient use of spectrum is important in ensuring that Canadians are able to enjoy the latest technologies. Although some respondents suggested only allowing indoor use of RLANs, ISED takes the position that a policy provision to allow all RLAN operations, indoor and outdoor, would be more efficient and forward-looking and would provide assurance to RLAN equipment manufacturers of a larger and more diverse market. An indoor-only approach could limit the development of a viable RLAN ecosystem for Canada, and potentially result in underutilized spectrum.

Not imposing a transition plan to displace existing ITS systems in the 5850‑5895 MHz band

69. In its submission, the GAC confirmed that its members do not presently install V2X devices in their vehicles sold in Canada. With the low number of OBU deployments in vehicles, the transmission and reception of signals between vehicles are consequently very limited. Thus, it is unlikely that there would be interference issues between currently deployed OBUs in Canada and both indoor and outdoor RLAN use in the 5850-5895 MHz band. As a result, ISED is of the view that a transition plan to displace existing ITS deployments out of the 5850-5895 MHz band is unnecessary. Furthermore, the existing ITS deployments in this band can continue to operate on a no-protection, no-interference basis.

70. ISED acknowledges stakeholder suggestions that a definitive transition plan would provide regulatory certainty and aid in ensuring the efficient deployment of RLAN equipment, while mitigating potential interference scenarios. As mentioned in paragraph 69 above, given the existing limited ITS deployments in Canada and the low likelihood of potential interference, a transition plan to displace deployed ITS systems out of the 5850-5895 MHz band is unnecessary.

Allowing the continued operation of existing ITS operations on a no-protection, no-interference basis, and no longer allowing the certification of new ITS devices in the 5850-5895 MHz band

71. ISED recognizes that there may be some, although limited, interest in continuing to operate existing ITS devices in the 5850-5895 MHz band on a no-protection, no-interference basis. Several stakeholders supported this proposal. ISED agrees that this provision would allow existing ITS deployments to continue operations and not cause unnecessary interruptions.

72. ISED did not receive any comments opposing its proposal to cease certification of new ITS devices in the 5850-5895 MHz band. Consistent with decision D2 in section 5 above to rescind the ITS designation in 5850-5895 MHz band, ISED will no longer accept applications for certification of ITS devices in the 5850-5895 MHz band effective April 1, 2023.

Decisions

73. ISED does not generally mandate specific technology standards as part of the technical rules; however, in some cases ISED has mandated that radio apparatus be certified to specific standards to ensure communication interoperability. In the Consultation, ISED sought comments on whether it should mandate a specific ITS technology in Canada and if so, whether it should mandate C-V2X technology to harmonize with the US.

Summary of comments

74. 5GAA, BlackBerry, IBI Group, Jaguar Land Rover, Qualcomm, Rogers, TELUS and UBC generally supported the use of a single technology, namely C-V2X, in the 5895-5925 MHz band. 5GAA mentioned that key automakers are already deploying C‑V2X in other parts of the world and that ISED should move quickly to facilitate the rapid deployment of this technology. Rogers noted that to help the development of an ITS ecosystem, mandating C-V2X will assist in getting mass market devices into commercial operations.

75. The majority of these stakeholders supported the idea that the mandated technology be harmonized with the US, with Rogers noting that the equipment ecosystem will be driven by the larger US market and the strong economic implications on the North American automotive manufacturing industries. Rogers further stated that harmonization will also facilitate cross-border coordination and reduce potential interference management. BlackBerry added that ensuring harmonization will enable Canadian businesses, researchers and consumers to access advanced ITS services on a broader scale.

76. The RABC indicated that while it is important to harmonize as much as possible on a particular technology with special consideration of the trends in the US, Europe and China, it proposed that such a decision be delayed until there is worldwide certainty regarding which technology will be adopted.

77. Although AEF welcomed mandating a single technology to facilitate interoperability between equipment, it did not see relevant advantages in C-V2X compared to DSRC. AEF noted that it would prefer continued use of DSRC due to a higher equipment maturity level and number of worldwide users of DSRC-based devices.

78. On the other hand, C2C-CC, CVMA and the GAC generally opposed mandating a single technology, and suggested that ISED should stay technology neutral. C2C-CC argued that not mandating a single technology allows for flexibility to adapt to future technologies. It believes this would also set a stable spectrum regulatory framework that would encourage investments by industry, and that vehicles crossing the Canada-US border would be covered by technological neutrality. It also argued that technology efficiency is key, and C-V2X has not been proven to be the most efficient technology.

79. Bosch noted that if ISED decides to pursue a multi-technology implementation, then it would request that the two technologies be able to coexist throughout the whole band.

Discussion

80. ISED has generally maintained a technology neutral stance when making spectrum available for use. However, in 2004, ISED published SP 3-30 GHz, in which it designated the use of a specific technology, namely DSRC, to support ITS applications. At that time, ISED believed that a specific technology would ensure interoperability and would provide automobile and ITS device manufacturers assurance and focus to develop and deploy ITS services. Taking into account the large number of daily and annual crossings of vehicles over the Canada-US border, ISED was of the view that aligning communication interoperability between vehicles, roadside units and portable units in both countries would be highly beneficial. Therefore, the use of the 5.9 GHz band, and the use of DSRC technology, was also harmonized with the use of the band in the US.

81. Global trends toward the development of advanced ITS technologies continue to evolve. In recent years, the 3rd Generation Partnership Project (3GPP) standards development body has standardized cellular-based technology for ITS services. C-V2X technology uses 4G Long Term Evolution (LTE) and 5G technology implementations. Forward-looking technologies, such as these, will enable drivers to take advantage of current and future communication capabilities, and thereby enrich the use of such technology by the transportation industry.

82. Many respondents supported the mandated use of a single ITS technology in the band to facilitate interoperability between ITS equipment. Despite typically being technology neutral, ISED is of the view that a single mandated ITS technology would lead to improved interoperability, transportation safety and traffic management benefits.

83. In the US, the FCC has mandated C-V2X technology and is moving away from DSRC. Given that C-V2X and DSRC are incompatible technologies, and that approximately 30 million vehicles cross the Canada-US border annually, the adoption of a single common technology in Canada and the US would provide the basis to ensure the continuity and availability of vehicle safety features for drivers within Canada and when traveling to the US.

84. In response to the comment that mandating a specific ITS technology at this time may be premature since C-V2X technology is still evolving, ISED is of the view that delaying the selection of a single ITS technology would leave the implementation of ITS services in jeopardy with the risk of having non-interoperable ITS deployments. In turn, this could hinder the development and adoption of vehicle safety features by Canadian ITS stakeholders and could lead to a lack of ITS deployments, as was the case with DSRC.

85. ISED recognizes the views of stakeholders who preferred that ISED remain technology neutral. In many cases, a technology neutral approach stimulates innovation and presents opportunities for Canadians to access a wide array of services and technologies. For ITS services, however, ISED believes that a technology neutral approach would be counterproductive. Vehicular transportation communication links can only take place when the ITS devices employ the same technology. The use of more than one communication technology for ITS devices will limit interoperability and potentially jeopardize the usefulness of safety-related ITS applications.

86. Although there has been a slow adoption rate of ITS devices, by mandating a specific technology and harmonizing with the US usage, the adoption rate of ITS in Canada could be expected to increase. Mandating the use of a single technology, namely C-V2X, in the 5895-5925 MHz band would promote interoperability, facilitate economies of scale, and provide the ITS community, including automakers, device manufacturers, and transportation authorities, the certainty required to quickly and efficiently develop and deploy ITS applications that can be enjoyed by Canadians.

87. Therefore, ISED will be mandating the use of a single technology, namely C‑V2X, to support ITS operations going forward. Consequently, the appropriate technical standards will be revised to allow the certification of only C-V2X-based equipment in the 5895-5925 MHz band. Existing DSRC-based equipment may continue to operate in the 5895-5925 MHz band on a no-protection, no-interference basis. ISED will no longer accept applications for certification of DSRC-based ITS devices in the 5895-5925 MHz band effective April 1, 2023.

88. Notwithstanding the adoption of C-V2X as the mandated technology at this time, ISED is of the view that as ITS evolves, there may be benefits in allowing other technologies in the band in the future. Such change would be considered through reviews of ISED technical standards at the appropriate time.

Decision

89. In the Consultation, ISED noted that the potential approaches to spectrum authorizations that would be best suited for ITS devices operating in the 5895-5925 MHz band are licence-exempt and spectrum (geographic area-based) licensing. The approaches considered for OBUs and RSUs are described below in sections 8.1 and 8.2, respectively.

8.1 Proposed approach for On-Board Units

90. OBUs under the existing DSRC technology have been authorized in Canada on a licence-exempt basis. As ITS technology becomes widely deployed, OBUs are expected to be ubiquitous across Canada and the rest of the continent, wherever vehicles are used. With this in mind, ISED sought comments on its proposal to permit OBUs to continue to operate on a licence-exempt basis, contingent on meeting all applicable technical standards.

Summary of comments

91. Continuing to authorize OBUs on a licence-exempt basis drew mixed responses from stakeholders, with some advocating for licence-exempt, some for licensing, and some for the licence-by-rule structure used by the FCC in the US.

92. General agreement with a licence-exempt approach for OBUs was expressed by IBI Group, the RABC, TELUS and UBC. IBI Group noted that licensing of OBUs could be a barrier to adoption.

93. The RABC highlighted the need to ensure that RLANs do not cause harmful interference to ITS OBUs. It was of the opinion that ITS safety services (such as critical messaging to prevent crashes) would be less likely to be deployed in Canada if operated under a no-protection rule from RLANs. UBC noted a potential drawback in that a licence-exempt approach would impede ISED’s ability to detect and remove unintentional/illegal short-range emitters in the band. 

94. Opposition to a licence-exempt approach was expressed by 5GAA, the GAC, Jaguar Land Rover and Rogers. The GAC stated that manufacturers are unlikely to deploy vehicles with C-V2X devices in Canada if these operate under a no-protection rule, given the safety-critical messaging to prevent traffic accidents. Although Rogers believes existing ITS OBUs should be allowed to operate on a licence-exempt basis for 10 years, it stated that it expects new C-V2X units would likely have modems connecting to a cellular network as part of the C-V2X functionality; therefore, ISED should consider the new OBUs as comprising both licensed (cellular network connectivity) and licence-exempt (C-V2X) components.

95. 5GAA pointed out that it would not be prudent for ISED to adopt a licence-exempt regime and that they preferred the adoption of the FCC’s dual “lite-licensing” regime for OBUs and RSUs, where OBUs are under a licence-by-rule system and RSUs are geographically licensed on a non-exclusive basis. Jaguar Land Rover argued that if both OBUs and RSUs do not receive interference protection, it would materially compromise C-V2X’s ability to support critical safety applications. In its reply comments, Jaguar Land Rover agreed with 5GAA’s comments that the FCC dual "lite-licensing" model will provide C-V2X with interference protection both domestically and when crossing the Canada-US border. Qualcomm also expressed support for using the same regulatory regime as proposed in the US.

Discussion

96. ISED is of the view that a licence-exempt approach for OBUs would help to minimize barriers to market entry, as devices need only meet the technical parameters outlined in appropriate technical standards, and could accelerate access to the latest technology and applications. OBUs are expected to have ubiquitous deployments and wide geographic range of operation; as a result, they would greatly benefit from a licence-exempt approach, which provides maximum flexibility and enables quicker adoption. Also, considering the millions of vehicles that cross the Canada-US border every year, not requiring every OBU to be licensed would facilitate harmonization with the US licensing approach for OBUs.

97. ISED recognizes that some stakeholders preferred a licensed approach for OBUs, as this would provide a level of protection for safety-critical messaging. ISED is of the view that it is not pragmatic to license OBUs individually. Having each OBU individually licensed would become cumbersome for licensees and Canadian vehicle owners, thus potentially impacting the adoption rate of ITS systems. In developing its policies, ISED seeks to strike a balance between system requirements (such as safety-related functions) while minimizing potential administrative burdens.

98. Some stakeholders raised concerns about potential interference between OBU devices. ITS technology is designed to enable coexistence and mitigate interference between ITS devices near each other. In addition, given the volume and the nomadic nature of OBUs, ISED believes that the administrative burden involved in licensing individual OBUs is not justified.

99. Regarding comments related to OBUs communicating with cellular networks, all such devices with cellular communications capability are required to conform with the technical standards and rules established for cellular bands. These requirements are outside the scope of this consultation process.

100. Some stakeholders recommended adopting the licence-by-rule approach used in the US, where OBU equipment can operate within the assigned spectrum and in accordance with the applicable technical rules, without a requirement to have an individual licence. Canada does not share the same licensing structures as in the US and does not have the same type of licence-by-rule mechanism in its legislation. Therefore, ISED can only consider licensing options that currently fall under its legislative mandate.

101. Based on the discussion above, ISED will allow OBUs to continue to operate under a licence-exempt regime, on a no-protection, no-interference basis.

Decision

8.2. Proposed approach for Roadside Units

102. As discussed in the Consultation, ISED is considering two options for the licensing regime for RSUs, specifically whether the RSUs should be licence-exempt or if users should be issued spectrum licences.

Summary of comments

103. Stakeholders that commented on the approach to RSUs were nearly unanimous in asking for a licensing regime to be used. Those in favour were 5GAA, the GAC, IBI Group, Jaguar Land Rover, Qualcomm, the RABC, Rogers, TELUS and UBC.  

104. TELUS was of the view that a licence-exempt approach would make control of the band and coordination amongst stakeholders more complex and make it difficult to achieve the ITS goal of improved automotive safety. In addition, the RABC and UBC argued that a licensing regime could help to deter deployment of RSUs that do not have a legitimate public safety or commercial ITS role and thereby reduce the potential for congestion.

105. 5GAA, the GAC, IBI Group, Qualcomm, the RABC and Rogers cited the licensing system that was proposed for C-V2X in the US, where RSU operators must obtain a licence and register each RSU in the FCC’s Universal Licensing System database to enable coordination. They argued for aligning Canada’s approach with the US approach. Further, 5GAA argued for a “lite-licensing” regime as used in the US, noting that it would lower administrative burden while also aligning the RSU protection level of both countries. Rogers noted that a licence-exempt approach would result in issues with both passive infrastructure access and cellular system interactions, hence also argued for a lightly licensed approach.

106. C2C-CC favoured a licence-exempt approach for RSUs, noting that the use of spectrum licensing for RSUs would deter entry into the band, as it would be an additional hurdle for small and medium-sized operators wishing to utilize the band.

Discussion

107. ISED is of the view that RSUs can benefit from a licensing regime. While OBUs may experience interference temporarily as they move from one place to another, interference generated or received by RSUs could be a longer term situation that licensing could help address. With a licensing regime for RSUs, ISED could impose conditions requiring licensees to provide ISED with location, operational, and technical data on all stations to facilitate coordination and manage interference.

108. Furthermore, a licensed approach allows ISED to set technical rules and operational restrictions on RSUs to protect other radio services. A licensed approach would also allow ISED to set other conditions of licence that could prove beneficial for safe and efficient operations in the band, such as an eligibility requirement for operators of RSU devices.

109. Many stakeholders argued in their comments that Canada should structure its ITS licensing regime in a similar way to the US. In order to harmonize as closely as possible with the US licensing regime, a licensed approach for RSUs in Canada would be required.

110. While some have noted that licensing may present a barrier to entry for new entrants, ISED notes that under a spectrum licensing regime, the administrative burden is lessened as licence holders may modify, move, or add equipment within a specified geographic area without the need for prior approval from ISED, as long as they are following ISED policies and technical standards.

111. ISED is of the view that a licence-exempt approach for devices affixed to infrastructure and intended to transmit transportation information over large distances could impact the efficacy of safety-related communications. ISED believes that ITS services could receive significant benefits if there is a coordinated and cohesive approach to roadside vehicular communication networks.

112. Based on the arguments above, ISED will adopt a spectrum licence approach for RSUs.

Decision

8.2.1 Licensing regime for Roadside Units

113. To better inform ISED of the requirements to potentially implement a licensing regime for RSUs, in the Consultation, ISED posed high-level questions regarding different licensing models, the most efficient way to assign spectrum, and any conditions of licence that should be considered to effectively manage interference and to facilitate coordination between stations. It was also noted that ISED could consider a licensing framework that restricts the number of licensees that are able to operate in a given area, and that different licensing approaches are possible for urban and rural areas.

Summary of comments

114. Several respondents, including 5GAA, IBI Group, Jaguar Land Rover and Qualcomm, recommended aligning with the US licensing structure, which they refer to as a “dual lite-licensing system,” where OBUs are under a licence-by-rule system and RSUs are geographically licensed on a non-exclusive basis. They cited benefits such as a reduced licensing burden, protection from interference, and seamless border crossing for ITS vehicles. 5GAA noted that RSUs should be registered in a database. IBI Group added that the licensing regime could change in the future if deployments become much more widespread.

115. Rogers recommended a light licensing regime and referenced the licensing structure from a recent ISED Decision (SMSE-013-17, Decision on the Technical and Policy Framework for Radio Local Area Network Devices Operating in the 5150-5250 MHz Frequency Band) on higher power outdoor devices (HPOD) in the 5150-5250 MHz band. It proposed that the ITS band be accessible only to radiocommunication service providers and end-users, including enterprise users, while prohibiting personal use of ITS equipment. Furthermore, Rogers recommended adopting an all-come, all-served structure based on a Tier 1 licence area, 10-year licence terms, and applying no licence fees until a separate consultation on fees is completed.

116. TELUS recommended a shared licensing approach, arguing for a hybrid approach that would include a “first-in” prioritization system and a coordination framework. It also recommended that operators must upload site information into a database in a timely manner. Further, it argued that it must be made clear what licensee obligations should be towards the transport safety community.

117. The GAC recommended that research into other jurisdictions be done to determine best practices for ITS licensing.

118. The RABC noted that research and development is underway for a software capable of detecting and reporting short-range interference, making coordination easier to accomplish.

119. Some respondents provided comments regarding how the ITS infrastructure would interact with existing cellular networks. TELUS noted that commercial wireless network operators have the existing expertise and that the transportation safety community could benefit from partnering with these operators. Rogers suggested that there should be no obligations placed on mobile network operators to maintain specific services, operations, or any other support to ITS RSUs that are not in line with the operator’s commercial interests.

Discussion

120. ISED has determined in decision D9 above, to adopt a spectrum licensing approach for RSUs. However, ISED considers that it could benefit from further consultation on the implementation of licensing for RSUs. As such, a decision on an RSU licensing structure will be deferred until more detailed information can be gathered as part of a future licensing framework consultation. The comments received through this Consultation will be considered in the development of a future licensing framework consultation.

Decision

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

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

Innovation, Science and Economic Development Canada
Engineering, Planning and Standards Branch
Senior Director, Terrestrial Engineering and Standards
6th Floor, East Tower
235 Queen St
Ottawa ON  K1A 0H5

Telephone: 613-797-2253
TTY: 1-866-694-8389
Email: spectrumengineering-genieduspectre@ised-isde.gc.ca