Consultation on the Policy, Technical and Licensing Framework for the VHF Maritime Frequency Bands

1. Through the release of this document, Innovation, Science and Economic Development Canada (ISED), on behalf of the Minister of Industry (the Minister), is hereby initiating a consultation on the policy, technical and licensing framework for maritime use in the very high frequency (VHF) bands 156.000-157.450 MHz, 160.600-160.850 MHz and 161.575-162.050 MHz (referred to as VHF maritime mobile band). The primary intent of the consultation is to enable the implementation of the VHF Data Exchange System (VDES) in the bands 157.1875-157.3375 MHz and 161.7875-161.9375 MHz (referred to as VHF Data Exchange (VDE) bands). In addition, the consultation also addresses considerations in relation to the use of the VDE bands by maritime and non-maritime users, with a particular focus on areas where maritime services are given priority of use in accordance with international regulations in effect for the VHF maritime mobile band.

2. The Minister, through the Department of Industry Act, the Radiocommunication Act and the Radiocommunication Regulations, with due regard for 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.

3. Wireless communications are an integral part of the Canadian economy. Businesses, public institutions and consumers rely on wireless services and technologies to enable day-to-day activities as well as to enable innovative and emerging use cases. Wireless services also extend to Canadian waterways and coasts, where they play a crucial role in facilitating maritime radiocommunications related to commercial activities such as shipping and fishing, various recreational pursuits on water, and in support of public safety in Canadian waters.

4. ISED, as the Canadian spectrum regulator, is committed to the objective that Canadians have access to the latest wireless services, including cutting-edge technologies for maritime radiocommunications, as wireless communications play an increasingly important role in ensuring safe navigation in Canadian waters. ISED works in collaboration with other federal departments, particularly Transport Canada (TC) and Canadian Coast Guard (CCG), given their key roles in Canadian maritime services. TC regulates operational maritime functions. For instance, it licenses, certifies and registers commercial and recreational vessels and regulates navigational aids as well as marine safety, security and training. CCG protects Canada's marine environment, and ensures the safety of mariners as well as supporting the sovereignty and security of Canadian waters.

5. To support the evolution of maritime communications and to accommodate new e-navigation applications for improved safety and operational efficiency at sea, the International Telecommunication Union (ITU) and International Maritime Organization (IMO) have been progressively working towards enabling the introduction of digital technologies in VHF maritime mobile band. VDES, considered as the next-generation Automatic Identification System (AIS), is an advanced communication system that utilizes terrestrial and satellite radio communication links within the VHF maritime mobile band to facilitate globally interoperable digital data exchange between ships, between ships and shores and between ships and satellites. This new maritime digital radiocommunication technology will enable two-way communication, including facilitating the rollout of emerging autonomous navigation systems.

6. In the ITU Radio Regulations, a deadline of January 1, 2030, has been set for VDE bands to no longer be used for analog communications. Until that date, the use of analog modulation in these bands is permitted only on a no-interference, no-protection basis with respect to the use of digital modulation. As a signatory treaty member to the ITU Radio Regulations, Canada will align its domestic regulations with these international requirements.

7. In developing this consultation, ISED was guided by the Spectrum Policy Framework for Canada (SPFC), which states that the objective of the spectrum program is to maximize the economic and social benefits that Canadians get 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.

8. The proposals outlined in this consultation support the objectives of the SPFC, positioning Canada at the leading edge of the digital economy through harmonized use of maritime VDE bands in Canada, while complying with international regulations. In this context, ISED's policy objectives for this consultation are to:

• facilitate improved connectivity on Canadian waters with the timely deployment of maritime applications and services for safety and commerce
• foster investment in next generation technologies and services such as e-navigation for maritime public safety, commercial and recreational uses
• enhance innovation by enabling Canadian companies to develop valuable use cases related to maritime use that put Canada at the leading edge of the digital economy

9. Maritime radiocommunications operating in the VHF maritime mobile band are an essential component of modern maritime operations, providing reliable means for vessels to communicate with each other and with shore-based stations. The VHF maritime mobile band is widely used due to its effectiveness of reaching relatively long distances, generally ranging from 20 - 50 nautical miles (up to approximately 90 km). This makes VHFs ideal in most near-coastal and open water scenarios. Further, it facilitates ship-to-ship and ship-to-shore communications, enabling the sharing of critical information related to navigation and weather conditions, as well as coordinating search and rescue operations.

10. The ITU and the IMO, along with International Organization for Marine Aids to Navigation and Lighthouse Authorities (IALA) and International Electrotechnical Commission (IEC), play essential collaborative roles in setting international regulations and standards for the VHF maritime mobile band. This collaboration ensures that VHF communications supporting global maritime operations are both efficient and reliable. While the ITU is responsible for regulating radio frequency spectrum and satellite orbits to minimize the potential for interference, the IMO sets operational standards and protocols for maritime communication, to ensure the safety of life at sea. IALA and IEC further contribute by developing technical standards and best practices that support safe and effective use of aids to navigation and related maritime technologies. These global standards ensure that administrations adhere to common practices, which enhances the security and effectiveness of maritime operations worldwide.

11. Appendix 18 Table of transmitting frequencies in the VHF maritime mobile band (referred to hereinafter as Appendix 18) of the ITU Radio Regulations (Edition of 2024) provides the spectrum framework for internationally aligned VHF maritime communications. Administrations use this framework to develop the spectrum policies and technical rules along with modifications specific to their needs, where permitted.

12. Appendix 18 details the specific harmonized channel assignments within the VHF maritime mobile band, with 25 kHz channel spacing. It identifies a number of channels for duplex operation and a number of channels for simplex operation. The channels identified for duplex operation are also permitted to be used in simplex mode (i.e., use of only the lower leg or the upper leg of the duplex channel).

13. Figure 1 below illustrates the VHF maritime frequency arrangements in Appendix 18. As shown in Figure 1, the numbering of a subset of channels is represented by 4-digits as defined in Appendix 18. This 4-digit VHF maritime channel numbering was established by the ITU-R in Recommendation ITU-R M.1084-5 (03/2012) (Annex 5), with the aim of enhancing spectrum efficiency and accommodating countries using duplex channels in simplex mode. As an example, for duplex channel 24, the lower leg of this channel's pair of frequency will be number 1024, and likewise the upper leg of this channel's pair will be number 2024. The IMO's Marine Safety Committee is working to encourage maritime vessels to gradually transition VHF radio equipment to meet the requirements of Appendix 18, including the use of 4-digit channel numbering. In this consultation, ISED will be using the ITU's 4-digit numbering scheme, where applicable.

Figure 1: VHF Frequency Arrangements in Appendix 18

14. Maritime radiocommunications are evolving with the broader digitalization of maritime services, such as with the advances in e-navigation. For instance, the introduction of AIS as a digital radiocommunication technology has revolutionized maritime navigation and communication, making it indispensable among mariners for various applications, including ship identification and tracking, search and rescue operations, information exchange, and enhanced situational awareness. AIS allows vessels to broadcast essential details like the maritime mobile service identity (MMSI) number, position coordinates, and navigational data, which can be integrated with radar and Electronic Chart Display and Information Systems (ECDIS) for precise tracking and collision avoidance. It significantly aids search and rescue missions by providing accurate data on vessels in distress and facilitates efficient information exchange, reducing the need for verbal communication and minimizing the risk of misunderstandings. The enhanced situational awareness it provides helps mariners make informed decisions, and improving safety, particularly in congested waters. However, the widespread adoption of AIS has led to the overloading of the two dedicated AIS channels, AIS 1 and AIS 2, especially in high-traffic areas, causing delays in data transmission and potentially compromising the system's effectiveness.

15. To cater to the growing demand for digital technologies to support a wide variety of emerging navigation applications, the ITU identified a subset of maritime VHF digital channels during the World Radiocommunication Conference (WRC)-2012, to enhance maritime data exchange capabilities beyond the existing AIS channels. This led to the development of the VDES, a next-generation maritime framework. The ITU continued to further define VDES, during WRC-2015 and WRC-2019. Recommendation ITU-R M.2092-1 (02/2022) Technical characteristics for a VHF data exchange system in the VHF maritime mobile band provides the technical details of operation of the VDES system, including the interoperability rules for the terrestrial and satellite components of VDES.

16. VDES integrates three (3) main components, as shown in Figure 2 below:

• the AIS channels, for vessel tracking and basic maritime safety
• the Application Specific Message (ASM) channels for specialized data exchange to relieve congestion on AIS channels
• VDE, comprising terrestrial (VDE-TER) and satellite (VDE-SAT) channels to enable advanced, high-capacity digital applications

Figure 2: VDES Channelization

17. Eighteen (18) channels are designated for the terrestrial and satellite components of VDES, supporting ship-to-ship, ship-to-shore, shore-to ship, ship-to-satellite and satellite-to-ship data exchanges. The complete set of VDES channels include:

• AIS channels: these include AIS 1 (161.9625-161.9875 MHz) and AIS 2 (162.0125-162.0375 MHz) for standard AIS operations, and long range AIS channels 75 (156.7625-156.7875 MHz) and 76 (156.8125-156.8375 MHz) designed for extended vessel tracking, including satellite monitoring of ships in remote or offshore regions. Effective January 1, 2025, ISED prohibited any non-AIS use of the AIS 1 and AIS 2 channels
• ASM channels: channels 2027 (ASM1: 161.9375-161.9625 MHz) and 2028 (ASM2: 161.9875-162.0125 MHz), used for transmitting application-specific messages tailored to maritime needs
• VDE channels: the VDE (VDE-TER and VDE-SAT) components of VDES operate in 157.1875-157.3375 MHz and 161.7875-161.9375 MHz. The VDE-TER channels are 1024, 1084, 1025, 1085, 2024, 2084, 2025 and 2085. These channels are also available for VDE-SAT, with additional VDE-SAT channels 1026, 1086, 2026 and 2086. Multiple contiguous 25 kHz channels can be merged to create larger bandwidths (50, 100, or 150 kHz) for bandwidth-intensive services. While Appendix 18 identifies a subset of channels as "digital only" to implement the VDE component of VDES, it also notes that analog modulation is allowed on those channels until January 1, 2030, subject to not causing harmful interference to, or claiming protection from other stations in the maritime mobile service using digitally modulated emissions, and subject to coordination with affected administrations

18. ISED is of the view that the emerging developments in the deployment of VDES functionalities in the VHF maritime mobile band present important opportunities to evolve maritime services in Canada. To support the introduction of VDES in Canadian waters and to ensure continued alignment with the ITU Radio Regulations, ISED is proposing modifications to its VHF maritime policy through this consultation. It also considers the potential impacts from implementation of VDES on existing users of the VHF maritime mobile band in Canada. These factors collectively inform the proposed policy changes and ensure that Canada's approach is aligned with both domestic priorities and international trends.

19. Globally, countries and organizations are actively working to enhance maritime communication and safety by amending regulations and operationalizing VDES which includes the development of an equipment ecosystem.

20. International context: the European Union (EU), through the European Commission and regional maritime authorities, has been a strong proponent of VDES as a means to improve data capacity and functionalities, to complement the existing AIS.

21. In 2019, the European Conference of Postal and Telecommunications Administrations' (CEPT) Electronic Communications Committee (ECC) published a decision to harmonize the use of the VDE channels and ASM channels among its member countries in the EU. The goal was for CEPT countries to implement the technology within a common timeframe, so as to minimize any confusion from the discontinuation of analog telephony on these channels. These ECC regulations mandated the discontinuation of analog voice telephony on the VDE channels as well as ASM channels by January 1, 2023. After this date, these channels would be used exclusively for VDES. Other CEPT activities include a report, expected to be completed by mid-2026, that will summarize the current authorization practices for VDES equipment among its administrations and provide insight into future regulatory approaches to harmonize the use of VDES equipment across member states.

22. Regarding the satellite component of VDE (VDE-SAT), Space Norway has been at the forefront of satellite deployment and testing of VDE-SAT, focusing primarily on providing service in the arctic regions. Moreover, Denmark's Sternula (a Danish maritime technology company best known for being the world's first commercial provider of VDE-SAT services and infrastructure) successfully launched a commercial VDES satellite in 2023.

23. In Australia, the Australian Communications and Media Authority (ACMA) regulated the use of VDES in maritime VHF channels following WRC-2015 and added VDES satellite use in early 2024. New Zealand's Radio Spectrum Management (RSM) organization has also eliminated the use of analog communications on the VDES channels.

24. In the United States (US), the United States Coast Guard (USCG) has been involved in discussions and trials related to VDES. The USCG developed a VDES implementation roadmap in 2021 along with some testing plans to assess VDES' implementation feasibility. However, some of the VHF channels designated for VDES use are currently licensed by the Federal Communications Commission (FCC) to MariTEL (a private communications provider that does not currently offer a commercial service in the band), making these frequencies currently not readily available for VDES deployment.

25. The VDES Alliance (a global association consisting of maritime authorities, organizations and industry members) is at the forefront of collaborative efforts to test, validate, and promote the adoption of VDES technologies worldwide.

26. Equipment ecosystem: traditionally, Canada has worked closely with other jurisdictions to harmonize frequency allocations and has aligned the use of spectrum. These approaches allow for economies of scale in equipment manufacturing, facilitate cross-border coordination of spectrum, and support a global equipment ecosystem.

27. Based on preliminary research and international context described above, ISED understands that some manufacturers have developed comprehensive VDES equipment based on existing global standards developed by the ITU, IMO and IALA, and continue to upgrade their products as these standards evolve. ISED is also aware that extensive field testing of VDE terrestrial and satellite equipment is ongoing, and that the VDES system is already in use in some countries.

28. ISED is of the view that the expanded use cases, enabled by the VDE-TER, VDE-SAT and ASM components of VDES, beyond those currently supported by AIS, represent significant advancements for Canadian maritime communications. These advancements include improved support for Search and Rescue (SAR) communications, Maritime Safety Information (MSI) services such as ice navigation, vessel traffic services, real time updates on ice charts, and Aids to Navigation (AtoN) services including Positioning, Navigation, and Timing (PNT), route exchange and logistics. These use cases are specific to maritime services and the data rates achievable with VDES technology are adequate to support these e-navigation applications.

6.1. Current allocations in the Canadian Table of Frequency Allocations (CTFA)

29. An excerpt from the Canadian Table of Frequency Allocations (CTFA) for VHF band from 156.7625 MHz to 162.0375 MHz corresponding only to those VHF frequencies identified by the International Telecommunications Union (ITU) for VDES is shown in Table 1 below. These allocations are aligned with the ITU frequency allocation table. The frequency ranges in the excerpt have been annotated with the different components of VDES (shown in parenthesis), for convenience.

30. Table 2 provides the excerpt of the relevant Canadian and ITU footnotes in the CTFA for VHF band from 156.7625 MHz to 162.0375 MHz

31. With respect to ISED publications related to the VHF maritime mobile band, Regulation by Reference-2, RBR-2 Technical Requirements for the Operation of Mobile Stations in the Maritime Service provides the technical requirements for the operation of mobile stations in the maritime service. Schedule I of RBR-2 identifies the frequencies, nature of service, type of traffic and area of operation with restrictions for the VHF band in the maritime service.

32. Other documents related to the VHF maritime mobile band include CPC-2-3-03 Frequency Bands in the Maritime Mobile Service and Maritime Radionavigation Service which identifies the types of use (e.g., distress, safety, radio telephony) for each of the maritime mobile services bands. Radio Standards Specification 182 (RSS-182) Maritime Radio Equipment Operating in the 156-162.5 MHz Band, provides the certification requirements for radio equipment used for maritime service in the band 156-162.5 MHz.

6.2. Current use of the VDE and ASM bands in Canada

33. In accordance with the services assigned in the CTFA, the associated ITU footnotes and Canadian footnotes, and all the other documents mentioned above, the maritime mobile service operates as the predominant service in this band, in and near Canadian waterways, and coexists with other terrestrial services under the ITU and domestic policies and regulations.

34. Aside from maritime mobile services, there are other services operating on the VDE and ASM bands in Canada, namely land mobile services and a space service licensee.

35. Maritime mobile services: maritime mobile services in the VDE bands as well as the ASM bands operate under the mobile primary allocation. ITU Radio Regulations footnote 5.226 is relevant to nearly all of the VHF maritime mobile band, including the VDE components (157.1875–157.3375 MHz and 161.7875–161.9375 MHz) and the ASM (161.9375 - 161.9625 MHz and 161.9875 - 162.0125 MHz) components. Within these bands, priority is given to the maritime mobile service only on those frequencies specifically assigned for maritime use. The footnote also indicates that use of these frequencies by stations of other allocated services should be avoided in areas where such operations could result in harmful interference to VHF maritime mobile radiocommunication services.

36. There are approximately 160 licences for maritime use in the VDE bands and 27 licences using the ASM channels. CCG is the largest licence holder, operating a significant portion of these frequencies to enhance maritime safety and coordination. Additionally, other governmental organizations, commercial entities involved in the shipping and fishing industries, and recreational maritime users also maintain a substantial number of these licences. These diverse stakeholders rely on the VHF maritime mobile band to ensure efficient communication, navigation and operational safety across Canadian waters.

37. Maritime mobile-satellite services: maritime mobile-satellite services (Earth-to-space, space-to-Earth) in the frequency bands 157.1875-157.3375 MHz and 161.7875-161.9375 MHz are restricted to non-geostationary orbit (NGSO) systems as per footnotes 5.228AB and 5.228AC, and as noted in Appendix 18 for VDE-SAT operation in these bands. Further, some of the bands identified for VDE-SAT operations (e.g., 157.1875 - 157.3375 MHz) are allocated to maritime mobile satellite services on a secondary basis.

38. Land mobile radio (LMR) and fixed services: in the VHF maritime mobile band, LMR and fixed systems are also allowed to operate outside of the maritime mobile service's areas of operation in Canada. During the licensing process, ISED carries out analyses to ensure that these systems can coexist with the maritime mobile systems in the areas of operation. Over 550 LMR licences have been granted in the VDE bands and approximately 70 LMR licences have been granted on ASM channels to various stakeholders, primarily in the provinces of Alberta, Saskatchewan and British Columbia, and a few in other provinces. The LMR licensees include commercial and public safety entities. There are no fixed systems operating in these bands.

39. ISED recognizes that sufficient and appropriate policies need to be in place to ensure that Canadians continue to benefit from advancements in maritime radiocommunications such as VDES, to support the evolution of e-navigation technologies. Additionally, ISED acknowledges that the CTFA allocations permit other uses of the band, such as for fixed and mobile services. In the context of the introduction of VDES in Canada, ISED is of the view that the existing allocations and footnotes in the CTFA support the introduction of this technology, without requiring modifications. ISED is seeking stakeholders' comments on its proposal that no modifications are needed to the existing allocations and footnotes in the CTFA for the VDE bands and ASM bands, to enable the implementation of VDES.

8.1. Proposed changes for the VDE bands and ASM bands

40. Decision on vacating analog maritime use in VDE bands: in order to meet Canada's obligations under the ITU Radio Regulations (Appendix 18) related to vacating maritime analog use of the VDE bands before the deadline of January 1, 2030, ISED is initiating the process of making the necessary changes to the use of the band, so as to allow sufficient time to make this transition. All current maritime services operating with analog modulation in the VDE bands (namely the channels 1024, 1084, 1025, 1085, 1026, 1086,2024, 2084, 2025, 2085, 2026, and 2086) must vacate these channels by December 31, 2029.

41. Maritime users currently operating on these analog duplex channels in the VDE bands can continue to operate existing systems with analog modulation, on a no-interference, no-protection (NINP) basis with respect to systems operating with digitally modulated emissions in the maritime mobile service until December 31, 2029; After this date, ISED will no longer allow analog operations in these bands.

42. Further, ISED is implementing a moratorium, as of the publication of this Consultation, on the acceptance of new licence applications for analog maritime systems in the VDE bands.

43. Treatment of non-maritime incumbents: the ITU Radio Regulations (Appendix 18) do not stipulate how administrations should treat non-maritime users in the VDE bands. As mentioned in Section 6, in Canada, there are non-maritime licensees, predominantly LMR licensees, operating in the VDE bands, where they currently coexist with maritime users.

44. ISED has conducted a coexistence analysis for the current LMR licensees operating in proximity to maritime services in the VDE bands. Based on this analysis, ISED is of the view that the majority of these systems can generally continue to operate, provided they can remain compatible with maritime services in the VDE bands in accordance with CTFA footnote 5.226.

45. In order to enable the expansion of the anticipated increase in maritime communication needs in the coming years, ISED is proposing to not accept licensing applications for new non-maritime systems in VDE bands. Existing non-maritime licensees in the VDE bands could continue to operate their systems on a NINP basis. In essence, existing non-maritime licensees cannot claim protection from, nor interfere with, terrestrial maritime VDE operations.

46. ISED notes that some channels in the VDE bands have been licensed for non-maritime public safety systems, including larger provincial systems, which may need to continue to be protected for a longer period until they transition to other frequencies. ISED is therefore considering to protect these existing non-maritime public safety systems until January 1, 2035. After this date, these systems will operate on a NINP basis if they still remain in VDE bands.

47. Treatment of displaced maritime incumbents: for the maritime incumbent licensees in the VDE bands that are impacted and continue to require channels to maintain existing services, ISED will attempt to provide alternate VHF maritime channels outside the VDE bands, where available, particularly for those channels that are needed to continue providing maritime safety and security services. This may require ISED to displace certain non-maritime incumbent licensees in VHF maritime mobile band outside of the VDE bands to other VHF frequencies, taking into account the existing services and applications of these non-maritime systems. In order to accommodate as many displaced maritime users as possible, ISED may, where appropriate, adopt policies such as channel sharing within an area of operation as defined in RBR-2, to support the displacements.

48. Proposal for vacating analog maritime use in ASM channels: as noted in section 4, although not required by the ITU Radio Regulations, the CEPT mandated its members to discontinue analog voice telephony on channels 27 and 28. The CEPT designated the channels 2027 and 2028 for ASM, and indicated that the channels 1027 and 1028 may continue to be used in simplex mode only.

49. ISED is of the view that dedicating channels 2027 and 2028 for ASM could reduce the congestion on AIS channels. Consequently, ISED is seeking comments on whether it should vacate and discontinue analog maritime use on channels 2027 and 2028 by December 31, 2029, in Canada. After this date, the channels would be dedicated for ASM only. As such, channels 1027 and 1028 would be made available for operation as simplex channels.

8.2. Proposals specific to the implementation of VDE-SAT in Canada

50. As introduced in section 4 of this consultation, the ITU has designated VDES channels in frequencies from 157.1875 to 157.3375 MHz (channels 1024, 1084, 1025, 1085, 1026, 1086) and from 161.7875 to 161.9375 MHz (channels 2024, 2084, 2025, 2085, 2026, 2086). Within these allocations, channels 1026, 1086, 2026 and 2086 are identified exclusively for VDE-SAT. The remaining channels (1024, 1084, 1025, 1085, 2024, 2084, 2025, 2085) are designated for both terrestrial (VDE-TER) operations and satellite (VDE-SAT) operations, without imposing constraints on terrestrial usage (see Appendix 18, general notes w). VDE-SAT may operate in either the space-to-Earth direction or the Earth-to-space direction.

51. As shown in Table 1: Excerpt from the CTFA (2022 Edition) in Section 6, the maritime mobile satellite service is secondary to the primary mobile service in the VDE bands. Therefore, VDE-SAT operations cannot cause harmful interference to the terrestrial licensees in the band. Moreover, Appendix 18 specifies that the Earth-to-space component of VDES shall not cause harmful interference to, nor claim protection from, nor impede the future development of terrestrial systems operating in the same frequency bands.

52. Policy considerations: in the Canadian context, VDE-SAT could provide enhanced and reliable coverage in Canada's remote and polar regions with extensive coastlines and increasing maritime activities, ensuring connectivity in areas where terrestrial infrastructure is sparse or nonexistent. This improved communication capability is vital for the safety and efficiency of maritime operations in these regions, to enable precise vessel tracking, better navigation, and timely emergency responses. VDE-SAT could facilitate more effective monitoring and management of the Arctic shipping lanes exposed by melting ice, ensuring that navigation through these routes is safe and environmentally responsible. Its capacity to deliver real-time environmental data could support better ice and weather monitoring, enhance search and rescue operations in the Arctic, as well as support Indigenous communities by providing them with reliable access to maritime communication. In summary, VDE-SAT could be instrumental in advancing maritime safety, environmental protection, and economic growth for northern regions of Canada, fostering resilience and sustainable development amidst the challenges posed by their remoteness and climate extremes, and a lack of terrestrial maritime sites for navigation.

53. Technical considerations: ISED conducted an initial compatibility assessment between the satellite component of VDES and incumbent non-maritime services such as LMR and fixed radio, based on the parameters given in the most recent version of Recommendation ITU-R M.2092. The assessment concluded that permitting the introduction of VDE-SAT services in Canada would have a negligible impact on existing non-maritime services. Consequently, ISED proposes to authorize the use of the satellite component of VDES over Canadian territory should an application be received, noting that the authorization would be on a NINP basis with respect to terrestrial operation and subject to compliance with the power flux density (PFD) mask specified in Recommendation ITU-RM.2092.

54. Further, in accordance with footnote 5.208A in the CTFA, referring to Recommendation ITU-R RA.769, VDE-SAT operations will be required to protect radio astronomy services in the band 150.05-153 MHz from potential harmful interference that could be caused by unwanted emissions from space stations operating in the maritime mobile-satellite service (space-to-Earth). In order to protect radio astronomy operations, ISED proposes to require VDE-SAT transmissions to comply with the protection criteria provided in the most recent version of Recommendation ITU-R RA.769, using the methodology given in Recommendation ITU-R M.1583-1, for the applicable radioastronomy frequency bands.

55. ISED has implemented licensing instruments for maritime mobile satellite systems that are in effect in Ultra High Frequency (UHF) and other bands. ISED could leverage these existing licensing instruments and fees for maritime mobile satellite operations in the VDES bands as well. The paragraphs below provide some details on the licensing instruments for satellites and earth stations.

56. Licensing instruments for satellites: to authorize space stations in Canada, ISED issues either a space station spectrum licence to a Canadian satellite operator planning to offer services globally and/or in Canada, or a foreign satellite approval (FSA) to foreign-licensed satellite operators planning to offer services in Canada. Both types of authorizations are typically granted on a Canada-wide basis and within Canadian airspace and waters where the Radiocommunication Act applies. The licensing process for Canadian space station spectrum licences is described in CPC-2-6-02 - Procedure for the Submission of Applications for Spectrum Licences for Space Stations and the approval process for FSAs is described in CPC-2-6-04 - Procedure for the Submission of Applications to Approve the Use of Foreign-Licensed Satellites in Canada.

57. Licensing instruments for earth stations: prior to communication with any satellite, an earth station spectrum licence must be obtained, and are typically issued for a Canada-wide service area (i.e., Tier 1), as well as Canadian airspace and waters where the Radiocommunication Act applies.

58. There are two (2) types of earth station spectrum licences: site-approved and generic. For the purpose of VDES, generic earth station spectrum licences would be most relevant. The licensing process is described in CPC-2-6-03 - Procedure for the Submission of Applications for Generic Earth Station Spectrum Licences. In the context of VDES, an "earth station" refers to any ground-based terminal, such as a coastal station or suitably equipped vessel, that communicates with satellites to exchange data.

59. Licensing Fees: ISED is of the view that the existing satellite fee orders are appropriate for VDES licences at this time. As VDES evolves, ISED will periodically review the fees to see if they remain appropriate. ISED therefore proposes that VDES space station and generic earth station spectrum licences be subject to the fees in Notices No. SMSE-001-23, Fee Order for Space Stations and No. SMSE-002-23, Fee Order for Earth Stations, which are based on the amount of spectrum assigned in specific frequency bands. Fees for both types of licences are applied on an annual basis, with fees payable each year by March 31 for the upcoming year. There are no fees associated with FSAs, and none are proposed. Details on how the fees are applied can be found in the Fee Orders.

60. Additional information on satellite-related licensing, including licence terms and service standards, can be found in No. SMSE-008-22, Decision on Updates to the Licensing and Fee Framework for Earth Stations and Space Stations in Canada.

61. The implementation of digital technology and the termination of analog technology use in the VDE channels in compliance with Appendix 18, has some relevant impacts on other portions of the VHF maritime mobile band, aside from the VDE bands. This section addresses those impacts on the VHF maritime mobile band overall.

62. Future need for analog duplex channels for public correspondence in the VHF maritime mobile band: RBR-2 identifies a number of duplex channels for public correspondence (PC) in the VHF maritime mobile band. These duplex channels are traditionally used to enable simultaneous two-way analog technology-based voice communication between vessels and land-based telephones, facilitated by coast stations that bridge the radio and Public Switched Telephone Network (PSTN).

63. RBR-2 identifies fifteen (15) duplex channels in the VHF maritime mobile band, fourteen (14) of which are allocated for PC. The eight (8) channels identified to be used for VDES in Appendix 18 overlap with eight (8) of the fifteen (15) duplex channels. These duplex channels will no longer be available for analog operation after January 1, 2030. Of the remaining six (6) duplex channels, the upper frequencies of five (5) overlap with spectrum licensed to the Railway Association of Canada (RAC) for use along all railway corridors. Since the railway corridors are often located adjacent to major Canadian waterways including the coasts, these five (5) duplex channels are effectively unavailable for maritime duplex use. Consequently, after January 1, 2030, only one (1) duplex channel, channel 23, will remain available for analog technology based PC.

64. Report ITU-R M.2231-1 (11/2014) Use of Appendix 18 to the Radio Regulations for the maritime mobile service notes that the number of coastal stations offering the PC service has greatly declined globally, and that many countries no longer offer such a service. Internationally, countries have eliminated the use of PC channels in the VHF maritime mobile band, due to the availability of other more popular means of communication for maritime users, such as cellular and direct-to-device satellite communications. ISED believes that these alternate means for PC will increasingly replace the need for analog duplex channels in the context of maritime use of PC, particularly beyond 2030. Moreover, eliminating PC channels in 2030 and beyond could open up additional channels for other maritime use in the VHF maritime mobile band. ISED is seeking comments on the continued need for PC duplex channels beyond 2030 in the VHF maritime mobile band. If it is no longer needed, ISED will remove the duplex channels for PC.

65. Updating RBR-2: ISED intends to update RBR-2 to align with ITU changes and direction. With the objective of enabling a greater number of VHF maritime mobile channels for maritime operation across Canada, ISED has reviewed the restriction in the RBR-2 such as area of operation, nature of service, etc., for the VHF maritime frequency range and finds that they are out of date and not reflective of present and future maritime operational needs. ISED found that the current areas of operation are restrictive which prevents or limits new maritime entrants, and is particularly restrictive for Northern Canada (Arctic) and inland waters of Quebec and Ontario. The present nature of service prevents sharing amongst maritime operations. Further, clarifications are required for port operation power limits for channels that are used for shore operations.

66. Following a decision on this consultation, ISED will consult stakeholders on changes proposed to be implemented in RBR-2 and other relevant documents, which typically takes place via the Radio Advisory Board of Canada (RABC).

67. ISED intends to review the comments received and publish its decision on the policy, technical and licensing framework for maritime services in the VHF frequency band. Following the publication of a decision, ISED will update RBR-2 and develop the applicable technical standards, in consultation with stakeholders.

68. The comment and reply comment period will be followed by one or more decisions (may not decide on all aspects at the same time).

69. Respondents are requested to provide their comments in electronic format (Microsoft Word or Adobe PDF) by email to consultationradiostandards-consultationnormesradio@ised-isde.gc.ca.

70. Respondents are requested to specify question numbers for ease of referencing and to provide supporting arguments and rationale for each response.

71. Respondents are requested to take Canadian context into consideration in their response.

72. Paper submissions should be mailed to the following address:

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

73. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (SMSE-010-25). Parties should submit their comments no later than January 22, 2026, to ensure consideration. Following the close of the comment period, all comments received will be posted on ISED's Spectrum management and telecommunications website.

74. ISED will also provide interested parties with the opportunity to reply to comments from other parties. Reply comments will be accepted until February 23, 2026.

75. Following the initial comment period, ISED may, at its discretion, request additional information if needed to clarify significant positions or new proposals. In such a case, the reply comment deadline may be extended.