Consultation on Amendments to the Tower Siting Process and Decision on Roaming, Tower Sharing and Annual Reporting Requirements for Terrestrial Licences

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

3. Pursuant to the Radiocommunication Act, the Minister has the authority to approve tower sites and the construction of antenna-supporting structures, plan the allocation and use of spectrum, issue spectrum licences, fix the terms and conditions of licences, and amend the terms and conditions of any spectrum licence.

4. The Government of Canada recognizes the vital role that wireless services have come to play in Canadians' everyday lives as well as in emergency situations. Much like roads or electricity, Canadians expect these services to be ubiquitous, high quality and affordable. Increasing tower infrastructure is critical to achieving greater coverage and closing connectivity gaps. As such, ISED's tower siting policy prioritizes the efficient expansion of wireless infrastructure and access to the wireless services that all Canadians need.

5. Wireless communication is an integral part of the Canadian economy. Businesses, public institutions and consumers rely on wireless services and technologies to enable day-to-day activities such as conducting commercial transactions or connecting with family and friends. These services are also increasingly being leveraged to enable innovative and emerging use cases. Moreover, in emergency situations connectivity may be the difference between life and death or play a key role in the reduction of injuries and preservation of property.

6. In line with Canada's Connectivity Strategy, ISED is committed to the objective that all Canadians have access to the latest wireless telecommunications services at affordable prices where they live, work and travel. The strategy considers the needs of today and growth for tomorrow. It leverages a range of tools so that rural and remote communities can fully participate in the global economy and society. The result is vibrant and more resilient communities and a stronger, more connected Canada overall. A robust wireless telecommunications industry drives the adoption and use of digital technologies while enhancing the productivity of the Canadian economy.

7. Increasing the availability of wireless services in turn necessitates increasing investment in physical wireless infrastructure, including antenna towers. ISED is committed to supporting the development of that wireless infrastructure.

8. Through this consultation, ISED is also furthering Canada's Telecommunications Reliability Agenda by proposing ways to enable smoother wireless rollout with the expectation that industry will increase deployment with Canada's interests at the forefront. This means increasing network resilience and critical infrastructure required to protect Canada's interests, sovereignty and security.

9. In developing this consultation, ISED has been 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 derive from the use of radio frequency spectrum. This objective and the enabling guidelines listed in the SPFC, remain relevant for guiding ISED in delivering its spectrum management mandate.

10. Consistent with both Canada's Connectivity Strategy and the Red Tape Review, ISED is aiming to reduce the regulatory and administrative burden on wireless communication operators while also modernizing and streamlining existing processes. With the changes discussed in this consultation, ISED expects that operators will see reduced costs associated with regulatory compliance and a more efficient environment in which to invest and expand networks while continuing to promote transparency, efficiency and service continuity.

11. In July 2025, the Government of Canada launched a Red Tape Review across departments and agencies with regulatory responsibilities. As a telecommunications regulator, ISED has begun its Red Tape Review exercise to streamline inefficient or complicated processes, reduce burden associated with regulatory authorizations, and address outdated requirements. To this end, through this consultation, ISED is proposing to modernize the antenna tower siting process.

12. ISED regulates the antenna tower siting process across Canada by setting rules that tower proponents (such as telecommunications operators, broadcasters or third-party tower owners) must follow. The last substantial revision to the tower siting process was in 2007-08, following a suite of recommendations in the National Antenna Tower Policy Review (also known as the Townsend report). The political and technological context surrounding connectivity has shifted dramatically since that time. Rural connectivity and universal high speed wireless internet access are federal government priorities. At the same time, in terms of technology, Canadians expect 4G/LTE and 5G speeds across the country, and mobile operators are now using higher frequency bands that require additional towers to achieve this high-speed coverage. To reach these goals, new antenna towers will need to be constructed, and proponents will need to be able to take advantage of space on existing towers and other structures.

13. Mandatory roaming and antenna tower and site sharing ("tower sharing") are powerful tools for bringing Canadians more choice and high-quality commercial mobile service nationwide. Roaming remains essential for ubiquitous access, allowing licensees to offer Canada-wide service even in areas where they have not deployed their own networks. Meanwhile, tower sharing simplifies infrastructure deployment, reduces duplication and supports competition. Taken together, these measures empower smaller or regional licensees to provide increased choice to Canadians through services competitive with those offered by the national wireless operators.

14. ISED has reviewed the mandatory roaming and tower sharing client procedures circular (CPC-2-0-17) and has identified rules that can be simplified to reduce regulatory burden. As part of this consultation, ISED is clarifying its expectations concerning technical feasibility, reducing reporting requirements, and aligning the processes for requests considered to be withdrawn.

15. ISED, in its review of licensee requirements, has also identified some that are inefficient or that do not contribute meaningfully to ISED's policy objectives. In addition, since the time these requirements were introduced, the telecommunications market has matured, and ISED finds that telecommunications operators are adequately incentivized by market pressures to meet the aims of these objectives without regulatory burden. For these reasons, ISED has decided to remove certain licence conditions relating to investments in research and development and some annual reporting.

16. ISED is undertaking this consultation and has made these decisions in the context of the government's ongoing efforts to enhance competition in Canada, including within the telecommunications sector, as outlined in Budget 2025.

17. ISED's general and technical requirements for tower siting are captured under CPC-2-0-03 — Radiocommunication and Broadcasting Antenna Systems. Tower proponents (those wishing to put up an antenna tower or, in some cases, modify an existing tower) are required to consult the land use authority (LUA) responsible for the proposed site of the tower, the general public and businesses surrounding the tower. Section 4 of CPC-2-0-03 provides details about this requirement.

18. However, ISED believes elements of this process are outdated and can be streamlined to increase efficiency. ISED is proposing changes to enable the smoother development of wireless infrastructure while maintaining a role for LUAs to represent local interests and concerns.

Modernized approach to public consultation

19. ISED has identified an opportunity to reduce administrative and regulatory burden on tower proponents when fulfilling their public consultation requirements. Since the mid‑2000s, tower proponents have been required to notify the general public and local businesses about proposed tower installations in their areas in the manner prescribed by CPC-2-0-03, which requires the use of hardcopy notification packages, unless the LUA has set out different requirements. These packages include information regarding site selection, impact assessment, and how the installation will comply with all regulatory and technical requirements (ISED, Health Canada, Transport Canada, NAV Canada). ISED believes that, instead of paper notification packages, proponents may see a reduction in administrative burden by using a digital tool.

20. Specifically, ISED intends to establish an online portal into which proponents can upload relevant information. Uploading this information serves several purposes, including the following:

1. removes the need for paper notification packages (reducing the burden associated with these packages as the public will be able to access the notification information online)
2. provides a transparent platform for proponents to attest to the thoroughness and completeness of various requirements (such as how site sharing and alternate sites have been assessed and how valid concerns have been addressed, etc.)
3. organizes the notification packages in a standardized way for tower proposals across Canada (increases transparency while enabling the general public and LUAs to find information and details that they are most interested in)

21. In introducing an online portal, ISED contemplates the following steps for proponents to consult LUAs and notify the general public. Firstly, the proponent signals to ISED through the portal that a new tower (or a non-exempt tower modification) is being proposed in a certain area. The proponent will then engage with the LUA to discuss preferred sites. Following these discussions, proponents will attest to their efforts to explore tower sharing and alternate sites before uploading public notification documents. At this time, the public will also be notified via signage in the manner set out below.

22. Once notified, the general public can access and review the notification documents, including a list of responses to commonly raised questions and concerns. Should a resident have a question or concern not already answered in the notification documents, they can communicate with the proponent at the coordinates that the proponent will provide in the portal upload, much like ISED's current default consultation process outlined in section 4.2 of CPC-2-0-03. Members of the public will have 30 days from the date of notification (upload to the portal and placement of signage, whichever is later) to make these communications.

23. ISED expects all communications during the consultation phase to be made between the parties – records of the consultation will not be maintained in the portal. As such, it will be the sole responsibility of the proponent to ensure accurate records are maintained.

24. Once the proponent has responded to all reasonable and relevant concerns, the proponent attests to this in the online portal, and a time-limited window begins for LUAs to provide concurrence. If the LUA does not indicate concurrence or non-concurrence within the timeframe (ISED is currently proposing 45 calendar days), ISED will consider the tower approved.

25. If the LUA does communicate concurrence, the proponent will be expected to upload the concurrence document into the portal. If an LUA does not concur with a proposal, it can communicate non-concurrence to the proponent, who is expected to upload this document into the portal.

26. ISED will establish a list of valid concerns an LUA may have to support non-concurrence (see "Proposed changes to LUA concurrence" section below). If an LUA does not concur based on one or more of these valid reasons, it will notify the proponent of its non-concurrence within the concurrence timeframe. Then, ISED will expect the proponent to address the concern, if possible. Once the concern is addressed, the LUA is expected to provide concurrence. If the concern is not addressed, the LUA will need to determine whether to seek a resolution to the dispute from ISED within the concurrence timeframe. If the LUA does not seek this resolution within the stipulated timeframe, the tower will be considered as approved to proceed, notwithstanding the lack of concurrence. Extensions to the timeframes for resolution of non-concurrence will be possible with mutual agreement between the proponent and the LUA.

27. The online portal will be available to the public and will allow interested individuals or groups to subscribe to notifications for tower proposals in their area when those proposals are released to the public. LUAs will also have access to this information, and LUAs may share the information with impacted constituents in the manner that they see fit. While the information concerning a proposed tower will be available to any member of the public, ISED will require that proponents respond only to the concerns and questions raised by the public who are located within a radius that is three times the height of the proposed tower.

28. With the online portal facilitating the LUA consultation and public notification process for tower siting proposals, ISED will employ this single-window digital space as a replacement for ISED's default public consultation process (section 4.2 of CPC-2-0-03). As a consequence of these steps to streamline and simplify the consultation process, the portal will support a single antenna consultation processes for use across Canada. Specifically, this process will replace antenna tower siting processes designed and used by municipalities.

Proposed changes to public notification requirements

29. Part of ISED's default public notification process, outlined in section 4 of CPC-2-0-03, requires proponents to respond to questions or concerns raised by the public that are reasonable or relevant. A list of examples of reasonable and relevant concerns are found in that section of the CPC. For concerns the proponent believes to be unreasonable or irrelevant, they are required to explain why they are of that view.

30. ISED intends to require that proponents clearly indicate, as part of the public notification process in the online portal, their answers to the following questions:

1. how will the tower improve telecommunication in the area?
2. why is the proponent not using an existing antenna system or structure (including listing nearby structures and explaining why they are not suitable)?
3. what alternate sites were considered and why were they not selected?
4. what is the proponent doing to ensure that the antenna system meets safety requirements, including aeronautical safety, radio frequency exposure limits, and restricted access to the general public?
5. how is the proponent minimizing impacts to the environment and meeting statutory requirements under the Impact Assessment Act?
6. how is the proponent trying to integrate the antenna into the local surroundings?

31. Further to the above, ISED proposes that proponents only be required to address the reasonable or relevant concerns of those inhabiting within a radius of three times the height of the proposed tower.

32. Tower proponents have used paper notification packages to inform communities of tower proposals for nearly two decades. Although ISED continues to believe in the importance that the public be notified of tower proposals, it is also ISED's belief that accessing the same information online presents a modernized approach that will deliver that same information more efficiently compared to paper copy notification packages. However, to ensure the public are made aware of any proposed antenna system, ISED proposes that in lieu of a paper notification package, proponents would be required to erect physical signage at the site of the proposed antenna tower directing the public to the web portal for further information.

33. Further to the above, ISED proposes that all physical signage include the following information:

• name of the proponent(s)
• the intention to construct a tower at the location
• address of the proposed site of the tower
• height of the proposed tower
• a link to ISED's online portal (e.g., QR Code), specifically the page where the information related to the tower proposal is located
• a valid telephone number that the public can contact to request a paper copy of the relevant information in the event they are unable to access the portal

34. Additionally, ISED proposes that following criteria should be observed regarding all physical signage, meaning it should:

• be digitally printed
• be put in place at the time the details of the public notification are uploaded to the online portal
• be easily legible from the area where the public could reasonably be expected to view it
  • in cases where the location of the proposed tower is neither accessible nor visible, the proponent should erect a sign in an area that is nearest to the proposed site
• be maintained by the proponent, including repair of damaged signs
• meet the official language requirements established under section 4.4. of CPC-2-0-03
• be removed within a week of the tower being approved

35. Given the clarity, transparency and accessibility enabled by the online portal, ISED is also proposing to remove the requirement for proponents to place notices in local newspapers for towers that require consultation.

Proposed changes to LUA concurrence

36. While only the federal Minister of Industry has the authority to approve tower sites, per paragraph 5(1)(f) of the Radiocommunication Act, LUA concurrence is an important aspect of the tower siting process as LUAs represent local concerns with respect to land use in their communities.

37. Currently, when an LUA does not concur with an antenna tower proposal, ISED encourages the proponent and the LUA to find a mutually agreeable solution to the LUA's concerns. If discussions are not fruitful, either party can signal an impasse to ISED, ISED will then request and review all information from both parties and make a final decision as to the tower's location.

38. Consistent with the priority placed on expanding connectivity for the benefit of Canadians, ISED is proposing to establish a timeline for such concurrence whereby once the proponent has indicated (through the online portal) that, to the best of its knowledge, all ISED requirements have been met, the LUA will have a limited time to provide either its concurrence or non-concurrence to the proponent. After this timeframe, if the LUA has not communicated concurrence or non-concurrence, the process will be deemed complete for the purposes of approving the tower. Strict timelines will minimize delays to the development of wireless infrastructure when accounting for LUA input into tower siting decisions.

39. ISED is proposing 45 calendar days for the LUA concurrence timeframe to strike a balance between the interests of both the communities and the proponents involved. If LUAs require additional time, they can communicate with the proponent to find a mutually agreed upon timeline to grant concurrence.

40. If an LUA is concerned that a proponent did not fulfil all ISED requirements or did not undertake a complete public consultation process, these would be valid reasons for non-concurrence. ISED invites comments on what other factors can be considered valid for the purposes of non-concurrence. Below are examples of what ISED considers valid concerns for LUAs to not concur with a tower proposal:

1. LUA consultation process not followed
2. public notification process not followed
3. safety requirements not followed (e.g., insufficient measures to prevent general public access to a tower site)
   1. this expressly excludes concerns related to the validity of Safety Code 6 as a measure of health impacts

41. In the event an LUA has concerns in relation to non-ISED and/or non-consultation requirements (e.g., non-compliance with Transport Canada's aeronautical safety requirements), ISED deems this to be separate from the tower siting process and the LUA should contact the responsible entity directly.

42. If an LUA objects to a tower proposal based on a valid concern, the LUA will notify the proponent, who will then be expected to take reasonable steps to resolve the concern within the original 45 day time period. However, if by the end of the concurrence timeframe the LUA is still of the view that the tower proposal should not go forward, the LUA must trigger dispute resolution by notifying ISED of the dispute, identifying the valid concern and providing supporting documentation. If the LUA does not take the step of triggering dispute resolution, the tower will be considered approved to proceed without the concurrence.

Dispute resolution process

43. Given the proposed concurrence timeframe and the default approval of the tower in the absence of a dispute being raised by the LUA, ISED is of the view that proponents will have little need to seek dispute resolution themselves.

The "15 metre exclusion"

44. Section 6 of CPC-2-0-03 lists types of proposals that ISED has excluded from the LUA and public consultation requirements in that document. One of those exclusions applies to proposals for new antenna systems where the height is less than 15 metres above ground level, sometimes called the "15 metre exclusion".

45. However, telecommunications operators, third-party tower owners and broadcasting undertakings are currently not permitted to use this exclusion. ISED is aware that not allowing certain proponents to use this exclusion may cause confusion among LUAs, proponents and Canadians, and imposes asymmetric regulatory burden on certain proponents. ISED is seeking views on standardizing the exclusion, such that it will apply to all proponents, allowing all proponents to forego LUA consultation and public notification for antenna systems below 15 metres.

46. Additionally, ISED is interested in comments about whether 15 metres in height for exclusion is the best threshold for proposals. This threshold has not been changed since it was introduced. ISED is seeking comments about whether that threshold should change and what the impacts would result from the change.

47. It should be noted that if ISED allows telecommunications operators, third-party tower owners and broadcasting undertakings to make use of the "15 metre exclusion" as discussed in Q9, a revised height limit will apply to these proponents as well.

48. Proponents will still be required to follow general requirements, including the strict radio frequency exposure limits established under Safety Code 6.

49. Exclusions from public notification requirements will also mean that the proposals will not be uploaded to the portal.

Facilitating small cell deployment

50. In most cases, small cells do not have dedicated antenna-supporting structures. Instead, they are affixed to buildings and street furniture. These installations are normally excluded from LUA and public consultation as set out in section 6 of CPC-2-0-03.

51. However, ISED is interested in hearing about gaps and/or opportunities in CPC-2-0-03 that ISED can examine to facilitate small cell deployment in the future.

52. Canadian wireless networks provide services not only through individual physical networks but also through network sharing and roaming arrangements. Additionally, tower sharing is an important tool to maximize efficient infrastructure development while minimizing tower proliferation. These measures empower smaller or regional licensees to provide increased choice to Canadians through services and coverage competitive with those offered by the national wireless operators.

53. Mandatory roaming and antenna tower and site sharing ("tower sharing") are powerful tools for bringing Canadians more choice and high-quality commercial mobile service nationwide. Roaming remains essential for ubiquitous access, allowing licensees to offer Canada-wide service even in areas where they have not deployed their own networks.

54. When it comes to roaming and tower sharing, ISED expects operators to negotiate in such a manner that Canadians, particularly those in rural and remote areas, will not suddenly lose service that they have come to rely on due to contract disputes. ISED also expects that operators will work together during disputes or negotiations and conduct themselves in a manner that shows a concern for the welfare of the customers involved.

Technical feasibility

55. Under the current mandatory roaming and tower sharing condition of licence, roaming and sharing must be offered where technically feasible, and ISED is consulted as necessary to decide on technical feasibility in the event of disputes. However, as noted in CPC-2-0-17, ISED expects that roaming and tower sharing will be technically feasible in the vast majority of cases.

Mandatory roaming technical feasibility

56. Since CPC-2-0-17 was last amended in 2013, smartphones have evolved to integrate most, if not all, commercial mobile bands available in Canada, providing the capability for these devices to roam on networks across the country. In the future, ISED does not foresee technical barriers to roaming given the widespread domestic and international agreements already in place. Therefore, ISED considers roaming to be technically feasible. All issues relating to technical details are to be dealt with through negotiation with recourse to arbitration. Given ISED's determination of roaming feasibility, ISED has decided to remove itself from these disputes and consequentially is making the following changes to CPC-2-0-17.

Tower sharing technical feasibility

57. Although tower sharing involves technical considerations such as tower capacity and interference, ISED is not in a position to make a ruling on technical feasibility of tower sharing and notes that there have been minimal complaints since the requirements were first imposed. ISED does not anticipate technical feasibility impediments to implementation. As a result, ISED considers tower sharing to be technically feasible and will no longer consider disputes relating to technical feasibility. Consequently, the following changes to CPC-2-0-17 will be made.

Technical feasibility section

58. Section 4.3 of CPC-2-0-17 addresses both mandatory roaming and tower sharing technical feasibility. It will be amended to reflect that all issues relating to technical details are to be dealt with through negotiation with recourse to arbitration.

Modification of arbitration CPC-2-0-18

59. ISED will amend CPC-2-0-18 - Industry Canada's Arbitration Rules and Procedures to indicate that an arbitrator will decide on any claims of technical feasibility.

Expiration of roaming requests

60. The following is included in the tower sharing portion of CPC-2-0-17:

• Outstanding Offers to Share:


• If, within 60 days, the Responding Licensee has not received a response from the Requesting Operator to an Offer to Share, the Licensee may treat the Offer to Share as withdrawn with no further obligations. A response may simply be an acknowledgement by the Requesting Operator that additional time is required to consider the Offer.

61. This concept is not included in the mandatory roaming portion of the CPC. For clarity and consistency, ISED has decided to include similar language for mandatory roaming and consequentially is making the following changes to CPC-2-0-17.

Reporting on refusal for imminent future use

62. Imminent future use refers to equipment installations planned within 18 months of a preliminary information package (PIP) request, which should not be disrupted unless both parties agree to negotiate access to it. These plans must be reasonable, well-documented, and align with near-term future needs (see CPC-2-0-17, section 2.2). ISED expects good faith negotiations for both near-term and long-term future use requirements. Currently, responding licensees must submit a copy of any PIP to ISED if it includes reservations for imminent future use.

63. Given the minimal complaints about the tower sharing condition of licence generally, and as an arbitrator can decide on disputes regarding good faith negotiating, ISED is removing the requirement to send ISED any PIP reports that include imminent future use scenarios.

Tower sharing reports

64. As per CPC-2-0-17, ISED currently requires all licensees to report on key tower sharing data points every six months to allow ISED to monitor negotiations and the effectiveness of the condition of licence in meeting the policy objectives.

65. To reduce regulatory burden on operators, ISED will no longer require operators to submit tower sharing reports twice per year. However, ISED can ask for any relevant information relating to compliance with this requirement at any time.

Research and Development (R&D) requirements

66. The Minister, in exercising their authorities as conferred on them by the Radiocommunication Act, has due regard to the policy objectives set out in section 7 of the Telecommunications Act, including "to stimulate research and development in Canada in the field of telecommunications and to encourage innovation in the provision of telecommunications services." For this reason, ISED has included the Research and Development (R&D) requirement upon terrestrial commercial mobile spectrum licences.

67. However, the telecommunications market has undergone significant growth and evolution since the R&D requirements were first introduced. Telecommunications is now a mature market, and sustained investments in new technology advancements and efficiencies will be more important than ever in an increasingly competitive environment, regardless of government intervention. This reality is reflected in overall licensee investment rates in R&D related activities, which already regularly exceed the 2% investment minimum required under the current condition of licence.

68. Given the already high level of R&D related activities undertaken by licensees, ISED is of the view that the R&D requirement is no longer needed to support the policy objectives of the Telecommunications Act. As such, ISED will remove this requirement from all existing terrestrial spectrum licences, effective from the date of the publication of this consultation.

Annual reporting requirements

69. An important aspect of taking a reasonable and effective approach to spectrum regulation means ensuring that licensee reporting requirements provide ISED the essential information it needs, when it needs it, to properly carry out government policy objectives and its responsibilities under the Radiocommunication Act.

70. ISED recently updated its reporting requirements on technical information associated with radiocommunication installations (site data). This update included the introduction of several new information fields and more frequent reporting obligations, requiring most spectrum licensees to report or update their information every month. It is expected that the information collected through this process will be sufficient to support ISED's spectrum management and policy development, including compliance verifications with licence terms and conditions, interference investigations, international coordination efforts, and other spectrum management policy decisions.

71. For these reasons, ISED has determined that the annual reporting requirement for terrestrial licences is burdensome, inefficient and redundant, and will remove it from all terrestrial spectrum licences. ISED notes that it may, at any time, request any information from licensees which it considers necessary for the purpose of verifying and upholding compliance with the Radiocommunication Act.

72. Each of the questions for consultation and decisions above are intended to enhance overall competition in the wireless telecommunications sector by enhancing the overall efficiency of providing wireless telecommunications and expanding wireless infrastructure. ISED is aware that further action could potentially make additional progress in this regard.

73. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (DGSO-001-26). Parties should submit their comments no later than July 16, 2026, to ensure consideration. Soon after 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 August 25, 2026.

75. Respondents are requested to provide their comments in electronic format (Microsoft Word or Adobe PDF) by email.

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

• Innovation, Science and Economic Development Canada
  Senior Director, Spectrum Operations Directorate, Spectrum Management Operations Branch
  235 Queen Street (6th Floor, East Tower)
  Ottawa ON   K1A 0H5

77. As all comments will be posted on the departmental website, those making submissions are responsible for ensuring that they do not contain confidential or private information.

78. All spectrum-related documents referred to in this paper are available on ISED's Spectrum Management and Telecommunications website.