Decision on Changes to Licensing Requirements and Conditions of Licence for Space Debris Mitigation

1. Through the release of this paper, Innovation, Science and Economic Development Canada (ISED), on behalf of the Minister of Innovation, Science and Industry (the Minister), announces decisions (the Decision) resulting from the consultation process undertaken in Canada Gazette Notice SMSE-013-24 - Consultation on Changes to Licensing Requirements and Conditions of Licence on Space Debris Mitigation (the Consultation). The Consultation focused on updating the current non-geostationary satellite orbit (NGSO) licensing requirements and conditions of licence (COL) related to the mitigation of space debris, as found in Client Procedures Circular CPC-2-6-02, Procedure for the Submission of Applications for Spectrum Licences for Space Stations.

2. Comments and/or reply comments were received from:

• AlbertaSat
• Astronomers – Group of individuals
• Astroscale Ltd (Astroscale)
• Canadian Space Agency (CSA)
• Commercial Smallsat Spectrum Management Association (CSSMA)
• Department of National Defence (DND)
• Environment and Climate Change Canada (ECCC)
• Fleet Space Technologies (Fleet Space)
• Geocentrix Technologies Ltd. (Geocentrix)
• GHGSat
• Global Satellite Operators Association (GSOA)
• Globalstar, Inc. (Globalstar)
• Halliwell, Erik and signatories
• International Astronomical Union (IAU)
• Kepler Communications Inc. (Kepler)
• Kuiper Systems LLC (Amazon Leo)
• Mann, Prof. Ian R., PhD FRSC
• MDA Space (MDA)
• Myriota Canada Inc. (Myriota)
• Outer Space Institute (OSI)
• Planet Labs PBC (Planet Labs)
• Purpose Partners
• Quaternion Aerospace Inc (Quaternion)
• Satelio IoT Services, S.L. (Sateliot)
• Space Exploration Technologies Corp. (SpaceX)
• Spire Global Canada Subsidiary Corp and Spire Global Inc. (Spire)
• Telesat
• Terrestar Solutions Inc. (Terrestar)
• University of Victoria Centre for Aerospace Research (UVic)
• Viasat

3. The Minister, under the Department of Industry Act, the Radiocommunication Act and the Radiocommunication Regulations, and in alignment with the objectives of the Telecommunications Act, is responsible for spectrum management in Canada. This includes developing national policies and objectives for spectrum use, as well as ensuring the efficient management and use of the radio frequency spectrum resource and associated orbital resources.

4. ISED is committed to ensuring that Canadians continue to benefit from advanced wireless services that support digital adoption, economic productivity and global competitiveness. Satellites play a critical role in delivering high-quality, innovative wireless services, particularly to Canadians in rural and remote areas.

5. The rapid deployment of satellite constellations in non-geostationary satellite orbits (NGSO), including low-Earth orbit (LEO), which is defined by the Inter-Agency Space Debris Coordination Committee (IADC) as an altitude range below 2,000 kilometers) and medium Earth orbit (MEO), which is defined as an altitude range between 2,000 kilometers and 35,786 kilometers, promises improved low-latency broadband connectivity. However, this proliferation increases orbital congestion and collision risks that could impact current and future services and threaten space sustainability, as highlighted in the United Nations Office for Outer Space Affairs' Guidelines for the Long-term Sustainability of Outer Space Activities.

6. In this context, it is increasingly important for all satellite operators to minimize the risks of space debris through responsible design, operation and the timely de-orbiting of their satellites. It is equally essential for regulatory frameworks to keep pace with the rapidly changing orbital environment.

7. In developing this Decision, ISED was guided by the policy objectives of the Telecommunications Act and the Spectrum Policy Framework for Canada (SPFC), which emphasizes that the radio frequency spectrum is a unique resource that should be utilized to maximize the economic and social benefits for Canadians. In the context of satellite spectrum, the Minister's responsibility under the Radiocommunication Act for the orderly development and use of the spectrum resource cannot be separated from the management of associated orbital resources.

8. ISED was also guided by its obligations under Article 44 of the International Telecommunications Union (ITU)'s Constitution, which states that Member States that use frequency bands for radio services "…shall bear in mind that radio frequencies and any associated orbits, including the geostationary-satellite orbit, are limited natural resources and that they must be used rationally, efficiently and economically."

9. As noted in the Consultation, the substantive increase in the deployment of NGSO satellite systems to support broadband connectivity has intensified orbital congestion, raising concerns about the growing risk of space debris, which the IADC defines as "all human made objects including fragments and elements thereof, in Earth orbit or re-entering the atmosphere, that are non-functional." The expected roll-out of commercial satellite constellations to support direct-to-device services will further intensify orbital congestion.

10. In such a congested space environment, operators have less time to assess and respond to potential collision risks, increasing the likelihood of accidental collisions and the subsequent creation of more debris. The rising number of space objects necessitates more frequent course corrections, which require the expenditure of onboard fuel and dedicated personnel, and disrupts operations. It also affects access to higher orbits, where satellites critical to global navigation and telecommunications services, among others, are deployed.

11. For Canadians, the potential loss of satellite services could severely disrupt communication services nationwide, hindering economic development, educational opportunities, and emergency response capabilities. It is with this context in mind that ISED published its Consultation on Changes to Licensing Requirements and Conditions of Licence on Space Debris Mitigation (the "Consultation"), aimed at strengthening regulatory measures that support long-term space sustainability.

12. Through this Decision, ISED is updating its licensing requirements and conditions of licence related to the mitigation of space debris to strengthen Canada's regulatory framework, advance international sustainability objectives, and safeguard satellite services relied upon by Canadians.

13. In the Consultation, ISED sought comments on several proposals to update the existing space debris framework. ISED noted that as part of the licensing application process, NGSO satellite operators are currently required to submit a space debris mitigation plan that is consistent with the guidelines issued by the IADC, including the requirement for the satellite(s) to de-orbit within 25 years of end of operational life. However, to reflect the evolving NGSO environment, changes in licensing practices among other satellite licensing administrations, and technical guidelines of international organizations such as the IADC, ISED proposed updates to the existing requirements. These include introducing specific requirements to reduce the probability of accidental collisions, amend the post-mission disposal requirement from 25 to five years and increase the reliability metrics of such disposal. Unless otherwise noted, these proposals were to apply to all types of NGSO systems (LEO, MEO, and Highly Elliptical Orbit (HEO)).

14. Overall, respondents supported many of ISED's proposals, highlighting the importance of addressing the growing risks of collision in congested orbital environments and contributing to long-term space sustainability. Respondents also stressed the importance of aligning with updated international guidelines and requirements of other satellite licensing administrations. They did, however, note concerns with, and opposition to, some of the proposals, which they saw as disadvantaging Canadian operators both financially and competitively.

15. This section details decisions to update the licensing requirements and conditions of licence on space debris mitigation. Updated wording for the conditions of licence is shown in Annex A.

5.1 Reducing the probability of accidental collisions

16. ISED proposed requirements in four key areas for limiting the risk of accidental collisions: knowledge of planned orbits; space situational awareness; an assessment of the possibility of collisions with objects, both large and small; and manoeuvrability.

5.1.1 Knowledge of planned orbits – detailed environmental assessment

17. ISED sought comments on the proposal to require applicants, as part of their application for a spectrum licence for an NGSO system, to provide a detailed assessment of the orbital environment in which they intend to operate. This assessment would include an analysis of the number of planned and operating satellites at or within ± 100 km of any of their proposed orbits, identification of collision risks, measures taken to coordinate with other systems, additional mitigation strategies, and the potential impact on adjacent satellite systems.

Summary of Comments

18. In general, respondents agreed with the intent of the proposals but emphasized the need for clearer guidelines, standardized tools, and alignment with international regulations.

19. Amazon Leo, Astroscale, CSA, GHGSat, MDA, Myriota, Purpose Partners, Quaternion, Telesat and Terrestar supported the requirement to undertake an environmental assessment. Professional Astronomers supported requiring NGSO applicants to provide additional information on collision avoidance manoeuvres and suggested that this information include frequent updates to public databases as these updates are vital to space situational awareness and radio astronomy.

20. GHGSat, MDA, Telesat and Terrestar argued that the ± 100 km range is excessive and burdensome. GHGSat noted that it is unrealistic for operators launching with rideshare programs to do a detailed assessment given that orbit prediction is difficult. MDA recommended limiting the range to within the planned orbit and only requiring applicants to report on potential mitigation measures when there is the potential for conjunction events. The company also suggested a detailed assessment should only focus on orbits where the satellite(s) will spend significant time. Telesat asked ISED to consider requiring applicants to declare the orbit altitude band from the nominal frozen orbit shells within which its planned satellites will operate, commit to operating its satellites within this band, and provide a corresponding space environment assessment. Terrestar supported Telesat's proposal.

21. Quaternion expressed the view that an assessment based solely on a 100 km range may not be sufficient as it may not capture conjunction events in substantially different orbits.

22. Myriota, Sateliot, Spire and two universities (AlbertaSat and UVic) expressed concerns about the regulatory burden, complexity, lack of reliable data, and the potential financial strain of providing an environmental assessment, advocating for a tiered or risk-based approach for small and academic missions. Telesat rejected the idea of a tier-based assessment proposal or stricter scrutiny for large constellations, arguing that risk is not size dependent. Spire proposed that the assessment of the environment only be mandated for either "mega constellation (e.g. 1,000+ satellites)" or "…very large-size satellites (180+ kg)".

23. CSA, DND, Geocentrix and Kepler noted the challenges of gathering reliable data on satellites operating within ±100 km of their proposed orbits and questioned the value of undertaking a detailed assessment given the rapidly-changing space environment between the time of application and launch of an NGSO satellite.

24. Geocentrix asked ISED to provide details regarding this requirement so that applicants can properly conduct an environmental assessment and to clarify whether these requirements are for information or assessment purposes. Astroscale and Kepler similarly recommended that ISED develop standardized assessment criteria and establish a centralized repository for satellite data. Purpose Partners suggested ISED develop a resource kit for applicants. Both Astroscale and GHGSat urged ISED to ensure that assessments do not result in restrictions on the use of orbital ranges given the dynamic nature of space operations.

25. Finally, CSA recommended that ISED specify models or tools such as NASA's Debris Assessment Software (DAS) or ESA's Meteoroid and Space Debris Terrestrial Environment (MASTER) tool. MDA requested that ISED ensure that existing tools such as DAS or Debris Risk Assessment and Mitigation Analysis (DRAMA) support the expected analysis results. In its reply comments, Terrestar expressed support for MDA's proposal.

Discussion

26. ISED notes the broad support received from stakeholders for the proposal to require applicants to provide a detailed assessment of the orbital environment in which they plan to operate. Respondents acknowledged the importance of such assessments in promoting space sustainability, reducing collision risk, and improving coordination among operators.

27. While Amazon Leo, CSA, MDA and Telesat expressed support for the proposed requirement, they did emphasize the need for clearer guidance, standardized assessment tools, and alignment with international best practices. ISED acknowledges these suggestions and recognizes the importance of ensuring consistency with evolving global norms. Therefore, ISED will not develop its own toolkit for assessments but will accept analysis resulting from internationally recognized tools such as NASA's DAS or ESA's DRAMA or MASTER.

28. At the same time, ISED believes it is important to strike a balance between providing sufficient clarity and avoiding an overly prescriptive approach, such as requiring that specific models be used when undertaking an environmental assessment. ISED is of the view that operators should retain flexibility in how they conduct and present their orbital environment assessments, provided that the submission clearly addresses the following core elements: identification of potential collision risks; measures taken or underway to coordinate with other satellite systems; any additional mitigation strategies to reduce risk; and the anticipated impact on adjacent or nearby systems. The submission must state which tool was used to conduct the assessment.

29. ISED acknowledges the need to ensure that regulatory obligations are practical and not unduly burdensome. As such, it agrees with the position advanced by Telesat and others that a uniform requirement should apply to all satellite operators, regardless of constellation size or mission scale. Mitigating the growing risk of space debris is a shared responsibility, and all actors—large and small—contribute to the long-term sustainability of the space environment. ISED believes that applying a consistent assessment requirement for all applicants is fair, transparent and accountable, and strengthens Canada's commitment to responsible space operations.

30. Regarding questions on whether the proposed orbital-environment assessment would influence licensing outcomes such as denying an application for certain orbital planes, ISED is of the view that this assessment is an essential component of an overall orbital mitigation strategy. As a result, ISED will evaluate the assessment on a pass or fail basis.

31. Regarding the proposed ± 100 km orbital margin for environmental assessments, several operators expressed concerns that the range was arbitrary and overly restrictive, and placed an unrealistic administrative burden on smaller operators given the rapidly-changing space environment between the time of application and launch. It was also highlighted that satellite operation is often maintained to within a few kilometers of the nominal orbits.

32. ISED recognizes the challenges of finding the appropriate distance for which to conduct an environmental assessment as there is no clearly established benchmark. In response to the feedback on this issue, ISED will require applicants to include an analysis of the number of planned and operating satellites at or within 30 km of any of their proposed orbits. This distance aligns with the orbital tolerance for declared satellites that was established in RESOLUTION 8 (WRC-23). ISED notes that the purpose of RESOLUTION 8 (WRC-23) is unrelated to orbital debris mitigation; however, it provides a reasonable basis for this requirement.

33. ISED recognizes that operators planning to launch with rideshare programs may not know, prior to launch, the exact orbit into which their space station will be inserted. Licensees using rideshare programs will be required to submit an environmental assessment of the orbit in which they expect to operate. Should the final orbit be different, an updated assessment must be submitted.

Decision

5.1.2 Updates to environmental assessment

34. ISED proposed that, when applying for a licence amendment to modify the authorised orbital parameters, NGSO licensees be required to submit an updated environmental assessment containing the same information required at the time of the original licence application and issuance.

Summary of Comments

35. Amazon Leo, CSA, MDA, Purpose Partners and Telesat, supported the proposal for updated assessments when applying for licence amendments. However, Kepler, Myriota, Sateliot and UVic were opposed as it would impose unnecessary regulatory burden and cost, with Kepler adding that it would discourage operators from making iterative improvements and stifle innovation. Kepler also requested that ISED provide detailed guidance to assist applicants in meeting this obligation and establish or facilitate access to a centralized repository containing up-to-date information on operating and planned satellites. Spire reiterated its position that environmental assessments should apply only to "mega-constellations" or "very large-size satellites (180+kg)."

36. AlbertaSat requested clarification on whether an amendment would be required whenever there is a significant orbit change during a mission such as during de-orbit phase.

37. Astroscale recommended a flexible approach and suggested exemptions for short-duration manoeuvres. Telesat proposed that updated assessments should only be required if changes exceed the Declared Altitude Band or the tolerances outlined in RESOLUTION 8 (WRC-23) while Purpose Partners suggested that an updated assessment only be mandatory when the proposed modifications significantly impact the results of the previously submitted assessment such as number of satellites, satellite mass, satellite reflectivity and cross-sectional area. Such a list would help applicants determine whether there are significant changes to highlight.

38. In its reply comments, Telesat re-iterated its opposition to proposals for stricter scrutiny for larger constellations. Terrestar supported the proposal to require more precision for environmental assessments when making a licence amendment. GHGSat requested clearer guidance on what triggers an amendment post-launch, and how it intersects with ITU modification obligations.

Discussion

39. Comments and reply comments demonstrated broad recognition of the importance of notifying ISED when operational changes may affect a satellite's collision or re-entry risk. At the same time, respondents expressed a wide range of views on how strictly these requirements should be applied, particularly in relation to modifications that have limited operational impact or that may not be known prior to launch.

40. ISED acknowledges these differing perspectives and maintains its view that operators must submit an updated space debris mitigation plan when there is a change in the satellite's authorised orbital parameters and/or satellite design that affects the results of the previously submitted orbital environment assessment - for example, changes to area-to-mass ratio, alterations to orbital configurations beyond ITU tolerances or shifts in operational behaviour that increases the risk of collision.

41. At the same time, ISED recognizes the need for operational flexibility. Temporary collision-avoidance manoeuvres, short-duration dynamic activities—such as Rendezvous and Proximity Operations—and other manoeuvres that do not materially affect long-term collision or re-entry conditions will not require an updated environmental assessment to be submitted.

42. Concerns regarding regulatory burden—particularly for small or new operators—were a recurring theme. ISED acknowledges these concerns but is of the view that updates to environmental assessments, which are essential to ensuring safe and sustainable orbital operations, will be required from all licensees.

Decision

5.1.3 Space situational awareness

43. ISED proposed introducing a condition of licence requiring NGSO licensees to register with, use, and maintain a space situational awareness (SSA) service throughout the operational life of their satellites. This measure is intended to ensure that satellite operators receive timely conjunction alerts and can take necessary actions to avoid potential collisions with other satellites or debris in increasingly congested orbital environments.

Summary of Comments

44. Respondents broadly supported ISED's proposal to require NGSO licensees to register with, use, and maintain an SSA service and receive conjunction alerts. Support was expressed by Amazon Leo, CSA, Geocentrix, GHGSAT, Erik Halliwell and signatories, Kepler, MDA, Myriota, OSI, Planet Labs, Sateliot, SpaceX, Spire, Telesat and Terrestar.

45. Flexibility in SSA provider selection was emphasized by GHGSat, MDA, Myriota and Telesat, who stressed the importance of operators being able to choose internationally recognized services that meet their operational needs while ensuring a baseline level of capability. Telesat further proposed expanding the requirement to include services comparable to those offered by the 18th Space Control Squadron, TraCSS, or EU SST, coupled with obligations for operators to assess and mitigate risks upon receiving conjunction warnings.

46. Several respondents underscored the need for low-cost or free options, particularly for small and academic missions. DND noted that private services may be considerable for academic or small operators, noting the need for a free basic safety collision screening assessment. Similarly, GHGSat, Kepler, Myriota, Sateliot and UVic recommended allowing the use of free or public SSA services. Sateliot proposed that ISED recognize commercial and publicly available SSA services such as CelesTrak and Space Track as compliance mechanisms.

47. Geocentrix suggested that if registration is mandatory, ISED or CSA should consider providing the service at no cost to maintain Canadian competitiveness. Similarly, AlbertaSat asked if ISED would provide the service to academic groups. CSA supported the proposal while recommending that ISED identify recognized SSA providers, clarify applicability for non-propelled spacecraft, encourage GPS-based tracking, require licensees to provide a designated point of contact, and require operators to maintain procedures for responding to alerts.

48. On data sharing and coordination, Amazon Leo supported the proposal but requested requirements for accurate ephemeris data sharing, up-to-date operator contact information, and coordinated collision-avoidance actions. GHGSAT also encouraged mandatory ephemeris data sharing and standardized operator communication. Spire, Planet Labs and OSI similarly highlighted the importance of transparent data exchanges and active operational coordination. SpaceX supported applying the rule to Canadian and foreign-licensed operators, calling for covariance-based ephemeris screening, public data sharing, and routine reporting to licensing authorities.

49. In the reply comments, Terrestar aligned with CSA, Myriota and Telesat, recommending that ISED develop and publish a list of high-quality SSA providers. Terrestar also agreed that operators should be required to share ephemeris data with SSA providers upon request to enhance collision avoidance.

50. In response to Astroscale's opposition to mandatory registration, Telesat reaffirmed its support for making SSA participation mandatory, highlighting that free, high-quality services such as Space-Track.org already meet the necessary standards. Telesat reiterated that licensees should certify that they will evaluate and mitigate any identified collision risks.

Discussion

51. There was strong consensus among respondents on the importance of implementing an SSA requirement for NGSO licensees to promote safe and sustainable satellite operations. However, respondents underscored the need for flexibility in how such a requirement is implemented, recognizing the wide range of operator capacities, mission types, and financial resources across the Canadian and international space sectors. ISED acknowledges this diversity and maintains its view that all NGSO licensees should be required to register with, use, and maintain an SSA service throughout the operational life of their satellites. This requirement is essential to ensuring that operators have access to reliable conjunction data and can take timely actions to prevent potential collisions.

52. ISED does not intend to designate a single SSA provider, create or publish a list of recognized SSA providers or offer a centralized government-operated system. Instead, licensees will be free to choose from a range of qualified services that meet minimum technical and operational criteria, including: (1) the ability to deliver conjunction alerts to operators subscribed to the service; (2) support for the ingestion and use of operator-supplied ephemerides; and (3) the ability for operators to provide their contact information. This approach will allow operators to select services that best align with their operational and financial circumstances.

53. ISED takes note of DND's view that national security missions may warrant special consideration and will address any such exemptions on a case-by-case basis.

54. Finally, ISED supports the broader objective raised by several respondents of improving transparency and coordination among satellite operators. ISED agrees that merely receiving SSA data or sharing ephemeris data with an SSA provider upon request is not sufficient to ensure safety. Accordingly, ISED will impose a condition of licence requiring operators to regularly update their ephemeris data and maintain current contact information with their SSA provider, as well as to monitor, assess and respond to conjunction alerts during the operational life of the satellite. This condition of licence will also require them to cooperate with other operators when potential conjunctions are identified and identify a 24/7 contact point.

Decisions

5.1.4 Possibility of collisions with large and small objects

55. ISED sought comments on its proposal to require NGSO licence applicants to provide a quantitative assessment of the probability of collision with both large and small objects during the satellite's orbital lifetime. Consistent with definitions adopted by the National Aeronautics and Space Administration (NASA) and the Federal Communications Commission (FCC), ISED proposed thresholds of less than 0.001 (1/1000 or 0.1%) for collisions with large objects (greater than 10 cm) and less than 0.01 (1/100 or 1%) for small debris (under 10 cm). Applicants would also be required to submit supporting information outlining how these assessments were derived.

Summary of Comments

56. Overall, the majority supported ISED's intent to introduce quantitative collision risk thresholds, provided that the Department clarify acceptable tools, methodologies, and data sources. A smaller group preferred a flexible, tiered, or risk-based approach to better accommodate smaller and academic operators.

57. Amazon Leo, CSA, Erik Halliwell and signatories, MDA, Myriota, OSI, Professor Ian Mann, SpaceX, Spire, Telesat and UVic expressed clear support for ISED's proposal, with Spire and SpaceX noting that these thresholds are consistent with international norms and appropriate for ensuring orbital safety. OSI recommended that these thresholds also be assessed at the constellation level to capture the cumulative risk from large constellations.

58. Amazon Leo, CSA, Myriota, Telesat and Terrestar supported the use of established international tools such as NASA's DAS or ESA's DRAMA as they are recognized internationally. Amazon Leo, CSA and Myriota also advocated for flexibility to use alternative tools of equivalent or higher fidelity if demonstrated to be reliable. Telesat specifically recommended that assessments be conducted per satellite, over the satellite's lifetime or 100 years (whichever is shorter), using NASA's DAS or a comparable high-fidelity tool.

59. CSA advised ISED to issue clear guidelines for conducting assessments, including whether collision avoidance manoeuvres should be factored into the probability calculations, and suggested encouraging third-party validation. Similarly, AlbertaSat and UVic requested clear instructions and examples for performing analyses, noting that smaller organizations often lack access to commercial tools or expertise.

60. Some respondents (DND, Erik Halliwell and signatories, MDA and Sateliot) requested that ISED re-consider the proposed thresholds for small objects. DND, Sateliot and MDA emphasized the need to better define small objects (less than 10 cm), with Sateliot emphasizing that so doing would allow for meaningful debris modelling. Erik Halliwell and signatories and Sateliot advocated for a tiered or proportional framework based on mission characteristics, suggesting that smaller, short-lived satellites could instead demonstrate natural deorbiting or passive risk mitigation.

61. While strongly supportive of the requirement to undertake collision assessments, Purpose Partners challenged the need for a specific threshold, suggesting instead that ISED use submitted data on collision probabilities to determine whether a deeper analysis is warranted and if the system should be licensed.

62. Finally, Astroscale proposed a phased or risk-based approach, where operators provide general manoeuvrability capabilities initially and more detailed assessments closer to launch. DND proposed assessing spacecraft survivability over mission lifetime rather than based only on raw collision probability values.

63. In the reply comments, respondents generally reaffirmed support for ISED's proposal while elaborating on implementation details and methodological refinements.

64. GHGSat supported the proposal, aligning it with the Zero Debris Charter, but requested clearer guidance on how to handle untracked small debris and on what actions operators should take if their calculated probabilities exceed the thresholds. They recommended standardized tools and consistent definitions.

65. CSA reiterated its support and proposed that ISED introduce requirements for spacecraft survivability analysis to address untraceable small debris. CSA suggested assessments be performed at both satellite and constellation levels, and recommended that ISED consult with stakeholders to standardize the assessment methods.

66. Telesat supported MDA's proposal to limit large-object analyses to non-manoeuverable periods and to clarify the definition of small debris. However, Telesat opposed constellation-wide or tiered probability thresholds, arguing that these would disadvantage Canadian operators relative to international competitors. It also disputed OSI's assertions about the high risk from large constellations, emphasizing that active collision avoidance effectively mitigates such risks.

Discussion

67. Most respondents supported requiring applicants to assess the probability of collision with large objects (>10 cm). However, as noted above, some expressed concern about the feasibility of meeting a rigid threshold, particularly the proposed 0.001 probability over the satellite's lifetime. ISED maintains that a clear, quantitative threshold for large object collision probability provides regulatory certainty and ensures consistent safety standards across all missions. The 0.001 limit is recognized by NASA and FCC as a reasonable risk ceiling for collisions with large objects.

68. Feedback on the requirement for applicants to assess the probability of collision with small objects (collision probability <0.01) was varied. While many stakeholders accepted the need to address risks from untracked objects, others voiced concern about assessing probabilities against objects that cannot be individually tracked. ISED acknowledges the limitations of modelling interactions with small debris but also emphasizes that the risks posed by such objects are non-negligible, particularly due to their high velocity and the potential for mission degradation. The proposed 0.01 threshold serves as a planning guide, helping applicants demonstrate that their spacecraft design, shielding, or operational profile mitigates this risk to an acceptable level. While certainty is not possible, standardized modelling approaches allow for meaningful comparison and responsible risk management. As with the collision threshold for large objects, this threshold is aligned with the FCC's and NASA's requirements.

69. Regarding system-wide versus per-satellite assessment, some stakeholders recommended conducting assessments at the constellation or system level to reduce workload and reflect shared risk. However, others stressed that satellite-level assessments are more transparent and reflect operational realities. ISED will require assessments to be submitted on a per-satellite basis rather than per-system basis. This approach ensures that every unit meets core safety standards, avoids averaging risks across a constellation, and enables clear accountability. Per-satellite evaluation also supports more precise regulatory oversight and is consistent with how operators typically plan and model spacecraft behavior. It is also in line with the approaches of NASA and the FCC.

70. Several respondents encouraged ISED to recommend or require the use of standardized tools for assessing collision probabilities, with suggestions including NASA's DAS, which is widely used and validated. ISED agrees and will accept analysis resulting from internationally recognized tools such NASA's DAS or other comparable high-fidelity tool to perform collision risk assessments.

Decisions

5.1.5 Manoeuvrability

71. ISED sought comments on its proposal to require all NGSO applicants, at the time of application as part of the space debris mitigation plan, to provide information on the number of expected collision avoidance manoeuvres, as well as how applicants will assess conjunctions and execute the required avoidance measures over the course of the satellite(s)' operational lifetime and de-orbit phases.

Summary of comments

72. Support for the proposal was varied, with some seeking clarification on the tools to be used and the threshold for assessment and others questioning its usefulness and the impacts for small operators.

73. CSA, MDA, Myriota and Spire supported the proposal. Spire emphasized the importance of following recognized international recommendations and relying on standards and associated software validated by regulators, policymakers and the industry. Myriota requested that ISED allow the use of NASA's DAS or an equivalent standardized tool to ensure consistency and avoid discrepancies between jurisdictions.

74. CSA endorsed manoeuvrability as essential for reducing debris risk and recommended that ISED define criteria for identifying conjunction events, and specify applicability to non-propulsive spacecraft. CSA also suggested third-party validation of mitigation plans and ensuring that propulsion or tracking systems support full operational and de-orbit phases. CSA recommended that ISED require satellites without propulsion or limited manoeuvrability to be designed for accurate tracking to enable effective avoidance by other operators.

75. Amazon Leo, Astroscale, Geocentrix, GHGSat, MDA, Telesat and Terrestar supported the requirement for NGSO applicants to describe how they will assess conjunctions and conduct collision avoidance manoeuvres. All but MDA objected to the requirement to estimate the number of expected manoeuvres at the time of licence application. These respondents explained that predicting the frequency of manoeuvres is speculative and outside an operator's control. They noted that such estimates would lack reliability, be impractical and provide little regulatory value, defeating the purpose of the requirement. Astroscale urged ISED to consider a flexible approach, which could involve requiring a general statement of manoeuvrability capabilities in the satellite design at the application stage, with detailed plans submitted as the mission design matures, thereby aligning with international best practices.

76. DND and GHGSat requested that ISED issue clear guidance on the minimum operational and performance standards or enforceable baseline to be demonstrated in licence applications. Similarly, Geocentrix asked ISED to publish clear details on the assessment process, including whether outcomes would be evaluated for information or compliance purposes. Telesat was opposed to the establishment of a threshold for assessing whether an expected number of collision events and associated avoidance manoeuvres demonstrates acceptable mitigation of collision risks, stating that the same number of manoeuvres have different implications for different satellite systems.

77. Telesat and Terrestar recommended requiring operators to commit to executing effective avoidance manoeuvres when conjunction warnings are received, consistent with international best practices.

78. AlbertaSat, UVic and Sateliot expressed concerns about the feasibility of this proposal for small or academic missions. AlbertaSat indicated that small teams lack the capacity for detailed conjunction simulations. UVic noted that many CubeSats and PocketCubes do not have propulsion and as a result cannot perform avoidance manoeuvres. The University instead proposed a tiered approach, applying the requirement only to spacecraft above certain mass or orbital thresholds and also raised questions about operational coordination, decision-making authority, and liability during avoidance events.

79. Sateliot agreed that operators should have a collision-avoidance strategy but recommended that ISED recognize alternative risk mitigation strategies and avoid imposing propulsion-based obligations on systems with inherently low debris risk.

80. OSI and Purpose Partners supported the proposal but recommended expanding its scope. OSI proposed that constellation-wide manoeuvres be reported, including raising and de-orbiting actions, and that expected and actual manoeuvres be compared in periodic reports. Purpose Partners supported requiring information on expected manoeuvres and processes but urged ISED to consider additional preventive measures such as system redundancy to avoid loss of control.

81. SpaceX supported the full intent of ISED's proposal, stating that applicants should describe how they plan and execute risk reduction manoeuvres, report their performance during operations, and provide data on thresholds used, unmitigated conjunctions, and coordination with other operators. In its reply comments, Terrestar reaffirmed its opposition to requiring applicants to estimate the number of expected manoeuvres and endorsed Telesat's position that operators should instead commit to performing effective avoidance manoeuvres upon receiving conjunction warnings from SSA providers.

Discussion

82. There was support among stakeholders regarding the requirement for NGSO licence applicants to describe how they assess potential conjunctions and carry out avoidance manoeuvres over the course of a satellite's operational and de-orbit phases. Respondents broadly agreed that manoeuvrability plays a critical role in reducing the risk of accidental collisions and limiting the growth of orbital debris. ISED agrees with this view and will maintain the requirement that applicants provide detailed information on their conjunction assessment and avoidance processes, including operational procedures, thresholds for action, coordination mechanisms, and system capabilities.

83. At the same time, many stakeholders expressed concern about the proposal to require applicants to provide an estimated number of expected collision avoidance manoeuvres at the time of licence application, noting that such estimates would be inherently uncertain and of limited practical value given the dynamic nature of the space environment. ISED agrees with this assessment and will not require applicants to provide a numerical estimate of expected manoeuvres as part of their licence application.

84. Instead, ISED will focus on ensuring that operators demonstrate in their space debris mitigation plan that they have a clear, technically sound strategy for managing conjunctions and executing avoidance when necessary. This includes outlining how they will manage the conjunction data they receive from their SSA provider: how it is analyzed, what thresholds or criteria trigger avoidance action, and how such actions are coordinated with other operators. ISED also strongly encourages the use of validated tools, such as NASA's DAS, to support conjunction analysis and consistency across submissions.

85. For satellites without propulsion or with limited manoeuvrability, applicants will be expected to explain their alternative risk mitigation measures, such as enhanced trackability, passive de-orbiting strategies, or design features that reduce collision likelihood. These measures must be clearly justified and proportionate to the mission's characteristics and its orbital environment.

86. Although ISED did not consult on trackability, it was suggested that ISED require satellites without propulsion or limited manoeuvrability to be designed for accurate tracking to enable effective avoidance by other operators. ISED notes that the FCC 's rules deem spacecraft that are 10cm by 10 cm by 10 cm (including those space stations that are 10 cm or larger in their smallest dimension, excluding deployable components) trackable in LEO.

87. Given the increase in orbital congestion in LEO and potential for collision risks, ISED is of the view that requiring trackability of small satellites would enhance the collision avoidance efforts of operators and contribute to space sustainability. ISED will therefore require satellites operating in LEO to be 10 cm or larger in their smallest dimension, exclusive of deployable components, so that they may be tracked.

Decision

6.2 Post-mission disposal

88. As underscored in the Consultation, post-mission disposal is an essential element of mitigating the increase in space debris. Spacecraft that are unable to complete post-mission disposal in a timely fashion will contribute to increased congestion in the space environment over the long-term.

5.2.1. Post-mission disposal in LEO

89. ISED proposed that NGSO licensees in LEO be required to dispose of their satellite(s) as soon as practicable, and no later than five years following the end of the satellite's operational life. ISED had also defined the end of operational life of an NGSO satellite as the date of completion of its primary function, such as handling client traffic, or providing telecommunication services.

Summary of comments

90. Five-year disposal requirement: Astroscale, DND, Geocentrix and UVic were opposed to five-year disposal requirement, given the costs to academic/scientific missions and start-ups, and proposed a tiered approach to disposal, along with a regulatory flexibility. Geocentrix proposed that ISED advocate for these proposals to be adopted globally, but ensure their implementation not be detrimental to Canadian operators.

91. CSA and Quaternion also supported a tiered approach to disposal, with more stringent requirements for large constellations. CSA supported a risk-based disposal requirement based on the size of constellations, while Quaternion proposed that large constellations (e.g. 100+ satellites) be subject to a shorter disposal period (e.g. two years following the end of operational life).

92. Telesat strongly objected to Quaternion's proposal to allow for longer disposal periods for low-cost research missions, arguing that all missions should comply with minimum de-orbit standards to mitigate the risk of orbital debris. Telesat emphasised the manoeuvrability that large constellations have, as opposed to individual satellites with no manoeuvrability capabilities, resulting in longer de-orbit times and an increased risk of orbital debris and collision.

93. End of operational life: Telesat supported ISED's proposed definition of "end of operational life" on the grounds that it is consistent with FCC requirements. However, MDA argued that ISED's definition diverged from the FCC's definition and urged ISED to align with it. GHGSat requested further clarification as to the meaning of the term "end of operational life" and indicated its support for the definition of end of operational life as being reached when command and control of the satellite is indefinitely lost, as found in the World Economic Forum's (WEF) "Space Industry Debris Mitigation Recommendations".

94. CSA urged ISED to consider the fact that many satellites are operated beyond their designed operational life and mission extension of operational satellites is one means to avoid increasing the number of objects in orbit. In its reply comments, CSA suggested that ISED provide a clearer definition of "end of operational life", and also suggested that ISED employ "mission objectives" instead of "primary function", since many satellites possess secondary instruments to support the mission objectives beyond the primary function and the operation of the main payload.

Discussion

95. Five-year timeframe: There was strong support for reducing the disposal timeline for NGSO satellites in LEO to five years. Stakeholders emphasized that timely post-mission disposal is essential to limiting long-term orbital debris and noted the importance of harmonizing with the requirements of other satellite licensing administrations such as the FCC and the guidelines of organizations such as the WEF. ISED agrees with this assessment.

96. While some respondents proposed a tiered or more flexible approach for academic, scientific or small missions, other small operators acknowledged that disposal within five years is achievable. ISED notes that space agencies and regulatory authorities broadly consider a five-year disposal timeframe feasible, including for small satellites. For example, NASA states that natural decay in less than 5 years can be achieved for most smallsats at altitudes <400 km while the FCC's streamlined licensing approach requires de-orbiting within five years. Similarly, ESA's Zero Debris guidelines state that a satellite or rocket body in LEO should not remain in orbit longer than five years.

97. ISED agrees with respondents who urged alignment with international guidelines and regulations of key satellite licensing administrations and will adopt a five-year timeframe as proposed. A consistent five-year standard for all satellite missions in LEO will ensure regulatory certainty and avoid creating divergence with international norms.

98. End of operational life: Respondents' comments focused on the proposed definition of "end of operational life" and the need to align its definition more closely with that adopted by other organizations and regulators.

99. ISED agrees that a clear and practical definition is necessary to avoid uncertainty and to also allow for some flexibility in extending a satellite's licence when necessary. ISED acknowledges that its definition may not address the observation made by CSA that many satellites are operated beyond their designed lifetime and that mission extensions can help reduce the number of new objects placed in orbit. As well, narrowly defining "operational life" in terms of a primary objective may not capture the nature of a satellite's mission objectives, which could include secondary functions. ISED is therefore revising its proposed definition of "end of operational life" as the point at which a satellite has completed its mission(s), depleted its fuel, or has suffered an unrecoverable anomaly or catastrophic failure. The five-year disposal period would begin at the end of the satellite's operational life.

100. ISED takes note of the comments regarding manoeuvrability and grand-fathering satellites already in orbit and will address these comments in subsequent sections of this Decision.

Decision

6.2.2 Reliability metric for successful post-mission disposal of LEO satellites

101. ISED sought comments on its proposal to establish a reliability metric for the post-mission disposal of LEO satellites, with a target of at least 90% for an individual spacecraft and 99% for each spacecraft within a constellation, defined as two or more satellites on the same mission. ISED is of the view that together, these measures would significantly mitigate the increase in long-term debris generation.

Summary comments

102. Comments varied on post-mission disposal probabilities, with some respondents either supporting or opposing both metrics and some supporting one but not the other.

103. Amazon Leo, OSI, Purpose Partners, Quaternion, Telesat and Terrestar supported a post-mission disposal method of 90% or greater for any individual space station. Quaternion stated that the metric is reasonable for an individual space station, while Terrestar called the measure responsible and achievable.

104. Erik Halliwell and signatories and Purpose Partners were supportive of both thresholds, with Purpose Partners proposing that some flexibility should be shown to operators that either may not have the capacity to perform detailed technical analyses and/or where achieving these high probabilities is technically or economically infeasible, especially for experimental, small-scale or academic missions.

105. There was considerable opposition from Amazon Leo, Astroscale, CSA, GHGSAT, MDA, Myriota, Telesat and Terrestar to the proposed post-mission disposal of 99% for each spacecraft in a constellation. Astroscale underscored that 99% should be an aspirational, not rigid threshold, proposing instead that ISED consider ESA's current standards (ESSB-ST-U-007), which set a 95% probability requirement for large constellations of 100 or more satellites, and 90% probability for individual spacecraft and constellations (10 or more satellites). The CSA highlighted the potential challenges for applicants in meeting a requirement for a 99% threshold versus the benefits of setting a slightly lower requirement (e.g., 95%, as is the case for the European Space Agency) and identifying 99% as a goal.

106. Amazon Leo, GHGSAT, MDA, Myriota, Telesat and Terrestar recommended aligning with international frameworks and the FCC's wording on the 99% requirement for post-mission disposal so as not to put Canadian operators at a competitive disadvantage with respect to their United States (U.S.) counterparts. Quaternion underscored that a 99% requirement for a mission with two or more satellites is unreasonable and overly burdensome to small constellation operators.

107. OSI emphasized the need to have a strict criterion for satellites within large constellations, stating a 99% post-mission disposal success rate per satellite will be insufficient.

108. Geocentrix was opposed to both metrics, underscoring that a unilateral imposition could disadvantage Canadian operators. Myriota and Sateliot were also opposed to both metrics, which they deemed overly rigid and unrealistic for small operators deploying satellites with limited propulsion capabilities, with Sateliot urging ISED to allow alternative metrics for determining compliance.

109. CSA, Myriota and Sateliot suggested that ISED adopt a tiered approach: Myriota proposed that the 99% only apply to constellations of 100 or more satellites; Sateliot proposed that constellations with fewer than 50 satellites be subject to a more achievable threshold, such as 95%; and CSA urged ISED to consider "scaling reliability thresholds" based on the number of satellites in a constellation (e.g., the more satellites in a constellation, the higher the reliability threshold).

110. CSA also suggested ISED consider higher reliability thresholds and probability of collision assessments for the disposal of satellites in higher LEO orbits, given the need to transit through dense lower orbits for de-orbit and re-entry. CSA and AlbertaSat sought clarification on the methodology to be used to simulate, analyze, and calculate the success of post-mission disposal methods, with AlbertaSat requesting specific guidance for missions that use other means of disposal such as graveyard orbits and active deorbit systems. UVic requested that ISED provide guidance and example analysis for applicants.

111. Spire was of the view that spacecraft operators in LEO should strive for post-mission disposal of 90-99% for each satellite that is part of a constellation. UVic stated that the proposed requirement is reasonable, but unnecessary for missions that dispose of their satellites via natural atmospheric re-entry.

112. In its reply comments, Telesat underscored its opposition to a tiered approach based on the size of the satellite or the constellation, stating that a 90% probability of successful disposal threshold should be satisfied by all new NGSO licence applicants. Terrestar noted the broad support for the 90% post-mission disposal threshold and took issue with Myriota's and Sateliot's arguments that it is unduly onerous for individual LEO satellites. Terrestar underlined that ISED's proposal constitutes an appropriate and measured response to the challenge of managing the ever-growing number of satellites in LEO.

113. Telesat took issue with the CSA's suggestion that ISED consider setting higher disposal reliability and lower probability of collision thresholds for satellites in higher LEO orbits, underscoring that post-mission disposal reliability thresholds must be consistently applied and based on a scientifically-supported and agreed-upon definition of risk for a satellite, rather than arbitrary pre-determined altitudes.

114. Terrestar highlighted the broad opposition to the 99% threshold, underlining that a rigid threshold could prevent the viability and deployment of satellite constellations given current technological limitations and in the absence of internationally recognized evidence of the necessity of the threshold. As such, Terrestar proposed that ISED wait for technological advances before making the disposal requirement stricter.

115. Definition of constellation: Of those who responded to ISED's proposed definition of a constellation, all except Telesat were opposed.

116. GHGSAT urged ISED not to narrowly define "constellation", as doing so would put Canadian satellite manufacturers and operators at a competitive disadvantage with their international counterparts. MDA expressed the view that defining a constellation as two or more satellites would impose steep changes in reliability requirements for a single satellite. Myriota noted that the proposed definition does not align with common industry usage, where a constellation typically refers to a coordinated network of satellites designed to work together for a shared purpose. As such, applying stringent post-mission disposal requirements to any two satellites launched together could impose an undue regulatory burden on missions that are not traditionally considered constellations.

117. Purpose Partners recommended that ISED's definition emphasize that satellites often work together as a cohesive system. Sateliot recommended that ISED clarify whether its definition applies to satellites operating in a coordinated manner within the same orbital regime rather than any two NGSO satellites in the same mission, as the latter could lead to an overly broad interpretation.

118. CSA urged ISED to clarify how the definition of constellation applies to licence applications for individual replenishment satellites to be inserted into a constellation.

Discussion

119. With respect to the 90% post-mission disposal metric, ISED notes that there was almost unanimous support as this metric is seen as achievable and aligned with international frameworks including the FCC's requirement, thereby ensuring that Canadian operators are not disadvantaged compared to their international counterparts.

120. Given the broad support, ISED will adopt the 90% threshold as a mandatory requirement for the post-mission disposal of individual satellites.

121. Regarding the 99% reliability threshold for satellites within a constellation, ISED acknowledges concerns raised by some stakeholders that it could be overly burdensome for operators, particularly of small or experimental constellations; that it may not be technically feasible given current technical capabilities; and that it is not harmonised internationally. The FCC's metric allows for a goal of 99% or greater for large constellations while the IADC's space debris mitigation guidelines state that the probability of successful post-mission disposal should be at least 90% with a goal of 99% or better. France's approach allows for a tiered metric based on the number of satellites in a constellation, with a post-mission disposal metric greater than or equal to 95% for a constellation of more than 50 satellites. ESA's current standards set the probability of successful disposal of each spacecraft of a large constellation as being above 95% through to the end of life.

122. While a 99% threshold is desirable in terms of contributing to space sustainability, it could place Canadian operators at a disadvantage due to current technological limitations and the lack of international harmonization. Therefore, ISED will encourage operators to strive for this higher reliability, while imposing only a minimum post mission threshold of 90% for a single satellite, regardless of whether it is part of a constellation. ISED may revisit the requirement as technologies evolve, as suggested by some respondents.

Decision

5.2.3 Alternative criteria for the effective disposal of LEO satellites

123. ISED sought comments on alternative criteria that could be considered for the effective disposal of satellites in LEO (e.g. more emphasis on probability of success over timelines).

Summary of comments and reply comments:

124. Alternative post-mission disposal criteria proposed by respondents can be grouped according to the themes listed below.

125. Performance-based, risk-oriented approach: Amazon Leo, Astroscale, CSA, Myriota and Sateliot urged ISED to adopt a framework that is performance-based, risk-oriented and/or technology-neutral, with Astroscale, Myriota and Sateliot recommending that ISED prioritize the probability of successful disposal over adherence to fixed timeframes, with Astroscale noting that this would encourage innovation and enhance space sustainability. CSA suggested that a performance and risk-based approach take into account orbit decay rates and/or the drag coefficient of the satellite, as well as survivability for demonstrating safe and predictable re-entry. Sateliot proposed that ISED require operators to demonstrate high probability of re-entry (e.g., 90%) within a specified period, taking into account altitude, drag effects, and natural de-orbit characteristics, thereby allowing satellites in lower LEO, which naturally decay faster, to be evaluated based on their orbital lifetime.

126. Alignment with international standards/approaches: Myriota and Spire encouraged ISED to align with international standards and best practices to ensure consistency, while Telesat cautioned against the adoption of criteria for the successful disposal of satellites that are not based on peer-reviewed and sound scientific analysis. Telesat stated that any alternative criteria, including the necessity for the requirement, should be validated by expert groups that study these matters, such as the IADC or the International Organization for Standardization (ISO), prior to adoption by ISED. Spire encouraged reliance on existing, already proven tools, such as NASA's DAS software.

127. Other disposal strategies: Some companies proposed that ISED's regulatory framework include consideration of a broad range of post-mission disposal solutions to enhance efforts towards greater space sustainability. Astroscale focused on different types of rendezvous and proximity operations missions such as in-orbit servicing, end-of-life services, and active debris removal. Purpose Partners focused on debris removal technologies (e.g. robotic arms, harpoon systems), mechanisms to increase drag on defunct satellites (e.g. drag sails), and the use of material and other forms of degradation (chemical or thermal) to aid in the timely disposal of satellites. CSA encouraged ISED to take into account satellite materials, mass, area and volume, while MDA highlighted design features that may enable future de-orbiting services (e.g. a fixture on the satellite that may be used by a future de-orbit technology).

128. IAU, however, cautioned that certain de-orbiting technologies such as drag sails or electrodynamic tethers could interfere with efforts to preserve Dark and Quiet Skies if they are not designed with light and radiofrequency pollution mitigations.

129. Myriota recommended flexibility in assessing compliance based on the specific post-mission disposal method used, since aerodynamic drag augmentation, controlled re-entry, or disposal to a graveyard orbit have varying levels of success depending on altitude and operational conditions. DND urged consideration of services that de-orbit and conduct collision avoidance manoeuvres for the satellite and proposed to prioritize success and timelines over actively controlling the satellite during deorbiting, which would allow for drag sails and therefore significantly reduce the costs associated with deorbiting.

130. Tiered approach or exemptions: DND, OSI and Sateliot urged ISED to introduce a tiered approach to post-mission disposal. DND and OSI stated that deorbiting periods and probability of success requirements should be based on the size of the constellation. Both recommended higher success rates for larger constellations, with OSI emphasizing that a 99% post-mission disposal success rate per satellite will be insufficient for large constellations.

131. Sateliot stated that small satellites with low mass and collision risk, that are designed for passive re-entry and have minimal debris-generating potential, should qualify for simplified compliance measures. Conversely, larger, high-mass satellites that pose greater long-term risks should be subject to more stringent disposal verification.

132. CSA asked ISED to provide exemptions to science satellites below the altitude of crewed spacecraft as they often do not have propulsion.

Additional considerations

133. DND suggested that the timing of key de-orbit operations be relative to the 11-year solar cycle. For instance, a satellite that begins its deorbit process near the peak of the solar cycle is much more likely to be successful than a satellite that begins deorbiting during solar minimum. DND also referenced the U.S. Government's Orbital Debris Mitigation Standard Practices guideline of using "object-years" as a means to limit the number of objects, and their cumulative residence time in orbit, thereby limiting the footprint that Canadian objects have on orbit.

134. Telesat was strongly opposed to both these approaches, underscoring that initiating deorbiting during a solar flux peak may not always result in the shortest disposal time, recommending that if ISED were to consider the effects of the solar cycle in the assessment of the post-mission disposal time period, it do so for the time-integrated solar flux throughout the entire deorbit period. Telesat also strongly opposed the use of "object-years" as a metric for ranking the sustainability of satellite missions. The company argued that collision risk depends on multiple factors, both related to system design and external conditions. Reducing collision risk assessment to a single factor, like altitude, is an oversimplification and would unfairly penalize missions at higher altitudes.

135. MDA recommended that ISED regularly review available services and technologies that can improve the de-orbiting of satellites and consider not only the overall reliability of de-orbiting within the desired timeframe but other possible mitigation efforts, such as the de-orbit timeframe in the case of a failure and the nature of the failure (for example, a satellite that remains in a controlled attitude but is unable to perform de-orbiting manoeuvres versus a tumbling satellite).

136. Impacts to astronomy: IAU, OSI and Radio Astronomers underscored that mitigating space debris through prompt post-mission disposal of satellites at end-of-life and the safe disposal of rocket bodies through controlled re-entry are important steps to addressing Dark and Quiet Skies as orbital debris hinders astronomy research. They urged ISED to include consideration of the impacts of light pollution created by satellites on Dark and Quiet Skies in the environmental assessment. Both OSI and IAU emphasised that de-orbiting mechanisms, such as drag sails, could interfere with Dark and Quiet Skies if not designed with light and radiofrequency mitigations. Professional Astronomers and IAU urged ISED to consider including in its conditions of licence, estimates of light and radiofrequency pollution on the orbital environment.

137. Finally, IAU and Professional Astronomers recommended that licensing requirements address the environmental impacts of de-orbiting satellites on the atmosphere via a requirement to report information about the yearly tonnage of elements such as aluminum, lithium, magnesium, hafnium, and titanium expected to be deposited in the atmosphere due to ablation.

Discussion

138. Regarding performance-based approaches that prioritise mission disposal probabilities over timelines, ISED's position is that one should not privilege the other as they work together to enhance space sustainability efforts. ISED notes that the requirement to have both a high probability of success and as short a timeframe as possible to de-orbit is an approach common to international organizations that set guidelines or standards, and to other space regulators. While the timelines and post-mission disposal success rates may differ internationally, they are both considered essential in reducing the risks to space sustainability. Satellites may be designed for high post-mission disposal success, but if left to de-orbit over extended periods, the risks to space sustainability in LEO increase.

139. ISED takes note of the proposals to incorporate in-orbit servicing, disposal strategies, active debris-removal technologies, and end-of-life services into its licensing framework. ISED agrees with Astroscale's assessment that integrating such solutions into its framework could strengthen long-term sustainability. However, ISED also agrees with respondents who recommended alignment with international standards and best practices so as not to disadvantage the Canadian space industry. ISED is not aware of such requirements being mandated/required by other space regulators at the moment, but many new technologies are currently being developed and tested such as ESA's Clean Space initiative, which is focused on the development and testing of technologies aimed at the mitigation of space debris generation and active removal of debris. The IADC Statement on Active Debris Removal highlights that such technologies are still being investigated and emphasizes that "prioritizing and properly balancing mitigation and remediation will be key to manage the long-term orbital debris problem in a cost-effective manner."

140. ISED also declines to incorporate criteria such as "object years" and de-orbiting relative to the 11-year solar cycle, since it is not aware of such criteria being incorporated into the regulatory frameworks of other licensing administrations.

141. ISED recognizes the global nature of the space industry and will strive to harmonize any future updates to its licensing requirements and conditions of licence with international best practices. In this sense, ISED agrees with MDA's suggestion that it regularly review available services and technologies that can improve the de-orbiting of satellites, as well as follow developments internationally to ensure that Canadian-licensed satellites can benefit from harmonized regulatory regimes, to the extent possible.

Decision

5.2.4 Post-mission disposal in MEO/HEO

142. ISED did not propose to changes to the existing NGSO de-orbit requirements for MEO and HEO satellites but sought feedback on appropriate post-mission disposal approaches and required probabilities of success for satellites operating in MEO and HEO, as well as challenges posed by those approaches.

Summary of comments

143. CSA, ECCC, MDA and OSI supported considering specific post-mission disposal for MEO and HEO, with CSA, ECCC, and MDA noting that directed de-orbit may not be feasible for all missions in these orbits due to economic or technical factors. Given that HEOs may include a wide range of orbital characteristics, they argued that other methods should be considered such as passivation of the satellite or disposal in a graveyard orbit, which could minimize the risk that decommissioned satellites in HEO pose to satellites in lower orbits. ECCC encouraged ISED to consider these methods on a case-by-case basis, based on orbital characteristics of the satellites. OSI commented that for HEO, using certain orbital resonances could lead to fast and predictable re-entries. Such deorbiting strategies should be allowed if a disposal plan with adequate justification is provided.

144. Telesat noted the importance of ensuring that requirements for satellite disposal in MEO and HEO be grounded in sound peer-reviewed scientific analysis that have been validated by relevant groups, such as the IADC or ISO. It also noted that the IADC is conducting studies to quantify the risks and benefits of four disposal strategies for satellites in MEO. CSA also emphasized that graveyard orbits and starting points in MEO and HEO are currently poorly defined and that the IADC will continue to work on this issue to develop recommendations and best practices, and suggested that ISED's requirements be aligned with the IADC recommendations.

145. Purpose Partners' view was that the reduction of orbital lifetime post mission completion should be the objective for satellites in MEO and HEO. Approaches such as using materials with faster degradation levels and spacecraft passivation could be considered.

146. DND commented that in addition to HEO and MEO, consideration should be given to the deployment of small secondary payloads in geosynchronous orbit (GSO), noting that small satellites in that orbit are difficult to track and increase the risk of collision.

Discussion

147. In 2017, ISED established a 25-year post-mission disposal requirement for all NGSO satellites. ISED recognizes, however, that developing post-mission de-orbit requirements that can be applied uniformly to all satellites operating in MEO and HEO is challenging due to the wide variability of their orbital characteristics. While de-orbit strategies may be feasible for some missions in HEO with low perigees, such approaches may not be practical or technically achievable for all missions given the diverse orbital characteristics of each mission.

148. ISED agrees that requirements applicable to MEO and HEO should be aligned with recommendations and guidelines from relevant expert groups to the extent possible. As ISED noted in the Consultation, guidelines for satellite disposal in MEO are still being studied by relevant expert groups such as the IADC. In addition, as there are a limited number of Canadian filings in MEO/HEO, ISED takes the view that there is no urgency to change its de-orbit requirements for MEO/HEO at this moment, as they could become misaligned with international guidelines.

Decision

6.3 Protecting the ISS and other crewed missions

6.3.1 Requirement to provide information on possible constraints to crewed missions

149. ISED sought comments on its proposed requirement that applicants provide detailed information on their operations' possible constraints posed to the International Space Station (ISS) and other crewed missions, and plans to minimize such constraints.

Summary of comments

150. Amazon Leo, Astroscale, GHGSat, MDA, Outer Space Institute, Quaternion, SpaceX and Telesat supported measures to protect crewed missions, such as the ISS.

151. Astroscale, CSA, CSSMA, GHGSat, MDA and Terrestar recommended that an outcome-based and technology-neutral approach be adopted to ensure the protection of crewed missions, instead of mandating specific technology such as propulsion.

152. GHGSat noted that crewed missions like the ISS have stringent safety protocols and typically prefer to execute any necessary manoeuvres when a threat is identified instead of relying on other entities. As such, requirements for frequent and timely ephemeris data-sharing could better protect crewed missions by improving collision predictions and response times for manoeuvres of these space stations, as compared to propulsion requirements. GHGSAT also emphasized that the IADC guidelines do not require satellites orbiting above the ISS to have propulsion.

153. DND highlighted that the range of ISS altitudes makes it difficult to plan an orbit profile, while CSA and OSI noted that requirements should protect all current and planned crewed missions.

154. Amazon Leo, OSI and SpaceX proposed that satellites be capable of actively performing collision avoidance manoeuvres until they are situated below orbital inhabited stations. Sateliot supported manoeuvrability requirements for spacecraft operating between 375 km and 450 km, which could be achieved through passive capabilities. Astroscale noted that manoeuvrability for spacecraft at altitudes around 400 km is critical for the safety of human spaceflight.

155. Sateliot expressed the need for the Department to provide clear and standardized guidelines on the level of detail to be provided should a requirement be adopted, adding that any requirement should be proportionate to the actual risk posed by a given mission.

156. Operators of small satellites such as AlbertaSat opposed the adoption of specific requirements, which they argued could cause an unreasonable burden on operators and be a strain on their resources. Professor Ian R. Mann noted that the reliability of de-orbit and propulsion systems may be so low for some satellites operating in LEO that requiring such systems may actually increase the risk of collision. UVic argued that any propulsion requirement should be supported by evidence and balance concerns like propulsion-related fragmentation and increased mass. Spire expressed the view that differential drag can be used at lower altitudes to perform collision avoidance manoeuvres and that data sharing agreements can enable space traffic management coordination with users of the LEO to ensure protection of crewed stations.

Discussion

157. ISED recognizes that the ISS is expected to be decommissioned in the near future, and that other crewed stations exist and are being planned. Using the specific altitude of the ISS to ensure the protection of crewed missions in general would therefore not be appropriate.

158. ISED also agrees that the protection of crewed stations can be greatly improved by the frequent sharing of ephemeris data. As indicated by GHGSat, crewed missions like the ISS may perform avoidance manoeuvres when a threat is identified based on their own risk criteria and may prefer not to rely on other entities to do so.

159. As stated in section 5.1.4, ISED is requiring that licensees register with, and use, an SSA service and provide regular updates of their ephemeris data to the SSA service provider. This requirement will facilitate the dissemination of up-to-date ephemeris data to other operators, including those responsible for crewed stations.

160. ISED believes that the capability to perform avoidance manoeuvres is necessary to ensure the protection of crewed missions and of LEO in general. While it is recognized that crewed missions will likely perform avoidance manoeuvres, it is also important to reduce the risk of collision in order to minimize the potential for debris where crewed missions typically operate. ISED is of the view that enabling satellites with no manoeuvring capability to be deployed in orbits at or above crewed missions would not be consistent with Canada's commitment to responsible space operations.

161. In the Consultation, ISED did not propose manoeuvrability requirements and instead focused on a proposal for active propulsion. However, ISED agrees with comments recommending technology-neutral approaches to ensure the protection of crewed missions. Therefore, ISED will require applicants of satellites to be deployed at altitudes above those of crewed missions to demonstrate the capability to perform collision avoidance manoeuvres. ISED does not mandate any specific technology such as active propulsion, but will enable the use of other mechanisms, including differential drag, if applicants can demonstrate that they will be sufficient for performing avoidance manoeuvres.

Decision

5.3.2 Requirement for active and redundant propulsion

162. To ensure that satellites have the capability to perform any necessary collision avoidance manoeuvres, ISED proposed to mandate active propulsion, with redundancy, for spacecraft operating at an altitude above 400 km. ISED also sought comments on whether 400 km and above is the appropriate altitude at which to require satellites to have propulsion, or whether it should be lower to provide a sufficient separation distance from the ISS.

Summary of comments

163. There was general disagreement on the proposal to mandate propulsion with redundancy.

164. CSSMA, GHGSat, Erik Halliwell and signatories, Kepler, Planet Labs and Sateliot expressed concern that such a requirement could make participation in the Canadian space industry nonviable by imposing significant cost and mass constraints on small satellite operators, potentially limiting innovation and accessibility for emerging space actors and putting Canadian operators at a disadvantage.

165. It was also noted that the requirement for redundancy may not reduce the probability of collision or fragmentation events. Erik Halliwell and signatories indicated that a redundant propulsion system would be inoperable in case of major malfunctions, providing no additional benefit with regards to collision avoidance. CSA noted that mandatory propulsion may exceed any potential benefit, noting that propulsion-related fragmentation events account for approximately 25% of fragmentation incidents.

166. Comments generally favoured a requirement that does not impose any specific propulsion technology. DND and Planet Labs argued that passive propulsion can allow for avoidance manoeuvres for some spacecraft and therefore should not be excluded. Amazon Leo, CSA, CSSMA, Astroscale, Planet Labs, Telesat and TerreStar suggested that ISED consider a performance-based approach focused on collision avoidance outcomes, where operators demonstrate that their manoeuvrability method is effective. Such a requirement would allow satellite operators to select the most appropriate technologies based on their specific mission requirements.

167. Some commenters supported a propulsion requirement without redundancy. Amazon Leo supported a requirement for active propulsion for satellites at altitudes above 400 km, while Purpose Partnership favoured 375 km. DND recommended that a propulsion requirement be set at 550 km, since the lifetime of debris under this altitude is generally short lived, while Myriota argued that natural drag at altitudes below 650 km enables passive de-orbiting within a reasonable timeframe. MDA argued that any propulsion requirement should apply to satellites orbiting at or above 400 km, as it generally corresponds to the altitude of the ISS and the Tiangong space station.

168. Professor Ian R. Mann noted that if a propulsion requirement were to be adopted, a grandfathering period longer than 2 years would be necessary to consider satellites that have been designed but not yet launched. Planet Labs proposed that a grandfathering period of at least five years be adopted.

169. Quaternion and UVic noted that the FCC's streamlined small space station rules require that satellites be deployed at an altitude of 600 km or below, or maintain a propulsion system and have the ability to make collision avoidance and deorbit manoeuvres using propulsion.

170. OSI supported a requirement for chemical or electrical propulsion only, with requirements to conduct collision avoidance manoeuvres under specific circumstances, such as when a collision probability threshold is reached.

Discussion

171. Many respondents expressed a preference for a performance-based approach focused on collision avoidance outcomes, requiring operators to demonstrate the effectiveness of their de-orbiting and space debris mitigation strategies. This approach would provide flexibility for operators to choose the technologies most suited to their specific missions and would continue with the common practice of implementing technology neutral regulations, which enable operators to find innovative solutions to achieve the desired outcomes.

172. ISED acknowledges the proposals of some respondents to mandate propulsion above a certain altitude and recognizes that both the French Space Operations Act (FSOA) and the FCC's small satellite streamlined approach prohibit satellites not equipped with propulsion systems above 600 km. ISED also notes that many respondents were opposed to mandated propulsion on the grounds of costs and risks of fragmentation events, for example. They urged ISED to consider passive propulsion as a method of collision avoidance and performance-based analyses.

173. While passive measures like natural drag may be used for natural deorbiting and manoeuvring for lower altitudes, ISED believes that propulsion is required to ensure sufficient collision-avoidance capability at higher altitudes. Different altitudes ranging from 400 km to 650 km were proposed by respondents in order to establish an active propulsion requirement. ISED also recognizes that imposing more restrictive propulsion requirements than other regulatory bodies may put Canadian operators at a disadvantage.

174. Therefore, ISED will require NGSO satellites with an apogee of 600 km or more to have active propulsion, which is the same altitude specified in the FCC's small satellite streamlined approach and the FSOA. This requirement will ensure that satellites can perform adequate avoidance manoeuvres at altitudes where satellites or debris would not deorbit naturally in a reasonable amount of time, while still providing access to space at lower altitudes for satellites without propulsion.

175. ISED acknowledges that requiring redundant propulsion could place Canadian satellite operators at a disadvantage due to cost and design challenges and would not be fully aligned with other regulatory frameworks. Furthermore, as noted in stakeholder comments, a redundant propulsion system would not provide any benefits with regard to collision avoidance in cases of major malfunctions that render satellites inoperable.

176. As highlighted by GHGSat, Quaternion and UVic, the FCC requires propulsion only for authorization through the streamlined process for small space stations. Erik Halliwell and other signatories recommended establishing a similar streamlined review process, providing a dedicated review track for student-led satellites to reduce the regulatory burden for both the applicants and ISED.

177. ISED notes that establishing a specific authorization process for small satellites was not in the scope of the Consultation. However, this may be an area of consultation in the future.

Decision

5.4. Foreign-licensed NGSO satellites

178. ISED sought comments on its proposal to require NGSO applicants seeking foreign satellite approvals (FSA's) to attest that a space debris mitigation plan is in place for the constellation and indicate whether that plan was required by the applicant's licensing administration.

179. ISED also sought comments on its proposal to require foreign applicants to submit their space debris mitigation plan for information, at ISED's discretion.

Summary of comments

180. Attestation requirement: Commenters generally supported ISED's proposed attestation approach for FSA applicants, including Amazon Leo, Astroscale, CSSMA, Fleet Space, GHGSat, Globalstar, MDA, Planet Labs, Purpose Partners, Quaternion, Sateliot, SpaceX, Spire and Telesat. Amazon Leo, Astroscale, CSSMA, Fleet Space, Myriota and Sateliot noted that the proposed approach would avoid duplicative regulatory requirements for applicants that have already complied with their home jurisdiction's requirements.

181. The CSA, Geocentrix, OSI and Terrestar were of the view that an attestation is not sufficient. These commenters recommended that ISED impose either the same or equivalent space debris mitigation requirements on FSA applicants as it does on domestic NGSO operators. Geocentrix and Terrestar emphasized that this would ensure a level playing field between both types of applicants and prevent foreign applicants from gaining an unfair advantage in accessing the Canadian market in the event that a foreign applicant's home licensing administration is more lenient in its application of space debris mitigation requirements. The OSI noted that such an approach would also prevent regulatory forum shopping by satellite operators.

182. Retaining discretion to request FSA applicants' debris plans: Respondents including Amazon Leo, Astroscale, CSA, Fleet Space, Globalstar, Quaternion, Spire and Telesat generally supported ISED's proposal to require FSA applicants to submit their space debris mitigation plans for information on a discretionary basis. Conversely, Geocentrix, GHGSat, Sateliot and Terrestar opposed this proposal. Geocentrix, GHGSat, and Terrestar recommended that ISED ensure its requirements for foreign applicants are comparable to those imposed on domestic applicants. Sateliot cautioned that a discretionary approach may create regulatory uncertainty.

183. Rather than adopt a discretionary approach, Astroscale, Globalstar, MDA, Sateliot and SpaceX suggested that ISED clarify parameters under which foreign applicants would be asked to submit their debris plans. Astroscale, Sateliot, SpaceX and Terrestar suggested that ISED consider exempting FSA applicants that are licensed by jurisdictions deemed as pre-cleared from having to submit their debris plans. Astroscale suggested this could be achieved through mutual recognition mechanisms, whereas Terrestar advised that such an exemption could be established for FSA operators licensed by countries represented at the IADC.

184. Astroscale, Myriota, GlobalStar, Purpose Partners and Spire suggested that ISED require foreign applicants to submit their debris plans for ISED's review when the size of their satellite system exceeds a predetermined threshold. Astroscale added further risk factors that ISED may wish to consider, suggesting that NGSO FSA applicants could include, in their debris plans, information on orbit congestion and systems that are deemed to pose enhanced risks to space sustainability.

Discussion

185. Given the broad support from stakeholders for the proposed approach with respect to an attestation, ISED will proceed as proposed. ISED maintains the view that an attestation approach, combined with the option to request that debris mitigation plans be submitted for information, will best balance considerations with respect to avoiding duplicating requirements for foreign-licensed operators while providing ISED with the flexibility to request further information as required.

186. With respect to ISED's proposal on reserving the right to request FSA applicants to submit their space debris plan for information, ISED acknowledges that multiple respondents proposed the establishment of pre-cleared jurisdictions or mutual recognition mechanisms that would recognize foreign administrations' licensing requirements as being sufficient to not require any further information from FSA applicants. ISED finds this to be an interesting approach meriting further analysis and discussion with other licensing administrations. ISED will explore this idea and may consider it for future updates to the FSA process.

187. In deciding when to request a FSA applicant's debris mitigation plan, ISED will take into account various factors including whether a foreign operator's licensing administration requires a space debris mitigation plan as part of their licensing application process and whether the foreign administration makes their requirements publicly available.

Decision

5.5 Implementation

188. In the Consultation, ISED sought comments on its proposal to make the updated spectrum licence application requirements for new space station licences effective as of the date of the publication of this Decision.

189. ISED also sought comments on its proposal to apply updated conditions of licence to all existing and new NGSO space station spectrum licences as of the date the decision is published, and to limit the application of the condition of licence to satellites launched two years after the publication of the decision, noting that existing licences include those issued up to 126 days after the decision is published.

Summary of comments

190. Support for ISED's proposal regarding the implementation of new licence application requirements upon publication of the Decision was mixed.

Requirements for new licence applications

191. Amazon Leo, MDA, OSI, and Telesat supported the proposal to apply the new licensing requirements and conditions of licence for space stations effective the date of publication of the Decision, with Amazon Leo and OSI underlining that this approach would ensure that space sustainability practices are observed promptly by satellite operators. While supportive of the proposals, Telesat added in its reply comments that a period of flexibility for new applications may also be helpful to reflect the lengthy design process that generally occurs before filing.

192. AlbertaSat, CSA, DND, Geocentrix, GHGSat, Quaternion and Spire expressed concern with the proposal arguing that the proposed new requirements (including 90% or 99% success rate, manoeuvring during de-orbit and redundant propulsion) could require substantial satellite re-design and engineering changes, incurring costs and delays. They recommended transition periods ranging from two to ten years following the publication of the Decision to accommodate existing mission planning and avoid unreasonable costs and delays.

193. AlbertaSat also suggested a two-year waiting period for new requirements as many NGSO spacecraft, especially academic missions, have advanced designs but have not yet applied for their ISED license, in part due to the additional reviews from amateur radio organizations whose spectrum is commonly required for academic missions. In addition, Quaternion recommended that updated requirements only apply to satellites launched two years after the Decision date, regardless of whether the licence is new or existing.

194. The CSA suggested that ISED consider waiving the new requirements on a case-by-case basis, such as for applicants with satellites currently in manufacturing. In its reply comments, CSA also recommended that ISED provide a longer timeline for implementation, given the long lead times to design and build satellites and that ISED further consult with regulated parties, including the CSA, to determine a practical implementation schedule that considers mission phases and timelines for new licence applications.

195. Purpose Partners and Sateliot recommended that ISED be flexible with projects that are currently under construction to ensure that they can proceed without significant delays or additional costs. Sateliot agreed with ISED's proposed grace period of 126 days to allow ongoing applications to adapt without jeopardizing planned satellite deployments.

Updated condition of licences for existing licences

196. There was notable opposition to the updated conditions of licence for existing licensees coming into effect on the publication date of the Decision.

197. Amazon Leo, Sateliot, and OSI generally supported ISED's proposed approach, noting it reasonably balances prompt regulatory action with sufficient adjustment periods for licensees subject to new requirements. Sateliot sought clarification on whether minor modifications to existing constellations, such as replenishment satellites or upgrades to existing deployments, would trigger full compliance with the new licence conditions.

198. AlbertaSat, CSA, DND, Geocentrix, GHGSat, MDA, Purpose Partners, Quaternion, Spire, Sateliot, Telesat and Terrestar expressed their opposition to applying the new conditions of licence to existing NGSO licences, with several arguing that the proposed timelines could require operators to revise satellite designs at a late stage – an undertaking that may be technically infeasible without incurring significant costs. DND highlighted that if the entire mission needed be re-designed and re-manufactured in order to meet the new requirements, costs could double. GHGSat and Telesat noted that design changes to meet new deorbiting requirements may be technologically infeasible to implement. Telesat added that even if the new system were able to comply with the new requirements, it could no longer be economically feasible.

199. MDA emphasized that hardware is often procured years before launch, and design-to-launch timelines frequently exceed five years. Consequently, missing the proposed two-year grandfathering window could result in a significant impact if a redesign of the satellite had to occur. MDA added that in the case of constellations with multiple launches, this impact would be exacerbated and that spare satellites should also be considered under the same regulations as the satellites from the original constellation.

200. GHGSat noted that the combined requirements to deorbit within five years with a 90% or 99% post-mission disposal success rate and redundant propulsion would require significant transition periods for implementation since these requirements may not align with mission plans that have already been established. Similarly, Quaternion, Spire and Terrestar stated that the proposed implementation timelines would be insufficient for meeting the proposed propulsion and manoeuvrability requirements.

201. AlbertaSat, DND, GHGSat, Quaternion and Terrestar suggested a wide range of transition periods. MDA noted that launch schedules for constellations also raise the risk that existing licences could miss the proposed two-year grandfathering window. Terrestar suggested extending the period during which a newly issued licence is considered an "existing licence" by four months to provide licensees with additional time to negotiate design amendments with manufacturers, noting that this flexibility could help address concerns related to propulsion, manoeuvrability and redundancy requirements. As an alternative, Terrestar suggested that it would be reasonable for the updated conditions of licence to apply only to satellites whose provisioning contract was signed two years after the Decision is published.

202. Telesat added that while it does not support applying new de-orbiting requirements that would necessitate design changes to existing satellite systems, the company believes that requiring existing licensees to register with an SSA service and receive conjunction alerts could reasonably take effect shortly after the date of publication of the Decision.

203. Finally, GHGSat, MDA and Telesat also noted their opposition to the updated conditions of licence being applied to any existing licences or amendments.

Discussion

204. ISED acknowledges that the proposal for application of updated conditions of licence received significant opposition. However, in light of ISED's decision to not require redundant propulsion and to adopt a goal of 99% probability of success for post-mission disposal of individual satellites in a constellation, which many stakeholders had identified as particular challenges, ISED considers that the overall impact on satellite design planning will be significantly reduced and therefore mitigates the need for a longer transition period.

205. ISED notes that many Canadian licensed operators also pursue market access in the U.S., where similar space debris mitigation requirements and the same transition approach are already in place. As such, these operators are likely to be well-positioned to meet the revised application requirements without the need for substantial redesign.

206. ISED therefore maintains the view that its proposed implementation of the updated requirements and conditions of licences aligns with international best practices and will ensure the prompt application of debris assessments and mitigation measures. ISED will consider, on a case-by-case basis, waving the new requirements for licensees who are seeking an amendment to their existing licences if the changes they are seeking would not affect the debris risk profile of their satellite systems - e.g. modifications to the frequencies authorised by the licence.

207. ISED also acknowledges the concerns raised with respect to the new requirements coming into effect upon the publication of the Decision. Respondents underscored that these could require substantial satellite design and engineering changes for projects already underway but for which a licence application has not yet been submitted. Consequently, ISED may consider requests to waive the new requirements on a case-by-case basis.

Decisions

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

209. 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, Space Services and International

235 Queen Street
Ottawa ON K1A 0H5

Email: satelliteplanning-planificationsatellite@ised-isde.gc.ca

Updated conditions for Canadian space stations are as set out below. Existing conditions for Canadian space stations from N2 – Space Station Licences that have not been modified for space debris mitigation will apply and are not repeated here.

1. Existing conditions from N2 with the following modifications will apply:

Space debris mitigation

For GSO satellites, the licensee shall remove the satellite from the geostationary satellite orbit region in a manner consistent with Recommendation ITU-R S.1003-2, Environmental protection of the geostationary satellite orbit, at the end of its life. The licensee must notify ISED of the removal and provide the information requested in section 8.3 of CPC-2-6-02.

For NGSO satellites, the licensee must implement space debris mitigation measures according to the post-mission disposal plan submitted with their spectrum licence application. NGSO satellites in Low Earth Orbit (LEO) must undergo controlled re-entry as soon as practicable and no later than five years following the end of operational life with a success rate of at least 90% for an individual satellite, regardless of whether it is part of a constellation.

Licensees of NGSO satellites in MEO and HEO must implement space debris mitigation measures following the guidelines established by the Inter-Agency Space Debris Coordination Committee. The licensee must also include the requirement for the satellite(s) to de-orbit within 25 years of end of operational life.

For all NGSO satellites, the licensee must notify ISED of the removal and provide the information requested in section 8.3 CPC-2-6-02.

2. New conditions that will apply:

Space Situational Awareness

The licensee is required to register with, use, and maintain a space situational awareness (SSA) service throughout the operational life of their satellites. The chosen SSA service must meet minimum functional requirements to support effective collision risk mitigation. These include:

• the ability to deliver timely and reliable conjunction alerts
• support for the ingestion and use of operator-supplied ephemerides and
• the ability for operators to provide their contact information

All NGSO licensees are required to regularly update their ephemeris data and maintain current contact information with their SSA provider, as well as monitor, assess and respond to conjunction alerts. Licensees are also required to cooperate with other operators when potential conjunctions are identified and identify a 24/7 contact point.