Consultation on the Revisions to the 2500-2690 MHz Band Plan

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

3. Wireless services are an important part of Canadians' daily lives. Now more than ever, Canadians expect these services to be high quality, widely available across all regions of the country, and competitively priced. A strong wireless telecommunications industry also drives the adoption and use of digital technologies, facilitates innovation, and enhances the productivity of the Canadian economy.

4. Spectrum is a critical resource for the telecommunications industry and a key enabler of a variety of services, including new technological developments, such as next-generation networks. The fifth generation of wireless technology, known as 5G, is changing the telecommunications landscape and facilitates the delivery of innovative services to Canadian consumers and businesses. ISED continues to foster investment and the evolution of wireless networks by enabling the development of high-quality 5G networks and technology. As such, maximizing the use and efficiency of currently available spectrum will support the continued development and deployment of 5G technologies, and prepare Canada for the sixth generation (6G) of wireless technology anticipated in a few years.

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

6. In 2010, through DGSO-001-10, Decisions on the Transition to Broadband Radio Service (BRS) in the Band 2500-2690 MHz and Consultation on Changes Related to the Band Plan, ISED initiated a public consultation to determine whether to adopt the U.S. Educational Broadband Service (EBS)/BRS band plan (henceforth referred to as the "U.S. band plan") or the International Telecommunications Union (ITU) band plan based on the Frequency Arrangement C1 in the Report ITU-R M.1036 (henceforth referred to as the "ITU band plan") for the 2500 MHz band. The U.S. band plan allows for only unpaired or Time Division Duplexing (TDD) operations, while the ITU band plan allows for both paired Frequency Division Duplexing (FDD) and unpaired TDD operations.

7. At the time, although stakeholders recognized that harmonization with the U.S. band would simplify cross-border frequency coordination and present a technology-flexible option, the majority of received comments supported adopting the ITU band plan. Therefore, in February 2011, through SMSE-005-11, Decisions on a Band Plan for Broadband Radio Service (BRS) and Consultation on a Policy and Technical Framework to License Spectrum in the Band 2500-2690 MHz, ISED adopted the ITU band plan, noting that it would:

• allow the deployment of both FDD and TDD systems;
• permit global harmonization, thus enabling economies of scale for equipment and international roaming; and
• enable access to a wider range of services and applications which were expected to be developed on a global basis.

8. Figure 1 illustrates the current band plan for BRS in the 2500 MHz band. Blocks in the 2500-2570 MHz frequency range are paired with blocks in the 2620-2690 MHz frequency range, while blocks in the 2570-2620 MHz frequency range are unpaired. TDD operations are permitted in the paired blocks but must be engineered to coexist with paired systems. The operation of these systems is also subject to the operation and displacement policy
SMSE 005-11. Within the unpaired spectrum, 2570-2575 MHz and 2615-2620 MHz are considered restricted bands. Licensees of unpaired blocks are permitted to operate within the restricted bands on a no-interference, no-protection basis with respect to FDD operations in the paired 2500-2570 MHz and 2620-2690 MHz blocks.

Figure 1: Current 2500 MHz band plan

9. In March 2012, through SMSE-002-12, Policy and Technical Framework: Mobile Broadband Services (MBS) – 700 MHz Band, Broadband Radio Service (BRS) – 2500 MHz Band, ISED specified the licensing structure for the 2500 MHz band, with paired spectrum licensed as blocks of 10+10 MHz and unpaired spectrum as blocks of 25 MHz, including the 5 MHz restricted bands. ISED also decided to auction the licences using Tier 3 service areas, except in Northwest Territories, Yukon and Nunavut, where Tier 4 service areas were used.

10. In SLPB-001-14, Licensing Framework for Broadband Radio Service (BRS) – 2500 MHz Band, ISED established the auction framework for the 2500 MHz band. The auction was held in 2015, where ISED awarded 304 licences on a 20-year term, expiring in 2035. In SLPB-009-17, Licensing Framework for Residual Spectrum Licences in the 700 MHz, 2500 MHz, 2300 MHz and PCS-G Bands, and in SPB-004-22, Notice of 2023 Auction of Residual Spectrum Licences, ISED outlined the frameworks for residual auctions held in 2018 and 2023, where an additional 66 licences were awarded with terms expiring in 2038. In addition, 204 licences held by incumbents prior to the 2015 auction remain in force, also expiring in 2035. Annex A provides a detailed table of existing licences in the 2500 MHz band, including their associated licensing area and frequency blocks.

11. In recent years, Canadian and U.S. licensees have deployed 5G systems along the border; however, differences in band plans have made cross-border coordination increasingly difficult. Canadian licensees have reported growing interference issues — most notably in the FDD uplink spectrum (2500-2570 MHz), where interference has created challenges in meeting deployment obligations. To manage this interference in the short-term and to maximize the useability of the spectrum along the border, Canadian operators have submitted a joint request to ISED to make modifications to the Canadian spectrum holdings as described further in SAB-01-26.

12. To address these interference issues in the long-term, Canadian licensees have requested that ISED consider transitioning to an unpaired band plan, which would improve cross-border coordination and maximize the usability of the spectrum. In the Spectrum Outlook 2023 to 2027 (the Spectrum Outlook), ISED also noted that it would consider proposals from licensees to convert the band to unpaired for TDD-use.

13. The equipment ecosystem for TDD has expanded significantly in recent years, particularly in the U.S. where operators have deployed large-scale 5G networks using this band. ISED considers that transitioning to an unpaired band plan would allow Canadian operators to benefit from access to a cost-effective, standardized solution with an extensive equipment ecosystem and the advantages of the economies of scale it provides.

14. In general, ISED is of the view that adopting an unpaired band plan would offer several key benefits:

• support long-term and sustainable use of the band for 5G and future networks;
• facilitate cross-border coordination with the U.S.;
• allow Canadian licensees to benefit from the large TDD equipment ecosystem.

15. ISED is proposing to revise the band plan of 2500-2690 MHz to unpaired TDD-use, as illustrated in Figure 2. ISED intends to include a more detailed band plan, establishing block sizes, as part of a future consultation.

Figure 2: Proposed band plan

16. In Decisions on a Band Plan for Broadband Radio Service (BRS) and Consultation on a Policy and Technical Framework to License Spectrum in the Band 2500-2690 MHz, ISED established conditions that would allow non-FDD operations to operate in paired blocks in the 2500 MHz band. As part of the future consultation to transition to an unpaired TDD-use band, ISED will consult on potentially revising these conditions to reflect changes to the band plan.

17. ISED will be seeking proposals from 2500 MHz licensees on a detailed plan to transition to the proposed unpaired band plan. Recognizing that the plan will be complex due to existing deployments in the band, ISED is seeking comments on when to start the transition and whether there is a need to revise existing deployment requirements. In addition, ISED is seeking preliminary comments on how a transition plan could be implemented.

6.1 Timing for the transition to the proposed new band plan

18. Preliminary discussions with 2500 MHz licensees suggest that the transition timeline will need to accommodate operators' differing capital investment cycles, as many have already procured and deployed equipment to meet the deployment requirements for the band. Since existing FDD infrastructure is generally not compatible with TDD equipment, additional time may be necessary for planning, procuring, and deploying new TDD-capable radios. Given these considerations, operators have indicated that they may be ready to start the transition to an unpaired band plan in some areas or markets around 2028, with an estimated four to six years required to complete the process through a phased approach to ensure continuity of services to Canadians.

6.2 Existing 2500 MHz deployment requirements

19. In SLPB-001-14, Licensing Framework for Broadband Radio Service (BRS) – 2500 MHz Band, ISED required licensees to demonstrate that they are putting spectrum in the 2500 MHz band to use within 10 years of the initial issuance of the licence, as specified in Table 6. ISED may consider adjusting these requirements as some licensees are not able to fully use their spectrum due to cross-border interference. Furthermore, given the potential transition to an unpaired TDD-use band plan, adjusting the deployment requirements may also provide operators with additional flexibility to align capital investments with future infrastructure and equipment upgrades. At the same time, ISED recognizes that several operators have already deployed in the band to meet existing deployment requirements. As such, ISED will not verify compliance with deployment requirements until the decision on the transition plan is published.

6.3 Transition plan implementation

20. At this stage, ISED is seeking preliminary input to inform the development of a future consultation on a transition plan towards unpaired TDD-use in the 2500 MHz band. ISED is of the view that current licensees are best positioned to develop the details of a transition plan that considers existing investments, minimizes service disruption, and delivers long-term benefits for Canadians and expects that industry collaboration will be essential to ensuring that issues are resolved efficiently during the transition.

21. Certain regions in Canada are more heavily impacted by cross-border interference and recognizing that a full transition to an unpaired TDD-use band plan will need to take place over multiple years, a phased or market-by-market approach may be more effective than a simultaneous nationwide transition. Such an approach would enable operators to prioritize regions where interference is most significant, while allowing additional time to adjust business plans in other markets, manage existing deployments, and plan for new investments. In addition, the Canadian FDD uplink spectrum (2500-2570 MHz) is more directly affected by cross-border interference than the downlink spectrum (2620-2690 MHz). As such, it may be appropriate to prioritize the transition of specific portions of the band. In this context, ISED is seeking input on whether certain geographic areas or frequency ranges should be transitioned first, and on how transition timelines could be structured to minimize disruption for licensees and users.

22. In moving to an unpaired TDD-use band plan, ISED recognizes that contiguous spectrum holdings may provide greater efficiency and flexibility in deploying TDD systems. In this context, ISED is seeking comments on whether licensees prefer to hold contiguous blocks, and, if so, what frameworks or mechanisms would be most effective in enabling fair and orderly exchanges of frequency assignments.

23. ISED is also seeking input on the appropriate geographic licensing level for the transition. Allowing operators to transition at smaller tier levels may provide more flexibility and additional time to transition to the revised band plan. However, this may also introduce additional complexity in managing the transition and ensuring deployment requirements are met. As such, ISED is seeking comments on the appropriate tier level for the transition and how deployment obligations need to be adjusted to reflect this approach.

24. ISED recognizes that temporary or longer-term technical measures may need to be implemented during the transition period to minimize harmful interference conflicts between licensees. However, pending the transition plan to be adopted, ISED expects that the resolution of these conflicts should be arrived at through mutual arrangements between the affected parties following consultation and coordination.

25. ISED will review the comments received and publish its decision on the issues raised in this consultation.

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

27. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (SPB‑002-26). Parties should submit their comments no later than March 31, 2026, to ensure consideration. Soon after the close of the comment period, all comments received will be posted on ISED's Spectrum management and telecommunications website.

28. ISED will also provide interested parties with the opportunity to reply to comments from other parties. Reply comments will be accepted until April 28, 2026.

29. In addition, respondents are asked to specify questions numbers for ease of referencing and to provide supporting rationale for each response. As all comments will be published, respondents are asked to not include confidential or private information in their submissions.

30. Following the initial comment period, ISED may, at its discretion, request additional information if needed to clarify significant positions or new proposals.