Consultation on a Policy, Licensing and Technical Framework for Remotely Piloted Aircraft Systems (RPAS) in the 5030-5091 MHz Band and Certain Bands Used to Provide Commercial Mobile Services

1. Through the release of this document, Innovation, Science and Economic Development Canada (ISED), on behalf of the Minister of Industry (the Minister), is hereby initiating a consultation on the spectrum policy, licensing and technical framework for Remotely Piloted Aircraft Systems (RPAS) in the 5030-5091 MHz band and in certain bands used for commercial mobile services.

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

3. Wireless services are an integral part of the Canadian economy. Businesses, public institutions and consumers rely on wireless services and technologies to enable day-to-day activities as well as to enable innovative and emerging use cases.

4. ISED's Spectrum Outlook 2023 to 2027 (2023 Outlook) noted the growing importance of spectrum as an economic driver and enabler of Industry 4.0. Radiocommunication equipment and wireless connectivity are key enablers of businesses in many sectors of the economy and increasingly support the development of new products, services and employee workplaces. Various industry sectors are increasingly relying on wireless technologies to develop such innovative goods and services. These technologies also enable companies to be more efficient, productive and innovative, leading to better and more affordable product and service offerings.

5. RPAS, also known as drones or unmanned aircraft systems (UAS), continue to grow in support of an increasing number of applications across multiple sectors, including, amongst others, logistics, precision agriculture, infrastructure and environmental monitoring and search and rescue. Although RPAS technologies have been around for several decades, commercial RPAS use began in the early 2000s, when it shifted from military exclusivity to mainstream availability. Significant advancements in stabilization, imaging, and automation have made RPAS a viable option for both recreational and professional use.

6. The 2023 Outlook further noted the growing interest by manufacturers and operators of RPAS in using different spectrum bands, including bands used for commercial mobile services. Currently, RPAS operate on a licence-exempt basis in certain bands such as the 2.4 GHz and 5 GHz bands, and are currently not permitted to operate in commercial mobile bands. In the 2023 Outlook, ISED noted that the testing of RPAS in various bands, including commercial mobile bands, may be authorized under a developmental licence, as applicable. It further noted the intention to release a future consultation on the use of RPAS in additional bands.

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

8. ISED's policy objectives for this consultation are to:

• foster investment and the evolution of wireless services by enabling the development of innovative and emerging applications
• enable the provision of wireless services and technologies that support spectrum as an economic driver and enabler of Industry 4.0

9. In proposing to make spectrum available for RPAS in Canada, ISED has also taken into account a variety of factors, such as the existing uses of the spectrum, the impact on existing users, and potential future RPAS use cases, including satellite technologies to enable RPAS operations in rural and remote areas. ISED has considered international allocations, the evolution of technologies, current and emerging technical standards, and the ecosystem for network and end-user equipment.

10. RPAS components: RPAS consist of remotely piloted aircraft (RPA), which refers to aircraft or drones, and remote pilot stations (RPS), which are stations from which the pilot controls the aircraft. RPAS rely on the use of the radio spectrum to safely operate the aircraft and to achieve various missions. The three components of RPAS that use radio spectrum are the command and non-payload communications (CNPC) link radios, radionavigation equipment and the payload.

11. The CNPC link, also known as the command-and-control (C2) link, includes telecommands that are issued by a pilot to control an aircraft and its reception of real-time information about the status of the aircraft and its environment, thereby enabling the safe operation of the aircraft. CNPC link transmissions can be provided either through terrestrial stations or space stations. In absence of spectrum policies for RPAS, commercial and recreational use has been limited to bands such as the 2.4 GHz and 5 GHz bands, where RPAS operate on a licence-exempt basis.

12. Radionavigation equipment, including Global Positioning System (GPS) receivers, radars and other aviation-grade navigation systems, may be used by RPAS to prevent collisions with objects and aircraft. This equipment typically transmits and/or receives the navigation-related information under the radionavigation or aeronautical radionavigation services.

13. Some RPAS missions may require the collection of data from sensors or cameras. This information is gathered through a payload and can be stored on board aircraft using memory cards or drives. In some cases, the transmission of this data is needed for immediate processing. In these instances, the RPAS payload requires access to spectrum to relay data collected during flights. Today, payload information can be transmitted only in bands where RPAS operate on a licence-exempt basis.

14. Regulations and international standards: In Canada, Transport Canada (TC) regulates the civil aviation industry, which includes the operation of RPAS, by developing and managing regulations related to the safe operation of aircraft. TC aims to integrate RPAS into Canada's airspace, including controlled airspace which is defined by the type of air traffic services that are required and available to airspace users. Its regulatory framework states that rules for the safe operation of RPAS are based on categorization of drone operations, pilot certification and aircraft registration. The rules that govern civil aviation are referred to as Canadian Aviation Regulations (CARs) within which TC currently defines RPA as "navigable aircraft, other than a balloon, rocket or kite, that is operated by a pilot who is not on board". TC has completed the first two phases of a regulatory strategy to support the routine operations of RPAS across the country through the 2019 creation of Part IX of the CARs and the first major expansion of these rules in 2025. This strategy will see the continued expansion of the CARs to include additional operations as both industry and TC continue to build their understanding of rapidly evolving technologies and operations.

15. Currently, commercial and recreational RPAS operations in Canada are mostly limited to small RPA operating within visual line of sight (VLoS), where unaided visual contact between the pilot and the remotely piloted aircraft must be maintained to ensure control of the aircraft. At this time, operations that are Beyond Visual Line of Sight (BVLoS) are permitted through a TC issued Special Flight Operating Certificate (SFOC). However, with increasing interest in expanding the types of services offered using RPAS, RPAS operators have expressed interest in regularized BVLoS operations. Consequently, TC recently updated its regulations to permit most lower-risk BVLoS and medium-sized RPA operations starting November 4, 2025.

16. International regulatory bodies have identified a number of candidate bands where BVLoS RPAS operations could be enabled on a licensed basis. For instance, the International Civil Aviation Organisation (ICAO), a specialized agency of the United Nations, develops internationally accepted standards and practices related to civil aviation. ICAO's Frequency Spectrum Management Panel and the Remotely Piloted Aircraft Systems Panel have developed Standards and Recommended Practices (SARPs) related to the use of the 5030-5091 MHz band by RPAS to ensure safe and reliable operations.

17. RPAS operators have also expressed interest in performing CNPC and payload operations in bands used to provide commercial mobile services, leveraging the associated networks owned and operated by mobile service providers. Many of these networks are well established, cover wide areas of the country, and offer the potential to facilitate BVLoS applications. It should be noted that for RPAS operations in these bands, aerial user equipment (UE) is typically installed on an RPA to access existing 3rd Generation Partnership Project (3GPP) compliant networks. Aerial UE refers to UE that supports RPAS features, such as the ability to transmit and receive command and non-payload communication information, and services according to relevant 3GPP specifications. In the context of the three components of RPAS that use radio spectrum as discussed above, in general, aerial UEs could be used for the CNPC link radios, and payload but not radionavigation in bands identified for commercial mobile services, given that aeronautical radionavigation or radionavigation services are not permitted in these bands.

18. As a result of the international standard development activities and growing market interest, spectrum regulators around the world are considering various mechanisms to facilitate innovative RPAS use in bands where they are not licence-exempt. Globally, the 5030-5091 MHz band, allocated to the aeronautical mobile (route) service (AM(R)S) and aeronautical mobile satellite (route) service (AMS(R)S), has been identified for the provision of CNPC services to RPA over long distances using aviation industry standardized radios. Moreover, some spectrum regulators have allowed, or are currently consulting on allowing, RPAS operations in commercial mobile bands.

19. In Canada, ISED is responsible for managing the radio spectrum, including RPAS use of radio frequencies for communications, control and navigation. Spectrum is managed through policy and licensing regimes, technical standards, and coordination mechanisms to mitigate interference between spectrum users.

20. Industry interest: Interest in RPAS deployment in Canada has been steadily growing, driven by technological advancements and the versatile applications across various sectors. For instance, in the agricultural industry, RPAS can conduct aerial surveys to monitor crop health, identify areas needing attention and optimize resource usage, ultimately leading to increased productivity and cost savings. In the field of public safety, RPAS can assist in emergency response by providing real-time information, aiding in search and rescue missions, and assessing hazardous situations from a safe distance.

21. Additionally, in infrastructure and construction, RPAS offers efficient inspection of buildings, bridges and other critical structures, ensuring timely maintenance and reducing the risk of accidents. Commercially, RPAS deliveries can revolutionize logistics by reducing delivery times and reaching remote or hard-to-access areas. Environmental monitoring and wildlife conservation can also benefit from RPAS ability to collect data in challenging terrains, track animal movements, and monitor ecological changes. Overall, the integration of RPAS into various Canadian industries promises enhanced efficiency, safety and innovation.

22. According to Transport Canada's Drone Strategy to 2025, TC estimates the RPAS industry in Canada to be worth approximately $6 billion, supporting 22,000 Canadian jobs. The commercial RPAS market is expected to grow by 17% by 2027 and Canadian companies are well-poised to capitalize on this growth by developing the RPAS applications of the future and leveraging RPAS to make their processes more efficient.

23. TC's RPAS regulatory framework was established in response to a growing interest in deployment. The implementation of the CARs Part IX in 2019 has further supported this growth, offering clearer guidelines and certification processes for both recreational and commercial drone operators. As a result, Canada has seen a rise in RPAS-related startups, investment in technology, and collaborations between government agencies and private companies to harness the full potential of UAV/RPASs. This dynamic environment highlights the significant role of RPAS in enhancing operational efficiencies, reducing risks, and offering new opportunities for Canadian industries.

24. Based on the activities above, ISED is initiating this Consultation for the use of RPAS in the 5030-5091 MHz band and certain commercial mobile bands.

5.1 International context

25. In 2009, the ITU published Report ITU-R M.2171 Characteristics of unmanned aircraft systems and spectrum requirements to support their safe operation in non-segregated airspace (the Report), which details the CNPC link requirements for Radio Line-of-Sight (RLoS) and beyond RLoS (BRLoS) operations. The Report states that allocations to AM(R)S and AMS(R)S could be used to provide CNPC service and concludes that 34 MHz of spectrum would be required for terrestrial RLoS systems, which refers to connections within the range of an aeronautical base station. It also states that 56 MHz would be required for satellite BRLoS systems, referring to connections outside the range of the aeronautical base station. The Report also notes that the spectrum requirements are estimated based on the safe, reliable and routine operation of RPAS in controlled airspace.

26. As a result of this and other reports, the 2012 World Radiocommunication Conference (WRC-12) decided to amend the ITU Radio Regulations to add primary AM(R)S and AMS(R)S allocations in the 5030-5091 MHz band for use by RPAS. This band is allocated globally, on a primary basis to the aeronautical radionavigation service (ARNS) and footnote No. 5.444 gives priority to the microwave landing system (MLS) over the use of the band by AM(R)S and AMS(R)S systems. The ITU is working to define the characteristics and protection criteria of RPAS in the 5030-5091 MHz band.

27. As part of ICAO activities, the organisation proposed a band plan to enable RPAS operations using terrestrial aeronautical base stations in the band 5040-5080 MHz when RPA are within RLoS, and using satellite stations in the bands 5030-5050 MHz and 5070-5091 MHz when operating BRLoS, as shown in Figure 1 below:

Figure 1: ICAO proposed band plan for 5030-5091 MHz

28. Following the amendments to the ITU-R Radio Regulations to include the AM(R)S and AMS(R)S allocations in the 5030-5091 MHz band in the international table of frequency allocations, and with the proposed band plan from ICAO, spectrum regulators, the aviation industry, and civil aviation authorities began working to enable the use of the band by RPAS through changes to their respective domestic spectrum policy and aviation regulations. A few spectrum regulators around the world are currently addressing regulatory questions in support of the use of RPAS in the 5030-5091 MHz band, as discussed below in paragraphs 29-32.

29. The Australian Communications and Media Authority (ACMA) consulted on whether to adopt ICAO's band plan. In response to the comments received, ACMA published Radiocommunications Assignments and Licensing Instructions (RALI) on Use of the 5030-5091 MHz band for remotely piloted aircraft system control and non-payload communications in May 2022, adopting the 5030-5091 MHz band for command and non-payload communications. Interim access to the 5055-5065 MHz band was authorized for CNPC RLoS operations, deferring any decision regarding a final band plan until international spectrum arrangements have been completed.

30. In January 2023, the United States's (U.S.) Federal Communications Commission (FCC) published a Notice of Proposed Rulemaking (NPRM), FCC 22-101, WT Docket No. 22-323, outlining service rules to support safety-critical communications (i.e., CNPC communications) for uncrewed aircraft systems in the 5030-5091 MHz band. The FCC proposed a band plan that is different from ICAO's, making 10 MHz of spectrum available for Non-Networked Access (NNA) in 5030-5035 MHz and 5086-5091 MHz for use cases where RPAS operations are within RLoS of a ground station. NNA refers to spectrum governed by services rules to support non-networked communication. The FCC also proposed to make 40 MHz of spectrum available for Network Supported Services (NSS) in 5040.5-5080.5 MHz to support operations that rely on networked infrastructure to relay information between the RPAS operator and the aircraft, thereby enabling BRLoS operations. NSS refers to spectrum or licences that are governed by service rules in support of the provision of network-based services. Finally, the FCC proposed that an additional 11 MHz would be made available to either NNA-based operators or NSS licensees in the 5035-5040.5 MHz and 5080.5-5086 MHz ranges for opportunistic or interim use.

Figure 2: FCC proposed band plan for 5030-5091 MHz

31. In August 2024, the FCC adopted a Report and Order, FCC 24-91, WT Docket No. 22-323, deferring a decision on a final band plan and temporarily making available only the 5040-5050 MHz range for NNA communications. A key component of this decision is the implementation of a Dynamic Frequency Management System (DFMS) to provide automated frequency assignments to operators, ensuring protected use of certain frequencies tailored to specific operations. While the DFMS is being developed, the FCC is making the broader 5040-5060 MHz range available through an interim access mechanism (IAM). In addition, the FCC adopted technical requirements based on the Radio Technical Commission for Aeronautics (RTCA) DO-362A standard, which includes power and emission limits, and other requirements such as channel size, frequency stability and time division duplexing requirements.

32. The FCC indicated that in the future, it will resolve issues relating to the amount and placement of NSS-only and NNA spectrum, their service rules, and measures to ensure co-existence between RPAS operations at the band edges and services in adjacent spectrum.

5.2 Canadian context

33. In 2014, ISED added AM(R)S and AMS(R)S allocations in the 5030-5091 MHz band and made changes to international footnotes No. 5.443C, 5.443D, and 5.444, based on what was adopted at WRC-12. Tables 1 and 2 provide excerpts of the current allocations and footnotes for the 5030-5091 MHz band in the CTFA (2022 Edition).

34. Given the increasing interest in Canada and around the world to expand the types of RPAS services offered, the 5030-5091 MHz band has been identified as a potential candidate for RPAS use.

5.3 Changes to the Canadian Table of Frequency Allocations

35. As mentioned, both the ITU Radio Regulations and the CTFA give priority to MLS under the ARNS allocation over the AM(R)S, AMS(R)S in the 5030-5091 MHz band through footnote No. 5.444. The MLS is a precision radio guidance system that was developed in the 1970s and 1980s to assist aircraft in landing in all weather conditions. This system was designed to replace the Instrument Landing System (ILS), but the technology was supplanted by more modern and less costly approaches that make use of global navigation satellite systems (GNSS) combined with ILS. As MLS is not used in Canada, the band remains underutilized and is currently only used to test various RPAS technologies.

36. Based on recent international activities, current underutilization of the 5030-5091 MHz band in Canada and the growing interest in its use for RPAS, ISED is proposing to introduce RPAS CNPC use in the band through amendments to the CTFA. Specifically, ISED is proposing to add a new footnote, CXX, designating the use of AM(R)S and AMS(R)S in the 5030-5091 MHz band for RPAS for CNPC applications, and to remove international footnote No. 5.444 from the CTFA, as shown below and in Table 3:

• ADD CXX The use of the 5030-5091 MHz frequency band by the AM(R)S and AMS(R)S is designated for command and non-payload communications (CNPC) for remotely piloted aircraft systems (RPAS).

• SUP 5.444 The frequency band 5030-5150 MHz is to be used for the operation of the international standard system (microwave landing system) for precision approach and landing. In the frequency band 5030-5091 MHz, the requirements of this system shall have priority over other uses of this frequency band. For the use of the frequency band 5091-5150 MHz, No. 5.444A and Resolution 114 (Rev.WRC-15) apply. (WRC-15)

37. Should ISED suppress footnote No. 5.444 from the CTFA, Appendix A of the Agreement Between Her Majesty The Queen in Right of Canada as Represented by the Minister of Industry and NAV CANADA Regarding Radio Frequency Spectrum Management (the Agreement) would require an update to reflect the new use of the band. Similarly, ISED would update frequency restrictions and allocations detailed in Regulation by Reference RBR-1 Technical Requirements for the Operation of Mobile Stations in the Aeronautical Service.

38. As per ITU Radio Regulations, AM(R)S and AMS(R)S are reserved for communications relating to safety and regularity of flight, primarily along national or international civil air routes. Accordingly, ISED is of the view that the following RPAS CNPC applications would be permitted to operate under the AM(R)S and the AMS(R)S:

• control of the RPA
• relay of air traffic control voice and data
• transmission of detect and avoid radar data
• transmission of weather radar data for RPA operations
• video used specifically for RPA operations
• other non-payload operations to monitor on-board systems

5.4 Band plan for RPAS in the 5030-5091 MHz band

39. As mentioned in section 5.1, globally, two band plans have been proposed for new RPAS operations in the 5030-5091 MHz band. ICAO has proposed a high-level band plan, which Australia proposed to adopt but ultimately deferred its adoption due to a lack of detailed international spectrum management arrangements. The U.S. also deferred adoption of its own band plan given a lack of consensus in the industry with respect to the appropriate uses and technologies for the band.

40. ISED recognizes the importance of the 5030-5091 MHz band for the operation of RPAS and the benefits that Canadian operators and consumers draw from economies of scale for equipment when spectrum use is harmonized. However, at this time, there does not appear to be coalescence around a band plan, either internationally or regionally.

5.5 Proposed authorization frameworks for RPAS in the 5030-5091 MHz band

41. Currently, the CNPC link for RPAS primarily operates in bands that support licence-exempt use, on a no-interference, no-protection basis. However, to enable the introduction of new and more complex RPAS operations, where the risk of interference must be minimized and more spectrum may be required for advance features, ISED is proposing to leverage existing authorization frameworks to authorize RPAS CNPC operations in the 5030-5091 MHz band:

• terrestrial aeronautical stations: authorization through radio licences operating under the AM(R)S, based on the licensing framework established under the Radiocommunications Regulations
• satellite space stations: authorization through spectrum licences, based on CPC 2-6-02 and CPC 2-6-04 for RPAS space stations operating under the AMS(R)S
• aircraft stations (i.e., RPA):
  • when communicating with terrestrial aeronautical stations: exempt from licensing provided that the requirements in section 15.1(2) of the Radiocommunication Regulations are met
  • when communicating with satellite space stations: authorized using a spectrum licence based on CPC-2-6-03 - Procedure for the Submission of Applications for Generic Earth Station Spectrum Licence

5.5.1 Aeronautical stations

42. To authorize terrestrial aeronautical stations of the RPAS in the 5030-5091 MHz band, ISED proposes to leverage the current radio licensing framework and issue radio licences for individual stations, on a first-come, first-served basis. Licensed apparatus must adhere to defined technical parameters.

43. Radio licensing eligibility, transferability, terms and conditions, and fees are set out in accordance with the Radiocommunication Regulations (the Regulations) and related regulatory documents. As such, the following will apply:

• eligibility to hold a radio licence is defined in section 9 of the Regulations; requirements related to operations in the service would also apply as per section 34
• as per section 33 of the Radiocommunication Regulations, operators of radiocommunication equipment in the aeronautical service are required to hold a Restricted Operator Certificate – Aeronautical (ROC-A)
• radio licences are only transferable if eligible based on Radio Systems Policy 010, RP-010 Policy Guidelines Concerning the Transfer of Radio Licences, so long as the technical parameters under which the RPAS operations were authorized remain the same
• as with all radio licensed equipment, the licence for terrestrial aeronautical stations would expire on March 31 of each year, with a high expectation of renewal
• existing fees associated with radio licences for fixed stations operating in the aeronautical service would be applied as per section 62(1)(a)(i) of the Regulations
• all fees are subject to the requirements of the Service Fees Act, including the implementation of a periodic fee adjustment and can be found on ISED's Spectrum and telecommunications fees webpage

5.5.2 Space stations

44. Although international standards have not yet been developed and adopted for the satellite component of RPAS in this band, ISED proposes to authorize RPAS space stations in Canada through either a space station spectrum licence issued to a Canadian satellite operator planning to offer services globally and/or in Canada, or a foreign satellite approval (FSA) issued to foreign-licensed satellite operators planning to offer services in Canada. Both types of authorizations are typically granted on a Canada-wide basis and within Canadian airspace and waters, where the Radiocommunication Act applies.

45. Space station spectrum licences for Canadian commercial communications satellites are typically issued with 20-year terms and FSAs typically do not have expiration dates. ISED proposes that these same licence terms would facilitate enabling and maintaining RPAS in Canada.

46. The spectrum licensing process for Canadian space stations is detailed in CPC-2-6-02 Procedure for the Submission of Applications for Spectrum Licences for Space Stations. The approval process for FSAs is detailed in CPC-2-6-04 Procedure for the Submission of Applications to Approve the Use of Foreign-Licensed Satellites in Canada.

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

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

5.5.3 Aircraft stations

49. ISED proposes to use different mechanisms for radio apparatus onboard an RPA operating in the aeronautical mobile service, based on whether it is communicating with terrestrial or space stations.

50. RPA (aircraft stations) communicating with aeronautical stations: ISED proposes that radio apparatus on board aircraft stations used to communicate with terrestrial aeronautical stations be exempt from licensing, provided that the requirements in section 15.1(2) of the Radiocommunication Regulations are met.

51. As specified in 15.1(2), the radio apparatus on board RPA must be operated in accordance with the technical requirements for aircraft stations in the aeronautical service that are specified in ISED's Regulation by Reference - 1, RBR –1 Technical Requirements for the Operation of Mobile Stations in the Aeronautical Service.

52. To enable aircraft stations to be exempt from licensing, ISED proposes to add a new item 31 in Schedule II of RBR-1 (shown in Table 4 below) to include the 5030-5091 MHz band and update section 6.4 (Power restrictions) to restrict output power to a maximum of 10 watts for item 31 of Schedule II.

53. ISED also proposes to modify Schedule III, Item 14 in RBR-1 to replace the MLS with CNPC applications for RPAS.

54. ISED proposes to further modify Schedule III, Item 20 in RBR-1 to allow 15.4-15.7 GHz to be used for detect and avoid radar. This addition would support the use of the 15 GHz band on a licence-exempt basis.

55. Aeronautical station licensees will be responsible for resolving cases of harmful interference caused by transmissions between their aeronautical stations and aircraft stations. ISED proposes that interference risks could be managed through an approach such as a Dynamic Frequency Management System, described in section 5.8, below.

56. Licence-exempt devices have no applicable fees. However, as per section 33 of the Regulations, operators of aeronautical stations must hold a Restricted Operator Certificate – Aeronautical (ROC-A).

57. RPA communicating with space stations: Prior to communication with any satellite, an earth station spectrum licence must be obtained, which are typically issued for a Canada-wide service area (i.e., Tier 1), as well as Canadian airspace and waters, where the Radiocommunication Act applies. In the context of RPAS, an "earth station" refers to any aircraft station communicating with a satellite, such as an RPA that communicates with satellites to exchange data. To differentiate between these RPA and other earth stations, ISED will refer to RPA that communicate with satellites as aircraft earth stations.

58. Under the current licensing framework, there are two types of earth station spectrum licences: site-approved and generic. As generic licensing of earth stations would be most appropriate for RPAS, ISED proposes to modify Annex A of CPC-2-6-03 - Procedure for the Submission of Applications for Generic Earth Station Spectrum Licences, to include the 5030-5091 MHz band as shown in Table 6.

59. ISED is of the view that the existing earth station fee orders are appropriate for RPAS licences at this time. ISED proposes that generic earth station spectrum licences be subject to the fees in Notice No. SMSE-002-23, Fee Order for Earth Stations, which are based on the amount of spectrum assigned in specific frequency bands. Fees are applied on an annual basis, with fees payable each year by March 31 for the upcoming year. Details on how the fees are applied can be found in the Fee Orders.

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

5.6 Transport Canada requirements

61. In addition to obtaining the relevant spectrum authorizations from ISED, RPAS operators must also utilize equipment which meets the relevant TC requirements prior to the operation of RPAS. Additional information on equipment requirements is available in the links below and any questions in this area should be directed to TC. TC.RPASINFO-INFOSATP.TC@tc.gc.ca

• CAR 901 Div XI (Regulations for OEMs and Technical Service Providers)

• 901 Div VI (Complex Ops) (Operational Requirements for Lower Risk BVLOS)

• CAR Standard 922 (Technical Requirements for Drones)

• AC 901-001 (RPAS Declaration Guidance)

• AC 922-001 (Technical Criteria for Compliance with CAR Standard 922)
• AC 901-002 (RPAS Operator Certification Guidance)

5.7 Technical requirements

62. The ITU-R is currently working on a draft recommendation on technical requirements, with the latest draft addressing RPAS operations in the 5030-5091 MHz band within RLoS and BRLoS.

63. In Australia, ACMA, in its decision on Interim access to 5055 – 5065 MHz for Line of Sight (LoS) Remotely Piloted Aircraft Systems (RPAS) Control and Non-Payload Communication (CNPC) links, published technical specifications representative of equipment in the 5030-5091 MHz band. It is noted that ACMA's decision reflects information it gathered prior to August 2022.

64. In the U.S., in FCC 24-91 - Report and Order, the FCC incorporated by reference into its technical rules specific sections of the RTCA DO-362A standard, Command and Control (C2) Data Link Minimum Operational Performance Standard (Terrestrial) technical standard, applicable to transmitter output power, emissions bandwidth, out-of-band emission limits, emission mask and time division duplexing. The RTCA DO-362A standard contains Minimum Operational Performance Standards (MOPS) for terrestrial-based (i.e., non-satellite) CNPC communication links in the 5030-5091 MHz band to support RPAS. ISED notes that the technical rules established by the FCC are applicable equally to RPAS aircraft stations as well as aeronautical stations operating in the 5030-5091 MHz band.

65. As a spectrum regulator, ISED's aim of these technical specifications is to ensure co-existence between different systems within the band and in adjacent bands. In Canada, technical requirements for radio equipment are typically set out in Radio Standards Specification (RSS) documents. These RSS documents outline the requirements used for testing and certification of radio products for the Canadian market. Alternatively, ISED could incorporate technical requirements directly into the conditions of licence (CoL) for licensed aeronautical stations used with RPAs as well as in RBR-1 for licence-exempt aircraft stations. However, ISED's preliminary view is that equipment certification for both RPAS aeronautical stations and aircraft stations is appropriate to ensure licence holders will be conducting operations with conforming equipment. Accordingly, ISED is seeking input on the best method to confirm the proper functioning of radio equipment used with RPAS in the 5030-5091 MHz band.

5.7.1 Coexistence with adjacent services

66. The introduction of RPAS operations in the 5030-5091 MHz band may pose interference risks to incumbent operations in adjacent frequency bands. As a result, consideration of incumbent operations is necessary to determine whether interference mitigation measures are required to protect these incumbent operations.

67. Radio astronomy service: The radio astronomy service (RAS) has a primary allocation in the 4990-5000 MHz band. Radio astronomy is the study of celestial objects through the radio frequencies they emit. These cosmological signals are very faint in comparison to communication signals. As a result, radio astronomy systems, which normally use sensitive receivers to pick up those faint signals, are particularly vulnerable to changes in their interference environment. Although the proposed RPAS band is not immediately adjacent to RAS, it is close enough that RAS could experience interference from RPAS.

68. Traditionally, most radio astronomy systems have relied on remote siting and the use of geographical features to reduce the likelihood of disruptions to scientific observations. In the U.S., the FCC requires RPAS operations to coordinate with RAS within the National Radio Quiet Zone (NRQZ). The FCC mandates that parties planning RPAS operations in this zone notify the NRQZ Administrator prior to a flight to ensure potential interference is assessed.

69. In Canada, the Dominion Radio Astrophysical Observatory (DRAO), located near Kaleden, British Columbia, is the most notable user of spectrum allocated for radio astronomy, and is an example of a radio astronomy system that could be at risk of interference from RPAS. It is situated within a valley, which further geographically isolates it from the nearest populated areas currently served by terrestrial deployments in bands used for other services, minimizing the probability of receiving interference. While the local geography provides protection to DRAO from operation of terrestrial services, this is less likely with RPAS operating at higher altitudes. As such, ISED is of the view that consideration of RPAS coexistence with RAS operating in the adjacent band is necessary.

70. To protect radio astronomy operations at DRAO from interference, ISED is proposing to establish an exclusion zone around the observatory, within which transmission and reception of signals for RPAS operations in the 5030-5091 MHz would be prohibited. Aeronautical stations would not be authorized in this exclusion zone, and licensees of all authorized aeronautical stations, regardless of their location, would be responsible for ensuring that all associated aircraft stations do not transmit or receive signals within the exclusion zone. This exclusion zone would be included in relevant technical standards to be developed by ISED in consultation with stakeholders, such as the Radio Advisory Board of Canada (RABC).

71. Fixed satellite service: There is a global primary allocation for the fixed-satellite service (FSS) in the 5091-5150 MHz frequency range, in the Earth-to-space direction. According to ITU Radio Regulations footnote No. 5.444A, the use of FSS in this frequency range is limited to feeder links of non-geostationary satellite systems (NGSO) in the mobile-satellite service.

72. As these earth stations operate in the Earth-to-space direction, an RPAS operating near an FSS earth station (e.g., within 15 km) transmitting in this frequency range may be susceptible to interference from the FSS earth station, depending on the technical characteristics of the RPAS. At the time of publication of this consultation, there are only two sites with FSS earth stations operating in Canada in the 5091-5150 MHz range, located in Smiths Falls, Ontario and High River, Alberta. ISED expects that the use of FSS in this band will not grow significantly in the future. Given such limited deployment of FSS in 5091-5150 MHz, ISED is of the view that coexistence measures are not required at this time. Prospective RPAS operators may consult ISED's Spectrum Management System for the current list and parameters of FSS earth stations operating in the 5030-5091 MHz band to aid in the design and deployment of their systems.

5.7.2 Cross border coexistence

73. Existing bilateral agreements between Canada and other administrations, notably the U.S., to enable terrestrial deployments near the Canadian border have been detailed in Terrestrial radiocom agreements and arrangements (TRAA). Many of these agreements are binding, and all domestic policy changes must continue to comply with existing treaty obligations as well as make good faith efforts to comply with non-binding arrangements.

74. At this time, existing cross border agreements do not explicitly address RPAS operations in the 5030-5091 MHz band. Until relevant cross border agreements are established, RPAS licensees would be responsible for mitigating any harmful interference to radiocommunication services operating in other administrations' territories. In addition, RPAS operations in the 5030-5091 MHz band will be subject to the requirements of any future cross border agreements that may be established between Canada and other administrations, including the U.S.

5.8 Interim approach for coordination of RPAS use

75. As mentioned in section 5.1, the FCC and ACMA have not yet adopted final band plans for the 5030-5091 MHz band but have both implemented interim arrangements to facilitate the near-term deployment of RPAS. Depending on the band plan and licensing mechanisms to be established for RPAS in Canada, different approaches could be used to enable coordinated use of the band for RPA, such as the database approach discussed in section 5.9, below. Recognizing that such an approach would depend on the band plan and would take time to implement, ISED is seeking comments on adopting an interim approach to coordinate RPAS use in order to facilitate the near-term deployment of RPAS in Canada.

76. ACMA's interim approach is limited to the band 5055-5065 MHz, which ICAO has designated for terrestrial CNPC in its proposed high-level band plan. This approach includes procedures for choosing and assigning frequencies to reduce the potential for interference between devices operating co-frequency in specific geographic areas. Systems are also required to adhere to technical and operating limits. The licensing procedure involves assigning forty (40) 250 kHz channels on a first-come, first-served basis in the band 5055-5065 MHz, with a geographic service area defined as being a 200 km radius from the registered aeronautical station location. Licences are issued for one-year with renewal on a case-by-case basis pending the development of global spectrum management arrangements, which could impact equipment availability and interoperability. Importantly, RPAS operators must seek the approval of aeronautical safety authorities to operate RPAS. Operators must ensure compliance with regulations to ensure the safe operation of their systems.

77. Similarly, the FCC's IAM will enable NNA entities to begin operations in the band absent final spectrum management rules. The IAM is available to all eligible NNA operators licensed by rule – that is, operators do not need an individual FCC licence, but are required to comply with all applicable operating requirements, procedures and technical specifications. Operators will be allowed limited, short-term access to 20 megahertz of spectrum in the 5040-5060 MHz range but must first coordinate with the Federal Aviation Administration (FAA) before registering with the FCC. For FAA coordination, the NNA operator must provide technical details of the requested location, frequency, and timeframe to situational awareness and strategic deconfliction, which are key to maintaining separation from other operators and from obstacles.

78. Once NNA operators receive FAA authorization/concurrence, they must register with the FCC and complete an online NNA registration. Once the registration form is completed and submitted, a confirmation number of their registration will be provided and NNA operations can commence immediately. During the IAM, the FCC will work with the FAA to resolve disputes or identify and address the sources of harmful interference or unauthorized operations in the 5030-5091 MHz band.

5.9 Dynamic frequency management system

79. As mentioned in section 5.8, depending on the band plan and licensing mechanisms to be established for RPAS in the 5030-5091 MHz band, different approaches could be used to enable coordinated use of the band by licence-exempt equipment on board an RPA. As an example, to facilitate efficient spectrum access for non-networked operations, a centralized, automated dynamic frequency management system (DFMS) could be used, as proposed in the U.S.

80. Through a DFMS, real-time coordination amongst multiple non-networked RPAS could facilitate coexistence between different RPAS operations. Under such an approach, a non-networked RPAS operator would submit a spectrum access request to the DFMS before flight. This could be done via an online interface (e.g., through a web portal or other integrated flight planning tool). The request would include key flight details such as the geographic area, time and duration of the flight, as well as the intended flight altitude and equipment characteristics. This information would be entered manually by the user or automatically via preprogrammed mission settings in compliant RPAS systems. The DFMS would then check for incumbent operations or other overlapping assignments in the specified area and time window, compute an exclusion zone, and assign appropriate CNPC frequencies for time-limited exclusive use. ISED is of the view that under such an approach, a DFMS would be administered by a private third-party and would require time to develop.

81. If DFMS is introduced in Canada, ISED recognizes the need for a standardized set of technology and certification requirements for DFMS-compatible RPAS equipment, database and designation processes. These requirements would form a key part of technical and operational framework for this band. As such, ISED is seeking initial comments on numerous proposals related to DFMS. These comments will be considered in a future technical and operational consultation if the DFMS approach is implemented in Canada.

82. Designation of DFMS administrators: ISED is seeking comments on authorizing multiple qualified third-party DFMS administrators to operate in Canada that would support different business approaches and encourage innovation, while promoting competition among service providers. To ensure harmonized and reliable frequency assignments, each DFMS administrator would be required to support interoperability and coordination with other DFMS providers operating in the same band. Coordination between administrators would help ensure consistency in responses to RPAS operators and seamless frequency management across the country.

83. DFMS agreements: DFMS administrators would be subject to formal agreements with ISED, defining their roles and responsibilities. These agreements would be modeled on precedents such as CPC-4-1-01 Application Procedures for White Space Database Administrators (WSDBAs) and CPC-4-1-02 Application Procedures for Automated Frequency Coordination System Administrators (AFCSAs), and would include necessary operational, compliance and reporting obligations.

84. Technical and operational implementation considerations: Approved DFMS administrators would be required to gather technical data necessary to facilitate co-existence with other spectrum users. For the system to function effectively, licensee data would need to remain accurate and up to date.

85. To enable safe flight operations and ensure interference protection, DFMS administrators would be required, as a minimum, to:

• accurately determine conflict-free frequencies based on submitted flight plans and the technical characteristics of RPAS equipment
• calculate exclusion zones around incumbent licensees using standardized interference protection criteria and suitable propagation models
• assign frequencies to non-networked RPAS operators on a first-come, first-served basis
• update their data on licensed incumbent users by retrieving records from ISED's Spectrum Management System (SMS) database at least daily
• maintain secure and private handling of user and licensee data in accordance with Canadian privacy laws

86. Detailed technical and operational rules reflecting these principles would be formalized through technical standards that DFMS administrators would have to meet on an ongoing basis.

6.1 Background

87. RPAS stakeholders in Canada and worldwide, have expressed interest in having dedicated spectrum to facilitate RPAS communications. Besides the 5030-5091 MHz band, stakeholders have emphasized the need for additional spectrum to not only enable CNPC links, but also telemetry and payload communications (e.g., video streaming), which are essential for advanced RPAS applications.

88. Bands used to provide commercial mobile services are of particular interest for the operation of RPAS. Commercial mobile operators are looking at expanding their markets to new services, while commercial businesses, including RPAS users, are seeking to take advantage of the existing commercial mobile infrastructure to enable a rapid and ubiquitous rollout of new RPAS capabilities. These capabilities include BVLoS applications that require secure communications, low latency and high throughput, which commercial mobile infrastructure can support. Moreover, bands used to provide commercial mobile services are generally harmonized across numerous countries. As such, the use of these bands could better support economies of scale of RPAS user equipment (UE), thereby enabling the development of RPAS applications and use cases.

89. As a part of this consultation, ISED aims to develop a framework that will enable RPAS aerial UE operations in bands used to provide commercial mobile services while minimizing interference with existing services. It should be noted that the operation of RPAS aerial base stations (tethered and untethered) is not currently being considered under this proposed framework.

6.2 International context

90. Globally, international standards development fora are looking at the operation of RPAS in bands used to provide commercial mobile services. Moreover, many administrations have recognized the growing need to enable aerial UE operations, and are at various stages in developing or have already established regulations to permit RPAS operations in the bands used to provide commercial mobile services.

91. Currently, many commercial mobile services operate in various mobile service bands identified for International Mobile Telecommunications (IMT) in the International Table of Frequency Allocations. In some of these bands, the mobile service allocation specifically excludes the aeronautical mobile service (i.e., MOBILE except aeronautical mobile), where aerial operations such as RPAS aerial UEs would not be allowed (e.g., portions of the 694-960 MHz band in some regions). Consideration of studies on the impact of removing such exceptions in some IMT bands is currently deferred until the World Radiocommunication Conference in 2027 (WRC-27), potentially leading it to become an agenda item for WRC-31. In 2022, the European Electronic Communications Committee (ECC) released the ECC Decision (22)07 in which it identified several commercial mobile bands for aerial UE communications. These bands included 703-733 MHz, 832-862 MHz, 880-915 MHz, 1710-1785 MHz, 1920-1980 MHz, 2500-2570 MHz and 2570-2620 MHz bands. The ECC Decision (22)07 recognized the potential for interference from aerial UE operations and recommended that national authorities conduct studies, as appropriate, to define and implement various mitigation measures to protect the operation of incumbent services in these bands.

92. In 2022, the United Kingdom's (UK) spectrum regulator, Ofcom, released a new UAS Operator Radio licence framework authorizing the use of specific radio equipment, including radars, beacons, radio altimeters, satellite equipment and mobile UEs in certain bands for UAS operations. In this framework, mobile UEs for UAS operations are limited to the following commercial mobile bands: 700 MHz, 800 MHz, 900 MHz, 1800 MHz, 2100 MHz, 2.3 GHz and 3.4-3.8 GHz. Ofcom requires the UAS Radio Operator licensee to comply with the existing technical parameters (e.g., EIRP limit) for terrestrial mobile UEs to the UAS operations, as set out in the relevant technical rules for the specific band. Ofcom also requires the UAS Operator Radio licensee to obtain written permission from the mobile network operator whose bands are intended for use. This permission is required due to the potential impact to the mobile network's quality of service caused by UAS operations.

93. In the U.S., the FCC's 2023 NPRM (FCC 22-101, WT Docket No. 22-323) noted the considerable interest in using existing terrestrial mobile networks for UAS communications, including CNPC, telemetry and payload communications. The FCC highlighted the potential coexistence concerns due to high altitude and density of unmanned aircraft, and sought stakeholder views on the sufficiency of existing flexible-use rules to prevent interference to and from UAS operations. The FCC's 2024 Report and Order (FCC 24-91, WT Docket No. 22-323) indicated that, given the evolving use of flexible use spectrum for UAS operations, it would continue to review developments to understand interference patterns for unmanned aircraft in different flexible use bands, unmanned aircraft altitudes and operating scenarios in order to determine if additional measures are warranted to enable coexistence between UAS and incumbent operations in flexible use bands. To date, the FCC has not released any decisions on enabling UAS operations in flexible-use bands.

94. Terrestrial commercial mobile networks use technology standardized by the 3GPP industry standard organization body. Recognizing the evolving need to support aerial-based applications, the 3GPP took steps to evaluate the impact of aerial UE operations in commercial mobile spectrum. Based on its findings, in June 2024, 3GPP developed technical requirements, including aerial UE operating bands, maximum power and out-of-band emission limits, within Long-term Evolution (LTE) and 5G New Radio (5G NR) UE technical standards for aerial UEs operations as a part of its Release 18. It should be noted that 3GPP technical requirements for aerial UEs are generally aligned with those standardized for terrestrial UEs.

95. In addition, the RTCA is working on developing performance standards for RPAS. Specifically, Special Committee (SC) 228 is responsible for developing the minimum performance standards for RPA, including communications through commercial mobile networks.

6.3 Canadian context

96. In recent years, many stakeholders have shown interest in conducting research and development for advanced RPAS applications, particularly using bands used to provide commercial mobile services in Canada. To this end, ISED has issued numerous developmental licences to support innovative trials for RPAS operations.

97. Although there is a growing interest in using existing bands that are used to provide commercial mobile services for RPAS communications, the terrestrial mobile networks were not initially designed with RPAS operations in mind. As such, current ISED policies and technical rules for terrestrial commercial mobile services do not take airborne operations into account. As indicated in the 2023 Outlook, RPAS operations are currently permitted only in certain bands (2.4 GHz and 5 GHz bands) where they operate on a licence-exempt basis, and are not allowed to operate in bands used to provide commercial mobile services in Canada for the reason mentioned above.

6.4 Spectrum policy framework for RPAS use in commercial mobile bands

98. This section focuses on the spectrum allocation and utilization policy considerations for RPAS operations in bands used for commercial mobile service.

6.4.1 General considerations for identifying specific commercial mobile bands for RPAS use

99. In identifying the specific bands that are used to provide commercial mobile services in which the proposed RPAS framework will apply, ISED proposes to use the following considerations:

100. Regional and/or international harmonization: ISED will consider regional and/or international spectrum use when enabling new RPAS use cases in bands used to provide commercial mobile services, as well as the development and availability of equipment ecosystems and standards related to the service and applications under consideration.

101. Stakeholder interest and benefits to Canadians: The introduction of RPAS in spectrum used to provide commercial mobile services is envisioned to increase the productivity and efficiency of various sectors, such as agriculture and security. To maximize these benefits to Canadians, ISED will take into account stakeholder interest when considering identification of spectrum used for commercial mobile services to enable RPAS use.

102. Potential interference concerns: Coexistence between different services is a key factor when considering new services. ISED will consider potential interference issues, both within the same band and in adjacent bands. Furthermore, in the CTFA, similar to the International Table of Allocations discussed above, certain mobile service allocations specifically exclude aeronautical mobile services (i.e., MOBILE except aeronautical mobile). As such, ISED will only consider commercial mobile bands under mobile service allocations that do not have such exclusion.

103. In addition to considering bands used for commercial mobile services to enable RPAS aerial UE, ISED also considered the possibility of bands currently available for non-competitive local licensing (NCLL), launched in May 2025. The NCLL service is designed to provide a simple licensing approach to allow small operators and businesses easy access to wireless services and beyond. A number of factors including policy, technical and licensing matters would need to be evaluated and examined in detail if RPAS operations were to be permitted in NCLL bands. Given the nascent nature of services deployed under the NCLL framework, at this time, ISED intends for NCLL to be limited to terrestrial use. Thus, consideration for RPAS operations in NCLL bands will not be considered in this consultation.

104. ISED is of the view that the above set of considerations supports the policy objectives discussed in section 3, and proposes that these considerations be used to help guide ISED in identifying the specific commercial mobile bands for which the RPAS framework will apply.

6.4.2 Proposed initial commercial mobile bands for RPAS use

105. ISED has applied the proposed considerations above to various bands that are currently being used to provide commercial mobile services, and proposes to apply this RPAS framework to the following bands:

• 600 MHz (617-652 MHz/663-698 MHz)
• 700 MHz (698-756 MHz and 777-787 MHz)
• Advanced Wireless Services (AWS)-1 (1710-1755 MHz/2110-2155 MHz)
• AWS-3 (1755-1780 MHz/2155-2180 MHz)
• Personal Communication Systems (PCS) (1850-1915 MHz/1930-1995 MHz)

106. The following sub-sections describe the context and current landscape in each of the bands where ISED is proposing to apply the RPAS framework.

600 MHz

107. The 600 MHz band was initially auctioned in 2019. In SLPB-002-18, Technical, Policy and Licensing Framework for Spectrum in the 600 MHz Band, ISED adopted a band plan of 10 MHz blocks (617-652 MHz/663-698 MHz) and a 3 MHz guard band (614-617 MHz). In addition, it set the auctioned licence areas as Tier 2 service areas, except in Yukon, the Northwest Territories and Nunavut, where Tier 4 service areas were licensed. Mobile service providers have been using the 600 MHz spectrum to provide commercial mobile services to customers for several years, as they continue to build out their 600 MHz networks.

108. In addition to commercial mobile use, a limited number of broadcasting stations continue to operate and will only be displaced two years following the issuance of a displacement notice from the commercial mobile licensee. In addition, there are a limited number of wireless microphone licences, as well as a limited number of land mobile stations operating through developmental licences, currently operating on a no-interference, no-protection (NINP) basis. The band also contains a few Remote Rural Broadband Systems (RRBS) stations, which have been authorized on a NINP basis with respect to TV broadcasting services. As indicated in SPB-001-24, Decision on New Access Licensing Framework, Changes to Subordinate Licensing and White Space to Support Rural and Remote Deployment (Access Licensing Decision), RRBS licences will no longer be renewed after March 31, 2027.

700 MHz

109. The 700 MHz band was initially auctioned in 2014. In SMSE-002-12, Decisions on a Policy and Technical Framework for Commercial Mobile Broadband Spectrum in the 700 MHz Band, ISED adopted a band plan for the 700 MHz band (698-806 MHz) that divided the band into two segments: lower 700 MHz (698-746 MHz) and upper 700 MHz (746-806 MHz). The lower 700 MHz band consist of three paired 12 MHz blocks in the 698-716 MHz/728-746 MHz and two unpaired 6 MHz blocks in the 716-728 MHz portion. The 746-756 MHz/777-787 MHz portion in the upper 700 MHz band consists of two paired 10 MHz blocks. DGSA-001-13, Licensing Framework for Mobile Broadband Services (MBS) — 700 MHz Band, set the licence areas as Tier 2 service areas, except in Yukon, the Northwest Territories and Nunavut, where Tier 4 service areas were licensed. The 700 MHz band has been deployed extensively by licensees since 2014 and it has a mature equipment ecosystem that is built into most North American handsets.

110. Also, the lower 700 MHz band contains a limited number of broadcasting stations operating on a NINP basis, a limited number of land mobile service licences and one land mobile service developmental licence operating on a NINP basis. In addition, the upper 700 MHz band contains one land mobile service developmental licence operating on a NINP basis. The upper 700 MHz commercial mobile operations are also adjacent to the 758-776 MHz/788-806 MHz public safety bands, which includes air-to-ground operations that operate on a NINP basis.

AWS-1 and AWS-3

111. The AWS-1 and AWS-3 bands were first auctioned in 2008 and 2015, respectively. The band plan for AWS-1 consists of six paired blocks: three paired 20 MHz blocks and three paired 10 MHz blocks. The auctioned licences in the AWS-1 band have a mix of licence areas, with some blocks licensed based on Tier 2 service areas and others licensed on a Tier 3 basis. Through SLPB-007-14, Technical, Policy and Licensing Framework for Advanced Wireless Services in the Bands 1755-1780 MHz and 2155-2180 MHz (AWS-3), ISED adopted a band plan consisting of four paired blocks: one paired 30 MHz block and three paired 10 MHz blocks. In addition, it set the auctioned licence areas as Tier 2 service areas. Both the AWS-1 and AWS-3 bands are extensively deployed across Canada.

112. In the CTFA, the AWS bands contain co-primary allocations for the fixed and mobile services, as well as the RAS on a secondary basis through footnote 5.385. In addition to commercial mobile services, the AWS bands contain a few land mobile licences operating on a NINP basis, a few standard and non-standard fixed point-to-point licences which are subject to displacement if preventing the deployment of an AWS system, as outlined in SLPB-007-14, and one radio astronomy licence operating at DRAO near Kaleden, British Columbia. Coexistence considerations with the RAS are discussed in sections 5.6.1 and 6.6.1.3.

Personal communication systems (PCS)

113. ISED first issued licences in a portion of the PCS band in 1995 through a process of comparative review. It subsequently made portions of the band available through two auctions in 2001 and 2008, and through a first-come, first-served process in 2003. The band plan consists of 11 paired blocks, one paired 30 MHz blocks and ten paired 10 MHz blocks. Licences in this band have a mix of licence areas, with the majority based on Tier 2 service areas and others based on Local Telephone Service Areas (TEL), Tier 3 and Tier 4 service areas. The PCS band is extensively deployed across Canada.

114. The PCS band is used primarily to provide commercial mobile services and some fixed services. It also contains a limited number of land mobile radio systems operating under developmental licences on a NINP basis, and some standard and non-standard fixed point-to-point systems that are subject to the displacement policies outlined in CPC-2-1-09, Displacement of Fixed Service Stations Operating in the 2 GHz Frequency Range to Accommodate Licensed Personal Communications Services (PCS).

6.4.3 Other policy considerations

115. In addition to the general considerations above, the following frameworks applicable to commercial mobile bands are discussed with regard to RPAS operations.

116. Access Licensing Framework: As a part of its suite of initiatives to improve mobile coverage and to enable the economic development of rural and remote areas, ISED released SPB 001-24 Decision on New Access Licensing Framework, Changes to Subordinate Licensing and White Space to Support Rural and Remote Deployment (Access Licensing Framework) in January 2024. Through that framework, ISED announced a new licensing approach to facilitate access to unused spectrum in rural and remote areas and support the provision or expansion of broadband services and new industrial or commercial applications in these areas. At the time of publication of that framework, ISED acknowledged concerns about potential coexistence challenges with respect to RPAS (referred to as drones in the Access Licensing Framework) use in bands identified for access licensing, and decided not to permit RPAS operations under the access licensing regime.

117. Through the present consultation however, ISED is revisiting this decision and is now proposing to remove the prohibition on RPAS operations from the Access Licensing Framework, noting that RPAS operations are limited to bands identified under the present RPAS framework consultation. Currently, only the PCS band is part of the Access Licensing Framework and the present RPAS framework consultation.

118. Supplemental mobile coverage by satellite : In February 2025, through the publication of SMSE-001-25 Decision on a Policy, Licensing and Technical Framework for Supplemental Mobile Coverage by Satellite (SMCS framework), ISED announced its decision to enable the use of bands for flexible use and/or commercial mobile services to support the expansion of coverage via satellite, particularly in areas where terrestrial network is unavailable. Under the SMCS framework, mobile subscriber devices (or UEs) may connect directly to authorized satellite space stations, to access commercial mobile network connectivity.

119. ISED believes that RPAS using SMCS could facilitate services and applications in areas where terrestrial commercial mobile coverage may be limited or unavailable. As a result, ISED proposes to permit RPAS aerial UEs to communicate with authorized satellites under the SMCS framework. As such, RPAS operations using SMCS would be limited to bands common to the SMCS framework and the RPAS framework. Licensing requirements for RPAS use in commercial mobile bands are discussed in section 6.5.

6.4.4 Changes to the Canadian Table of Frequency Allocations

120. As discussed in Section 6.4.1, ISED will not consider those commercial mobile bands where the aeronautical mobile service is explicitly excluded from the allocation.

121. Aerial UEs are able to communicate CNPC information as well as payload information. However, aerial UEs would not be permitted to communicate radionavigation-related information using the commercial mobile bands since there is no aeronautical radionavigation or radionavigation allocations in these bands. Thus, ISED is proposing to modify the CTFA to include the following footnote for the applicable bands:

ADD CYY: Aerial user equipment for Remotely Piloted Aircraft System (RPAS) operations are permitted under the mobile service allocations in the following frequency bands: 617-652 MHz/663-698 MHz, 698-756 MHz and 777-787 MHz, 1850-1915 MHz/1930-1995 MHz, 1710-1755 MHz/2110-2155 MHz, and 1755-1780 MHz/2155-2180 MHz. RPAS operations in these bands are limited to command and non-payload communications (CNPC) and payload communications.

122. ISED will monitor international developments and may adjust spectrum policies, as appropriate, based on outcomes.

6.5 RPAS licensing framework in commercial mobile spectrum

123. In permitting RPAS operations in commercial mobile spectrum, ISED is considering licensing mechanisms that support the timely deployment of RPAS applications while facilitating coexistence between RPAS and incumbent operations in the relevant bands. It is noted that in addition to obtaining the relevant spectrum authorizations from ISED, RPAS operators must also meet the relevant TC requirements prior to the operation of RPAS (see section 5.6 above).

124. In Canada, spectrum licences have been granted to commercial mobile service providers to enable flexible use (i.e., fixed and mobile) services in specific bands. In general, commercial mobile service licensees can deploy terrestrial base stations and UEs anywhere within their licence area, subject to relevant policy, technical and operational requirements. There is no additional licence required for the deployment of individual base stations or UEs.

125. ISED recognizes that RPAS applications are intended to benefit from the reliability, security and wide area coverage offered by commercial mobile networks. As such, one option to enable the operation of aerial UEs could be to permit these RPAS operations under the existing spectrum licences issued to commercial mobile licensees in specified bands. Under this option, a third party RPAS operator (i.e., an RPAS operator that is not a commercial mobile licence holder in a particular band and geographic area) could access commercial mobile networks, subject to contractual service agreement with the relevant commercial mobile licence holders. That is, the RPAS operator would be a subscriber of the commercial mobile operator. No new spectrum licences would be required for, or issued to, the RPAS operator. This approach would be similar to terrestrial UE operators (e.g., smartphone users) seeking service with a mobile network operator.

126. This option has the benefit of enabling commercial mobile licensees to retain control of the access to their networks, while enabling access by third-party RPAS operators as their subscribers. The commercial mobile licence holder, as the licensee, will continue to be responsible for compliance with the policy, technical and operational requirements in accordance with their licence. As per current practice, interference mitigation between co-channel, adjacent area terrestrial operations between different operators would remain the responsibilities of the commercial mobile licensees. With the introduction of RPAS operations, the same interference mitigation practice would also apply in the same manner. However, specific technical provisions may be necessary to take into account the nature of aerial UE operations, as described in section 6.6 on technical considerations for aerial UEs. Nevertheless, ISED believes this licensing option could enable a timely deployment of RPAS UEs, taking advantage of an existing licensing framework with minimal amendments, and enabling effective coexistence of all users.

127. As an alternate licensing option, ISED could consider other licensing models such as the one adopted in the UK by Ofcom. As mentioned in the section 6.2, Ofcom introduced a new licence called UAS Operator Radio Licence to authorize the use of specific radio frequencies on RPAS aerial UEs. Under this licence, a UAS (or RPAS) operator is permitted to utilize mobile networks for connectivity provided they obtain consent from the relevant network operator to do so. Ofcom highlighted that studies have shown that aerial UE operations can have a negative impact on a commercial mobile network, and concluded that the operation of aerial UEs in a commercial mobile network requires the agreement of the network operator before UAS Operator Radio Licence is granted by Ofcom. It should be noted that Ofcom has generally granted nation-wide licences for commercial mobile services, as such, co-channel interference in adjacent areas is not applicable in the operation of aerial UEs in the UK.

128. In the Canadian context, under this model, an applicant, i.e. either a third-party licensee or a commercial mobile licensee, would be issued a new licence specifically for the operation of aerial UEs. Further consultation would be required to determine licensing elements such as the type of licence (e.g., an aeronautical radio licence or a spectrum licence), licence area type (e.g., a licence area defined by a tier service area or an area defined by the aerial UE flight path), duration of the licence term and an appropriate fee structure, among other things. A further consultation on these elements would be essential to clearly define an appropriate licensing framework for third-party access to commercial mobile spectrum, but may delay the deployment of aerial UEs in commercial mobile bands. Under this licensing option, the use of the commercial mobile spectrum by an RPAS licensee for the operation of aerial UEs would be subject to the agreement of all relevant commercial mobile licensees where the aerial UE intends to operate. In addition to the agreement from the relevant licensees, RPAS operators issued a licence to operate an aerial UE would also need to seek agreements from all impacted commercial mobile licensees (i.e., those who may not be within the intended operation, or flight path of the RPAS aerial UEs, but those that could potentially be impacted or interfered with by the RPAS operation). Unlike the first option, which requires existing commercial mobile licensees be responsible for mitigating interference with adjacent area operations, this approach would require RPAS licensees to take on such responsibilities. Securing agreement among all affected parties could be technically complex, time-consuming, and administratively burdensome.

129. ISED proposes to permit RPAS aerial UE operations under the existing spectrum licence held by the commercial mobile licensee in specified bands. The commercial mobile licence holder would be responsible for meeting all of their conditions of licence. Any third-party operator deploying RPAS services would do so as a subscriber of the applicable commercial mobile operator.

6.5.1 Conditions of licence

130. If the proposal to permit RPAS aerial UE operations under the existing spectrum licence issued to the commercial mobile licensee in specified bands is adopted, ISED seeks comments on whether current conditions of licence applied to existing commercial mobile spectrum licences, in the applicable bands, are sufficient to enable RPAS aerial UE operations. It is noted that technical rules and coexistence measures may need to be modified to enable RPAS UE operations (see section 6.6). As per existing commercial mobile licences, licensees are obligated to comply on an ongoing basis with the applicable Radio Standards Specifications (RSS) and Standard Radio System Plans (SRSP), as amended from time to time. Thus, changes to technical rules do not necessitate changes to the conditions of licence.

131. Furthermore, it is noted that licences issued by ISED only permit access to the use of radio frequency spectrum resources. It is the responsibility of the commercial mobile licensee to ensure the operation of an RPAS aerial UE in commercial mobile spectrum comply with all relevant laws and regulations, including but not limited to, TC's regulations governing the operation of RPAS in Canada.

6.5.2 Authorizing RPAS aerial UE connectivity via SMCS space stations

132. As discussed in section 6.4.3 above, under the SMCS framework, mobile subscriber devices (or UEs) may connect directly to authorized space stations, to access commercial mobile network connectivity.

133. Given ISED's proposal to permit RPAS aerial UE operations under the SMCS framework, ISED is proposing to extend the generic SMCS earth station spectrum licences to also include RPAS aerial UEs. RPAS aerial UE operations served by SMCS would not be permitted until both the SMCS satellite licence and the generic earth station licence have been issued.

6.6 Technical considerations

134. RPAS operations in commercial mobile spectrum introduces a new interference environment. Aerial UEs will operate at higher altitudes than typical terrestrial UEs, providing them with line-of-sight propagation conditions to a greater number of terrestrial stations. This could result in a heightened risk of interference to both terrestrial operations and aerial UEs. This interference may result in the degradation or loss of communications. As a result, careful consideration and a sound understanding of the potential RPAS use cases would enable ISED to develop the appropriate technical rules to support RPAS operations while also facilitating the continued operation of incumbent services.

135. Technical considerations of envisioned RPAS use cases: There are many envisioned applications of aerial UEs for which the altitude of operation of these applications may vary widely. For example, in the agriculture sector, an aerial UE used for long range surveying may operate at a height between 50-120 metres. In the transportation sector, on the other hand, remotely piloted aircrafts for passenger taxis may operate at higher altitudes, potentially between 300-1500 metres above ground level.

136. ISED notes that globally recognized technical equipment standards, such as those published by the 3GPP for aerial UEs, suggest that the majority of aerial UEs will generally fly at a height of up to 300 metres in order to meet certain performance requirements, such as data rate or latency, for RPAS operations. ISED also recognizes that TC's drone regulations evaluate risks associated with aircraft operations. In these aforementioned regulations, small or medium lower-risk remotely piloted aircrafts for BVLoS operations are generally limited to altitudes below 122 metres (400 feet).

137. Accordingly, ISED is seeking comments on the anticipated use cases and deployment considerations of RPAS aerial UEs, including their associated altitudes of operations in commercial mobile bands, particularly with respect to how they could impact the interference environment with other users.

6.6.1 Coexistence between RPAS and other systems

6.6.1.1 Coexistence between RPAS and commercial mobile systems

138. As mentioned, the introduction of RPAS operations in commercial mobile bands could potentially impact the operation of incumbent commercial mobile networks: within the commercial mobile operator's own network (i.e., intra-network interference), co-channel systems operating in adjacent geographic areas (i.e., co-channel inter-network interference), and adjacent-block operations in the same geographic area (i.e., adjacent-block inter-network interference).

139. Accordingly, ISED has reviewed published studies, including 3GPP's TR 36.777, Enhanced LTE Support for aerial vehicles (Technical Report 36.777), and ECC's ECC Report 309, Analysis of the usage of aerial UE for communication in current Mobile/Fixed Communications Network (MFCN) harmonised bands (ECC Report 309) which address coexistence challenges between RPAS operations and existing terrestrial commercial mobile networks. Both of these studies used the same general technical parameters, based on 3GPP specifications, to characterize both the terrestrial and aerial UEs. ISED has also conducted preliminary studies, assessing the impact of aerial UEs to existing commercial mobile networks.

140. Intra-network interference: 3GPP's Technical Report 36.777 and ECC Report 309 investigated potential co-channel intra-network interference arising from the integration of RPAS aerial UEs into existing LTE networks. Both studies concluded that aerial UEs will cause more interference than terrestrial UEs within its own network due to the aerial UEs operating in direct line-of-sight of more cells than terrestrial UEs.

141. The 3GPP Report 36.777 further identified potential network-based solutions, including mechanisms for aerial UE operations such as power control and the implementation of on-board directional antennas to mitigate intra-network interference. For instance, operators can dynamically adjust transmission power to the necessary levels required for RPAS operations, thereby reducing the likelihood the aerial UE transmits with excessive power. In order to facilitate coexistence and implement interference mitigation measures specific to aerial UEs, the ECC further suggested that a commercial mobile network operator should be able to differentiate between an aerial UE and a terrestrial UE within its network by employing mechanisms developed by the 3GPP.

142. Intra-network interference mitigation measures: Based on these findings, ISED believes that the potential for intra-network interference when RPAS aerial UEs access a commercial mobile operator's network is likely best addressed by the commercial mobile operator serving the aerial UEs. ISED's proposal, above, to permit RPAS aerial UE operations under the existing spectrum licence issued to the commercial mobile licensees in specified bands, would enable commercial mobile licensees the flexibility to adjust their networks to facilitate intra-network coexistence with RPAS, as required. Comments are sought on the effectiveness of such an approach in addressing potential intra-network interference issue.

143. Co-channel inter-network interference: The 3GPP and ECC studies did not address potential co-channel inter-network interference to neighbouring commercial mobile operations.

144. With the current licensed operations in mind, ISED has conducted preliminary studies to assess the impact of aerial UEs to co-channel commercial mobile operations in adjacent geographic licence area. Specifically, the study assessed the probability of throughput degradation to the victim terrestrial commercial mobile network in the adjacent geographic licence area. ISED's preliminary results indicate that aerial UE operations in terrestrial commercial mobile networks has the potential to cause interference to co-channel licensees operating in the adjacent geographic licence area if there are no mitigation measures implemented. ISED's preliminary results also indicate that the impact of interference to terrestrial commercial mobile networks is proportional to the altitude of the interfering aerial UEs. Furthermore, it was observed that aerial UEs are capable of interfering at much greater distances than conventional terrestrial UEs, highlighting the unique impact of RPAS on the radio environment.

145. Co-channel inter-network interference mitigation measures: In facilitating coexistence between different terrestrial commercial mobile services operating on the same frequency blocks in adjacent areas, ISED's technical rules typically include coexistence measures such as a maximum allowable field strength or power flux-density (pfd) at the licence area boundary. Deviations from these measures may be permitted in certain cases through agreements between licensees.

146. As noted above, through this consultation, ISED proposes to permit RPAS aerial UEs to connect to terrestrial base stations and SMCS space stations in order to access commercial mobile network connectivity. ISED anticipates that potential interference from aerial UEs, whether connected to a terrestrial base station or via an SMCS space station, into networks operating on the same channel in the adjacent licence area would be managed by applying commonly used regulatory mitigation measures found in ISED's technical standards, such as pfd limits at the licence boundary.

147. Other non-regulatory mitigation measures could be implemented by the network operators such as resource scheduling, operator to operator coordination mechanism, including antenna down tilting, antenna offset, etc.

148. Although aerial UEs may require higher operating power levels when connecting to SMCS space stations, ISED believes that the low density of drones in addition to the low density of networks operating on the same channel in the adjacent licence area, particularly in rural and remote areas that are envisioned for SMCS, minimizes the potential for harmful interference.

149. Furthermore, because aerial UEs are highly mobile and transmit only in part of the channel which is dynamically assigned, any potential interference caused by aerial UEs is expected to be intermittent. By adopting appropriate mitigation measures, the network may optimize its capabilities and dynamically manage any received interference. As a result, ISED proposes that current coexistence mechanisms, such as the pfd limits at the licence boundary, in the applicable Standard Radio System Plan (SRSP) are sufficient and no changes to these technical rules are required with the introduction of RPAS aerial UEs in the relevant commercial mobile bands.

150. ISED, however, is of the view that certain technical equipment rules specific to aerial UE devices may be required considering current Radio Standards Specifications (RSS) have been developed for terrestrial UEs. Specific technical requirements such as power limits and transmit power control provisions may need to be applied to the aerial UE. Consequently, ISED proposes to develop new technical requirements in the relevant Radio Standards Specifications (RSS) for aerial UEs through a future consultation with stakeholders such as the Radio Advisory Board of Canada (RABC).

151. Adjacent block inter-network interference and related interference mitigation measures: ISED also conducted preliminary studies assessing the impact of aerial UEs, based on compliance with existing terrestrial UEs technical specifications such as out-of-block emission limits, to adjacent block licensees operating in the same geographic area. Based on ISED's preliminary study, such interference is minimal. This aligns with adjacent block inter-network studies in ECC Report 309, which concluded that degradation caused by aerial UEs into the adjacent block would result in minimal throughput loss. As such, ISED proposes to not require any additional interference mitigation measures to address adjacent block inter-network interference.

6.6.1.2 Coexistence between RPAS and fixed and land mobile systems

152. As a part of ISED's preliminary studies, ISED also evaluated the potential interference into other systems operating in adjacent bands.

153. The proposed introduction of aerial UEs operating in the initial bands, notably the 700 MHz, AWS-1 and AWS-3 presents potential coexistence challenges with incumbent services in the adjacent spectrum. Specifically, the 768–776 MHz band is currently for public safety services. The 1700–1710 MHz, 1780–1800 MHz and 1830–1850 MHz bands are used by fixed point-to-point line-of-sight digital radio systems, which provide backhaul for emergency services and commercial networks.

154. Based on ISED's preliminary analysis, ISED is of the view that coexistence with adjacent public safety and fixed point-to-point services, in the relevant bands mentioned above, can be achieved using the existing technical mitigation measures, such as the out-of-band emission (OOBE) limits in the relevant RSS. Additional interference mitigation measures are not required.

6.6.1.3 Coexistence with the radio astronomy service

155. As discussed in section 5.6.1, radioastronomy operations at DRAO may be susceptible to harmful interference from RPAS operations, especially since the use of aerial UEs could nullify the geographical isolation offered by the DRAO site. In particular, radio astronomy operations in the 608-614 MHz band, could be impacted by aerial UEs in the adjacent 600 MHz band. Furthermore, radio astronomy operations in the 1400-1427 MHz band may be susceptible to potential harmful interference from the harmonics of systems used in the 700 MHz band proposed for RPAS.

156. To mitigate the impact of potential harmful interference towards the radio astronomy service, ISED proposes to establish, in applicable bands, exclusion zones around DRAO within which transmission and reception of signals for RPAS operations would be prohibited. Commercial mobile licensees would be responsible for ensuring that all associated aerial UEs do not transmit or receive signals within the exclusion zones. The exclusion zones would be included in relevant technical standards to be developed by ISED in consultation with stakeholders, such as the Radio Advisory Board of Canada (RABC).

6.6.1.4 Coexistence with the meteorological-satellite service

157. In Canada, certain meteorological data is received by satellites operating in the geostationary orbit (GSO), which maintain a fixed position relative to the Earth, and polar-orbiting satellites (e.g., NGSO), which orbit from pole to pole. Multiple earth stations are used to track the satellites and to receive their transmissions. Meteorological-satellite (MetSat) earth stations presently coexist with adjacent band commercial mobile networks and devices with the help of appropriate coexistence measures.

158. In Europe, similar to Canada, MetSat services operate in the 1695-1710 MHz band for space-to-earth data transmission. Recognizing the potential for adjacent band interference from aerial UEs operating above 1710 MHz to these MetSat earth stations below 1710 MHz, the ECC performed technical studies, outlined in ECC Report 309. The ECC study concluded that a more stringent out-of-band emission limit for aerial UEs operating above 1710 MHz is required to ensure protection of MetSat earth stations receiving in the 1675-1710 MHz band. Otherwise, the establishment of exclusion or coordination zones around earth stations may be required to ensure the integrity of meteorological satellite data reception. The CEPT subsequently adopted the recommended out-of-band emission limit in ECC Decision(22)07. It should be noted that the out-of-band emission limit adopted by the ECC for aerial UEs operating above 1710 MHz is more stringent than the existing out-of-band emission power limit for terrestrial UEs in the relevant technical equipment standard in Canada.

159. The 3GPP, through its Release 18 standard also updated relevant 3GPP specifications for UEs to include the additional out-of-band emission limit specific to aerial UEs to protect MetSat earth stations operations below 1710 MHz.

6.6.2 Cross border coexistence and international obligations

160. Existing bilateral agreements between Canada and other administrations, notably the U.S., to enable terrestrial deployments near the Canadian border have been detailed in Terrestrial radiocom agreements and arrangements (TRAA). Many of these agreements are binding, and all domestic policy changes must continue to comply with existing treaty obligations as well as make good faith efforts to comply with non-binding arrangements.

161. At this time, existing cross border agreements only address interference caused by base stations and do not take into account potential interference from aerial UE operations. Although ISED is of the view that potential interference from aerial UE operations can be managed by applying commonly used mitigation measures and through operator to operator agreements until the applicable cross border agreements have been revised, any interference caused by Canadian RPAS aerial UE operations to U.S. operations near the border must be resolved in a timely manner.

162. The operation of RPAS aerial UEs in the initial commercial mobile bands proposed for RPAS will be subject to the requirements of any future cross border agreements that may be established between Canada and other administrations, including the U.S.

6.7 Other considerations

163. As mentioned above, ISED recognizes that potential RPAS operations in commercial mobile bands is in the early stages of development and continues to evolve. As such, ISED will continue to monitor both international and domestic developments related to RPAS, and factor any new considerations in the establishment of the RPAS framework, and any future updates. ISED welcomes comments related to any other considerations related to RPAS use of commercial mobile bands.

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

165. In addition, respondents are asked to specify the paragraph or proposal number for ease of referencing and to provide a supporting rationale and arguments for each response.

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

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

167. All submissions should cite the Canada Gazette, Part I, the publication date, the title and the notice reference number (SMSE-016-25). Respondents should submit their comments no later than 27 February 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.

168. ISED will also provide interested parties with the opportunity to reply to comments from other parties. Reply comments will be accepted until 27 March 2026.

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