The Canadian spectrum regulator, Innovation, Science and Economic Development Canada (ISED) initiated a public consultation on June 17, 2024 on policy, licensing and technical aspects of supplemental mobile coverage by satellite (SMCS). The consultation will cover key questions including which terrestrial mobile bands should be considered for the service, service area size, licensing of the satellite stations for coverage in Canada, support for 911 and emergency alerts, coexistence with other services and cross-border issues. Comments are due on September 13, 2024 and Reply Comments until October 15, 20214,
It is also noteworthy that ISED also plans for the new SMCS framework to take effect on April 1, 2025. D2D services represent a great opportunity for mobile coverage in Canada and can lead to significantly better service availability and quality in many areas of the country.
At the same time the FCC in the US is in the midst of a similar consultation following a Further Notice of Proposed Rulemaking on “supplemental coverage from space” (SCS) issued in March 2024. There are a number of key differences between ISED and the FCC… notably in terms of the proposed bands and the geographic area for the service. ISED and the FCC both exclude existing MSS providers from the new regime.
The ISED consultation has important implications going forward for existing mobile spectrum licensees as well as for existing and potential satellite providers.
Providing a lifeline for emergencies is likely to be an initial focus of SMCS service as well as expanding mobile services in unserved and underserved areas including indigenous areas.
Longer term it could support a broader service offering particularly as mobile non-terrestrial network (NTN) standards and technology evolve.
This framework could eventually lead to fundamental changes on how mobile services including emergency services are delivered in currently unserved areas including roads and remote areas. Some areas for comment in the ISED consultation are:
- Band choice – The FCC bands are all FDD and ISED has prioritized FDD, given the complexity of using TDD for satellite connections, while noting that TDD is commonly used in terrestrial networks. ISED is however proposing a broader set of spectrum bands than those covered by the recent FCC framework. This implies that satellite providers could want to support a different set of bands than those identified by the FCC. A good review of the bands, issues, and developments would complement the discussion and help focus ISED on what the best approach is considering the FCC process as well as what is planned and being implemented by various satellite operators.
- Geography – Canada’s geography and mix of regional and national providers does not lend itself to requiring the equivalent of a CONUS area for coverage as proposed by the FCC. The closest would be Tier 1, which no mobile operator has. Different geographic options should be reviewed to suggest an approach that would accommodate the Canadian context.
- MSS providers – As ISED notes, the existing framework for MSS already supports direct-to-device operations in spectrum allocated to MSS. On that basis a separate regime makes sense, but it will be important not to over-burden SMCS services with requirements that are not necessarily in place for MSS. One example cited in the US, is the question of location-specific information for emergency calling.
- ISED is silent on MVNO’s… the ISED proposals apply to “flexible use licensees”, including subordinated licensees, and it is not clear if/how the SMCS capability would flow through to MVNO arrangements under the current CRTC framework. However, ISED does address mandatory roaming as a condition of license and suggests two proposals which are focused on delaying a mandatory roaming provision or not to have it at all.
- There are many other elements of the consultation… In terms of using foreign satellites for SMCS services, ISED proposes to require that there be an agreement in place between the foreign satellite operator and a Canadian mobile provider before making an application for foreign satellite approval. And in addition that the agreement cannot be exclusive. Implementation of the service could also require that SMCS service be included in operators’ agreements for emergency roaming.
Please contact us to discuss with you how we can help assess the impact of this proposed framework on your current and future operations.