Further Comments : Canadian Federation of Agriculture (Intervenor 205)

Document Name: 2015-134.223881.2537712.Further Comments (1$#4001!).pdf

Submission by the Canadian Federation of Agriculture (CFA) Canadian Radio-television and Telecommunications Commission (CTRC):

Phase 2 - Review of Basic Telecommunications Services for all Canadians Telecom Notice of Consultation CRTC 2015-134-3

February 8th, 2016
**** Ross
Director of BRM and Farm Policy
21 **** street Ottawa,
Ontario *** ***
******@***.com
cfa-fca.ca
mailto:******@***.com
mailto:******@***.com

21 rue **** St., Ottawa, Ontario, *** *** • Tel. *-***-***-**** • Fax/Téléc. *-***-***-**** • www.cfa-fca.ca 1 Background:

The CFA was formed in 1935 to answer the need for a unified voice to speak on behalf of Canadian farmers. It continues today as a farmer-funded, national umbrella organization representing provincial general farm organizations and national commodity groups. Through its members, it represents over 200,000 Canadian farm families from coast to coast. The CFA's mission is to promote the interests of Canadian agriculture and agri- food producers, including farm families, through leadership at the national level and to ensure the continued development of a viable and vibrant agriculture and agri-food industry in Canada.

CFA works to coordinate the efforts of agricultural producer organizations throughout Canada for the purpose of forming and promoting national agricultural policies to ensure Canadian agriculture remains profitable, competitive, and has the stability needed to innovate and adapt to meet changing domestic and international conditions.

CFA’s Perspective:

As an organization, we maintain the belief that all agricultural producers should have access to modern communications technology, equal in price, reliability, and speed to services in urban areas.

CFA would like to express our members’ support for the government’s reaffirmed commitment to extend and enhance broadband internet services in rural and northern communities in order to meet the continued demand for fixed wireless services in rural areas through the 2014 Economic Action Plan’s commitment of $305 million to upgrade broadband services in unserved and underserved communities in Canada. Access to high speed, broadband internet services at a reasonable cost is a necessity for Canada’s producers and rural communities to remain competitive and fully leverage modern technologies available to them.

Canadian agriculture is at the heart of an agri-food industry that contributes over $103 billion dollars to Canada’s GDP, and employs over 2.1 million Canadians. Affordable broadband internet access is integral to Canadian agriculture as a means of connecting producers to both domestic and international markets, accessing and leveraging innovative technologies, and ultimately maintaining the industry’s competitiveness moving forward. As a driver of the Canadian economy, agriculture’s continued international competitiveness depends on Canada’s ability to increase and enhance the provision of broadband internet to rural communities. This is only possible if current access is maintained, enhanced, and made more affordable.

http://www.cfa-fca.ca/

21 rue **** St., Ottawa, Ontario, *** *** • Tel. *-***-***-**** • Fax/Téléc. *-***-***-**** • www.cfa-fca.ca 2 Canadian Agriculture & the Digital Economy

Canadian agriculture’s use of technology continues to evolve at a dramatic pace. Innovations in marketing, production, and product research continue to create additional opportunities for producers to participate in both domestic and global marketplaces through online technologies. As a result, access to broadband internet service has become an essential tool for primary agricultural producers in the modern economy.

In CFA’s previous submission, we noted that a significant number of producers still lack access to broadband internet services and that an even larger proportion of the industry lacks access on a reliable and affordable basis, especially when compared to urban services. At the same time, affordability for these services remains a major concern for Canadian farmers. A lack of service provider competition has been noted across many parts of rural Canada, leading to inadequate internet download/upload speeds, inconsistent servicing, and a lack of adequate investment in deployment of broadband internet infrastructure outside of urban centres.

Farmers across Canada continue to cite a lack of access to reliable broadband internet access, preventing them from being able to take advantage of many opportunities. Online e-learning, on-farm computer systems, and on-demand market information all require access to streaming information on a time-sensitive basis; however a general lack of access to more reliable options continue to prevent producers from accessing this essential service without significant delays, uncertainty, and ultimately, lost productivity. This situation is all the more problematic, given that the internet connectivity needs of farmers is expected to increase dramatically over the next 5 to 10 years, due to increased emphasis on data, analytics, and associated on-farm management technologies as the next major source of productivity gains in Canadian agriculture1.

Redefining “Basic” Broadband Access

In contrast to previous assertions that high-speed broadband internet connectivity is only required to serve recreation and video entertainment, Canadian agriculture is poised to require a dramatic increase in internet connectivity needs due to the rapidly emerging application of precision agriculture and telematics combined with increasing needs for real-time market research, e-commerce, and online learning. As identified in CFA’s previous submission, Precision farming is a farming management approach based on measuring and responding to inter and intra-field variability in crops, with similar corollaries emerging in livestock management systems through barn monitoring systems. Telematics refers to technology that allows “farmers to remotely monitor their equipment and the farm workers operating the equipment, upload variable rate prescriptions to applicators, and gather real-time equipment diagnostics and site-specific sensor data.”2

Recent technological advances in smart sensors and wireless networks are creating new opportunities for efficiency and productivity gains through real-time monitoring of data involved in raising livestock and crops. Use of on-farm data monitoring and management systems is part of a global trend in agriculture, and for Canadian farmers to remain competitive and access these technologies, increased upload and 1

Farm Credit Canada. FCC Economic Update: Think Big (Data) in Agriculture. https://www.fac-fcc.ca/en/ag-knowledge/technology-and-innovation/fcc-economic-update-think-big-data-in-agriculture.html 2

Whitacre, B.E.; ****, T.B.; ****, T.W (2014). How Connected are Our Farms? Choices: The magazine of food, farm, and resource issues. 29(3). pg. 2

http://www.cfa-fca.ca/

21 rue **** St., Ottawa, Ontario, *** *** • Tel. *-***-***-**** • Fax/Téléc. *-***-***-**** • www.cfa-fca.ca 3 download speeds across rural Canada will be essential. As identified in CFA’s past submission, “a lack of broadband connectivity could hinder the adoption of precision agricultural processes and negatively impact any associated productivity and efficiency gains”3 With the majority of Canadian farmers relying on fixed wireless and satellite services, the level of service available to many farmers continue to fall short of current agreed-upon definitions of minimum “basic” broadband access (5 Mbps). These current levels of broadband access already constrain Canadian farmers’ ability to meaningfully participate in the digital economy, forcing some to procure disproportionately expensive secondary services to meet their on-farm needs that unduly increase businesses expenses. The aforementioned trends will exacerbate the existing service gap facing many regions of rural Canada, unless the basic service objective is updated to recognize current download/upload requirements and the expected increase in demand for higher speeds.

As such, CFA supports the Affordable Access Coalition4 in advocating that the Commission set a goal of all Canadian households being able to access 25 Mbps broadband internet service by 2020 (the “25 Mbps by 2020” goal), subject to annual updates to the definition of “basic” broadband. Not only would this fall in line with the broadband access goals of Canada’s major trading partners, it would provide a foundation through which the CRTC and service providers could address the growing disparity in service availability between rural regions and urban centres.

Addressing the Broadband Service Gap: The Need for Investment in Broadband Deployment To support the achievement of the aforementioned goal of 25 Mbps by 2020, the existing subsidy regime must be supplemented to ensure adequate investment is made in rural broadband deployment. As identified above and in CFA’s previous submissions, Canadian farmers in many parts of Canada currently lack access to internet services capable of providing services with adequate speeds and consistency. **** in terms of availability and affordability, this has resulted in a growing divide between the level of services available to urban and rural Canadians. Given the rural and remote locations of many farm operations, by necessity, addressing this divide requires dedicated investment into deployment of broadband internet infrastructure across Canada.

To achieve this end, CFA believes the Commission should establish a new funding mechanism, supplemental to the existing National Contribution Fund, to specifically support broadband deployment.

CFA advocates for the establishment of the Broadband Deployment Funding Mechanism (BDFM), as developed by Edgardo **** in the report entitled “Funding support for low-income Canadians and Broadband Deployment” (see Appendix A for this report).

This funding mechanism is designed to reduce the broadband Internet access services gap between and within regions, including urban-rural discrepancies, by supplementing the current subsidy regime. This mechanism could be financed through the existing National Contribution Fund by modifying it to include retail Internet and paging service revenues as eligible revenues.

The BDFM is designed directly to target the expansion of networks and/or services, rather than the 3

Whitacre, B.E.; ****, T.B.; ****, T.W (2014). How Connected are Our Farms? Choices: The magazine of food, farm, and resource issues. 29(3). pg. 1

4

Comprised of the Association of Community Organizations for Reform Now, Canada (“ACORN Canada”); The Consumers’ Association of Canada (“CAC”); The Council of Senior Citizens Organizations of British Columbia (“COSCO”); The National Pensioners Federation (“NPF”); and The Public Interest Advocacy Centre (“PIAC”) http://www.cfa-fca.ca/

21 rue **** St., Ottawa, Ontario, *** *** • Tel. *-***-***-**** • Fax/Téléc. *-***-***-**** • www.cfa-fca.ca 4 maintenance of existing services, which has been the primary outcome of the existing subsidy regime. By operating through a market-oriented approach, service providers would participate in a ‘minimum subsidy auction’ to determine the most cost efficient proposal able to achieve deployment objectives identified by the Commission or a third-party. This active administrator would identify, select, design, cost, tender, and monitor projects with the objective of having a sequenced and economical deployment strategy.

Therefore, the BDFM approach would provide greater transparency as to the true cost of services and financial certainty as to the contribution amounts dedicated to deployment of internet services. By capping the total contribution amount on an annual basis, currently suggested at $220 million per year over the 2017-2020 period (Appendix A), this would ensure the contribution amounts fall closer in line with programs available to Canada’s main trading partners while remaining reasonable and falling within the historical average of the National Contribution Fund. As identified in the **** Report, program cost for the Broadband Deployment Funding Mechanism of $220,000 per year over the 2017-2020 period would, in combination with the existing subsidy regime, represent 0.60% of the Canadian Telecommunications Service Revenues over the 2017-2020 period. This percentage still falls below the historical average from 2001-2014 of 0.74%.

In Summary:

Canadian farmers and rural communities continue to face significant constraints in accessing reliable and adequate internet services. A lack of competition in many rural regions has left these regions with limited options, disproportionate service costs, and an inability to achieve upload/download speeds that meet even the minimum basic broadband service levels. As CFA identified in its previous submissions, this is resulting in missed business opportunities, limiting access to uptake of technological innovations in the industry, and ultimately undermining many farmers’ ability to participate meaningfully in the digital economy.

CFA has identified two important measures that would meaningfully contribute to reducing this service gap by improving the level of basic broadband service across Canada and dedicating increased investment to digital infrastructure deployment. These include:

1. That the Commission set a goal of all Canadian households being able to access 25 Mbps broadband internet service by 2020 (the “25 Mbps by 2020” goal), subject to annual updates to the definition of “basic” broadband.

2. That the Commission establish the Broadband Deployment Funding Mechanism (BDFM), as developed by Edgardo **** in the report entitled “Funding support for low-income Canadians and Broadband Deployment” (see Appendix A for this report).

In combination, these two measures would illustrate a commitment to improved rural internet service delivery; begin to reduce the divide between urban and rural internet services, and ultimately position Canadian agriculture to participate in a global agricultural marketplace that is increasingly reliant on digital and on-line technologies. I do not want to appear at the public hearing.

http://www.cfa-fca.ca/

APPENDIX A – Funding Support for low-income Canadians and for Broadband Deployment, by Edgardo ****

Funding support for low-income Canadians
and for Broadband Deployment
Report for CRTC TNC 2015-134: Review of
Basic Telecommunications Services
prepared for the
Public Interest Advocacy Centre (PIAC)
on
July 14, 2015
by
Edgardo ****
President, **** Consulting Inc.
Toronto, Ontario
*** *** Canada
E-mail: ******@***.com
www.esepulveda.com
Summary

This Report provides rationale and financial estimates for two new funding mechanisms that would helpincrease broadband Internet access and improve telecommunications affordability for low-incomeCanadians, to be financed through the National Contribution Fund (“NCF”). These would supplementthe current residential local wireline subsidy regime, which would continue to operate as is.

The Report proposes creating an Affordability Funding Mechanism similar to programs in otherjurisdictions (USA, ****, Spain, etc.) that offer telecommunications subsidies to low-incomehouseholds, and describes two possible versions of such a subsidy. The "baseline" version represents anaverage of subsidies offered in other jurisdictions, while the "ambitious" version would mirror the "bestin class" program, as currently available to low-income households in California. The Report describeshow an Affordability Funding Mechanism would operate, setting out eligibility criteria and providingestimates for number of eligible households, monthly subsidy, and total annual costs for each version.

The annual cost for the "base" version of the Affordability Funding Mechanism would be capped at $70million, while that of the "ambitious" version would be capped at $410 million.

The Report also proposes a Broadband Deployment Funding Mechanism to widen access to broadband,based on a minimum-subsidy auction approach for funding broadband deployment projects, similar tothe method used in other jurisdictions and recently adopted by the FCC in the United States. The annualcost of the Broadband Deployment Funding Mechanism would be capped at $220 million per year.

These two new funding mechanisms would require an increase to NCF contributions, which isreasonable given that the current NCF is relatively small and has decreased significantly in recent years,even as telecommunications service revenues have increased. The NCF contribution regime should beexpanded to include certain currently exempted services, and the percentage contribution should beincreased. The total annual cost of implementing the current subsidy regime, the baseline AffordabilityFunding Mechanism, and the Broadband Deployment Funding Mechanism would return the NCF to thehistorical average for the 2001-2014 period, 0.74% of telecommunications services revenues. The totalannual cost with the ambitious Affordability Funding Mechanism would increase the NCF to 1.42% oftelecommunications services revenues, equal to the average size of the USA Federal Universal ServiceFund over the 2001-2014 period.

Contents

1 Introduction................................................................................................................ 11.1 Current residential local wireline service subsidy regime...............................................22 Affordability Funding Mechanism........................................................................... 62.1 Overview .........................................................................................................................62.2 Financial Design of Affordability Funding Mechanisms................................................72.2.1 Baseline Affordability Funding Mechanism ...........................................................................72.2.2 Ambitious Affordability Funding Mechanism ........................................................................92.3 Beneficiary Eligibility ...................................................................................................102.4 Administration...............................................................................................................102.5 Eligible Services............................................................................................................102.6 Program Discount..........................................................................................................112.7 Eligible Service Providers .............................................................................................112.8 Program Participation and Participation Rate ...............................................................112.9 Program Cost.................................................................................................................112.10 Summary .......................................................................................................................123 Broadband Deployment Funding Mechanism ...................................................... 133.1 Overview .......................................................................................................................133.2 Design of Broadband Deployment Funding Mechanism..............................................133.3 Eligible Infrastructure/Services .....................................................................................163.4 Eligible Service Providers .............................................................................................163.5 Funding Amount and Distribution ................................................................................163.6 Administration...............................................................................................................163.7 Regulatory and Contractual Conditions ........................................................................173.8 Program Cost.................................................................................................................174 Contribution Mechanism (NCF) ............................................................................ 204.1 Cost of New Funding Mechanisms ...............................................................................204.2 Contribution Mechanism...............................................................................................22Annex: Low-Income Programs in other Jurisdictions ................................................ 25USA - Federal Lifeline ..............................................................................................................25USA - California Lifeline..........................................................................................................27Spain..........................................................................................................................................30**** ........................................................................................................................................33Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1341

1 Introduction

PIAC has commissioned me1 to propose designs for two new funding mechanisms: (i) a fundingmechanism to subsidize access to telecommunications services by low income Canadians (the“Affordability Funding Mechanism”), and (ii) a funding mechanism to support the deploymentof broadband Internet access (the “Broadband Deployment Funding Mechanism”).

For the purposes of these new funding mechanisms, PIAC has asked me to assume that there is atelecommunications affordability gap and a broadband Internet access services gap in Canada,neither of which will be closed or significantly reduced in the long-term by targeted Governmentfunding, public-private partnerships, or market forces. Additionally, PIAC asked me to assumethat residential local wireline service continues to be very important, and that the currentresidential local wireline service subsidy regime could continue. In this context, theAffordability Funding Mechanism is designed to reduce the telecommunications affordabilitygap and the Broadband Deployment Funding Mechanism is designed to reduce the broadbandInternet access services gap. These two new funding mechanisms would be supplemental to thecurrent residential local wireline service subsidy regime.

The rest of this Report is structured as follows:

• Section 1.1 sets out that the current residential local wireline service subsidy regime could becontinued “as is,” and projects that, based on the extension of recent trends, it will continueto decline to about $80 million per year over the 2017-2020 period.

• Chapter 2 describes the Affordability Funding Mechanism. Other jurisdictions I reviewedoffer subsidies to low income households to promote telecommunications affordability.

These include the USA “Lifeline” programs and similar programs in Spain and ****.

PIAC requested that I develop two versions of the Affordability Funding Mechanism - a“baseline” version reflecting my assessment of the comparative “average” of these otherprograms, and an “ambitious” version based on my “best in class” assessment. The“baseline” and “ambitious” Affordability Funding Mechanisms differ by monthly subsidyamount, number of eligible households, and annual cost, with the “baseline” AffordabilityFunding Mechanism having a monthly subsidy of $11 available to about 1.34 million eligiblehouseholds, for an annual capped cost of $70 million, and the “ambitious” version having a$22 subsidy to 2.61 million households and an annual capped cost of $410 million.

1 I have more than fifteen years of experience in universal service-related issues, having advised Governments and serviceproviders in relation to policy-setting, economic analysis, regulatory reform, establishment of universal service funds,auction design, and implementation of universal service projects in more than a dozen countries (e.g. Canada, Jamaica, St.

****, St. ****, Dominica, Cambodia, Saudi Arabia, Albania, Bahamas, ****, Morocco and Thailand.

I was the principal author of the “Universal Service” chapter of the Telecommunications Regulation Handbook (2000) andhave prepared the following: “Minimum Subsidy Auctions for Public Telecommunication Access in Rural Areas” (Chapterin ITU Trends in Telecommunication Reform [2003]); ITU “Report on Universal Access and Service Funds in the Sub-Saharan Africa Region” (2010); ITU “Improving the disbursement effectiveness of low disbursing Universal Service Fundsin Developing Countries” (forthcoming).

Prior to forming **** Consulting Inc. and becoming an independent consultant in 2006, I was SeniorTelecommunications Economist with **** Tétrault LLP and Senior Economist at Bell Canada.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1342

Household eligibility criteria and other elements of these Affordability Funding Mechanismsare developed in Chapter 2.

• Chapter 3 describes the Broadband Deployment Funding Mechanism. Other jurisdictionshave established funding mechanisms to deploy broadband based on a minimum-subsidyauction-based approach, a model that has also been recently adopted and implemented by theFCC in the USA. Under this approach, a specific contribution amount is collected or setaside for this funding mechanism. Separately, the National Regulatory Authority ("NRA")may identify, select, design, cost, and tender specific broadband deployment projects, at aspeed to be determined, in communities to be determined. Having access to the collectedamounts, the NRA sets aside a maximum available subsidy for each specific project.

Generally all service providers are eligible to participate in these auction processes. Theparticipating service provider bid proposing the lowest subsidy is selected for that project.

That winning service provider is then required to implement the project and is compensatedwith the winning subsidy amount. The annual cost of the Broadband Deployment FundingMechanism would be capped at $220 million per year. The rationale for this estimate andother elements of the Broadband Deployment Funding Mechanism are developed in Chapter3.

• These two new funding mechanisms would be supplemental to the current residential localwireline service subsidy regime and would therefore be financed by an increase incontributions to the National Contribution Fund ("NCF"). From a historical perspective, thecurrent NCF is relatively small and decreasing. Over the 2001-2014 period, the NCFaveraged $258 million per year (equivalent to 0.74% of telecommunications servicerevenues), and reached a historical low of $112 million in 2014. Chapter 4 describes howthe contribution regime could be expanded to include retail Internet and paging servicerevenues, thereby broadening the contribution-eligible “revenue base.” For the 2017-2020period the contribution amount for the current residential local wireline service subsidyregime (capped at $80 million) and the Broadband Deployment Funding Mechanism (cappedat $220 million) would reach $300 million in total. Adding to this amount the “baseline” or“ambitious” version of the Affordable Funding Mechanism ($70 million and $410 million)would result in an overall contribution amount of either $370 or $710 million per year.

These amounts are equivalent to about 0.74% and 1.42% of telecommunications servicesrevenues. The former is the same as the historical NCF average (0.74% oftelecommunications services revenues over 2001-2014), while the latter is equal to theaverage size of USA universal service fund (1.42% of telecommunications services revenuesover 2001-2014).

1.1 Current residential local wireline service subsidy regimeThis Section assesses the current residential local wireline service subsidy regime.

The first question I examine is whether currently or in the long-term the current subsidy regimecould be expected to close or significantly reduce either the telecommunications affordabilitygap or the broadband Internet access services gap. For both questions my assessment is negativebecause the current subsidy regime was not designed to address these gaps.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1343

Given this assessment, the second question I address is whether the current subsidy regime couldbe amended or redesigned to address the telecommunications affordability gap and thebroadband Internet access services gap, or whether new funding mechanisms should beintroduced.

• On the telecommunications affordability gap question, my assessment is that a newfunding mechanism could be introduced because it would not be feasible to amend thecurrent subsidy regime without fundamentally changing it. By way of example, thecurrent subsidy regime is geographic and cost-based, while any affordability-relatedfunding mechanism would likely be non-geographic and income-based. Chapter 2presents a new Affordability Funding Mechanism to reduce the telecommunicationsaffordability gap.

• On the broadband Internet access services gap question, my assessment is that while itwould be feasible to amend the current subsidy regime, it would not be desirable to do so,and hence a new funding mechanism should be introduced. Chapter 3 presents the newBroadband Deployment Funding Mechanism to reduce the broadband Internet accessservices gap and discussed the advantages relative to simply expanding the currentresidential local wireline service subsidy regime to include broadband.

On this second question, it is important to highlight that all of the jurisdictions I reviewed hadmore than one program as part of their overall universal service regimes. At the federal level inthe USA, the universal service fund (“USF”) traditionally had four separate programs (Lifeline,High Cost Program (now the Connect America Fund), Schools and Libraries Program, and RuralHealth Program), each designed to address specific issues. As set out in the Annex, the USF inSpain has three different programs, the USF in **** it has four different programs and the USFin Australia has two programs.2 This is in contrast to Canada, where the NCF has included onlyone program, the residential local wireline service subsidy regime. Based on the introduction ofthe new Funding Mechanisms described in Chapters 2 and 3, the NCF in Canada could in thefuture include three funding mechanisms.

Given the discussion above, a third question of whether the current subsidy regime could becontinued “as is,” refined, or discontinued can be considered in the context of the introduction ofthe two new Funding Mechanisms outlined in Chapters 2 and 3, the absolute and relativefinancial cost of the current subsidy regime, and the mid-term financial projections.

From a historical perspective, the current subsidy regime in Canada is small and decreasing.

Figure 1 shows the current subsidy regime in Canada from 2001 to 2014.3 Over the 2001-2014period it averaged $258 million per year. After the start-up year, the program cost of the currentsubsidy regime was relatively stable, after which it started to decline, reaching a historical low of$112 million in 2014.

2 These included “standard telephone service” in high-cost areas and public telephones. See “Services provided under theUSO” page from ACMA (the Australian NRA) at http://archive.acma.gov.au/WEB/STANDARD/pc=PC_24133 “Total Contribution” from “Central Funds Administration: Quarterly Report) http://www.crtc.gc.ca/eng/cfund-fondc.htm(Accessed ****, 2015).

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1344

Absent any further amendments to the current subsidy regime, it is reasonable to expect thatprogram cost will continue to decline, as presented in Figure 2, which shows that the averageprogram cost of the current subsidy regime over the 2017-2020 period could be projected toaverage about $77 million per year.4

In summary, based on the projections above, over the 2017-2020 period, the program cost of thecurrent residential local wireline service subsidy regime will continue to decline, averaging about$77 million per year. With the objective of enhancing financial certainty related to contributions,4 Projections for 2015-2020 are based on a simple statistical trendline (Y = 4702.7X-1.422) fitted over the 2009-2014 periodand extrapolated from 2014 to 2020.

$0
$100
$200
$300
$400
$500
$600
$700
$800
$900
$1,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure 1: Current Subsidy Regime in Canada

(CAD $000,000)
Average over
2001-2014
Period
$0
$100
$200
$300
$400
$500
$600
$700
$800
$900
$1,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 2: Current Subsidy Regime in Canada

(CAD $000,000; 2015 to 2020 are projections)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1345

the CRTC could cap the cost of the current subsidy regime at a level of $80 million starting 2017(which is the year that the Affordability Funding Mechanism and the Broadband DeploymentFunding Mechanism could begin to be implemented) to 2020. In this overall context, myassessment is that the current subsidy regime could continue “as is,” at least into the mid-term.

My assessment is based on the following considerations:

• The assumption that residential local wireline service continues to be very important, andtherefore the current subsidy regime could continue;

• given the new funding mechanisms discussed in Chapters 2 and 3, there is no need for thecurrent subsidy regime to be expanded to increase the affordability of telecommunicationsservices for low-income households or to subsidize the deployment of broadband Internetaccess services; and

• the expected decrease in the cost of the current subsidy regime will continue to create“budgetary slack” for the introduction of the two new funding mechanisms discussed inChapters 2 and 3.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1346

2 Affordability Funding Mechanism

This Chapter describes the Affordability Funding Mechanism. This funding mechanism isdesigned to reduce the telecommunications affordability gap and is supplemental to the currentresidential local wireline service subsidy regime. The Affordability Funding Mechanism couldbegin to be implemented in 2017.

2.1 Overview

I designed the two versions of the Affordability Funding Mechanisms based on my review andassessment of other jurisdictions that offer subsidies to low income households in order topromote the affordability of telecommunications. These include the USA (federal) program(“Federal Lifeline”), 17 State-level programs in the USA (“State Lifelines”), and programs in**** and Spain. All of these programs are funded by their respective USFs.5Table 1 and the Annex include a summary and a description of the above-noted programs. Theseprograms are described based on the following elements:

• Beneficiary Eligibility. This refers to the criteria used to determine which households areeligible to benefit from the program. Eligibility criteria may be program based only, incomebased only, both income and program based, or income or program based.

• Administration. This refers to whether the national regulatory authority (“NRA”) or a thirdparty administrator administers the program, including verifying beneficiary eligibility andliaising with service providers.

• Eligible Services. This refers to the services that may be provided to the beneficiaryhouseholds at a USF-funded discount.

• Program Discount. This refers to the monthly USF-funded discount applicable to theeligible services provided to the beneficiary households.

• Eligible Service Providers. This refers to the service providers that are eligible to5 For reference purposes, I also took into account the recently-announced Ontario Electricity Support Program (“OESP”),which will provide subsidies to low-income households for electricity starting January 2016. The OESP is a first of its kindin Canada (there are a number of comparable Federal and State-level plans in the USA and other countries) and wasdesigned by the Ontario Energy Board (OEB) based on direction by the Minister of Energy. Potential beneficiaries mustmeet income criteria (be below Statistics Canada’s LIM-AT income measure). Beneficiary eligibility verification will becarried out by a Third Party Administrator. The reduction of electricity bills for residential consumers is based on a slidingscale benefit that varies between $20 and $50 per month based on income and household size, with an estimated average of$27 per month. The OEB estimates program costs are at between $175 and $225 million a year, which would be financedby an end-user a surcharge on electricity usage. See the OEB “Report of the Board - Developing an Ontario ElectricitySupport Program” (December 2014) at http://www.ontarioenergyboard.ca/oeb/_Documents/EB-2014-0227/Report_of_the_Board_Developing_an_OESP_20141222.pdf, the OESP Backgrounder (March 2015) athttp://www.ontarioenergyboard.ca/oeb/_Documents/EB-2014-0227/OESP_Backgrounder_20150326.pdf and the OESPFAQ at http://www.ontarioenergyboard.ca/oeb/_Documents/EB-2014-0227/OESP_FAQ_20150326.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1347

participate in the program and may receive compensation for providing discounted services.

• Program participation and participation rate. This refers to the overall number ofhouseholds that participate in the program and the rate of program participation as apercentage of all eligible households.

• Program Cost. This refers to the annual costs of the program, expressed as an absoluteamount, and as a percentage of telecommunications service revenues.

2.2 Financial Design of Affordability Funding MechanismsThis Section provides the rationale for the elements of the Affordability Funding Mechanismrelated to overall cost (beneficiary eligibility, program discount, program participation, andparticipation rate).

2.2.1 Baseline Affordability Funding Mechanism

I designed the “baseline” Affordability Funding Mechanisms based on my assessment of thecomparative “average” of the programs in the USA, ****, and Spain.6 I used my judgement toapply the results to the Canadian context.

My primary criteria for comparison purposes was the comparative size of the respectiveprograms. For this I used the size of the program as a percentage of telecommunications servicerevenues. I consider that, for comparison purposes, telecommunications service revenues7 is theappropriate base of comparison, rather than the respective contribution-eligible revenues. This isbecause the set of services that are included in contribution-eligible revenues is different for eachof the jurisdictions and hence would not provide an appropriate basis for comparison.

Figure 3 shows that over the 2001-2014 period the low-income program of the USA USFaveraged 0.22% of telecommunications services revenues, while those in Spain and ****averaged 0.13% and 0.06%, respectively. The period average of these three countries was 0.14%of telecommunications services revenues, which is also presented in Figure 3. These averagesare also included in Table 1. The 0.14% is the percentage of CTSR “target” for the baselineAffordability Funding Mechanism for Canada.

Conceptually, this percentage is the product of the monthly subsidy and the number ofbeneficiary households. Further, the beneficiary households are the product of the number ofeligible households and the program participation rate. The average monthly USF-funded6 Please refer to the Annex for all data sources and other information related to these low-income programs.

7 For Canada I used “Canadian Telecommunications Service Revenues” (“CTSR”) from Central Funds Administration:

Quarterly Report) http://www.crtc.gc.ca/eng/cfund-fondc.htm. For other jurisdictions (USA, Spain, **** and Australia(see Chapter 3) I generally used “Telecommunications Revenue” from “OECD Communications Outlook 2013,” page 76http://dx.doi.org/10.1787/888932801014. For Canada I confirmed that the OECD’s revenue estimates are reasonablycomparable to CTSRs, generally being on average 3% higher during the 2001-2011 period.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1348

discount for USA, Spain and **** is CAD $11.60,8 and, as set out in Table 1, the averagepercentage of eligible households (of total population) is 13%.

Using a participation rate of 40% (see explanation below) and applying the average percentageof households (13%) and the average monthly discount ($11.60) applied to projected CTSRsover the 2017-2020 period9 results in an “over-shooting” of the 0.14% CTSR target.10 Adjustingthe two multiplicands downwards to “hit the CTSR target” results in a monthly discount of $11and a percentage of eligible households of about 10%.

With respect to the percentage of eligible households, my review of the Canadian contextindicates the following as reasonable candidate program and/or income eligibility criteria:

• provincially-administered11 social assistance programs or federally-administered Income8 As set out in Table 1, the USA, Spain and **** discounts are USD $9.25, €13.32 and €5.04. I used the average of annualexchange rates from OECD (2015) Exchange (indicator) http://dx.doi.org/10.1787/037ed317-en (Accessed July, 2015)) overthe 2010-2014 period to convert these to CAD.

9 Estimated as follows: “Canadian Telecommunications Services Revenue” for the 2001-2014 period are from “Central FundsAdministration: Quarterly Report) http://www.crtc.gc.ca/eng/cfund-fondc.htm (Accessed ****, 2015). Revenues for 2015-2020 extrapolated from 2014 using cumulative average growth rate (“CAGR”) of “Canadian Telecommunications ServicesRevenue” from above over the 2001-2014 period (calculated at 2.8%).

10 The over-shooting is attributable to differing participation rates across the jurisdictions.

11 See “Social Assistance Summaries 2014” (March, 2015) Caledon Institute of Social Policy athttp://www.caledoninst.org/Publications/PDF/1062ENG.pdf (Accessed **** 2015). The following are the provincially-administered social assistance programs: Newfoundland - Employment and Income Assistance (EIA); Nova Scotia -Employment and Income Assistance (ESIA): Prince Edward Island – Social Assistance (SA) and Disability SupportProgram (DSO); New Brunswick – Transitional Assistance (TA), Transitional Assistance-Single Employable (TA-SE) andExtended Benefits Program (EBP); Quebec - Social Assistance Program and Social Solidarity Program; Ontario – OntarioWorks OW) and Ontario Disability Support Program (ODSP); Manitoba - Employment and Income Assistance (EIA);

Saskatchewan - Saskatchewan Assistance Program (SAP), Transitional Employment Allowance (TEA) and SaskatchewanAssured Income for Disability (SAID); Alberta – Alberta Works (AW) and Assured Income for the Severely Handicapped0.00%

0.05%
0.10%
0.15%
0.20%
0.25%
0.30%
0.35%
0.40%
0.45%
0.50%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure 3: Low-Income USF Programs

(% telecommunications service revenues)
****
USA
Spain
Average over
2001-2014
Period (0.14%)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-1349

Assistance for households living on-reserve,12 (together the social income assistance “SIA”programs), which cover 1.34 million households, or 10% of all households (13.3 million).13This would be a program-based eligibility criteria.

• an income-based eligibility criteria based on a number of possible low-income measuresdefined and measured by Statistics Canada,14 including the after tax Low Income Cut Off(“LICO-AT”), the before tax LICO (“LICO-BT”), the after tax Low Income Measure (“LIM-AT”) or the before tax LIM (”LIM-BT”).

Of the candidates, the SIA program-based eligibility criteria “hits the target” of 10% of eligiblehouseholds. The income-based criteria have higher percentage of eligible households (seebelow) and hence would “over-shoot” the CTSR target. The resulting monthly discount of $11appears reasonable as a monthly discount. Together, these two elements result in a baselineAffordability Funding Mechanism of $70 million per year, equivalent to 0.14% oftelecommunication services revenues over the 2017-2020 period.

2.2.2 Ambitious Affordability Funding Mechanism

I designed the “ambitious” Affordability Funding Mechanisms based on my assessment of the“best in class” jurisdiction amongst the programs in the USA, ****, and Spain. As set out inthe Annex, the combined Federal and State Lifeline programs applicable to eligible householdsin California is the “best in class” in terms of coverage and amount of monthly USF-fundeddiscount. I used my judgement to apply the results to the Canadian context. As above, myprimary criteria for comparison purposes was the comparative size of the respective program.

As set out in Table 1, the combined Federal and California Lifeline has a current program cost of0.82% of telecommunications services revenues. The maximum monthly discount is USD$21.90 (or CAD $22.50)15, and the percentage of eligible households is 24%. The 0.82% is thepercentage of CTSR “target” for the ambitious Affordability Funding Mechanism.

Using a participation rate of 60% (see explanation below) and applying the percentage of eligiblehouseholds (24%) and the maximum monthly discount (CAD $22.50) to projected CTSRs overthe 2017-2020 period results in a slight “over-shooting” of the 0.82% CTSR target. Adjustingthe two multiplicands slightly downwards to “hit the CTSR target” results in a monthly discount(AISH); British Columbia - Temporary Assistance (TA) and Disability Assistance (DA); Yukon – Social Assistance (SA);

****-West Territories - Income Assistance Program (IAP).

12 Aboriginal Affairs and Northern Development Canada, “Income Assistance: Key Facts” (accessed **** 2015) athttps://www.aadnc-aandc.gc.ca/eng/1369766807521/1369766848614.

13 Statistics Canada, “Canadian households in 2011: Type and growth” at https://www12.statcan.gc.ca/census-recensement/2011/as-sa/98-312-x/98-312-x2011003_2-eng.cfm. (Accessed ****, 2015).

14 See Statistics Canada “Low-Income ****, 2012-2013 athttp://www5.statcan.gc.ca/access_acces/alternative_alternatif.action?l=eng&loc=/pub/75f0002m/75f0002m2014003-eng.pdf&teng=Low%20Income%20Lines,%202012-2013&tfra=Les%20lignes%20de%20faible%20revenu,%2012-2013.

15 I used the average of annual exchange rates from OECD (2015) Exchange (indicator) http://dx.doi.org/10.1787/037ed317-en(Accessed July, 2015)) over the 2010-2014 period to convert this USD amount to CAD.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13410

of $22 and a percentage of eligible households of about 20%.

Of the candidate eligibility criteria, the LIM-AT “hits the target” of 20% of eligible households(there are 2.61 million households below the LIM-AT).16 The LIM-AT also has social policysupport precedent in Canada, as it is the income criteria to be used in the OESP (see above). Therevised monthly discount of $22 appears reasonable as a monthly discount. Together, these twoelements result in an ambitious Affordability Funding Mechanism of $410 million per year,equivalent to about 0.82% of telecommunication services revenues.

Note that because the low income measures are substantially above the benefits payable underany of the SIA programs, the ambitious Affordability Funding Mechanism could use a programor income eligibility criteria (in other words, recipients would qualify for the discount if they meteither the SIA program eligibility or income eligibility criteria), and the total number of eligiblehouseholds would not be affected materially from using the income eligibility criteria only. Theadvantage of this income or program eligibility is that the application process for SIA programeligible households would be simplified (they would not have to submit documentation related toincome), and the administration costs of verifying such eligibility would be reduced.

2.3 Beneficiary Eligibility

Baseline Affordability Funding Mechanism. The eligibility criteria is SIA program eligibility.

For 2013-2014 the SIA programs covered 1.34 million households, or 10% of all households inCanada.

Ambitious Affordability Funding Mechanism. The eligibility criteria is either LIM-ATincome or SIA program eligibility. Income eligibility is based on the LIM-AT as defined andupdated by Statistics Canada. For 2012 there were a total of 2.61 million households below theLIM-AT across Canada, or 20% of all households in Canada.

2.4 Administration

Baseline or Ambitious Affordability Funding Mechanism. These types of affordabilityprograms require an administration entity, which would verify beneficiary eligibility, monitoron-going participation, and liaise with service providers. Such administration could be carriedout by the NRA or a third party administrator (“3PA”). Experience from other jurisdictionsshows that a 3PA is the most common approach. The 3PA could be funded by the NCF andcould be the same as the current Central Funds Administrator (“CFA”).

2.5 Eligible Services

Baseline or Ambitious Affordability Funding Mechanism. In principle, anytelecommunications service could be eligible to be subject to the monthly discount, including16 Statistics Canada CANSIM Table 111-0015 “Family characteristics, Low Income Measures (LIM), by family type andfamily type composition” at http://www5.statcan.gc.ca/cansim/a01?lang=eng. (Accessed ****, 2015).

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13411

residential fixed wireline, mobile wireless, or broadband service. As per all other programsreviewed, there would only be one discounted eligible service per eligible household.

2.6 Program Discount

Baseline Affordability Funding Mechanism. The NCF-funded discount is $11 per month.

Ambitious Affordability Funding Mechanism. The NCF-funded discount is $22 per month.

2.7 Eligible Service Providers

Baseline or Ambitious Affordability Funding Mechanism. All service providers designatedby the CRTC would be eligible to receive funds. The CRTC would determine the criteria thatdesignated service providers would have to meet.

2.8 Program Participation and Participation Rate

Baseline Affordability Funding Mechanism. The estimated participation rate of 40% is basedon the current USA Federal program participation rate of 38% (See Table 1), which has thehighest participation rate of the USA, Spain and ****. With a 40% participation rate, 0.53million households would participate (out of 1.34 million eligible households).

Ambitious Affordability Funding Mechanism. Because of the higher benefit amount, theestimated participation rate may be expected to be higher than the baseline Affordability FundingMechanism.17 The estimated participation rate of 60% is based on such a comparison andconsideration of the California Lifeline participation rate of (currently at 68%, with an averageparticipation rate over the previous 12 month period of 49%). With a 60% participation rate,1.57 million households would participate (out of 2.61 million eligible households).

2.9 Program Cost

Baseline Affordability Funding Mechanism. Based on 0.53 million participants at $11 permonth per household, the annual program cost would be $70 million.

Ambitious Affordability Funding Mechanism. Based on 1.57 million participants at $22 permonth per household, the annual program cost would be $410 million.

17 See FCC discussion on this matter on page 18 of “REPORT AND ORDER AND FURTHER NOTICE OF PROPOSEDRULEMAKING (January, 2012) (FCC12-11_ at https://apps.fcc.gov/edocs_public/attachmatch/FCC-12-11A1.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13412

2.10 Summary

The baseline and ambitious Affordability Funding Mechanisms are presented in summary formin Table 1, which also includes a summary of the other programs described in the Annex.

Table 1: Summary of Baseline and Ambitious Affordability Funding Mechanisms in Canadaand Low-Income Programs in Other Jurisdictions

USA
Federal
Spain **** Average:
USA (Fed),
Spain &
****
CANADA
Baseline
Affordability
Funding
Mechanism
California
State
California
Federal
+
State
CANADA
Ambitious
Affordability
Funding
Mechanism
Households (million) 116 18 28 13.3 12.5 12.5 13.3
Beneficiary Eligibility
Program or
Income
Program and
Income
Program
only
Program
only
Program or
Income
Program or
Income
Income or
Program
Eligibility Verification
Eligible
Service
Provider
Designated
USP
Social
Assistance
Administrator
3rd party
administrator
3rd party
administrator
3rd party
administrator
3rd party
administrator
Eligible Services
Residential
fixed or
mobile
telephony
Residential
fixed
telephony
Residential
fixed
telephony
Residential
fixed or
mobile
telephony, or
broadband
Residential
fixed or mobile
telephony
Residential
fixed or mobile
telephony
Residential
fixed or
mobile
telephony, or
broadband
Services per Household 1 1 1 1 1 1 1
Monthly USF-funded
Discount per Service
USD $9.25 ≈€13.32 €5.04 CAD $11.60 CAD $11.00
USD $12.65
wireline; $5.75/
$12.65
wireless
USD $21.90
wireline;
$15.00/ $21.90
wireless
CAD $22.00
Eligible Service Providers
Multiple;
determined by
State PUCs
1 designated
USP
1 designated
USP
Multiple;
determined
by CRTC
Multiple;
determined by
CPUC
Multiple;
determined by
CPUC
Multiple;
determined
by CRTC
Eligible Households (HH)
(million & % of all HH)
32.6m
(28%)
≈0.8m
(≈4%)
2.5m
(9%)
13%
1.34m
(10%)
3.0m
(24%)
3.0m
(24%)
2.61m
(20%)

Actual HH Beneficiaries 12.4m 0.12m 0.33m 2.05m 2.05mProjected HH Beneficiaries 0.53m 1.57m

Participation Rate 38% ≈15% 15% 40% 68% 68% 60%
Program
Cost
(per
year)
Average
(2001-most recent)
USD $1,120m € 45m € 27m
Projections
(2015)
USD $337m USD $565m
Projections
(avg. 2017-20)
CAD $70m CAD $410m
Avg. (% revenues,
2001-most recent)
0.22% 0.13% 0.06% 0.14%
Projections (%
revenues, 2015)
0.49% 0.82%
Projections (%
revenues 2017-2020)
0.14% 0.82%

Source: See Annex for USA, Spain, **** and California. See this Chapter for Affordability Funding Mechanisms.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13413

3 Broadband Deployment Funding Mechanism

This Chapter describes the Broadband Deployment Funding Mechanism. This fundingmechanism is designed to reduce the broadband Internet access services gap and is supplementalto the current residential local wireline service subsidy regime. The Broadband DeploymentFunding Mechanism could begin to be implemented in 2017.

3.1 Overview

In Question 13 of Telecom Notice of Consultation (“TNC”) 2015-134 the Commission asked ifthere is a need to establish a new funding mechanism to support the provision of moderntelecommunications services and stated that any response “should address the mechanismdescribed in Telecom Regulatory Policy 2013-711 for transport services and/or any othermechanism necessary to support modern telecommunications services across Canada.”The following sections describe the new Broadband Deployment Funding Mechanism, whichconstitutes a specific detailed design of a “new funding mechanism to support the provision ofmodern telecommunications services” formulated in Question 13 of TNC 2015-134. Thesections are broadly based on the elements set out in Question 13, as follows:

• Eligible Infrastructure/Services. This refers to the infrastructure and services that areeligible to be funded.

• Eligible Service Providers. This refers to those service providers which are eligible toparticipate in the program and which may receive compensation.

• Funding Amount and Distribution. This refers to the amount of the subsidy providedand the mechanism by which the subsidy is distributed amongst eligible serviceproviders.

• Administration. This discusses whether the national regulatory authority (“NRA”) or athird party administrator could administer the program, including identifying the specificprojects to be undertaken.

• Regulatory and Contractual Conditions. These would be specific regulatory orcontractual conditions and obligations that would be imposed on the service providersreceiving funding from the funding mechanism.

• Program Cost. This refers to the annual costs of the program, expressed as an absoluteamount, and as a percentage of telecommunications service revenues.

3.2 Design of Broadband Deployment Funding MechanismI designed the Broadband Deployment Funding Mechanism based on a composite “DeploymentUSF Model” of minimum-subsidy auction-based universal service-related programs in otherReport prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13414

jurisdictions,18 including as adopted and implemented by the FCC in the USA.19It is important to highlight some of the conceptual similarities and differences between theDeployment USF Model and the current residential local wireline service subsidy regime inCanada. In the Deployment USF Model, the USF contributions may be collected in advance ofand not directly linked to any previously-established universal service-related compensationamount. Separately, the NRA may identify, select, design, cost, and tender specific expansionprojects. The USF contributions allow the NRA to offer a subsidy for each of the specificselected projects. Generally all service providers are eligible to participate in these auctionprocesses. The participating service provider bid proposing the lowest subsidy is selected forthat project. That winning service provider is then required to implement the project and will becompensated with the winning subsidy amount. This model was designed and has generallybeen implemented in the context of the expansion of networks or services. Under this model, an“active” administration is required to identify, select, design, cost, tender, and monitor projects.

Taking into account the objective of reducing the broadband Internet access services gap, theDeployment USF Model has the following advantages relative to simply expanding the currentresidential local wireline service subsidy regime to include broadband:

• Better suited to deployment and expansion of services and network. The DeploymentUSF Model was designed and has generally been implemented in the context of theexpansion of networks or services, rather than the traditional type of wireline service subsidyregime, which was designed and has generally been implemented in the context ofmaintenance of existing services.

• Certainty over amount of contributions. The amount of contributions may be establishedwithout regard to any expected future compensation of universal service-related costs. In thecase at hand, this means that the contribution may be established independently of anydecisions related to obligation to serve, the BSO, or the related estimated costs. This has theadvantage of providing financial certainty related to the contribution amount, regardless ofthe other decisions. From this perspective, the contribution amount may be established withgreater reference to a reasonable contribution burden, rather than established to “pay” for aspecific compensation cost.

• Greater market-orientation. The Deployment USF Model is much more market-orientedthan the traditional current subsidy regime. First, it introduces competition to the provisionof universal service by allowing any interested eligible service provider to participate in theminimum subsidy auction. This could result in innovative proposals and greater competition.

Second, the actual compensation amount is determined as a result of a competitive bidding18 For a general overview see, for example, “Universal Access and Service; Availability, Accessibility and Affordability forUniversal Service,” in particular Section 4.3.2 "Competing for subsidies from Universal Access and Service Funds" andSection 4.7 “Competing for UAS Subsidies” at http://www.ictregulationtoolkit.org/4.7.

19 For example, see FCC’s “REPORT AND ORDER, DECLARATORY RULING, ORDER, MEMORANDUM OPINIONAND ORDER, SEVENTH ORDER ON RECONSIDERATION, AND FURTHER NOTICE OF PROPOSEDRULEMAKING” Adopted: **** 23, 2014 Released: **** 10, 2014 (FCC 14-54), paragraphs 235-250 for a description ofMobility Fund I and II at https://apps.fcc.gov/edocs_public/attachmatch/FCC-14-54A1.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13415

process, rather than the administratively-determined compensation amount. Participatingeligible service providers will be incented to reveal their true cost of providing the services.

This will likely result in efficiency and administrative gains.

• Sequenced and economical deployment. Under the Deployment USF Model, an “active”administration is required to identify, select, design, cost, tender, and monitor projects withthe objective of having a sequenced and economical deployment strategy. An example ofsome elements of this approach was the FCC’s 2012 one-time Mobility Fund process toprovide mobile broadband access to certain locations.20 This was the first universal servicecompetitive bidding process in the USA. The FCC identified the available designated areas,and carriers were invited to bid on one or more areas. Subsidies were awarded based on thelowest subsidy amounts submitted, to at most one service provider in a given area. Subsidieswere awarded based on winning bids in an ascending per road-mile basis until the USD $300million “hard” budget for the Mobility Fund was exhausted. The remaining designated areasthat did not receive bids will be the subject of subsequent processes. The result was that theauction revealed the lowest subsidy areas and the greatest number of areas was able to beserved for a given fixed subsidy amount. Another standard auction approach is for the NRAto identify the specific area to be served and seek subsidy offers only on that area.

Similarly, the possible disadvantages are well known, and mitigating measures may be taken:

• Unsuccessful Auctions. It may be expected that at least some auction processes may beunsuccessful because no service providers participate. A common response to thisoccurrence is to review the terms and conditions of the auction, including the amount of thesubsidy, and retender the revised project.

• Incremental progress. The corollary of having a sequenced deployment strategy is that bydefinition this Deployment USF Model achieves specified objectives incrementally overtime, area by area, rather than in a single instance.

• Risk of no disbursement. Some developing countries that have adopted the DeploymentUSF Model have struggled to implemented an effective deployment strategy and have thusaccumulated USF surpluses because they have not disbursed to projects. This poorperformance is due to poor institutional capacity, governance problems, and other challengesthat generally do not apply to Canada and other industrialized countries.

It is worth pointing out that the Deployment USF Model is similar in some respects to traditionalGovernment funding programs, such as the Government of Canada’s Connecting Canadiansprogram (budget of $305 million).21 **** approaches have a “hard” budget and include amethodology to distribute the funds. However, the Deployment USF Model differs fromtraditional Government programs in a number of ways, including that the funding in theDeployment USF Model is ongoing and predictable, and the amount and allocation of funds is20 Ibid.

21 See http://www.ic.gc.ca/eic/site/028.nsf/eng/00588.html.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13416

based on a minimum subsidy process.
3.3 Eligible Infrastructure/Services

In principle, all types of infrastructure that facilitate the provision of the designated servicesshould be eligible to be funded. The specific infrastructure and services to be funded could bedetermined by the Commission or a third party administrator appointed by the Commission.

3.4 Eligible Service Providers

In principle, all service providers would be eligible to receive funding. The service provider thatactually receives funding would be the winner of a “minimum subsidy” competitive biddingprocess.

3.5 Funding Amount and Distribution

The amount of the funding would be determined by the subsidy requested by the winning bidderof the “minimum subsidy” competitive bidding process. The funding would be distributed to thewinning bidder of a “minimum subsidy” competitive bidding process.

3.6 Administration

The administration of the Broadband Deployment Affordability Funding Mechanism could beundertaken by the Commission or a third party administrator appointed by the Commission(“3PA”). The 3PA could be the same as the current CFA or a different entity.

The administration of the Broadband Deployment Funding Mechanism would be project-oriented (a separate function from the collection and accounting function under the currentCFA). The main project-oriented functions would include, but not be limited to the following:

• Market Assessment. The 3PA should at all times monitor sector developments and beaware of possible future developments to identify current and future gaps, based onwhich it would identify potential projects, thus, as noted in TNC 2015-134, ensuring that“this mechanism should complement, and not replace, other investments from the privatesector and governments, including public-private partnerships.”• Plans, Programs and Strategies. The 3PA should be guided by a series of tools to plan,coordinate, implement, and monitor broadband deployment performance. These toolsmay include a multi-year strategic plan, programs, and other documents.

• Project Identification. The process for identifying priority projects will result in a “longlist” of possible projects to be considered by the 3PA. Projects may be internallygenerated by the 3PA as a result of its own assessment or proposed/suggested by externalparties.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13417

• Project Selection. The 3PA would select projects it wants to undertake from the “longlist” of projects identified. The 3PA could select this "short-list" of projects based on aset of Commission-approved criteria, including project financial sustainability (postsubsidy), market orientation, and contestability.

• Project Design. Once a project has been selected, the 3PA would specify the project insufficient detail that it is implementable and a project contract is enforceable.

• Project Implementation. This final phase involves the 3PA preparing the correspondingrequest for proposals or an equivalent bid document, holding the bidding process,awarding the Contract, and disbursing funds consistent with the Contractor complyingwith contractual milestones. Bids should be evaluated according to the procedures andindicators established in the bid document. Based on evaluation results, a Contractshould be finalized with the selected Bidder. Once the Contact has been signed, the 3PAcan begin to monitor the progress of the Contractor to ensure that all the correspondingobligations and milestones are met. Disbursements of the agreed-upon financing willgenerally be made on the completion of the contract milestones.

3.7 Regulatory and Contractual Conditions

The infrastructure and service funded under the Broadband Deployment Funding Mechanismwould be subject to standard commercial provisions related to the payment of the subsidyamount, pursuant to the project contract.

In addition to these provisions, if appropriate and technically feasible, project-specific regulatoryconditions may also be included. These could include, for instance, that the infrastructure to befunded should be made available on a wholesale basis, or that any telecommunications servicethat is subsidized be subject to a maximum retail rate. The specific regulatory conditions wouldbe proposed by the 3PA on the particular project to be funded, subject to approval by the CTRC.

3.8 Program Cost

I designed the Broadband Deployment Funding Mechanism based on my assessment of thecomparative “average” of the programs in the USA and Australia. I used my judgement to applythe results to the Canadian context.

My primary criteria for comparison purposes was the comparative size of the respectiveprograms. I then reviewed the results of these factors and undertook an iterative process toadjust the results of this funding mechanism to take into account the overall program costs(including the Affordability Funding Mechanism). In this respect, I consider as reasonabletargets 0.74% of CTSR for the overall program costs (with the baseline Affordability FundingMechanism) and 1.42% of CTSR with the ambitious Affordability Funding Mechanism, giventhe differing objectives of the two versions of the Affordability Funding Mechanism (seeChapter 4 for explanation).

For purposes of this section, I consider the Broadband Deployment Funding Mechanism and theReport prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13418

current residential local wireline service subsidy regime to be two elements of an overallgeographic-based high-cost funding mechanism. I begin by calculating the program costs of theoverall area-based high-cost mechanism, from which I subtract the capped program cost of $80million per year of the current residential local wireline service subsidy regime to calculate theprogram cost of the Broadband Deployment Funding Mechanism.

For comparative purposes to estimate the high-cost program costs, I reviewed the high-costprograms in the USA22 and Australia.23 As set out in Figure 4, over the 2001-2014 period, theHigh-Cost program of the Federal USF in the USA averaged 0.79% of telecommunicationsservices revenues,24 while that in Australia averaged 0.47%.25 The period average of these twocountries was 0.63% of telecommunications services revenues, as presented in Figure 4. The0.63% is the percentage of CTSR “target” for the Broadband Deployment Funding Mechanism.

Applying this going-in target to projected CTSRs over the 2017-2020 period results in programcosts of about $315 million per year. This figure compares to the NCF average of $258 millionover the 2001-2014 period. However, taking into account that the baseline and ambitiousAffordability Funding Mechanisms are at 0.14% and 0.82% of CTSR, the 0.63% results in aslight “over-shooting” of the 0.74% and 1.42% of CTSR targets for the overall program cost.

Based on the above, therefore, I adjust the program cost for the overall geographic-based high-cost funding mechanisms to 0.60% of CTSR over the 2017-2020 period, equal to $300 millionper year. Subtracting the capped program cost of $80 million per year of the current subsidyregime leaves the difference of $220 million per year as the program cost for the BroadbandDeployment Funding Mechanism over the 2017-2020 period.

22 For 2001-2013, see “High-Cost Support” in Table 1.10 “Universal Service Disbursements 2001-2013” in FCC’s “UniversalService Monitoring Report” at https://apps.fcc.gov/edocs_public/attachmatch/DOC-330829A1.pdf. For 2014, see “High-Cost” on page 45 of the Universal Service Administrative Company (“USAC”) “2014 Annual Report: Moving ****” athttp://www.usac.org/_res/documents/about/pdf/annual-reports/usac-annual-report-2014.pdf.

23 For 2002-2004, see “Universal Service Subsidies (2001-02, 2002-03, 2003-04 Default Area) Determination (No. 1) 2001” athttps://www.comlaw.gov.au/Details/F2004B00472. For 2005, see “Universal service subsidies for 2005-06 to 2007-08 -PROPOSAL PAPER” (November 2004) at

http://www.acma.gov.au/webwr/telcomm/universal_service_regime/universal_service_obligation/costing_funding/subsidies_proposal_2005_2008.pdf. For 2006-2008, see “Universal Service Subsidies (2005-06, 2006-07, 2007-08 Default Area)Determination (No. 1) 2005” at https://www.comlaw.gov.au/Details/F2005L01828. For 2009-2012, see “Funding the USO”page from ACMA (the Australian NRA) at http://archive.acma.gov.au/WEB/STANDARD/pc=PC_2483.

24 “Telecommunications Revenue” for 2001-2011 from “OECD Communications Outlook 2013,” page 76http://dx.doi.org/10.1787/888932801014 (Accessed ****, 2015). Telecommunications service revenues for 2012extrapolated from 2011 national currency estimate using 2011 to 2012 growth rates of “Revenue from all telecommunicationservices” in USD from “World Telecommunication/ICT Indicators database 2014 (18th Edition, December, 2014), ITU(2014) http://www.itu.int/en/ITU-D/Statistics/Pages/publications/wtid.aspx (Subscription accessed ****, 2015).

Telecommunications service revenues for 2013-2014 extrapolated from 2012 using cumulative average growth rate(“CAGR”) of “Telecommunications Revenue” from above over the 2001-2011 period (calculated at 2.3%).

25 “Telecommunications Revenue” for 2001-2011 from “OECD Communications Outlook 2013” page 76http://dx.doi.org/10.1787/888932801014 (Accessed ****, 2015), converted to national currency using exchange rates fromOECD (2015) Exchange (indicator) http://dx.doi.org/10.1787/037ed317-en (Accessed July, 2015). Telecommunicationsservice revenues for 2012-2013 extrapolated from 2011 national currency estimate, using 2011 to 2012 and 2012 to 2013growth rates of “Revenue from all telecommunication services” in national currency from “World Telecommunication/ICTIndicators database 2014 (18th Edition, December, 2014), ITU (2014) http://www.itu.int/en/ITU-D/Statistics/Pages/publications/wtid.aspx (Subscription accessed ****, 2015).

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13419

0.0%
0.1%
0.2%
0.3%
0.4%
0.5%
0.6%
0.7%
0.8%
0.9%
1.0%
1.1%
1.2%
1.3%
1.4%
1.5%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure 4: High-Cost USF Programs

(% telecommunications services revenues)
USA
Australia
Average over
2001-2014
Period (0.63%)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13420

4 Contribution Mechanism (NCF)

The Affordability Funding Mechanism and the Broadband Deployment Funding Mechanism aresupplemental to the current residential local wireline service subsidy regime and would thereforebe financed by an increase in contributions to the NCF. This Chapter also describes how thecontribution regime could be expanded to include some currently-exempted services, therebybroadening the contribution-eligible “revenue base”.

4.1 Cost of New Funding Mechanisms

Figures 5 and 6 show the projected cost to 2020 of adopting from 2017 the Affordability FundingMechanism and the Broadband Deployment Funding Mechanism.26 Figure 5 shows the baselineversion of the Affordability Funding Mechanism while Figure 6 shows the ambitious version.

Each of these figures provides a breakdown of the costs over the 2017-2020 period of theexisting subsidy regime and the two new funding mechanisms: the current residential localwireline service subsidy regime (capped at $80 million), the Broadband Deployment FundingMechanism (capped at $220 million), and the baseline or ambitious version of the AffordableFunding Mechanism (capped at $70 million or $410 million respectively), resulting in a totalcost of either $370 or $710 million per year over the 2017-2020 period.

26 For 2001-2014, see “Total Contribution” from “Central Funds Administration: Quarterly Report)http://www.crtc.gc.ca/eng/cfund-fondc.htm (Accessed ****, 2015). Projections for 2015-2016 are based on a simplestatistical trendline (Y = 4702.7X-1.422) fitted over the 2009-2014 period and extrapolated from 2014 to 2020. Projections for2017-2020 include the existing subsidy regime and the two new funding mechanisms.

$0
$100
$200
$300
$400
$500
$600
$700
$800
$900
$1,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 5: NCF projections - with

Baseline Affordability Funding Mechanism
(CAD $000,000)
NEW
"Baseline"
Affordability
Funding
Mechanism
Existing Subsidy Regime
NEW
Broadband
Deployment
Funding
Mechanism

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13421

By way of comparison, Figure 7 shows the NCF and the USA USF,27 expressed as a percentageof telecommunications service revenues over the 2001-2014 period and projections for the NCFto 2020. Figure 7 also includes the respective averages of the NCF and the USA USF over the2001-2014 period (0.74 and 1.42%, respectively).

27 For 2001-2013, see “Total” in Table 1.10 “Universal Service Disbursements 2001-2013” in FCC’s “Universal ServiceMonitoring Report” at https://apps.fcc.gov/edocs_public/attachmatch/DOC-330829A1.pdf. For 2014, see page 45 of theUniversal Service Administrative Company (“USAC”) “2014 Annual Report: Moving ****” athttp://www.usac.org/_res/documents/about/pdf/annual-reports/usac-annual-report-2014.pdf.

$0
$100
$200
$300
$400
$500
$600
$700
$800
$900
$1,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 6: NCF projections - with

Ambitious Affordability Funding Mechanism
(CAD $000,000)
Existing Subsidy Regime
NEW
Broadband
Deployment
Funding
Mechanism
NEW
"Ambitious"
Affordability
Funding
Mechanism
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 7: USA Federal USF and NCF - Projections

(% telecommnuications service revenues)
USA Federal USF
Total NCF
(with "ambitious"
Affordability
Funding
Mechanism)
Total NCF (with
"baseline"
Affordability
Funding
Mechanism)Average of USA
USF over 2001-
2014 period
(1.42%)
Canada NCF
Average of Canada
NCF over 2001-2014
period (0.74%)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13422

Figure 7 shows that overall program costs over the 2017-2020 period with the baselineAffordability Funding Mechanism average 0.74% of projected CTSRs, while the overallprogram costs with the ambitious Affordability Funding Mechanism average 1.42% of projectedCTSRs. The former is the same as the NCF 2001-2014 average (0.74% of CTSRs), while thelatter is the same as the USA USF 2001-2014 average (1.42% of telecommunications servicerevenues). Hence, Figure 7 confirms that the overall program costs are consistent with thepercentage of telecommunications service revenues targets I consider as reasonable, given thediffering objectives of the two versions of the Affordability Funding Mechanism.

4.2 Contribution Mechanism

Having determined the program cost, this section relates to reviewing the current contributionmechanism. The NCF is funded by a “contribution rate” (percent) of Contribution EligibleRevenues (“CERs”). Figure 8 shows CERs and CTSRs28 from 2001 to 2014. Figure 9 showsthat the CER/CTSR ratio averaged 62% over the entire period, but has declined to a low of 49%in 2014.

Figure 9 shows that the contribution-eligible “revenue base” will continue to decline as Internet,and, to a lesser extent, paging service revenues continue to increase.29 With the objective ofensuring that the contribution contribution-eligible “revenue base” is “broad and sustainable,”Internet and paging service revenues could be included as CERs starting 2017. This would28 ”Canadian Telecommunications Services Revenue” and “Contribution Eligible Revenues” from “Central FundsAdministration: Quarterly Report” http://www.crtc.gc.ca/eng/cfund-fondc.htm (Accessed ****, 2015).

29 Internet retail service revenues increased from 22% of CTSR in 2011 to 32% in 2014, based on CRTC Letter of July 2. 2015re “Disclosure of certain information from the Data Collection System (DCS)” CRTC reference 8663-C12-201503186 athttp://www.crtc.gc.ca/eng/archive/2015/lt150702a.htm.

$0
$10,000
$20,000
$30,000
$40,000
$50,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure 8: Telecommunications Service Revenues and

Contribution-Eligible Revenues
(CAD $000,000)
Canadian Telecommunications
Services Revenues
Contribution-Eligible
Revenues

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13423

increase the CER/CTSR ratio to a range of about 80% in the 2017-2020 period30, as set out inFigure 10.

30 “Expanded” CERs for 2015-2020 are estimated as follows: Projected “As Is” CERs extrapolated from 2014 usingcumulative average growth rate (“CAGR”) of CERs over the 2009-2014 period (calculated at -3.3%), to which I addedprojected “Retail Internet Service Revenues” and “Retail Paging Service Revenues” for 2015-2010. Retail Internet ServiceRevenues are extrapolated from 2014 using the average year-over-year change in the ratio of Retail Internet ServiceRevenues to CTSR over the 2011-2014 period and then applying the resultant ratios for 2015-2020 to projected CTSRs tocalculate projected Retail Internet Service Revenues. Retail Paging Service Revenues are extrapolated from 2014 using thecumulative average growth rate (“CAGR”) of “Retail Paging Service Canadian” over the 20011-2014 period (calculated at5.0%).

0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure 9: Contribution Eligible Revenues as % of

Telecommunications Service Revenues
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 10: Contribution Eligible Revenues as % of

Canadian Telecommunications Service Revenues -
Projections

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13424

Figure 11 shows the “contribution rate” (NCF as a percent of CERs) over the 2001-2014 period(average of 1.13%) and, based on the above-noted expansion of the contribution-eligible“revenue base,” the contribution rate that would be required to fund total program costs over the2017-2020 period under each of the two scenarios (averaging 0.92% and 1.77%, correspondingto the capped $370 million and $710 million per year, respectively).

0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
3.5%
4.0%
4.5%
5.0%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020Figure 11: NCF Contribution Rate - Projections

(% of "Expanded" Contribution Eligible Revenues for 2017-2020)Average of NCF

Contribution Rate
over 2001-2014
period (1.13%)
Total NCF
(with
"baseline"
Affordability
Funding
Mechanism)
Total NCF
(with "ambitious"
Affordability
Funding
Mechanism)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13425

Annex: Low-Income Programs in other Jurisdictions

This Annex includes a description of programs to promote the affordability oftelecommunications for low-income households in the USA (Federal program), California(combined Federal and State programs), ****, and Spain. Each program is presented based onthe seven elements included in Chapter 2.

USA - Federal Lifeline

The FCC’s Lifeline program provides USF funding to compensate designated eligibletelecommunications carriers (“ETC”) for providing discounted services to eligible low-incomebeneficiaries. Lifeline was originally applicable only to residential fixed telephonesubscriptions, until 2012, when it was expanded to include wireless telephony services. TheFCC recently issued a Further Notice of Proposed Rule-Making (“FNPRM”) that would, ifadopted, further expand the program to include broadband access.31 The Lifeline program is oneof four major programs administered by the Federal USF, the others being the High-CostProgram (now the Connect America Fund), the Schools and Libraries Program, and the RuralHealth Program.

Beneficiary Eligibility

Potential beneficiaries must meet program OR income criteria. In 2012, the FCC amended itsrules so that all States must, at a minimum, use a uniform set of baseline eligibility criteria32. Ontop of these baseline criteria, individual States may adopt additional program or income criteriato address specific State circumstances.

Administration

Potential beneficiaries are required to submit an application form to receive the Lifeline discount.

The application procedures vary by State, depending on State-specific administrationarrangements. ETCs can use one of three methods to verify eligibility: a) If available, ETCs canaccess state or federal social services eligibility databases to determine an applicant’s eligibility;

b) If a state agency or administrator determines a consumer's eligibility, ETCs may rely on thedetermination of the agency or administrator; or c) if an ETC has no access to an eligibilitydatabase and the ETC, rather than a state agency or administrator, is responsible for establishing31 See SECOND FURTHER NOTICE OF PROPOSED RULEMAKING, ORDER ON RECONSIDERATION, SECONDREPORT AND ORDER, AND MEMORANDUM OPINION AND ORDER (FCC 15-71) (June, 2015) athttp://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0622/FCC-15-71A1.pdf.

32 The uniform baseline eligibility criteria are the following: a) beneficiaries must show that they are in receipt of one or moreof the following federal social assistance programs: Medicaid; Supplemental Nutrition Assistance Program (SNAP),formerly known as Food Stamps; Supplemental Security Income (SSI); Federal Public Housing Assistance; Low-Income**** Energy Assistance Program (LIHEAP); National School Lunch Program’s free lunch program; and TemporaryAssistance for Needy Families (TANF). Low-income consumers living on Tribal lands may also qualify by participation inone of several additional assistance programs: **** of Indian Affairs general assistance; Tribally-administered TANF; or**** Start (only those meeting its income-qualifying standards), OR b) beneficiaries must show that they have an annualfamily income below 135% of federal poverty guideline. REPORT AND ORDER AND FURTHER NOTICE OFPROPOSED RULEMAKING (January, 2012) at https://apps.fcc.gov/edocs_public/attachmatch/FCC-12-11A1.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13426

consumer eligibility, ETCs must review documentation to determine eligibility for newsubscribers.33

Eligible Services

The Lifeline discount may be applied to only one telephone service from one ETC per eligiblehousehold. The telephone service maybe either a residential fixed telephone service or a mobiletelephone. The recent FNPRM would, if adopted, further expand the program to includebroadband access.

Program Discount

The applicable USF-funded discount per household is USD $9.25 per month.

Eligible Service Providers

Only designated eligible telecommunications carriers (ETC) are eligible to receive compensationfrom the federal USF Lifeline program. Generally, it is the State utility regulatory commissionsthat are responsible for the designation of ETCs in their respective states, and service providersmust apply to be designated an ETC with them. If the State commission does not have ETCjurisdiction, then an interested service provider may petition the FCC directly.

Program Participation and Participation Rate

There were 12.4 million Lifeline subscribers at the end of 2014.34 In 2012, the FCC estimatedthat there would be approximately 32.6 million eligible subscribers over the 2012-2014 period;35therefore the national participation rate at the end of 2014 was approximately 38%. The eligiblehouseholds made up 28% of the 116 million households in the USA.36Program Cost

Program costs over the 2001 to 2014 period are presented in Figure A1 and averaged USD$1,120 million over this period.37 Figure A2 shows program costs as a percentage oftelecommunications services revenues, which averaged 0.22% over the period.

33 See http://usac.org/li/telecom-carriers/step06/default.aspx.

34 See page 9 of the Universal Service Administrative Company (“USAC”) “2014 Annual Report: Moving ****” athttp://www.usac.org/_res/documents/about/pdf/annual-reports/usac-annual-report-2014.pdf.

35 See page 153 of the FCC’s “REPORT AND ORDER AND FURTHER NOTICE OF PROPOSED RULEMAKING” (FCC12-11) (January, 2012) at https://apps.fcc.gov/edocs_public/attachmatch/FCC-12-11A1.pdf.

36 See http://quickfacts.census.gov/qfd/states/00000.html.

37 For 2001-2013, see “Low-Income Cost Support” in Table 1.10 “Universal Service Disbursements 2001-2013” in FCC’s“Universal Service Monitoring Report” at https://apps.fcc.gov/edocs_public/attachmatch/DOC-330829A1.pdf. For 2014,see “Low-Income” on page 45 of the Universal Service Administrative Company (“USAC”) “2014 Annual Report: Moving****” at http://www.usac.org/_res/documents/about/pdf/annual-reports/usac-annual-report-2014.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13427

USA - California Lifeline

States in the USA may supplement the Federal Lifeline Program with their own State LifelinePrograms financed by State-level universal service funds. In 2014 a total of 17 States had State-level Lifeline programs, which totalled USD $199 million.3838 See “State Universal Service Funds 2014” by **** Lichtenberg, National Regulatory Research Institute (“NRRI”) ReportNo. 15–05 (June 2015) at http://nrri.org/download/nrri-15-05-state-usf/ (Accessed ****, 2015). This publication alsohighlights that most State USFs also fund other State-level programs, including High-Cost support programs, Schools andLibraries programs, etc.

$0
$500
$1,000
$1,500
$2,000
$2,500

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A1: USA Federal USF Low-Income Program

(USD $000,000)
Average over 2001-
2014 period
0.0%
0.1%
0.2%
0.3%
0.4%
0.5%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A2: USA Federal USF Low-Income Program

(% telecommunications service revenues)
Average over 2001-
2014 period (0.22%)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13428

California has the largest State Lifeline program. The California Lifeline Program isimplemented under the California Public Utility Commission (“CPUC”), which compensatesdesignated ETCs from funds collected via the State-administered Universal Lifeline TelephoneService (“ULTS”) surcharge on end-users’ intra-state telephone bills. The California Lifelinewas originally applicable only to residential fixed telephone subscriptions, until **** 2014,when it was expanded to include wireless telephony services.39 To take into account theexpected corresponding increase in program costs, the ULTS surcharge was increased from1.15% to 2.40% in January 2015.40

Beneficiary Eligibility

California uses the uniform baseline eligibility program OR income criteria established by theFCC for the Federal Lifeline program, except in two respects. First, it adds California-specificprograms, including “MediCal” and the “Women, Infants and Children Program (WIC)”program administered by the USDA to the list of eligible programs. Second, it raises the incomecut-off to 150% of the federal poverty guideline (rather than the 135% figure used by the FederalProgram).41

Administration

Potential beneficiaries are required to submit an application form to the “California LifelineThird Party Administrator,” which is responsible for verifying eligibility.42Eligible Services

The Lifeline discount may be applied to only one telephone service from one ETC per eligiblehousehold. The telephone service may be either a residential fixed telephone service or a mobiletelephone.

Program Discount43

All service providers that offer wireline service in California are required to offer a designatedLifeline service. The CPUC provides a maximum USD $12.65 per line subsidy payment forthese wireline services. Further, the California Third Party administrator also applies the FederalLifeline maximum discount of USD $9.25 per month to federal and State universal servicesurcharges (for example such as the Federal Subscriber Line Charge currently at USD $6.50), inthis manner “combining” the California and Federal wireline discounts, so that eligible recipients39 See CPUC Decision 14-01-036 “DECISION ADOPTING REVISIONS TO MODERNIZE AND EXPAND THECALIFORNIA LIFELINE PROGRAM” (January 16, 2014) at http://www.cpuc.ca.gov/NR/rdonlyres/3AF6F731-5B5A-45F8-AADD-163EAA5E1284/0/DecisionAdoptingRevisionstoModernizeandExpandtheCaliforniaLifelineProgram.pdf.

40 See CPUC Resolution T-17460 “Approval of the California LifeLine Program Surcharge Rate of 2.40%, Effective January1, 2015.” (December, 2014) at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M143/K313/143313864.PDF.

41 See CPUC “California LifeLine Program page at http://www.cpuc.ca.gov/PUC/Telco/Public+Programs/ults.htm.

42 See CPUC “California LifeLine (detail) page at http://www.cpuc.ca.gov/PUC/Telco/Public+Programs/lifelinedetails.htm.

43 See CPUC Decision 14-01-036 “DECISION ADOPTING REVISIONS TO MODERNIZE AND EXPAND THECALIFORNIA LIFELINE PROGRAM” (January 16, 2014) at http://www.cpuc.ca.gov/NR/rdonlyres/3AF6F731-5B5A-45F8-AADD-163EAA5E1284/0/DecisionAdoptingRevisionstoModernizeandExpandtheCaliforniaLifelineProgram.pdf.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13429

receive a total discount of USD $21.90.

Service providers that offer wireless services may offer a Lifeline-eligible wireless service. TheCPUC has established a series of conditions, such as a minimum number of minutes on wirelessplans which are eligible for Lifeline discounts. Plans that include 500 to 1000 minutes areeligible for a USD $5.75 Lifeline payment subsidy, while those that offer more than 1000minutes are eligible for a USD $12.65 per line subsidy payment. These subsidy payments aregenerally supplemental to the Federal Lifeline (if the providers and services meet conditions forboth plans). Therefore, eligible recipients may receive a total discount of USD $15.00 and USD$21.90 for wireless plans that include 500-1000 minutes and more than 1000 minutes,respectively.

Eligible Service Providers

Only designated eligible telecommunications carriers are eligible to receive compensation fromthe California Lifeline program. The CPUC is responsible for the designation of ETCs.

Program Participation and Participation Rate

For May 2015, the California Lifeline program supported 0.74 million wireline and 1.31 millionwireless subscribers, for a total of 2.05 million.44 In early 2015, the CPUC estimated that therewere would be approximately 3.0 million eligible Lifeline subscribers; 45 therefore the May 2015participation rate was 68%, while the average participation rate over the previous 12 monthperiod was 49%. The eligible households made up 24% of the 12.5 million households inCalifornia.46

Program Cost

Based on an increase of the ULTS starting January 1, 2015 to take into account program changesadopted in 2014 (the addition of wireless telephony), program costs have increased to about USD$337 million for 2015.47 As a percentage of projected 2015 California telecommunicationsservices revenues,48 program costs will be about 0.49% for 2015.

44 See “Third Party Administrator LifeLine Customer Counts” link in the CPUC page “LifeLine Related Forms and NoticesFor Carriers” http://www.cpuc.ca.gov/PUC/Templates/Default.aspx?NRMODE=Published&NRNODEGUID={794440F3-F0DC-4A29-8AB1-

99ED492A14CE}&NRORIGINALURL=%2FPUC%2FTelco%2FPublic%2BPrograms%2FFormNotices_Public%2BProgram.htm&NRCACHEHINT=Guest. (Accessed ****, 2015).

45 See State of California Budget Change Proposal “Increase Appropriation to Ensure Adequate Funding for Lifeline Servicesin **** of Increased Wireless Subscribers” (January 2015) at http://www.cpuc.ca.gov/NR/rdonlyres/7FBA0C56-0D99-4C66-8A3E-A202D396CBA6/0/BCP_7_Lifelinefinal.pdf.

46 See http://www.census.gov/quickfacts/table/PST045214/00,06.

47 See CPUC Resolution T-17460 “Approval of the California LifeLine Program Surcharge Rate of 2.40%, Effective January1, 2015” (December, 2014) at http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M143/K313/143313864.PDF.

48 To calculate Telecommunications Services Revenue for California in a comparable manner to the other jurisdictions, Iapplied the percentage (11.74%) of End User Telecommunications Revenue by State: 2011 table 1.8 in the FCC’s“Universal Service Monitoring Report” at https://apps.fcc.gov/edocs_public/attachmatch/DOC-330829A1.pdf. In thismanner, the projected Telecommunications Services Revenue for California is estimated at USD $68.8 billion.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13430

Combined Federal and California Lifeline

Based on the subscription numbers above, the Federal Lifeline costs in California may beestimated to be $9.25 × 2.05 million × 12 months = $228 million for 2015, or equivalent to0.33% of projected California telecommunications services revenues for 2015. When added tothe California Lifeline costs of $337 million for 2015, the total combined costs of Federal andCalifornia Lifeline in California in 2015 are $565 million, or about 0.82% of projected Californiatelecommunications services revenues.

Spain

As a Member-State of the European Union, Spain’s universal service regime is subject toEuropean Commission norms - and in particular the Universal Service Directive (“USD”) of2002.49 The USD sets out the services that may be funded by a service provider-funded USF, thedesignation of universal service provider(s) (“USP”), the approach and methodology to be usedfor the calculation of any USF compensation, and other matters.

Approved USF data are available up to 2011. Over the 2001-2011 period the universal serviceregime has included three different programs: “uneconomic services” (i.e. discounts to low-income subscribers), “uneconomic areas” (i.e. service to high-cost areas), and directory services.

Spain’s USF-financed program that provides discounts to low income subscribers is called“Abono Social” (“Social Tariff”).

Beneficiary Eligibility

Potential beneficiaries must meet program AND income criteria: a) beneficiaries must show thatthey are in receipt of any social assistance program that provides income support in the form of a“pension” (and therefore are referred to as a “pensionista”),50 and b) beneficiaries must showthat they have an annual family income below 120% of the IPREM, a Government-establishedincome measure.51

Administration

Potential beneficiaries are required to submit application forms directly to Telefonica de España,the designated USP, to receive the “Abono Social.” Telefonica is responsible for verifying49 Directive 2002/22/EC of the European Parliament and of the Council of 7 **** 2002 on universal service and users' rightsrelating to electronic communications networks and services (Universal Service Directive) http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32002L0022

50 See Presidential Order PRE/531/2007 “Acuerdo de la Comisión Delegada del Gobierno para Asuntos Económicos(CDGAE) por el que se aprueban las condiciones para garantizar la asequibilidad de las ofertas aplicables a los serviciosincluidos en el servicio universal” http://www.boe.es/boe/dias/2007/03/10/pdfs/A10354-10356.pdf51 The IPREM is a Government-established income indicator used to determine eligibility for social assistance and othermatters. The threshold of 120% was set by Presidential Order PRE/1619/2010 “Acuerdo de la Comisión Delegada delGobierno para Asuntos Económicos de 13 de mayo de 2010, por el que se modifica el umbral de renta familiar que daacceso al abono social” BOE-A-2010-9718.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13431

eligibility.52
Eligible Services

The “Abono Social” is only applicable to one residential telephony service at a fixed location perhousehold.

Program Discount

The USF compensates Telefonica approximately €13.32 per “Abono Social” per month.53Eligible Service Providers

Only Telefonica de España, the designated USP, is eligible to receive compensation from theUSF for providing the “Abono Social”.

Program Participation and Participation Rate54

In 2010, the average number of telephone lines that were the subject of the “Abono Social” was116,374.55

Program Cost

Program costs over the 2001 to 2011 period are presented in Figure A3 and averaged €45 millionover this period.56 Figure A4 shows the program costs as a percentage of total52 See http://www.movistar.es/particulares/atencion-cliente/telefonia-en-casa/lineas/ficha-ayuda/abono-social (Accessed ****,2015)

53 Note that the beneficiary receives a discount of €18.05 per month, based on a percentage discount of 95% (see PresidentialOrder PRE/531/2007 “Acuerdo de la Comisión Delegada del Gobierno para Asuntos Económicos (CDGAE) por el que seaprueban las condiciones para garantizar la asequibilidad de las ofertas aplicables a los servicios incluidos en el serviciouniversal” http://www.boe.es/boe/dias/2007/03/10/pdfs/A10354-10356.pdf) as applied to the lowest basic monthlysubscription of €19.00 per month (see USP web-site: http://www.movistar.es/particulares/fijo/ (Accessed **** 2015)). As inthe case of **** (see below), the USF appears to compensate Telefonica only for a portion of this beneficiary discount. Iwas able to calculate this amount implicitly for 2010 based on the total program costs of €18.6 million ÷ number ofbeneficiaries (116,374) ÷ 12 months = €13.32. In this context, Telefonica is not compensated directly for the residual of€4.73 (€18.05 - €13.32) per month.

54 I was unable to find any publicly-available data on the participation rate or the total number of eligible households. Itherefore assumed that the participation rate was the same as that of **** (15%). Based on this, I was also able to estimatethe total number of participating households at 116,374 ÷ 15% = 775,826, or equivalent to 4% of all households in Spain (18million) (see http://www.ine.es/en/prensa/np837_en.pdf).

55 See page 11 of CMT Resolution AEM 2012/1946 “Informe relativo a la determinación del coste neto del servicio universalpresentado por Telefónica de España, S.A.U. por el ejercicio 2010” at http://www.cnmc.es/es-es/telecomunicacionesysaudiovisuales/resolucionestelecomunicacionesyaudiovisuales.aspx.

56 For year 2001, see page 2 of CNMC Resolution SU/DTSA/765/13 EJECUCIÓN CNSU 2001 “RESOLUCIÓN SOBRE ELPROCEDIMIENTO EN EJECUCIÓN DE SENTENCIA SOBRE LA DETERMINACIÓN DEL COSTE NETO DEPRESTACIÓN DEL SERVICIO UNIVERSAL EN EL AÑO 2001 PROPUESTO POR TELEFÓNICA DE ESPAÑA,S.A.U. For year 2002, see page 2 of CNMC Resolution SU/DTSA/766/13 EJECUCIÓN CNSU 2002s “RESOLUCIÓNSOBRE EL PROCEDIMIENTO EN EJECUCIÓN DE SENTENCIA SOBRE LA DETERMINACIÓN DEL COSTE NETODE PRESTACIÓN DEL SERVICIO UNIVERSAL EN EL AÑO 2002 PROPUESTO POR TELEFÓNICA DE ESPAÑA,S.A.U.” For years 2003-2011, see page 6 of CNMC Resolution SU/DTSA/989/14/CNSU 2012 TTP “SOBRE LAVERIFICACIÓN DE LOS DATOS RELATIVOS A LA DECLARACIÓN DE COSTE NETO DEL SERVICIOUNIVERSAL REALIZADA POR TELEFÓNICA TELECOMUNICACIONES PÚBLICAS, S.A.U. PARA EL EJERCICIO2012” at http://www.cnmc.es/es-es/telecomunicacionesysaudiovisuales/resolucionestelecomunicacionesyaudiovisuales.aspx.

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13432

telecommunications services revenues,57 with an average 0.13% over the period.

57 Telecommunications service revenues for 2001-2011 from “OECD Communications Outlook 2013” page 76, available athttp://dx.doi.org/10.1787/888932801014 (Accessed ****, 2015), converted to national currency using exchange rates fromOECD (2015) Exchange (indicator) http://dx.doi.org/10.1787/037ed317-en (Accessed July, 2015).

€0
€10
€20
€30
€40
€50
€60
€70
€80

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A3: Spain USF Low-Income Program

(€ 000,000)
Average over 2001-
2011 period
0.00%
0.05%
0.10%
0.15%
0.20%
0.25%
0.30%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A4: Spain Low-Income USF Program

(% telecommunications services revenues)
Average over 2001-
2011 period (0.13%)

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13433

****

As a Member-State of the European Union, ****’s universal service regime is subject toEuropean Commission norms and in particular the Universal Service Directive.

Approved USF data are available up 2013. Over the 2001-2013 period, the universal serviceregime has included four different programs: “social tariffs” (i.e. discounts to low-incomesubscribers), “geographic averaging” (i.e. service to high-cost areas), public payphones, anddirectory services. ****’s USF-financed program that provides discounts to low incomesubscribers is called “Abonnement Social” or “Tarifs Sociaux” (“Social Tariff”).

Beneficiary Eligibility

Potential beneficiaries must meet program criteria ONLY: beneficiaries must show that they arerecipients of any one of three main social assistance programs (“le revenu de solidarité active(RSA)”, “l'allocation de solidarité spécifique (ASS),” or “l'allocation aux adultes handicapés(AAH)”), or are a disabled war veteran.58

Administration

The social assistance Government institutions that administer the relevant eligible programs(RSA, ASS and AAH) notify all program recipients of the availability of the “AbonnementSocial” and provide the corresponding application forms that must be submitted (to the sameinstitutions) to receive the “Abonnement Social.”59Eligible Services

The “Abonnement Social” is only applicable to one residential telephony service at a fixedlocation per household.

Program Discount

The USF compensates **** Telecom €5.04 per “Abonnement Social” per month.60Eligible Service Providers

Only **** Telecom, the designated USP, is eligible to receive compensation from the USF forproviding the “Abonnement Social.”

58 See “les tarifs sociaux” page on ARCEP (France’s NRA) web-site: http://www.arcep.fr/index.php?id=10308 (Accessed**** 2015).

59 See USP web-site: http://boutique.orange.fr/ESHOP_mx_ft/?tp=F&ref=3610&IDCible=&donnee_appel=&id=&type=3(Accessed ****, 2015).

60 The “Abonnement Social” is priced at €6.49 (€10.47 below the corresponding “standard” price of €16.96). The USFcompensates **** Telecom for €5.04. **** Telecom is not compensated directly by the USF for the residual of €5.43(€10.47 - €5.04) per month (see page 10 of Autorité de la Concurrence « Avis n° 11-A-10 du 29 juin 2011 portant sur lamise en place d’un tarif social permettant l’accès des personnes aux revenus modestes aux services Internet haut débit » athttp://www.autoritedelaconcurrence.fr/user/avisdec.php?numero=11A10. , as updated in the «les tarifs sociaux” page onARCEP web-site: http://www.arcep.fr/index.php?id=10308).

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13434

Program Participation and Participation Rate

At year-end 2010, the number of “Abonnement Social” telephone lines was 328,209.61 Theparticipation rate was 15% for 2010, from an estimated total of about 2.5 million potentialbeneficiaries.62 The eligible households made up 9% of the 28 million households in ****.63Program Cost

Program costs over the 2001 to 2013 period are presented in Figure A5 and averaged €27 millionover that period.64 Figure A6 shows program costs as a percentage of telecommunicationsservices revenues,65 with an average of 0.06% over the period.

61 Ibid.
62 Ibid.

63 See http://www.insee.fr/fr/themes/tableau.asp?reg_id=0&ref_id=AMFd2 (Accessed ****, 2015).

64 See “Service Universel” page on ARCEP (France’s NRA) web-site: http://www.arcep.fr/index.php?id=8102&L=0(Accessed **** 2015).

65 “Telecommunications revenue” for 2001-2011 from “OECD Communications Outlook 2013” page 76http://dx.doi.org/10.1787/888932801014 (accessed ****, 2015), converted to national currency using exchange rates fromOECD (2015) Exchange (indicator) http://dx.doi.org/10.1787/037ed317-en (accessed July, 2015). Telecommunicationsservice revenues for 2012-2013 extrapolated from 2011 national currency estimate using 2011 to 2012 and 2012 to 2013growth rates of “Revenue from all telecommunication services” in national currency from “World Telecommunication/ICTIndicators database 2014 (18th Edition, December, 2014), ITU (2014) http://www.itu.int/en/ITU-D/Statistics/Pages/publications/wtid.aspx (Subscription accessed ****, 2015).

€0
€10
€20
€30
€40
€50

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A5: **** Low-Income USF Program

(€ 000,000)
Average over 2001-
2013 period

Report prepared on behalf of PIAC for Telecom Notice of Consultation 2015-13435

0.00%
0.05%
0.10%
0.15%
0.20%
0.25%

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Figure A6: **** Low-Income USF Program

(% telecommunnication sector revenues)
Average over 2001-
2013 period (0.06%)

Further Comments : Canadian Federation of Agriculture (Intervenor 205)

Document Name: 2015-134.223881.2537711.Further Comments (1$#3z01!).html

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