Interventions Phase 2: Intervenor 760

Document Name: 2015-134.227315.2537062.Interventions Phase 2(1$dly01!).html

My comment is an attached letter dated January 26, 2016 to the Chairman of the CRTC about a licensing a technology that would permit a low cost cell phone service to be created over a radio based Internet service that is already available in rural Canada.As required, the attached letter has been converted to RTF format as I do not have access to Microsoft Word. It does not contain any graphical material.

Interventions Phase 2: Intervenor 760

Document Name: 2015-134.227315.2537061.Interventions Phase 2(1$dlx01!).doc
BRAD J. BROOKS ******@***.com
BARRISTER & SOLICITOR Box 2461
****, MB *** ***
Telephone: (204) 822-6903 Facsimile: (866) 744-2579
___________________________________________________________
January 26, 2016
Mr. ****-Pierre ****
Chairman
Canadian Radio-television and Telecommunications Commission
Les Terrasses de la Chaudière, Central Building
1 Promenade du Portage, Gatineau QC *** ***
**** Mr. ****:
Re: Policy to Increase Wireless Communication Services in Remote Locations

I have reviewed the Report on Plans and Priorities, 2015-6 ("Report") and in particular, the planning highlights under Program 1.2: Connection to the Communication System and have a suggestion regarding a policy to improve wireless communication services in rural and remote locations ("RRL").

Proposed Technology

As you are aware, current wireless providers ("Providers") have been reluctant to provide service to RRL due to the lack of profit as the fees from usage are not sufficient to provide a sufficient return on the cost of building and running the infrastructure in RRL. One solution would be to use a new form of technology that is essentially a cell phone system in a box ("CPSB") for less than $10,000 U.S. per node that can cover a 10 km radius1. Each node would require power and access to the Internet. Now that radio based Internet services are becoming more widespread in RRL, it could be used to form the basis of a cell phone network in RRL throughout Canada.

Policy Elements
Ownership Restriction

As this technology is quite portable and could be installed anywhere, Providers would object strenuously to this technology being available in Canada given the amount that they have spent on spectrum and infrastructure for their wireless networks. One element of this policy would be to restrict who may own a CPSB. The CRTC could restrict ownership to non-profit community based entities ("CBE") (e.g. rural municipalities, or groups of rural municipalities, or corporations owned by them). Thus, ownership would be restricted to competent legal authorities over which the CRTC could exercise oversight and to which the CRTC could grant licences to own a CPSB.

Location Restriction

As Providers would object strenuously to the location of CPSB in areas already served by them in urban or near urban areas, the CRTC could restrict the operational area of a CPSB to those locations where a low cost unit by Provider (e.g. a phone that would cost $0 over a two year contract) could not sustain a five minute phone call in a vehicle. Presumably, technical specifications could be developed to show objectively where those locations existed. If Providers and CBE could not agree on whether a specific area could be covered by a CPSB, the CRTC could resolve the dispute on a low cost and short time period basis.

Same Terms of Services

As Providers would object to dealing with numerous CBEs in respect of billing of roaming fees, both by Provider subscribers in CBEs' area of operations, and CBE subscribers in Providers' areas of operation, there would be one (Canada-wide) or a very small number of organizations (at most one for each province or region) to which all CBEs would be required to belong. This umbrella organization would handle the roaming charges between Providers and CBEs and between individual CBEs and then distribute the net funds, if any, to the individual CBEs belonging in the umbrella organization.

Reduction in Requirement of Service by Providers

If Providers still object to CPSB, they could be released from any requirement in their current licences to provide service in RRL that are not profitable to them once a CBE is operational in that area. This way Providers could concentrate only on the most profitable geographical areas. However, the CRTC could mandate either a reduction in the costs that Providers could charge to their subscribers, or require them to contribute a certain amount to the umbrella organization of CBEs to help finance the cost of their networks.

Costs of Services to CBE Subscribers

As the CBEs would be non-profit and locally owned, the fees should not be higher than what Providers currently charge for similar services. Any profits would either be returned to the CBE subscribers or invested in improving a CBE's network.

Advantages of Suggested Policy
Safety

As noted in Report, the CRTC facilitates the orderly development of a communication system for all Canadians in order to strengthen the social and economic fabric of Canada and enhance the safety and interests of Canadians. This policy of allowing CPSBs would be a significant improvement in the safety of Canadians in RRL, both for those who reside there2 and those who travel in RRL.

No Subsidies Required

As CPSBs are relatively low cost, subsidies by the federal or provincial governments should not be required, as CBEs should be able to finance CPSBs themselves or sustain themselves from the amounts provided by Providers as noted earlier. If not, perhaps the federal or provincial governments would be willing to provide a low interest loan to those CBEs that could not afford or obtain the required initial financial investment. Even if loans were required, it would still be considerably less expensive than providing an incentive to Providers to improve their service to RRL.

Support of Radio Internet Services

This policy would increase substantially the amount of traffic on the radio Internet services that have been deployed in RRL which should in turn increase the profitability, and thus, the sustainability of such services.

By adopting a policy of this kind, this would help achieve one of the CRTC’s key goals of ensuring that Canadians have access to a world-class communication system as noted in Report.

I look forward to hearing from you as to the feasibility of implementing such a policy.
Yours truly,
**** J. ****
_________________________________________________________________
Footnotes

1 An example of such a service is CCN1 made by Endaga (see www.endaga.com/products). Attached as an appendix is an edited extract of my discussions with an Endaga representative. I am putting forth the Endaga product as a sample of the type of technology available, but I am not endorsing the product in any way.

2 As an example, please see http://winnipeg.ctvnews.ca/southern-manitoba-community-calls-on-government-to-fund-cell-coverage-for-emergencies-1.995340 showing what happens when cell phone service is not available in a RRL community.

I live in a RRL that is served by a Provider, but I am able to use my GSM cell phone for a sustained phone call only if I have a booster. As I do not have a booster due to the expense, I am restricted to using text messages if I am in an emergency situation near where I live.

____________________________________________________________
Appendix - Edited Discussion

BB: Could the CCN1 box be attached to the radio Internet towers? The towers have power and Internet and are based around 40 km apart, but are set up so there would be an overlap of signals at any particular location. If so, I am hoping I could have the company running the radio system run the cell phone network as it runs through most of rural southern Manitoba providing Internet services.

Endaga: Yes, that would be a great solution.

[Note by BB: A CCN1 box could be set up with a Internet connection anywhere in the 40 km zone to provide another 10 km broadcast radius resulting in each tower supporting several CCN1 boxes]BB: Is it possible to connect the CCN1 boxes together to cover a larger area than a 6 mile (10 km) radius in hilly terrain so that calls will not drop when people are travelling?

Endaga: Yes, multiple units can be linked and call handover will work.
BB: Can it handle -40C weather on its own or would additional weatherproofing be required?
Endaga: Yes, it is rated to handle that temperature.

BB: **** your system provide 911 call support to any telco GSM phone. If it does, then every rural municipality will fund for your service that has NetSet or a similar radio Internet system throughout Canada if it has any under-served areas in the municipality?

Endaga: Yes, we can support 911 calls. I believe in Canada everything connects to a central answering service, but my information may be dated. We are not currently providing 911 service in Canada, but our equipment and service can support it.

BB: **** your system support voice mail, caller id and call forwarding?

Endaga: We provide caller ID, but do not currently offer call forwarding or voicemail. We may add both of those features in the future. Many smart phones natively support voicemail and that will work with our service.

BB: What happens to the system if the Internet is not working - can the system still enable calls within that particular cell system (i.e. a subscriber calling another subscriber within range of the same box)? Can it work with adjoining cells?

Endaga: The system is fully functional for local calls without internet access. If multiple units are connected via PtP wifi or other means, calls would work with them as well. That said, the system is not designed to be permanently without access. Adding new subscribers and other administrative tools are compromised in off-line mode.

BB: **** your software allow for the tracking of the use of wholesale minutes / data bought from a telco so that it can be billed out to the customer? Ideally, the cell phone network I have in mind would allow the use of telco network once the user travelled outside the area covered by your devices. This way the customer would not have to have two phones, one for the Endaga network and one for the telco network.

Endaga: We provide the connection to the carrier for phone numbers, minutes and SMS. The data connection is up to you. Our management software includes a pre-paid billing system for you to manage your subscribers. We eventually hope to support roaming onto other networks, but we do not today. It will require agreements with the incumbent mobile carriers.

BB: **** your system permit cell phone number transfer so that a customer could transfer their number from a telco to your network?
Endaga: Yes, you can port a subscriber number to our network.

BB: What kind of data speeds would be possible through the cell phone? The radio based Internet system requires an expensive antennae that needs to be attached to a building along with a good line of sight to radio tower.

Endaga: This is a 2.5G solution. It provides low speed data. Typically, we would expect to see 20-30k to a handset. We are working on adding **** support, which would move that higher. A LTE version will be ready next year, but the coverage radius you need would require many more units.

BB: Do your handsets generate a WIFI signal? Even at 20K that is 7x faster than dialup Internet that quite a few of my neighbours are still using.

Endaga: We do not provide handsets. Our BTS provides data service over GPRS. Nearly every handset in the world will support GPRS data.