Intervention: Vaxination Informatique (Intervenor 279)

Document Name: 2015-134.224006.2394818.Intervention(1fb%q01!).html

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Intervention: Vaxination Informatique (Intervenor 279)

Document Name: 2015-134.224006.2394816.Intervention(1fb%_01!).pdf
Comments
to
Canadian Radio-television and Telecommunications
Commission
by
Vaxination Informatique
regarding
Telecom Notice of Consultation
CRTC 2015-134
Review of basic telecommunications services
File: 8663-C12-201503186
****-Francois ****
Vaxination Informatique
******@***.com
Montréal, Québec
14-July-2015
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2015-134
Table of Contents

Introduction ..................................................................................................................3Big Picture ..................................................................................................................................................3Canadians’ evolving needs for telecommunications services .................................4The Commission’s role regarding access to basic telecommunications services ....5Can market forces and government funding be relied on? ..................................................................6What should the Commission's role be ? ...............................................................................................7Regulatory measures for basic telecommunications services ...................................8Performance standards .............................................................................................................................8Monthly Usage Limits ................................................................................................................................9Equivalency of technologies .........................................................................................................9Rural systems and technology ................................................................................. 10Access to Internet Transit .......................................................................................... 12Services to the Arctic ................................................................................................. 13Arctic Fibre .............................................................................................................................................. 14Permafrost ............................................................................................................................................... 15Conclusion .................................................................................................................. 16Vaxination Informatique 3 of 16

14-Jul-2015
2015-134 Introduction
Introduction

1. Pursuant to Telecom Notice of Consultation 2015-134 and 2015-134-1 Vaxination Informatique submits its initial comments for the Review of Basic Telecommunication Services.

-Vaxination Informatique wishes to be considered an intervenor in this proceeding.

-Vaxination Informatique requests to appear at the hearing.

Big Picture

2. As a nation, Canada can choose to set low standards so it can keep rewarding those companies that deploy substandard services based on older technologies. Or it can set bolder standards that provide incentives to deploy newer technologies that actually deliver future proof broadband to homes in all regions of the country. This takes vision and a commitment to see it through, one that outlasts an election cycle.

3. Connecting all Canadians with usable broadband is a formidable challenge. It is one that takes perseverance, money and innovation something Section 7(g) of the Telecom Act encourages. Lets not ask why rural or the north can't be served with modern broadband, lets ask HOW can we serve everyone with modern broadband. "Better than dial-up" doesn't cut it anymore.

4. The incumbents have failed to do this on their own, so a regulatory intervention is necessary either to force incumbents to do what is needed, or to allow others to step in with real solutions.

5. Section 7(g) of the Telecom Act should compel the Commission to stimulate development of innovative solutions that would make it possible to deliver real broadband to the hardest to reach areas of Canada, whether it is in northern Ontario, or Grise Fiord.

6. Canadians need broadband to their
home, not broadband to the glossy
Canada 150 brochure.
Rural FTTP deployment. Optical Splitter box.
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2015-134 Canadians’ evolving needs for telecommunications servicesCanadians’ evolving needs for telecommunications services 7. For every industry it has touched, the Internet has revolutionized it. The internet has also become integral part of how we live, our culture and economy. While everyone knows it has become an essential part of life, the Commission has yet to utter the word essential.

8. The internet is not just creating a digital economy, it is creating a digital society. We're now in a global village where we can all become aware of a racoon's funeral in Toronto. In the same vein, we should be able to hear of a polar bear rummaging through Resolute Bay. For shared experiences to encompass all Canadians, the Internet much reach all Canadians.

The ability to contribute to our national identity requires access to the Internet.

9. While the broadcasting act is not part of this consultation (and shouldn't), allowing Canadians from all regions to express themselves via uploaded tweets, videos, YouTube and whatever else might come in years to come is an extremely important objective for cultural expression and participation in a shared national experience, something which traditional linear television is not so good at. The portions of Canada which are geographically or economically excluded from the Internet cannot participate in this new cultural experience and they are the people who need it most due to their isolation.

10. Similarly, with linear television losing importance, a connection to the Internet becomes very important to receive cultural content. And this is especially true of specialized content such as content targeted at First Nations in their languages.

11. It should be noted that internet shopping, something we take for granted in the south, is a HUGE thing for people outside of major cities where internet shopping liberates them from the limited selection of goods at their local Coop or Northern store.

12. The Commission must also consider advantages to society which may not be tangible in the restricted scope of the Commission. Without telemedicine, any serious ailment requires a government paid and very expensive flight to the south for a consultation. Reducing the number of such trips would save provincial governments large sums of money. This requires bidirectional HD capable video conference. The nurse in a remote community can have access to specialists in the south, something which is not possible without internet access.

13. By no means is this an exhaustive list, as Vaxination expects many other participants to provide many other examples.

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2015-134 The Commission’s role regarding access to basic telecommunications servicesThe Commission’s role regarding access to basic

telecommunications services

14. The conversion from analogue to digital started at the cores. Telephone switches started to talk "digital" to each other while POTS service remained analogue. Cable carriers got digital TV signals in MPEG2 from satellites but distributed in analogue NTSC over the coax.

As time progresses, the conversion to digital got closer and closer to homes.

15. We are now in an era where a digital link to the Internet has become THE basic service that supports voice, internet, and video entertainment (includes "television" and many other forms of video such as Netflix, Youtube, newspaper web sites that have videos etc). When a properly functioning data link is available, voice telephone becomes an application, as does television. And as access to the Internet has become an integral part of society and economy, it can be argued that the data link between the home and the rest of the world has become essential.

16. This does not prevent the Commission from continuing to assert that a voice link is essential (especially for 911 service), but this essential application can be provided over many different mediums, from old POTS, VoIP, cellular, Skype etc. This means that the copper wire to every home is no longer an essential service.

17. Therefore, the basic service should be the data link to the home. The medium (FTTP, fixed wireless, etc) used to deliver such a service is not important, as long as the medium provides the performance/usage standards needed to support the applications that are also considered "basic service". In a digital environment, the data link is the basic service, and voice becomes an application over the basic service.

18. So it becomes possible to mandate that voice , as an application, must be provided, and that a data link as a basic service must be provided. In areas where the data link is not yet present, the requirement to provide voice application still compels the incumbent to provide it either via POTS or cellular. As stated previously, when cellular or fixed wireless are substitutes for wired connection, the rates charged must be those of wireline service.

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2015-134 The Commission’s role regarding access to basic telecommunications servicesCan market forces and government funding be relied on?

19. Unfortunately, the industry as a whole has become addicted to subsidies, so they lack initiative, preferring to wait for subsidies or being forced by the Commission to act.

The reality is that there are areas that cost more to serve than others, and some form of government intervention at regulatory and financial levels are necessary.

20. There is a sense of urgency to serve all of Canada so that the nation can move to "digital" instead of being seen as a laggard by the rest of the world (as it the case now).

21. The Australian NBN experience has shown that unless all political parties are fully behind a "nation building" scheme, it risks being sabotaged when an opposition party who has campaigned against it gains power. So Canada needs to find the proper balance for a rapid implementation without risking political influence so that the project, which is a long term project, can come to completion independent from politics.

22. Furthermore, Canadian firms have been able to deploy FTTP at greater rate than the fully funded NBN Co in Australia when its plan was to deploy FTTP, and this is without any formal government plans to deploy FTTP in Canada. The caveat: In Canada, incumbents have focused investment where copper customers were being lost to Cable, so rural areas with no service have generally not benefitted.

23. Large government projects with huge sums of money tend to slow to a crawl with ever increasing costs as contractors see an endless potential for money. (not too different from other large scale projects such as hosting Olympics in Montréal in 1976).

24. In areas where incumbents are not interested in deploying FTTP because there is no cable to lose customers to, any company should be able to benefit from funding, including funds set aside by incumbents.

25. The Australian model had one great advantage: A single source for funding and clear technology parameters for deployment, with various contractors bidding to install that technology. (for instance FTTP for all towns, fixed wireless for remote communities too far from fibre trunk, and satellite for truly remote stations/farms and isolated areas. The Original NBN laid out exactly what technology a town would get right from the start, and it was just a matter of implementing it. The project also had clear standards for minimum speeds.

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2015-134 The Commission’s role regarding access to basic telecommunications servicesWhat should the Commission's role be ?

26. Most importantly, there must be a single standard in Canada, and one whose targets do not fluctuate with the political wind. Contradictory deadlines and standards between the Commission and Industry Canada are not good. There must be a single "written in stone" policy that is followed to full implementation irrespective of temporary changes in political winds.

27. Ideally, a program to connect all Canadians should be fully funded and funds dispersed as quickly as possible to get any/all companies to deploy as fast as possible. Availability of funds should be based on logical parameters and have some form of standard (for instance, in farming areas, max of $x per home passed, in remote communities, $x per home passed etc). Political pressures to have deployment in one area before another should be avoided.

If the money is available, all areas should get the same priority.

28. One aspect that has not been discussed would be PPP (Public Private Partnerships) where the government could provide equity into a project and remain part owner until the operator can buy back the government's shares and become full owner of the facility. This has different image from the government handing a big bag full of cash to an incumbent to do something the incumbent could have done on its own. And those systems that are successful will buy back their shares, meaning the government gets its money back.

29. The Commission should draw the list of funding requirements and combine sources of funding from federal, provincial and incumbent funds to create a single fund used for last mile deployment, and another fund to build trunk lines that reach communities that are currently isolated from high capacity links.

30. There needs to be a clear definition of areas that are considered eligible for funding and areas where incumbents or others are expected to do this on their own. This is important if the Commission raises speed standards , which causes many urban areas to fall below the new standards. Should Bell Canada get federal funding to upgrade the ancient malfunctioning Stinger DSLAMs it deployed in urban areas ? No.

31. In the case of telephony, the Commission mandated that everyone must be served. The telcos were permitted to charge urban customers more to help pay to deploy to higher cost areas. Can this mechanism still be used considering retail internet is not regulated, and considering deployment in rural areas is not necessarily going to be done by the incumbent?

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2015-134 Regulatory measures for basic telecommunications servicesRegulatory measures for basic telecommunications servicesPerformance standards

32. The current schemes have a generic 5mbps down, 1mbps up advertised speed standard.

There are unfortunately many reports of deployments do that not reach full geographic coverage, or are under provisioned and do not provide advertised speeds in real life.

33. A system may perform well on the first year with 100 customers, but what happens if, after they cashed the government cheque, they subsequently get 1000 customers on the same antenna and customers get under 1mbps service ? Since Industry Canada has marked the area as "served", no other company can come in and deploy a new better performing system.

34. As part of qualifying for a government grant, a company must be made to disclose what their last mile capacity is to be, for how many homes served, and what average bandwidth per home standard the will uphold (requiring new antennas/node splits when customer base or usage grows). Shared media which may have had enough capacity to meet funding criteria this year can quickly become outdated and under performing as number of customers grows and average usage grows.

35. Furthermore, because the customer base can grow and average usage grows, there must be a mechanism which will declare a region "unserved" if the operator has failed to increase capacity and the system has fallen well below standards of capacity per end user.

36. There may be cases where an under performing system is warranted as a short term stop gap measure. But this should not in any way prevent a more permanent solution to be funded.

37. For unreliable legacy technologies such as DSL/FTTN, the company must guarantee that 100% of users will get the minimum advertised speed ("down to" instead of "up to"). Even FTTN cannot meet the BSO upload minimum of 1mbps throughout the footprint served by a DSLAM (especially Bell Canada's old Stinger DSLAMs that give down to 888kbps upload).

38. For TCP connections, insufficient upload makes it impossible to use full download. For instance, a company which advertises 25mbps download and 1mbps upload is misleading as to make use of 25mbps throughput in download, one would need to send about 2mbps of "ACK" packets on the upload.

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2015-134 Regulatory measures for basic telecommunications servicesMonthly Usage Limits

39. The conversation has focused much on speed. However, under provisioned systems can hide lack of capacity by greatly limiting monthly usage limits. In effect, they get their grant money without having to actually deliver the capacity that is needed.

40. This strictly limits the types of use one can make. Someone advertising 25mbps service may appear to provide modern service, but if they impose a monthly 20gig usage limit (UBB), then such service is not really usable to stream television, download large games etc.

41. Therefore, the Commission should set a minimum monthly usage limit as part of the standard (on top of service speed and also capacity per user). The higher the monthly usage standard, the greater the incentive to deploy a technology that performs instead of hiding under performing network through restrictive business practices.

Equivalency of technologies

42. There are occasions where an incumbent may pitch a wireless (fixed or cellular) solution to cover an area instead of deploying wireline infrastructure. Such proposal should only be accepted as a substitute for wireline if the incumbent is able to offer the same usage limits and pricing as its wireline service. Advertising 25mbps with only a 20 gig limit is not a substitude from the end user's point of view as it greatly limits use of the link.

43. In cases where this is considered better than nothing, such deployments could be accepted with a caveat that the area remains marked as "unserved" and other parties could obtain financial help to deploy a proper long term technology.

44. The danger is that a subsidy based system provides incentive for anyone to stake their subsidy claim and not really serve the population. It should be made very clear that unless the service is future-proof, the party risks being displaced by another. (this becomes important if subsidies for high cost areas are recurring instead of one-time.

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2015-134 Rural systems and technology
Rural systems and technology

45. Vaxination would like to bring the Commission's attention to the quiet community of Très St-Rédempteur (QC) near the Ontario border, south of Rigaud. It formed a cooperative called CSUR1 Here is text about its internet access from their web site:

La Coop CSUR est une coopérative de
solidarité sans but lucratif dont l’objectif est
de fournir aux citoyens et entreprises de la
région de Vaudreuil-Soulanges un accès
Internet haute vitesse en zone rurale au
même tarif et avec les mêmes services qu’en
zone urbaine.
Le projet visait initialement à répondre aux
besoins de la municipalité de Très-Saint-
Rédempteur (MRC de Vaudreuil-Soulanges).
Rapidement, des résidents des municipalités
voisines — comme Sainte-Marthe, Rigaud,
****-Fortune, Sainte-Justine-de-Newton,
Saint-Polycarpe, Saint-Télesphore, Rivière-
Beaudette et d’autres — ont manifesté leur
intérêt et sont devenus membres.

Coopérative de solidarité sans but lucratif: pour fournir aujourd’hui Internet haute vitesse à plus de 600 membres utilisateurs, la Coop CSUR compte sur ses membres travailleurs (4 employés salariés à temps plein ou à temps partiel ) et sur un conseil d’administration bénévole élu par les membres.

46. This region was in a void. The incumbent cable carrier never upgraded to bidirectional, so internet cannot be provided over coax, and the area is too far from a Bell Canada central offices to get DSL. Initially, they deployed fixed wireless technology originally with 3mbps up/down at the tower which proved grossly insufficient. Later, upgrading technology, they were able to offer 20mbps up/down at their multiple antennas (they had a few to split the load), but even then quickly proved to be inadequate. Last year, they deployed FTTP , passing some 684 homes, and plan on nearly doubling homes passed by next year. This was self funded because they could not get funding, as areas were deemed "covered" by Industry Canada.

47. One advantage of the progressive FTTP deployment in this area is that every home that moves from fixed wireless to FTTP frees up capacity on the fixed wireless network for those homes still on it, making fixed wireless infrastructure in the region less unpalatable. (Note:

portions of that territory is also served by Xittel, whose ratings are apparently very low due to insufficient capacity in their fixed wireless network.

1 CSUR: http://www.csur.ca
http://www.csur.ca
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2015-134 Rural systems and technology

48. Despite being in a rural area with farmland and low population density, they averaged a cost of just over $1000 per home passed. Their system uses lasers with a 20km reach, which means they can serve a very large area from a central location without the need for light amplifiers. In essence, FTTP is proving to be an efficient solution even in rural areas because of the reach.

49. This particular case is interesting as it encompasses not only the last mile aspect, but also access to transit. Originally, they were allowed to use the MRC Vaudreuil Soulanges' fibre network which had been funded provincially to connect towns (library, school, fire hall, town hall), as they were a non-profit municipally supported organisation. However, the fibre got them as far as Rigaud where the only transit provider was Bell Canada. Later on, they were able to stop using the MRC's network and get transit from Bell Canada at St-Rédempteur.

50. However, because Bell Canada's transit costs are very high, (since there is no competition in rural areas), CSUR only offers up to 40mbps service despite their GPON system being able to offer 1gbps service to customers.

51. ISPs who are based in large cities such Montréal, Toronto, Vancouver have access to a large array of transit providers, many of them American, who provide far lower transit pricing, so this puts ISPs who are not based in large cities at a clear disadvantage, unless to grow to a size where they can afford to buy ethernet to the large city where they can buy transit at lower cost.

52. Furthermore, in small communities where the only connection is via an incumbent's transit service, the ISPs must not only purchase transit capacity at higher rates, but also pay for capacity for all content whereas those in cities with peering exchanges off-load much of the capacity used by Netflix, Google, CBC/Akamai to the transit-free local peering exchange.

Off-loading the biggest bandwidth generators to transit-free exchange greatly reduces transit costs. CIRA has been promoting deployment of more peering exchanges in Canada but there are realistic limits to how many can be created.

53. When one considers far more remote regions of Canada, it becomes clear that funding for the last mile portion is only one part of the equation, as transit becomes an important cost.

54. In the case of Arctic communities, one possibility would be for the Government to fund Content Distribution Network (CDN) nodes to store content locally, to reduce the load on the satellite link. (this would help a lot for CBC/APTN content for instance). A CDN node in Iqaluit would reduce load on the satellite link and provide content locally.

55. The other aspect to be learned from CSUR's experience is that FTTP solutions have become financially viable for a much wider scope of applications (geography/population density) than originally thought. This is why there needs to be some refinement of standards where the Commission should push for FTTP deployments everywhere it is feasible and only promote fixed wireless or satellite where absolutely necessary.

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2015-134 Access to Internet Transit
Access to Internet Transit

56. As mentioned in the section on CSUR, access to affordable Internet Transit is an important part of the chain which must not be forgotten. In the case of an incumbent which extends its retail internet service to a town, the transit to the town is essentially free, and the incumbent takes that traffic to their true connection to the Internet in New ****, Chicago, Seattle etc.

(incumbents tend to peer in USA, not Canada). However, a community without incumbent retail service needs to find a way to connect their town to the Internet. This would mean either stringing their own fibre all the way back to the south, or purchasing expensive transit from the incumbent assuming the incumbent has transit available at their town.

57. This problem is felt in the south (such as St-Rédempteur) as well as remote regions.

58. The Cree setup their fibre network to connect their communities. It is called Eeyou Communications

Network2. It starts at Chicoutimi and rides on
a Hydro Québec poles to Radisson where
it then travels south mostly buried to coastal
communities.
59. They are lucky in that the **** Bay Hydro
Québec project has given them revenues that
enable such endeavours. Few First Nations are in
such positions.

60. This link is far from being able to serve all of northern Québec as the vast Inuit territory

(Nunavik) north of the **** Bay area remains
inaccessible by road.
61. However, the experience of this network should
be used wisely, especially the technical expertise
of building fibre in sub-permafrost northern areas.
(Cree territory is south of permafrost).

2 Eeyou COmmunications Network: http://www.eeyou.ca/en/homeEeyou Communication Network pops out of

the ground on the **** Bay road for the
connection of the spur to Wemindji.
http://www.eeyou.ca/en/home
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2015-134 Services to the Arctic
Services to the Arctic

62. A recent press release from Ledcor3 shows it was awarded a contract to outfit 25 Nunavut communities with fibre to connect government offices, schools, emergency response centres, fisheries, research centres and medical facilities. The Commission should ask itself why this contract did not involve wiring each community with GPON to every home. If you're going to send crews to each town, why not do the full job once you are there instead of just wiring a few buildings ? With an FTTP system may have been considered "overblown" a few years ago, it should be considered "basic" in 2015, since it provide much more reliable service in the last mile and could be used to deliver locally stored video content (from a CDN node as an example). Lack of vision is likely to blame, and this is where the Commission should step in. With a long term plan, each step could be executed to implement such plan step by step.

63. The satellite inquiry report header by Commissioner **** does not paint a rosy picture on any imminent plans to give Arctic communities high bandwidth satellite services. It should be noted that the Australian NBN project still calls for 2 satellites to be launched with 101 spot beams and over 120gbps capacity, and the service will offer 25/5 to the most isolated regions of Australia.

64. Providing proper broadband to the north is the best way to assert Canada's sovereignty over the area and give Canadian citizens who live there modern access to the internet, something we consider a basic need.

3 Ledcor press release, fibre within 25 communities:

http://www.ledcor.com/our-projects/communications/wireline-outside-plant/nunavut-fiber-optic-deployment?from=list&categoryid=13

Pangnirtung, Nunavut at night, circa 1990. Highly dependent on satellite communications.

http://www.ledcor.com/our-projects/communications/wireline-outside-plant/nunavut-fiber-optic-deployment?from=list&categoryid=13http://www.ledcor.com/our-projects/communications/wireline-outside-plant/nunavut-fiber-optic-deployment?from=list&categoryid=13Vaxination Informatique 14 of 16

14-Jul-2015
2015-134 Services to the Arctic
Arctic Fibre
65. Alternatively, the Commission
should consider undersea fibre
opportunities. While not all
Arctic communities might be
connected via fibre (at first),
connecting the largest ones
would free up much capacity
on satellites, allowing better
service to those communities
still on satellite.

66. A project called Arctic Fibre4 plans to connect Tokyo to England over the Canadian Arctic and proposes to connect a number of communities. Considering that fibre is being built to Tuktoyaktuk on shores of **** Sea, and considering fibre is available at Chissassibi QC on the shore of **** Bay (or a separate one strung along Hydro Québec poles back to the south), the connection of Arctic communities could be made via undersea cables.

The Alaskan panhandle is already connected to the USA via undersea fibre. There are opportunities for innovation and development of technologies/designs for landings on Arctic shores (issues with ice scraping bottom as it moves) and if solutions are found/exist, then connecting all Arctic communities via fibre (as well as those along shores of ****/**** bay) becomes a far more realistic proposition than originally thought. This would provide those communities with services comparable to those found in the south, both in terms of capacity and latency.

67. Unfortunately, stringing undersea fibre would not reach all of the towns served via satellite.

However, such an endeavour might reduce the number of transponders and spot beams needed to service those communities not served via undersea cable.

4 Arctic Fibre .com : http://arcticfibre.com/network/routing-map/http://arcticfibre.com/network/routing-map/

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2015-134 Services to the Arctic
Permafrost
68. Canada's north presents a formidable
opponent that is worse than an
incumbent's regulatory lawyer:
Permafrost.
69. Fortunately, it appears that this daemon
is being tamed (unlike regulatory
lawyers). Finished in 1979, the
**** highway was a learning
experience in building roads on
permafrost where the fragile vegetation
acts as insulating barrier during summer
to prevent the ground below it from
melting. And now, the **** Valley
Fibre Line is being buried all the way to
Inuvik and Tuktoyaktuk and will likely
present similar challenges in dealing with
permafrost.
70. Experience with telephone poles has
evolved and existing infrastructure in the
north is usable to string fibre to homes in
communities.
71. This review of basic services is the best
opportunity to kick Section 7(g) into
action and use current knowledge and
technology to spur development of modern broadband
infrastructure in the Nunavut, NWT, Northern Québec

and Yukon. It may take some time for fibre to reach Grise Fiord (or Alert), but this should be the eventual goal.

Telephone pole in Pangnirtung NU

Ledcor ditch witch in permafrost source Ledcor web site)Old telephone poles east of **** City

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2015-134 Conclusion
Conclusion

72. Through this consultation, the Commission has the opportunity to put Canada on a fast path to catching up to the rest of the world. Fibre technology has come down in cost, and deployment techniques now enable more varied deployments and should be considered as a priority.

73. Furthermore, there needs to be help in connecting communities to the backbones (internet transit).

74. Vaxination hopes to have more extensive comments. But for now, the 20:00 EDT deadline looms and this must be filed ASAP :-)

***END OF DOCUMENT***