Further Comments : First Mile Connectivity Consortium (Intervenor 298)

Document Name: 2015-134.224010.2530488.Further Comments (1$8jc01!).pdf
FMCC – Further Intervention February 1, 2016
First Mile Connectivity Consortium
Rob ****, Coordinator
PO Box 104
Fredericton, NB *** ***
Telephone toll free:
1-*-***-***-**** extension 4522
February 1, 2016
Submitted Electronically
Ms. **** May-Cuconato
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, ON *** ***

RE: Telecom Notice of Consultation CRTC 2015-134 Review of basic telecommunications services — Further Intervention from the First Mile Connectivity Consortium (“FMCC”) **** Ms. May-Cuconato,

In accordance with the process established by the Telecom Notice of Consultation CRTC 2015-134 dated 9 **** 2015 (as amended), the First Mile Connectivity Consortium (FMCC) files the attached intervention.

The FMCC is seeking means to ensure access to reliable and affordable broadband in northern Aboriginal communities, with engagement of Aboriginal residents in provision of services.

Importantly, our member organizations support broadband-enabled public services such as online education and telehealth, as well as entertainment services for household consumers. In the attached intervention, the FMCC represents the following First Nations organizations, (listed geographically from the Western to the Eastern regions of Canada):

• First Nations Technology Council (B.C.)

• First Nations Technical Services Advisory Group (Alberta) • Assembly of Manitoba Chiefs (Manitoba)

• First Nations Health and Social Secretariat of Manitoba (Manitoba) • Keewaytinook Okimakanak K-Net Services (Ontario)

• Keewaytinook Okimakanak Research Institute (Ontario)
• First Nations Education Council (Quebec)

• Atlantic Canada First Nations Help Desk (Atlantic Canada The FMCC requests to appear at the public hearing in Gatineau, Quebec, scheduled to begin on 11 **** 2016. An appearance at the hearing is necessary in order to answer any questions that the Commission may have regarding our submission, and to ensure that the fulsome views of our members are presented.

Rob ****
First Mile Connectivity Consortium
FMCC – Further Intervention February 1, 2016

Submission of First Mile Connectivity Consortium in Consultation CRTC 2015-134, 1 February 2016

1. The First Mile Connectivity Consortium (FMCC) is an incorporated independent not-for-profit national association. Our members are First Nations Internet service providers – what we call “community intermediary organizations.” Our associate members are university and private sector researchers and others interested in Indigenous and community communications and telecommunication services for the public good. Our work focuses on innovative solutions to digital infrastructure and services with and in rural and remote communities.

2. In this final written submission before the public hearing in ****, we would like to bring to the attention of the Commission some findings of our recent research and highlight some key points from our earlier interventions.

The Importance of Broadband for Northern and Indigenous Communities 3. We have stated that Basic Service should be expanded to include broadband, and provided detailed evidence about the importance of Internet access and broadband for Indigenous communities in our original submission.1 To summarize, the members of these communities require sufficient capacity, speed, and low latency to provide a range of services including online banking, e-health, telemedicine, e-commerce, distance education, and e-government services to ensure that community members will have the same access to the essential public and commercial services available to urban Canadians.2 We noted that online access to these services is perhaps more important to rural and remote community members because they lack the availability and range of services (healthcare, education, food, supplies, banking, etc.) found in urban areas.

4. Our initial submission cited several references concerning the value of broadband for rural social and economic development. We would also like to include the World Bank’s just published 2016 World Development Report which is focused exclusively on digital technologies and development. Entitled Digital Dividends, it includes extensive analyses of the contribution of the Internet to development, and states that making the Internet universally accessible and affordable should be a global priority. It states that these goals can be achieved through “a judicious mix of market competition, public-private partnerships, and effective regulation of the Internet and telecom sector.”3 We believe that Canada, including its remote and Indigenous communities, will benefit from accessible and affordable high speed Internet, overseen by effective regulation.

Research on Affordability

5. In northern Canada, where jobs are few and the cost of living is high, it is critical to meet the challenge of ensuring that telecommunications services are affordable. The central importance of addressing this challenge is enshrined in the Telecommunications Act, which states that rendering “reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada” is among the primary objectives of Canadian telecommunications policy. Implementing this goal requires consideration of both the cost of services (including installation and 1 FMCC Initial Intervention to CRTC 2015-134.

2 For examples of research on this topic, see the papers published through the First Nations Innovation project:


3 Digital Dividends. World Bank Development Report 2016. Washington, DC: World Bank.

FMCC – Further Intervention February 1, 2016

activation fees, monthly charges and usage charges) and the ability of community members to pay for them, as measured by cost of living statistics in the ****.

6. The FMCC is concerned that the affordability of Internet services reflects persistent inequities both between and within regions of Canada. Benefits from broadband require high levels of adoption – not just availability. We noted in our initial intervention for CRTC 2015-134 that northern community members face an affordability gap for telecommunications services. Research in rural Alaska, where remote villages are very similar to Indigenous communities in the Canadian ****, found that affordability is a significant barrier to adoption. Like their counterparts in the Canadian ****, many Alaska Natives have only seasonal incomes or are not employed, and their cost of living is high. A 2012 study in southwest Alaska directed by Professor **** Hudson of the University of Alaska Anchorage’s Institution of Social and Economic Research (ISER) found that while there was general enthusiasm about broadband, the primary concern among the households who were not sure if they would sign up for broadband when it became available was cost – and specifically, monthly subscription and data overages or other charges.4 In 2015, ISER researchers interviewed representatives of nonprofits, government agencies and businesses in Southwest Alaska that were now using broadband. Without exception, they said that broadband was very important for their work, but they could not take full advantage of it because of the high pricing, including usage caps.5

7. To assess the ability of community members in the Canadian **** to pay for telecommunications services, we refer to data on average income and cost of living. In Nunavut, for example, unemployment is 16.8 percent, while the cost of living in is 1.6 to 3 times that in other provinces and territories.6 Also, the population is very young, with 51 percent under the age of 25, so there are many young dependents to support and fewer people established in their careers.7 There are also disparities between small communities and urban centres within the ****. For example, family incomes in Dene communities in the Northwest Territories are less than 45 percent of the average family income in Yellowknife.8 These figures are similar for people living in the remote communities in the northern regions of provinces.

8. To measure and track geographic inequities in service pricing and affordability faced by residents of rural, remote and northern regions, we are currently developing a broadband affordability mapping methodology. This methodology utilizes GIS mapping software to generate visuals that layer statistical data sets associated with broadband affordability (such as cost-of-living; employment; and household expenses) on maps of northern regions (including both territories and the northern regions of provinces). By utilizing and aggregating publicly available data from various statistical agencies, and mapping it on to specific geographic regions of Canada, we can use this process to illustrate geographic broadband affordability gaps on an ongoing basis. This 4 ****, **** E. et al. Toward Universal Broadband in Rural Alaska. Institute of Social and Economic Research (ISER), University of Alaska Anchorage, November 2012. Available at:

http://www.iser.uaa.alaska.edu/Publications/2012_11-TERRA.pdf 5 ****, **** E. et al. After Broadband: A Study of Organizational Use of Broadband in Southwest Alaska.

Institute of Social and Economic Research (ISER), University of Alaska Anchorage, **** 2015. Available at:

http://www.iser.uaa.alaska.edu/Publications/2015_06-AfterBroadband.pdf 6 Nunavut **** of Statistics (2015, **** 1). Available at: http://www.gov.nu.ca/eia/information/statisticshome 7 ibid.

8 Northwest Territories **** of Statistics (2015). Available at: http://www.statsnwt.ca FMCC – Further Intervention February 1, 2016


methodology uses spatial analysis to illustrate socioeconomic conditions and affordability gaps in rural, remote, and Indigenous communities of northern Canada.

9. This mapping initiative provides a means to collect, aggregate and present publicly available statistics from organizations such as:

• Federal Agencies such as Statistics Canada

• Provincial and Territorial Government Agencies such as the Nunavut **** of Statistics (http://www.stats.gov.nu.ca/en/home.aspx)

• Aboriginal government agencies such as Nunavik Statistical Program (http://www.nunivaat.org)

• Nongovernmental organizations and Internet monitoring agencies such as M-Lab (http://www.measurementlab.net) and the Canadian Internet Registration Authority (http://www.cira.ca)

10. Many challenges arose in our attempts to collect and standardize socioeconomic data from census and intercensal years, due to major changes in the methods and variables utilized by statistical agencies. It has also been difficult to disaggregate data for Indigenous populations, particularly within the northern regions of the provinces. We continue to develop this affordability mapping methodology, and can provide the Commission with more details moving forward, if requested.

Research on Federal Funding Programs

11. The FMCC is conducting research to identify past and existing broadband funding initiatives provided by federal government departments and funding agencies. Some intervenors in this consultation and in the Northwestel hearing (CRTC 2012-669) argued that federal government programs should suffice to fund any unmet requirements for northern communications. However, our initial review clearly illustrates the complex and fragmented nature of funding for broadband infrastructure and services in rural, remote and northern communities.

12. Our research to date has determined that limited funding exists for broadband infrastructure, ongoing operating expenses, connectivity/bandwidth, public access, education/training, and research. Many of these funding sources are one-time and are often spread across a broad and confusing range of large and small programs with overlapping mandates across multiple departments. While some programs are well-publicized and broadband-specific, others sometimes include broadband as one aspect of a broad program mandate, or may fund ICT development to help achieve other program objectives, such as socio-economic development.

13. Broadband funding programs are also periodic and inconsistent. Many end abruptly – sometimes in spite of positive evaluations from government funders, as was the case with the Community Access Program. The uncertainty of accessibility to these funding initiatives makes it difficult for community-based organizations to engage in strategic planning, and threatens the long-term sustainability of their services and infrastructures.9 14. Our initial analysis of broadband funding programs has also identified a lack of coordinated funding opportunities for community-based organizations. Public programs often fund incumbent telecommunications providers directly to upgrade their infrastructure, rather than seeking competitive bids or partnerships with community 9 For example, see our discussion of the case of Isuma TV in FMCC’s Final Comments to CRTC 2014-190 (Let’s Talk TV), para. 18.

FMCC – Further Intervention February 1, 2016

providers. The result can be negative outcomes in terms of costs of projects and failure to achieve service goals. For example, in northwestern Ontario, when the incumbent provider experienced project cost overruns, five remote communities scheduled to receive a fibre connection were left off the network and removed from the project.

Further, incumbent wholesale prices for 100 mbps to serve an entire remote community were more than 20 times the current retail price for 100 mbps service to a residential customer in a small city such as Fredericton, NB.10

Community Intermediary Organizations

15. In our initial intervention to CRTC 2015-134, we introduced the concept of broadband-focused “community intermediary organizations” that are developing and providing technology support services to their constituent populations. We argued that these organizations have a strong “community service case” to be responsible to their constituents, and have no obligation to generate profits for distant shareholders. They can therefore provide telecommunications services in areas that otherwise lack a business case to do so – such as in rural, remote and northern regions. Rather than remit profits to shareholders, broadband community intermediary organizations invest any excess revenues to improve services, such as by purchasing equipment, upgrading networks, and/or lowering rates. These organizations work directly with their member communities, with their board of directors often being local community leaders and/or community members.

16. In our initial submission we further described these support activities for community networks as including:

• Setting up and operating industry standard broadband infrastructure.

• Supporting the delivery of online applications.

• Aggregating customers or ‘anchor tenants’ for community networks, such as public and community services like online education and e-health providers.

• Providing training in digital literacy to establish a skilled public service in every First Nation.

• Developing local skilled employment through jobs such as cable plant technicians and videoconferencing coordinators, or as administrators and technicians of community networks.

• Supporting partnerships between community networks and other public and private sector entities.

• Enabling community networks to achieve economies of scale in the purchasing of hardware, software and bandwidth (including satellite bandwidth and/or mobile spectrum).

• Providing strategic planning and business support for community networks.

17. In our intervention to the Commission's satellite inquiry (TNC 2014-44), we distinguished between two types of network design:

• A community-based model where a Point of Presence (PoP) to an external provider connects a locally-managed community network. This infrastructure model allows community members to set up a local or regional organization to manage, control, and operate telecommunications services. This approach both supports and enables economic development initiatives such as Internet Service Providers and/or data 10 See FMCC Response to Interrogatories FMCC (CNG/ECN), November 2, 2015, paras. 56 and 57.

FMCC – Further Intervention February 1, 2016

• A decentralized residential consumer model that connects an external telecommunications provider directly to individual households. This infrastructure constrains the ability of local organizations to manage and develop services since it precludes the development of community-run networks, applications and services.

18. We argued that community-based networking models allow community members to utilize telecommunication infrastructures and services as common resources that provide opportunities for the economic development initiatives that arise from local management, distribution and use of telecommunications services. This arrangement also involves partnerships with the telecommunications service providers from whom community organizations purchase equipment, bandwidth and other services and infrastructures.

19. From the shores of Haida Gwaii in northern B.C., to the remote communities of Nunavik in northern Quebec, communities and their regional community intermediary organizations are setting up and managing local and regional broadband initiatives.

Examples of such community infrastructure projects include:

• ****-range wireless networks managed by the GwaiiTel non-profit broadband organization on the islands of Haida Gwaii and a local wireless network owned and operated by the Seabird Island Band in B.C.

• Examples of local community fibre optic networks include those owned by K’atl’deeche First Nation, a Dene community in the Northwest Territories, Slate **** in northern Ontario (which also operates a community-owned Voice-over-IP telephone system), and Saugeen First Nation in central Ontario.

• Other examples of community infrastructure projects include the Membertou data centre in Nova Scotia and the Keewaytinook Mobile regional mobile service in northern Ontario.

20. A specific example of such a community-based approach is Slate **** First Nation in northwest Ontario. Working with the community intermediary organization K-Net, Slate **** provides residential Internet and VoIP telephone services through a Band-owned and operated service provider that leases backhaul from an external provider. Revenues from this arrangement serve to pay a local technician’s salary, purchase equipment, and subsidize phone and data services (including videoconferencing) for public and community service providers.11 Local government, residents, K-Net12 and government funders all participated in the Slate **** community network’s design.

21. Many community intermediary organizations and their partners are focused on developing and providing broadband-enabled health applications. For example:

• Broadband to deliver healthcare to First Nations in B.C.

• A range of ICT applications to manage health data – such as through the Mustimuhw Health Data Management System developed by the Cowichan Tribes in B.C.

• Videoconferencing networks to provide health information in remote communities in northwest Ontario and to network communities in the Yukon.

11 Additional information about the early stages of this project is available here:

12 See http://services.knet.ca/
FMCC – Further Intervention February 1, 2016

• Use of SMS text messaging to support diabetes management in remote Ontario communities.

22. Many rural, remote and northern communities are also developing and adopting broadband-enabled education applications. Examples include:

• ICT applications to support K-12 education in First Nations schools in Conne River, Newfoundland, and in several First Nations in Quebec, including Kahnawake, Wemotaci, and at Alaqsitew Gitpu School in Listiguj.

• ****-secondary education and technical training, such as at the Sunchild e-Learning Centre in Saskatchewan and the First Nations Technical Institute in Tyendinega, Ontario.

• Local and regional First Nation governments are starting to use the First Nations Student Information System Outcomes in Nova Scotia, New Brunswick, Ontario, and Quebec.

23. The First Mile website provides more than 80 community broadband case studies in rural, remote and northern regions. We invite the Commission to browse the website (http://firstmile.ca/category/community-stories) for examples of success stories of community broadband initiatives.

The Northern Infrastructure and Services Fund: NISF

24. In its Notice of Consultation, the Commission stated that it would “examine whether a mechanism is required in Northwestel’s operating territory to support the provision of modern telecommunications services by funding capital infrastructure investment in transport facilities as well as the cost of maintaining and enhancing these facilities. The Commission will also examine whether such a mechanism should be considered for other rural and remote areas in Canada.”13 In our initial submission to these proceedings,14 we proposed the creation of a Northern Infrastructure and Services Fund (NISF).

25. NISF support would not be limited to incumbent providers. It would enable community intermediary organizations and community service providers to access funding to support the development and operations of the broadband infrastructure and services required in the **** to meet local community connectivity needs. The NISF would enable community-based organizations and community networks to build, manage and operate their own network infrastructure and services by providing them opportunities to access a stable, sustainable source of funding dedicated to these purposes.

26. The regions eligible for NISF funding would include the northern territories of Yukon, Northwest Territories and Nunavut as well as the northern parts of the provinces and the regions of Nunavik and Nunatsiavut, which include remote communities similar to those in the territories.

27. In addition to infrastructure and basic services, the proposed NISF would also provide funds for:

13 Telecom Notice of Consultation CRTC 2015-134, para. 34, 9 ****, 2015.

14 FMCC Initial Intervention, CRTC 2015-134, 14 July, 2015.

FMCC – Further Intervention February 1, 2016

• Training for community members in operations and management of telecommunications services;

• Training for community members in digital literacies, including Internet Performance Measurement; and

• Strategic planning and research.

28. Priority access to the NISF should be given to community and regional organizations based in the ****, either as stand-alone providers or in partnership with other entities.

We noted that in such cases, the northern organization would be required to be the majority partner in any NISF-funded initiative. To ensure the equitable distribution of subsidy funds from the NISF, priority should be assigned according to the needs of communities, rather than according to the priorities of service providers.

29. We envision the NISF as an independent organization licensed by the Commission and governed by a Board of Directors, including representatives with strong ties to rural, remote and northern regions. The Board of the NISF would consist of representatives appointed by the Commission. NISF Directors would have no direct financial ties to entities applying to the Fund.15

30. The process used by the Commission to select representatives to this NISF Board should:

• be open, transparent and public;

• ensure balanced representation of cultural populations and geographic regions across the **** (including remote regions of the provinces);

• be based on nomination, including self-nomination;

• be large enough to ensure that directors are representative of the diverse communities and entities involved; and

• include representatives from private, public and civil society organizations with ties to rural, remote and northern regions and/or communities.

31. The proposed NISF governance model contrasts with the structure of the Canadian Telecommunications Contribution Consortium (CTCC) that administers the NCF. In the CTCC, nine of the 11 board members are from Ontario, with one each from Saskatchewan and Nova Scotia. None are from the ****. Further, most are current or former employees of major telecommunications services providers. In addition, the existing criteria and selection process for the NCF board members do not appear to be transparent or publicly disclosed.

32. We propose that the NISF adopt a transparent process that clearly demonstrates how capital and operational funds from the NISF will be spent to support and improve telecommunications infrastructures and services in remote and northern regions, and includes clear performance benchmarks and reporting requirements.

33. We appreciate the opportunity to file these comments, and would be pleased to provide additional information to the Commission.


15 This model is analogous to the governance structure of the Community Radio Fund of Canada (CRFC), as described in FMCC Initial Intervention, CRTC 2015-134, paras. 176-177.

Further Comments : First Mile Connectivity Consortium (Intervenor 298)

Document Name: 2015-134.224010.2530489.Further Comments (1$8jd01!).html

Please find attached the Further Intervention (Feb. 1, 2016) from the First Mile Connectivity Consortium (“FMCC”) to Telecom Notice of Consultation CRTC 2015-134 Review of basic telecommunications services.Raisons pour comparaitre / Reasons for appearanceThe FMCC is seeking means to ensure access to reliable and affordable broadband in northern Aboriginal communities, with engagement of Aboriginal residents in provision of services. Importantly, our member organizations support broadband-enabled public services such as online education and telehealth, as well as entertainment services for household consumers. The FMCC represents the following First Nations organizations, (listed geographically from the Western to the Eastern regions of Canada):• First Nations Technology Council (B.C.)• First Nations Technical Services Advisory Group (Alberta)• Assembly of Manitoba Chiefs (Manitoba)• First Nations Health and Social Secretariat of Manitoba (Manitoba)• Keewaytinook Okimakanak K-Net Services (Ontario)• Keewaytinook Okimakanak Research Institute (Ontario)• First Nations Education Council (Quebec)• Atlantic Canada First Nations Help Desk (Atlantic CanadaThe FMCC requests to appear at the public hearing in Gatineau, Quebec, scheduled to begin on 11 **** 2016. An appearance at the hearing is necessary in order to answer any questions that the Commission may have regarding our submission, and to ensure that the fulsome views of our members are presented.