Interventions Phase 2: The Nunavut Association of Municipalities (Intervenor 780)

Document Name: 2015-134.227357.2537886.Interventions Phase 2(1$#8%01!).doc
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[bookmark: _GoBack]February 8, 2016
Mr. John Traversy
Secretary General
Canadian Radio-television and Telecommunications Commission
Ottawa, ON
*** ***
Submitted Electronically

Re: Telecom Notice of Consultation 2015-134 Review of basic telecommunications services - File number: 8663-C12-201503186**** Mr. Traversy,

1. The Nunavut Association of Municipalities (NAM) represents 25 Municipal governments across Nunavut. The association was formed to make important contributions to decisions about Nunavut communities and capital projects. The group provides a single voice for mayors and municipal administrators of the territory's 25 communities.

2. The growing digital divide between Nunavut and most of Canada has long been a concern for NAM and its members. NAM supports the interventions already submitted by the Federation of Canadian Municipalities and the Nunavut Broadband Development Corporation.

3. NAM would like to reiterate the following concerns:

4. The high cost and limited capacity of services currently available in Nunavut, whether to the public, private sector or government, inhibit meaningful participation in the digital economy and limit government’s ability to deliver services.

5. Limited monthly data allowance and high overage charges are just as debilitating as slow upload and download speeds. Any national broadband service target should encompass affordability, upload speed, download speed and monthly data allowance. Such a target needs to be regularly reviewed and revised in order to keep pace with technological and social change.

6. At a time when we see increasing technological convergence, the current approach is fragmented: voice and data, private and public sector access are each supported through different mechanisms. Each successive funding program has enabled incremental improvements by supporting the procurement of additional satellite capacity. Such an approach does not lend itself well to supporting long-term investments in transport infrastructure, and fibre optic backbone in particular.

7. Subsequently, NAM respectfully submits that:

· The CRTC should update its definition of basic telecommunication services to include broadband Internet access.

· The base price for this basket of newly defined basic telecommunication services should be similar in rural/remote and urban communities in Canada.

· Any changes in regulation and funding should support an open access backbone model over imposing an obligation to serve on the incumbent.

8. In closing I would like to thank the Commission for it’s continued attention to northern telecommunications issues.

**** Fleming
Executive Director
Nunavut Association of Municipalities
P.O. Box 4003, Iqaluit, NU *** ***
Telephone: *-***-***-**** Fax : *-***-***-****
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Interventions Phase 2: The Nunavut Association of Municipalities (Intervenor 780)

Document Name: 2015-134.227357.2537887.Interventions Phase 2(1$#8v01!).html

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