Intervention: NWT Association of Communities (Intervenor 253)

Document Name: 2015-134.223964.2394429.Intervention(1fbjx01!).html

Raisons pour comparaitre / Reasons for appearanceWe wish to appear to stress the importance of a change to the definition of enhanced service to include high-speed internet service and the importance of reliability of all telecom systems to NWT residents and corporationsAppearing in person will allow the NWTAC to adequate demonstrate the unique nature and challenges of telecom services in the **** and its great importance to NWT communities.

Intervention: NWT Association of Communities (Intervenor 253)

Document Name: 2015-134.223964.2394428.Intervention(1fbjw01!).pdf

200, 5105 – 50th ****, Yellowknife NT *** *** *-***-***-**** tel *-***-***-**** fax

www.nwtac.com
July 14, 2015
Mr. John Traversy
Secretary General

Canadian Radio-Television and Telecommunications Commission Ottawa, ON

*** ***

Re: Telecom Notice of Consultation CRTC 2015-134 Review of Basic Telecommunication Services

File Number: 8663-C12-2015031186

Northwest Territories Association of Communities Comments **** Mr. Traversy;

1. The Northwest Territories Association of Communities (NWTAC) appreciates the opportunity to provide input on issues raised in Telecom Notice of Consultation CRTC 2015-134 related to the provision of Basic Telecommunication Services.

2. The NWTAC requests to appear at the public hearing scheduled for **** 11, 2016 in Gatineau, Quebec.

3. The designated representative of the NWTAC, for correspondence concerning the proceeding are:

**** Brown, Chief Executive ****
NWT Association of Communities
Suite #200, 5105 – 50th ****
Yellowknife, NT
*** ***
Email: ******@***.com

4. The NWTAC is a non-profit, non-governmental organization that represents the interests of 100% of NWT communities. NWTAC provides access to knowledge, technical expertise or capacity to community governments in the NWT. NWTAC also regularly distributes information on tools, best practices and project results to member communities. Our mission is to work together to serve our communities by addressing common issues, delivering programs and exchanging information. We are the united voice for communities on municipal goals determined by our members.

5. As the NWTAC represents all of the communities in the NWT, we are making the application on their behalf.

6. In addition to replying to the questions posed in the consultation document, a resolution was passed by our membership at our AGM of May 9-12, 2015 as follows:

2015-07 CRTC Review of Telecoms

WHEREAS the Canadian Radio-Television and Telecommunications Commission (CRTC) is embarking on a national consultation on Basic Telecommunication Services;

AND WHEREAS the nature of the geography of our territory and the size of our communities makes the use of telecommunications and broadband even more critical than many other areas of Canada;

AND WHEREAS the current limitations of telecommunications and broadband services in the NWT has been flagged repeatedly as a significant obstacle in the growth of the NWT;

AND WHEREAS NWT residents should have access to affordable, competitive and reliable telecommunications and broadband services, similar to those available in **** Canada;

THEREFORE BE IT RESOLVED THAT the CRTC and the Government of Canada consider the interests of the GNWT, communities, residents and businesses when making any decisions regarding telecommunications or broadband that could affect the ****;

mailto:******@***.com

AND FURTHER THAT the NWTAC register and participate as an Intervenor with the CRTC’s national consultation on behalf of its member communities;

AND FURTHER THAT the NWTAC work with our partners such as the GNWT as well as Yukon and Nunavut Associations of Communities to ensure that the voice of the **** is heard in the CRTC Consultations 7. In reply to the questions posed in the consultation document:

a. Canadians’ evolving needs for telecommunications services i. Given the remote nature and size of NWT communities, telecommunications is extremely critical. There is no ability to drive to many resources whether it is a store, bank, health care provider, educator, police etc. so all forms of telecommunications are extremely important to NWT communities participating in the digital economy.

Access to broadband internet has become essential to living in the modern world and the lack of access or bandwidth limitations in the **** has long been identified as an impediment to the growth of our communities and the NWT as a whole.

Levels of service that are taken for granted in the south are unheard of in much of the NWT. Something as simple as a logo in an email can bring your email to a grinding halt.

Attempting to file a document required for a funding grant to your community can prove nigh on impossible.

The NWT is experiencing a general out migration and some of this may be attributed to the inability to function in today’s digital world. It is certainly listed as a liability for businesses attempting to operate in the NWT and the same can be said for municipal corporations.

In today’s knowledge based global economy these service gaps are a significant gap to participating effectively.

Another area of concern for northern communities is a lack of redundancy which leaves communities vulnerable to service outages and technical failures. Having all telecommunication systems off-line for days at a time is unacceptable today and yet it is a fairly common occurrence in the ****.

ii. Coming from an area that for the most part does not meet these basic target speeds (of 5 Mbps download and 1 Mbps upload), achieving these targets would appear at first blush to be an amazing achievement however by the time these targets are achieved, they would no longer be appropriate. Satellite dependent communities will not even come close to achieving those targets even with currently planned enhancements.

Instead targets such as those identified in the 2014 report of the Northern Communications and Information Systems Working Group of 9 Mbps download and 1.5 Mbps Upload and 11Mbps Download and 16 Mbps Upload for education and healthcare are more appropriate.

b. The Commission’s role regarding access to basic telecommunications services

i. The Commission has an important role to play to ensure the NWT and the **** have adequate telecommunications and broadband (in terms of speed, bandwidth and availability) to ensure Northerners can effectively participate in not only the digital economy but all aspects of digital life.

ii. The reality in the **** is that we cannot wait for market forces to drive our progress and that funding must be secured for this to happen. Basic service objectives must include high-speed internet access and service reliability and funding must be to these levels of service which one would argue have become the new “basic”.

iii. How a service is provided should not change the definition of “Basic” which we have stated before should include affordable, competitive and reliable telecommunications and broadband services, similar to those available in **** Canada iv. While we cannot comment on the ability of other levels of government to participate in the provision of telecoms services in the NWT, we can highlight that municipalities are fiscally unable to participate. Recent funding reviews conducted by the Territorial Government have shown that community governments are currently underfunded by 37%.

c. Regulatory measures for basic telecommunications services i. Redundancy and reliability of service needs to be included in regulatory measures along with high-speed broad internet service of adequate speed and bandwidth as basic telecommunications service objectives.

ii. As we are unable to comment knowledgably on the funding regime and how it might support northern telecommunications, we would instead state that a basic principle of ensuring it is affordable and reliable should be a goal.

8. The NWTAC thanks the Commission for the opportunity to provide comments to CRTC 2015-134

Yours truly,
**** Brown, P.Eng.
Chief Executive ****
NWT Association of Communities

b. The Commission’s role regarding access to basic telecommunications services i. The Commission has an important role to play to ensure the NWT and the **** have adequate telecommunications and broadband (in terms of speed, bandwidth and availability) to ensure Northerners can effectively participate in not only the digital ec...

ii. The reality in the **** is that we cannot wait for market forces to drive our progress and that funding must be secured for this to happen. Basic service objectives must include high-speed internet access and service reliability and funding must...

iii. How a service is provided should not change the definition of “Basic” which we have stated before should include affordable, competitive and reliable telecommunications and broadband services, similar to those available in **** Canada iv. While we cannot comment on the ability of other levels of government to participate in the provision of telecoms services in the NWT, we can highlight that municipalities are fiscally unable to participate. Recent funding reviews conducted by the...

c. Regulatory measures for basic telecommunications services