Final Submission : Kativik Regional Government (Intervenor 240)

Document Name: 2015-134.223965.2614314.Final Submission (1k17%01!).html

Attached is the Final Submission from the Kativik Regional Goverment.

Final Submission : Kativik Regional Government (Intervenor 240)

Document Name: 2015-134.223965.2614313.Final Submission (1k17t01!).pdf
Submitted Electronically
****-François ****

Senior Coordinator of Programs and Partnerships, Tamaani Internet Administration Department

Kativik Regional Government
Tel.: *-***-***-****
May 25, 2016
Ms. **** May-Cuconato
Secretary General

Canadian Radio-television and Telecommunications Commission Ottawa, ON *** ***

Re: Final Submission - Notice of Consultation 2015-134 – Review of Basic Telecommunication Services, File number: 8663-C12-201503186 **** Ms. May-Cuconato,

1. The Kativik Regional Government (KRG) is pleased to provide its final submission for the Review of Basic Telecommunication Services.

Broadband as a basic service

2. The KRG maintains that broadband is an essential service and the information presented by the parties during the hearings reaffirm this position.

3. The KRG is in the midst of implementing its Tamaani Internet Phase 4 project, which is a five year plan to provide basic Internet connectivity to Nunavik over C-band satellite with consumer broadband plans of 1.5Mbs/0.375Mbs for basic service and 3Mbs/0.5Mbs for premium service. Service obligation has essentially been imposed by Innovation, Science and Economic Development Canada under the Connecting Canadians program rules. We respectfully request that the Commission consider this project and avoid making a decision that would conflict with this obligation.

4. In parallel with our Phase 4 project, the KRG is also working with the government of Quebec toward the goal of building an undersea fibre optic network to Nunavik that will provide much greater capacity for the region. While funding for this project is unconfirmed at this point in time, we are optimistic that we can achieve this goal and greatly increase our service plans to Nunavik broadband users by 2021.

5. Some new information has come to light since the hearings. Pursuant to a recent announcement made on May 20, 2016 by Premier **** Couillard, the government of Quebec has stated that it intends to make significant investments in order that all residents of Quebec have access to broadband service of 30 megabits per second (Mbs) by 20211,2. During the hearings, we did not make a specific recommendation for speed, latency, or volume targets for a basic service. Based on this announcement, the KRG will adopt the Quebec goal as an aspirational target. In keeping with practices that we have adopted over the last twelve years, a lower cost basic service at half of the aspirational target should be set. We therefore recommend setting, by 2021, a basic target of 15Mbs download. Upload speeds should aim for a 5:1 ratio of the download speed, and monthly volume should be equivalent to the amount of data required to use the service at full capacity for one hour per day.

Latency should have an aspirational target below 100ms round trip between the CPE and the nearest Internet gateway; however, latency targets for communities served be geostationary satellites should not be set.

Aspirational Target (2021) Basic Service (2021)
Download speed 30 Mbs 15Mbs
Upload speed 6 Mbs 3 Mbs
Monthly Volume 490GB 245GB
Latency (round trip) <100ms n/a
Table 1: Recommended broadband targets
Technological issues

6. During the course of the hearing, there were many targets suggested as basic or aspirational targets. The download to upload ratio was as high as 25:1 for some. We would caution the Commission to do a technical feasibility analysis of highly asymmetric service plans before setting such targets, especially in high latency networks. There is some research that indicates that, as connections become highly asymmetrical, upload traffic can interfere with download traffic, in some cases reducing the download speed as low as 20% of the maximum capacity3.

7. In general, we believe that the negative impact of high latency on performance is understated. We have gone into some detail in our letter to the Commission, dated 1 Ministère de l’Économie, de la Science et l’Innovation du Québec, 200 M$ pour le Plan d'action en économie numérique - 100 M$ pour les infrastructures d'Internet haute vitesse - Un processus de cocréation de la Stratégie numérique **** Release, May 20, 2016 2 Codère, ****-François. Québec investit 288 millions pour le numérique, lapresse.ca, http://affaires.lapresse.ca/economie/technologie/201605/20/01-4983564-quebec-investit-288-millions-pour-le-numerique.php (accessed May 25, 2016)

3 Merrit, ****. Understanding Asymmetric Links, Buffers and Bi-Directional TCP Performance (M.S. diss.

University of Colorado, 2010)

**** 21, 20154, and will not belabour the point here, other than to say that geostationary satellites, and other technology that increases round trip latency above 100ms, should be considered technologies of last resort for broadband service.

National Broadband Strategy

8. The KRG welcomes the Commission’s request for comments with regards to a national broadband strategy. While we understand that a national broadband strategy must encompass the needs of the entire country, we will limit our comments to those that are pertinent to broadband development in the Arctic.

9. In our view, the last two programs offered by the federal government to stimulate broadband development, Broadband Canada: Connecting Rural Canadians, and Connecting Canadians, have been short term economic stimulus programs designed to stimulate immediate growth through spending as much as to promote broadband development. While we are not opposed to economic stimulus as such, the lack of a long term national broadband strategy has led to short term solutions which ultimately cost more in the long term while forcing providers to make compromises that affect service quality in order to meet short deadlines. We fully support the position of the Nunavut Broadband Development Corporation with regard to the need for a vision that goes beyond a single electoral cycle.

10. A short term program designed to solicit competitive bids from private sector organisations, that must have some hope of seeing a return on their investments, will never be able to achieve needed results. A holistic approach that considers not only telecom market potential, but also the cost savings to government departments and increased revenue from economic spillover, can justify the high level of investment needed to build essential telecom infrastructure in remote regions, just as spending on highway infrastructure is justified in urban regions.

11. In the far ****, the financial benefits of broadband to the community and to governments who provide services locally far outweigh the telecom market potential of these communities. There is a strong potential for bandwidth driven services to reduce the cost of delivering government services in the **** where the primary means of travel is by air. The question most asked when considering the construction of communications infrastructure in the **** is “How much will it cost to build?” While this is certainly a valid question, it is less intuitive yet equally crucial to ask “How much will it cost not to build?” Unlike many other vital infrastructure components, such as roads and bridges, communications infrastructure in Canada is built almost entirely by the private sector, a model that will not work in the far ****.

One can understand intuitively, for example, that rebuilding highway infrastructure such as the **** exchange in Montreal for a cost of three billion dollars is worthwhile because its value is worth more to society than its cost, in spite of the 4 Kativik Regional Government, Telecom Notice of Consultation 2015-134 - Response to interrogatories – File number: 8663-C12-201503186, letter to the CRTC, **** 21, 2015 fact that it generates no direct revenue whatsoever. The same intuitive leap is not readily done for telecom infrastructure, and yet, the parallel is entirely valid. Using preliminary data, the KRG estimates that the opportunity loss to government of not building an undersea fibre transport network to Nunavik’s communities is at least 122 million dollars over 25 years, and likely much more.5 Unfortunately, the paucity of available northern data on the financial benefits of broadband infrastructure, versus the financial cost of “travel instead of virtual” makes calculations of this nature extremely difficult and uncertain.

12. The mandate to create the national broadband strategy must therefore come from a high enough level that it takes into account the big picture, rather than to attempt to create a telecom industry in an area that simply does not have a sufficient market to sustain it. The department responsible for this strategy must have sufficient clout that it can break through silo-think. Nobody would expect the various federal or provincial health or justice departments to directly bear the cost of building an undersea fibre optic network to Nunavik; and yet, over a 25 year period6, these departments would collectively save more money from this network than the cost of its construction.

13. The KRG has the following specific recommendations:

a. Adopt a long term plan that spans at least 15 years.

b. In considering financial requirements, enlist the expertise of departments who can consider the global impact on government spending rather than simply considering the direct revenue potential of communications infrastructure.

c. Enlist the expertise of departments who can collect data and perform the required analyses to calculate the total financial and social benefits of communications infrastructure.

d. Avoid a one-size-fits-all approach and make special considerations for nonstandard business models, such as publicly owned providers or aboriginally owned providers.

e. Recommend programs that fit the regions, rather than expecting the regions to fit the programs, and allow program officers enough latitude to make exceptions on a case by case basis where these make sense for the public good.

f. Phase in recommendations so as to not disrupt time sensitive projects that are underway, or about to start.

14. Given the multijurisdictional nature of public institutions in Canada, the creation of a national broadband strategy will no doubt be daunting in its scope and require, if not 5 Kativik Regional Government, The Unconventional Business ****, Undersea Fibre Optics for Nunavik , Presentation, Northern Lights 2016, Ottawa, ON, January 2016.

6 Twenty five years is used for the amortization of undersea fibre optic networks, since this is the typical design life given by manufacturers. In reality, it is not unreasonable to expect the fibre optic cable to be functional for up to 30-40 years. (From private correspondence with Ciena Corporation engineers, 2014).

full consensus, at least a level of acknowledgement from provincial, regional and local governments and stakeholders on the objectives and recommendations of this strategy. In Nunavik alone in the past decade, there has been involvement of federal, provincial and regional governments. Some other areas in the **** may involve private corporations, band councils or aboriginal organisations. What is clear is that a one-size-fits-all model will not work. A market based approach might be the best model in some areas such as the western Arctic, but a public utility model might be the only successful model in the eastern Arctic. The strategy must be flexible enough to accommodate the particularities of each region of the country, while being focussed enough to ensure the achievement of the end goal: to make high quality broadband service available and affordable for every Canadian.

Sincerely,
[original signed]
****-François ****
cc: CRTC 2015-134 parties
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