Final Submission : TCPub Media Inc. (Intervenor 105)

Document Name: 2015-134.222671.2614238.Final Submission (1k15q01!).html

Attached are my final comments for CRTC-2015-134 - Basic Telecommunications Services.

Final Submission : TCPub Media Inc. (Intervenor 105)

Document Name: 2015-134.222671.2614237.Final Submission (1k15p01!).pdf
Ottawa, May 25, 2016.
Ms. **** May-Cuconato
Secretary General

Canadian Radio-television and Telecommunications CommissionOttawa, Ontario

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Re: Telecom Notice of Consultation CRTC 2015-134
Review of Basic Telecommunications Services
Final Comments
**** Ms. May-Cuconato,

1. On **** 11 2016, I had presented to the Commission my intervention in the form of a video titled "Everything is Data". The YouTube links to my presentation and to my appearance at the hearing are asfollows:

Presentation: (9 minutes)Appearance: (45 minutes)2. I would now like to present my final comments.

Obsolete Technologies

3. In my video, I had stated that both copper and satellite based technologies are obsolete and inadequate for both our current and future needs. The accuracy of this statement has been greatly reinforced by the statements made by many of the intervenors during the course of the hearing.

4. For example, how can satellite technology still be considered "current" when, for example, Xplornet's future Internet speed offering and coverage will continue to be years behind traditional copper-based Internet speeds and coverage?

5. And the copper against which satellite performance is often compared is hardly any better. DSL and Cable technology's maximum speed of 200 Mbps will still be extremely slow when compared against optical fibre's minimum speed of 1 Gbps per fibre strand.

6. Our nation is becoming an ever increasing networked community, but the network coverage across the nation is highly uneven due to the continued use of obsolete networking technologies. We must stop supporting – and funding – these obsolete technologies, and concentrate all of our efforts into funding fibre optics based network roll-outs that will give us plenty of room for growth for the next few decades.

Minimum Level of Service

7. The minimum level of service decided by the CRTC through this hearing will very likely be obsolete by the time the chosen minimum level of service is fully implemented.

CRTC-2015-134 - Basic Telecom Services - Final Comments **** 1 of 3

8. Over the years, as the world's data networks were continually improved, new technologies were createdto take advantage of the latest improvements. The demand for improved network capacity increased even more when new delivery platforms were introduced such as smartphones, tablets, gaming consoles and smart appliances.

9. This area of growth isn't limited to entertainment based products and services; it also extends to business and government oriented products and services such as on-line shopping, teleconferencing, telecommuting, on-line education and government services.

10. How can we possibly decide on a minimum level of service to satisfy our current data needs when it's evident that it'll already be inadequate the day the decision is implemented? Instead, we should decide on a target level of service that will give us plenty of room to support both our current and future data needs for a very long time.

11. I recommend this target be set at 1 Gbps symmetrical per household over fibre optics cable. This targetmust also become a condition for any entity wishing to receive government funding to help finance the building or expansion of their network infrastructure.

Government Funding

12. On the subject of government funding, has anyone ever compared the amount of government money the larger corporations are receiving to build and expand their networks against the amount of money they're paying out to their directors and shareholders in the form of bonuses, stock options and dividends?

13. If a corporation is giving more money to their shareholders than it's receiving from the government, does that mean all of the taxpayer's money the corporation has received is funding the lifestyles of the corporation's shareholders? Why are we giving taxpayer money to large corporations that can finance their own expansion projects with their existing profits?

14. Commissioner **** MacDonald had asked me many questions about the funding for my Community Network Initiative. I now recommend that we revoke the public funding given to corporations that clearly don't need the money, and reallocate the funding to communities that will benefit the most from building and leasing access to their own Last Mile network.

The Commission

15. On **** 18 2016, The Chair, Mr. ****-Pierre ****, delivered formal remarks during the course of the hearing where he made the following statement (paragraph 7604 of the transcript):

“Ladies and gentlemen, in light of all this, it strikes us that this proceeding launched over 12 months ago may very well be the last best chance to get it right. A chance to create together a coherent national broadband strategy through an open and transparent process based on evidence from all Canadians, achieve to the extent possible through consensus, and implement it through shared responsibility.”

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16. I must add that this proceeding may also be the last best chance for the Commission to demonstrate their viability as a public organisation.

17. During the last few years, many decisions released by the Commission appeared to be partial and incomplete solutions to ongoing complex problems, with many decisions challenged or ridiculed by large corporations. These challenges waste an enormous amount of time and money, denying many Canadians access to improved telecommunications services at competitive prices.

18. Two recent examples of this phenomenon are Bell Canada's challenge against the Telecom Regulatory Policy CRTC 2015-326 - Review of wholesale wireline services decision (later denied by the federal government), and the transformation of “Skinny Basic” by the larger BDUs into an extremely expensive and unattractive package.

19. It's as if a significant portion of the Canadian telecommunications industry were empowered to throw a big “Frank ****” towards the Commission on a regular basis.

20. While I do commend the Commission for launching its review on the implementation of “Skinny Basic” television services, will any corrective action decided by the Commission actually stick? Or willthe Commission's decisions still be challenged and ridiculed by large corporations for years to come?

21. The Commission must now ask themselves how they can become an effective mechanism for change for all Canadians without being endlessly challenged over every decision they make. We've arrived at a crossroad where any decision made over Basic Telecommunications Services could have serious ramifications over the entire nation for decades to come. Any further delays in the process could be very costly for all of us.

22. I would like to end my final comments by pointing out that my proposal for building community networks can be accomplished by any government agency or community group without the need for the Commission to become directly involved in these projects. However, it would be nice if the Commission could become an active participant in its success by creating policies that would encourage the development of these community networks and not hinder them.

23. I thank the Commission for their time.
Yours truly,
**** Caron
President and CEO
TCPub Media Inc.
275 **** Street, suite 900
Ottawa, Ontario
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(613) 688-3334
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CRTC-2015-134 - Basic Telecom Services - Final Comments **** 3 of 3
Obsolete Technologies
Minimum Level of Service
Government Funding
The Commission
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