Intervention: Federation of Canadian Municipalities (FCM)

Document Name: 2015-134.223981.2394482.Intervention(1fbl#01!).pdf

Federation of Canadian Municipalities  24 **** Street, Ottawa *** ***  *-***-***-****  www.fcm.ca Federation of Canadian Municipalities

Intervention – Phase 1 of Telecom Notice of
Consultation CRTC 2015-134, Review of basic
telecommunications services
CRTC File No.: 8663-C12-201503186
July 14, 2015
- 2 -

1. The Federation of Canadian Municipalities (FCM) is pleased to participate in the first phase of the Commission’s Review of basic telecommunications services (Telecom Notice of Consultation CRTC 2015-134). FCM requests to appear at the public hearing scheduled for 11 **** 2016 in Gatineau, Quebec.

Introduction

2. The Federation of Canadian Municipalities (FCM) has been the national voice of municipal government since 1901. With some 2,000 member municipalities, FCM represents the interests of municipal governments on policy and program matters that fall within federal jurisdiction. Members include Canada's largest cities, small urban and rural communities, and 18 provincial and territorial municipal associations.

3. Rural, remote and northern Canada helps fuel our national economy and define our national character. Yet the unique conditions and characteristics of rural and remote communities pose serious challenges for delivering essential services, including telecommunications services. This challenge is recognized by all orders of government and is mentioned specifically in Canada’s telecommunications policy objectives, which include “rendering reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada.”1

4. FCM has long advocated for increased federal involvement in developing the telecommunications infrastructure that is critical to the social, cultural and economic vibrancy of Canada's rural, northern and remote communities. We have actively participated in previous federal consultations on telecommunications services, including rural broadband spectrum allocation and the development of Industry Canada’s Connecting Canadians program. FCM also commissioned a major report in 2014 on rural broadband availability in Canada,2 and has developed a series of recommendations regarding northern connectivity.3

5. The availability of affordable broadband services remains a major concern of FCM’s members and the Rural Forum and Northern and Remote Forum, two representative mechanisms that provide a regional perspective to FCM’s National Board of Directors. Considering the importance of this consultation, FCM held a targeted discussion on broadband access with rural and northern delegates at the **** 2015 Annual Conference in Edmonton, Alberta. Delegates were surveyed on their communities’ challenges accessing affordable and reliable broadband service, which indicated that municipalities continue to experience barriers to participating meaningfully in the digital 1

See paragraph 7(b) of the Telecommunications Act.
2

FCM (2014), Broadband Access in Rural Canada: The role of connectivity in building vibrant communities, http://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdf.

3

FCM (2015), “Northern broadband,” http://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htm.

http://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdfhttp://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdfhttp://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htmhttp://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htm - 3 -

economy. Selected survey results from this discussion are referenced throughout this submission, and are included in Annex A.

6. The following comments respond to the topics and questions identified in Appendix B of Telecom Notice of Consultation CRTC 2015-134. We expect that these recommendations will help guide the Commission as it reviews its policies regarding basic telecommunications services in Canada. FCM looks forward to participating in subsequent stages of the consultation, including the public hearing scheduled for **** 2016.

Canadians’ evolving needs for telecommunications services Broadband Internet availability in rural, northern, and remote communities 7. Broadband Internet access has become fundamental to modern life, and has the power to transform rural and northern Canada. Networks contribute to economic growth by improving productivity, providing new services, supporting innovation, and improving market access. Unfortunately, the “broadband gap” remains a reality in these communities, as some are without broadband coverage while others remain underserved by insufficient bandwidth and network capacity to meet user demands.

8. FCM’s 2014 report Broadband Access in Rural Canada – The Role of Connectivity in Building Vibrant Communities, prepared by Nordicity, included findings from focus group interviews with eight rural communities representing all regions of the country. The interviews focused on the connectivity needs of four major user groups: small-to-medium enterprises, health care and first responders, educators, and municipal governments. Of particular relevance to this consultation are the findings related to SMEs and municipal governments: “What was once known as a ‘digital divide’ is now more like a ‘community divide’ – the disruptive effect of low connectivity on resident outmigration as well as employee/business retention further lowers the feasibility of enhancing connectivity in a region.”4

9. FCM’s survey of rural and northern delegates at the 2015 Annual Conference found similar concerns regarding the quality of service provided, with 50% of respondents identifying the ability to attract and retain young talent as the primary benefit of improved broadband access. Internet service was identified as being inferior to neighboring communities by half of all respondents. According to conference delegates, the greatest barriers to participation in the digital economy were lack of broadband access and poor uploading and downloading speeds, at 23% and 40%, respectively.

Regarding access to government e-services, 70% of respondents indicated that they had difficulty in the past connecting to all of the following e-services: health care/e-health, education/e-learning, and federal websites (i.e. Service Canada, Canada Revenue Agency).

10. Specific barriers faced by Canada’s northern and remote communities that inhibit their meaningful participation in today’s digital economy are a lack of service parity across these communities and 4

FCM (2014), p. 22.
- 4 -

with southern Canada, along with a lack of redundancy, lack of capacity and high system vulnerability, highlighted by service outages and technical failures. The 2011 Arctic Communications Infrastructure Assessment (ACIA) Report included a series of recommendations5 to the CRTC as well as federal and territorial policy makers to address these challenges, many of which were subsequently adopted as policy by FCM’s Northern and Remote Forum and are included as recommendations in paragraph 22 of this intervention.

11. Of particular importance for the ****, but also applicable to rural areas, is the ACIA Report’s emphasis on ensuring that telecommunication networks in these regions “include provisions for the increasing rate of change of technology, and the continuous introduction of new consumer services and devices.” Unfortunately Canada continues to suffer from a persistent lag in bringing high-speed broadband to rural areas and northern and remote communities at speeds comparable to larger centres.

Uploading and downloading speeds

12. In FCM’s view, the Commission’s current target speeds for broadband – a minimum of 5 Mbps download and 1 Mbps upload – are no longer sufficient to meet the minimum needs of Canadians, and compare poorly to targets established internationally. The European Union, for example, has established 30 Mbps as the minimum speed for “fast broadband” and has targeted universal access to 30 Mbps download speeds by 2020.6 In early 2015, the U.S. Federal Communications Commission (FCC) revised its benchmark for “advanced” broadband access to 25 Mbps download and 3 Mbps upload speeds. The FCC also requires minimum speeds of 10 Mbps download and 1 Mbps upload for “basic” broadband access funded through federal subsidies, although bids with faster speeds are prioritized and project proponents “will be required to meet an evolving standard over the 10-year term of support, based on the highest speed adopted by a majority of households nationwide.”7 13. Recent Canadian studies, including the Commission’s own reporting on broadband availability in Canada, underscore the need for an evolving broadband speed target that is more reflective of current and anticipated needs. The Commission’s Communications Monitoring Report 2014 concluded that only 72% of rural households had access to download speeds between 5 and 10 Mbps (76% including mobile Internet access), compared to 100% universal access in urban areas.

This divide is even greater at faster speeds, with only 29% of rural residents and 84% of residents in small population centres having access to download speeds between 16 and 25 Mbps, compared to near universal access in medium and large urban centres.

5

Northern Communications and Information Systems Working Group (April 2011), A Matter of Survival: Arctic Communications Infrastructure in the 21

st

Century - Arctic Communications Infrastructure Assessment Report, prepared by Imaituk Inc., http://www.aciareport.ca – see chapter 9 for recommendations.

6

European Commission, “Broadband Strategy and Policy”, https://ec.europa.eu/digital-agenda/en/broadband-strategy-policy.

7

Federal Communications Commission (January 2015), 2015 Broadband Progress Report and Notice of Inquiry on Immediate Action to Accelerate Deployment, https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-10A1.pdf - see para. 55 for explanation of the speed target used for the FCC’s Connect America program.

http://www.aciareport.ca/

https://ec.europa.eu/digital-agenda/en/broadband-strategy-policyhttps://ec.europa.eu/digital-agenda/en/broadband-strategy-policyhttps://apps.fcc.gov/edocs_public/attachmatch/FCC-15-10A1.pdf - 5 -

14. In terms of quantifying user needs in Northern Canada’s most remote regions, a comprehensive report commissioned in 2014 by the multi-agency Northern Communications and Information Systems Working Group (NCIS-WG) identified a target of 9 Mbps download and 1.5 Mbps upload speeds for residential users to be achieved by 2019.8 The report also determined 11 Mbps and 16 Mbps requirements for educational and healthcare users, respectively. While the residential target is lower than some international targets, it should be noted that satellite-dependent communities in Nunavut will only be receiving 3 Mbps download speeds under the “enhanced serviced” being made available starting in 2016 through Industry Canada’s Connecting Canadians program.

15. Delegates at FCM’s 2015 Annual Conference were asked whether they believe the Commission’s current 5 Mbps / 1 Mbps target is sufficient to meet the minimum needs of their communities. Only 9% of respondents felt that this remains a sufficient target, with 23% preferring a 10 Mbps speed target and 53% selecting 25 Mbps as the appropriate speed target for Canada.

The Commission’s role regarding access to basic telecommunications services 16. FCM believes the Commission has a critical role to play not only in terms of setting broadband speed targets, but also in ensuring that basic telecommunications services, including broadband, are available to all Canadians regardless of the size or level of remoteness of their community.

17. In Telecom Regulatory Policy CRTC 2011-291, the Commission established the current 5 Mbps / 1 Mbps speed target while concluding that “the deployment of broadband Internet access services, including deployment in rural and remote areas, should continue to rely on market forces and targeted government funding, an approach which encourages private and public partnerships.” 18. The aspirational speed targets contained in CRTC 2011-291 have provided a useful benchmark for targeted government programs, notably the Connecting Canadians program first announced in the 2014 federal budget. FCM remains supportive of this program due to its objective of bringing a minimum of 5 Mbps service to underserved areas. Connecting Canadians is anticipated to bring enhanced broadband to a greater number of households than originally expected – at least 356,000 households compared with an original estimate of 280,000 households – with some projects delivering speeds in excess of 5 Mbps.

19. We would note, however, that the roll-out of the first phase of projects funded through Connecting Canadians will not be complete until 2017 – two years after the Commission target date. This is a significant lag given the rapid and continual evolution in basic broadband requirements, and supports the need for a more comprehensive approach to bringing basic broadband to all Canadians in a timely fashion. This type of targeted program also lends itself to last-mile solutions rather than major investments in transport infrastructure (fibre backbone in particular). While last-mile solutions are necessary, investments in backbone are needed to support evolving 8

Northern Communications and Information Systems Working Group (January 2014), Northern Connectivity Ensuring Quality Communications, prepared by Nordicity, http://northernconnectivity.ca/resources/ncis_wg_report.pdf.

http://northernconnectivity.ca/resources/ncis_wg_report.pdf - 6 -

telecommunications services, as noted by the Commission in the consultation document. A good example of the long-term benefits of investing in transport infrastructure is the Alberta SuperNet which supports at least 80 service providers including the 1 Gbps network established by the rural community of Olds, Alberta.

Regulatory measures for basic telecommunications services 20. The CRTC’s basic service objective does not currently include high-speed broadband Internet access, and instead is limited to the capability to connect via low-speed data transmission. Given the persistent lag in bringing high-speed broadband to rural and remote areas, and the challenges of relying on targeted government funding and market forces, the Commission should update the basic service objective to include broadband at an internationally-comparable and evolving speed target.

21. It follows that the Commission will need to adopt a comprehensive and long-term funding mechanism for basic broadband access, and that the existing contribution arrangement for basic telecommunications services offers a logical starting point. While FCM does not have specific recommendations to make at this time regarding the structure of such a funding mechanism, it should be noted that this approach should reduce the traditional lag-time in improving broadband service in high-cost serving areas, while allowing for targeted investments by governments to focus on advanced broadband access, rather than primarily on the provision of basic services.

Recommendations

22. Based on the above assessment of the connectivity challenges facing Canada’s rural, northern and remote communities, FCM recommends that the Commission:

 Expand the basic service objective to include universal access to affordable high-speed broadband Internet at speeds that reflect present realities and guarantee long-term, reliable connectivity;

 Continually re-evaluate its broadband speed targets to reflect technological advancements, changes in user needs, traffic, and network capacity;

 Adopt a national, comprehensive and long-term funding mechanism for basic broadband access to complement the current mix of targeted government programs and public-private partnerships;

 Develop a specific strategy for Canada’s **** that sets out a sustained funding commitment for developing communications networks;

 Commit to service parity among northern communities and with southern urban centres;

 Ensure every Arctic community has a redundant connection to prevent gaps in essential communication services;

 Develop a regulatory environment that fosters competition in ICT services in Canada’s ****;

 Ensure that investment strategies for Arctic communication networks include provisions for rapid technological change; and

 Meaningfully engage municipalities in decision-making and strategic planning going forward.

- 7 -
Conclusion

23. Closing the broadband gap and reducing the significant lag-time in bringing faster speeds to rural and remote areas requires the CRTC to update its approach to basic telecommunications services by incorporating high-speed broadband access as an essential service. This consultation provides a historic opportunity to establish a comprehensive, long-term plan for universal access to high-speed broadband. Expanding the basic service objective to include high-speed broadband is critical to enhancing Canada’s global competitiveness and ensuring that all Canadians have access to affordable and reliable broadband service at speeds comparable to Canada’s peers in the United States, Europe and elsewhere.

24. To realize this vision, we believe that all orders of government must work together. FCM and its member municipalities look forward to continuing this discussion with the Commission through the next phase of the consultation. We will also be available to provide input, examples and regional perspectives on the key issues that emerge following this first phase of consultations.

25. For additional information or inquiries, please contact **** Rubinstein, Manager, Policy and Research, at ******@***.com or *-***-***-****.

mailto:******@***.com
- 8 -

ANNEX A – SELECTED RESPONSES FROM SURVEY OF RURAL AND NORTHERN DELEGATES FCM 2015 ANNUAL CONFERENCE – EDMONTON, ALBERTA – JUNE 2015 1.) What is the approximate population of your community? / Quelle est la population approximative de votre collectivité? (multiple choice)

Northern
(count)
Rural
(count)
Total
(count)
Total (%)
Under 200 people / Moins de 200 personnes 0 1 1 1%
200 to 500 people / de 200 à 500 personnes 3 3 6 4%

500 to 1,000 people / de 500 à 1 000 personnes 6 6 12 9% 1,000 to 5,000 people / de 1 000 à 5 000 personnes 25 26 51 38% 5,000 to 10,000 people / de 5 000 à 10 000 personnes 8 20 28 21% Over 10,000 people / plus de 10 000 personnes 14 22 36 27% 56 78 134 100%

2.) Overall, how does the internet service in your community compare to other communities in your region? / De façon générale, comment se compare le service internet de votre collectivité à celui des autres collectivités de votre région? (multiple choice)

It is superior to other communities in my region / Il est supérieur à celui des autres collectivités de la région.

16 3 19 14%

It is inferior to other communities in my region / Il est inférieur à celui des autres collectivités de la région.

16 52 68 50%

There is little difference between the internet service in my community and others in my region / Il y a peu de différence entre le service internet de ma collectivité et celui des autres collectivités de la région.

25 23 48 36%
57 78 135 100%

3.) What kind of technology do you currently use to access the internet? / Quel type de technologie utilisez-vous actuellement pour avoir accès à l'internet? (multiple choice) Dial-up / Accès par ligne commutée 2 2 4 3%

Fast wired connections (cable or fibre) / Connexion réseau rapide avec fil (câble ou fibre)

19 17 36 26%

Mobile wireless/cellular / Service mobile sans fil/cellulaire 16 17 33 24% Fixed wireless / Accès sans fil fixe

16 23 39 28%
Satellite / Par satellite 6 19 25 18%
59 78 137 100%
- 9 -

4.) What is the greatest barrier facing your community from meaningfully participating in the digital economy? / Quel est le plus grand obstacle a votre communauté de participer pleinement à l'économie numérique? (multiple choice) Lack of broadband access / Absence d'accès à internet large bande

4 26 30 23%

Poor uploading and downloading speeds / Vitesses lentes de téléchargement en amont et en aval

20 33 53 40%
Prices / Les coûts 18 13 31 23%

Digital literacy / Manque de connaissances numériques 9 2 11 8% Lack of redundancy (back-up networks) / Manque de

redondance (absence de réseaux de sécurité)
2 5 7 5%
53 79 132 100%

5.) Have you experienced difficulty accessing the following online services in the past due to a poor internet connection? / Avez-vous déjà eu de la difficulté à avoir accès aux services en ligne ci-dessous en raison d'une mauvaise connexion internet? (multiple choice)

Health care/e-health / Soins de santé/télésanté 0 1 1 1% Education/e-learning / Éducation/apprentissage en ligne 0 3 3 2% Federal websites, i.e. Service Canada, Canada Revenue Agency / Sites web du gouvernement fédéral : Service Canada, Agence du revenu du Canada

3 3 6 5%

1 or more of the above / À l'un ou plusieurs des services susmentionnés

12 15 27 22%

All of the above / À la totalité des services susmentionnés 40 48 88 70% 55 70 125 100%

6.) How much does the average monthly internet package cost in your community? / Quel est le coût moyen mensuel d'un forfait internet dans votre collectivité? (multiple choice) Under $40 / Moins de 40 $ 0 1 1 1%

Between $40 and $60 / Entre 40 $ et 60 $ 11 28 39 29% Between $60 and $80 / Entre 60 $ et 80 $ 18 27 45 34% Above $80 / Plus de 80 $ 29 19 48 36%

58 75 133 100%
- 10 -
***End of document***

7.) Do you believe the CRTC’s current target uploading speed (1 Mbps) and downloading speed (5 Mbps) for 100% of Canadians by the end of 2015 is sufficient to meet the minimum needs of your community? / Croyez-vous que l'objectif actuel du CRTC en matière de vitesse de téléchargement en amont (1 Mo/s) et de téléchargement en aval (5 Mo/s) pour 100 % des Canadiens d'ici la fin de 2015 permettra de répondre aux besoins de base de ton communauté? (multiple choice) Yes / Oui 10 3 13 9%

No, the target should be at least 10 Mbps / Non, l'objectif devrait être au moins de 10 Mo/s.

12 21 33 23%

No, the target should be at least 25 Mbps / Non, l'objectif devrait être au moins de 25 Mo/s.

20 56 76 53%

I am not familiar with this terminology / Je ne connais pas cette terminologie.

16 6 22 15%
58 86 144 100%

8.) In your opinion, how often should Canada update our national broadband targets for the purpose of establishing a minimum level of basic service? / À votre avis, à quelle fréquence le Canada devrait-il réviser ses objectifs nationaux de services à large bande, afin d'en maintenir un niveau minimal? (multiple choice)

Every 3 years / À tous les 3 ans. 47 65 112 81%
Every 5 years / À tous les 5 ans. 11 13 24 17%
Every 7 years / À tous les 7 ans. 0 3 3 2%
58 81 139 100%

9.) How would improvements to basic broadband service in your region improve your local economy? / En quoi l'amélioration du service à large bande de base serait-elle bénéfique pour l'économie de votre région? (multiple choice)

Greater access to education and training resources / Meilleur accès aux ressources en matière d'éducation et de formation.

17 9 26 20%

Greater access to the global internet marketplace for our goods and services / Meilleur accès au marché internet mondial pour nos produits et services.

11 16 27 20%

Greater ability to attract and retain young talent in our community / Capacité accrue d'attirer et de conserver les jeunes talents dans notre collectivité.

22 44 66 50%

Greater and more affordable and efficient access to health care services / Meilleur accès et accès plus abordable et efficace aux services de soins de santé.

5 9 14 11%
55 78 133 100%

Intervention: Federation of Canadian Municipalities (Intervenor 234)

Document Name: 2015-134.223981.2394482.Intervention(1fbl#01!).pdf

Federation of Canadian Municipalities  24 **** Street, Ottawa *** ***  *-***-***-****  www.fcm.ca Federation of Canadian Municipalities

Intervention – Phase 1 of Telecom Notice of
Consultation CRTC 2015-134, Review of basic
telecommunications services
CRTC File No.: 8663-C12-201503186
July 14, 2015
- 2 -

1. The Federation of Canadian Municipalities (FCM) is pleased to participate in the first phase of the Commission’s Review of basic telecommunications services (Telecom Notice of Consultation CRTC 2015-134). FCM requests to appear at the public hearing scheduled for 11 **** 2016 in Gatineau, Quebec.

Introduction

2. The Federation of Canadian Municipalities (FCM) has been the national voice of municipal government since 1901. With some 2,000 member municipalities, FCM represents the interests of municipal governments on policy and program matters that fall within federal jurisdiction. Members include Canada's largest cities, small urban and rural communities, and 18 provincial and territorial municipal associations.

3. Rural, remote and northern Canada helps fuel our national economy and define our national character. Yet the unique conditions and characteristics of rural and remote communities pose serious challenges for delivering essential services, including telecommunications services. This challenge is recognized by all orders of government and is mentioned specifically in Canada’s telecommunications policy objectives, which include “rendering reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada.”1

4. FCM has long advocated for increased federal involvement in developing the telecommunications infrastructure that is critical to the social, cultural and economic vibrancy of Canada's rural, northern and remote communities. We have actively participated in previous federal consultations on telecommunications services, including rural broadband spectrum allocation and the development of Industry Canada’s Connecting Canadians program. FCM also commissioned a major report in 2014 on rural broadband availability in Canada,2 and has developed a series of recommendations regarding northern connectivity.3

5. The availability of affordable broadband services remains a major concern of FCM’s members and the Rural Forum and Northern and Remote Forum, two representative mechanisms that provide a regional perspective to FCM’s National Board of Directors. Considering the importance of this consultation, FCM held a targeted discussion on broadband access with rural and northern delegates at the **** 2015 Annual Conference in Edmonton, Alberta. Delegates were surveyed on their communities’ challenges accessing affordable and reliable broadband service, which indicated that municipalities continue to experience barriers to participating meaningfully in the digital 1

See paragraph 7(b) of the Telecommunications Act.
2

FCM (2014), Broadband Access in Rural Canada: The role of connectivity in building vibrant communities, http://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdf.

3

FCM (2015), “Northern broadband,” http://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htm.

http://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdfhttp://www.fcm.ca/Documents/reports/FCM/Broadband_Access_in_Rural_Canada_The_role_of_connectivity_in_building_vibrant_communities_EN.pdfhttp://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htmhttp://www.fcm.ca/home/issues/rural-and-northern/northern-communities/northern-broadband.htm - 3 -

economy. Selected survey results from this discussion are referenced throughout this submission, and are included in Annex A.

6. The following comments respond to the topics and questions identified in Appendix B of Telecom Notice of Consultation CRTC 2015-134. We expect that these recommendations will help guide the Commission as it reviews its policies regarding basic telecommunications services in Canada. FCM looks forward to participating in subsequent stages of the consultation, including the public hearing scheduled for **** 2016.

Canadians’ evolving needs for telecommunications services Broadband Internet availability in rural, northern, and remote communities 7. Broadband Internet access has become fundamental to modern life, and has the power to transform rural and northern Canada. Networks contribute to economic growth by improving productivity, providing new services, supporting innovation, and improving market access. Unfortunately, the “broadband gap” remains a reality in these communities, as some are without broadband coverage while others remain underserved by insufficient bandwidth and network capacity to meet user demands.

8. FCM’s 2014 report Broadband Access in Rural Canada – The Role of Connectivity in Building Vibrant Communities, prepared by Nordicity, included findings from focus group interviews with eight rural communities representing all regions of the country. The interviews focused on the connectivity needs of four major user groups: small-to-medium enterprises, health care and first responders, educators, and municipal governments. Of particular relevance to this consultation are the findings related to SMEs and municipal governments: “What was once known as a ‘digital divide’ is now more like a ‘community divide’ – the disruptive effect of low connectivity on resident outmigration as well as employee/business retention further lowers the feasibility of enhancing connectivity in a region.”4

9. FCM’s survey of rural and northern delegates at the 2015 Annual Conference found similar concerns regarding the quality of service provided, with 50% of respondents identifying the ability to attract and retain young talent as the primary benefit of improved broadband access. Internet service was identified as being inferior to neighboring communities by half of all respondents. According to conference delegates, the greatest barriers to participation in the digital economy were lack of broadband access and poor uploading and downloading speeds, at 23% and 40%, respectively.

Regarding access to government e-services, 70% of respondents indicated that they had difficulty in the past connecting to all of the following e-services: health care/e-health, education/e-learning, and federal websites (i.e. Service Canada, Canada Revenue Agency).

10. Specific barriers faced by Canada’s northern and remote communities that inhibit their meaningful participation in today’s digital economy are a lack of service parity across these communities and 4

FCM (2014), p. 22.
- 4 -

with southern Canada, along with a lack of redundancy, lack of capacity and high system vulnerability, highlighted by service outages and technical failures. The 2011 Arctic Communications Infrastructure Assessment (ACIA) Report included a series of recommendations5 to the CRTC as well as federal and territorial policy makers to address these challenges, many of which were subsequently adopted as policy by FCM’s Northern and Remote Forum and are included as recommendations in paragraph 22 of this intervention.

11. Of particular importance for the ****, but also applicable to rural areas, is the ACIA Report’s emphasis on ensuring that telecommunication networks in these regions “include provisions for the increasing rate of change of technology, and the continuous introduction of new consumer services and devices.” Unfortunately Canada continues to suffer from a persistent lag in bringing high-speed broadband to rural areas and northern and remote communities at speeds comparable to larger centres.

Uploading and downloading speeds

12. In FCM’s view, the Commission’s current target speeds for broadband – a minimum of 5 Mbps download and 1 Mbps upload – are no longer sufficient to meet the minimum needs of Canadians, and compare poorly to targets established internationally. The European Union, for example, has established 30 Mbps as the minimum speed for “fast broadband” and has targeted universal access to 30 Mbps download speeds by 2020.6 In early 2015, the U.S. Federal Communications Commission (FCC) revised its benchmark for “advanced” broadband access to 25 Mbps download and 3 Mbps upload speeds. The FCC also requires minimum speeds of 10 Mbps download and 1 Mbps upload for “basic” broadband access funded through federal subsidies, although bids with faster speeds are prioritized and project proponents “will be required to meet an evolving standard over the 10-year term of support, based on the highest speed adopted by a majority of households nationwide.”7 13. Recent Canadian studies, including the Commission’s own reporting on broadband availability in Canada, underscore the need for an evolving broadband speed target that is more reflective of current and anticipated needs. The Commission’s Communications Monitoring Report 2014 concluded that only 72% of rural households had access to download speeds between 5 and 10 Mbps (76% including mobile Internet access), compared to 100% universal access in urban areas.

This divide is even greater at faster speeds, with only 29% of rural residents and 84% of residents in small population centres having access to download speeds between 16 and 25 Mbps, compared to near universal access in medium and large urban centres.

5

Northern Communications and Information Systems Working Group (April 2011), A Matter of Survival: Arctic Communications Infrastructure in the 21

st

Century - Arctic Communications Infrastructure Assessment Report, prepared by Imaituk Inc., http://www.aciareport.ca – see chapter 9 for recommendations.

6

European Commission, “Broadband Strategy and Policy”, https://ec.europa.eu/digital-agenda/en/broadband-strategy-policy.

7

Federal Communications Commission (January 2015), 2015 Broadband Progress Report and Notice of Inquiry on Immediate Action to Accelerate Deployment, https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-10A1.pdf - see para. 55 for explanation of the speed target used for the FCC’s Connect America program.

http://www.aciareport.ca/

https://ec.europa.eu/digital-agenda/en/broadband-strategy-policyhttps://ec.europa.eu/digital-agenda/en/broadband-strategy-policyhttps://apps.fcc.gov/edocs_public/attachmatch/FCC-15-10A1.pdf - 5 -

14. In terms of quantifying user needs in Northern Canada’s most remote regions, a comprehensive report commissioned in 2014 by the multi-agency Northern Communications and Information Systems Working Group (NCIS-WG) identified a target of 9 Mbps download and 1.5 Mbps upload speeds for residential users to be achieved by 2019.8 The report also determined 11 Mbps and 16 Mbps requirements for educational and healthcare users, respectively. While the residential target is lower than some international targets, it should be noted that satellite-dependent communities in Nunavut will only be receiving 3 Mbps download speeds under the “enhanced serviced” being made available starting in 2016 through Industry Canada’s Connecting Canadians program.

15. Delegates at FCM’s 2015 Annual Conference were asked whether they believe the Commission’s current 5 Mbps / 1 Mbps target is sufficient to meet the minimum needs of their communities. Only 9% of respondents felt that this remains a sufficient target, with 23% preferring a 10 Mbps speed target and 53% selecting 25 Mbps as the appropriate speed target for Canada.

The Commission’s role regarding access to basic telecommunications services 16. FCM believes the Commission has a critical role to play not only in terms of setting broadband speed targets, but also in ensuring that basic telecommunications services, including broadband, are available to all Canadians regardless of the size or level of remoteness of their community.

17. In Telecom Regulatory Policy CRTC 2011-291, the Commission established the current 5 Mbps / 1 Mbps speed target while concluding that “the deployment of broadband Internet access services, including deployment in rural and remote areas, should continue to rely on market forces and targeted government funding, an approach which encourages private and public partnerships.” 18. The aspirational speed targets contained in CRTC 2011-291 have provided a useful benchmark for targeted government programs, notably the Connecting Canadians program first announced in the 2014 federal budget. FCM remains supportive of this program due to its objective of bringing a minimum of 5 Mbps service to underserved areas. Connecting Canadians is anticipated to bring enhanced broadband to a greater number of households than originally expected – at least 356,000 households compared with an original estimate of 280,000 households – with some projects delivering speeds in excess of 5 Mbps.

19. We would note, however, that the roll-out of the first phase of projects funded through Connecting Canadians will not be complete until 2017 – two years after the Commission target date. This is a significant lag given the rapid and continual evolution in basic broadband requirements, and supports the need for a more comprehensive approach to bringing basic broadband to all Canadians in a timely fashion. This type of targeted program also lends itself to last-mile solutions rather than major investments in transport infrastructure (fibre backbone in particular). While last-mile solutions are necessary, investments in backbone are needed to support evolving 8

Northern Communications and Information Systems Working Group (January 2014), Northern Connectivity Ensuring Quality Communications, prepared by Nordicity, http://northernconnectivity.ca/resources/ncis_wg_report.pdf.

http://northernconnectivity.ca/resources/ncis_wg_report.pdf - 6 -

telecommunications services, as noted by the Commission in the consultation document. A good example of the long-term benefits of investing in transport infrastructure is the Alberta SuperNet which supports at least 80 service providers including the 1 Gbps network established by the rural community of Olds, Alberta.

Regulatory measures for basic telecommunications services 20. The CRTC’s basic service objective does not currently include high-speed broadband Internet access, and instead is limited to the capability to connect via low-speed data transmission. Given the persistent lag in bringing high-speed broadband to rural and remote areas, and the challenges of relying on targeted government funding and market forces, the Commission should update the basic service objective to include broadband at an internationally-comparable and evolving speed target.

21. It follows that the Commission will need to adopt a comprehensive and long-term funding mechanism for basic broadband access, and that the existing contribution arrangement for basic telecommunications services offers a logical starting point. While FCM does not have specific recommendations to make at this time regarding the structure of such a funding mechanism, it should be noted that this approach should reduce the traditional lag-time in improving broadband service in high-cost serving areas, while allowing for targeted investments by governments to focus on advanced broadband access, rather than primarily on the provision of basic services.

Recommendations

22. Based on the above assessment of the connectivity challenges facing Canada’s rural, northern and remote communities, FCM recommends that the Commission:

 Expand the basic service objective to include universal access to affordable high-speed broadband Internet at speeds that reflect present realities and guarantee long-term, reliable connectivity;

 Continually re-evaluate its broadband speed targets to reflect technological advancements, changes in user needs, traffic, and network capacity;

 Adopt a national, comprehensive and long-term funding mechanism for basic broadband access to complement the current mix of targeted government programs and public-private partnerships;

 Develop a specific strategy for Canada’s **** that sets out a sustained funding commitment for developing communications networks;

 Commit to service parity among northern communities and with southern urban centres;

 Ensure every Arctic community has a redundant connection to prevent gaps in essential communication services;

 Develop a regulatory environment that fosters competition in ICT services in Canada’s ****;

 Ensure that investment strategies for Arctic communication networks include provisions for rapid technological change; and

 Meaningfully engage municipalities in decision-making and strategic planning going forward.

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Conclusion

23. Closing the broadband gap and reducing the significant lag-time in bringing faster speeds to rural and remote areas requires the CRTC to update its approach to basic telecommunications services by incorporating high-speed broadband access as an essential service. This consultation provides a historic opportunity to establish a comprehensive, long-term plan for universal access to high-speed broadband. Expanding the basic service objective to include high-speed broadband is critical to enhancing Canada’s global competitiveness and ensuring that all Canadians have access to affordable and reliable broadband service at speeds comparable to Canada’s peers in the United States, Europe and elsewhere.

24. To realize this vision, we believe that all orders of government must work together. FCM and its member municipalities look forward to continuing this discussion with the Commission through the next phase of the consultation. We will also be available to provide input, examples and regional perspectives on the key issues that emerge following this first phase of consultations.

25. For additional information or inquiries, please contact **** Rubinstein, Manager, Policy and Research, at ******@***.com or *-***-***-****.

mailto:******@***.com
- 8 -

ANNEX A – SELECTED RESPONSES FROM SURVEY OF RURAL AND NORTHERN DELEGATES FCM 2015 ANNUAL CONFERENCE – EDMONTON, ALBERTA – JUNE 2015 1.) What is the approximate population of your community? / Quelle est la population approximative de votre collectivité? (multiple choice)

Northern
(count)
Rural
(count)
Total
(count)
Total (%)
Under 200 people / Moins de 200 personnes 0 1 1 1%
200 to 500 people / de 200 à 500 personnes 3 3 6 4%

500 to 1,000 people / de 500 à 1 000 personnes 6 6 12 9% 1,000 to 5,000 people / de 1 000 à 5 000 personnes 25 26 51 38% 5,000 to 10,000 people / de 5 000 à 10 000 personnes 8 20 28 21% Over 10,000 people / plus de 10 000 personnes 14 22 36 27% 56 78 134 100%

2.) Overall, how does the internet service in your community compare to other communities in your region? / De façon générale, comment se compare le service internet de votre collectivité à celui des autres collectivités de votre région? (multiple choice)

It is superior to other communities in my region / Il est supérieur à celui des autres collectivités de la région.

16 3 19 14%

It is inferior to other communities in my region / Il est inférieur à celui des autres collectivités de la région.

16 52 68 50%

There is little difference between the internet service in my community and others in my region / Il y a peu de différence entre le service internet de ma collectivité et celui des autres collectivités de la région.

25 23 48 36%
57 78 135 100%

3.) What kind of technology do you currently use to access the internet? / Quel type de technologie utilisez-vous actuellement pour avoir accès à l'internet? (multiple choice) Dial-up / Accès par ligne commutée 2 2 4 3%

Fast wired connections (cable or fibre) / Connexion réseau rapide avec fil (câble ou fibre)

19 17 36 26%

Mobile wireless/cellular / Service mobile sans fil/cellulaire 16 17 33 24% Fixed wireless / Accès sans fil fixe

16 23 39 28%
Satellite / Par satellite 6 19 25 18%
59 78 137 100%
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4.) What is the greatest barrier facing your community from meaningfully participating in the digital economy? / Quel est le plus grand obstacle a votre communauté de participer pleinement à l'économie numérique? (multiple choice) Lack of broadband access / Absence d'accès à internet large bande

4 26 30 23%

Poor uploading and downloading speeds / Vitesses lentes de téléchargement en amont et en aval

20 33 53 40%
Prices / Les coûts 18 13 31 23%

Digital literacy / Manque de connaissances numériques 9 2 11 8% Lack of redundancy (back-up networks) / Manque de

redondance (absence de réseaux de sécurité)
2 5 7 5%
53 79 132 100%

5.) Have you experienced difficulty accessing the following online services in the past due to a poor internet connection? / Avez-vous déjà eu de la difficulté à avoir accès aux services en ligne ci-dessous en raison d'une mauvaise connexion internet? (multiple choice)

Health care/e-health / Soins de santé/télésanté 0 1 1 1% Education/e-learning / Éducation/apprentissage en ligne 0 3 3 2% Federal websites, i.e. Service Canada, Canada Revenue Agency / Sites web du gouvernement fédéral : Service Canada, Agence du revenu du Canada

3 3 6 5%

1 or more of the above / À l'un ou plusieurs des services susmentionnés

12 15 27 22%

All of the above / À la totalité des services susmentionnés 40 48 88 70% 55 70 125 100%

6.) How much does the average monthly internet package cost in your community? / Quel est le coût moyen mensuel d'un forfait internet dans votre collectivité? (multiple choice) Under $40 / Moins de 40 $ 0 1 1 1%

Between $40 and $60 / Entre 40 $ et 60 $ 11 28 39 29% Between $60 and $80 / Entre 60 $ et 80 $ 18 27 45 34% Above $80 / Plus de 80 $ 29 19 48 36%

58 75 133 100%
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***End of document***

7.) Do you believe the CRTC’s current target uploading speed (1 Mbps) and downloading speed (5 Mbps) for 100% of Canadians by the end of 2015 is sufficient to meet the minimum needs of your community? / Croyez-vous que l'objectif actuel du CRTC en matière de vitesse de téléchargement en amont (1 Mo/s) et de téléchargement en aval (5 Mo/s) pour 100 % des Canadiens d'ici la fin de 2015 permettra de répondre aux besoins de base de ton communauté? (multiple choice) Yes / Oui 10 3 13 9%

No, the target should be at least 10 Mbps / Non, l'objectif devrait être au moins de 10 Mo/s.

12 21 33 23%

No, the target should be at least 25 Mbps / Non, l'objectif devrait être au moins de 25 Mo/s.

20 56 76 53%

I am not familiar with this terminology / Je ne connais pas cette terminologie.

16 6 22 15%
58 86 144 100%

8.) In your opinion, how often should Canada update our national broadband targets for the purpose of establishing a minimum level of basic service? / À votre avis, à quelle fréquence le Canada devrait-il réviser ses objectifs nationaux de services à large bande, afin d'en maintenir un niveau minimal? (multiple choice)

Every 3 years / À tous les 3 ans. 47 65 112 81%
Every 5 years / À tous les 5 ans. 11 13 24 17%
Every 7 years / À tous les 7 ans. 0 3 3 2%
58 81 139 100%

9.) How would improvements to basic broadband service in your region improve your local economy? / En quoi l'amélioration du service à large bande de base serait-elle bénéfique pour l'économie de votre région? (multiple choice)

Greater access to education and training resources / Meilleur accès aux ressources en matière d'éducation et de formation.

17 9 26 20%

Greater access to the global internet marketplace for our goods and services / Meilleur accès au marché internet mondial pour nos produits et services.

11 16 27 20%

Greater ability to attract and retain young talent in our community / Capacité accrue d'attirer et de conserver les jeunes talents dans notre collectivité.

22 44 66 50%

Greater and more affordable and efficient access to health care services / Meilleur accès et accès plus abordable et efficace aux services de soins de santé.

5 9 14 11%
55 78 133 100%

Intervention: Federation of Canadian Municipalities (FCM)

Document Name: 2015-134.223981.2394483.Intervention(1fblf01!).html

Raisons pour comparaitre / Reasons for appearanceFCM would like to further discuss the importance of including high-speed broadband in the basic service objective to Canada's rural, remote and northern communities. The issues raised in this consultation, in particular establishing the broadband speed target for Canada and reforming the basic service objective, will have long-term impacts on the sustainability and vibrancy of our communities.As the only national representative of Canada's local governments, FCM is in a unique position to provide further perspectives to the Commission on the issues raised in this consultation, including the perspectives of other organizations participating in phase 1 of the process.

Intervention: Federation of Canadian Municipalities (Intervenor 234)

Document Name: 2015-134.223981.2394483.Intervention(1fblf01!).html

Raisons pour comparaitre / Reasons for appearanceFCM would like to further discuss the importance of including high-speed broadband in the basic service objective to Canada's rural, remote and northern communities. The issues raised in this consultation, in particular establishing the broadband speed target for Canada and reforming the basic service objective, will have long-term impacts on the sustainability and vibrancy of our communities.As the only national representative of Canada's local governments, FCM is in a unique position to provide further perspectives to the Commission on the issues raised in this consultation, including the perspectives of other organizations participating in phase 1 of the process.