Interventions Phase 2: Députés de Laurentides--Labelle de Pontiac (Intervenor 709)

Document Name: 2015-134.227235.2536861.Interventions Phase 2(1$dgd01!).pdf
February 4th, 2016
Mr. John Traversy, Secretary General
Canadian Radio-television and Telecommunications Commission
1 Promenade du Portage
Gatineau, Quebec *** ***
RE: Let’s Talk Broadband Internet (CRTC 2015-134-3)
**** Mr Traversy,

As the newly elected Members of Parliament for Laurentides–Labelle and Pontiac, we have been tasked by the many communities which we represent with finding solutions to the weak, inadequate, and often piecemeal access to the Internet which afflicts our constituents, as well as the related problem of inadequate cell phone coverage. Throughout both ridings, thousands of citizens and small businesses have made it clear to us that unlimited data, low latency, and high throughput – the ingredients of greater connection quality – are essential to the functioning of our local and regional economies. The existing gaps in digital access compound broader socio-economic challenges in communities whose development is depressed by years of underinvestment in infrastructure, industry, and technology, cuts in employment insurance, struggling seasonal industries and a shrinking population base.

Digital access inequities also have a significant impact on the ability of rural populations to participate equally in our democracy and be heard in their communities. Therefore, it is incumbent upon elected representatives at all levels of government, as well as independent regulatory bodies, to confront this challenge squarely.

Our submission seeks to provide both a riding-level perspective as well as constructive solutions. The comments and suggestions it contains are based on riding-wide consultations which we have personally conducted. They are not formulated by, nor on behalf of, the government, but rather on behalf of those communities who have given us the mandate to represent them and to seek solutions to the most serious problems we face. Furthermore, as executive members of the Liberal Party's national rural caucus, we can report that these views are shared by many other MPs representing rural ridings across Canada.

This CRTC study specifically seeks to consult with underserved and unserved regions, which are in most circumstances rural. We would be happy to facilitate CRTC consultations in the regions we represent and look forward to the opportunity to do so.

Network access and economic development

Poor access to digital networks compounds the structural economic and demographic challenges that smaller rural communities face. Migration of the rural population is a case in point. In the reasonably well-connected southern portions of our ridings, net migration remains positive. But moving further north and west, just a few dozen kilometers from Gatineau and Montreal, it is increasingly difficult to attract 2

new investors or to grow small- and medium-sized enterprises. Of course, access to capital is a perennial problem. But scarce capital is compounded where potential professionals and entrepreneurs find no signal, teenagers’ access to entertainment is stifled, and city-based families have a hard time finding cottages that allow them to stay connected. Consequently, efforts to reverse trends of population decline are hampered. For many people, in a time when human experience is increasingly mediated by digital technologies, this ‘social disconnect’ is simply too high a price to pay.

The technological solutions exist

Nevertheless, it is our belief that the industry has developed the necessary technology to deploy broadband Internet in excess of 10Mbps across all of rural Canada. LTE antennas, 60’ towers, 3.5GHz licensed and 3.65GHz lightly-licensed radio spectra are available and relatively inexpensive. The regulatory hurdles for the installation of low-height antennas have been largely cleared. There is an increasing amount of competition in the wireless Internet service provider (ISP) sector reminiscent of the plethora of small, local hard-wire ISPs that populated the **** American market before the consolidation of the late 1990s. Thanks to various federal government programs dedicated to enhancing rural broadband access, dark (installed, but not actually used) and underutilized fiber-optic lines which have technical capacities in excess of 10 Gbps serve schools, city halls, and public libraries in small towns. For much of rural Canada, the problem is thus one of “last-mile connection”, as the geographic density is simply too low for ISPs to make a business case out of servicing certain areas.

What is required, we believe, are regulatory reforms that more aggressively incentivize this deployment; a regulatory framework that would make it beneficial, and necessary, for service providers to work hand in hand with municipalities in order to cast, simply put, a wider net.

Market structure and the “business case”

Under current regulations, companies have strong market-based incentives to come into a town with, for example, a thousand customers, and provide service to 90% of them while ignoring the 20 houses on the other side of the hill. Yet, those incentives are much more the effect of the regulation-driven structure of the market than of the technology, geography, and desires which underlie it. Indeed, we believe that private investment and competition would be better served by regulations that do not make such cherry-picking of customers a competitive necessity. Consequently, we would like to encourage the study of the notion that Internet Service Providers be required to provide service to all households in a municipality, county, or region if they provide it to any, at an equal cost to all.

We would also encourage the CRTC to envision regulations that would encourage the creation of new types of partnerships between public authorities and ISPs to facilitate the financing of digital infrastructure. In Sweden, for instance, a regulatory framework was established wherein the network is considered public infrastructure, much like a national system of roads. ISPs provide a service over that network, much like freight carriers, and they pay a fee for using it, much like a toll. Some 10 years in, that system is profitable; not only to ISPs, who were never in the red, but also to the local governments who paid for the initial hardware. What is more, the service standard in the country is symmetric 100 Mbps, and 1 Gbps service is available for a modest premium. On top of that, dozens of providers compete to 3

service the last mile. We would therefore like the CRTC to conduct an objective study of whether the Swedish model could function in Canada, and what its consequences would be for all stakeholders involved.

We cannot, alone, prejudge the result of such an investigation. But we can report to the CRTC that the current state of affairs is no longer acceptable. Over 25 years into the Internet revolution, large regions of our country are more than 10 years behind the centres in terms of access. What is considered normal use in Toronto or Fredericton is a distant luxury for millions of Canadians. Numerous rural areas are, quite simply, left behind, and the inequitable distribution of economic opportunity which ensues causes a slow and steady socio-economic withering of our rural fabric.

The reality on the ground

The current situation, really, is hard to fathom for those who spend most of their time in urban centres.

Could you imagine that entire communities only a few kilometers from the TransCanada highway have the choice of low speed dialup or high latency satellite for Internet? It has been a long time since most of us considered a 56k modem an acceptable connection, or cloud-cover an acceptable excuse for losing signal, but that is the daily reality for many people in the ridings we represent.

For instance, the community of Sainte-Anne-du-Lac, population 619, has no cell phone service and high speed Internet access is limited to its downtown core. In ****-Saint-Michel, a few minutes south of it (population 635), proper connections are limited to those households which can see their neighbours. In ****-Saint-Philippe (population 892), not far to the east of ****-Saint-Michel, the service is so poor that the mayor has brought together a steering committee regrouping 20 municipalities that consider the situation urgent. A few minutes to the west, between ****-Saint-Philippe and ****-Saint-Michel, the community of Lac-Saint-Paul (population 475) has invested over $100,000 municipally, on an extraordinarily tiny tax-base, to get community Internet working - to no avail - while at the same time being 12 years into a boil water advisory.

Communities such as these can be found in every province and territory and the millions of Canadians that inhabit them will continue looking at the opportunities of the digital revolution from the margins until we find a way to structure the market so that it includes them.

Why satellite doesn’t cut it

High latency, low-speed, simplex connections are no longer adequate for today’s Internet users. Nor are geo-stationary satellites, often used for Internet service, a viable solution.

Indeed, the simple physics of geo-stationary satellites leads to a number of technical difficulties. Such satellites operate at 35,786 km above the surface of the equator, which for all of Canada is at a position relatively close to the southern horizon. Anyone who faces substantially higher terrain to the south cannot access these satellites, and the further north one resides, the less terrain it takes to obstruct the signal.


Second, at their altitude, the minimum one-way transit time for a data packet from the transmitter to the satellite is 119 milliseconds. Round-trip times for an Internet connection via a geo-stationary satellite therefore start at nearly half a second (without accounting for the time needed to connect to the ISP’s servers and to be routed to the wider Internet), making services like remote desktops, virtual private networks, internet telephony and video conferencing effectively unusable.

Third, the limited number of satellites leads to evident capacity issues, low uplink speeds, and small usage caps.

The cost of data

The CRTC currently specifies that 5 Mbps down, and 1 Mbps up, qualifies as a broadband Internet connection. Numerous residents and community leaders have made it clear to us that this standard is not adequate for today’s Internet, and our communities do not consider those speeds broadband.

Capacity and affordability is another issue which we believe should be viewed in terms of modern usage.

Paying more than $1 per gigabyte of data used is not acceptable in today’s web environment. A single video on a video sharing platform like YouTube can use a whole gigabyte of data. An hour-long video call on Skype will run a customer’s usage around 0.2 gigabytes. Self-updating devices such as smartphones and tablets can quietly upgrade a new 3 GB operating system overnight without even informing the user. Yet, many services provide 40 GB caps for a monthly price of $50, and then charge $1.50, $2.50, or in the case of cell phone providers, as much a $10 per additional gigabyte, whereas the marginal cost of that data transfer is negligible. We believe that any future regulatory framework should facilitate the provision of affordable unlimited data plans.

An era yet to be seized

The CRTC, the industry and the three levels of government have long worked hand-in-hand to bring Internet access to rural Canada. Various programs and policies work in favor of rural communities and make a real difference when they are implemented. However, usage and technology have evolved so quickly that the digital divide is continuing to widen. That is why we urge the CRTC to reform the regulatory framework as it applies to rural Canada. We see no reason why the market couldn’t be permanently restructured so as to make true high speed access to the Internet as ubiquitous as access to the electric grid, all while preserving the interest of all stakeholders.

We also urge the CRTC to pursue its outreach in rural communities, taking particular attention to reach out to people who do not already have Internet.

The territory covered by our ridings is as mountainous as it is vast, facing an average population density of fewer than five people per square kilometre, dispersed through hills and valleys, along river systems, and often far from highways. It is one of the most challenging regions in the world to achieve universal broadband access.


We know that Canada is up to this challenge. We see it as an opportunity to bridge the rural-urban divide.

Canada is in a unique position to become host to innovation and experimental technologies. Google and Facebook, for example, are both working on technological solutions to provide Internet service to under-serviced regions of the world. There is no better testing ground than rural Canada for such services and we believe the CRTC should encourage such innovators into the market.

The Internet, its hardware and technology, its social networks and virtual communities, will be the medium of business and communication throughout the 21st century. We must strive to be leaders in its development.


In view of these thoughts and considerations, we respectfully submit the following ideas for the CRTC’s study:

 That options should be considered to encourage or possibly require ISPs, both large and small, to provide service to all residents of any market which they invest, at an equal price for all - effectively removing the socially negative incentive to cherry-pick customers;

 That new regulations should be envisioned which would facilitate new types of partnerships between governments and ISPs to finance digital infrastructure;

 That an objective study should be conducted on foreign models such as the one prevailing in Sweden and on how their lessons can be applied to our context;

 That our policies should consider high speed, high uptime (the connection should be available at all times), low latency (the time it takes for data to travel between the user and the server), no cap (unlimited) Internet a universal right in the modern economy, in much the same way as landlines and electricity are guaranteed;

 That no connection with a packet round-trip time in excess of 100 milliseconds to the nearest backbone should be considered high speed, as longer delays result in excessive latency limiting the usefulness of fast connections;

 That no connection with a sustained capacity below 10 megabits per second should be considered high speed, with the option to gradually increase this threshold over time;

 That bandwidth caps should themselves be capped and regulated, and restricted to situations that are technically justified.

We appreciate the opportunity the CRTC has provided with this process. We believe that we, as elected representatives, our local and regional counterparts, the Internet Service Providers, and the CRTC, are all partners in this enormous challenge, and we look forward to continuing to work with you.

Respectfully submitted,
Laurentides–Labelle Pontiac

Interventions Phase 2: Députés de Laurentides--Labelle de Pontiac (Intervenor 709)

Document Name: 2015-134.227235.2536862.Interventions Phase 2(1$dg#01!).html

Voir pieces jointes svpRaisons pour comparaitre / Reasons for appearanceSujets que j’aimerais aborder à l’audience (David ****):- Faire rapport des consultations que j’ai menées à la grandeur de la circonscription à propos des besoins en accès Internet haute vitesse. Cet enjeu est une priorité partout dans la circonscription;- Parler des effets socio-économiques du manque d’accès à la haute vitesse dans les communautés rurales de Laurentides—Labelle, en particulier sur la jeune génération, sur les entrepreneurs, et sur l’industrie touristique;- Parler des impératifs techniques qui permettront d’assurer un accès minimum nécessaire aux entreprises locales désireuses de profiter des opportunités qu’entraîne l’économie numérique. Ayant étudié et travaillé plusieurs années en technologies de l’information, j’ai une expertise que peu de députés possèdent à ce chapitre;- Faire rapport de mes consultations auprès de nombreux petits fournisseurs d’accès Internet qui oeuvrent dans les régions;- Faire rapport des certaines discussions et préoccupations des députés membres du caucus rural national du Parti libéral ainsi que du caucus libéral de l’infrastructure numérique, deux caucus que j’ai contribué à mettre sur pied.Les raisons pour lesquelles nos observations écrites ne suffisent pas et pourquoi une comparution est désirable (David ****):- Mes consultations auprès des 43 municipalités de Laurentides—Labelle se poursuivent jusqu’au début avril. J’aurai alors une vue d’ensemble des besoins d’une circonscription rurale typique dont je pourrai faire rapport;- Les deux caucus nationaux auxquels j’ai fait référence auront pris leur envol plus sérieusement en avril et le premier budget du gouvernement libéral aura vraisemblablement été déposé. Comme l’accès à Internet dans les régions est un enjeu d’intérêt pour ces deux caucus ainsi que pour le gouvernement, je pourrai livrer une analyse à jour de la situation;- Les difficultés qu’entraîne le manque d’accès dans les régions rurales sont ressenties aux niveaux sentimental et culturel. Un témoignage en personne sera plus fidèle à la réalité éprouvée par les Canadiens touchés par cet enjeu qu’une soumission écrite;- Les citoyens de Laurentides—Labelle m’ont expressément chargé de porter leur voix auprès des institutions fédérales et l’accès à Internet dans les régions mal desservies est sans doute l'enjeu qui m’a été mentionné le plus fréquemment au cours de la dernière campagne électorale. Ma soumission écrite n’aura pas la valeur symbolique d'une comparution en personne, à savoir qu’une institution fédérale d’importance porte une attention intéressée à la réalité des villages ruraux et relativement isolés du Québec.