Final Replies : First Mile Connectivity Consortium (Intervenor 298)

Document Name: 2015-134.224010.2630333.Final Replies (1kdkt01!).pdf
First Mile Connectivity Consortium
Rob ****, Coordinator
PO Box 104
Fredericton, NB *** ***
http://www.firstmile.ca
Telephone toll free:
1-*-***-***-**** extension 4522
**** 13, 2016
Submitted Electronically
Ms. **** May-Cuconato
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, ON *** ***

RE: Telecom Notice of Consultation CRTC 2015-134 Review of basic telecommunications services — Final Reply Comments from the First Mile Connectivity Consortium (“FMCC”) **** Ms. May-Cuconato,

In accordance with the process established by the Telecom Notice of Consultation CRTC 2015-134 dated 9 **** 2015 (as amended), the First Mile Connectivity Consortium (FMCC) files the attached Final Reply Comments.

The FMCC is seeking means to ensure access to reliable and affordable broadband in northern Indigenous communities, with engagement of residents of these communities in the provision of services. Importantly, our member organizations support broadband-enabled public services such as online education and telehealth, as well as entertainment services for household consumers.

Sincerely,
Rob ****
First Mile Connectivity Consortium
******@***.com

Public Access to Information on Federal and other Public Funding received:

1. During the hearings, the CRTC requested several intervenors to file undertakings on public funding they had received to extend broadband. Xplornet and SaskTel provided this information in confidence, citing potential advantage to competitors if this information were publicly available. We requested that this information be placed on the public record.

2. In its response, SaskTel reiterated its refusal to put most of this information on the public record. FMCC then discovered that information on public funding of several broadband projects was posted on SaskTel’s website. When we pointed this out, SaskTel responded: “Upon review, SaskTel has discovered that detailed information regarding these specific projects was provided on its website in error, and is in the process of removing this information forthwith.” It did include the information from the website on its amended submission, but refused to provide information on public funding of other projects.

3. As of this date, Xplornet has not responded to our request.

4. We again assert that it is in the public interest for Canadians to know how their tax dollars have been spent. Further, during the hearing, the Commissioners specifically requested information that would help them understand how much funding would be required to extend service to unserved and underserved communities and residents, including estimates based on data from previous projects. FMCC and several other intervenors have submitted funding information on the public record. We believe that all intervenors should do so.

Required Parameters for Basic Broadband:

5. ****: Xplornet “believes email, electronic banking, software updates, being able to search for educational or health information, and the ability to access government services, form the basis of what defines basic service.” Xplornet and several intervenors conclude that 5 mbps down/1 mbps up is a sufficient requirement for basic service. We believe that higher speeds should be required because of the trend for more content and software to be located in “the cloud,” requiring uploads and downloads of large files, and the increasing use of video for educational applications (rather than solely for entertainment) and interactive videoconferencing for a variety of applications including meetings, interviews, and webinars.

6. Bell states: “For those activities that do require increased bandwidth, cloud based services are available to meet their needs” (Bell Canada Final Submission). But Bell ignores the need for increased bandwidth to be able to access these cloud-based services.

7. FMCC member organizations have stressed that local communities and their regional intermediary organizations require sufficient bandwidth to deliver telemedicine applications, two-way symmetrical videoconferencing, e-learning applications, justice applications, home-care applications and a host of online applications that local individuals, families, households, organizations and businesses require. While the specific level of bandwidth required must be determined based on several variables including population and demand, FMCC recommends that plans for every remote and rural community include a minimum of 500MB of bandwidth capacity, with larger communities (over 1,000 people) provided a minimum 1GB of capacity. This bandwidth can be delivered via a fibre-based network to serve the whole community.

8. We reiterate that regardless of the speed parameters adopted, speed and bandwidth will remain moving targets that must be regularly reassessed. We propose that they be revisited and revised if necessary, every three years.

9. Quality of Service: We disagree with some intervenors who state that there should be no mandated requirements for quality of service. For example, we disagree with the statement by TELUS that “The market adequately determines quality of service.” Numerous intervenors pointed out that poor quality of service hinders usage of broadband, including for some remote participants, use of Skype to participate in the hearings. We disagree with MTS that relying on programs such as Connecting Canadians that establish minimum parameters that must be met in order to qualify for funding, “the appropriate place to establish the technical requirements that must be met would be through these programs” (MTS Final Submission). The result would be a piecemeal approach that applies only for projects with funding from these programs. Specification and monitoring of QOS parameters must apply to services from all providers to all Canadians.

Need for a Northern Infrastructure and Service Fund (NISF):

10. We disagree with providers that state there is no need for a new fund because Connecting Canadians and/or the marketplace will provide adequate resources to meet the broadband needs of all Canadians. We have pointed out in our Final Submission that federal and other public funding programs have been very valuable, but are a patchwork that is not sufficient nor predictable. In addition, we have noted that these funding programs provide one-time capital support, and there is a need in remote and isolated regions for ongoing operational support to ensure that these services are sustainable.

Participation in Design and Execution of a National Broadband Strategy:

11. We agree with Shaw, Rogers, and some other intervenors that a multi-stakeholder advisory council should be established as part of the process to draft and implement a National Broadband Strategy, and that this Council should include First Nations representatives. We agree with Shaw that: “To be successful, this will depend on the involvement of many stakeholders, including governments, First Peoples, the Commission, industry competitors and advocacy groups” (Shaw Final Submission).

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Final Replies : First Mile Connectivity Consortium (Intervenor 298)

Document Name: 2015-134.224010.2630334.Final Replies (1kdk%01!).html

**** 13, 2016Submitted ElectronicallyMs. **** May-Cuconato Secretary GeneralCanadian Radio-television andTelecommunications CommissionOttawa, ON *** ***RE: Telecom Notice of Consultation CRTC 2015-134 Review of basic telecommunications services — Final Reply Comments from the First Mile Connectivity Consortium (“FMCC”)Dear Ms. May-Cuconato,In accordance with the process established by the Telecom Notice of Consultation CRTC 2015-134 dated 9 **** 2015 (as amended), the First Mile Connectivity Consortium (FMCC) files the attached Final Reply Comments. The FMCC is seeking means to ensure access to reliable and affordable broadband in northern Indigenous communities, with engagement of residents of these communities in the provision of services. Importantly, our member organizations support broadband-enabled public services such as online education and telehealth, as well as entertainment services for household consumers. Sincerely,Rob McMahonFirst Mile Connectivity ******@***.com