Intervention: Ontario Ministry of Economic Development, Employment and Infrastructure (Intervenor 239)

Document Name: 2015-134.223958.2394405.Intervention(1fbj901!).pdf
Ontario Ministry of Economic Development,
Employment and Infrastructure
Submission to Telecom Notice of Consultation
Canadian Radio-television and
Telecommunications Commission 2015-134
(Broadband Internet Services)

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 2 of 16

Executive Summary

1. The Internet has become an inseparable part of the lives of Canadians.

Canadians use the Internet for connecting to important services such as e-learning, e-health, online banking, and much more. Online services allow Canadians living in rural and remote regions, including First Nations communities, to easily participate in the digital economy.

2. While broadband Internet connectivity has improved greatly over the past few years through natural market forces and targeted government funding, there are still large numbers of Canadians, including some First Nations communities, who do not have access to broadband Internet services at the Canadian Radio and Telecommunications Commission’s (the “Commission” or the “CRTC”) current target speeds.

3. The Commission’s current target speeds, 5 megabits per second download and 1 megabit per second upload, were relevant at the time of introduction in May 2011. Today, online services and applications that deliver high quality streaming audio and video rely on faster connections. Several comparable jurisdictions have recently adjusted their target speeds. The Commission should consider similar target speed adjustments. The Commission should also consider setting a quantifiable target level for monthly download allowance to guide service providers’ overage usage charges.

4. Broadband Internet access at the Commission’s target speeds should be considered a basic telecommunications service. This could be accomplished by adapting various components of the existing CRTC regulatory framework used for wireline phone service, and the recent decisions and directions the Commission has made in regional cases to the entire country.

5. In considering an appropriate funding mechanism for areas in need of broadband Internet within the country, the Commission should endeavour to maximize consumer choice, affordability, and leverage market forces.

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 3 of 16

Answers to the Questions for Discussion

1. Canadians are using telecommunications services to fulfill many social, economic, and cultural needs in today’s digital economy.

a) Explain how telecommunications services are used to meet these needs.

For example, uses may include e-commerce (i.e. the online purchase and trade of products or services), e-banking and/or telephone banking, e-health or telehealth services, telework, and distance education. Which of these uses of telecommunications services are the most important to ensure that Canadians meaningfully participate in the digital economy?

6. The Internet is Canada’s great connector. It allows Canadians to communicate with family, friends, coworkers and businesses around the world, to work from their homes, to scale-up their businesses, and much more.

7. All of the example applications mentioned in this question are important to meaningfully participate in the digital economy, though individual needs will vary based on many different variables.

8. What is universally important is an accessible, fast, and affordable platform that will allow Canadians to connect with all of these telecommunications services.

9. This platform is also important for citizen access to services. Online services such as e-commerce and e-health are often more capable and accessible than telephone-based services – especially for residents of rural or remote areas and some First Nations communities. For governments, online service delivery has the potential to improve access and efficiency in service delivery.

b) Explain which telecommunications services are most important to support these needs and uses. What characteristics (e.g. capacity, mobility, high speed, and low latency) should these telecommunications services have?

10. A high speed broadband Internet connection is critically important to support the social, economic, and cultural needs of Canadians. Other key characteristics include low transmission latency and sufficient monthly data usage allowances.

11. High speed is perhaps the most important characteristic for broadband Internet. With new digital applications needing higher and higher digital connectivity throughput, widespread deployment of fibre optic network infrastructure to get residential and business premises connected to fibre cable is paramount to grow our digital economy and be globally competitive.

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 4 of 16

12. In the United States, Google is deploying Gigabit fibre network connectivity with speed up to 1,000 Mbps in many cities at reasonable service prices. This will allow the people in these cities to have an economic development edge by being able to explore and innovate on this high performance digital platform.

13. Rural stakeholders in Ontario have identified the importance of telecommunications networks to participate and compete in an economy that is increasingly based on knowledge, innovation, and instant communication.

Access to high-speed broadband creates many opportunities for people living in rural and remote areas that would not be available otherwise.

14. Increasingly common business activities such as online stores, video-conferences, and e-banking require high-speed access to help rural businesses succeed. Research from the Monieson Centre and Queen’s University found that the deployment of broadband between 1997 and 2011 promoted rural employment and wage growth by “helping overcome geographical barriers that have traditionally hampered growth.” 1 15. However, given that many of the telecommunications services used to meet social, economic, and cultural needs are now in real-time and media rich, high speed connectivity by itself is no longer sufficient to ensure meaningful participation in the digital economy.

16. Broadband Internet subscriptions must also offer sufficient capacity and quality to ensure reliable service. For example, low transmission latency is an important requirement for high quality real-time audio-visual services (e.g., video calls). Research has shown that real-time call quality is negatively impacted by high latencies2.

17. Similarly, low monthly data usage allowances discourage the use of high bandwidth services. The 2014 edition of the CRTC’s Communications Monitoring Report (CMR) notes that the average residential subscriber downloaded almost 45 gigabytes (GB) of data per month. The report also notes that almost 25% of households subscribed to Internet service plans with less than 40 GB per month of download capacity. Many households may be paying high overage charges, or curtailing their usage to avoid further charges.

1

**** Ivus and **** Boland. "The Employment and Wage Impact of Broadband Deployment in Canada," Canadian Journal of Economics, 2015.

2

See, for example, G. W. Cermak, “Packet Loss, Bandwidth, and Latency Affect Judged Quality of Videoconferencing.” Proceedings of the First International Workshop on Video Processing and Quality Metrics for Consumer Electronics, Scottsdale, Arizona, 2005.

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 5 of 16

18. Given anticipated growth rates in download data, and the range of media rich applications, Canadians may be increasingly paying more for exceeding the monthly data allowances.

c) Identify and explain the barriers that limit or prevent Canadians from meaningfully participating in the digital economy (e.g. availability, quality, price, digital literacy, and concerns related to privacy and security). Identify which segments of the Canadian population are experiencing such barriers.

19. Ontario is concerned that many residents do not have access to ultra-high speed broadband Internet services that are comparable to the United States Google Gigabit fibre service of up to 1,000 Mbps. In particular, many communities in Ontario do not have sufficient broadband infrastructure, in the form of ultra high speed broadband Internet fibre cable network. For example, in urban Greater Toronto-Hamilton Area (GTHA), **** Perry and Uxbridge both have mean download speeds of less than 10Mbps3.

20. Based on 2014 CMR and 2011 population census, Ontario estimates that approximately 800,000 households in Canada do not have access to the Commission’s target download speed of 5 Mbps. This challenge is particularly acute in rural and remote areas – the 2014 CMR indicates that only 72% of rural households have access to the Commission’s target download speed.

21. Affordability is also a major concern, particularly for rural and remote areas and First Nations communities. The low population density in these areas means that the per user cost associated with developing and servicing broadband is higher than in urban areas. The CMR shows that rural areas generally spend up to $25 more per month for services than those in urban areas. Rural stakeholders in Ontario have expressed concerns that although high speed broadband may be available, the cost to receive these services is often prohibitive and out of reach for many of these residents.

d) Identify and explain any enablers that allow Canadians to meaningfully participate in the digital economy (e.g. connected devices and applications).

22. Enabling devices could include any electronic device with an affordable and fast connection to the public Internet. These devices can take the form of a desktop computer, laptop computer, tablet, smartphone, or even a non-traditional device like a video gaming console or smart television.

3
Ookla Net Index – May 2015

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 6 of 16

e) As Canada’s digital economy continues to grow and evolve during the next 5 to 10 years, which telecommunications services are Canadians expected to need to participate meaningfully? Specify how your responses to parts a) through d) above would change based on your answer.

23. Canadians will continue to require access to all of the services discussed in the previous answers. In addition, with the rapid shift to move traditional services online, Canadians will increasingly be accessing additional new services through their Internet connections.

24. Online commerce, where people can easily connect, trade, buy, sell products and exchange services, will continue to have a profound influence on the online landscape.

25. Ontario businesses are trending toward new disciplines and applications that require higher data throughput on our networks. Besides people connecting to other people on our networks, devices are connected and communicating to other devices in the Internet of Things (IoT) resulting in the transmission and acquisition of huge data volumes – Big Data.

26. In the IoT, currently there is an estimate of 24 billion connected devices with the prediction of 50 billion connected devices in year 20204 driving the need of bandwidth capacity increase to accommodate future Internet use. Other disruptive business and industry trends in Ontario that may require high digital network throughput will be the area of 3D Printing/Manufacturing, genomics, artificial intelligence, quantum computing and robotics.

2. The Commission’s current target speeds for broadband Internet access service are a minimum of 5 Mbps download and 1 Mbps upload, based on uses that consumers should reasonably expect to make of the Internet. Are these target speeds sufficient to meet the minimum needs of Canadians today? If not, what should the new targets be and what time frame would be reasonable to achieve these new targets?

27. Ontario believes that the Commission should revisit the current target access speeds to better reflect the needs of the digital economy.

28. The current CRTC target speeds of 5 Mbps download and 1 Mbps upload was a good target speed set in 2011 but is no longer sufficient to take full 4

Cisco Systems - 2014

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 7 of 16

advantage of media-rich online services such as e-commerce, e-learning, and e-health.

29. For example, the Commission has previously noted that a given household could simultaneously be engaged in four or five communications activities – using the phone, television, surfing the web and running a mobile wireless device. This use case would require a combined sustained data rate of 7.6 Mbps5, a data rate 50% higher than the Commission’s current target download speed. Moreover, this figure is conservative, given that web-based activities often incorporate high definition video streaming.

30. Ontario notes that other jurisdictions have recently revisited their target speeds, acknowledging that the importance of high speed broadband Internet to the digital economy.

31. In January 2015, the regulatory agency for telecommunications in the United States of America, the Federal Communications Commission (FCC), revised its broadband benchmark speeds to 25 Mbps download and 3 Mbps upload6.

The FCC’s previous standard set in 2010 was very close to the CRTC’s current target: 4 Mbps download and 1 Mbps upload.

32. In the United Kingdom, the Government recently reaffirmed its goal of providing 95% of the UK with download speeds of at least 24 Mbps by 20177.

In Germany, the Federal Government recently declared that all households in the country would have access to speeds of at least 50 Mbps by 20188; the **** government plans to use the proceeds of electromagnetic spectrum auctions to help meet this goal9.

33. The Commission should identify new targets that correspond with the usage patterns of Canadians. In doing so, the Commission should give consideration to the heavier data traffic associated with the newest generation of streaming Internet applications.

5

Assuming the home phone uses VoIP at 128 kilobits per second (kbps), the home television subscription service is Netflix (High-Super HD) at 5,638 kbps, Web surfing uses 1,500 kbps, and the mobile wireless device is streaming Google Play Music at 349 kbps over the home’s Internet connection through a local wireless network. We acknowledge, of course, that many online streaming services will automatically adjust their bitrates to suit the connection.

6

FCC Finds U.S. Broadband Deployment Not **** Pace [Online]. Available:

https://www.fcc.gov/document/fcc-finds-us-broadband-deployment-not-keeping-pace 7

Fixed Broadband: Policy and Speeds [Online]. Available:

http://researchbriefings.parliament.uk/ResearchBriefing/Summary/SN06643 8

Digital Agenda for Europe – Country Information – Germany [Online]. Available:

https://ec.europa.eu/digital-agenda/en/country-information-germany 9

Germany to Devote Spectrum Proceeds to Broadband Expansion [Online]. Available:

http://www.wirelessfederation.com/news/120518-germany-to-devote-spectrum-proceeds-to-broadband-expansion

Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 8 of 16

34. The Commission may also wish to consider adding a monthly download data usage cap allowance target to its speed targets. Along with upload and download target speeds, monthly download data usage cap allowances represent a major quantifiable feature in a broadband subscription. Low-income consumers might subscribe to plans with low data cap allowances out of necessity; these consumers might not be able to fully take advantage of important online services for fear of exceeding their plan’s data usage allowance.

3. Which services should be considered by the Commission as basic telecommunications services necessary for Canadians to be able to meaningfully participate in the digital economy? Explain why.

35. Ontario would encourage the Commission to consider the inclusion of broadband Internet as a basic telecommunications service. The Commission could use its own broadband target speeds to determine the threshold for qualifying as true “broadband Internet.”

36. As the breadth of online services continues to grow, the importance of having a broadband connection to the Internet will intensify.

37. By defining broadband Internet service as a basic telecommunications service, the Commission would be stating that broadband Internet access is at least as important as telephone service. Given the rapid convergence between the traditional telephone system and the Internet, it will become increasingly difficult for the CRTC and Canada’s service providers to separate the two systems in the regulatory environment.

3. a) Explain whether the underlying technology (e.g. cable, digital subscriber line, fibre, fixed wireless, mobile wireless, and satellite technology) should be a factor in defining whether a telecommunications service should be considered a basic service.

38. As much as possible, the Commission should be technology agnostic in its decisions. A technology neutral approach can help ensure that Canada’s telecommunications service providers are equitably affected by any changes in the regulatory regime.

39. The Commission may wish to consider making an exception for inclusion as basic service for satellite Internet access. Given the long distance that signals must travel between the subscriber, the satellite, and the terrestrial network operations centre, satellite communication features a lengthy inherent delay.

While not necessarily noticeable while using non-real-time or streaming services, the delay can severely disrupt the quality of real-time services.

40. In the Telecom Regulatory Policy CRTC 2013-711 (Northwestel Inc. – Regulatory Framework, Modernization Plan, and related matters) decision, Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 9 of 16

the Commission noted that “[satellite] services are generally more expensive than terrestrial retail Internet rates for comparable speeds. Further, the maximum speed for satellite retail Internet services is much lower than the maximum speed for terrestrial retail Internet services.” Based on these factors, the Commission decided that “satellite retail Internet services are not substitutes for terrestrial retail Internet services.” We recommend that the Commission continue to use its finding to state that “satellite retail Internet services are in a different relevant product market than terrestrial retail Internet services.”

b) Identify, with supporting rationale, the terms, conditions, and service characteristics under which basic telecommunications services should be provided. Should any obligations be placed on the provider(s) of these services? If so, what obligations and on which service provider(s)?

41. Ontario believes that the Commission should give consideration to an appropriate consumer rights framework for broadband Internet service. In so doing, the Commission may wish to review and adapt the consumer rights established under Telecom Decision CRTC 2006-52 (Statement of Consumer Rights).

c) What should be the prices for basic telecommunications services and how should these prices be determined? Provide rationale to support your answer.

42. The Commission should continue to abstain from regulating retail Internet prices wherever possible with exceptions in situations that the Commission deems necessary.

43. Prices for basic telecommunication services should be fair, affordable and determined by market forces. However, as the Commission has shown in its decision in Telecom Regulatory Policy CRTC 2013-711, that there may be circumstances in which certain retail Internet prices need to be regulated.

These circumstances could include insufficient competition and relatively high prices, particularly among underserved, unserved and some First Nations communities.

4. Can market forces and government funding be relied on to ensure that all Canadians have access to basic telecommunications services? What are the roles of the private sector and the various levels of government (federal, provincial, territorial, and municipal) in ensuring that investment in telecommunications infrastructure results in the availability of modern telecommunications services to all Canadians?

44. Ontario recognizes that Canada is a very large country with a mixture of densely populated urban areas and large rural and remote areas that feature Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 10 of 16

low population densities and challenging terrain. In that context, Canada’s telecommunications service providers and governments have made significant progress in promoting service throughout the country.

45. However, market forces and government funding to date have not fully met all the telecommunications needs of Canadians.

46. Approximately 800,000 households do not have access to the Commission’s current target speeds for broadband Internet access. If the Commission were to increase its target speeds as a result of this proceeding, this number could grow even higher. For example, if the Commission were to revise its download speed target to 25 Mbps, over 2.5 million households would be deemed to not have sufficient access to broadband Internet.

47. The role of the private sector is to continue providing excellent Internet access service. The private sector is responsible for designing, operating, and maintaining high quality broadband networks that allows consumers to participate in the digital economy. Private sector service providers also have a responsibility to continue treating their customers fairly, provide excellent customer service, offer their services at fair prices, and protect customer privacy.

48. All levels of government have provided funding to various broadband connectivity programs. For example, since 2007 the Government of Ontario has invested $170 million and leveraged more than $300 million of private, municipal, and federal funding to upgrade broadband infrastructure to deliver basic broadband speeds of at least 1.5 Mbps in rural and remote communities across Ontario.

49. Projects include the Eastern Ontario Regional Network which delivers speeds up to 10 Mbps to 91% of households in the target area; and the Northwestern Ontario Broadband Expansion Initiative which connected 20 remote First Nations’ communities through the construction of a 2,000 km long fibre optic network at speeds of up to 100 Mbps. These and other programs have been extremely successful in increasing the number of Canadians who have access to broadband Internet.

50. Ontario believes that the primary responsibility for building out broadband infrastructure remains with service providers and the citizens and businesses who will be accessing the service. However, governments should continue to strategically support priority broadband network infrastructure where it makes sense to do so, by leveraging both public and private sector partners.

51. Ontario recognizes that there may be opportunities for governments to support broadband connectivity by creating an enabling environment for broadband fibre build-outs. This could include entering into mutually beneficial Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 11 of 16

access agreements with service providers, providing timely and cost-effective access to rights of way so that they can install their infrastructure, and streamlining permitting requirements where it makes sense to do so.

5. What should be the Commission’s role in ensuring the availability of basic telecommunications services to all Canadians? What action, if any, should the Commission take where Canadians do not have access to telecommunications services that are considered to be basic services?

52. The Commission has a long history of successfully ensuring that basic telecommunications services are widely available to Canadians.

53. Ontario would encourage the Commission to continue to follow its policy direction of relying on market forces wherever possible to ensure that Canadians have affordable access to these services.

54. In circumstances where market forces have been unable to provide basic telecommunications services, the Commission could consider a regulatory approach.

55. The addition of broadband Internet service as a new basic telecommunications service would require changes to the Commission’s regulatory system. Ontario would encourage the Commission to develop a supporting regulatory regime that addresses those regions where the Commission determines that broadband Internet service at the Commission’s target speeds is not available.

56. Ontario would encourage the Commission to develop this framework in consultation with service providers, governments and stakeholders.

57. In order to determine the locations of need, the Commission should continue to gather network coverage data from Canada’s telecommunications service providers.

6. In Telecom Regulatory Policy 2011-291, the Commission stated that it would closely monitor developments in the industry regarding the achievement of its broadband Internet target speeds to determine whether regulatory intervention may be needed. What action, if any, should the Commission take in cases where its target speeds will not be achieved by the end of 2015?

58. In cases where service providers have not delivered broadband Internet that meets or exceeds the Commission’s target speeds, the Commission could consider coming up with a strategy that will require the affected service providers file a network modernization plan.

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59. Satellite services should not be considered in this directive.

60. Elements of network modernization plans could include: an outline of how the service provider’s network will be upgraded/expanded, timeline for implementation, and with other considerations such as reliability, redundancy, pricing, scalability, information security, and environmental factors.

7. In Telecom Regulatory Policy 2013-711, the Commission stated its intention to establish a mechanism, as required, in Northwestel’s operating territory to support the provision of modern telecommunications services.

Such a mechanism would fund capital infrastructure investment in transport facilities (e.g. fibre, microwave, and satellite), as well as the cost of maintaining and enhancing these facilities. The Commission considered that this mechanism should complement, and not replace, other investments from the private sector and governments, including public-private partnerships.

a) Explain, with supporting rationale, whether there is a need for the Commission to establish such a mechanism in Northwestel’s operating territory. As well, explain whether there is a need for such a mechanism in other regions of Canada.

61. We have no comments specific to Northwestel or Northwestel’s operating territory, as it falls outside of Ontario’s jurisdiction.

62. There are regions of Canada where broadband Internet service at the Commission’s target speeds is not available, despite many years of investments from the private sector and governments. The Commission should review whether the funding mechanism under consideration for the Northwestel operating territory might also be appropriate and beneficial for other underserved areas of the country.

63. In considering an appropriate funding mechanism for areas of the country needing broadband service, the Commission should endeavour to maximize consumer choice, affordability, and leverage market forces.

b) What impact would the establishment of such a mechanism have on private sector investment and government programs to fund the provision of modern telecommunications services?

64. The impact of a new funding mechanism would be dependent on the scope, scale and parameters of this mechanism. Should the Commission choose to extend the mechanism recommended in the Northwestel decision to other regions of the country, Ontario would encourage the Commission to consider how best to maximize consumer choice, affordability, and existing market forces.

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65. For example, a well-designed funding mechanism could serve to improve the business case of future network deployments, and thereby leverage additional investment from service providers. It could also increase the reach of many government programs, such as Industry Canada’s Connecting Canadians program.

8. What changes, if any, should be made to the obligation to serve and the basic service objective?

66. The Commission should consider adding broadband Internet service at the Commission’s target speeds to the basic service objective.

67. This revised basic service objective would only apply in areas where the Commission has determined with good reasons such as insufficient competitive behaviour, or in areas deemed necessary by the Commission.

9. Should broadband Internet service be defined as a basic telecommunications service? What other services, if any, should be defined as basic telecommunications services?

68. The Commission should consider including broadband Internet service at speeds of at least the Commission’s target speeds to be a basic telecommunications service.

10. What changes, if any, should be made to the existing local service subsidy regime? What resulting changes, if any, would be required to the existing regulatory frameworks (e.g. price cap regimes)?

69. Any changes to the local subsidy regime should be made with considerations to current and future market forces, market failures, lack of competition and the affordability of local services. The Commission decisions in Northwestel such as transport facilities subsidy looks promising and should be explored for adaption to other regions of the country.

11. What changes, if any, should be made to the contribution collection mechanism? Your response should address, with supporting rationale, which TSPs should be required to contribute to the NCF, which revenues should be contribution-eligible and which revenues, if any, should be excluded from the calculation of contribution-eligible revenues.

70. Should the Commission choose to establish a new funding mechanism for areas in need, the existing contribution collection mechanism may require appropriate modifications.

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71. Ontario would encourage the Commission to develop these modifications in consultation with industry, governments and stakeholders.

12. Should some or all services that are considered to be basic telecommunications services be subsidized? Explain, with supporting details, which services should be subsidized and under what circumstances.

72. Broadband Internet as a basic telecommunications services should be available to all Canadians for reasonable prices. A subsidy funding mechanism may be required to make this happen.

73. Ontario would encourage the Commission to develop these mechanisms in consultation with industry, governments and stakeholders.

74. The Commission should continue to monitor retail Internet prices and act, as necessary, to ensure that rates are reasonable. In markets where the Commission determines that it can no longer refrain from regulating rates, it should step in to regulate following its policy directions.

13. If there is a need to establish a new funding mechanism to support the provision of modern telecommunications services, describe how this mechanism would operate. Your response should address the mechanism described in Telecom Regulatory Policy 2013-711 for transport services and/or any other mechanism necessary to support modern telecommunications services across Canada. Your response should also address, but not necessarily be limited to, the following questions:

a) What types of infrastructure and/or services should be funded?

b) In which regions of Canada should funding be provided?

c) Which service providers should be eligible to receive funding, and how should eligibility for funding be determined (e.g. only one service provider per area, all service providers that meet certain conditions, wireless service providers, or service providers that win a competitive bidding process)?

d) How should the amount of funding be determined (e.g. based on costs to provide service or a competitive bidding process)?

e) What is the appropriate mechanism for distributing funding? For example, should this funding be (i) paid to the service provider based on revenues and costs, or (ii) awarded based on a competitive bidding process?

f) Should any infrastructure that is funded be available on a wholesale basis and, if so, under what terms and conditions?

g) Should the Commission set a maximum retail rate for any telecommunications service that is subsidized?

h) Should this mechanism replace the existing residential local wireline service subsidy?

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If so, explain how the existing subsidy should be eliminated, including details on any transition period. In addition, explain whether the small ILECs and/or Northwestel should be subject to any special considerations or modifications for this transition period.

75. Ontario would encourage the Commission to consider an appropriate funding mechanism that would address the needs of underserved areas of the country for broadband Internet service.

76. In so doing, the Commission may wish to consider previous telecom regulatory policies such as the decision to fund capital infrastructure investment in transport facilities in Northwestel’s operating territory.

77. In particular, the Commission may wish to consider a funding mechanism for transport facilities as a means of attracting service providers to provide retail Internet access service to underserved areas, by removing the high cost economic barrier of implementing fibre transport facilities to these areas.

78. The Commission should continue to engage with service providers, stakeholders and governments on specific elements of any funding mechanism considered. This would include issues related to eligibility, impacts on providers and customers, and promoting market competition and competitive neutrality.

79. We are also in receipt of the Commission’s letter, dated May 7, 2015, asking for additional information about any networks that we might have built to provide broadband Internet service to Ontario’s communities.

1. With respect to your organization’s telecommunications networks or facilities (built and/or owned) or telecommunications services offered, provide the following information:

a) The type of network that was built (e.g. fixed, mobile) along with the capacity to the various locations (e.g., schools, hotspots, end-users) and the technology used (e.g. fibre, cable, digital subscriber line, mobile, satellite, Wi-Fi);

b) The broadband service speeds available to subscribers, and the method used to determine that those speeds would meet subscribers’ needs;

c) The amount of investment and the funding mechanism(s) used;

d) The details of any partnership undertaken with other organizations for the network deployment;

e) The reasons behind your decision to deploy a broadband network; and Government of Ontario, Ministry of Economic Development, Employment and Infrastructure Submission to Telecom Notice of Consultation CRTC 2015-134 **** 16 of 16

f) Your approach to the use of the network by service providers (if applicable), including:

i. the company or companies that provide(s) retail service; and ii. a description of the method used to select the TSP (if there is a single service provider;

2. If retail services are available over your network, provide the following information:

a) The types of telecommunications service available (i.e. wireline voice, mobile wireless voice, wireline Internet and mobile wireless Internet) as well as the price for each service offering, and a description of the service characteristics included in each retail offering (e.g. speed, data usage, voice minutes);

b) The three most popular retail offerings for each type of service identified in a) above; and

c) For each category of telecommunications service provided (i.e. wireline voice, mobile wireless voice, wireline Internet and mobile wireless Internet), a description of the service offerings (e.g. discounted plans, special pricing) or initiatives (e.g. bill management tools, toll denial) available to assist certain segments of the population for which access or affordability may be a concern (e.g. seniors, low income Canadians, people with disabilities, students).

80. This request is not applicable to the Government of Ontario.

***End of document***

Intervention: Ontario Ministry of Economic Development, Employment and Infrastructure (Intervenor 239)

Document Name: 2015-134.223958.2394406.Intervention(1fbj@01!).html

Copie envoyée au demandeur et à tout autre intimé si applicable / Copy sent to applicant and to any respondent if applicable: Non/No

Intervention: Ontario Ministry of Economic Development, Employment and Infrastructure (Intervenor 239)

Document Name: 2015-134.223958.2394404.Intervention(1fbj801!).pdf