Final Submission : Intervenor 414

Document Name: 2015-134.226842.2605219.Final Submission (1j%7701!).html

The attached document contains my final comments subsequent to my appearance at the CRTC hearings on basic telecommunications services, on **** 25th 2016. My comments support the CRTC legislating in this area, and are in opposition to the testimony of Canadian Telecom companies that testified that 5 MBPS download/1 MBPS upload speeds are sufficient for most Canadians and that satellite Internet is adequate to fill the rural gaps that they are unwilling to serve. I refute these points based on my own experience with poor performance of Satellite Internet nominally at 10 MBPS down/1 MBPS up.Raisons pour comparaitre / Reasons for appearanceShould subsequent hearing sessions take place within this intervention, I request to appear in order to ensure my comments are on the record, and to be able to answer any questions commissioners may have about my comments. I believe specifically that it is important for me to demonstrate to commissioners that what the Telecom companies are suggesting is completely out of touch with the actual requirements of rural Canadians.

Final Submission : Intervenor 414

Document Name: 2015-134.226842.2605218.Final Submission (1j%7601!).pdf

Re: Review of basic telecommunications services, Final Submission Lac- Brome, Quebec, May 18th 2016

Mr. Chairman, Commissioners;

It was grateful for the opportunity to take part in the hearings concerning a National Broadband Internet Strategy for Canada. In addition to my own presentation, I was able to hear the other presentations on the day I attended, as well as those on previous and subsequent days via the CPAC channel.

Throughout the hearings, I was able to determine that my situation as a rural Internet consumer residing only a few kilometers from reliable broadband Internet was not unique, but that we are scattered over vast distances thus making it difficult to join forces and be heard. I therefore particularly appreciated the opportunity to present my situation in person.

I was also able to take note of the submissions from major telecommunications providers that were proposing 5 MBPS download and 1 MBPS upload as meeting the minimum standards and consumer needs for broadband Internet. Moreover, it appeared that many of them, e.g. Telus, hope to rely on Xplornet satellite to fill in the gaps in coverage. I believe that adopting this as a standard will ensure that rural Canadians remain economically disadvantaged by being unable to fully participate in the digital economy.

My impression from the hearings was that there are four separate questions that the CRTC needs to consider:

1) Should the Internet be considered a public utility?

2) What is the minimum Internet performance that will enable all Canadian families to have an adequate level of broadband access for normal family use?

3) What is the minimum infrastructure performance level that is required in rural and remote areas of Canada to ensure that these regions are economically competitive with the rest of the country and that knowledge workers, professionals and entrepreneurs in those parts of Canada can contribute from their location?

4) What is the minimum access level for economically disadvantaged Canadians that should be subsidized so all Canadians can afford to be connected?

To answer these questions, we need to consider the types of on-line tasks that are required in all three cases. For the purpose of this submission, I will consider that the usage in the second and last case will be similar and will therefore combine them, assuming that the only difference is the issue of subsidy for those unable to afford this level of connectivity.

1) Should the Internet be considered a public utility?

Consider that the following are now true:

• It is impossible to file a job application for many open positions other than by Internet

• It is impossible to search for most jobs without the Internet • It is difficult to plan travel without the Internet; the number of travel agencies is decreasing as use of the Internet increases • Many smaller communities have lost their bank branches, making on-line banking essential

• The default means for answering the 2016 Census is the Internet • La Presse, the ****-language Montreal daily, ceased publishing its daily paper edition in January 2016; during weekdays, the only way of reading this daily is on-line.

• Schools require that pupils use the Internet for homework and research for projects

• Many employers require that employees be able to access e-mail and other applications from home

It is thus increasingly obvious that the Internet is quickly becoming, if it already hasn’t become, an essential service and an essential part of our public infrastructure to a degree similar to what hydro, landline telephone service, television and radio were 30 years ago.

2) What is the minimum Internet performance for Canadian families?

In order to answer this question, we must examine the typical tasks that will be carried on-line by Canadian families. A by no means complete list of such tasks and requirements will likely include:

• On-line banking and financial transactions • Job searches

• On-line research:
o For homework/education
o For travel
o For health care information
o For professional development
o Consumer information
• Searching for information
• Basic tele-health
• Viewing short on-line videos
• On-line shopping
• Entertainment (movies, music, etc.)

• Multi-device support (computers, tablets, smart phones) o Several family members on-line at the same time o One or more children doing research for educational purposes at the same time.

My own Xplornet satellite connection delivers:

• Nominally 10 MBPS download/1 MBPS upload

o Reality: on average 22% of download speed reached at peak times

o Reality: on average 50% of upload speed reached at any given time

o 800-1000 ms latency

o Severe curtailment of speed when the “fair access policy” determines “excessive use”.

• 50 GB data per month with $2 per GB overage charges when exceeding that level

Currently as empty-nesters, my wife and I share this connection, with occasional visits from other family members; to date this connection has been inadequate to support our most basic needs:

• At peak times, two devices (typically a computer and a tablet) can only be supported for the most basic surfing tasks:

o **** loading is very slow with page load errors o Images are very slow to load

o Watching a YouTube video is impossible
o VOIP or Skype telephony is impossible

o Large downloads make the connection unusable by initiating the “fair access policy” which slows down the connection to dial-up speeds, making software and operating system updates a challenge

o Having other devices online from visiting family members renders the connection practically unusable

• At other times the video component of Skype cannot be used • Satellite latency makes voice calls difficult, with gaps, delays and dropped connections

• Satellite transmission and reception is subject to atmospheric conditions with significant degradation of performance during heavy rain, snow and electrical storms.

I would therefore conclude that with no significant performance degradation at peak times (80% of maximum), a family of 4 would require a 25 MBPS download/3 MBPS upload connection at less than 50 ms latency, with 100 GB of monthly data usage, and a couple, would require a 10/1 connection also at less than 50 ms latency, with 60 GB data monthly.

Only for a single individual using the Internet in the above manner, would a 5/1 connection provide a bare minimum of functionality.

3) What is the minimum infrastructure performance level that is required in rural Canada?

Rural Canada also includes farms, small, medium and large enterprises, tourist facilities (inns, bed & breakfasts, resorts), knowledge workers working from home, and professionals operating individually or in clinics or offices. In addition to carrying out the typical uses of a family, businesses and knowledge workers may also need conduct the following additional typical tasks:

• On-line reservations
• Multiple users on line concurrently:
o Employees

o Guests of tourist facilities such as B&Bs which may require support for multiple concurrent devices at peak times • Managing electronic medical records:

o Remote access of records

o Accessing provincial health care records systems (e.g. the Dossier Santé Québec)

o Accessing hospital systems from clinics/private practices (e.g.

for lab results, discharge reports, requisitions) o Electronic prescriptions

• E-commerce

• Large downloads and uploads of creative work:

o Image files
o Software applications
o Software code
o Video files
• VOIP telephony
• On-line video conferencing
• Telematics for remote/farm equipment
• Remote video surveillance

It should be clear from the above uses, and the testimony of rural Canadians at the hearings in ****, that the proposed standard of 5/1 suggested by the Telecom companies is completely inadequate to fulfill these requirements.

Nor would “aspirational” goals solve the immediate needs of rural Canadians who need to do much more than just simple Internet surfing.

Moreover, to rely on satellite technology to fulfill these needs, based on current speeds, degradation of service in peak times and foul weather do not meet these needs with current technology. While satellite may be the only technically feasible solution in remote areas at the present time, it is a totally unacceptable solution for last-mile users who are within only a few kilometers of true affordable broadband service, such as my current situation which I detailed in my **** 25th presentation.

In order to be able to carry out the above tasks, the infrastructure must be able to handle it. Even though not all rural customers may need or wish to pay for the service level necessary to fulfill the above requirements, the infrastructure needs to meet the needs of those who do require the ability to perform these tasks. It is my opinion that the following infrastructure capacity is required for all Canadians, as soon as possible:

• 100 MBPS down/10 up
• Less than 50 ms latency

• More than 120 GB data capacity, with unlimited data plans for large consumers (businesses, knowledge workers, professionals).

A typical small farm, small to mid-sized business, or family of 4 with one or two family members working from home would probably have their needs met by purchasing packages in the 25/3 to 50/5 speed range; a larger business, large farm, professional or knowledge worker would likely need the full 100 MBPS. **** families and individuals who do not consume much Internet capacity would probably be purchase packages in the 5/1 to 10/1 range.

4) What is the minimum access level for economically-disadvantaged Canadians?

The first point to note is that usable broadband internet must first be available everywhere before this question can be fully answered. The above two questions are essentially infrastructure questions while this one is a social policy question that is dependent on the availability of true broadband Internet everywhere in Canada. Regardless of how this issue is resolved, economically-disadvantaged have the same technical needs as other Canadians. Regardless of the level at which this question is resolved (federal, provincial or local), the following should be the minimum performance levels that should be considered for the economically-disadvantaged:

• Subsidy for a 5/1 connection for individuals • Subsidy to 10/1 for families of 2-3 members living in the same household

• Subsidy of 25/3 for larger families (4 or more) under the same roof, or a disadvantaged Canadian attempting to start a small business from home or on his or her property.


In conclusion, it would appear that if rural Canadians are to be full participants in the Canadian economy, reliable and affordable broadband Internet must be available to all Canadians regardless of location, and within reasonable technical limitations. For rural areas where land infrastructure is already broadly available (hydro and telephone lines and nearby existing broadband Internet), I believe that the following targets are reasonable, achievable and should be mandated by the CRTC:

• The minimum level of acceptable performance for a family of 4 or a small business and which should be available within 2 years to all Canadians where proximal physical infrastructure is available should be:

o 25 MBPS down/3 MBPS up
o less than 50 ms latency

o Minimum 60 GB of monthly data with unlimited data plans available • The real target (not aspirational) should be to ensure all rural Canadians have access to 100 MBPS down/10 up/50 ms latency/100+ GB data within 5 years

• Telecom companies should not rely on Xplornet satellite to “fill the gaps” in rural coverage; satellite performance with current technology simply isn’t competitive with wired solutions; satellite solutions should be limited to areas not reachable by physical infrastructure.

• All Canadians should be able to afford packages with the following performance levels, and should be subsidized based on financial need:

o 5 MBPS down/1 up for individuals

o 10 MBPS down/1 up for families of 2-3 living in the same home o 25 MBPS down/3 up for families of 4 or more living in the same home, or economically-disadvantaged Canadians setting up a home-based small business.

• All levels of government should be involved in establishing needs, and considering novel ways of financing the necessary infrastructure:

o Subsidies

o ****-term financing through property taxes, such as a $200 a year surcharge to finance the infrastructure at preferred interest rates, such as is currently done with other public utilities such as sewage, water and hydro.

It is to me painfully obvious that the 5/1 standard proposed by the Telecom companies, coupled with their excessive reliance on satellite to fill the gaps even in areas where physical infrastructure exists to bring in service levels that are often available only a few kilometres away, will ensure that rural Canadians remain well behind fellow citizens living in urban and suburban areas. A standard of 5/1, far from being adequate, is 5-10 years behind urban standards, and is the modern-day equivalent of having rural Canadians remain on party-line telephones. Reliable broadband Internet is every bit as essential today as POTS and hydro were 70 years ago.

Canadian Telecom companies have failed and continue to fail in their duty of public stewardship, and require government legislation to complete a task that is long overdue. The CRTC can be of tremendous assistance not just in establishing the necessary regulations, but also in helping to coordinate efforts at all levels of government.

Once again I am grateful for the opportunity to participate in this process and am available and willing to assist the CRTC in any way I can on this important file.

Respectfully yours,
**** Gammon, B. Sc.
Lac-Brome, QC.