Intervention: CanWISP (Intervenor 260)

Document Name: 2015-134.223990.2394501.Intervention(1fblx01!).pdf
300 Berge du Canal, Suite 316
Lachine, Québec *** ***
Canada
*** ***
Branchons nos communautés
Connecting our communities
Ottawa, July 14th 2015
Mr. John Traversy
Secretary General
Canadian Radio-Television and
Telecommunications Commission
Ottawa, Ontario
Canada, *** ***
SUBJECT: CRTC consultation 2015-134 – CanWISP Submission
**** Mr. Traversy,

CanWISP is pleased to respond to this CRTC consultation in the form of the attached document.

Through this response, CanWISP, the Canadian Association of Wireless Internet Service Providers, would like to declare its intention to participate in the Public Hearing for this consultation.

We believe that we bring an important perspective to this consultation since our members provide high speed Internet access to more than 120,000 rural subscribers in Canada, in areas that are difficult to reach and are at the heart of the concerns of the consultation. The wireless Internet service provider industry in total reaches more than 200, 000 Internet subscribers.

We intend to fully participate in this process in order to raise the awareness of the challenges of serving rural Internet subscribers, and the solutions that our industry has developed.

Thank you in advance for your considerations.
Yours truly,
**** Duchcherer
Chairman of the Board
CanWISP
******@***.com
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Introduction:

CanWISP is an organization representing Canadian Wireless Internet Service Providers. Our members operate networks providing fixed wireless Internet access to households in rural areas throughout Canada – areas that the large telecom operators are not servicing. Our members’ business model allows them to serve areas of low density profitably and at low cost, unlike the large telecom service providers, whose business model is usually designed to optimize return to shareholders, and is not suited to provide service in these areas, even if they are close to large population centers.

Our members’ networks range in size from hundreds up to 20,000 subscribers, and supply high speed internet service as well as VoIP-based voice services, and video services. Overall, our 30 members provide service to around 120,000 subscribers in hard to reach rural areas. We estimate that the total number of subscribers serviced by similar wireless operators (more than 150 others) is around 115,000. The total subscriber base served by fixed wireless ISPs is thus well over 200,000; this represents a market of over 140M$ a year. More than 98% of the connections are fixed wireless.

**** operators have only 5 employees and the larger ones have up to 30. But overall, our members are very small businesses to small businesses.

Our members have very detailed knowledge of the areas where they provide services. They are committed to and involved in their communities. They are also very resourceful, providing carrier grade service at an acceptable cost while consuming very little radio frequency spectrum – certainly very little to no licensed spectrum.

Position:

CanWISP members want to establish two key points in our response to the current consultation:

1. CanWISP members prefer to have market forces dictate the deployment of services in under-served areas, without the allocation of operating subsidies to any service provider.

CanWISP members do believe, however, that targeted grants may be required for network construction in difficult to serve areas.

2. CanWISP members believe that the CRTC does have a role in ensuring the availability of spectrum to smaller rural operators, since wireless technology is the only currently viable high speed technology for low population density areas.

The fundamental arguments in support of these positions are outlined in the following paragraphs, while CanWISP’s answers to the commission’s questions are provided in the following sections of this document.

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Allocation of Subsidies

CanWISP members have all expressed reservations regarding the allocation of subsidies.

Historically, most of our members, and specifically the smaller ones, have suffered from unfair competition caused by subsidies distributed by higher level of governments. Our members feel that their voice and efforts are not taken into consideration when decisions are taken in government; subsidies are allocated to large organization to provide services in areas that are in fact already being serviced by our members.

Because of their small size, CanWISP members have little means to keep up with the multiple requirements from higher level of governments, and are at disadvantage in obtaining subsidies, despite often being the best-placed to actually deliver services to subscribers. In other words, CanWISP members believe that the subsidy “playing field” is skewed to favour larger providers, and subsidies flow to those who are best able to “play the subsidy game”, as opposed to those who can most effectively serve rural communities.

However, our members also recognize that there are hard to reach locations that are expensive to service even by their dynamic companies and if a better class of service than satellite is to be provided (low latency services, for example), targeted grants are necessary to build the infrastructure.

To make sure that our members are not at a disadvantage when subsidies are allocated, we need the CRTC and Industry Canada to work at local level applying local solutions and not only at national level applying macro level solutions that only macro companies can fulfill. CanWISP is certainly ready to help in these matters, interfacing with the CRTC and Industry Canada directly if need be.

Spectrum Access

Beyond a level playing field for operating subsidies, CanWISP members require improved access to spectrum to offer services that meet the evolving needs of rural communities. CanWISP members believe that the CRTC has a role to play in ensuring spectrum access to service providers that are actively offering service in a timely and affordable manner to rural residents.

Our members’ networks, being primarily wireless, rely on spectrum resources as their lifeblood.

However, given the current spectrum situation in Canada, where spectrum resources have been allocated by means of auctions, our members have effectively been shut out of the spectrum market, despite the significant role they play in providing broadband Internet service to rural areas.

Spectrum that could be put to valuable use in rural areas lies idle because it is held by large telecom operators that bought it for use in urban areas and do not have the intention to use it for rural Internet service. The well-known case of the 3.5 GHz band is a case in point; this spectrum has gone effectively unused for 10 years, despite it being assigned to large national telecom operators.

In the meantime, under the leadership of agile operators an entire industry has sprung up around the unlicensed bands, which have now reached their limits. Our members believe that if they are **** | 4

given access to spectrum resources, they have the means to radically improve Internet access for inhabitants of rural Canada.

To resolve the current lack of spectrum for WISPs to improve their service offer in rural areas, CanWISP members propose that:

1. In the short term, and only in rural areas, the CRTC should impose upon inactive spectrum holders the obligation to permit its use by active operators, for a defined period of time.

2. In the longer term, we believe that the CRTC may allocate subsidies for spectrum costs for small service providers in rural areas. The cost of spectrum licenses are a significant barrier to entry to CanWISP members, particularly for smaller operators, who may be unable to afford to buy licenced spectrum, and therefore are unable to even reach the stage of asking for subsidies at a later time to establish service.

General Request:

Finally, in order to understand what areas are being discussed and addresses by the Commission, CanWISP would like the CRTC to publish a map of the HCSA in both the forborne and regulated exchanges.

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Answers to questions:

The following answers reflect the perspective of CanWISP, as the representative of the Wireless Internet Service Providers of Canada, on the current Consultation. Our members’ perspective is based on their experience as rural telecom service providers.

Canadians’ evolving needs for telecommunications services

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?

CanWISP: Subscribers to our rural networks have the same needs as subscribers in urban areas, and very often rely on the Internet to perform transactions rather than physically travelling to a point of service. E-government, E-commerce, e-banking, telework, distance education, and where available e-health and telehealth are all services used by CanWISP’s rural subscribers. Moreover, farmers very often rely on Internet to check market prices of their production, order their different working material, etc. Rural businesses, such as lumber mills, outfitters, retail stores, and others all rely on fixed wireless Internet services.

In addition, the Internet is becoming the primary source for all types of in-home entertainment services, as it is for subscribers in urban areas. Online television, Youtube, and other video services are prevalent in rural areas. However, bandwidth limitations limit the take-up of video services such as Netflix or other similar services. Access to news and information services such as newspapers and major news services such as the CBC/Radio Canada, and CTV is increasingly, if not yet predominantly mediated through the Internet. In the case of music, in particular, access to content is now predominantly through the Internet.

Internet service is slowly reaching all locations, but the demand for more bandwidth is rapidly increasing as more and more services (e.g. television) migrate online.

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?

CanWISP: Our residential customers are requesting more and more bandwidth as digital literacy increases, and subscribers are watching more on demand programs. Our business subscribers, and the increasing number of home workers, have a critical requirement for low latency Internet **** | 6

connectivity to lower their phone costs by switching to VoIP services, and to ensure that their transactions are as fast as possible.

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.

CanWISP: CanWISP members think that they are enablers for Canadians living in rural areas to participate meaningfully in the digital economy by making bandwidth affordable to these areas.

We are at the edge of the coverage of the large providers and extending high speed internet.

CanWISP members have been successful in bringing high speed Internet access to many areas that were previously without service. Today we see the main challenge to participation in the digital economy as the continued need for greater and greater bandwidth. With our experience, we can say that digital literacy is lower in the rural areas but it is definitely catching up to national levels. The young rural generation going to school are absorbing knowledge from the schools and from their peers, and are really the ones demanding efficient, high capacity Internet access.

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

CanWISP: CanWISP members believe that the enablers of the digital economy are largely available in rural areas: PCs, smartphones, tablets, and other connected devices; as well as the digital literacy necessary to use them. We believe that what is still lacking are the networks to support these connected devices and their increasingly demanding users.

CanWISP members recognize that mobile networks are important in rural areas to support both every-day and emergency voice connections; as well as the so-called “App Economy” based on software and services centered on mobile platforms such as smartphones and tablets; and future innovations like connected cars and the Internet of Things (IoT). However, we are convinced that mobile networks can’t replace home Internet access. The types of devices (e.g. televisions, PCs, home automation devices, and in future appliances) are distinct from mobile networks. The volume of data supported by fixed networks also far exceeds that supported by mobile networks. Moreover, families need to pay a reasonable amount for their Internet service, which must be accessible to all age groups – both the very young and the very old. It is in the family setting that parents teach their young kids how to safely use Internet, and it is in this setting that parents apply some control.

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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.

CanWISP: No one can predict which service or application will be important over a longer time frame of 5 to 10 years. However, based on trends observed over the past 15 years, CanWISP foresees that the demand for bandwidth on members’ networks will continue to grow exponentially. CanWISP members believe that a fast, high-capacity and low latency residential Internet access, as well as access to a high speed mobile network, are both necessary for full participation in the evolving digital economy. **** types of networks require more speed, as the number of connected devices is exploding. While large telecom providers (operators of mobile networks) are requesting more spectrum to service dense areas, CanWISP is requesting more spectrum to service rural areas.

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?

CanWISP: Today, Internet access is used in many ways. In general, the services requiring higher throughput are video services. We know that the introduction of Netflix has fired up the demand for throughput and download capacities – our members have seen its impact on their networks.

And we note that for people living in rural areas, getting access to a large number of programs without driving long distances to rent a movie or get to a library is a real advantage. Aside from culture and art, the Internet also gives access to multiple video services such as Youtube, for example, which have become a real treasure trove of “how-to” information for rural residents; if you want to know how to knit a sweater or repair your tractor, Youtube has a wealth of information. Rural residents must often be self-reliant, and this kind of video service has proven to be very important.

To truly get rural communities participating in society at the same level as the urban population, Internet should be available at speeds supporting at least 2 TV sets in the home watching videos.

Therefore CanWISP suggests that 10Mbps should be targeted in the 5 to 7 year timeframe.

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The Commission’s role regarding access to basic telecommunications services 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.

CanWISP : CanWISP members are of the opinion that:

- Voice service is still essential for meaningful participation in the society.

Voice is a simple means of transmitting information rapidly and carries more information than just typed words. It is important to keep this asset.

Our members’ networks can carry Voice over IP services and most of our members offer this service. However, CanWISP members are hesitant to call voice a basic service since this definition carries specific meaning in terms of service obligations and subsidy allocations.

- High speed internet up to 5 Mbps must also be considered an essential service for participation in the digital economy, for the reasons stated below:

1. In order for all Canadians to live in the same world at the same level, they need to have access to the same information and the same tools.

2. Giving access to minimum speeds in rural or remote areas is the best tool to encourage Canadians to occupy all the Canadian territory.

- However, our members are unequivocal in their position: considering Internet access as an essential service MUST not mean that subsidies have to be allocated to large corporation to service remote areas.

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.

CanWISP: Technology is a tool and should not dictate the type of service. Recent experience has shown that subscribers themselves increasingly overlook technology as an integral part of their concept of telecommunications services. Examples include the increasing substitution of wireline voice services by mobile phones, and the so-called “cord cutting” phenomenon where cable TV subscribers replace that service by on-demand video services delivered through the Internet.

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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)?

CanWISP: Under the current regime, ILECs have the obligation to offer voice services in HCSA, and benefit from subsidies to do so. In addition, CanWISP members, as well as other ISPs, also provide voice service in many HCSA. In areas where multiple service providers can offer voice services, CanWISP believes that no service obligation should be enforced. As for broadband services, competition is already present in most of Canada, since most of the territory that our members cover is already serviced by satellite, which offers a minimum service, while CanWISP members offer a higher class, more cost-effective service. CanWISP’s position is that there should not be any obligations put on broadband service providers, since competition between satellite services and WISPs is already adequate to ensure a high quality of service.

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

CanWISP: In most rural areas served by CanWISP members, the price for basic telecommunications should be left to the market to decide. The ceiling price for an Internet connection is set by the price of satellite service. This service is an effective cap on prices, since in most areas, residents can choose a better internet service at a lesser cost with one of CanWISP’s members. The price of a basic voice service from a practical perspective, is set by mobile access, which, according to the latest CRTC report is available to 99% of the households. Residents can also elect to have a home phone with less expensive voices services from CanWISP members, if available.

Note that the preceding argument does not apply to the Northern territories where fiber optic links to major Internet service providers are not available.

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?

CanWISP: Members of CanWISP are of the opinion that market forces can be relied on given that a true level playing field is established. This involves:

- fair access to subsidies with a more local approach than large projects - Consultation on behalf of the CRTC and Industry Canada with local government (mostly municipal)

- Consultation on behalf of the CRTC and Industry Canada with local small telecom service providers

- fair access to spectrum with pricing levels accessible to small enterprises for both backhaul and access

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The roles should be the following:

- Federal government is responsible to lay out the rules and policies to ensure that all companies have the same chances of success.

- Federal government should also have a clear picture of where broadband service is available. To this end, the federal government should:

1. Create an accurate and detailed map of Broadband service availability and publish it online permanently

2. To create this map, the government should do investigate at the local level to find out who the providers are and map their coverage Note: The Quebec Provincial government used this method

to determine coverage in its territory. It has the advantage of being accurate and taking into consideration all the

providers. Subsidies provided did not overlap coverage
already in place, avoiding significant un-necessary
government expenditures.

- Private sector: aggregate the demand (new connections and increase in bandwidth) and plan for service and ask for subsidies to build infrastructure if required.

- Municipal governments must have a voice as to whom subsidies should be allocated. They must also help with the process of installation of infrastructure (like tower permits, etc.)

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?

CanWISP: The Commission must ensure that essential telecommunication services be available to all Canadians. It should do so by consulting local governments, ISPs (large and small) and Canadians in general to make sure that information about availability and grade of service offered by all service providers is available for all regions of Canada. The Commission should continue to subsidize basic voice services through industry-sourced funds in areas where no alternatives, such as mobile service or VoIP services are available. CanWISP believes that the CRTC also has a similar role to play in the distribution of spectrum, which is the key resource for the economical deployment of high speed networks, in rural areas. We propose that the CRTC obtain, on behalf of rural wireless Internet service providers, sufficient spectrum resources to deploy high speed wireless access and backhaul networks. This spectrum should be assigned to the service provider best able to offer service in rural areas, as a type of “in-kind” subsidy. Since most of the spectrum resources belong to the major telecommunications companies, getting spectrum resources from these providers can be considered as a subsidy to the rural industry.

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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?

CanWISP: The Commission should work closely with IC, local governments, and local and national service providers to get the right market coverage information of what is covered and what will be covered by the Connecting Canadians Program and then allocate construction subsidies to get markets up to date. Subsidies should be made available not only to large telecom service providers, but also and perhaps preferentially to local service providers that are already providing services in rural areas. CanWISP is willing to help communications with our members to clearly establish the areas and subscribers served by wireless Internet service providers, and the grade of service available.

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.

CanWISP: Our members don’t offer service in this territory. We don’t think that there is a need for such mechanism elsewhere except for territories or areas where there is only one backhaul (fibre connection to Internet) service provider. In that case, our members have noticed that the backhaul pricing is very high, forcing our members to offer service at a high cost to the end subscribers.

Either a second Internet fibre provider should receive subsidies or the Internet connection pricing should be fixed to the same level as rural areas around large cities.

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?

CanWISP: Having a second provider of fibre backhaul to the Internet will have a positive impact on the pricing for residential and business customers. Competition in this field has always shown to be profitable to the end subscriber.

http://www.crtc.gc.ca/eng/archive/2011/2011-291.htm
http://www.crtc.gc.ca/eng/archive/2013/2013-711.htm
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Regulatory measures for basic telecommunications services

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

CanWISP: CanWISP members’ position is that the obligation to serve and the basic service objective should apply only to voice service in areas where no acceptable service is available.

 Voice services are distinct from broadband services because of their function in emergencies. We therefore believe that the obligation to serve should remain in place for voice services only.

 In the territories that we cover, voice services are available from several providers, including ILECs, WISPs, and mobile operators. In most cases, subscribers have access to both fixed (wired or wireless) and mobile voice service. In today’s environment, mobile voice services and VoIP based services can provide high-quality voice access. Therefore, we believe that the obligation to serve is necessary only locations where a single service provider, or no service provider, exists.

 In the case of broadband services in areas where wireless ISPs are active, coverage of almost all subscribers is possible via the wireless network. In some cases where coverage is difficult, the customer has the choice to pay for better receiving facilities (for example, a tower for the receiving antenna); or to pay monthly fees for satellite service. In both cases, we believe that no obligation to serve is necessary. What is required to ensure that the customer has the best available Internet service, at the lowest monthly cost, are direct subsidies for the construction of the wireless network and access to optimum spectrum for the WISP; and subsidies to the customer for construction of improved receiving facilities in cases where they are necessary.

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

CanWISP: Our members are of the opinion that broadband Internet service should not be defined as a basic telecommunications service. Although we do believe that Internet service is essential for participation in modern-day economic and cultural life, our experience demonstrates that the private sector is motivated to supply service, and is able to supply service in virtually all instances, and it is not necessary for the CRTC to define it as a basic service and subsidize its operations.

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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)?

CanWISP: The existing subsidy regime is founded on two principles:

i. Basic (i.e. subsidized) consist only of voice services

ii. Basic (voice) service must be provide over wired facilities CanWISP is of the opinion that basic voice services should not be limited to wired access only. This reflects overall trends away from traditional wired voice service and towards wireless voice services and VoIP services.

Moreover, CanWISP believes that where a cellular phone service or a VoIP service can be provided by a WISP or by other means, there is no need to subsidize wired service.

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.

CanWISP: The regime has proven to be working for areas in need so it does not need to be changed or modified for voice services.

However, as we have already expressed, CanWISP proposes that the large providers should contribute with in-kind spectrum subsidies to the rural operators (that is, temporary rights to use spectrum) so that better service can be provided to the rural subscribers.

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.

CanWISP: The basic voice POTS service should be subsidized if it’s not available through cellular or VoIP.

As we have stated in our response to questions 8 and 9, CanWISP believes that private industry is successfully serving rural communities’ needs for Internet access. We do not believe operating subsidies are required for broadband Internet service.

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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:

CanWISP: Our members are of the opinion that two key funding mechanisms are required:

 Direct grants for infrastructure, either for coverage expansion or for major equipment upgrades

 Funding in terms of in kind spectrum subsidies is also required to permit capacity expansion.

To cater to the upgrade from 5Mbps to 10Mbps of minimum service for the next years, our members are foreseeing large investments required on their networks. Doubling the capacity means doubling the equipment in a wireless world.

CanWISP believes that regular yearly funding is required so that each network can be upgraded or extended as needs arise. This contrasts to today’s five-year rounds of funding which only allows service providers to address network upgrades sporadically, and well after increased needs have arisen. Moreover, the 5-year funding cycle may provoke the perception that it is linked to election periods.

CanWISP estimates that a provision of 45M$ to 65M$ per year of funding available to our members (without taking into consideration the Northern Territories) would be adequate.

This will allow our members to keep up with the increasing bandwidth demand and also expanding in territories that have not been serviced yet.

We propose that funding would come from the Industry with a regime similar to that for voice, i.e. a percentage of Internet business of the high revenue companies. The advantage of this source of funding has been proven to be efficient and it’s not linked to any political decisions so it’s stable. It also has a very small to no impact on the Industry.

As for the in kind spectrum funding, large operators are holding on to high frequency like 3.5GHz spectrum (as well as 2.3GHz and 2.5GHz in some cases) that is unused in most areas. This spectrum will be valuable to the large telecom operators in areas of high population density for mobile operations but certainly not in rural areas where subscriber density is too low. CanWISP would welcome the opportunity to enter into a dialogue with the large providers to establish a mechanism to share the spectrum between rural and densely populated areas.

The mechanism to get access to spectrum should be kept simple and be initiated by a WISP to a large spectrum owner. In principle, if the spectrum owner does not have subscribers in the defined rural area, he would have to provide the spectrum to the WISP. Technical guidelines should be established in advance by IC and the CRTC.

http://www.crtc.gc.ca/eng/archive/2013/2013-711.htm
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a) What types of infrastructure and/or services should be funded?

CanWISP: Funding should be provided for infrastructure to improve both access and backhaul links, to allow greater access speeds, monthly capacities, and coverage extension. Spectrum acquisition and spectrum licences should also be subsidized.

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

CanWISP: Funding should be provided for all rural areas that don’t have the minimum service (5Mbps/1Mbps) now and 10Mbps/2Mbps in 5 years. Industry Canada should continue to make a map of the available service and get inputs from the different service providers. This map should be the reference to take decisions.

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)?

CanWISP: If there is no provider for a certain area, a provider should be allowed to request a subsidy to service the areas. If there is only one provider, it should be allowed to have subsidies to upgrade its service. Finally, if there are multiple providers, a bidding process should be put in place unless a provider volunteers to offer the minimum grade of service without subsidies.

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

CanWISP: **** depending on the situation above. If a provider is alone on its area, then cost should prevail. If there are multiple providers, a bidding process should be used.

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?

CanWISP: We don’t foresee the need for funding to support operations. Therefore distribution should be done on either a request from a provider or through a bidding process only for infrastructure.

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

CanWISP: Adding wholesale will have a big burden to our members. If wholesale service is a need, then it should be financed by the wholesale business itself.

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

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CanWISP: Since our members are already competing against satellite services, we think that the business will self-regulate.

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

CanWISP: CanWISP members are ready to provide telephony service on our current infrastructure. As for broadband, it should replace the actual subsidies.

Intervention: CanWISP (Intervenor 260)

Document Name: 2015-134.223990.2394502.Intervention(1fbly01!).html

Raisons pour comparaitre / Reasons for appearanceCanWISP, Canadian Association of Wireless Internet Service Providers, have quietly been delivering broadband solutions to rural Canadians for a number of years. We would like to have an opportunity to discuss how our industry will continue to deliver services (including voice) to areas of Canada that traditional carriers have found to be unprofitable.