Intervention: OneWeb, Ltd.

Document Name: 2015-134.223976.2394469.Intervention(1fbl101!).pdf
OneWeb, Ltd.
13 **** Street
St. Helier JE4 5UT, Jersey
Date: July 14, 2015
Submitted electronically
Mr. John Traversy
Secretary General
Canadian Radio-television
and Telecommunications Commission
Ottawa, Ontario *** ***
**** Sir/Madam,

Re: OneWeb’s Response to Appendix B of Telecom Notice of Consultation CRTC 2015-134, Review of basic telecommunications services, CRTC File number: 8663-C12-201503186 OneWeb, Ltd. (“OneWeb”) has the honor of responding to Telecom Notice of Consultation CRTC 2015-134 published on 9 **** 2015 (as amended by Notice 2015-134-1) (the “Notice”). Please find our responses to Appendix B of the Notice in the Attachment below.

OneWeb is a global communications company building a global network to provide low latency broadband to rural and remote areas. Starting in 2019, the network will operate globally via an initial constellation of 648 low earth orbiting satellites providing broadband to end-users anywhere in the world through small, affordable terminals. In particular, OneWeb will have the opportunity to address Canadian broadband access requirements for underserved and unconnected communities in rural and remote areas, with speed and capacity comparable to, if not better than, that offered today in urban areas.

In accordance with paragraph 47 of the Notice, I request the opportunity to appear at the public hearing.

Sincerely Yours,
**** Wyler
Founder and CEO
OneWeb, Ltd
Please direct all correspondence to ******@***.com

Attachment: OneWeb’s Response to Appendix B of the Telecom Notice of Consultation CRTC 2015-134.

1 www.oneweb.net

ATTACHMENT
OneWeb’s Response to Appendix B of
Review of basic telecommunications services,
Telecom Notice of Consultation CRTC 2015-134
File number: 8663-C12-201503186
July 14, 2015

OneWeb’s Response to Telecom Notice of Consultation CRTC 2015-134 Below are OneWeb’s responses to the questions posed in Appendix B of the above-referenced Notice.

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?

Our Response

Telecommunications services provide the means for connecting individuals, businesses and government services, and are key to economic growth.

Who Types of Communications
Citizens Individuals communicating at any
point in time and space with one
another to access information
necessary for everyday life
e.g., e-commerce, accessing health
records, paying bills, social media,
school work, watching films and
TV programs live or on a demand
basis
Businesses Front Office / **** Office
employees
e.g., conducting everyday
commercial transactions with
customer’s emails, telephone calls,
online chat, and social media
Suppliers e.g., making orders, tracking a
particular shipment, e-fax
Employees e.g., working from home,
emailing, salaries
Operations e.g., transport fleet management
(land, maritime and air), mining
and oil platform telemetry
Industries e.g., airline communications,
filming industry, TV/Broadcasting,
IoT, M2M

2 www.oneweb.net

Government Schools/universities e.g., communicating with students, research, online courses

Emergency services and policing e.g., first responder
communications, disaster
management/relief
Transport (roads, rail, waterways,
airways)
e.g., active traffic management and
monitoring
Meteorology e.g., monitoring stations, bulletins
Military applications e.g., deployment of forces, multi-
task force communications

In the past, telecommunications services were provided over separate networks using different technologies and data protocols (i.e. telephony, private line services, e-banking, e-health, telework, email, etc.). In today’s digital economy, virtually all telecommunications services are provided using the Internet Protocol (IP) over the Internet. For this reason, it is not appropriate to rank the previously distinguishable services in terms of importance. In order to ensure that all Canadians participate in the digital economy, the Internet, which is provided through fixed and mobile high-speed broadband access, must be accessible.

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?

Our Response

As mentioned in the response to 1.a., above, over the past decade telecommunications services have converged into the Internet. Access to high-speed Internet is therefore the only telecommunications network required to provide all telecommunications services required to fulfill the needs of Canadian citizens in today’s digital economy.

We believe that Canada should strongly consider minimum service specifications for broadband access services. We have described some of the most important specifications below:

 Coverage is the most important aspect of any service. Whether a user is mobile or at rest, they must have access to simple, affordable, and reliable connectivity. Coverage is highly personal. Internet access at the end of the street is different than Internet access that reaches your home. Often an area, for instance within a zip/postal code, will be designated as “covered” when, in actual fact, Internet access is available to only a small percentage of the homes.

Coverage must also be feasible, meaning affordable and installed quickly after an order is placed.

For satellite technology, feasibility requires that operation occurs at a high look angle (i.e. the satellite dish should be pointed above 40 degrees to avoid trees, buildings and mountains), that the terminals should have solar power and/or battery backup options, and the installation cost and service must be affordable to the target customer class.

3 www.oneweb.net

****, Volume, and Latency are the key elements to define the quality of a link:

 **** (Mbps) defines how fast data can be downloaded and uploaded.

 Volume (Gigabytes per month or GB/Month) defines how much data the user can consume per period of time.

 Latency (milliseconds or ms) defines the usability and experience of the link. The FCC’s1 average latency by technology was 24ms for Fiber, 32ms for Cable Modems (“Cable”), and 49ms for DSL solutions.

Most new applications are designed for these low latency links. **** Computing, for instance, requires lots of back-and-forth between data centers and user devices. The user experience is thus highly impacted by the time for each of the round trip connections (latency). Voice, gaming, and other communications are also highly affected by latency. LTE and cellular backhaul also require low latency links in order to allow for handover between sites.

OneWeb is designed to provide a latency of <30ms, which is roughly equivalent to fiber and cable Modems.

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.

Our Response

As noted in paragraph 30 of the Notice, currently 18,000 Canadian households in “satellite-dependent communities” in remote and high latitude regions of Canada are potentially unable to participate in the digital economy since they are “without access to broadband Internet service at the Commission’s target speeds …”.

Furthermore, paragraph 31 of the Notice states that “[i]n 2013, approximately 1.2 million, or 9% of, Canadian households [the vast majority being in rural and remote areas] did not have access to broadband Internet service at the Commission’s target download and upload speeds[,]” these speeds being 5 Mbps in the downlink and 1 Mbps in the uplink.

2

One major barrier to participating in the digital economy is affordable access. This affects all rural, remote, and lower income populations. The cost of access is highly related to the cost of building the infrastructure to provision such access. Sometimes this is defined as cost per home passed.

On a countrywide basis, terrestrial networks such as cable, fiber and DSL all have a significantly higher cost per home passed than satellite networks. However, the terrestrial networks have had much lower latency than the satellite networks and therefore much higher usability. OneWeb combines the latency advantage of terrestrial networks with the coverage benefits of satellite.

1

https://www.fcc.gov/reports/measuring-broadband-america-2014 2

Paragraph 24 of the Notice (http://www.crtc.gc.ca/eng/archive/2015/2015-134.htm) states “The Commission established target speeds of 5 megabits per second (Mbps) download and 1 Mbps upload, which it expected should be available to all Canadians, through a variety of technologies, by the end of 2015[.]”

https://www.fcc.gov/reports/measuring-broadband-america-2014
http://www.crtc.gc.ca/eng/archive/2015/2015-134.htm

4 www.oneweb.net

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

Our Response

OneWeb’s low latency broadband network will cover 100% of Canada, improving the availability and overall quality of the Internet for everyone. The OneWeb network can reach each of (i) the 18,000 Canadian households that don’t have access to broadband Internet access in remote areas, and (ii) the 1.2 Million households living in rural and remote areas that do not have the basic quality of service based on the Commission’s targeted rates of a 5 Mbps downlink and 1 Mbps uplink.

OneWeb will be a wholesale provider to Canadian telecommunications service providers (TSPs).

Uniquely, OneWeb’s terminals will provide both direct to home broadband and increased wireless service coverage. By providing TSPs with a new product (which is designed for rural and remote coverage and wireless coverage extension), OneWeb will help spur local entrepreneurship and local jobs for installation and maintenance as well as enable digital education, medicine and connectivity to enhance all forms of economic growth and global digital participation.

In comparison to legacy geostationary orbit (“GEO”) satellites, OneWeb will provide:

 Increased availability with high look angle operation, as the satellites are almost always straight up  **** and less expensive terminals, which are easier to install and do not require any pointing  Lower power terminals, which can operate on solar power

 Low latency to enable an Internet experience identical to that of any terrestrial technology, such as a cable modem

 LTE wireless coverage neutral to any carrier and useable by all carriers to extend their networks to rural and remote areas, not-spot fill in, or provide densification in areas of high demand  Mobile LTE Wireless coverage for emergency vehicles such that a 400m diameter LTE coverage spot will travel with the emergency vehicle anywhere in Canada 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.

Our Response

As previously mentioned, telecommunications services have converged on IP. If Canadians have access to the Internet with a proper quality of service (equal to or greater than that established by the Commission), they will be equipped with the means to meaningfully participate in the digital economy.

5 www.oneweb.net

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?

Our Response

The Commission should consider establishing two targets for broadband Internet access services: one that can be included in the definition of Basic Service and the other which is needed to achieve full consumer grade Broadband Service.

With respect to the first target, assuming that the Basic Service is defined as a service that should be both economically and physically available for everyone, then the current target speeds of 5Mbps/1Mbps are likely adequate. However, the Commission should include both Latency and Volume targets in the Basic Service as well. The Latency targets define usability and the Volume targets define the total quantity available. As discussed in the response to 3.b below, the Basic Service specification should include target Latency characteristics of 30ms and Volume offerings of at least 10 GB/Month.

With respect to the second target for Broadband Service, this should include at least 25 Mbps download speed, 5 Mbps upload, latencies of 30ms and at least 100 GB/Month of data. This should be available to 100% of Canadians by 2020.

Such Basic and Broadband target speeds should be reconsidered on a regular basis.

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.

Our Response

As provided in our response above, the Internet is the all-encompassing service required for Canadians to meaningfully participate in the digital economy.

Low Latency Internet Access has become the primary and most important service for basic telecommunications.

Why? Because low latency access allows every other form of telecommunications to be made available, including:

 Voice Calls
 Mobile Network Extension (SmallCells)
 Fax

 Internet and data services for television, streaming, emailing, static web-browsing and e-commerce, as well as other professional, business and operational communications necessary to conduct business, scientific research and government activities

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

6 www.oneweb.net

Our Response

The underlying technology should not be considered a factor in defining whether a telecommunications service should be considered a Basic Service. Technology is only a means to provide Basic Services.

Therefore, the definition of a Basic Service should be defined by the link quality parameters of 1.b., above, rather than any particular technology. These are basic physical parameters defined generally for all digital communication systems and are independent of any specific physical hardware and software implementation of a digital telecommunication network.

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)?

Our Response

Telecommunications services, similar to any other consumer product, require a standardized set of specifications, which consumers can use to compare offerings.

The consumer information needed to understand and compare available offerings should include speed, volume, latency and price.

We suggest that the Commission consider defining the terms Basic Service and Broadband Services, with the ideal that the Basic Service offering should be designed to promote affordable access to lower income populations at a minimum price, and ensure that every Canadian has the access required for such necessities as children’s education and access to important services.

A Basic Service should be defined to include the following:
 ****: 5 Mbps / 1 Mbps
 Volume: 10 GB/Month
 Latency: 30ms

Broadband Services should be defined to include the following:

 25 Mbps / 5Mbps
 100 GB/Month
 30ms latency

We further recommend that the Commission ensure a simple upgrade from the Basic Service to the target Broadband Service described above. As an end-user’s technical literacy and dependence on the Internet increases, their connection and network should be upgradeable to the target Broadband Service.

7 www.oneweb.net

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

Our Response

Ideally, Basic Services would be free of charge and subsidized. Internet access is so fundamental to personal growth and empowerment that the societal benefits, like elementary education, strongly outweigh the costs.

However, it is unlikely that a subsidy of this extent is possible. Thus, the government should look to achieve Basic Services within the affordability index for a high percentage of the population. As it does today, the government could use targeted funding to finance installation costs and require, as a condition of such financing being made available, a Basic Services package price that meets the above targeted affordability-index based pricing.

This acknowledges that such Basic Services will provide a minimum level of service and that upgraded packages would be purchased by most consumers.

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?

Our Response

Market forces alone will not ensure basic communication services to all citizens and consumers in Canada.

Therefore, governments must play a role to ensure such services.

Current technologies such as fiber, cable and microwave have costs that are highly related to housing density.

High housing density environments allow many customers to share in the costs of the infrastructure. In lower housing density environments, the cost of the aforementioned technologies are amortized across a smaller set of customers and the cost per home raises dramatically.

Countries around the world struggle with the limited availability of existing communications technologies. In many cases, the first 65% of homes are reached by market forces alone, but each remaining percent of coverage is asymptotically more expensive.

While the government cannot force service providers to be unprofitable, it can provide funding and bulk buying power incentives to bring providers into certain areas. As infrastructure takes many years to build, guaranteed contracts for a minimum number of users would provide an increased incentive for such infrastructure to be built at virtually no cost to the government. Different levels of federal, provincial, territorial and even municipal governments could commit and sponsor varying additions to the same contract.

For instance:

 The Federal Government could issue a RFP to pay $5/month to a TSP to provide Basic Services for up to 100,000 rural homes and installation costs of $200 per home. Each provincial government could then augment this subsidy with their own funds, for example, an extra $1 per home.

A Minimum Basic Service requirement could be set as well as a definition of “Rural”, which may include only the most rural 5% of homes with housing densities below a specified value. Further, the 8 www.oneweb.net

government should set a requirement that the service can support, for instance, 300,000 rural homes and that all homes must be upgradeable to at least the recommended minimum Broadband Service described in the response to 3.b above.

A maximum installation time could also be part of the bid requirements.

 TSPs would then submit bids to provide a basket of services to end users based on the area and subsidy provided by the varying levels of government. The TSP with the best basket of services and best upgrade path would be awarded the contract guarantee. After the infrastructure is completed, the TSP would then have to sell the product. Each customer would reduce the government commitments and represent an upsell opportunity to the TSP to provide the recommended minimum Broadband Service.

 The Service Provider would then have a known minimum quantity customer set and could be reliably incentivized to build infrastructure in regions, which otherwise would represent too high of a risk.

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?

Our Response

As discussed above, the government’s support as a guarantor could be a key and dollar neutral way to ensure that all Canadians have access to Basic Services and an optional upgrade path to the recommended minimum Broadband Service.

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?

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.

Our Response

Basic Services and an upgrade path to Broadband Services should be available to 100% of Canadians.

Supporting infrastructure through direct government funding is the surest way to achieve such coverage and a basket of technologies will be most appropriate.

The funding criteria should weigh in favor of technologies that will support Broadband Services for unserved and underserved Canadians in all regions of the country.

9 www.oneweb.net

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?

Regulatory measures for basic telecommunications services

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

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

Our Response

Basic Services as defined above should be included in the definition of basic telecommunications services. The provision of dial tone voice will be less expensive when bundled with a basic Internet offering than providing voice services alone.

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)?

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.

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.

Our Response

The definition of Basic Services should be updated and revisited from time to time in order to ensure that it properly reflects the needs of Canadian citizens and consumers. Once this is done, then the means of communications, including a mix of technologies if necessary, that assures the provision of the Basic Service should be provided to all citizens and consumers. OneWeb, through partner TSPs, can provide Basic Services to all Canadian citizens.

The government should consider subsidizing local communities, so they can have access to Basic Services based on the service definition, regardless of whether it is over Fiber, Cable, DSL or satellite.

** End of Document **

Intervention: OneWeb (Intervenor 245)

Document Name: 2015-134.223976.2394469.Intervention(1fbl101!).pdf
OneWeb, Ltd.
13 **** Street
St. Helier JE4 5UT, Jersey
Date: July 14, 2015
Submitted electronically
Mr. John Traversy
Secretary General
Canadian Radio-television
and Telecommunications Commission
Ottawa, Ontario *** ***
**** Sir/Madam,

Re: OneWeb’s Response to Appendix B of Telecom Notice of Consultation CRTC 2015-134, Review of basic telecommunications services, CRTC File number: 8663-C12-201503186 OneWeb, Ltd. (“OneWeb”) has the honor of responding to Telecom Notice of Consultation CRTC 2015-134 published on 9 **** 2015 (as amended by Notice 2015-134-1) (the “Notice”). Please find our responses to Appendix B of the Notice in the Attachment below.

OneWeb is a global communications company building a global network to provide low latency broadband to rural and remote areas. Starting in 2019, the network will operate globally via an initial constellation of 648 low earth orbiting satellites providing broadband to end-users anywhere in the world through small, affordable terminals. In particular, OneWeb will have the opportunity to address Canadian broadband access requirements for underserved and unconnected communities in rural and remote areas, with speed and capacity comparable to, if not better than, that offered today in urban areas.

In accordance with paragraph 47 of the Notice, I request the opportunity to appear at the public hearing.

Sincerely Yours,
**** Wyler
Founder and CEO
OneWeb, Ltd
Please direct all correspondence to ******@***.com

Attachment: OneWeb’s Response to Appendix B of the Telecom Notice of Consultation CRTC 2015-134.

1 www.oneweb.net

ATTACHMENT
OneWeb’s Response to Appendix B of
Review of basic telecommunications services,
Telecom Notice of Consultation CRTC 2015-134
File number: 8663-C12-201503186
July 14, 2015

OneWeb’s Response to Telecom Notice of Consultation CRTC 2015-134 Below are OneWeb’s responses to the questions posed in Appendix B of the above-referenced Notice.

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?

Our Response

Telecommunications services provide the means for connecting individuals, businesses and government services, and are key to economic growth.

Who Types of Communications
Citizens Individuals communicating at any
point in time and space with one
another to access information
necessary for everyday life
e.g., e-commerce, accessing health
records, paying bills, social media,
school work, watching films and
TV programs live or on a demand
basis
Businesses Front Office / **** Office
employees
e.g., conducting everyday
commercial transactions with
customer’s emails, telephone calls,
online chat, and social media
Suppliers e.g., making orders, tracking a
particular shipment, e-fax
Employees e.g., working from home,
emailing, salaries
Operations e.g., transport fleet management
(land, maritime and air), mining
and oil platform telemetry
Industries e.g., airline communications,
filming industry, TV/Broadcasting,
IoT, M2M

2 www.oneweb.net

Government Schools/universities e.g., communicating with students, research, online courses

Emergency services and policing e.g., first responder
communications, disaster
management/relief
Transport (roads, rail, waterways,
airways)
e.g., active traffic management and
monitoring
Meteorology e.g., monitoring stations, bulletins
Military applications e.g., deployment of forces, multi-
task force communications

In the past, telecommunications services were provided over separate networks using different technologies and data protocols (i.e. telephony, private line services, e-banking, e-health, telework, email, etc.). In today’s digital economy, virtually all telecommunications services are provided using the Internet Protocol (IP) over the Internet. For this reason, it is not appropriate to rank the previously distinguishable services in terms of importance. In order to ensure that all Canadians participate in the digital economy, the Internet, which is provided through fixed and mobile high-speed broadband access, must be accessible.

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?

Our Response

As mentioned in the response to 1.a., above, over the past decade telecommunications services have converged into the Internet. Access to high-speed Internet is therefore the only telecommunications network required to provide all telecommunications services required to fulfill the needs of Canadian citizens in today’s digital economy.

We believe that Canada should strongly consider minimum service specifications for broadband access services. We have described some of the most important specifications below:

 Coverage is the most important aspect of any service. Whether a user is mobile or at rest, they must have access to simple, affordable, and reliable connectivity. Coverage is highly personal. Internet access at the end of the street is different than Internet access that reaches your home. Often an area, for instance within a zip/postal code, will be designated as “covered” when, in actual fact, Internet access is available to only a small percentage of the homes.

Coverage must also be feasible, meaning affordable and installed quickly after an order is placed.

For satellite technology, feasibility requires that operation occurs at a high look angle (i.e. the satellite dish should be pointed above 40 degrees to avoid trees, buildings and mountains), that the terminals should have solar power and/or battery backup options, and the installation cost and service must be affordable to the target customer class.

3 www.oneweb.net

****, Volume, and Latency are the key elements to define the quality of a link:

 **** (Mbps) defines how fast data can be downloaded and uploaded.

 Volume (Gigabytes per month or GB/Month) defines how much data the user can consume per period of time.

 Latency (milliseconds or ms) defines the usability and experience of the link. The FCC’s1 average latency by technology was 24ms for Fiber, 32ms for Cable Modems (“Cable”), and 49ms for DSL solutions.

Most new applications are designed for these low latency links. **** Computing, for instance, requires lots of back-and-forth between data centers and user devices. The user experience is thus highly impacted by the time for each of the round trip connections (latency). Voice, gaming, and other communications are also highly affected by latency. LTE and cellular backhaul also require low latency links in order to allow for handover between sites.

OneWeb is designed to provide a latency of <30ms, which is roughly equivalent to fiber and cable Modems.

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.

Our Response

As noted in paragraph 30 of the Notice, currently 18,000 Canadian households in “satellite-dependent communities” in remote and high latitude regions of Canada are potentially unable to participate in the digital economy since they are “without access to broadband Internet service at the Commission’s target speeds …”.

Furthermore, paragraph 31 of the Notice states that “[i]n 2013, approximately 1.2 million, or 9% of, Canadian households [the vast majority being in rural and remote areas] did not have access to broadband Internet service at the Commission’s target download and upload speeds[,]” these speeds being 5 Mbps in the downlink and 1 Mbps in the uplink.

2

One major barrier to participating in the digital economy is affordable access. This affects all rural, remote, and lower income populations. The cost of access is highly related to the cost of building the infrastructure to provision such access. Sometimes this is defined as cost per home passed.

On a countrywide basis, terrestrial networks such as cable, fiber and DSL all have a significantly higher cost per home passed than satellite networks. However, the terrestrial networks have had much lower latency than the satellite networks and therefore much higher usability. OneWeb combines the latency advantage of terrestrial networks with the coverage benefits of satellite.

1

https://www.fcc.gov/reports/measuring-broadband-america-2014 2

Paragraph 24 of the Notice (http://www.crtc.gc.ca/eng/archive/2015/2015-134.htm) states “The Commission established target speeds of 5 megabits per second (Mbps) download and 1 Mbps upload, which it expected should be available to all Canadians, through a variety of technologies, by the end of 2015[.]”

https://www.fcc.gov/reports/measuring-broadband-america-2014
http://www.crtc.gc.ca/eng/archive/2015/2015-134.htm

4 www.oneweb.net

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

Our Response

OneWeb’s low latency broadband network will cover 100% of Canada, improving the availability and overall quality of the Internet for everyone. The OneWeb network can reach each of (i) the 18,000 Canadian households that don’t have access to broadband Internet access in remote areas, and (ii) the 1.2 Million households living in rural and remote areas that do not have the basic quality of service based on the Commission’s targeted rates of a 5 Mbps downlink and 1 Mbps uplink.

OneWeb will be a wholesale provider to Canadian telecommunications service providers (TSPs).

Uniquely, OneWeb’s terminals will provide both direct to home broadband and increased wireless service coverage. By providing TSPs with a new product (which is designed for rural and remote coverage and wireless coverage extension), OneWeb will help spur local entrepreneurship and local jobs for installation and maintenance as well as enable digital education, medicine and connectivity to enhance all forms of economic growth and global digital participation.

In comparison to legacy geostationary orbit (“GEO”) satellites, OneWeb will provide:

 Increased availability with high look angle operation, as the satellites are almost always straight up  **** and less expensive terminals, which are easier to install and do not require any pointing  Lower power terminals, which can operate on solar power

 Low latency to enable an Internet experience identical to that of any terrestrial technology, such as a cable modem

 LTE wireless coverage neutral to any carrier and useable by all carriers to extend their networks to rural and remote areas, not-spot fill in, or provide densification in areas of high demand  Mobile LTE Wireless coverage for emergency vehicles such that a 400m diameter LTE coverage spot will travel with the emergency vehicle anywhere in Canada 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.

Our Response

As previously mentioned, telecommunications services have converged on IP. If Canadians have access to the Internet with a proper quality of service (equal to or greater than that established by the Commission), they will be equipped with the means to meaningfully participate in the digital economy.

5 www.oneweb.net

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?

Our Response

The Commission should consider establishing two targets for broadband Internet access services: one that can be included in the definition of Basic Service and the other which is needed to achieve full consumer grade Broadband Service.

With respect to the first target, assuming that the Basic Service is defined as a service that should be both economically and physically available for everyone, then the current target speeds of 5Mbps/1Mbps are likely adequate. However, the Commission should include both Latency and Volume targets in the Basic Service as well. The Latency targets define usability and the Volume targets define the total quantity available. As discussed in the response to 3.b below, the Basic Service specification should include target Latency characteristics of 30ms and Volume offerings of at least 10 GB/Month.

With respect to the second target for Broadband Service, this should include at least 25 Mbps download speed, 5 Mbps upload, latencies of 30ms and at least 100 GB/Month of data. This should be available to 100% of Canadians by 2020.

Such Basic and Broadband target speeds should be reconsidered on a regular basis.

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.

Our Response

As provided in our response above, the Internet is the all-encompassing service required for Canadians to meaningfully participate in the digital economy.

Low Latency Internet Access has become the primary and most important service for basic telecommunications.

Why? Because low latency access allows every other form of telecommunications to be made available, including:

 Voice Calls
 Mobile Network Extension (SmallCells)
 Fax

 Internet and data services for television, streaming, emailing, static web-browsing and e-commerce, as well as other professional, business and operational communications necessary to conduct business, scientific research and government activities

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

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Our Response

The underlying technology should not be considered a factor in defining whether a telecommunications service should be considered a Basic Service. Technology is only a means to provide Basic Services.

Therefore, the definition of a Basic Service should be defined by the link quality parameters of 1.b., above, rather than any particular technology. These are basic physical parameters defined generally for all digital communication systems and are independent of any specific physical hardware and software implementation of a digital telecommunication network.

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)?

Our Response

Telecommunications services, similar to any other consumer product, require a standardized set of specifications, which consumers can use to compare offerings.

The consumer information needed to understand and compare available offerings should include speed, volume, latency and price.

We suggest that the Commission consider defining the terms Basic Service and Broadband Services, with the ideal that the Basic Service offering should be designed to promote affordable access to lower income populations at a minimum price, and ensure that every Canadian has the access required for such necessities as children’s education and access to important services.

A Basic Service should be defined to include the following:
 ****: 5 Mbps / 1 Mbps
 Volume: 10 GB/Month
 Latency: 30ms

Broadband Services should be defined to include the following:

 25 Mbps / 5Mbps
 100 GB/Month
 30ms latency

We further recommend that the Commission ensure a simple upgrade from the Basic Service to the target Broadband Service described above. As an end-user’s technical literacy and dependence on the Internet increases, their connection and network should be upgradeable to the target Broadband Service.

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

Our Response

Ideally, Basic Services would be free of charge and subsidized. Internet access is so fundamental to personal growth and empowerment that the societal benefits, like elementary education, strongly outweigh the costs.

However, it is unlikely that a subsidy of this extent is possible. Thus, the government should look to achieve Basic Services within the affordability index for a high percentage of the population. As it does today, the government could use targeted funding to finance installation costs and require, as a condition of such financing being made available, a Basic Services package price that meets the above targeted affordability-index based pricing.

This acknowledges that such Basic Services will provide a minimum level of service and that upgraded packages would be purchased by most consumers.

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?

Our Response

Market forces alone will not ensure basic communication services to all citizens and consumers in Canada.

Therefore, governments must play a role to ensure such services.

Current technologies such as fiber, cable and microwave have costs that are highly related to housing density.

High housing density environments allow many customers to share in the costs of the infrastructure. In lower housing density environments, the cost of the aforementioned technologies are amortized across a smaller set of customers and the cost per home raises dramatically.

Countries around the world struggle with the limited availability of existing communications technologies. In many cases, the first 65% of homes are reached by market forces alone, but each remaining percent of coverage is asymptotically more expensive.

While the government cannot force service providers to be unprofitable, it can provide funding and bulk buying power incentives to bring providers into certain areas. As infrastructure takes many years to build, guaranteed contracts for a minimum number of users would provide an increased incentive for such infrastructure to be built at virtually no cost to the government. Different levels of federal, provincial, territorial and even municipal governments could commit and sponsor varying additions to the same contract.

For instance:

 The Federal Government could issue a RFP to pay $5/month to a TSP to provide Basic Services for up to 100,000 rural homes and installation costs of $200 per home. Each provincial government could then augment this subsidy with their own funds, for example, an extra $1 per home.

A Minimum Basic Service requirement could be set as well as a definition of “Rural”, which may include only the most rural 5% of homes with housing densities below a specified value. Further, the 8 www.oneweb.net

government should set a requirement that the service can support, for instance, 300,000 rural homes and that all homes must be upgradeable to at least the recommended minimum Broadband Service described in the response to 3.b above.

A maximum installation time could also be part of the bid requirements.

 TSPs would then submit bids to provide a basket of services to end users based on the area and subsidy provided by the varying levels of government. The TSP with the best basket of services and best upgrade path would be awarded the contract guarantee. After the infrastructure is completed, the TSP would then have to sell the product. Each customer would reduce the government commitments and represent an upsell opportunity to the TSP to provide the recommended minimum Broadband Service.

 The Service Provider would then have a known minimum quantity customer set and could be reliably incentivized to build infrastructure in regions, which otherwise would represent too high of a risk.

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?

Our Response

As discussed above, the government’s support as a guarantor could be a key and dollar neutral way to ensure that all Canadians have access to Basic Services and an optional upgrade path to the recommended minimum Broadband Service.

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?

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.

Our Response

Basic Services and an upgrade path to Broadband Services should be available to 100% of Canadians.

Supporting infrastructure through direct government funding is the surest way to achieve such coverage and a basket of technologies will be most appropriate.

The funding criteria should weigh in favor of technologies that will support Broadband Services for unserved and underserved Canadians in all regions of the country.

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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?

Regulatory measures for basic telecommunications services

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

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

Our Response

Basic Services as defined above should be included in the definition of basic telecommunications services. The provision of dial tone voice will be less expensive when bundled with a basic Internet offering than providing voice services alone.

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)?

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.

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.

Our Response

The definition of Basic Services should be updated and revisited from time to time in order to ensure that it properly reflects the needs of Canadian citizens and consumers. Once this is done, then the means of communications, including a mix of technologies if necessary, that assures the provision of the Basic Service should be provided to all citizens and consumers. OneWeb, through partner TSPs, can provide Basic Services to all Canadian citizens.

The government should consider subsidizing local communities, so they can have access to Basic Services based on the service definition, regardless of whether it is over Fiber, Cable, DSL or satellite.

** End of Document **

Intervention: OneWeb, Ltd.

Document Name: 2015-134.223976.2394470.Intervention(1fbl201!).html

Raisons pour comparaitre / Reasons for appearanceOneWeb wishes to elaborate on its satellite service plans for Canada, including coverage in the far ****. OneWeb also wishes to elaborate on its proposed funding framework.

Intervention: OneWeb (Intervenor 245)

Document Name: 2015-134.223976.2394470.Intervention(1fbl201!).html

Raisons pour comparaitre / Reasons for appearanceOneWeb wishes to elaborate on its satellite service plans for Canada, including coverage in the far ****. OneWeb also wishes to elaborate on its proposed funding framework.