West Parry Sound SMART Community Network Inc. (WPS SMART)
Submission to CRTC Telecom Notice of Consultation CRTC 2017-112
Following is WPS SMART’s input to Consultation CRTC 2012-112. Thank you for the opportunity to participate.
Governance, operating, and accountability frameworks
Roles of the Commission and the third-party administrator(s) – Questions 1-5
- We believe that there should be separate functions (project management and accounting). It serves to provide a broader framework for oversight.
- We would like to see this governance and oversight to be federally centralized. This would ensure a consistent and fair administration. Enabling existing government funded regional organizations to provide this oversight is not productive. To date, the funding of these organizations has not resulted the building of the required rural capacity as had been intended or funded.
- We support the CTCC as an appropriate accounting function. Board members should be selected from a broad geographical area, preferably rurally based and be unbiased by nature of their role in the telecom industry in Canada.
Governance structure of the third-party administrator(s) – Questions 6-7
- We support a Federally appointed independent committee be established to monitor the performance of all stages of the funding process …..from application through selection and throughout the execution. The reason for this Fund by CRTC is that previous processes and methods for funding underserved areas has not resulted in the expected outcome.
- Metrics should measure the outflow of money, recipients project status, and periodic random audits to ensure that the use of funds is properly executed and results are as reasonably planned at the outset in the application.
- Consumers of the service should be the beneficiaries and should attest to that attainment of the broadband service mandated by CRTC’s target.
Calls for applications – Question 8
- We would support 2 applications over the 5 years. This would provide a reasonable amount of funds to warrant the comprehensive application process and would recognize that technology advancement creates and enables more effective and cost-efficient solutio
Distribution of funding – Question 9
- We would recommend an initial payment to enable project start-up costs, then payments based on completed milestones as demonstrated by the successful applicant
Enforcement of funding agreements – Questions 10 and 11
- We support a transparent process to ensure that projects are delivered as per the funding agreements. Projects that do not meet pre-approved strategic milestones should be put on notice with no further interim funding until the deficiencies are remedied.
Collecting and reporting information from applicants/recipients – Questions 12 – 16
- The Administrator(s) should regularly review the performance of all projects funding under the program and as noted above address accordingly
- Information relating to the approved project should be available for public consumption. This would be a strong motivator to complete the projects to achieve the intended results. The ability to share this information publically should be part of the funding agreement.
- Recipients should be required to participate in a broadband monitoring program and share progression publically.
- Applications and recipient names should be publically shared.
Eligible geographic areas – Questions 17-21
- Our major concern in relation to questions 17 and 18 is that the information in relation to “access” to broadband in rural areas is incorrect. We have submitted information to the CRTC in relation to these discrepancies. For instance, the 2016 Communications Monitoring Report indicates that 12.8 M households in Canada have fibre optic passing by. While this statement may be true the fact is that not all fibre optic cable along a route is accessible/affordable for distribution. Much of this fibre is nearing end of life.
Latency and other issues:
In addition, much of the “access” information is provided by TSPs and other groups that have been funded to-date to provide broadband internet capacity. The information from these organizations is not reflective of the actual experience by their subscribers. Subscribers experience throttled back service and latency. Speed tests prove out the “underserved” areas. We recommend that current information relating to “access” is treated with skepticism and not used to determine eligible areas. The parties applying for the funds should provide real information relating to their actual service and accessibility/affordability to fibre.
- We do not recommend the use of hexagons. Hexagons may work for wireless solutions and even then with some of the wireless solutions it would require line of sight with the tower. In rural areas such as West Parry Sound the topography and tree cover absorption will limit signal strength and also be a factor to block line of sight.
- For a fibre/”wired/cabled” solution, the best measurement would be a spatial dataset or a GIS. GIS has been around for 30 years plus and offers accurate reliable data and can be presented along municipal and provincial lines. This becomes important when gathering community support, local funding, alignment with regional economic strategies, etc. As noted in the point above, the applicant should provide actual local GIS based data that sets out their “underserved” status. Using databases and other information that contributed to the current assessments of underserved would be inaccurate and unfair.
Eligible Recipients – Questions 22
- No additional comments
Eligible Costs – Questions 23-24
- It is recommended that applicants are advised that contingency costs be included in their financial submission
- An eligible cost should include project management and related project operations costs.
Funding from a government entity – Questions 25-27
- Applicants should be required to have a signed funding agreement
Applicant investment – Questions 28-30
- Applicants should provide signed funding agreement(s).
- Ownership of assets should go to the recipient. The recipient should have a legal undertaking to maintain and support the asset for a pre-determined period of time and to ensure the provision of services as set out initially.
Project Viability – Question 31
- Applicants should provide a clear statement of the contribution from CRTC and the benefit to the community that would not have otherwise been possible.
Project Type – Question 32
- Impact on economic growth (jobs, GDP, attraction of new businesses, adoption/participation in the digital economy and digital innovation).
Project Assessment Criteria – Questions 33 – 37
- Focus on rural
- Minimize the weighting on “other” government funding. This will level the playing field.
- Recommend a project achievement check list where the overall impacts can be assessed holistically. Do not use weighting as “assessment of the whole” is greater than the sum of its parts.
- Subscriber use and network resiliency are critical attributes of a viable network service over time. The incorporation of resiliency and use would reflect on our previous statement about overall impact (no weighting).
Criteria to identify “priority underserved” geographical areas – Questions 38-41
- We do not support the hexagonal model. We do support the priority for the most underserved areas.
- Additional considerations should include open access, latency, and cost per gigabit.