Telecom - Staff Letter addressed to the Distribution List
Ottawa-Gatineau, 10 January 2025
Reference(s): 1011-NOC2023-0089
BY E-MAIL
Distribution list
Subject: Broadband Fund Policy Review, Telecom Notice of Consultation CRTC 2023-89, Additional Requests for Information
On 23 March 2023, the Commission issued Broadband Fund Policy Review, Telecom Notice of Consultation CRTC 2023-89 (TNC 2023-89), inviting interested persons to propose changes to the Commission’s Broadband Fund program (the Broadband Fund policy review).
Commission staff has reviewed the record of the proceeding and has concluded that further inquiry is necessary. Specifically, the Commission is seeking additional comments regarding a new resiliency focused project type that is being considered under the Broadband Fund.
Parties are requested to provide comprehensive answers, including any supporting information, to the attached requests for information. Responses to the requests for information are to be filed with the Commission, and served on all other parties, by 24 January 2025.
Any party, including parties not named as respondents to a question, may comment on requests for information or responses to requests for information, serving such replies on other parties, by 7 February 2025. The Commission will also consider this date to be the close of record for issues considered in this phase of the proceeding.
As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin 2010-961, 23 December 2010, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.
Yours sincerely,
Original signed by
Julie Cook
Director, Broadband Fund Regime
Telecommunications Sector
c.c.:
Phillip Arnott, CRTC, phillip.arnott@crtc.gc.ca
Jessica Dare, CRTC, jessica.dare@crtc.gc.ca
Attach. (2)
Attachment 1:
1. DEFINITIONS AND CRITERIA FOR RESILIENCY PROJECTS
In Telecom Notice of Consultation 2023-89 (TNC 2023-89), the Commission considered that improving network resiliency in rural and remote areas was vital, and took the preliminary view that it should support resiliency projects under the Broadband Fund. In support of that preliminary view, the Commission provided a proposed definition for resiliency projects and invited interested persons to respond to several questions related to the provision of funding for resiliency projects.
Based on the interventions on the record, the Commission is seeking additional information on the options being considered with respect to the resiliency project type definition, as well as new eligibility and assessment criteria that the Commission may use to evaluate those projects. Parties are invited to review and comment on the potential refinements to the resiliency project definition and proposed new eligibility and assessment criteria provided below.
A. Resiliency - Project type definition
A resiliency project builds or upgrades transport infrastructure to one or more communities that are already served with existing high-capacity transport service. This project type ensures redundant and diverse transport routes, thereby reducing the risk of an outage due to a single point of failure that would cause a community to be isolated from telecommunication services.
Transport infrastructure includes all equipment and material required to connect existing core network infrastructure to broadband access or mobile wireless networks. Broadband access infrastructure, mobile wireless infrastructure, and customer premises equipment are not eligible for funding under the resiliency project type.
Where no more than one terrestrial transport route serves a community or communities, a resiliency project must create a second diverse transport route by either:
- closing a loop or ring in an existing transport network by building transport infrastructure between two existing transport routes serving separate areas;
- building a second route to one or more communities where completing a ring or loop to a separate part of an existing network is not feasible or possible; or
- deploying satellite ground station equipment to establish an alternative data transport route for primary and emergency services.
B. Eligibility criteria - Resiliency projects
The Commission’s proposed new views on technical and geographic eligibility and assessment criteria that the Commission may use to assess resiliency projects are presented below. Applications may be assessed based on these criteria, with the primary objective of providing a redundant and diverse transport route to a community that is served by no more than one terrestrial transport route.
- Geographic eligibility - Resiliency project
An applicant’s proposed resiliency project must build or upgrade transport infrastructure to provide a redundant transport route that reduces the risk of an outage due to a single point of failure that would cause a community to be isolated from telecommunication services.
- Geographic eligibility - Community eligibility
An applicant’s proposed resiliency project must build or upgrade transport infrastructure to serve communities that are rural, remote, difficult to reach due to geographic features (e.g. bodies of water, mountains, and broad areas of undeveloped land), or lacking year-round road access, .These communities will likely have repair times impacted by factors such as travel time and difficulty of getting crews and equipment on site.
For the purpose of the Broadband Fund,
- remote describes an area or a community that is classified as such by Statistics Canada using an Index of Remoteness. Statistics Canada’s recommendation at the time of publishing this regulatory policy is to classify a community that has an Index of Remoteness of 0.4 or above as remote. Statistics Canada concludes that this classification is generic, and that different applications might require specialized groupings by remoteness; and
- rural describes an area that is defined by Statistics Canada as including any area of Canada that is not within a population centre. Currently, rural areas include any area with a population of less than 1,000 or a density of less than 400 people per square kilometre.
The Commission may modify the geographic eligibility of resiliency projects in each call for applications.
-
Transport route diversity
An applicant’s proposed resiliency project must build or upgrade transport infrastructure to provide transport route diversity. The Commission will consider transport route diversity to include either a geographically diverse route (i.e. a significantly separate physical route into a community) or a technologically diverse route (i.e. a transport route provisioned using a different transport technology).
- Applicant eligibility - Existing telecommunications infrastructure
An applicant that proposes a resiliency project must meet all general Broadband Fund applicant eligibility criteria and must have its own telecommunications infrastructure and/or an interconnection agreement with a telecommunications service provider(s) (TSP) that would collectively have existing telecommunications infrastructure in each community that would benefit from the resiliency project.
- Wholesale open access to funded transport infrastructure
An applicant that proposes to build or upgrade transport infrastructure as part of a resiliency project must commit to offering wholesale open access service packages and meeting the requirements set out in sections E20 and I18 of Appendix 1 to Telecom Regulatory Policy 2024-328.
- Retail open access to funded transport infrastructure
An applicant that proposes to build or upgrade transport infrastructure as part of a resiliency project must commit to providing retail open access to that infrastructure, consistent with the eligibility criterion set out in section E21 of Appendix 1 to Telecom Regulatory Policy 2024-328.
C. Assessment criteria - Resiliency projects
- Outage risk and impact
The Commission will use this criterion to assess the risk of an outage and the impact of an outage on each community that would benefit from the project. The applicant should explain why the resiliency project is important to existing services and to each community that will benefit from the resiliency project.
This criterion will be assessed using three factors:
- Risk of future outages
- The applicant must provide an analysis of the risk of future outages due to factors such as extreme weather events, wildfires, power outages, vandalism, etc., along the existing transport route(s) for each community that will benefit from the resiliency project. The Commission will assess a project more favourably if there is a higher probability of this type of outage.
- Impact of outages
- The applicant must identify the impacts of a service outage on access to all telecommunication services, including wireless and wireline services such as home telephone, Internet, mobile, and emergency services, for each community that would benefit from the project. The applicant must provide information on the type and number of telecommunication services offered in each community that would be impacted by an outage.
- History of outages
- The applicant must provide a history of outages along the existing transport route(s) for each community that will benefit from the resiliency project. The Commission may assess a project more favourably based on a greater number and severity of previous outages caused by a single point of failure along the existing transport route serving each community that will benefit from the project.
The Commission will assess a project more favourably if it would safeguard a greater number of telecommunication services.
- Geographic merit
The Commission will use this criterion to assess the degree to which each community that will benefit from the resiliency project is rural, remote, difficult to reach due to geographic features, or distant from year-round roads. The Commission will assess a project more favourably based on how rural, remote, difficult to reach due to geographic features, or distant from year-round roads each community that will benefit from the project is.
- Number of households
The Commission will use this criterion to determine the number of households in the communities that will benefit from the resiliency project. The Commission will assess a project more favourably if it serves a higher number of households.
- Number of communities
The Commission will use this criterion to determine the number of communities that will benefit from the resiliency project. The Commission will assess a project more favourably if it serves a higher number of communities.
- Service outage mitigation
The Commission will use this criterion to determine how the proposed resiliency project would mitigate an event that could cause a service outage. The applicant should demonstrate how the proposed project will reduce the impact of an outage for each community that will benefit from the resiliency project and how the network will remain functional and viable following an incident or event that might otherwise cause a service outage.
The Commission will assess a project more favourably based on the robustness of the proposed measures to minimize service disruption and its ability to maintain an acceptable level of service during failures and challenges in normal operations.
- Proposed transport capacity
The Commission will use this criterion to assess the proposed transport capacity to each community that would benefit from the resiliency project, with consideration given to the size of the community (e.g. number of households) to ensure that the proposed transport capacity is adequate for maintaining connectivity following an incident or event that might otherwise cause a service outage. The Commission will assess a project more favourably based on how much transport capacity in each community that would benefit from the project will increase as a result of the project.
- Maintenance and operations plans
The Commission will use this criterion to assess the applicant’s maintenance and operations plans to ensure the long-term sustainability of the funded infrastructure. The Commission will assess a project more favourably based on how comprehensive and complete the applicant’s plans are for ongoing maintenance and operations.
Respondents: All parties.
2. DATA COLLECTION FOR ASSESSMENT OF PROJECTS
In question 4 of the first series of requests for information circulated as part of TNC 2023-89, the Commission invited parties to comment on what information the Commission should collect for the purpose of funding resiliency projects under the Broadband Fund. Specifically, the Commission asked questions about what data would be necessary to identify resiliency projects in eligible geographic areas and how that data should be collected. Parties provided constructive responses to those questions.
The Commission is seeking additional input on three options to identify geographic areas in need of funding for resiliency projects.
- Some parties suggested that the Commission collect data on all transport facilities, including transport routes that are not currently included in the CRTC Annual Facilities Survey.
- Other parties suggested that the Commission collect less detailed aggregate transport facilities data, at the community level or above, on the basis that collecting higher-level data would mitigate competitive and security risks to some extent.
- Finally, some parties suggested that the Commission should not collect additional data on transport facilities, due to competitive and security risks. Instead, they submitted that any applicant that requests funding for a resiliency project must provide rationale and evidence supporting the need for the proposed project.
Provide comments on the options set out above, specifically:
- Which option(s) would best enable the Commission and/or applicants to identify areas in need of funding for resiliency projects? Why (aside from considerations of competitive or security risks, which have been previously expressed on the record)?
- For options (A) and (B), which would require additional data collection:
- What data should the Commission collect to identify geographic areas in need of funding for resiliency projects? For example:
- For option (A), the Commission could collect data on existing transport routes and sites, as geolocated lines and points. These data could include information categories such as capacity, backhaul technology, installation type (e.g. aerial, buried, etc.), infrastructure age, wholesale services available, and presence of dark fibre.
- For option (B), the Commission could collect data on each community in a service provider’s service area that is at risk of a service outage due to a single point of failure. These data could include information categories such as capacity, backhaul technology, outage risk (e.g., aging single fibre route, a demonstrated history of outages at a specific location, etc.).
- How long would it reasonably take transport service providers to gather, review, and submit these data for option (A) or option (B)?
- What would be an acceptable file format (or file formats) to use to provide:
- route and site information (e.g., spatial files in shapefile, Mapinfo, geopackage, GeoJSON, Open Fibre Data Standard format, etc.); and
- community information (e.g., spreadsheet in comma-separated values (CSV), etc.)?
- Would the collection of data on transport routes in a non-geolocated format be sufficient for the Commission to assess a need for transport route diversity? For example, could the Commission collect data on transport sites only as geolocated points, identifying:
- the number of diverse routes for each site that connect back to a core network; or
- a list of routes represented that identify the start site and the end site, without providing the exact route?
- What data should the Commission collect to identify geographic areas in need of funding for resiliency projects? For example:
- For option (C), which would require no additional data collection:
- What evidence is needed to identify a lack of diversity in the transport networks serving a proposed project area (e.g., a network diagram of existing infrastructure in the area)?
- Can an applicant accurately assess and document the existence of another service provider’s transport infrastructure in the project area?
- How can the Commission validate resiliency rationale and evidence, in the absence of data collection? For example, would an attestation of the accuracy and completeness of the applicant’s assessment be sufficient?
Respondents: All parties.
Distribution list
A. Johnson, sojrnrr@protonmail.com
A. Moskal, FAN143@GMAIL.COM
Access Communications Co-operative Limited, documents@myaccess.coop
Agricultural Producers Association of Saskatchewan, bkobes@apas.ca
Alberta Rural Connectivity Coalition, imran.mohiuddin@cybera.ca
Anton van Arendonk, Tonirricana@tutamail.com
Association of Manitoba Municipalities, amm@amm.mb.ca
Bell Canada, bell.regulatory@bell.ca
Bragg Communications Inc., carrying on business as Eastlink, regulatory.matters@corp.eastlink.ca
Canadian Federation of Independent Business (CFIB), jasmin.guenette@cfib.ca
Chris Creasor, ccreasor@hotmail.ca
Christian Salazar, sidebar_hectare_0q@icloud.com
Cogeco Communications Inc., leonard.eichel@cogeco.com
David Taylor, hereismyalias@duck.com
Deputy to Yves Perron in the federal electoral district of Berthier-Maskinongé, andre.beauchesne.312@parl.gc.ca
Dilan Paradis, Dparadis@nordcom.ca
Eeyou Communications Network, trishtoso@gmail.com
Elizabeth MacKenzie, liz@storm.ca
Ernest Taylor, polarissucks@gmail.com
Federation of Canadian Municipalities, rrizzuto@fcm.ca
First Mile Connectivity Consortium, info@firstmile.ca
First Nation of Nacho Nyak Dun, adrienne.hill@nndfn.com
First Nation of Nacho Nyak Dun, Lisa@badenhorst.ca
Francis Carriere, francis.pj.carriere@gmail.com
Frank Neitzert, phranque_n@outlook.com
Government of the Northwest Territories, dave_heffernan@gov.nt.ca
Government of the Northwest Territories, telecom_reg@gov.nt.ca
Great Northern Wireless Inc., jm@micsystems.ca
Indigenous Connectivity Institute, mark@clearskyconnections.ca
Infrastructure Ontario, gord.reynolds@infrastructureontario.ca
Jacob Shaw, jacobshaw99@hotmail.com
James Trevail, jtrevail@gmail.com
Jen Kightley, Jen.Kightley@yahoo.com
Jocelyn Mallett, jocelyngm@rogers.com
Joey MacPhee, joeymacphee1@gmail.com
Leepfrog Telecom, gchriss@leepfrogtelecom.com
Lora Danielson, loralynn81@gmail.com
Marie-Josée Roy, mariejo458@gmail.com
Matthew Storms, majf.storms@gmail.com
Mattthew Lawrence, matt@bungee.ca
Michael James, michaelbyrnes2022@gmail.com
National Capital FreeNet, execdir@ncf.ca
Northern Sunrise County, lflorence@northernsunrise.net
Ontario Federation of Agriculture , jason.bent@ofa.on.ca
Pawel Wojciechowski, pawcio198012@gmail.com
Province of British Columbia , telecom@gov.bc.ca
Public Interest Advocacy Centre , jlawford@piac.ca
Québecor Média inc., regaffairs@quebecor.com
Rogers Communications Canada Inc., regulatory@rci.rogers.com
Rural Municipalities of Alberta, karrina@rmalberta.com
Sarah Reaume, csreaume@gmail.com
Saskatchewan Association of Rural Municipalities, dnichols@sarm.ca
Saskatchewan Telecommunications (SaskTel), document.control@sasktel.com
Saskatchewan Wheat Development Conseil, james.lokken@saskwheat.ca
SaskCanola, dleftwich@saskcanola.com
Spirit Mobile Inc., christian@spiritmobile.ca
SSi Micro Ltd., dba SSi Canada, regulatory@ssicanada.com
Stéphane Simard, scote@ent-ssimard.com
Steven Lindsay, pearadisesails@gmail.com
Suzanne Olson, Hazelsuzolson@aol.com
TELUS Communications Inc., karen.cheung@telus.com
TERAGO, Daniel.vucinic@terago.ca
The City of Calgary, monique.nesset@calgary.ca
The Coalition, jonathan.holmes@itpa.ca
Viasat, jarrett.taubman@viasat.com
Wesley Dyas, wescdyas@gmail.com
Xplore Inc., cindy.wallace@xplore.ca
CCSA, ceo@ccsaonline.ca
307net, johnlomoro@weboctane.com
KNet LP, jessefiddler@lp.knet.ca
Jason Presement, jpreseme@gmail.com
Blue Sky Economic Growth Corp (Blue Sky Net), susan.church@blueskyregion.ca
Melanie Deslauriers, melaniedeslauriers@hotmail.com
Daren Janes, darenjanes@hotmail.com
Tlicho Government, jonathan.glaisher@tlicho.ca
Taku River Tlingit First Nation, capital@gov.trtfn.com
Kativik Regional Government, dpellerin@krg.ca
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