Telecom Procedural Letter Addressed to the Distribution List

Ottawa, 16 October 2017

Our reference: 1011-NOC2017-0112

BY EMAIL

Distribution

Re: Requests for information related to Telecom Notice of Consultation CRTC 2017-112 on the Development of the Commission’s broadband fund regime and further process

Dear Madam, Sir:

In order to assist the Commission in its consideration of the issues set out in the Notice of Consultation, Commission staff is requesting information from parties. Commission staff considers that there are areas of the record that could be further developed. As such, in Appendix 1, Commission staff sets out general questions and invites any party on the distribution list to further comment on these particular issues. All parties may file their answers by 10 November 2017Footnote1 .

In addition, appendices 2 to 8 contain questions specific to certain parties. The responses to these requests for information must be filed by parties named in those appendices via My CRTC Account by 10 November 2017.

Responses should be provided in a single document, addressing requests for information, in order to facilitate accessibility and administrative processing.

As set out in section 39 of the Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, 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.

Parties may file requests for the disclosure of information that has been designated as confidential, serving a copy on the applicable party, by 20 November 2017. Parties may file responses to any such requests, serving a copy on the requesting party, by 27 November 2017.

All parties may file final submissions with the Commission on any matter within the scope of this proceeding by 18 December 2017.

Should you have any questions regarding this letter, please contact Kim Wardle by email at kim.wardle@crtc.gc.ca.

Sincerely,

Original signed by

Chris Seidl
Executive Director
Telecommunications Sector

c.c.:  Kim Wardle, CRTC, 819-997-4945, kim.wardle@crtc.gc.ca;

Distribution List

regulatory@openmedia.org
jlawford@piac.ca
bell.regulatory@bell.ca
document.control@sasktel.com
regulatory.affairs@telus.com
stephen.scofich@tbaytel.com
regulatory@cnoc.ca
telecom.regulatory@cogeco.com  
rwi_gr@rci.rogers.com  
regulatory@sjrb.ca
regulatory@ssimicro.com
kelly@3cis.com
regulatory@bcba.ca
cedwards@ccsa.cable.ca
policy@cybera.ca
regulatory@derytelecom.ca
Regulatory.Matters@corp.eastlink.ca
hglustein@rtscanada.ca
rick@galaxybroadband.ca
jasons@mcsnet.ca
regulatory@teksavvy.ca
cdifrancesco@telesat.com
george.kaichis@wireie.com
cj.prudham@corp.xplornet.com
dennis.beland@quebecor.com
regulatory@swiftnetwork.ca
wyatt.skovron@aamdc.com   
nkrawetz@amm.mb.ca
dfell@eorn.ca
jlawson@fcm.ca
mleblanc@fqm.ca
lmorin@sarm.ca
info@firstmile.ca
bob@albertasouthwest.com
ruth-williams@outlook.com
ben.hyman@bc.libraries.coop
susan.church@blueskyregion.ca
swhitehead@fasken.com
eric@canwisp.ca
cbbc@cbt.org
adaml@corp.cciwireless.ca
david.laureti@fccq.ca
dsmith@inuvialuit.com
barry@ncra.ca
neforum-telecom@qiniq.com
nunavutlibraryassociation@gmail.com 
jen@onenationnetworks.com
mmcnally@ualberta.ca
caronf@tcpubmedia.com
guyrodgers@quebec-elan.org
lis@smartnow.ca
linda_maljan@gov.nt.ca
michelle.wallace@gov.mb.ca
carla.joy@gov.nl.ca
lori.kimball@gov.nu.ca
danpellerin@ictechnologies.ca
jean-jacques.adjizian@mcc.gouv.qc.ca
roman.mateyko@gov.bc.ca
cam.whitehead@ontario.ca
monique.arsenault@novascotia.ca
stephen.bull@gov.ab.ca
steve.sorochan@gov.yk.ca
shathaway@warnercounty.ca
bernard.genereux.c1a@parl.gc.ca
claude.beaulieu@mrcmekinac.com
jouellet@mrctemis.ca
st-adelphe@regionmekinac.com
al.radke@powellriverrd.bc.ca
pgreco@twp.prince.on.ca
kathi.day@strathcona.ca
dave.dumas@ville.rimouski.qc.ca
adameei@qiniq.com
ryan@adamsworks.ca
Howard.Heitner@mcgill.ca
sophie.legault@gmail.com
luxmoredaniel@yahoo.ca
fenwick.mckelvey@concordia.ca
patrick_riley@hotmail.com
johnphiliproman@gmail.com
eric@rothschildco.com
tshowell1003@highland.net
mike.bossio@parl.gc.ca

Appendix 1:  Questions for all parties on the distribution list

  1. Many parties have referenced Innovation, Science and Economic Development Canada (ISED) and the Connect to Innovate (CTI) program in their interventions and replies. Some parties suggested that the Commission name ISED as the third-party administrator responsible for the project management function. Others have commented that the Commission or the third-party should use ISED staff and/or data when reviewing applications. Some recommended that the Commission model its fund off of ISED’s, using the same or similar criteria, but without ISED’s direct involvement. In order to better comprehend the suggestions and arguments that parties have proposed, the Commission is seeking comments on the following questions:
    1. Do you agree that ISED should be involved?
    2. If ISED were to be involved, what should their role and responsibilities be?
    3. Do you foresee any issues (policy, legal, financial, administrative or otherwise) with ISED’s participation in the Commission’s broadband funding regime?
  2. In Telecom Regulatory Policy 2016-496, the Commission determined that a third party or third parties will operate the fund at arm’s length in a manner that is transparent and efficient. What process should be used to reimburse the third party or parties for expenses incurred from performing their roles and responsibilities, and would this process need to be modified depending on which type of entity the Commission chooses to perform the role?
  3. In order to create a final administrative board to administer the Broadband fund, the Commission could appoint an interim board similar as it did in Telecom Regulatory Policy 2014-187, when the Commission established a video relay service administrator. This interim board would be responsible for completing the steps necessary to create the non-profit corporate entity, and establishing and running the election process for permanent board members with the Commission’s directions. Who do you think should constitute this interim board?
  4. There are divergent viewpoints on whether applications should be selected for funding using a comparative selection process, such as that conducted by ISED for its Connect to Innovate program, or a reverse auction process as proposed by the National Pensioners Federation and Public Interest Advocacy Centre and Bell Canada (NPF-PIAC/Bell). Compare the two processes in view of the principles set out in Appendix B of the 25 August 2017 National Pensioners Federation and Public Interest Advocacy Centre (NPF‑PIAC) Reply Comments. The response should also elaborate on the benefits and challenges of each process, in particular with respect to:
    1. Level of administrative overhead;
    2. Fairness and transparency;
    3. Self-policing of project costs to ensure cost-effectiveness of subsidy;
    4. Ease of the funding application process.
  5. Many parties to this proceeding have proposed different processes to award funds from the broadband funding regime. In an effort to better conceptualize the various processes proposed, describe the decision making process (e.g. the flow and detailed description of the necessary steps and/or tasks) that you are advocating. Ensure that your description refers to each administrative body (e.g. the Commission, a third-party administrator, an entity governed by a board of directors, etc.) that you believe should take part in the broadband fund administrative and decision making process and fully explains what function each administrative body will be performing.
  6. Some parties advocated for applicants to get input from local community representatives. Do you agree that the broadband fund regime should actively solicit involvement with local communities? If yes, answer the following questions:
    1. What is the best process for increasing awareness and involvement of local communities in the broadband fund regime? How should such a process be implemented? Comment on which of the following examples would best engage local communities in the regime and what benefits would be realized as a result of using that process:
      • ‘Consultation’ prior to an application being filed to serve a local community (e.g. an eligibility requirement of engagement or support);
      • Local community ownership or participation to serve a community;
      • Support to assist local communities to file applications for funding;
      • ‘Consultation’ during the application (e.g. provide notice that an application has been filed and/or an opportunity to comment on an application filed related to a community);
      • Explicitly allowing funds to be used for accommodations (e.g. revenue sharing, training, local benefits, etc.); and
      • Local community decision-making (e.g. representation, using the Natural Sciences and Engineering Research Council of Canada (NSERC) model, where NSERC’s governing body is a council composed of a President and up to 18 other members, and grants and scholarships are awarded through a competitive peer review process that involves smaller, specialized, selection committees with local community representation on the individual committees created to review each application).
    2. How can a local community best be involved in the broadband fund regime in an efficient manner that does not unduly delay the application process and/or the application review process?
  7. In paragraphs 44-46 and questions 38-41 of Appendix 2 of Telecom Notice of Consultation CRTC 2017-112, the Commission raised the possibility of identifying “priority underserved” geographic areas for funding. In reply, some parties proposed prioritizing, among other things:
    • Rural, remote, and/or northern areas;
    • Satellite-dependent communities;
    • Allocating separate funding envelopes for terrestrial unserved and underserved communities, as well as by region (province or territory they are located in);
    • Categorizing applications into three categories (major, regional, and local);
    • Areas that are the most difficult-to-serve;
    • Areas categorized by their closeness to transport; and
    • Areas where private capital will not be deployed over the next five years to create networks sufficient to meet the universal service objective established by the Commission in Telecom Regulatory Policy 2016-496.
    1. Indicate whether and why a call for applications for broadband funding should be open to all projects at once or if the Commission should issue different calls for specific prioritized area. Specify which process would be most efficient for (i) prospective applicants, and (ii) the broadband fund administrator.
    2. Should the Commission prioritize different areas in different calls for applications? If so, why and how?
    3. Are there certain methods of prioritization that could provide an advantage or disadvantage certain types of prospective applicants? How?
  8. Some parties, such as the Cree Nation Government and the Eeyou Communications Network, were of the view that mobile services would be important for underserved and unserved transportation roads. What metrics/assessment criteria should applicants provide, such that projects proposing mobile services can be assessed against each other? For example, should applicants provide:
    1. The distance travelled on the transportation road without coverage;
    2. The distance from the unserved/underserved portion of the transportation road to the nearest served community; and/or
    3. The amount of automobile traffic on the unserved/underserved portion of the transportation road in a given period of time.
  9. Several parties to this proceeding were of the view that the broadband funding regime should prioritize funding to Indigenous communities. Alternately, parties have suggested that the Commission could prioritize or positively weight applicants that include Indigenous representation or are composed of a certain proportion of Indigenous peoples (for example, an application by an Indigenous community or by a company that is owned in some part by Indigenous peoples).
    1. How should an Indigenous community be defined for the purpose of the broadband fund?
    2. How could Indigenous communities be better engaged in the broadband fund regime?
  10. Some parties suggested that the broadband fund regime should discourage the use of funds for overbuilding networks. For example, on page 5 of Attachment A of Rogers Communications Canada Inc.’s (RCCI) 28 June 2017 intervention, RCCI proposed that there should be a mechanism for competitors to challenge the funding of a project on the grounds that it already has a service that meets the Basic Service standard, or will have one within the next two years (emphasis added). Alternately, some parties suggested that the process could require service providers to identify areas where future builds are to occur, such that the appropriate information is available to identify applications that would result in overbuilds.
    1. If the Commission decides to discourage the use of broadband funds for overbuilding networks, how should the broadband fund process ensure that no funds are allocated to overbuilding?
    2. What factors should the Commission consider, and why?
    3. How can the Commission ensure that service providers could not use such a process to “block” applicants or prospective applicants from securing funding for competitive reasons?
  11. In paragraph 133 and 134 of Bell Canada’s 28 June 2017 intervention, Bell Canada suggested that the Commission could broadly earmark terrestrial funds by province and territory, by:  1) the percentage of telecom subscribers from each province and territory, 2) the percentage of underserved and unserved premises represented by each province and territory, or 3) by provincial/territorial population. Bell Canada further provided a table illustrating what its prioritization plan may look like.

    Similarly, Columbia Basin Trust proposed that funds could be allocated into three categories:  major, regional, and local.

    In paragraph 52 of TCC’s 25 September 2017 reply comments, TCC argued that Bell Canada’s proposal to earmark terrestrial funds by province and territory would limit efficiency and creativity due to a subjective preselection of what precisely is being auctioned.

    1. Should the broadband fund regime allocate funds into different envelopes, representing different geographical or provincial/territorial regions? Why or why not?
    2. Is Bell Canada’s proposal to proportionally earmark terrestrial funds by province and by territory appropriate? Is the proportional distribution of telecom subscribers representative of the proportional distribution of unserved and underserved communities? Why or why not?
      1. If not, provide examples of provinces and/or territories which would likely be disadvantaged as a result of such a proportional distribution of funding.
    3. Would such a distribution of funding limit successful applications due to limited funds available in a specific province or territory? For example, would some projects be unattainable due to a limited amount of funding in a specific province or territory?
    4. Are there projects that could be located in more than one province or territory? If so, how could the broadband fund account for such applications if the funds are earmarked as proposed by Bell Canada?
  12. In its 28 June 2017 intervention, Bell recommended that, at this time, the minimum service standard for funding for satellite-dependent communities be set at 25 Mbps/3 Mbps with a monthly data plan of 100 GB.
    1. Do you agree with Bell’s recommendation to set a minimum service standard for funding for satellite-dependent communities?
    2. If so, do you agree with the minimum service standard proposed by Bell and if not, what minimum service standard should be established and why?
  13. In paragraph 41 of its 28 June 2017 intervention, SWIFT submitted that “wholesale access obligations that enable third party entities (e.g. other service providers, large organizations such as schools, hospitals) to interconnect with publicly subsidized networks should be viewed as a requirement for eligibility for the funding regime. This is a particularly important requirement to have in higher-cost communities as it will encourage cooperation and risk sharing among operators and with public sector users. Anticipated wholesale pricing approach and the degree by which it is expected to improve affordability of services in a targeted community should be a critical consideration in assessing proposals.”
    1. Comment, with supporting rationale, on whether a service provider that builds access infrastructure with support from the broadband fund should be subject to wholesale obligations. If so, describe the type of wholesale obligations and regulatory measures (existing or new) that would be needed (e.g. mandated wholesale service at market rates, mandated wholesale service with regulated rates) and why.
    2. Comment, with supporting rationale, on whether a service provider that builds transport infrastructure with support from the broadband fund should be subject to wholesale obligations. If so, describe the type of wholesale obligations and regulatory measures (existing or new) that would be needed (e.g. mandated wholesale service at market rates, mandated wholesale service with regulated rates) and why.
  14. In paragraph 10 of its 28 June 2017 intervention Teksavvy submitted that “…recognizing that it is more difficult to provide wholesale access below scale, service providers serving less than 20,000 endpoints should be permitted to deploy funded projects without providing wholesale access—except that, in such cases, the retail rates of resulting services offered to end-users would instead be regulated directly by the Commission. Smaller service providers preferring to avoid retail regulation would implement wholesale access.”
    1. Should such a threshold based on endpoints, or end-users, be established? If so, what is an appropriate threshold?
    2. Comment on Teksavvy's proposal that the Commission should regulate retail rates.
  15. Appendix 2:  Questions for Bell Canada (Bell) and the National Pensioners Federation and Public Interest Advocacy Centre (NPF-PIAC)

    Refer to the 25 August 2017 NPF-PIAC Reply, Appendix B:  Design Principles developed in collaboration with Bell, where NPF-PIAC and Bell (NPF-PIAC/Bell) jointly propose principles based on the FCC’s reverse auction approach to allocating funds. Also, in section I - Priority areas, NPF-PIAC/Bell submitted that “Acceptable types of priority areas would include non-satellite dependent communities that are unserved and non-satellite dependent communities that are underserved at a specific speed threshold”.

    1. Describe in detail the proposed reverse auction process, its design and the steps involved. Explain whether multiple rounds are required and if so how the multiple rounds would be designed and implemented. If the proposed reverse auction process requires a base-clock percentage, explain its purpose, and how it would be used in the reverse auction process. Note that FCC’s reserve auction mechanism is described in its Public Notice DA 17-733, Technical Guide on Proposed Bidding Procedures for the Connect America Fund Phase II Auction. It refers to a base-clock percentage to determine the range of percentages at which bidders can place bids during a round.
    2. Also refer to Appendix A of the NPF-PIAC/Bell reply comments, which state that “the Commission should use the best geographic data available, which will generally be household-level data, to avoid excluding partially unserved or underserved geographic units.” To further elaborate on the details of the referenced principle, provide a detailed description, with examples, of the other steps required to operationalize the proposed “reverse auction” model with respect to:
      1. Selecting the eligible and priority areas, elaborating on how the principle of using the best geographic data could be operationalized with respect to selecting the eligible and priority areas;
      2. Establishing funding envelopes according to eligible and priority areas;
      3. How the objectives of transparency and fairness could be incorporated into the eligible and priority area selection and the establishment of funding envelopes.
  16. In paragraph 24 of NPF-PIAC’s 25 August 2017 reply, NPF-PIAC stated that the transport provider should either make retail price and speed commitments, or partner with a retail provider who can make such commitments. Does this statement mean that it is NFP-PIAC’s position that the broadband fund should not provide funds for projects that propose to provide transport without also providing an access or last-mile component? If yes, provide rationale for this position. If not, explain how the process should evaluate transport versus last-mile access projects?
  17. Refer to paragraph 60 of NPF-PIAC’s 25 August 2017 reply where NPF-PIAC stated that “Generally, applicants should be required to meet the USO (50/10 with an unlimited option). However that requirement may be modified where terrain and population dispersion may make fixed wireless the only viable option.”
    1. Provide details on how the proposed model for a reverse auction mechanism would operationalize the requirement that applicants meet the Universal Service Objective (USO).
    2. Explain how that requirement may be modified and operationalized for areas where fixed wireless may be the only viable option, providing concrete examples and suggestions.
  18. Refer to paragraph 15 of the 25 August 2017 NPF-PIAC Reply, in which NPF-PIAC proposed requiring all applicants to offer prices reasonably comparable to urban/unsubsidized areas. Define “reasonably comparable” and explain the steps that would be needed within the proposed model for a reverse auction mechanism to ensure the requirement that all applicants offer prices that are reasonably comparable to urban/unsubsidized areas is met.
  19. Refer to paragraph 62 of NPF-PIAC’s 25 August 2017 reply in which NPF-PIAC proposed that applicants “offer 100% coverage for a hexagon, with coverage down to 90% tolerated at a loss of 2% of the subsidy for each 1% of homes not connected.” Provide details on how the proposed model would take into account, using the weighted scoring formula, applications that provide coverage down to 90%. Further explain how the loss of 2% of the subsidy for each 1% of homes not connected would be monitored and administered.
  20. Describe the roles of the Commission and the fund administrator if the process to select applications for funding was based on the proposed NPF-PIAC/Bell model for a reverse auction mechanism. Provide a clear delineation of the roles of the Commission, the fund administrator and/or any other third party performing the accounting function for the fund. The response should describe in detail all roles pertaining to each body, including but not limited to specific roles such as public consultations for local community engagement and coordination with local and regional initiatives, activities to educate and assist potential bidders, pre-determining bidder eligibility, overbuild screening, ensuring transparency, weight selection and weighted formula administration by each funding envelope, and quality of service checks.
  21. At E)2 of Appendix B of NPF-PIAC’s 25 August 2017 reply, NPF PIAC proposes that “given the limited amount of funds available, we recommend that funding not be allocated to areas where 50 Mbps download speeds are available until the Commission has funded all reasonably cost-effective project proposals for areas with lower levels of existing service.” Define “reasonably cost-effective project proposals”. How can it be determined that a project proposal is not reasonably cost-effective?

    Appendix 3:  Question for the National Pensioners Federation and Public Interest Advocacy Centre (NPF-PIAC)

  22. In paragraph 57 of NPF-PIAC’s 25 August 2017 reply, NPF-PIAC proposes that the Commission should initially allocate all subsidy funding for the first five years to envelopes dedicated to unserved and dramatically underserved households, rather than exclude areas which the Commission believes are likely to be served by private investment. How would this proposed method avoid interfering with market forces that might otherwise result in the provision of service to unserved or dramatically underserved households?

    Appendix 4:  Questions for Blue Sky Economic Growth Corp. (Blue Sky Net) and Rogers Communications Canada Inc. (Rogers)

  23. In its 28 June 2017 intervention Blue Sky Net submitted that satellite-dependent communities “should not be treated any differently than other rural communities in need for connectivity”. In its 28 June 2017 intervention, Rogers indicated that satellite-dependent communities’ component of the fund should be implemented in much the same way as the other components.
    1. Should all applications for broadband funding be assessed against each other, regardless of the type of technology or community for which it is requested?
    2. Should the Commission consider both capital and operational costs eligible for satellite and terrestrial projects targeting satellite-dependent communities?

    Appendix 5:  Question for Bell Canada (Bell), Eastern Ontario Wardens’ Caucus and Eastern Ontario Regional Network (EORN/EOWC), the Federation of Canadian Municipalities (FCM), the Government of Northwest Territories and the National Pensioners Federation and Public Interest Advocacy Centre (NPF-PIAC)

  24. Many parties suggested that the Commission, given the nature of satellite retail services and the remoteness of satellite-dependent communities, should implement a specific strategy for these communities. For example, in paragraph 30 of its 28 June 2017 intervention, the FCM submitted that “identifying funding for satellite-dependent communities as a separate subset of overall funding is appropriate because of the unique needs of these communities (…). FCM believes applications for this pool of funding should be assessed separately from other applications”.

    In the event that the Commission implements a specific process to assess applications for satellite-dependent communities’, should it use different assessment criteria for satellite dependent communities’ projects and if so, what specific criteria should be considered?

    Appendix 6:  Questions for Bell Canada (Bell) and Saskatchewan Telecommunications (SaskTel)

  25. In paragraph 63 of its 28 June 2017 intervention, SaskTel submitted that a 50/10 Mbps speed goal will never be feasible with current technology and the high cost of the satellite backhaul facilities required. SaskTel suggested that a lower end goal may need to be established for communities in which satellite is the only option until alternative technologies are available. In its 28 June 2017 intervention, Bell recommended that, at this time, the minimum service standard for funding for satellite-dependent communities should be set at 25 Mbps/3 Mbps with a monthly data plan of 100 GB.
    1. Please provide further details on the specific technical limitations and costs that would prevent broadband service in satellite-dependent communities from reaching the 50 Mbps/10 Mbps speed objective.
    2. Could any satellite providers provide a service that would enable broadband access speeds of 50 Mbps/10 Mbps in the foreseeable future?
    3. Please comment on the alternative technologies and timelines that could make 50/10 feasible in the future.

    Appendix 7:  Questions for the Governments of Manitoba, Newfoundland and Labrador, Northwest Territories, Nunavut, and Yukon, the Ministère de l'Économie de la Science et de l'Innovation / Ministère de la Culture et des Communications (Québec), the Ministry of Technology, Innovation and Citizens of British Columbia, the Ontario Ministry of Infrastructure on behalf of various parties, the Province of Nova Scotia, Department of Business, Service Alberta, and the Kativik Regional Government, All Nations Trust Company, Association of Manitoba Municipalities (AMM), BC Libraries Cooperative, British Columbia Broadband Association (BCBA), Canadian Association of Wireless Internet Service Providers (CANWISP), Canadian Cable Systems Alliance Inc. (CCSA), Canadian Network Operators Consortium Inc. (CNOC), Columbia Basin Broadband Corporation (CBBC), Eastern Ontario Wardens’ Caucus and Eastern Ontario Regional Network (EORN/EOWC), Eeyou Communications Network, First Mile Connectivity Consortium (FMCC), National Pensioners Federation and Public Interest Advocacy Centre (NPF-PIAC), Nunavut Economic Forum Coalition, Rogers Communications Canada Inc., Rothschild and Co. Ltd., OpenMedia, and West Parry Sound SMART Community Inc.,

  26. Some parties proposed forming sub-committees or advisory groups made up of representatives possessing expertise (geographic, technical and otherwise) relevant to the specific applications being evaluated in order to ensure that the best projects are selected and that topical and local considerations be taken into consideration, while others recommended that this expertise be housed within the board(s) of directors. In light of this:
    1. Is it necessary for regional representatives to be involved in the selection process?
    2. If so, where should this expertise be housed (sub-committee, advisory group or within the board(s) of directors etc.); what process should be used to determine who should represent the interests of different regions, provinces and territories; what role would these representatives play; and at what stage in the process should they be involved?

    Appendix 8: Questions for the Governments of Manitoba, Newfoundland and Labrador, Northwest Territories, Nunavut, and Yukon, the Ministère de l'Économie de la Science et de l'Innovation / Ministère de la Culture et des Communications (Québec), the Ministry of Technology, Innovation and Citizens of British Columbia, the Ontario Ministry of Infrastructure on behalf of various parties, the Province of Nova Scotia, Department of Business, Service Alberta, and the Kativik Regional Government

  27. As part of their different submissions, provinces/territories expressed concerns with collaboration between provincial programs and the fund:
    1. How could the province/territories and the Commission share information regarding funding programs and provincial priorities?
    2. What instrument, if any, could be used to formalize this relationship?
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