Telecom Commission Letter Addressed to Susan Hart (Innovation, Science and Economic Development Canada)

Ottawa, 16 October 2017

Our reference: 1011-NOC2017-0112

BY EMAIL

Ms. Susan Hart
Director General, Broadband Programs Branch
Innovation, Science and Economic Development Canada
susan.hart2@canada.ca

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 Ms. Hart,

In Telecom Regulatory Policy CRTC 2016-496 the Commission announced that it would create a broadband funding regime to support continuing access of Canadians to this basic telecommunications service, pursuant to section 46.5 of the Telecommunications Act. In Telecom Notice of Consultation 2017-112, the Commission set out its preliminary view that the project management functions listed in Appendix 1 to that Notice should be fulfilled by a third-party administrator, who would be responsible, among other things, for receiving and reviewing applications and providing to the Commission a list of eligible applications, including projects recommended for funding.

As part of this proceeding, parties have suggestedFootnote1 several approaches for allocating funds. For example, some parties have suggested creating a program similar in nature to that of Innovation, Science and Economic Development Canada’s (ISED) Connect to Innovate (CTI) program, while others have proposed a reverse auction model similar to that used by the United States’ Federal Communications Commission or a regional/community-based decision-making approach.

In the context of these proposed approaches, several parties to this proceeding have suggested that ISED, given its experience with its CTI program, should play a role in the Commission’s Broadband Fund. The type of involvement suggested by parties ranges from that of coordinating and sharing of best practices, to designating ISED to oversee the project management function. Parties have also suggested options within this range, including ISED providing staff or specific tools to be used by the Commission or a third-party administrator in its evaluation of applications.

In order to evaluate the submissions of parties, it would be beneficial for the Commission to have on the public record of the proceeding certain factual information with respect to the capacity of ISED to participate in the administration of the Commission’s Broadband Fund:

  1. Would ISED be capable of fulfilling any of the following tasks, either on its own or in conjunction with a third-party administrator or the Commission as appropriate:
    1. Produce for Commission approval an assessment tool (such as an assessment grid) and a guide for applicants to the Broadband Fund;
    2. Administer the applications process;
      • Receive applications;
      • Answer procedural questions posed by applicants or potential applicants;
      • Create and provide to the Commission a list of eligible applications using the criteria as determined by the Commission;
    3. Manage funding agreements with those granted funds by the Commission;
      • Prepare and sign funding agreements with Fund recipients;
      • Inform the third-party administrator for the accounting function and/or the Commission that conditions for the release of funds pursuant to the funding agreement have been met and that funds can be released;
      • Certify compliance of fund recipients with their funding agreements based on interim, annual, and final performance reports;
    4. Collect data from fund recipients required for;
      • The approval of applications;
      • The enforcement of funding agreements; and
      • As requested by the Commission; and
    5. File with the Commission annual public reports on the performance of the broadband fund.
  2. Indicate any concerns that ISED has identified (policy, legal, financial, administrative or otherwise) that would affect its ability to perform any of the tasks listed above.

In order to ensure that parties have the opportunity to comment on the information provided by ISED on the public record, the Commission would appreciate if responses to these questions could be filed by 22 November 2017.

Yours sincerely,

Original signed by

Chris Seidl
Executive Director
Telecommunications Sector
c.c.:  Kim Wardle, CRTC, 819-997-4945, kim.wardle@crtc.gc.ca

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