Telecom Commission Letter Addressed to Dennis Béland (Quebecor Media Inc.)

Ottawa, 13 December 2018

Our reference: CSP 9010-7

BY EMAIL

Mr. Dennis Béland
Vice-President, Regulatory Affairs
Telecommunications
Quebecor Media Inc.
regaffairs@quebecor.com

Re: Request for information on broadband maps and data

Dear Mr Béland:

This is in response to your letter dated 30 November, and subsequent letters from Bell Canada, Bragg Communications Inc., CANWISP, Cogeco Communications Inc., Déry télécom inc., The Independent Telecommunications Providers Association and TELUS Communications Inc. regarding the request for information on the 2017 broadband maps and the associated data sets published by the CRTC.

You have asked that respondent TSPs be requested to provide maps and data as of the date of response rather than as of 31 December 2017. You have also asked that telecommunication service providers (TSPs) be provided the opportunity to provide maps and data related to their near-term (24-month) broadband facility investment plans and you have recommended that the Commission ensure that any projects that have received subsidies under the Connect to Innovate program are incorporated the CRTC’s maps and data.
The CRTC’s 2017 maps and data sets are based on information provided by TSPs to either the CRTC as part of its 2017 annual facilities survey or to Innovation, Science and Economic Development Canada (ISED) as part of its broadband programs.

The purpose of this exercise is to seek TSP feedback on any potential errors or omissions in order to ensure that the published maps and associated data are as accurate as possible as of the 31st of December 2017.  CRTC staff understands that it may be challenging for some TSPs to backdate information to the end of 2017.  Therefore, while TSPs are expected to do their best in identifying any errors or omissions, they are not required to submit comments to the Commission if they are unable to perform this task.

With regard to your concerns about outdated transport coverage data, the current process provides the opportunity for TSPs to provide updated information as of 31 December 2017. Regarding your more general concerns about the possible use of out-of-date information in the awarding of broadband funding, the Commission will be collecting updated and comprehensive 2018 coverage data in early 2019 as part of its annual data collection process. The Commission will consider at a later date how to incorporate in its assessment of broadband funding applications the most up-to-date coverage data at its disposal.

The information received by TSPs must be processed through a lengthy data entry and validation process. This processing includes soliciting input from TSPs who may be delinquent in their response or whose data is anomalous, correcting errors and formatting the data. As a result, data that is typically requested in January is only ready to be published toward the end of the same year, through maps or the CRTC’s Communications Monitoring Report.  It is simply not feasible for 2018 data to be processed on a real time basis.

Regarding the inclusion of near-term investment plans, Commission staff agrees with Bell Canada that TSPs’ broadband roll-out plans can change after the data used to create the maps are provided and before funding applications are submitted.  In addition, including near-term investment plans in the eligibility maps could result in the gaming of the process by a TSP seeking to block a community from eligibility for funding.  

Finally, you have raised a concern that ISED Connect to Innovate projects that have been announced have not been included in the Commission’s maps. This was intentional as many of these projects are still being vetted before implementation begins and may be altered as a result. Additionally, ISED’s program approved projects based on different eligibility criteria including speed requirements that may not meet the CRTC’s eligibility requirements.
In Telecom Regulatory Policy 2018-377, Development of the Commission’s Broadband Fund (TRP 2018-377), the Commission stated that it will consider areas where public funding from other sources, such as CTI or provincial/territorial governments, is committed to a similar project in a manner that does not cause overlap in projects or funding sources, so as to ensure the efficient use of the funds.
As a reminder, the scope of the first call for applications has yet to be determined. As such, the currently published maps and associated data display national coverage for all types of projects, and may not be representative of the eligible areas or project types related to the first call for applications.

In light of the above, the information requested, as well as the 14 December 2018 submission date, remain unchanged. This date was chosen to avoid the holiday season based on the concern, as noted by Bell, regarding the lack of resources within TSPs to respond to the RFI during the impending holiday season.

Sincerely,

Original Signed by Ian Baggley

Ian Baggley
Director General, Planning, Broadband Fund & Networks
Telecommunications Sector

c.c:  Renée Doiron, CRTC, renee.doiron@crtc.gc.ca  
Simon Levasseur, CRTC, simon.levasseur@crtc.gc.ca
Bernard Minuk, CRTC, bernard.minuk@crtc.gc.ca  
Bragg Communications Inc., regulatory.matters@corp.eastlink.ca  
Bell Canada, bell.regulatory@bell.ca
CANWISP, info@canwisp.ca
Cogeco Communications Inc., telecom.regulatory@cogeco.com
Déry télécom inc., diane.serres@derytelecom.ca
The Independent Telecommunications Providers Association, regulatory@itpa.ca
TELUS Communications Inc., regulatory.affairs@telus.com

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