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866775-300990285753657602352675215265321183080645 -752475153035The “Affordable Access Coalition”FINAL SUBMISSIONTelecom Notice of Consultation CRTC 2015-134 (as amended)Review of basic telecommunications services25 May 2016Contents TOC \o "1-3" \h \z \u I. Introduction and Overview PAGEREF _Toc451960569 \h 1II. It is time: The Commission must declare broadband “basic” PAGEREF _Toc451960570 \h 3III. Funding needed until market forces, government funding, and satellite actually deliver “basic” broadband to all Canadians PAGEREF _Toc451960571 \h 11IV. The Commission must act to support low-income Canadians PAGEREF _Toc451960572 \h 15V. The Cost of the AAC’s Proposals PAGEREF _Toc451960573 \h 20VI. The AAC’s plan for a National Broadband Action Strategy PAGEREF _Toc451960574 \h 23The AAC’s Action Plan PAGEREF _Toc451960575 \h 24The AAC’s comments on the National Broadband Task Force Report PAGEREF _Toc451960576 \h 25VII. Conclusion: A Call to Action PAGEREF _Toc451960577 \h 29I. Introduction and OverviewThe Affordable Access Coalition (the “AAC”) represents the largest coalition of public interest and consumer groups in Review of basic telecommunications services, Telecom Notice of Consultation 2015-134 (as amended).This proceeding is about ensuring Canadians have access to “basic telecommunications services”. The proceeding is not about ensuring all Canadians can access high-end telecommunications services. It is, as Commissioners repeatedly commented at the hearing, about “needs, not wants.” This proceeding is about the four corners of the Telecommunications Act, not human rights. This proceeding is principally about facilitating “the orderly development throughout Canada of a telecommunications system that serves to safeguard, enrich and strengthen the social and economic fabric of Canada and its regions”; rendering “reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada”; and responding to the “economic and social requirements of users of telecommunications services”. Fundamentally, this proceeding is about the two digital divides the AAC cited in its first intervention – the technical digital divide (access), and the socio-economic digital divide (affordability), and which the Minister of Innovation, Science and Economic Development recently cited. The AAC’s proposals revolve around (i) the need for basic broadband; and (ii) the need to address affordability of telecommunications services for low-income Canadians.Regarding the need for basic broadband, the evidence supports a finding that broadband should be considered a basic telecommunications service. The Commission has recognized this. The question remains: What speed is “basic” broadband? Regarding affordability, the record indicates that many low income Canadians are struggling to afford essential telecommunications services.As the Chairperson said on behalf of entire Commission panel, “Clearly, the CRTC has work to do under its jurisdiction.” The question is: What to do?Steps the Commission can take without delay The AAC’s high-level response is that question is the Commission must do something. The Commission has before it a considerable record containing extensive research on the Canadian telecommunications system, public opinion research, and direct evidence from numerous service providers, users, and public interest groups. It should not be an option to accept the status quo on broadband, or to proceed with proposals for further discussion, when it is clear that broadband access is essential, and low-income Canadians are struggling to afford basic telecommunications services. In terms of specific actions, there are five steps the Commission can take without delay in furtherance of the Canadian telecommunications policy objectives cited above. The AAC has in its interventions and evidence tabled what is in effect an action plan, and one that accords with the Commission’s jurisdiction and mandate under the Telecommunications Act. The most obvious immediate steps the Commission should take, based on the record, are to declare broadband of at least 10/1, if not 10/3, to be a basic telecommunications service, to establish a fund which provides incentives to build to areas where no business case exists, and to implement an affordability subsidy. Taking these and other steps, and actively monitoring and making necessary course corrections, would support the user-focussed Canadian telecommunications policy objectives.The balance of this final submission expands upon these points. In Section II the AAC explains why “basic telecommunications services” necessarily includes broadband of at least 10 Mbps download, and at least 1 Mbps upload (“10/1”), if not 10/3 (as numerous interveners advocated) and other quality of service standards, and should still include voice.In Section III the AAC argues that the Commission should adopt the AAC’s Broadband Deployment Funding Mechanism (“BDFM”) and responds to various industry viewpoints that the Commission should leave the problem of universal broadband to market forces, government funding, and unproven or un-deployed satellite services.In Section IV the AAC argues that the Commission should adopt the AAC’s Affordability Funding Mechanism (“AFM"), and responds to certain views that governments (federal and provincial) are better situated to address what is a widely seen as a telecommunications affordability problem for low-income Canadians.In Section V the AAC addresses Rogers’ inaccurate re-costing of the AAC’s funding proposals, proposals that Canadians appear willing to support and fund, as do several other parties.In Section VI the AAC provides its views on the National Broadband Task Force Report and a national broadband action strategy, and explains how the AAC’s proposals amount to an immediately actionable plan.In Section VII the AAC issues a call to action to the Commission, based on what the Telecommunications Act requires of the Commission to do in the legitimate performance of its duties. II. It is time: The Commission must declare broadband “basic”It is time to recognize that broadband is a basic telecommunications service. The AAC believes that the Commission has recognized this: 7564 Overall, in a nutshell, witnesses that appeared so far have agreed to a self-evident truth. Today, in Canada, broadband is vital.7566 So unless you disagree with this conclusion, let us not spend more hearing time on this self-evident truth. We have other more important things to focus on.7583 As you can see, the acknowledgement of broadband being vital to economic, social, democratic and cultural success of individuals and collectivities is a given. […] Chairman Blais accurately portrayed the opportunity costs (human and financial) and consequences of failing to act now. There is a cost to Canadians, to small and medium enterprises, and to Canada’s competitive advantage. The AAC detailed and expounded on the full definition of “Basic telecommunications service” in its various interventions. Most pertinent to these final arguments are the AAC’s proposal that “basic telecommunications” should be defined as a “high quality telecommunications network connection” that provides, beyond voice service, the functional equivalent of (among other things): Capability to connect via broadband transmission to the internet; and a reasonable monthly data allotment for any such internet connection before additional charges are levied.The Commission should therefore set the a minimum level of broadband functionality that all Canadians can expect to be able to use reliably to meet their household’s needs, without anachronistic limits to functionality that only enables one-user, using one-device, for one application. While the AAC is not advocating for high-level broadband access, it is no longer realistic to restrict broadband to a telephone-like paradigm when most Canadian households have multiple users, using multiple devices, for multiple applications, to perform essential tasks. Yet a number of service providers are seeking to keep expectations dismally low by suggesting, for example, that video functionality, because it is often used to consume “entertainment”, is a “want”, but not a “need”, or that Canadians should not expect to count on having multiple users access basic broadband at any given time. The AAC submits that Canadians need to know that it is not only permitted to make reasonable use of broadband in daily life, but that they can expect their broadband access to live up to their realistic needs. The Commission did not concern itself with the usage and content of telephone calls when it declared voice to be a basic service, and it similarly should not when it comes to broadband. The Commission should only concern itself with ensuring that all Canadians have reasonable access to broadband services that allow them to participate in our country’s social and economic life. To the extent that Canadians increasingly consume video services, including videos for education and health, it is irrelevant that the functionality may also enable consumption of things Canadians may “want”. The AAC believes that basic broadband is at least 10 Mbps download and 1 Mbps upload ("10/1"). Many other interveners proposed similar or higher basic speed targets, with a notable number proposing 25/1 or 25/3. A number of telecommunications service providers also gave support of various sorts to a 10/1 Mbps target. Reasons for a target speed of at least 10 Mbps down, if not higher, include current average subscriber speeds hovering above 20 Mbps; future-proofing scaling capacity and preventing early obsolescence and duplicate investment; adequate capability to serve users with disabilities; and the fact that TSPs themselves instill such expectations in users, as Chairman Blais observed and as the AAC presented evidence demonstrating.The 50-80 rule that the AAC proposed also likely gives rise to 10/1 as the minimum basic speed today, based on the 2015 Communications Monitoring Report, as detailed in the AAC’s further intervention. This is a clear, objective benchmarking tool the Commission may use to give to the minority who lack access what the majority already has, rather than a more subjective assessment implicated by a “needs and wants” analysis.TSPs’ arguments that 5/1 Mbps suffices as basic do not stand up to the evidence and testimony on the record in this proceeding. Interveners pointed out, for instance, that the 5/1 target is “being overtaken by the bandwidth demands of available applications”; that it limits regional economic development; and that it fails to meet the needs of users with disabilities. Time will only exacerbate this deficiency. The graph relied on by TSPs in Exhibit 1 indicates that 5/1 suffices only for one person and assuming no additional challenges such as a disability, weather-sensitive technology, or very low data caps. It does not account for households with multiple people and multiple devices connecting at one time, or for people with additional connectivity needs or challenges. The fact that 5/1 may suffice for one representative from a company such as Bell Canada is not evidence that 5/1 is “basic” for all other Canadians. As Shaw said, despite supporting 5/1: “[I]f you build anything we should be building it to at least 25/3. If there's money from somewhere that isn't 100 percent private investment, there's no advantage at this point to building the 5 and 1.” TSP market offerings also suggest that 10/1 is now basic.The AAC also urges the Commission to reject self-serving arguments such as Bell advocating against setting a standard higher than 5/1 by saying “you’re increasing the size of the problem”. Once a problem is established—such as through evidence and testimony of actual internet users, non-profit and community-oriented ISPs, surveys, and public interest groups—the problem does not change size according to fiat; it remains the same size regardless of which part of it we choose to acknowledge as a problem. As the Chair articulated in response to similar thinking from SaskTel, “[W]e don’t build substandard to cover more people; we find the correct standard and then we find the money.”Finally, it is worth remembering among granular details the overriding purpose of this entire exercise: “[N]eeds for what? [I]n setting a specific threshold it’s not just about needs to just scrape by in your current situation, but making sure that you don’t undercut the advantages of being connected to broadband.” Considering that “5-1 service...is the dial-up of the 21st century”; that the 5/1 targets “were inadequate when the Commission adopted them five years ago”; and that remaining at the 5/1 “inflection point” may “incent people to take subsidies to build basic copper loops” that will quickly become obsolete, the Commissioners must force service providers to answer one simple question: “[D]o they want to be internet service providers of the 21st century, or not”?The AAC rooted its 1 Mbps upload recommendation in the 50-80 rule; however, evidence from the proceeding suggests a 3 Mbps upload target is appropriate and equally important, with several interveners calling for symmetrical target speeds. Many argued that robust upload speed can be just as critical as download, whether for reasonable upload times of everyday life content; running a business; cloud computing and the Internet of Things; or functional connectivity for users with disabilities. Smaller, independent, and community TSPs such as Axia and the CCSA also indicated the importance of higher upload speeds. While Rogers, SaskTel, and Bell stated VRS does not require 1 Mbps upload, it seems valid to concede the point to those who actually use and rely on such services daily for essential functions. As OpenMedia stated, large TSPs’ positions on required upload “has little or nothing to do with what the incumbent ISPs think that their customers actually need”; SaskTel demonstrated this particularly well in their exchange with Chairperson Blais.In setting the future of the Canadian digital economy, or society, it is absolutely critical that the Commission allow for true, active participation through content creation, interlocution, and innovative emergent uses not yet dreamt of, to avoid limiting Canadians to passive participation through consumption. Seemingly the only cases in which TSPs conceded higher upload was in the context of business; however, what if an individual requires the same functions in the context of running a non-profit group, sharing their artwork, crowdsourcing rare diagnoses (such as with CrowdMed and Figurel), live journalism, or mobilizing a political movement? The AAC cautions the Commission against accepting SaskTel’s implied suggestion that an area with less than 1 up may still be considered served and rather must set a target “to send a signal that symmetric bandwidth [or working towards it] is extremely important”.The Commission should also avoid tiered targets, and treat rural and urban areas as equally and equitably as possible, a point best articulated by those best placed to speak: [T]he idea that for remote and isolated communities, [“]maybe it just can’t be done in terms of that higher level[“]. What I might say to that is I don’t expect that we would accept that premise, especially when we’re considering that we’re talking about the telecommunications industry and services. If there is any industry where the sky is the limit and where you can count of innovative and creative advancements, it’s with that technology sector.And so we’re advocating for a minimum standard that needs to be met for all Canadians. [...][I]n representing, you know, northern First Nation communities and that married with the technology sector, I just don’t know that we can accept that there’s not a solution out there when we see how far we’ve come...“We ask that you reject the assumption that Nunavut is an acceptable anomaly.”The specific speed target of basic broadband service should also be set as a minimum standard, or “at least”, rather than “as advertised” or “up to”. The numerous complaints and difficulties customers faced, as put on the record by interveners, attest to the need for actual service levels. The AAC notes that the Commission set its previous “target” speeds in 2011 as “actual speeds delivered, not merely those advertised”, but also acknowledged that access speeds were affected by a “wide range of factors, some of which are outside the control of the network provider”. The AAC believes that “actual speeds delivered” ought to be the standard, without qualification.Finally, the Commission should avoid implicitly telling Canadians what they can and cannot do online, in setting the basic speed targets, despite large service providers’ comments on activities deemed “entertainment”. The Commission did not concern itself with the usage and content of telephone calls when it declared voice to be a basic service, and similarly it should not when it comes to broadband. The Commission should only concern itself with ensuring that all Canadians have reasonable access to broadband services that allow them to participate in our country’s social and economic life. To the extent that Canadians increasingly consume video services, it is irrelevant that the functionality may also enable consumption of things Canadians may “want”. As Commissioner Vennard expressed, “[T]he bandwidth is the bandwidth [whether] you’re using it for a health application or...Netflix”. Looking beyond speed, the Commission should set basic service targets for quality of service standards including latency, jitter, packet loss, and downtime—qualities that can impact the user experience and connectivity as much as if not more than speed. This could be monitored through a CISC working group or tools such as M-Lab, SamKnows, or CIRA’s Internet Performance Test. Multiple interveners in addition to the AAC recommended this, including specific numerical criteria. The AAC would also caution the Commission against TSP arguments for enabling user customization as an excuse to set the lowest common denominator, rather than a higher, more inclusive umbrella.As for data caps, the Commission should aim to eliminate them altogether. This is particularly key as robust speed means little without the accompanying data to use it. While caps may have begun as a legitimate network management tool to address congestion, they have since primarily fulfilled the role of an additional revenue stream for service providers without adding value, based on the testimony of numerous interveners and the individuals they represent, particularly low-income and senior users as well as users with disabilities. As Cybera indicated, data caps are “anathema to the research mentality”, and the AAC would argue, also to the mentality of meaningful, active participation in whatever capacity the internet allows—see upload comments, above. The network congestion explanation is belied by the infinite nature of bits and bytes, and data caps wreak more harm than good, moreover, disproportionately upon already vulnerable groups.If the Commission must set a data cap, the AAC proposes 200 GB/month, based on the analysis in our first intervention and the real household needs of everyday internet users, as related by many during the hearing. For comparison, the parallel FCC Lifeline program provides for 150 GB/month.The basic service standard should also be technologically neutral, provided close attention is paid to whether a certain technology meets all the usage criteria in the geography and circumstances in which it will be deployed, and how future-proof it is.The ongoing importance of voiceThe AAC believes that, for the time being, voice service should remain a basic service requirement; however. it may be provisioned by any “high quality telecommunications network connection”, which may include any form of broadband access technology, including wireless. Voice remains important to Canadians, especially those who have limited or no broadband access or who choose not to adopt broadband access, and it is also important for accessing emergency services. The AAC recognizes that there may be a point in the future where voice service will be assured by any telecommunications connection. Until such time, however, it should explicitly remain in the basic service objective.The Canadian Hearing Society, as well as the Deaf Wireless Canada Committee, gave at the hearing a compelling justification for preserving wireline voice. MTS also expressed concern over the relative cost of wireless as a solution, and related to voice, observed that VoIP cannot be a suitable voice substitute in the absence of universal broadband access.Due to the importance of affordable voice services, the Commission ought to reject Bell’s request for a rate increase for the reasons expressed by the AAC in its written submissions. As TELUS’s witness said at the hearing, Bell’s proposal is “unprincipled, based on faulty analysis and may jeopardize telephone service to Canadians in high cost serving areas.” The Commission should also reject proposals to redirect the national contribution fund to broadband deployment. The AAC’s funding proposals are additive, bringing the industry to a higher, but still reasonable level of contribution.III. Funding needed until market forces, government funding, and satellite actually deliver “basic” broadband to all CanadiansAt the outset of the hearing, the Chairman issued the following challenge to interveners: “Demonstrate to us, using evidence, that the public interest and the specific situation in each region justifies action by the CRTC; explain to us why market forces are currently insufficient to respond to the public’s needs; needs not wants.”The AAC believes that it was one of many interveners that met the Commission’s challenge with compelling evidence that regionally, and nationally, there is a broadband access problem that needs addressing because market forces and targeted government funding alone have not been, and will not be, enough to deliver “basic” broadband to all Canadians. The question is whether anything has changed since Telecom Regulatory Policy 2011-291 to indicate that the former approach worked. The AAC believes that approach taken then, even if it was appropriate then, is not appropriate now. Many Canadians still do not have access to the aspirational target of 5/1, let alone the 10/1 that is clearly “basic” broadband today. As the AAC explained at the hearing, if market forces had been working, all Canadians would have the broadband access they need, and government funding would not be necessary. If targeted government funding were working to meet Canadians needs, the extensive gaps (at 5/1 and at 10/1) would already have been eliminated. We know this is not the case.In the absence of any broadband strategy action plan, governments will continue to “pour water into sand” in terms of any broadband funding. Because government funding has not been continuous or coordinated, and because it can be susceptible to political influence and patronage impulses, unserved and underserved Canadians do not have a reliable framework in place that will ensure their basic telecommunications services will be met.Market forces simply will not provide basic broadband to all Canadians. Many service providers admitted this at the hearing. Without a business case due to factors relating to geography, technology, and population density, certain communities and certain households will never be served unless the Commission intervenes. A number of service providers have indicated this reality, and filed evidence of receiving apparently significant amounts of government funding. (As an aside the AAC notes its concern with SaskTel and Xplornet filing that information about public funding in confidence.)Satellite technology is a very intriguing promise, but it is still only a promise. None of the plans presented by Xplornet or OneWeb demonstrated that either or both were position to execute on delivering universal and affordable broadband connectivity to Canadians. OneWeb acknowledged that certain things had to fall into place for it to be able to provide service, and even at that, the OneWeb model, which is a wholesale model, relies on willing and interested last mile service providers to connect users. It was not clear at all from OneWeb’s presentation that it had interested service providers. Telesat provided few details reassuring the AAC that its planned non-geostationary constellation of satellites will be reliably in service, instead providing only plans, tests, and expectations that may come into fruition only by 2023, almost ten years from now. Telesat also provided little indication as to how its offerings would result in affordable service to end users.The Commission asked many service providers to provide information about their plans to use certain satellite bands in the future. Unfortunately, that information was generally filed in confidence, and completely redacted in most cases. At least one service provider, MTS, indicated it has no plans to use high-throughput satellite.It would therefore be imprudent to leave such an important objective, again, to market forces and government funding, especially if the industry estimates of billions of dollars are accurate. To the extent that satellite is looked upon to play a role in closing the digital divide, current pricing, as provided in response to undertakings by Xplornet, indicate that pricing is higher for satellite (and fixed wireless) connectivity, depending on where the user lives, the type of technology used to provision the service, and the use of data caps. This goes against the Ekos survey results, which suggest that Canadians are only accepting of modest differences between urban and rural pricing. Nor would it be acceptable to rely on the promise of satellite. A number of Commissioners expressed skepticism in their lines of questioning about the potential for OneWeb to deliver.Like the proceeding which led to Telecom Regulatory Policy 2011-291, it appears that once again satellite is being billed as the total solution to connectivity challenges in Canada, yet for that to happen, so many things beyond the service providers’ control must happen, from radiocommunications regulation changes, to rockets being launched on time. If satellite does indeed close the connectivity problem, once and for all, at speeds, functionality and prices that make the service fully functional, then at that time the Commission can cease pursuing funding support for broadband deployment. Until then, however, the AAC believes the Commission should act.Rather than accept that the “pouring money into sand” approach alone is going to yield satisfactory service for all Canadians, the AAC has proposed a funding mechanism, the BDFM, that targets communities that most need broadband service, and provide stable funding to deploy. Without this type of action, the systemic discrimination involved in leaving certain Canadians out, particularly northern Canadians, will become more and more pronounced.Cost estimates for closing the broadband access gap, provided by some parties at the hearing, range in the billions. The AAC is not proposing, or suggesting, that the access gap can be addressed in one fell swoop. Rather, the AAC is proposing that the access gap can be closed, over time, by modestly supporting the funding of deployments to high-cost areas, with priority areas and those areas where expenses are mostly capital (infrastructure), not operational, being served first. The AAC is aware that transport is a considerable operating expense that challenges the delivery of broadband, particularly in northern areas. The AAC notes in this regard that a number of parties proposed discrete transport subsidies. The AAC’s BDFM could be used to support transport costs, but due to the persistent ongoing nature and particularly outsized costs of the problem posed by transport, the AAC believes that no more than 25% of BDFM funding in any given year should go to transport, and that the majority of the funding should go to funding capital investments that can deploy broadband, gain traction with a customer base, and then generate sufficient revenues to cover costs and a return. As the capital intensive projects diminish as more and more Canadians are served, the BDFM could be adjusted to provide more money to op-ex intensive projects. That said, there may be cases where BDFM funding can be used to support investment in fibre builds to communities that currently are satellite dependent, as seems to be the case with the Kativik Regional Government, which given time and financial pressures under the Connecting Canadians has been relying on C-band satellite service but would prefer to invest in fibre.As for Bell’s broadband funding proposal, the Commission should reject their 50/50 mechanism as self-serving and discriminatory to smaller service providers. A subsidy regime that requires all recipients to fund 50% of any given project in, by definition, a high-cost area automatically precludes all providers who do not have access to that level of capital. If the Commission does not allow for the possibility that a provider may be 100% subsidized, the subsidy regime will inherently favour large service providers such as Bell Canada. First, this will cut off subsidies from independent or community service providers who might be best positioned to serve particular communities, such as where First Nations groups are concerned, as indicated by MKO and the Cree Nation Government, for example. Second, this risks leaving black holes of communities where the field is left unoccupied due to Bell not building for a variety of reasons. combined with smaller providers barred from serving a community due to inability to fund 50% of the required build-out. Third, this will decrease competitive forces overall across the country, as smaller providers will be further disadvantaged while large incumbent providers are granted further gains.In the AAC’s view, it is laudable for the Commission to address issues of digital literacy and adoption, should they choose to do so; however, this must not come at the expense of the Commission’s core mandate as applied here, which is to ensure that all Canadians who do recognize a need for high-speed broadband internet are able to access such services. The Commission’s core mandate, as applied in this proceeding, moreover includes ensuring that these services meet the basic service objective and are reliable, affordable, and high-quality. Only once these goals are met, or well underway, should the Commission turn its mind to addressing adoption and digital literacy.IV. The Commission must act to support low-income CanadiansThe Commission has heard compelling evidence that telecommunication service affordability is a significant problem. This evidence came from the AAC, individual ACORN members, numerous citizens online, academics, and advocates for various different communities. The on-the-ground impact of this problem was conveyed with particular force in the form of Skype appearances by those struggling to have adequate accessOpenMedia similarly observed:As powerful, courageous testimony from ACORN members and disabilities stakeholders reminds us, Canada's digital divide doesn't just prevent marginalized groups from accessing the Internet. This divide actually perpetuates and—worse yet—accentuates problems of inequality. This gap between digital haves and digital-have-nots is a glaring problem the Commission must address.Most major service providers seemed to argue that telecommunications affordability is not the problem, poverty is, and that the Commission should stay out of the way and let other actors address the situation. Bell, for example, said it was enlightened by the stories it had heard, and suggested the Commission could collect information and then provide advice to other actors to address issues. Cogeco suggested telecommunications affordability was part of a larger poverty problem, best left to Governments. Rogers referred to its “Connected for Success”, which offers certain low-income households a 10 Mbps/1 Mbps service at $9.99.Aside from the self-interest at stake in refusing to admit to one’s regulator that one’s industry does not provide affordable services, conflating telecommunications affordability with broader issues of poverty ignores (i) the human experience, expressed in testimony to the Commission, that indeed telecommunications services are posing affordability problems; and (ii) it ignores the clear mandate expressed in the Telecommunications Act “to render reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada”.The AAC highlights some of the testimonials made by ACORN Canada members at the hearing:5801 Living in poverty and being disabled forces me to make choices I don’t want to and having a roommate allows me to scrape together some funds from my budget to pay for this utility [home broadband] and connect to the outside world.5802 Because I’m disabled and poor I’m denied certain things. I didn’t choose to be poor and disabled and many other people don’t choose to be poor.5803 For me, affordable internet means being connected to places I cannot access and it connects me to programs that help reduce the day-to-day barriers that I face.-Blaine Cameron, Ottawa6056 Having such a difficult time learning, remembering new things brings me to tears so I require activities I can do at home to help me. This all hinders me greatly from performing the work duties and tasks that are required of me. Plus, everything is so expensive, even purchasing fruit and vegetables. That's a real treat for me when I get to have any, if there is a little entertainment money.[…]6059 I have very limited job opportunities and resources such as housing information; knowing tenants rights; what qualifications are required; searching various areas of availability -- this is difficult as newspapers offer very little -- and any low-income housing, if any; also government services; accessing various medical information, new breakthroughs; government forms and different programs offered to assist me in helping my disability.6060 Therefore, low-income persons as myself should not be priced out of this basic needed service I truly need. And I thank you and I appreciate your attention. -Linda Tetlock, VancouverThese testimonials, among so many others, show that a solution to affordability is necessary and needed now.In the AAC’s view, the Commission is in the best position to address the affordability of telecommunications services. It has expertise in the telecommunications market and provision of telecommunications services and jurisdiction over all telecommunications service providers in Canada. The AAC believes that the Commission must recognize that telecommunications service affordability, as reflected in section 7(b) of the Telecommunications Act, is part of universal service, and therefore the Commission should take action to address this discrete problem, as other actors (governments) have broader responsibility for addressing poverty, but not universal telecommunications service.Just as the Commission can take immediate action towards achieving the user-focussed Canadian telecommunications policy objectives by recognizing broadband as a “basic telecommunications service” (subsection 7(h)), the Commission can further the objectives (subsection 7(b)) by including affordability in universal service and recognizing telecommunications affordability is a problem for low-income Canadians. The Commission, like its U.S. counterpart did, can take effective, immediate action to make a difference in its sphere of influence, and to do so with national effect. It is not enough for the Commission to, as Bell suggested, facilitate creating and maintaining a record of provincial subsidies and social assistance programs for broadband to facilitate access for vulnerable Canadians, nor sufficient to rely on provincial governments taking into account the cost of broadband when setting social support levels. That is highly unlikely, and could take years to accomplish were it even possible. It is not enough to leave the affordability challenge solely to market forces. The experience of the very few service providers that have indicated they are exploring low-income problems suggests that these programs, where they have actually been deployed—which is on a very limited basis—have either been very limited and restrictive in scope, as in the case of Rogers. TELUS’s pilot program, which is not squarely aimed at affordability but also adoption and equipment, has not even launched due to the multitude of obstacles TELUS faces. Shaw, acknowledging that “[c]learly a gap exists”, undertook only to “do something” on their own if a “clear consensus” did not come out of this proceeding. The AAC believes that this should invite skepticism about whether or not, to use Commissioner Molnar’s words, the industry will “step up”, or even can effectively step up to respond to low-income users’ requirements. In the absence of proof that the industry is acting on a systematic basis to address the affordability problems of low-income Canadians, for all telecommunications services, the AAC believes the Commission must act. In the AAC’s view, last-minute and incomplete programs, or delayed action, demonstrate that industry on its own will have difficulty providing an adequate solution to the challenges facing low-income Canadians, and the Commission has before it an opportunity to support access to telecommunications services, in a coordinated and comprehensive fashion, and with the support of Canadians, and efficiently without the delay and hassle of further discussion forums.While the AAC’s members would be willing to participate in further processes regarding improving telecommunications affordability for low income Canadians, the AAC does not believe further discussion is necessary for the Commission to proceed with an affordability subsidy for low-income Canadians. The AAC has detailed its AFM proposal in its evidence.In addition, the Commission can make use of several takeaways from the Ontario Energy Board’s (“OEB”) initiatives to address affordability for low-income consumers, including through the Ontario Electricity Support Program (“OESP”), the Low-income Energy Assistance Program, and the Energy Conservation Program. These programs represent a multi-pronged approach and real life examples of the experience of a Canadian regulator which recently designed and implemented new initiatives targeted towards low-income customers. In order to address questions raised by the Commission during the AAC’s appearance at the hearing, the AAC wishes to highlight three characteristics of the OEB’s low-income initiatives especially.First, in order to determine eligibility while protecting privacy, the OESP uses the Ontario Ministry of Finance and Canada Revenue Agency (CRA) to determine whether the applicant’s income meets the eligible thresholds. The OEB contracts with a third-party administrator (the “Centralized Service Provider”) which receives applications and forwards a request to the CRA for verification. Eligibility and the applicable credit amount are determined without the disclosure of income or financial information to either the OEB or electricity distributors.Second, as described in the AAC’s undertakings, the federal budget and Ontario regulations now explicitly exclude credits received from the OESP from constituting “income” for the purposes of determining the amount of social assistance. Therefore, there is no concern of a social assistance “clawback” from OESP recipients.Third, the OEB established a multi-stakeholder Financial Assistance Working Group (FAWG) which assists the regulator in building expertise in low-income and affordability issues and also provides program design solutions and recommendations. FAWG was instrumental in the development of the LEAP and OESP programs and resulting Program mission should allow market to decide packages, but support access with low-income subsidyThe AAC believes the Commission should allow market forces to work to respond to users’ needs in terms of various packages, but should support access for low-income Canadians by implementing the AAC’s Affordability Funding Mechanism (“AFM") low-income subsidy for low-income Canadians to put toward the telecommunications (not just broadband) services of their choosing. The AAC believes that this approach will result in much greater success than a mandated basic broadband service package with a price ceiling. The AAC believes that a mandated basic broadband package with a price ceiling would not be successful because it would not empower Canadians to make telecommunications choices to suit their individual needs, nor address affordability concerns for other telecommunications services (notably wireless service). A mandated basic broadband service package with a price ceiling would also be vulnerable to jurisdictional attack, delays and gaming by reluctant service providers. It would also neither empower Canadians to make telecommunications choices that suit their individual needs, nor would it address affordability concerns for other telecommunications services (notably wireless service).The AAC agrees with Teksavvy that “the basic service objective should be broadband availability such as to support the Internet service package that all Canadians should have the opportunity to buy […]” To the extent that the Commission proceeds with a Commission-mandated basic broadband service package with a price ceiling, it should be designed based on observations of the “skinny basic” TV package, ensuring there are no loopholes, opportunities for extra fees, or tied selling, and that the service is made available throughout each service provider’s serving territory to all customers. Given that there will be a price ceiling, the Commission will also have to ensure that the affordability subsidy is large enough so that internet service providers actually compete for low-income customers. The AAC explained its reservations with a Commission-mandated basic broadband service package with a price ceiling at the hearing.V. The Cost of the AAC’s ProposalsThe AAC’s proposed funding mechanisms are designed to complement, not replace, market forces and targeted government funding. They are flexible, predictable, capped programs that can provide an annual amount of funding to support fulfillment of the telecommunications policy objectives. As already detailed extensively in the AAC’s evidence, over the 2017-20 period the BDFM would be capped at $190 million/year, and the Affordability Funding Mechanism would be capped at $70 million/year (“baseline” version) or $410 million/year (“ambitious” version).This would be funded through the existing National Contribution Fund mechanism, with an expanded revenue pool and increased contribution rate. Requiring telecommunications service providers to contribute to the fund would be consistent with Canadians’ expectations. The AAC’s Environics survey responses indicate that 90% of respondents believe that phone and Internet service providers should contribute to the National Contribution Fund. The majority also believed that the federal government should contribute to the fund. About 1 in 2 Canadians believed that telecommunications subscribers should contribute to the fund.Canadians are indeed willing to pay to support universal broadband access and affordable telecommunications for low-income Canadians. The mean and median monthly amounts Environics’ survey respondents were willing to pay are set out below.Figure 1. How much are Canadians willing to pay as a small surcharge on their monthly bills in order to ensure…All respondentsMeanMedianCanadians have access to telephone service no matter where they live in Canada$3.10$1.00Low-income Canadians can afford basic home phone service$2.74$1.00Canadians have access to broadband home Internet service no matter where they live in Canada$2.55$0.50Low-income Canadians can afford broadband home Internet service$2.32$0.50Responding to the Chairman’s comment about “only one wallet being tapped”, and questions about Canadians’ willingness “to contribute to that national vision and contribute financially one way or another to that national vision of a more connected country”, MP David Graham astutely observed: “there’s a willingness because I think if we invest in expanded infrastructure it will end up costing less for people, not more.” The AAC agrees.With the objective of quantifying the cost of its proposals for the average household, at the hearing the AAC entered Exhibit 2, which presented initial estimates of the possible maximum direct impact on average household bills of its proposals from services provided to residential subscribers. Rogers argued at the oral hearing that any analysis should also take into account the indirect impact on households of the AAC’s proposals from services provided to business subscribers. This section revises AAC’s initial estimates and expands the Rogers analysis based on the following considerations:Consistent data periods and calculation of residential/business share of contribution revenues. As a methodological simplification, the initial AAC analysis calculated per household contribution amounts by applying the AAC-proposed percent contribution percentages applicable to Canadian Telecommunications Service Revenues (“CTSRs”) for the 2017-2020 period (0.74% and 1.42% for the two funding proposals) to the average household telecommunications bill for 2014. Rogers extended this analysis by multiplying the average household bill by the number of households in 2011 to calculate the total direct contribution amount for residential customers, and indirectly the residential share of contribution revenues (47%), with the business share being calculated residually (53%). The revised analysis included in this section revises these analyses by using only time-consistent data (2017-2020) and by directly calculating the residential/business share of revenues based on the 2015 Communications Monitoring Report (“CMR”).Incidence of the Contribution charge. Distinct from the question of who pays for a charge from an administrative perspective is the economic question of the distribution of the burden of the charge. In the case at hand, an operator faced with a higher contribution charge will have the incentive to “flow-through” the amount to its customer, including via higher prices. Any amount not flowed-through would be borne by the operator, including via lower profits. The specific “incidence” would be the result of a complex and dynamic interaction of demand and supply conditions, the calculation of which is a complex undertaking outside the scope of this proceeding. Both the initial AAC and Rogers analyses provided single-point incidence assumptions. This section expands the analysis by including a series of incidence scenarios to investigate the sensitivity of such assumptions.There are many possible incidence results. For sensitivity analysis, Table 1 presents three scenarios for residential and business customers: two extreme cases (none and complete flow-through) and one intermediate case that is mid-way between the two extremes. For instance, under Scenario R1 operators bear 100% of the contribution (none is flowed-through to households). Scenario B2 is an intermediate case where operators flow-through 50% to businesses and those businesses in turn flow-through half of that amount (25%) to households, including in the form of higher prices for the goods and services they provide.Table 1: Description of Incidence ScenariosScenariosIncidence of Contribution ChargeOperatorsBusinessesHouseholdsServices provided to Residential CustomersR1100%N/A0%R250%N/A50%R30%N/A100%Services provided to Business CustomersB1100%0%0%B250%25%25%B30%0%100%Table 2 applies the incidence scenarios to three contribution amounts: “Base” case (current residential local wireline subsidy regime (PES) and the video relay service (VRS) funding subsidy amounts) calculated to average $106 million per year and the two total proposed funding mechanisms capped at $370 and $710 million per year, respectively. It includes three (out of a possible nine) combinations of the residential and business scenarios (e.g. Scenario R1+B1 combines Scenarios R1 with B1, etc.). The estimates in Table 2 are based on a residential/business average share of contribution revenues of 63.5%/36.5% over the 2017-2020 period. The two combined “extreme” scenarios are R1+B1 and R3+B3, while the intermediate case is Scenario R2+B2. Table 2 also shows the incremental contribution associated with the proposed funding mechanisms over the 2017-2020 period. For example, for the contribution amount of $370 million, operators/businesses/households would have contribution burdens of $185/$34/$151 million under Scenario R2+B2, and this would constitute a respective increment of $132/$24/$108 million over the Base case.Table 2: Contribution amounts under Incidence Scenarios(Annual averages over the 2017-2020 period, $ millions)Scenarios“Base”: PES + VRS = $106Total: PES + VRS +AFM (Baseline) + BDFM = $370Total: PES + VRS +AFM (Ambitious) + BDFM = $710OperatorsBusinessesHouseholdsOperatorsBusinessesHouseholdsOperatorsBusinessesHouseholdsR1+B1$106$0$0$370$0$0$710$0$0R2+B2$53$10$43$185$34$151$355$65$290R3+B3$0$0$106$0$0$370$0$0$710R1+B1Incremental to “Base”$264$0$0$604$0$0R2+B2$132$24$108$302$55$247R3+B3$0$0$264$0$0$604Table 3 presents the contribution burden only as it applies to households (the applicable contribution burdens for operators and businesses are included in Table 2) for the three combined scenarios and presents the corresponding results on a per-household basis. For instance, under Scenario R1+B1 operators bear 100% of the contribution (none is flowed-through to households) and hence the contribution costs to households is zero. At the other extreme, under Scenario R3+B3, all of the contribution cost is borne by households. Given the likely demand and supply conditions, neither of these “extreme” scenarios could reasonably be considered as realistic. Nevertheless, Roger’s analysis is indeed equivalent to one such extreme scenario (R3+B3).Table 3: Per Household Contribution (monthly averages over 2017-2020 period)Scenarios“Base”:$106mTotal:$370mTotal:$710mR1+B1$0.00$0.00$0.00R2+B2$0.25$0.88$1.68R3+B3$0.62$2.14$4.11R1+B1Incremental to “Base”$0.00$0.00R2+B2$0.62$1.43R3+B3$1.53$3.49Table 3 shows that over the 2017-20 period the maximum the average household would pay (under Scenario R3+B3) would average about $0.62/month under the Base case and $2.14 and $4.11 per month for the proposed funding mechanisms under the Baseline and Ambitious AFM, respectively. These correspond to incremental to Base contributions amounts of $1.53 and $3.49 per month per household, respectively. The actual incidence is likely to be some intermediate result wherein operators, businesses and households would bear some of the increased contribution charge. As discussed, one such intermediate case is Scenario R2+B2, which is calculated mid-way between the two extremes. For such a scenario, Table 3 shows that households would already have a contribution charge of $0.25/month under the Base case, and this would increase to $0.88 and $1.68 per month for the proposed funding mechanisms, resulting in incremental contribution costs to households of $0.62 and $1.43 per month, respectively. The contribution costs not covered by households would be borne by operators and businesses, as per Table 2.VI. The AAC’s plan for a National Broadband Action StrategyAt the hearing, the Chairman said: “Canada needs a plan.” He then invited parties to “provide their views on a national broadband action strategy for Canada”, and parties have been given 5 pages to discuss the “topic of a national broadband strategy”. The AAC notes that TNC 2015-134, until amended at the final stage, was not framed as a hearing about a national broadband action strategy, and therefore questions whether TNC 2015-134 rightly constitutes a “chance to create together a coherent national broadband strategy through an open and transparent process based on evidence from all Canadians”. The AAC nevertheless welcomes the invitation, having been advocating for a plan since this proceeding began. It is time for action, not simply further study and discussion.A “strategy” can be defined as a “plan of action or policy designed to achieve a major or overall aim”. Universal access to necessary telecommunications services has been the overall aim of the AAC’s proposals, one that is guided by the Canadian telecommunications policy objectives in the Telecommunications Act.In its initial intervention, the AAC observed that other jurisdictions have taken bold steps to connect their citizens and to address affordability barriers. The AAC stated that the Commission now has the opportunity, under the mandate entrusted to in the Telecommunications Act, to do the same. The AAC argued that bold action is necessary to ensure that all Canadian households have access to broadband Internet service at a speed that allows them to participate in the digital economy, and so that low-income Canadians can afford access to basic telecommunications service of a high quality. The AAC’s Action PlanThe AAC has in its interventions and evidence tabled what is in effect an action plan that the Commission can execute without delay, and one that accords with the Commission’s jurisdiction and mandate under the Telecommunications Act. The plan has five main actions: Table 4: The AAC’s Action PlanActionTimingDeclare broadband of at least 10/1 as a “basic” telecommunications serviceImmediatelySupport broadband deployment to higher cost areas via the BDFM Within one year of decision on TNC 2015-134 (2017)Support low-income households’ access to telecommunications service by adopting the Affordability Funding MechanismWithin one year of decision on TNC 2015-134 (2017)Monitorbroadband deploymentaffordability Yearly, commencing in 2018AdjustAs necessary based on changes in needs, technology, and speeds, according to the “50-80” ruleThe issue for resolution in TNC 2015-134 is access to basic telecommunications services under the Telecommunications Act. By recognizing broadband as a basic telecommunications service, and supporting affordable access to it, the CRTC can fill in key elements of what a national broadband action strategy should look like. The AAC’s 5 actions above would be a major element of any broader, more comprehensive strategy. In the absence of such a broader plan, however, the AAC’s action plan would address the basic telecommunications service needs of Canadians.The AAC’s comments on the National Broadband Task Force ReportTo the extent that the Commission wishes to take a leadership role in convening a multi-stakeholder process for the purposes of articulating a national broadband action strategy for recommendation to the Federal Government, the AAC makes the following recommendations, using as a starting point the 2001 Johnston Report mentioned on a number of occasions at the hearing.The Johnston Report is laudable, even prescient for its time. Indeed, PIAC, a member of the AAC, was a signatory to the report. Yet the report has, in retrospect, two failings.First and foremost, the report did not result in all Canadians having access to basic telecommunications services in 2016. In this regard the AAC disagrees with Cogeco that the principles in the Johnston Report have “worked well for Canada”. The AAC disagrees that 1.5 Mbps is the standard by which to measure success—it clearly is not—and the AAC strongly disagrees that there is competition “virtually everywhere”. The record plainly shows that there are many areas where there is no competition, and many areas where there is no service. Secondly, and surprisingly, the Johnston Report largely wrote the CRTC out as an actor in the telecommunications ecosystem. The Commission, tasked with overseeing the telecommunications system in Canada as well as the now-intertwined broadcasting system, is referenced but twice. The first time is a recommendation that the Commission ensure its decisions do not interfere with the industry’s need to make a return (“recover”) on its capital investments. The second, a reference to CRTC 99-16 (the basic telephone / dial-up decision), relates to the Task Force’s marching orders from the Minister of Industry, concerning approaches to connecting communities that were unlikely to obtain high-speed broadband without government involvement.The lack of a noted role for the CRTC in this most central of telecommunications matters is surprising. The CRTC ought, given its statutory mandates, to have a recognized leadership role in this matter, yet the Johnston Report only spoke of government leadership, and private sector leadership. Going forward, therefore, the AAC believes that the CRTC must be involved in Canada’s broadband future.Administratively, there are concerns that a multi-stakeholder process could be mired by agency problems such as shirking, free-riding, or lack of political will to arrive at a solution that Canadians need. In all likelihood, if such a massive multi-stakeholder / multi-jurisdictional process actually results in action, it would be “lowest common denominator” in calibre — far from ambitious.The Chairman expressed some of these concerns at the hearing. Rogers, proposing a multi-stakeholder advisory council to study (again) the issue, acknowledged the complexity of such an undertaking: “We don’t want to undersell the complexity and magnitude of such a council because we know, having participated in the previous ones that there was a lot of infrastructure to a council; there's a lot of participation, a lot of resources involved.” The AAC also shares the concerns expressed by the witness for National Capital Freenet about users and their not-for-profit representatives being excluded from, or systemically disadvantaged in such a process due to lack of resources. This is all the more reason to adopt the AAC’s proposed action items 1 through 5. Turning now to the principles expressed in the Johnston Report, the AAC believes that the principles expressed in the report are, generally speaking, reasonable, and the AAC notes there was limited opposition to any of the principles expressed at the hearing. Subject to the AAC’s comments earlier about the Commission needing to play a central role in Canada’s broadband future, the AAC provides the following specific comments on each of the principles.Johnston Report overarching principle: broadband access as a matter of urgency for various vital reasons. The AAC agrees that broadband access is a matter of urgency, much more than it was in 2001.Johnston Report first principle: definition of broadband. The AAC has in this proceeding proposed, rather than a definition of broadband, a definition of basic telecommunications service which is a “high quality telecommunications network connection” that is accessible, and provides the functional equivalent of voice grade telephone service, enhanced calling features, including access to emergency services, and capability to connect via broadband transmission to the internet, as a speed determined by the Commission. The AAC believes that proposals such as Bell’s to include an “aspirational” goal as meaningless without an actual commitment and plan to deliver. Contrary to Bell’s assertion that a distinction between basic and “aspirational” targets would enable “managing Canadians’ expectations”, the dual goals would set an unrealistic expectation of higher speeds when what Canadians need is a baseline, i.e., basic, guarantee.Johnston Report second principle: social, cultural and economic benefits. The AAC believes this principle, which speaks to “all Canadians” having access to the “social, cultural and economic benefits delivered through broadband networks” is something that the Commission can accomplish by declaring broadband (10/1, at least) to be a “basic telecommunications service”, and supporting its deployment with the BDFM. Johnston Report third principle: capacity to realize benefits, being “the parallel development of content and services, and individual and community capacity”. The AAC believes Johnston Report’s third principle is something the Commission ought not to be concerned with. Regarding content, as the Commission’s “Discoverability Summit” promotions note, we are in “the age of abundance”. Regarding “capacity”, the AAC believes the major barriers to Canadians accessing broadband are lack of deployment in certain areas, and affordability. The focus of the Commission, under the Telecommunications Act, must be on users, not non-users. Finally, as Bell notes, this principle seems oriented to the Task Force’s mandate, and the Task Force is defunct.Johnston Report fourth principle: equitable and affordable access to broadband. This principle merits quoting in full: “All communities, institutions, businesses and individuals in Canada should have equitable and affordable access to broadband services and to the widest possible range of content and service providers.”This, of all principles, is paramount, and the AAC believes is a condensed version of most of the Canadian telecommunications policy objectives expressed in the Telecommunications Act, and laterally the Broadcasting Act. Bell’s proposed amendments would undercut this paramount principle, and water it down into a murky, unactionable concept. The AAC believes that the concept of “equitable” access allows sufficient room, if any is to be needed, to account for minor differences between regions and between access technologies in terms of pricing, but beyond those minor differences, all Canadians should be able to access an affordable baseline of broadband service.Johnston Report fifth principle: the important role of communities. The AAC’ has recognized that communities and their special priorities ought to play an important role in considering funding from the BDFM. Johnston Report sixth principle: the role of the private sector: the AAC agrees with that the private sector should play a leadership role in the development and operation of broadband networks and services for Canadians. The AAC does not agree however that the matter should be left to “competitive market forces” given that the record of TNC 2015-134 clearly demonstrates that market forces are not working to deliver the necessary level of broadband to certain areas, and are not working to serve low-income Canadians. Johnston Report seventh principle: role of governments. The AAC agrees that all governments should take various steps to promote broadband, however the AAC notes that the seventh principle focuses only on governments’ potential roles vis-a-vis the industry, and enabling it, rather than on users. There is no question that the federal government should play a leading role in setting a more comprehensive and ambitious national digital strategy for Canada, one that touches on broader issues including digital skills, literacy, adoption, and equipment access. Without a national plan, government measures may appear ad hoc and politically motivated, rather than continuous, coordinated, and comprehensive. The Commission however must play its role under the Telecommunications Act in defining basic telecommunications services in response to the needs of users, and ensuring all Canadians in all regions can access reliable and affordable telecommunications services.Johnston Report eighth principle: “Broadband Infrastructure Development Programs” – emphasis on government programs to deliver broadband to areas where the private sector is unlikely to do so. The AAC has, at length, argued that government funding, and market forces, on their own, have proven insufficient to deliver the broadband that all Canadians need, and therefore believe a complementary CRTC fund is necessary. The AAC agrees with Bell’s proposed amendment to include openly competitive reverse auctions as the manner for distributing funding.Johnston Report ninth principle: prioritization of sustainable broadband access to educational institutions, libraries, health care centres, and other designated public access points. The AAC does not disagree that these locations must have broadband access, but believe that the focus should shift to residential broadband access now. These principles should not simply be dusted off and entered into the Commission’s decision in this proceeding. The problem is that the principles did not result in sufficient action. Thus, the AAC is wary of any recommendations for further study when the path forward is clear: broadband is a “basic telecommunications service”, and not all Canadians can access broadband because it is not available or because it is too expensive. Like the telephone, the Commission should require service providers to pay into a contribution fund to support its access. Another report without any concrete action, and therefore no progress, would be a waste of time and resources.VII. Conclusion: A Call to ActionAs the Chairman acknowledged at the hearing, “Clearly, the CRTC has work to do under its jurisdiction.”The AAC believes the CRTC should: (i) declare broadband to be a basic telecommunications service; (ii) adopt the BDFM, to support access to broadband; (iii) adopt the AFM, to support access to all telecommunications services; (iv) monitor progress; and (v) make course corrections as appropriate.A number of interveners explicitly or implicitly expressed support for these proposals, and the AAC’s research shows Canadians would support taking these measures, and actually paying for them. The AAC has also put forward an auction model for the BDFM which is based on principles which many service providers appear to support to the extent that the Commission does proceed with funding support.The AAC’s two funding mechanisms are not radical proposals; rather, they leverage existing CRTC mechanisms. They are reasonably priced, and capped; in fact, they track telecom industry funding levels in other notable jurisdictions. They aim for a national broadband standard that is realistic, not out of reach. Canadians would support these measures; indeed, Canadians believe in universal broadband and affordable telecommunication service, will pay to support one another, and will laud the Commission for making it all possible. Asking for basic broadband for all Canadians and affordability support for low-income Canadians is not, as one intervener implied, a calculated appeal to emotions. The AAC’s proposals are explicitly rooted in how users are actually using telecommunications service, as indicated through frontline surveys and testimonials on the record. To the extent that emotions are involved, it is because Canadians are making real sacrifices, a fact that the AAC believes was not lost on the Commission as it listened to or read the many touching submissions of hardship, sacrifice, and lost opportunity.Adopting the AAC’s proposals would be consistent with the Commission’s duties under the Telecommunications Act, and would further the user-focussed Canadian telecommunications policy objectives. In terms of jurisdiction, as detailed in the AAC’s submissions on jurisdiction, the Commission has, in subsection 46.5(1) of the Telecommunications Act, authority to implement the AAC’s funding proposals, in addition to its jurisdiction to mandate service upgrades of broadband service to the “basic” speed in certain cases.Doing so is also necessary to preserve the Commission’s legitimacy. The two funds the AAC has proposed are legitimate tools. The record, which includes PIAC’s Environics Survey, suggests that the broader population base supports all Canadians having access, and supports contributing money to ensure that all Canadians have access. The AAC believes that the most obvious immediate steps the Commission should take, based on the record, is to declare broadband of at least 10/1, if not 10/3, to be a basic telecommunications service, and to implement an affordability subsidy. Doing nothing cannot be an option, and it would be a mistake to say that the targets from 2011-291 remain appropriate. As the AAC told the Commission at the hearing, Canadians need a champion.***END OF DOCUMENT*** ................
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