December 16, 2021

FMCC makes a submission to CRTC Call for comments regarding potential regulatory measures to make access to poles owned by Canadian carriers more efficient (CRTC 2020-366)

Telecom Notice of Consultation CRTC 2020-366

Call for comments:

October 30, 2020 the Commission announced the initiation of a proceeding designed to identify and implement regulatory measures that would improve access to poles owned by Canadian carriers.

The FMCC submission offered an overview of the experiences of many FMCC member organizations with delayed and costly access to poles. FMCC requested that the CRTC review support structure tariffs; address issues third party providers experience with ILEC’s in regard to pole repair; maintenance and upgrading fees; as well as the need for standardized permit approval and dispute resolution processes. FMCC also brought attention to the need for the recognition of Indigenous governments, land, and treaty rights by government agencies in the development of infrastructure, and ensure that meaningful consultation and informed consent takes place.

FMCC intervention

For all parties’ interventions.

On January 10, 2021, FMCC responded to points raised by other parties in the proceeding, including agreeing with others that access to poles, conduits, towers and sites needs to be done in a fair, efficient, and timely manner to increase supply of universal service objective-level services in all regions of Canada.

For FMCC’s Reply to Comments

On June 7, 2021, FMCC responded to requests for information with respect to a proposed 60 day deadline for  ILECs to grant permit for access to 50 or more poles; questions about penalties for missing deadlines; replacement of poles; as well as dispute resolution.

For FMCC’s response to Requests for Information

On June 27, 2022, FMCC submitted its final comments and reiterated its proposed solutions to ensure fair, timely, and affordable access to existing poles for Indigenous service providers. These include that the Commission adopt a symmetrical, principles-based approach that aligns fair costs with incentives and promotes innovation, as well as reforming the current support structure regime by implementing a One-Touch Make Ready (OTMR) work process, as well as other measures that eliminate advantages held by carriers who have been designated as the manager or partial owner of utility poles.

For FMCC’s final submission, and for final reply letter and signatories.