CRTC invited interested parties to identify barriers that ISPs and communities face in building new facilities or accessing existing facilities, and how these barriers are preventing parties from extending networks and offering universal service objective services. The call for comments asked that responding parties propose potential regulatory measures to address identified barriers.
FMCC made a number of submissions including: first intervention (April 23, 2020); Reply Comments (July 10, 2020); Requests for Information for Parties (August 14, 2020); Requests for Information (October 13, 2020); Final Comments (February 22, 2021); Response to Comments (March 8, 2021). See below for PDF of each.
FMCC’s submission asked that service providers receiving funding from the Broadband Fund be required to provide wholesale access to their networks, and those transport services be regulated to ensure fair access, as well as CRTC and ISED provide clear definitions of the conditions required for Open Access to Transport Services. The submission also recommended that the federal government (including the CRTC) establish an emergency fund specifically for non-profit and Indigenous telecom providers working to connect their communities, and that the services of large incumbent TSPs to third-party providers be regulated and monitored. Finally, the submission recommended that specific language be adopted to explicitly include Indigenous land and treaty rights, and the procedures needed to access land and “passive infrastructure”.
FMCC’s submission is here: FMCC – CRTC 2016-406 (April 23, 2020)
FMCC’s submission responded to arguments by ILECs that wholesale should remain unregulated because there is potential for facilities-based competition, in addition to not being able to afford to serve these regions if they have to provide wholesale access to other providers.
The submission registered FMCC’s disagreement with assertions made by commercial TSPs that the Commission’s wholesale policies have reduced incentives to private investment in high-cost service areas, arguing instead that a reliance on facilities-based competition has not resulted in extending reliable and affordable broadband to many rural and remote communities.
On August 19, 2020 FMCC submitted:
FMCC posed questions for large commercial ILECs and CLECs including Bell, Northwestel, TELUS, Rogers, Shaw, Cogeco, SSi Micro, Quebecor, Eastlink and Xplornet, as well as questions for PIAC.
On October 13, 2020, FMCC filed its
The document address questions on efficient and affordable access to existing transport services, access to dark fibre, rights of way timeliness, pricing, access to facilities owned by public utilities, spectrum, infrastructures database, and Indigenous rights of access.
FMCC submitted documents for the CRTC 2019-406 proceeding on February 22, 2021 that summarized FMCC’s conclusions and recommendations regarding potential barriers to the deployment of broadband-capable networks in underserved Northern and Indigenous regions.
Final Comments from FMCC – CRTC 2019-406 (Feb. 22, 2021)
On March 8, 2021, FMCC submitted a Response to Comments
Response to Comments CRTC 2019-406 (March 8, 2021).