|CRTC 2015-134 Submission|
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1305 Richmond Rd. Suite 206 Ottawa, ON K2B 7Y4
July 14, 2015
John Traversy Secretary General Canadian Radio-television and Telecommunications Commission Ottawa, ON K1A 0N2
Re: CRTC 2015-134 Review of basic telecommunications services
1. I am writing on behalf of National Capital FreeNet (NCF), a not-for-profit internet service provider based in Ottawa. Founded in 1992, we currently offer DSL internet as a Bell re-seller, as well as locally-hosted dial-up internet and email, and basic webhosting for individuals and community groups. We are supported by DSL subscription fees and by member donations.
2. NCF would like to appear at the review of basic telecommunications services hearing to provide further information and context as a not-for-profit ISP and to elaborate on the needs of our members.
3. We have approximately 5000 members, including about 3000 DSL subscribers. Many of our members are seniors, new Canadians, have disabilities and/or live on low incomes. We are actively pursuing a plan to grow our membership.
4. As part of our mandate we aim to keep our prices affordable, we don't bind people to contracts, we invest in connectivity, and we believe that everyone in Canada's National Capital Region should have access to the internet; meaning that they can afford a high-quality connection, understand how to use it, and feel safe online.
5. The NCF Help Desk is largely staffed by a diverse group of about 20 volunteers who offer a range of in-person and telephone services that go beyond just answering questions about our internet services to include hands-on tutorials, advice about software, computer repair, discussions about online privacy, and more. We also host online discussion groups so our members can exchange their skills and knowledge directly.
6. Our current DSL offerings range from 2Mbps to 50Mbps download speed, with upload speeds from 0.8 Mbps to 10 Mbps. Prices range from a special package for our dial-up members of $20.95 per month to $49.95 per month for our 50/10 Mbps package. We offer 300 GiB (or about 322 GB) of bandwidth per month. Users who go over that amount are requested to make a donation for additional capacity. Currently our most popular offering is the 6/0.8 Mbps service.
7. We offer payment by VISA and EFT, but also by cash for those who may not have credit or access to traditional banking.
Responses to questions in CRTC 2015-134
Canadians are using telecommunications services to fulfill many social, economic, and cultural needs in today”s digital economy.
Explain how telecommunications services are used to meet these needs. For example, uses may include e-commerce (i.e. the online purchase and trade of products or services), e-banking and/or telephone banking, e-health or telehealth services, telework, and distance education. Which of these uses of telecommunications services are the most important to ensure that Canadians meaningfully participate in the digital economy?
8. In the last 12 months, 495 NCF members answered an internal survey about how they used the internet. In descending order, it included: email (97% of respondents), news (77% of respondents), consumer uses (72% of respondents), health (52% of respondents), work (34% of respondents), education (28% of respondents), investment (27% of respondents), forums (23% of respondents), and job hunting (12% of respondents).
9. We believe these uses suggest the range of meaningful activities Canadians use the internet to participate in, and also how those without regular and reliable internet access might be missing out on the benefits of the digital economy.
Explain which telecommunications services are most important to support these needs and uses. What characteristics (e.g. capacity, mobility, high speed, and low latency) should these telecommunications services have?
10. Our experience has shown that NCF members care most about latency, but that high speed and capacity are increasingly important.
Identify and explain the barriers that limit or prevent Canadians from meaningfully participating in the digital economy (e.g. availability, quality, price, digital literacy, and concerns related to privacy and security). Identify which segments of the Canadian population are experiencing such barriers.
11. We believe that pricing is the most significant barrier that limits NCF members and those in the National Capital Region from meaningfully participating in the digital economy. In our experience, this is particularly true for seniors, new Canadians, people with disabilities, and/or those living on low incomes. As evidenced by the people who use our Help Desk, we find these same groups often need support with their digital literacy. Consequently, we play an ongoing role in reducing the “digital divide”.
12. It also is worth noting that because of cost, it is our experience that many people, particularly youth, are currently forced to choose between phone service (for which they use mobile wireless devices) and a fixed internet connection where they live. They then end up using their smartphone as their main internet connection (directly or by establishing it as a mobile hotspot) which can lead to higher mobile bills because of the charges associated with mobile capacity.
The Commission”s current target speeds for broadband Internet access service are a minimum of 5 Mbps download and 1 Mbps upload, based on uses that consumers should reasonably expect to make of the Internet. Are these target speeds sufficient to meet the minimum needs of Canadians today? If not, what should the new targets be and what time frame would be reasonable to achieve these new targets?
13. NCF is confident that many other interveners will speak to and provide research around the need for specific speed targets. That said, we believe it is important that the Commission ensure that as demand for higher speeds and different kinds of internet offerings grow, that the means to deliver it (e.g., through fibre to the home) should be made available to all ISPs.
14. Finally, we note that NCF is new to participating in regulatory proceedings and therefore we are offering limited comments at this time. We look forward to participating more fully in future Commission proceedings.