File # 1011-NOC2017-0112
The persons set out in the following list have provided interventions in support of the position of Blue Sky Net, that will support a more granular geographic eligibility across Canada for a Broadband funding regime that would be managed by an established external not-for-profit regional third party, with understanding and expertise in Broadband deployment practises.
This is to confirm that:
i. the persons named on this list have requested that the party submit the attached interventions and accept service of documents on their behalf;
ii. each person named on this list has been informed by the party that their name and intervention will be posted on the Commission’s website as part of the public record of this proceeding and that all information provided by this person becomes part of the publicly accessible file, including personal information such as full name, email address, postal/street address, telephone and facsimile number(s) and any other personal information provided; and
iii. no person named on this list is requesting to appear at the hearing, where one will be held.
Name of Applicant:
Blue Sky Economic Growth Corporation
102-150 First Ave. West
North Bay, ON P1B 3B9
1. Mr. Stuart Morley
Parry Sound Muskoka Community Network (PMCN)
P.O. Box 524
Gravenhurst, ON P1P 1T8
2. Mr. Paul Ouimette
PO Box 3211 STN MAIN,
Timmins, Ontario, P4N 8R6
3. Mr. Angelo Pacione
Sault Ste. Marie Innovation Centre
99 Foster Dr., Level Six
Sault Ste. Marie, ON, Canada P6A 5X6
4. Mr. James Ellard
Northwestern Ontario Innovation Centre
2400 Nipigon Rd. Box 398,
Thunder Bay, Ontario, P7C 4W1
Telecom Notice of Consultation CRTC- 2017-112
Development of the Commission’s Broadband Funding Regime
Responses to Appendix 2 to Telelcom Notice of Consultation CRTC 2017-112
Third-party Administrator(s) and Board (s) of Directors – Questions 1-5
Accountability and Fairness- Questions 6 - 7
Calls for Applications – Question 8
Distribution of Funding- Question 9
Enforcement of funding agreements – Question 10-11
Collecting and reporting information from applicants – Question 12-16
Eligible geographic areas
Blue Sky Net and the four other similar Information Communication Technology Networks as named and described in our covering letter, often found it difficult to find consensus between would-be subscribers of broadband services and other stakeholders like municipal councils and the service providers themselves. Generally speaking, the former’s perspective would tend to exaggerate the size and magnitude of coverage gaps and the latter tended to avoid directly identifying their network footprint and any deficiencies their services might have.
Over the course of several years, Blue Sky Net has developed what is now called Broadband and Associated Infrastructure Mapping and Analysis Project or “BAIMAP”. At its heart is a partnership of ISPs who have contributed detailed and accurate broadband coverage information and a variety of base information upon which coverage data can be overlaid and compared. At its most detailed, BAIMAP can cross-reference every known assessed address point to various broadband service levels, platform the service is delivered from (DSL, Fixed Wireless, Fibre, etc.) and who owns and operates the network. We are also able to roll up this data for customized visual or tabular reports at the community, district size or any custom geographic unit. The individual results can also be applied to correlate directly with the hexagon maps.
BAIMAP is a trustworthy, verifiable and objective database of fixed and mobile coverage across Northern Ontario. Using GIS it is capable of identifying coverage gaps and analyzing, quantifying and estimating costs to develop a coverage solution based not on a hexagon of 25km, but down to the property line level. BAIMAP is able to respond to individual requests for information and is also a platform capable of meeting needs of several interest groups/stakeholders including ISPs, Municipal staff and councils and program officers from Provincial and Federal Ministries. It is a tool such as this we strongly recommend CRTC uses to determine eligible geographic areas. BAIMAP uses Ontario Property Parcel information (MPAC) as a base layer, which is available in some form, nationwide.
Hex units can still be used as there is an established protocol for their use in the Federal Government. The consistent size of the unit also makes it easy to calculate population/household densities, which is an important factor in broadband service provisions.
The main critique of the hexagons is that they are too big. If one is to believe the speculation that 5G networks of the near future will have to support up to 1 million connected devices per kilometer (Robert Pothier, SVP, Telecon Inc., June 6th, 2017 Canadian Telecom Summit.), including autonomous vehicles, home monitoring systems, watches and other wearable technology, it is absurd to be measuring broadband penetration rates at levels no less accurate than at 25 square kilometers.
While a hexagon of 25 square kilometers may be an effective size for analysing service gaps across the country at a high level, it is not granular enough to address the needs of small pockets of demand for improved broadband service. This lack of granularity has resulted in errors in eligibility for some hexagons and “disqualification” from eligibility for others. Three examples are detailed below:
We have seen past Federal funding programs treat partial spatial coverage of a hexagon as criteria to remove it from eligibility. Given the size of the area contained within the hexagon it is hard to determine the actual impact of the partial coverage.
In the current Hexagon maps, each Hexagon is given an estimated household and population count. One must assume that these single points of population and houses have been distributed evenly throughout the entire 25 square km area of the hexagon in the absence of more granular information. In reality, this is not the case. Homes are situated unevenly throughout the hexagons clustered around roads, intersections, lakes and schools or other institutions.
Given this fact, even if we mapped that broadband service was available to 25% of the hexagon’s area, given the current model, we are forced to assume therefore that 25% of households are covered. Given the reality of the unequal distribution of households for the reasons listed above, we know this estimate is going to be inaccurate.
Serving small gaps, but preventing overbuilds
From experience we’ve seen that it’s pretty typical in suburban environments that multiple networks exist, each of which partially serves the broadband needs of the area. Within one single hexagon there may be 2-3 unique networks still not serving 100% of the area. It is unlikely that these networks are capable of delivering the new expectation of 50/10Mbps.
The main issue with the Hexagon maps in situations where there’s multiple networks partially serving a hexagon is two-fold; a) we cannot properly quantify the gap or inequity of coverage because we do not actually know where the households are in the hexagon and b) even if subsidies could be accessed in these situations to improve coverage there is no mechanism to monitor the potential for overbuild without more granular information.
We have developed a GIS and database for Northern Ontario whose model can be applied to the rest of Canada. The GIS is called BAIMAP (Broadband and Associated Infrastructure Mapping and Analysis Project) and can, if needed, link broadband availability to every property in Northern Ontario.
In 2013, and again in 2015 we reached out to any ISP that owned and operated broadband networks in Northern Ontario. We asked them to provide coverage boundaries as well the platform, location of key infrastructure and performance measures for their services.
At the time, both the CRTC and the Federal Government were targeting 5Mbps down and 1Mbps uploads as a target for every Canadian to have access. We then grouped all the coverage files into three classifications:
1) areas that cannot receive fixed broadband service and were likely to only access broadband through Satellite and/or cellular/Mobile broadband.
2) Areas that could receive broadband service but based on the performance measures provided by the submitting ISPs would likely experience a service that consistently delivered below the 5/1 service threshold, and
3) Areas that were covered by fixed broadband networks and constantly delivered 5/1 service. We then had an accurate depiction of three levels of spatial broadband coverage.
To analyze the impact of this coverage, we overlaid the spatial coverage on a number of base maps including the hexagon maps and Statistics Canada’s Dissemination Blocks. However, the most accurate analysis comes from cross referencing our spatial coverage with digital parcel maps.
In Ontario, the Municipal Property Assessment Corporation (MPAC) maintains active records for every assessed property in Ontario of ownership, assessed value, street address, property type and classification. Along with their strategic data management partner TeraNet, this assessment data is linked to a digital parcel boundary map for each and every assessed property, linking the two files with a common (usually) 15 digit roll number.
Through our unique position, and appealing to MPAC that we were doing work on behalf of municipalities, we were able to purchase a three year licence to this data for much less than the advertised pricing. We then spatially matched the coverage files with the physical property files to determine service availability for each property. Now, we have a database and GIS layers of over 530,000 unique properties all linked to service availability and corresponding gaps.
This GIS data can then be rolled up and customized for visual or tabular reports by community, district, or customizable units. We have also used the hexagon maps as a giant “cookie cutter” to link each hexagon in Northern Ontario with our property level analysis results. Therefore, we have the ability to maintain the benefits of the consistent size of the hexagons but have the confidence that the analysis behind the results is as granular as possible.
We have gone beyond this in order to test the claims of providers. We have created www.connectednorth.ca which is a public portal that presents useful information about broadband availability throughout Northern Ontario using our BAIMAP analysis. Also, we use this site to collect our own speedtest information that we subsequently map to compare “crowd sourced” user performance results and the ISP submitted data.
We have contacted several provincial level organizations across the Nation, to determine the availability of parcel level data. During these preliminary discussions it appears that some level of parcel data is available across the country.
We believe we can replicate BAIMAP across the country.
1) Have an independent engineer/consultant provide written statement that there is insufficient access,
2) Provide speed test data spread out geographically and over time to provide evidence of insufficiencies, and
3) Municipal staff/council of ineligible area could provide a statement testifying to the insufficiencies.
Eligible recipients – Question 22
Eligible costs- Question 23 -24
Funding from a government entity Question 25-30
Project viability – Question 31
Project Types – Question 32
Project Assessment criteria – Question 33-37
Criteria to identify “priority underserved” geographic areas.- Questions 38-41
Satellite-dependent communities component- Questions 42-45