Attention: Ian Scott, Chairperson and Chief Executive Officer
Dear Mr. Scott,
Re: Telecom Notice of Consultation CRTC 2022-147; Call for comments – Telecommunications in the Far North, Phase II
On behalf of the National Indigenous Economic Development Board (NIEDB), I very much welcome this timely opportunity to offer advice to the CRTC, on how to improve Information and Communications Infrastructure (ICI) in the Far North. In particular, you have asked for input on how to improve home phone and Internet services in the Far North by making them more affordable, more reliable, and more competitive, while serving the overall goal of better supporting reconciliation with Indigenous peoples.
Background and Context
Established in 1990, NIEDB members are appointed by the Minister of Indigenous Services Canada with a mandate to provide strategic policy advice to the federal government on issues related to Indigenous economic development. The Board is composed of First Nations, Inuit and Métis business and community leaders from across Canada.
NIEDB research and expertise in the area of infrastructure, including connectivity, supports the proposition that sound and robust ICI is among the key building blocks of a healthy modern economy and that, without adequate ICI, development of Indigenous economies are detrimentally impacted. Additionally, a significant infrastructure gap exists between non-Indigenous and Indigenous communities in this regard, even in northern Canada – Indigenous communities and peoples find themselves on the wrong side of this “digital divide.” The recommendations outlined below will illustrate the necessity of immediate action by CRTC, with the objective of improving the economic and social situation of Indigenous peoples in the Far North.
Canadian experiences throughout the pandemic and, more recently, with the Rogers Communications system failure on July 8, have demonstrated beyond a shadow of a doubt the centrality of reliable telecommunications and its underlying infrastructure to our modern society and economy. Broadband connectivity has been identified as a critical tool for Indigenous peoples towards improving health and safety, increasing social well-being, and providing economic development opportunities and growth for Indigenous communities.
The definition of Far North you have provided for this engagement (the Northwest Territories, Nunavut and Yukon, communities in northern British Columbia, and Fort Fitzgerald, Alberta), does not include the
northern portions of all provinces. Because Indigenous communities are located in such areas, and because these areas are also known to experience less than adequate ICI and connectivity, the NIEDB suggests the geographical catchment for this engagement be modified to include the northern portions of all provinces.
National Indigenous Economic Strategy (2022)1
Crafted by more than 20 national Indigenous economic organizations, and released on June 8 of this year, the National Indigenous Economic Strategy identified Infrastructure, along with People, Lands and Finance, as key pillars toward the goals of economic reconciliation and the meaningful engagement and inclusion of Indigenous peoples in the Canadian economy. The NIES contains 107 Calls to Economic Prosperity, two of which are central to the CRTC mandate and should be implemented immediately future:
60. Prioritize provision of broadband services in rural and remote communities; set aside telecommunications spectrum for Indigenous communities, and report annually on progress in meeting connectivity goals
80. Enable federal and provincial co-funding and industry partnerships to provide broadband services to Indigenous communities in rural and remote areas; prioritize Indigenous participation; provide dedicated Indigenous funding for all major infrastructure programs and projects, including Indigenous ownership.
The NIEDB requests that that the CRTC share the NIES internally across your organization, advise how the CRTC can assist in carrying out the Calls to Economic Prosperity, and include specific Calls to Economic Prosperity within your strategic planning processes.
Indigenous Economic Progress Report (2019)2
Dependable ICI has become increasingly important as a necessary precondition to economic development and social cohesion. In 2012, the Board produced the Aboriginal Economic Benchmarking Report, which identified a comprehensive set of indicators and benchmarks to measure the social and economic well-being of First Nations, Inuit, and Métis people and communities in Canada. This was updated in 2015 and 2019.
The 2019 Indigenous Economic Progress Report demonstrates that connectivity in northern and remote communities is significantly below levels of all other communities, including remote non-Indigenous communities. The Nunavut Broadband Development Corporation, for example, has reported that consumers in satellite-served, remote, and predominantly Indigenous communities face the most restrictive data allowance among Canada’s peers in the Group of Eight industrialized economies and in the Organisation for Economic Cooperation and Development. While almost all cable and fibre-based broadband internet subscribers in urban centres can choose various data allowance packages, including unlimited data or data add-on’s, many Canadians in rural or remote areas do not have these choices due to a much smaller marketplace for home phone and internet services.
The 2019 Report contains the following recommendation regarding connectivity, which remains applicable today, and which the CRTC should take immediate steps to implement:
This report has demonstrated that connectivity in Northern and remote communities is significantly below levels for all other communities, including remote non-Indigenous communities. Connectivity impacts virtually every aspect of our lives, and predictions for the future of work include an increasing reliance on connectivity and economic progress divided along lines of access to a global economy based on connectivity. Increasing speed and data capacity to all Indigenous communities is essential to social and economic development. Forecasting community need to be ahead of current demand and in consideration of housing realities will ensure connectivity is less likely to be outdated before it becomes a reality.
Remote areas are more likely to have data transmission speeds that are simply inadequate for current digital services and tools. Due to rough terrain and lack of related infrastructure, remote communities are likely to have poor or minimal broadband infrastructure, or they are more likely to rely on satellite-based networks. Significantly, satellite-based communications have much lower data rates and more propagation delays, as compared to cable.
Indigenous peoples are at a distinct disadvantage in comparison to other Canadians, in terms of reliable broadband connectivity, given that they tend to be located in more remote locations including the Far North. Economic conditions in the Far North are such that the earnings of Indigenous peoples fall well below the Canadian average. In the Far North, where the average number of people per household is higher than in the rest of Canada, a large number of residents in a home may be sharing a single internet connection and may easily exhaust their monthly data allowance.
Where overcrowding and prohibitive pricing is the norm, the insufficiency of required broadband connection potentially puts participation in Ehealth, E-finance, and online learning opportunities out of reach for many. This results in reduced access to services commonly available in southern Canada, such as:
- Monitoring and transmission of a trauma patient’s vital signs in real time via a smartphone app, where time, human and medical resources are lacking
- Learners able reach their full academic potential, acquiring the required skills and knowledge to compete in today’s labour market; young persons’ ability to plan and reach career goals and aspirations
- Businesses and employees able to work remotely, to exploit digital business tools and applications, such as conference calls, real-time collaborative work and cloud-based tools
- Application of increasingly digitized operations in agriculture (e.g. computerized crop management systems) that require high data capacity; hence, potential efficiencies are unavailable without reliable access to higher quality broadband services
Remote communities bear the brunt of these deficiencies, and more so due to conditions in the Far North.
Community perceptions in the Far North
Anecdotally, we understand that internet connectivity has changed significantly over the past decade – for the better. Where dropped cellular phone calls were once commonplace, telephone signals today are reported to be stronger and dropped calls much less frequent.
Zoom calls from Iqaluit are a reality today, whereas video calls would commonly freeze prior to 5G. However, we are also aware that some residential users – e.g. persons with serious medical conditions – obtain a landline in addition to cable internet, solely to access emergency medical assistance, in anticipation of not unlikely outages of the cellular phone network.
The current provider of home phone and internet services in Iqaluit is commonly perceived as unresponsive and unsympathetic to complaints. For example, inadequate responses are common to residential users’ complaints over inequitable charges for data overages. There is a belief among subscribers that, in cases of data overages, the provider is not obliged to advise the details of digital content constituting the supposed overage event(s).
Similarly, requests for reimbursement for loss of service, even for several days at no fault of the subscriber, are not well-received by the provider.
There is a perception that, due to insufficient or constrained rates of data transmission, a subscriber paying for a 20GB data package in the Far North simply does not experience the same performance as someone using 20GB in southern Canada. This may be due to selective constraints on data transmission that is under the control of the service provider, and completely out of the control of subscribers.
There is also the perception that the current provider enjoys a favourable position in the industry, in terms of preferential treatment by the regulator; and that a recent survey appeared to be structured in such a way to produce a favourable result for the current provider.
Further, there is a perception that in cases of natural disaster and other outage events, Indigenous communities are among the last to which service is restored. Given the often remote location of such communities, lives are at risk when service is not available.
Summary
The existing concentration of ownership has produced a skewed telecommunications services marketplace in the Far North. As suggested above, it is essential to decrease the costs and increase both the speed and data capacity of telecommunications services, in support of the social and economic development of Indigenous communities in the Far North.
The NIEDB would, therefore, make the following recommendations:
- Foster greater competition in all aspects of ICI policy and procurement, including by allowing Indigenous providers to utilize existing infrastructure, to make it more possible for Indigenous enterprises to gain entry and prosper in the telecommunications sector, which has reportedly favoured large players
- Given the central importance of good ICI to community health and economic development, and recognizing that servicing small and remote communities is not always profitable for telecommunications firms, prioritize the provision of broadband services in rural and remote communities, and seek federal, provincial and territorial support in doing so – such support could be inclusive of government construction and ownership of ICI infrastructure in the Far North and/or federal, provincial and territorial co-funding and industry partnerships
- Ensure a telecommunications services marketplace that is competitive, and affordable for average earners in the Far North, including limiting (capping) the fees that may be charged by telecoms and/or issuing periodic rebates to subscribers
- Prioritize Indigenous participation in the provision of home phone and internet services, as well as within all components of the supply chain and within the leadership and executive ranks of telecommunications companies
- Require large incumbent service provider(s) to devolve and offer ownership opportunities to Indigenous communities
- Set aside portions of the telecommunications spectrum for Indigenous communities
- Provide dedicated Indigenous funding for all major infrastructure programs and projects, including Indigenous ownership
- Report annually on progress in meeting connectivity goals for Indigenous communities, including remote Indigenous communities
- Initiate a feasibility study of potential locations in the Far North for data centers for information concerns, where the cold climate provides a natural advantage for companies such as Facebook, Google, etc.
In conclusion
Connectivity impacts virtually every aspect of our lives, and predictions for the future of work include an increasing reliance on connectivity and economic progress divided along lines of access to regional, national and global economies via a robust information and communications infrastructure. Young people living in the Far North, just as their counterparts in other parts of Canada, exist in an increasingly digital environment, and such individuals deserve no lesser prospects than youth in other parts of the country, along with the required tools and skills.
The NIEDB provides the above recommendations in good faith, and heartily encourages the CRTC to enact them in substance. We would welcome the opportunity to attend either virtually or in person at the hearing scheduled for April 17, 2023 in Whitehorse. Thank you for the opportunity to comment, and to be part of this process.
Sincerely,
Dawn Madahbee Leach
Chairperson
National Indigenous Economic Development Board
- NIEDB 2019 Indigenous Economic Progress Report