Consultation on Repurposing the 600 MHz Band. Notice No. SLPB Published in the Canada Gazette, Part 1 Dated January 3, 2015

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3 Consultation on Repurposing the 600 MHz Band Notice No. SLPB Published in the Canada Gazette, Part 1 Dated January 3, 2015 Comments of Ontario Ministry of Economic Development, Employment and Infrastructure February 17, 2015

4 Question 1: Industry Canada is seeking comments on the overall proposal of repurposing the band to include commercial mobile broadband and the initial step of participating in a joint repacking process with the United States. We support Industry Canada s proposal of repurposing the 600 MHz band to include commercial mobile broadband services. The Canadian Radio-television and Telecommunications Commission s (CRTC s) 2014 Communication Monitoring Report shows that more than 60% of adult Canadians use smartphones, a percentage that is rising rapidly. The same report shows that many Canadians are using their smartphones for streaming audio and video. These activities use significantly more bandwidth than voice calls or text messages. Industry Canada should continue to make available any inefficiently used spectrum for mobile broadband services to ensure that service providers will have sufficient spectrum to meet their customers needs. Industry Canada should also promote the development and adoption of new signal processing techniques that would increase the spectral efficiency of spectrum that has been allocated for mobile broadband. We also support Industry Canada s efforts to harmonize the 600 MHz band with the United States by participating in a joint repacking process. A significant majority of Canadians live within close proximity to the border with the United States. These Canadians are able to enjoy American over-the-air (OTA) television broadcasts, just as many Americans who live close to the border are able to enjoy Canadian broadcasts. Industry Canada should continue to work with the United States to ensure that both Canadians and Americans can benefit from each other s OTA television broadcasts. In addition, as part of the eventual license conditions for 600 MHz mobile broadband services, we strongly encourage Industry Canada to adopt stringent deployment requirements. This will ensure that mobile service providers put the spectrum to good use in a timely manner. Question 2: Industry Canada is seeking comments on the future spectrum requirements for OTA TV broadcasting, taking into consideration the overall changes to the broadcasting industry, and noting that the CRTC Let s Talk TV hearing recently closed. A growing number of Canadians are cutting the cord by cancelling their cable television subscriptions offered by broadcasting distribution undertakings. The CRTC s 2014 Communication Monitoring Report shows that the number of subscribers to cable broadcasting has declined over the last several years. The report also shows that the percentage of Canadians using various Internet video services is rising rapidly. During the CRTCs recent Let s Talk TV hearing, Rogers Communications Inc. reported that more than 1.5 million Canadians watch OTA broadcasts. While we have been unable to find additional statistics showing whether or not this number is increasing or 1 of 4

5 decreasing, an American study by market research firm GfK showed that in 2013 nearly 20% of American households with televisions watched only OTA broadcasts, a significant increase from 14% of households in GfK also noted that broadcastonly levels are even higher among minority and lower-income homes, as well as with younger householders; these groups have all have seen higher-than-average increases in broadcast-only reception in recent years. We expect that the situation would be similar in Canada. We believe that many Canadians who use Internet video services are supplementing with OTA television to enhance reception of local programming. We expect that the number of OTA television users in Canada will continue to grow for the foreseeable future. Therefore, Industry Canada should ensure that the repurposing process provides sufficient space in the lower channels for all Canadian OTA stations to relocate. Question 3: Industry Canada is seeking comments on the Department's proposal to: adopt the U.S. 600 MHz band plan framework; and commit to repurpose the same amount of spectrum as the United States, as determined in the FCC's incentive auction. We support Industry Canada s intention to adopt the U.S. 600 MHz band plan framework. Once the 600 MHz band has been repurposed for mobile broadband services, it is very important that consumers mobile devices continue to function reliably while roaming on U.S. and other foreign networks when away from their home country. An important dimension of harmonizing this band with the United States is to ensure that both countries make available the same amount of spectrum in the 600 MHz band to ensure full mobile network interoperability. Industry Canada should commit to adopt the entire band plan framework. Question 4: Industry Canada is seeking comments on the size of the proposed guard band between the TV broadcasting and mobile services. Is the mobile service appropriately protected by the proposed guard band? Is the TV broadcasting service appropriately protected by the proposed guard band? If additional protection measures are needed, what alternatives (such as increasing the size of the guard band, adding a pass band/notch filter at the TV receiver port, etc.) could be used and what alternatives would be practical to deploy? 2 of 4

6 Question 5: Industry Canada is seeking comments on the proposed transition policy for the regular power TV stations, including but not limited to the design objectives for the development of the new DTV allotment plan; the methodology and parameters to ensure minimal impact to TV reception; the minimum notification period for the relocation to the new DTV assignments; and the overall timing for the transition to the new DTV allotment plan. Question 6: Industry Canada is seeking comments on the proposed transition policy for LPTV undertakings in the spectrum to be repurposed to mobile use. Question 7: Industry Canada is seeking comments on the proposed transition policy for LPTV undertakings below the 600 MHz band. Question 8: Industry Canada is seeking comments on the proposed transition policy for RRBS. Remote rural broadband systems (RRBS) provide Internet access to consumers and small and medium enterprises (SMEs) in rural and remote regions throughout the country. The Internet plays an extremely significant role in the lives of almost all Canadians. Canadians use the Internet for entertainment, education, commerce, medicine, and much more. This is especially true for Canadians living in rural and remote parts of the country, which often lack brick and mortar institutions. The latest version of the CRTC s Communications Monitoring Report confirms that Canadians living in rural communities spend more on telecommunications services than those living in urban centres. The CRTC will initiate later this year a comprehensive review of basic telecommunications services. This review will determine whether or not broadband Internet access is required by all Canadians to fully participate in the digital economy. We believe that it is very important that Canadians living in rural and remote regions have continued access to broadband Internet access. In some areas of Canada, this broadband Internet access is provided solely by RRBS service providers. Between 2006 and 2012, Industry Canada allowed RRBS through Radio Systems Policy RP-006, but warned that it might make changes to this band in Framework for the Use of Certain Non-broadcasting Applications in the Television Broadcasting Bands Below 3 of 4

7 698 MHz. During that period, many RRBS service providers made significant investments in their broadcasting equipment and infrastructure. These service providers had a reasonable expectation that they would be able to provide service for a long period of time. Should Industry Canada not be able to provide displaced RRBS service providers with alternate spectrum in the ultra high frequency (UHF) band, these service providers will be burdened with expensive radio equipment that they can no longer use. Given the relatively small number of subscribers, the payback period of these investments has likely not yet been reached by many RRBS providers. It is possible that even with assistance in finding new channels of operation, some RRBS operators might not be able to afford to make the transition to new operating bands. This would mean that some RRBS providers might shut down their operations, depriving Canadians of broadband Internet access. Employees of these service providers might also lose their jobs. We understand that satellite Internet access remains an option for households and SMEs in most parts of Canada. However, we do not consider satellite Internet access to be a viable alternative to terrestrial access given its inherent technological, capacity limitations, plus higher comparative cost. Industry Canada should consider providing assistance to RRBS operators to transition to new frequencies, preferably in the UHF band. In particular, in order to minimize the impact of displacement, Industry Canada should assign new channels to RRBS operators that would work with the operators existing equipment. This would require that Industry Canada engage in discussions with its current RRBS licensees to determine their individual capabilities. In the U.S incentive auction for the 600 MHz band, television broadcasters who voluntarily relinquish their spectrum for mobile services will receive a portion of the proceeds from the ensuing auction. Similarly, Industry Canada should consider financially compensating displaced RRBS providers who are unable to use their existing broadcasting equipment in their newly assigned frequencies. In advance of receiving the proceeds of the eventual 600 MHz band auction to mobile broadband service providers, Industry Canada should consider using the Consolidated Revenue Fund to compensate affected RRBS providers. Question 9: Industry Canada is seeking comments on the proposal to update the Canadian Table of Frequency Allocations by adding co-primary allocations to fixed and mobile services in the MHz and MHz ranges. We support Industry Canada s proposal to update the Canadian Table of Frequency Allocations to include co-primary allocations to fixed and mobile services in these ranges. Industry Canada should also update the table to include fixed service in other ranges that RRBS providers might be relocated into. This includes the MHz range (television channels 14-20). ** End of document ** 4 of 4