Lend your voice to ARCC’s submission to ISED

ARCC’s response to this consultation was submitted on November 21, 2022 with over 20 seconders, including the City of Calgary and other municipalities.

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Innovation, Science and Economic Development Canada (ISED) is currently undertaking a consultation to inform its management of spectrum over the next five years (Spectrum Outlook 2022 to 2026). ISED is seeking stakeholder input on a number of policy considerations with significant impact for rural, remote, and First Nations connectivity. The deadline for submitting to this consultation is November 21, 2022.

The Alberta Rural Connectivity Coalition’s Policy Committee will be submitting a response to this consultation and invites individuals or organizations to attach their name to this submission by signing the consent form. Lending your voice to this consultation will make a significant impact in advocating for the Government of Canada to act on rural connectivity.

Only those who sign will be attached to this submission.

Please review the ARCC Policy Committee’s responses to ISED’s questions (below), before signing the consent form. If you require any further information, or clarification of our positions, contact us at info@abconnectivity.ca

ARCC Steering Committee Positions

ISED consultation question 1
In light of the Government’s proposed policy direction to the Canadian Radio-television and Telecommunications Commission on a renewed approach to telecommunications policy, should the policy objective and enabling guidelines in the 2007 Spectrum Policy Framework for Canada continue to drive ISED’s overall approach to releasing spectrum? Are there other policy considerations that ISED should consider?

ARCC position
Given that the 2007 Spectrum Policy Framework for Canada (SPFC) was devised in light of the 2006 policy direction to the CRTC, and that the new 2022 proposed Policy Direction would rescind the 2006 one, a revision to the SPFC is appropriate. 

ISED consultation question 2
Should any of the guiding principles listed in section 4 be removed or modified?

ARCC position
ISED should align the SPFC enabling guidelines with the spectrum outlook guiding principles so there is a singular set of policy guidelines for achieving the SPFC policy objective over the next five years. Furthermore, having two sets of guidelines may lead to, at times, policy incoherence, where guidelines may diverge or be at odds.

ISED consultation question 3
Are there additional considerations other than the ones defined in section 7 to support rural connectivity?

ARCC position
The department should conduct a review of deployment requirement targets, particularly in consideration of Tier 5 licences to consider the impact various thresholds will have on different Tiers.

A significant measure ISED could make to improve rural connectivity would be to work with the broader Government of Canada and to ensure a portion of spectrum licensing revenues were moved from general revenues to be invested in strategic spectrum priorities such as rural and Indigenous connectivity.

ISED consultation question 4
How can ISED’s spectrum management program best support Indigenous connectivity (see discussion in section 8)?

ARCC position
To best support Indigenous connectivity, ISED should meaningfully engage with Indigenous communities, and Indigenous connectivity must be a priority for spectrum management going forward. This should include discussions about spectrum sovereignty.  

ISED consultation question 5
How can ISED best address environmental impacts in the spectrum management program (see discussion in section 9)?

ARCC position
Canada should look to add more local IXPs. It saves energy use in transport. 

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