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Xplornet Communications Inc Canada Gazette Notice No. SLPB-006-17, October 2017 Consultation on the Spectrum Outlook 2018 to 2022 Reply Comments of Xplornet Communications Inc. March 16, 2018 INTRODUCTION 1. These reply comments are submitted by Xplornet Communications Inc. (“Xplornet”) in response to the comments of other interested parties on Innovation, Science and Economic Development Canada (ISED)’s Consultation on the Spectrum Outlook 2018 to 2022. 2. Upon review of the submissions Xplornet believes a number of core principles have emerged which ISED should identify as the basis for constructing a forward looking spectrum outlook for Canada. Xplornet would summarize these principles in the following way: (i) The convergence of fixed wireless and mobile technology, illustrated through the introduction of fixed wireless 5G trials in urban Canada, has permanently blurred the lines separating fixed and mobile broadband. (ii) The result of this convergence will be one concept, wireless broadband, which will enable Canadians’ connectivity in the years ahead. (iii) As technology converges, the method of separately defining licences as fixed or mobile will become increasingly antiquated. Therefore, a progressive licensing regime should apply the principle of flexible use across all bands of spectrum in order to allow operators to continue to innovate and invest strategically in their networks. (iv) Canada’s spectrum policy should and, in fact, can address the needs of all Canadians, regardless of where they choose to live, and need not favour urban broadband consumers to the detriment of rural broadband consumers. (v) The deployment of licensed, flexible use spectrum over the long term should be the focus of Canada’s spectrum outlook and that more spectrum should be released across all bands so that providers can invest in their networks to keep pace with the ever- growing needs of Canadians. 3. Xplornet believes the vast majority of intervenors in this consultation are supportive of these ideas, particularly the principle of flexible use. Indeed, upon review of the comments submitted, from ISPs both large and small, to equipment vendors and municipalities, Xplornet sees considerable agreement and support for these objectives. It is against this backdrop that Xplornet submits its reply comments. - 3 - 4. This consultation comes at a crucial juncture in the evolution of the telecommunications industry in Canada. Wireless broadband technology is becoming increasingly important in the delivery of the Internet to Canadians, whether at home, at the office or on the move. The phenomenal growth in the consumption of video services via the Internet is expected to continue unabated, leading to a requirement for more bandwidth and hence, more spectrum. 5. To deliver on these demands, technology is converging. The introduction of 5G trials is leading to the deployment of fixed wireless technology in urban areas where wireline technology has to date been ubiquitous. Meanwhile, rural providers continue to innovate, using the same fixed wireless technology to deliver service to millions of Canadians who live outside of Canada’s largest cities. The need for spectrum for fixed wireless use is no longer a uniquely rural requirement. 6. There is therefore much at stake in this consultation. Technology is converging, requiring the need for a mix of high, low, and middle band spectrum to support the needs of both rural and urban Canadians for both fixed and mobile connections. This convergence will only accelerate with the introduction of 5G technology, with certain Incumbent providers already deploying mobile spectrum to offer fixed services. The result is one concept, wireless broadband, which will enable Canadians’ connectivity in the years ahead. 7. In this consultation Xplornet urges ISED to look beyond the self-interested views of certain providers who narrowly view this process as a vehicle to acquire mobile at the expense of other providers. Xplornet will address these specious proposals later in these reply comments. 8. In order to meet the needs of Canadians in the years ahead, ISED must apply a technologically agnostic approach to allow ISPs the ability to innovate and respond to Canada’s evolving conditions. Applying flexibility – so that providers can serve customers with the latest in wireless broadband technology – will allow for Canada’s telecommunications industry to address and respond to changing consumer demands. 9. In practical terms, given the finite nature of spectrum, ISED must take steps following this consultation to make available more multi-use spectrum, and promote the efficient and flexible use of spectrum across low, high and middle range bands. 10. Xplornet remains extremely concerned that all significant spectrum allocations in Canada in the last five years have focused exclusively on mobile needs. Once again, Xplornet believes that the Outlook places too much emphasis on the need for defining licences as fixed versus mobile in a converged wireless world of continuous innovation. There has already been a considerable amount of - 4 - spectrum devoted to this use over the past decade, as ISED explicitly notes in its consultation document.1 11. In the years ahead, flexible use of spectrum needs to be expanded to make more efficient use of the spectrum, and to serve the needs of all forms of wireless broadband, enabling both fixed and mobile applications. As the introduction of 5G and the Internet of Things makes access to the Internet even more pervasive, the means by which it is delivered will become increasingly irrelevant to consumers. What will matter is the availability of wireless broadband – from either mobile or fixed connections, but increasingly both. ISED must ensure a flexible approach is taken to allow all providers (regardless of the technology which is deployed or the geography where it is deployed) to expand their networks for the benefit of Canadians. 12. Finally, the Outlook devotes considerable attention to unlicensed spectrum. While unlicensed spectrum will have a role to play in the delivery of services, for example, at Wi-Fi hotspots, it is generally not a long-term solution to the provision of certain applications that require reliable delivery by carriers. Its availability is too uncertain for the investment of billions of dollars in the infrastructure to delivery high quality services to consumers and businesses in Canada on a consistent basis. In addition, coordination issues are complex and generally result in an unreliable service. One new area in which Wi-Fi may prove useful is in the delivery of new Licence Assisted Access (LAA) which is discussed in Xplornet’s initial comments in this proceeding.2 13. In these reply comments Xplornet has addressed a number of key issues where a variety of views have been expressed. Failure by Xplornet to respond to any specific comment made by another party in the first round of submissions does not signify Xplornet’s agreement with the comment made. Xplornet’s full position on the issues raised in the public consultation is set forth in its submission of February 16, 2018. Encouraging the Deployment of Wireless Broadband 14. Xplornet has noted throughout this consultation the disproportionate emphasis on spectrum needs for commercial mobile versus fixed applications, rather than the need to deliver converged services over wireless broadband. 15. As anticipated, two of the incumbent carriers, Bell and TELUS, have emphasized the need to support commercial mobile services and stressing mobile over other important spectrum uses by other providers. 16. Bell Mobility, for example, states: 1 Consultation on the Spectrum Outlook 2018 to 2022, page 3. 2 Comments of Xplornet Communications Inc., February 16, 2018, page 7. - 5 - “3. Demand for commercial mobile services will vastly outpace all other services in the coming years, and the Department's greatest priority should be allocating licensed spectrum for flexible fixed and mobile use.” 17. In a similar vein, TELUS argues that: “5. In a consultation as broad as this one, the Department will have to absorb and assess input from an array of stakeholders with varying and often directly competing interests. Stepping back from it all, the Department must have one overriding priority which dwarfs all others as it will directly impact every business and every citizen in Canada. It is imperative that the Department ensure that the mobile network providers that serve 99.4% of the Canadian population have access to the spectrum they need to deliver 5G. Everything else, while potentially important in its own right, pales in comparison.” (emphasis added) 18. Xplornet does not dispute the increasing demand for mobile spectrum. However, this demand cannot ignore significant emerging trends in Canada’s telecommunications system. Fixed wireless services, for example, also currently outpace demand for spectrum in Canada, and is projected to continue to do so into the future. The most recent Cisco VNI Forecast underlines the significant growth of fixed residential internet traffic in Canada in the coming years.3 By 2021, Internet household traffic is projected to generate 142.6 GB per month – an increase of almost 2.7 times from the 63.6 GB per month in 2016. In Canada, there will be 2 million households (18.6% of all Internet households) generating more than 500 GB per month of data in 2021, with over 650 households generating more than a terabyte of data per month.4 Meanwhile, Canada’s “fixed/Wi-Fi” household traffic will comprise 54.1% of total Internet traffic in 2021, while mobile Internet traffic will comprise just 5.6%.5 19. As Canada’s largest rural-focussed ISP, Xplornet understands these trends very well. Approximately 80% of Canadians live in urban or near-urban areas with access to wired technology. The remaining 20% live in rural areas where either fixed wireless or satellite technology provides a more economic and efficient solution. The result is that LTE networks are carrying primarily mobile traffic in urban areas and primarily fixed broadband traffic in rural areas.
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