Bell says no evidence spectrum will go unused without deployment reqs, supports contiguous holding

The telecoms companies that supported Innovation, Science and Economic Development’s (ISED) proposal to impose further deployment requirements on licences primarily used to provide commercial mobile wireless services failed to provide evidence of “a persistent market failure” in the delivery of wireless services, Bell told the department in reply, while also supporting a proposal from Rogers Communications Inc. regarding contiguous holding of personal communications services (PCS) licences. Wednesday ISED released the replies to the comments on its consultation to reintroduce requirements to the cellular and PCS bands that have been or will be renewed through the 2011 Renewal Process. ISED said the deployment requirement would be “at least as ambitious” as the 20-year requirements it established in its policy for the 3500 MHz band. Approximately 290 licences would have no deployment requirements if no changes are made, according to ISED’s consultation documents. “However, a lack of a deployment requirement does not mean that the spectrum is not being used. Cellular and PCS spectrum licences are currently used and will continue to be used (including for 5G services) even in the absence of a deployment requirement,” Bell wrote in its reply. Ecotel Inc., which did not submit an initial consultation comment and only a reply, fired back at Bell’s initial comments and argued to ISED that it needs to promote “real usage of spectrum,” stating that the incumbents who “crawl under enough low band (sub 1GHz) spectrum, have no use for the mid-band” in rural and remote areas. It instead argued for the “use it or lose it” approach and suggested ISED “immediately mandate” subordination of the PCS band where it is not currently used, on a per grid cell basis, in rural and remote areas. Bell also said it supports Rogers Communications Inc.’s recommendation that ISED better coordinate with the CRTC and government regarding subsidy programs to connect the remaining one per cent of Canada which is the “uneconomical rural and remote parts.” ISED wrote in the consultation that it also wants cellular and PCS bands to be subject to conditions of licence “to deter licensees from acquiring spectrum for speculation, warehousing or anti-competitive purposes.” Bell told ISED its proposal is “inconsistent” with its own policies, which state that the objective is "to maximize the economic and social benefits that Canadians derive from the use of the radio frequency spectrum resource,” and is inconsistent with its own guidelines which state that "market forces should be relied upon to the maximum extent feasible." Bell said both the objectives and guidelines are already being met without further interference from the government. New targets would significantly increase prices for telecoms companies at a time when wireless network builders' capital is at its highest. Bell said that would force companies to recuperate their additional costs through price increases at a time when the government and CRTC are pressuring telecoms to lower consumer bills. Bell was also supported by Saskatchewan Telecommunications Holding Corp. (which did not submit a reply) in opposing the proposal. Xplornet Communications Inc., Cogeco Inc., Iristel Inc., the Federation of Canadian Municipalities (FCM) and Canadian Communications System Alliance (CCSA) were all generally in favour, with minor recommendations made and minor concerns raised. Bell argued those five interveners did not provide any evidence or rationale in support of the appropriateness of imposing new requirements, but rather “seemed to have simply reacted favourably to the unsolicited proposal put forward in the consultation.” Bell cited data which claimed that since 2013, 4G LTE coverage in the country rose from 35.4 per cent to 97.4 per cent. “Thus, there is no demonstrated need that supports such a drastic change in the existing conditions of licence,” it wrote. SSi Micro Ltd., in its reply, also supported some proposals made by Rogers. SSI Micro, in its original submission noted decision to establish Tier 5 licence areas in the territories and other parts of the North “was arbitrary… appearing to respond more to a desire to facilitate the use of public spectrum resources for closed networks by private enterprises, such as agriculture and mining, than to any realistic prospect of extending spectrum-based telecommunications services to the general public.” The company argued ISED should not permit licensees — such as CCSA members which serve localized markets in rural and remote areas — to satisfy deployment obligations at lower tier levels than initially set because it will make it easier for existing licensees to satisfy deployment obligations rather than extend coverage beyond the localized markets they serve. SSi Micro wrote that it supported Rogers’ proposal to “reassign PCS spectrum to create contiguous holdings before imposing additional deployment obligations on existing licensees for these services.” It argued that would improve incentives for subordination. “Reassigning the PCS spectrum frequencies so that all current PCS licensees’ holdings are assigned as contiguous blocks will permit operators both large and small to use the PCS spectrum more effectively for wireless internet access and other vital services enabled by wider, contiguous spectrum,” SSi Micro wrote. Bell also noted in its reply that it supports the idea, however, it recommended that industry participants organize and manage the initiative on a commercial basis. It said that ISED should simply act as support experts to the industry and, when required, act as informal mediators between conflicting licensee interests. “Upon reviewing all comments all stakeholders, particularly Cellular and PCS licensees, the optimal long-term policy to maximize the usage of the spectrum still appears to also include rationalizing the PCS holdings. This will allow all carriers – large and small; regional and national – to more efficiently and economically deploy the spectrum as contiguous blocks for the greatest benefit of all Canadians,” Rogers wrote to ISED in its own reply. Meanwhile, Telus Corp. said it shared many of the views and concerns, mainly higher costs, expressed by Bell, Rogers, and SSI Micro in their comments. However, the company, in its reply, stuck by its originally propose modifications that ISED adopt the percentage coverage requirements in its 2018 Advanced Wireless Services (AWS) renewal decision, applying the Tier 3 requirement milestones in five years and Tier 4 deployment requirements in nine years. “Telus suggests these graduated requirements would afford licensees more time to adjust their investment plans, thus helping to somewhat blunt the concerns about the negative impacts from ISED’s proposal,” the company wrote in its reply, adding that it agrees with Rogers that a funding policy needs to be developed in tandem. — Reporting by Jenna Cocullo at jcocullo@thewirereport.ca and editing by Paul Park at ppark@thewirereport.ca.

Bell says no evidence spectrum will go unused without deployment reqs, supports contiguous holding

News | November 18, 2021

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Bell says no evidence spectrum will go unused without deployment reqs, supports contiguous holding

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