Joint comments to the Innovation, Science and Economic Development’s Consultation on the Technical and Policy Framework for White Space Devices in Canada

In 2016, the Canadian Radio-television and Telecommunication Commission (CRTC) ruled that broadband Internet is a basic telecommunication service. The CRTC set the ambitious goal of ensuring 90 per cent of Canadian householders would have access to broadband speeds of 50Mbps download and 10Mbps upload.

The unfortunate reality in Canada is that the remaining 10 per cent of Canadians that will be left behind if this goal is achieved are predominantly from rural, remote, and Indigenous communities. There is a solution to reduce this disparity. Community networks, small, locally owned and operated networks, have proven to be a viable connectivity solution where traditional or commercial networks do not reach, or where it is not economically viable for a private sector entity to operate in a particular region.

However, to be successful, community network operators, among other key factors, require access to adequate and sufficient spectrum. TV White Space (TVWS) technology offers great potential to provide access to necessary spectrum for rural, remote, and Indigenous communities in Canada.

The ecosystem of communication technologies and infrastructure is changing; opening up new possibilities for the delivery of universal service. While we recognise that mobile networks are a critical last-mile access technology, additional complementary options, especially in poorer regions outside of urban areas, should be considered to help connect Canadians. To truly connect everyone, everywhere, community networks must be recognized as a viable way for the unconnected to connect their communities. This is a paradigm shift where the focus is on allowing communities to actively connect themselves. To achieve this paradigm shift, policy makers and regulators should recognize that connectivity can happen from the “village” or “community” out – where the last mile is essentially a “first-mile,” where citizens build their own networks. Community networks are complementary to traditional, commercial telecommunications networks.

TVWS technology operating in sub-1GHz frequencies offer particular potential for rural access in general and community networks in particular. The ability to propagate in non line-of-sight (NLOS) conditions directly addresses access challenges in rural Canada where the Boreal forest often makes the deployment of communication infrastructure challenging or expensive or both. The comparatively low cost of these technologies, combined with the low barrier to use through the revolutionary use of dynamic spectrum allocation through a geo-location database, means that communities and small ISPs may be able to use these technologies in a similar manner to Wi-Fi technologies which have proven to be a revolution in access throughout the world. TVWS offers tremendous potential to empower communities to solve their own connectivity challenges.

TVWS technology is particularly well-suited for rural and remote access both in terms of its propagation characteristics as well as its cost. As such, Canada has an opportunity to demonstrate leadership in the use of TVWS for community networking. In fact, leadership from Canada in empowering regulations for TVWS can have ripple effects across the world, as less well-resourced countries may look to Canada for leadership in this area. Strong leadership from Canada in this area will also serve as a signal to investors to deepen their commitment to innovative companies in Canada.

TVWS also represents an excellent risk mitigation strategy for the regulator. TVWS regulation offers short-term, low-risk (to the regulator) use of the some of the same spectrum in the TVWS bands, and should be seen as strategically complementary to Canada’s plans for spectrum auctions and be given greater priority than they have to date.

Read the call for the consultation here.