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Chebucto Community Net
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Halifax, Nova Scotia Residential Internet Access Prices as of September 2016. Non-profit Internet Access via Chebucto Wireless the clear budget champion.

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Halifax, NS Residential Internet Access Prices - June 2016.
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We missed the deadline for CRTC submission. Here's what we would have said.



June 12, 2016
 
Ms Danielle May-Cuconato
Secretary General
CRTC
Ottawa, ON K1A 0N2
 
Dear Ms. Secretary General;
 
Re: Final reply comments on Review of Basic Telecommunications Services (CRTC 2015-134)
 
On behalf of Chebucto Community Network, we are pleased to submit some final comments with respect to Telecom Notice of Consultation CRTC 2015-134.
As a society that has been providing low cost Internet to people since 1994 we are quite invested in the outcome of this consultation.
Chebucto Community Network (CCN) re-iterates its position that access to the Internet is vital for people to be able to meaningfully participate in the democratic, economic and cultural life of the country, as well as to access services.
 
The Nature of “Access to the Internet”
Chebucto began providing dialup Internet because of our belief that open and easy access to information would allow people to be better informed citizens, and to build community, that is to say that it was one way of increasing people's opportunities.  In the succeeding years the Internet has only become more entrenched in the lives of the general population and has moved from being simply a way of lifting oneself from poverty and participating in the community when one faces barriers to accessing the wider world, to being vital to one's ability to access the economy, democracy and culture. 
Initially Chebucto provided access to textual information from all around the world expanding community.  In addition it provided local information in the home for people with mobility challenges.  These challenges might be commonly viewed physical challenges, but can also include ability to access transportation, or family status (allowing new mothers to participate in a discussion board or mailing list for new mothers.)   These uses have become very compelling and have infiltrated the broader society not just for people who must access the community in this manner but also for those without these challenges.  This has led to an expansion of the meaning of access to Canadian culture from the culture of a 50 km area around oneself and the one way culture delivery from the CBC and other commercial broadcasters, to a more global perspective and communities of interest unconstrained by geography.  As Canada is a multi-cultural society, it is well within the meaning of Canadian culture to say that the access to the country of origin streaming video service we alluded to in our presentation does form a portion of access to the culture and community building aspect of access to the Internet, and should be equally facilitated compared to our local community focus.
With widescale adoption of high speed network access, certain assumptions are made about the basic features of a connection.  As mentioned in our presentation, modern operating systems on computers, the mediator of access to the Internet, make assumptions of excess bandwidth to be used for their own maintenance.  Modern website design assumes “large” capacity to make a good presentation with pictures, and moving images, and interactive features rather than just the text of the original Web.  In addition, streaming media has also become a core feature of the Internet.   In short, dialup access is no longer able to access the modern Internet effectively. 
a)      Access to the Economy: Often it is cheaper to buy things online, and local advertising is increasingly online.  It is impossible to access the eBay or Amazon websites with a connection speed effectively limited to 56 kbps.  Likewise a small business that needs to upload content to gain access to the global market, or even a local market needs a faster connection than dialup can provide.
b)      Access To Government: Accessing the documents to prepare this presentation would have taken hours from the CRTC website over our dialup service.  Increasingly government services are moving from Service Canada offices to online primarily.  These websites also take very long periods to load over 56 kbps dialup. 
c)      Access to Democracy: With political campaign discourse increasingly moving through online delivery whether it is streaming video or audio for debates, political advertising, or online coordination of campaigns (email and otherwise).   Access to the political process increasingly needs access to a network or internet delivered faster than 56 kbps service can provide.
d)      Access to Culture: Canadian cultural content is increasingly delivered online.   Not only with consumption of access to online music stores, or entertainment and educational media no longer delivered on physical media in local stores, but also cultural production.  Without a high speed network connection to upload their content, the author would not have been able to listen to N'we Jinan, a northern aboriginal youth group that put out an album later played on the CBC.  In addition, YouTube as a democratization of cultural production is not accessible with a 56 kbps network connection.  Libraries are also augmenting their digital offerings, and access to a local Internet facilitates access to this public resource.
e)      Creation of Community: Our founding focus was creation of community.  Originally this was over text mailing lists of communities of interest that spontaneously formed when we provided the infrastructure.  This trend has continued, but much of this has moved into websites delivered on demand rather than stored locally and delivered in small pieces. Depending on the website design, it is a less than effective experience or unusable experience to access these websites and participate in these micro-communities. 
It should be noted that with local caching it is possible to somewhat ameliorate some of the challenges presented by the move to high speed network access as basic (or assumed) service.  Remote websites do not “have the patience” to complete transfers at 56 kbps and if they do not deliver their content within set time limits, they will hang up the connection.  We mitigate this by downloading a copy of the content to a local machine at full speed and then delivering to the end user at the speed their connection can handle. This makes the website work, but does not create a pleasant and easy experience.
Within our organization, we have not come to a conclusion about what the basic service speed should be.  We are agreed that it is far above 56 kbps today, and based on the discussions above of what are the basic required features of “the Internet”, it drives the question of what an adequate speed would be.  However, as experience has shown, what is “special access” today is “basic” tomorrow.  When we began our enterprise core Internet was access to text-based content in email and newsgroups, and one transferred images as special supplement to demonstrate something hard to present in text.  Today, we have presented a case that YouTube, video blogs, and similar modest bandwidth services both up and down are core content, with the attendant implications about what is a basic speed.  We are hesitant to phrase it in this way, since it skirts the hazardous assertion that the CRTC should regulate the content of “the Internet” rather than simply asserting that a particular speed is “high quality telecommunications services”.  The point however, is that while a party line phone was “high quality” in the days of manual switchboards, today this is below basic service.   Similarly, we are hesitant to pick a particular number as the basic access level unless it is a matter of regular review.  A 5 Mbps down/ 1 Mbps up connection could be considered barely sufficient even for relatively low-usage users today. A 10 Mbps down/ 2 Mbps up connection would be fairly good for most current usages but these numbers will look painfully slow even in a few short years as consumer bandwidth usage grows over time.
Among ourselves the question of how proximate the access must be came up.   There used to be an initiative to deliver Internet access in local convenient locations such as public libraries. (Leaving aside the question in Newfoundland of what happens when a provincial library is used as the means to deliver a federal mandate, let us assume the libraries are in fact there and open.) Does this fulfill the access requirements?  We believe it does not.  There are time limits on duration of access that must be imposed at a library both for fair sharing of the resource, but also because of opening and closing hours.  In addition, it engages dignity concerns if someone of lesser means must research their medical conditions in full view of the public when someone of greater means can do so in private.  Finally, we return to the accessibility issues.  For various reasons from lack of public transport infrastructure, inaccessibility of public transport, lack of affordability of public transport, physical disability, or the special demands of, for example, being a new single parent or similar situations, travel to a community hub does not always, and might rarely fulfill the accessibility requirement.   We believe that Internet should be delivered to the home (or possibly to mandate workplaces deliver private use Internet usage, but this raises all sorts of complexity and is less feasible than mandating access to the home.)
There is a fundamental question of what exactly what is being purchased when buying “Internet” access.  One can narrowly say that the point to point link between one entity and another, or “computer network access”, is the service, and the fact that the other end happens to forward that access to another service is happy accident, or one can broadly say that the carrier is delivering access to a world of content and reselling that which they do not own.  Our local focus (expanded upon below) allows us to easily say that speed of access to the local service is the most important and if long distance links to the rest of the world are not at 5 Mbps/1 Mbps end-to-end then that is unfortunate as long as there is no prioritization going on between users, and the wider world resources are available at some speed.  However, it is possible that other interveners would assert that basic service is access to all the world end-to-end at the set speed.  This is a question for the Commission to struggle with, but one we thought is an issue to be discussed and addressed
 
Affordability
For many of our members, $80/month is not an affordable option for gaining access to this wider community, when the competing immediate demands of shelter and food are presented. The question is whether it is a basic dignity right to not be shut out of Canadian culture, to not simply live a sparse subsistence existence.  In addition, there is the argument of equality of economic opportunity.  Some aspects of life are cheaper with access to the Internet.  Is it an appropriate economic ordering that one must have wealth to save cost of living in Canadian society?  In addition, access to the Internet provides one with economic activities as an entrepreneur, and access to skills training not available to those without access.  This is an opportunity to lift oneself from poverty that is blocked by lack of access.   A failure to be able to access the Internet prevents one from participating fully in political life, returning us to the democracy of landed gentry, rather than the moves away from that model that we have made in modern times. Today, it is necessary for Internet access to be affordable to more than the affluent.
Balanced against these imperatives is the right of the current providers to benefit economically from their investment in the existing infrastructure.  The CRTC is mandated to give the market every opportunity to deliver efficiently and affordably before interceding.  We assert the market has failed, and the time has finally come for the CRTC to no longer stay the heavy hand of regulation to curb the tendency to duopoly and inefficiency.
While we have chosen to step into the gap to make access affordable and would advocate for our model of communities coming together to provide what they need for themselves to be encouraged and facilitated, we are not opposed to the telecommunications companies delivering the service directly under their model, but being forced to provide it equally, effectively and affordably. 
 
Efficiency and Innovation
The market has failed to deliver on efficiency and innovation.  In our presentation we cited several examples of innovation and efficiency achieved by the collective effort of a local community. 
From a theoretical perspective, the market should have been able to deliver a very efficient solution.  Large providers are able to provide coordinated delivery reducing the potential duplication of many small efforts all operating in the same area.  In addition, the telephone, cable and power companies are able to leverage the sunk costs of their existing infrastructure by utilizing the excess capacity in their installed equipment to deliver additional services.  In addition, by having two such providers one achieves long term redundancy where end users can shift over in the case of failure of one of the providers.  Unfortunately this theory has not come to practice. 
The situation at the beginning of our “Manors Project” is representative of the failure of the market to deliver.  In the telco model, each provider does a “home run wire” all the way to the unit, and from there achieves final feet delivery through wifi to the end users' devices.  When we entered, one provider had yet to install the necessary quality wiring and the other was delivering at a cost well above an affordable rate for most end users.  
The Chebucto model is to have a Wifi network in one building link to a high speed Internet bridge. The obvious problems with this are that (a) it has to cope with a lot of frequency contention, and (b) the network chain supplying connectivity is vulnerable to equipment and link single points of failure.  Balanced against this is the efficiency and cost-savings that can be achieved, making it affordable to the particular end-users that we stepped in to service. 
In practice, with one provider priced well above what the market could bear, there was a loss of long-term redundancy and the service could not be delivered universally at all. 
In our Manors Project, we experience some frequency contention with other wifi access points not part of our system, but are achieving full network speeds to our end users, and currently our link to the high speed network access point is able to deliver speeds well above the working definition of “basic access” of 5 Mbps/1 Mbps.  Currently our users receive 15 Mbps up and down. Through convenience of geography we were able to make the physical network link from the building to a high speed Internet access point at quite minimal cost, and through bulk purchase of Internet bandwidth we are able to achieve savings in Internet access costs.   However, by sharing the physical uplink costs between building residents we believe that this model could be replicated to achieve lower cost Internet access for any dense building. 
For completeness, we can compare to a market that is operating “properly” in the apartment building of one of our board members.  In this building both competing providers are operating and each unit then passes this connection on to its residents through local Wifi Access Points.  The wireless spectrum is so crowded that it is a challenge to get full wireless speeds, and each user is paying 8 times the cost for 1.2 times above the working definition of “basic service” download speed, and only 8/10th of the proposed upload speed.  Competition has inherently halved the potential efficiency, and lack of coordination in the local community leaves a lot of potential bandwidth underutilized as each user hits their lower cap for short periods of the day while not being able to share their unused bandwidth with their neighbours during the rest of the day.  (Obviously, the regulator can address Wifi frequency competition by opening more of the spectrum to unlicensed computer networks but this does not address the fundamental inefficiency of not being able to match idle usage with active usage.)  In practice, each provider is so reliable that redundancy has so been unnecessary to achieve sufficient reliability.  Most network failures are deliberate due to organizational administrative failures rather than technical failures. 
Our view is that while density provides us with inherent abilities to achieve efficiencies in an urban area, likewise collective action and lack of density allows groups like B4RN, and the radio-delivered network in Burgeo, NL to achieve similar efficiencies in rural areas.  (The latter achieving it through lack of competition on the radio spectrum in the local area).  In comparison the model of individual delivery chosen by the telcos is inherently inefficient, and the CRTC has failed to fulfill its mandate to encourage innovation. 
Like National Capital FreeNet we have also benefited from the winning combination of having an educational institution as an anchor, having local leadership, and many dedicated volunteers.  While our IT sector is not as extensive as that in Ottawa, starting in a Computer Science department at a university gave us access to a sufficient IT sector to form and sustain ourselves.  However, there are other initiatives cited that have not had these benefits, and have also formed and sustained themselves.  In the succeeding years, the IT sector at the level necessary has expanded to being so ubiquitous that it is no longer necessary to have access to these concentrations of expertise, and access to the Internet delivers training opportunities to develop the necessary expertise.  The other feature that the University anchor provided was that as users of the Internet of those days the benefits were clear and this gave the drive to get the initiative off the ground.   As demonstrated by the popular call for these hearings, this understanding of the benefits of the Internet, or computer network-mediated access to resources has become clear to the rest of the community also.
 
Local Access, Local Solutions
Given our foundations, we advocate for encouragement of local access and local solutions. 
While we subscribe to some aspects of The Internet as a world-wide network, we are more focused on it being a network of interconnected networks.  High speed local networks at low cost have always been achievable, and have only become more so.  Traditionally, high speed networks over long distances have been prohibitively expensive.  However, local initiatives to connect to the nearest high speed connection point have proven highly effective. 
While there is nothing to prevent the telcos from mediating and facilitating the models of these local initiatives, for various reasons they have not pursued this route.  If nothing else, we would advocate the use of the regulatory power to prevent entrenched players from using their position to frustrate these local initiatives. 
The various local initiatives cited have adapted the approach to delivery based on local conditions, both challenges presented and inherent advantages of their local situation.   The inherent advantages of a local situation are not immediately apparent to a central controller in a remote office and sometimes the local challenges can appear more daunting to someone who is trying to achieve the efficiencies of a one-model delivery to their entire service area, causing them to decide not to extend the service at all to an area.   We believe that the local players or groups can better utilize local knowledge to achieve the same effect, high speed network access, even if they are not employing the same solution used in the current service areas.  Likewise local groups are more motivated to achieve the goal than those who don't care about the delivery of the service to a particular area other than that it is something they have expertise in doing elsewhere and hence should have more efficiency and more profitability than a local group.  That is to say, without profitability in a particular area, there is no motivation to deliver in that area, unless forced to do so in order to be able to deliver in a more profitable area. Profitability can be undermined by both inherent technical challenges of delivering in an area, but also by the area being poor and not being able to afford the service at the same cost as the customers in a more profitable area even if the service can be delivered at cost for much less. 
Because of our originative bias toward using computer networks for local community building, we are more interested in defining mandated Internet access as high speed access to local resources, local entrepreneurs, government services and similar resources, and separating the question of speed of access to remote resources into a different sub-question.  While we do believe that access to global resources is very valuable both culturally and economically, we want to avoid the potential for it being the basis upon which a telecommunications provider can defend fees beyond those that are affordable for a “basic Internet” service. 
 
CRTC Role
We were asked at the hearing what role the CRTC can play in achieving its mandate to render reliable and affordable telecommunications services of high quality accessible to Canadians in all areas of Canada.  
As observed by the University of Ottawa Samuelson Glushko Canadian Internet Policy and Public Interest Clinic, we believe the CRTC not only has broad powers to act to achieve the aims of universal access to broadband Internet at affordable rates, but further we believe it has an imperative to do so. 
As observed during the question and answer at our presentation to the Commission, the CRTC could be a central coordinator of discovering resources available to local initiatives. They could also mandate the creation of an Internet fund that can be made available to local initiatives for areas or communities that the large scale market-based initiatives have failed to deliver to.  It is unclear how much power or persuasion the CRTC has to influence the government Executive to fund this initiative from the savings achieved by closing local Service Canada points of presence. 
31.  As a regulator, the CRTC can also impose conditions to prevent entrenched players from thwarting new players and local initiatives. The CRTC can be a venue for disputes over fair rates for bulk access to the wider Internet, and for fair access to the existing telco infrastructure.  In addition, the Commission can regulate the conditions of provisioning services to prevent existing players from denying new players or individuals from reselling services purchased from them.  We believe it is clearly within the powers of the Commission to mandate that in situations of local initiatives to connect areas unserved or under-served by existing carriers that interconnection to the rest of the Internet shall be provided by reliable connections at affordable rates to the groups undertaking such enterprises, should such enterprises be able to make a connection into a fully served area. 
32.  We believe the Commission's powers set out in sections 26 and 27 of the Telecommunications Act to set rates are more clearly stated than those to mandate that a carrier to serve an area.  The Commission is directed to do that which would further the goal of providing reliable and affordable telecommunications services in all areas, urban and rural, in Canada but the rate setting power is specifically spelled out whereas utilizing any other powers to allow or deny to achieve its goals is less clearly stated.  We observe that s 27(6)(b) of the Act allows a carrier to request to reduce or eliminate their charges to charitable organizations, disadvantaged persons, and others, and we speculate about whether the broader powers might allow such an order to be initiated at Commission instance to facilitate or make feasible the connection of local initiatives, specifically those designed to serve such groups or organizations. 
 
Conclusion
33.  In conclusion, we believe that it is vital to provide some form of basic Internet universally, and affordably, and that the CRTC has both the mandate and powers to mandate this.  We believe this can be achieved by a National Contribution Fund to fill in gaps where the profit motive is insufficient to encourage delivery, or by regulation setting rates and service level guarantees.  However, we believe our model is efficiently filling the gap, and could be replicated in other communities with funding and the ability to connect to the nearest highspeed link.

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Chebucto Community Net's testimony at the CRTC Talk Broadband hearings in Gatineau, Québec on 25 April 2016.

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Ottawa's National Capital FreeNet's testimony at the CRTC Talk Broadband hearings in Gatineau, Québec on 25 April 2016.

The Annual General Meeting of the Chebucto Community Net Society will take place on Thursday, April 14 at 6:30 PM in the Slonim Seminar Room, Dalhousie University Goldberg Computer Science Building, 4th Floor, 6050 University Avenue. We look forward to seeing you!

AGENDA

6:30 - 7:00 PM  Social Meet and Greet old friends and new. Refreshments provided.

Call to Order

Video: "Digging To The Future!"

1. Minutes (2014 AGM)

2. Chair's Report

3. Treasurer's Report

4. Policy Committee Report

5. Technical Committee Report

6. Election of Directors

7. Appointment of Auditor

8. Other Business

9. Awarding of door prizes to winners in attendance

10. Adjournment






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Halifax NS Highspeed Internet Access Prices as of 24 March 2016.
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Dear Chebucto Friend:

I'm writing to tell you about a very important upcoming event and to urge you to mark it on your calendar. The Annual General Meeting of the Chebucto Community Net Society will be held on Thursday April 14, 2016 at the Slonim Seminar Room of the Dalhousie University Goldberg Computer Science Building, 6050 University Avenue, next door to the Nova Scotia Public Archives Building on the corner of Robie Street and University Avenue.

We will meet at 6:30 PM to enjoy some light refreshments and the chance to say Hi to some old friends and meet some new ones. The business meeting will begin at 7:00 PM and will last approximately 1 1/2 to 2 hours. There will be door prizes awarded following the meeting.

It is very important that we have a good turnout for this meeting. You
will be asked to pass motions that will enable the Board of Directors to conduct business on your behalf over the coming year. You will also be asked to elect the incoming Board of Directors.

If you are a member in good standing of the Society, you are eligible to offer to serve on the Board. No special technical skills are required.
What is needed is a commitment to the cause of providing affordable
Internet access and the willingness to offer some time and talent to
furthering that cause. If you wish to offer to serve on the Board please contact office@chebucto.ns.ca and provide a short bio.

An official notice of the Annual General Meeting along with an agenda will be sent to you several days before the meeting date. Please do plan to be present! Looking forward to seeing you there! :)



Marilyn MacDonald

Chair, Board of Directors

Chebucto Community Net Society





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Halifax N.S. Internet Access Prices December 2015
Non-Profit access in white.

Posted regular prices without bundles or promotional pricing as of December 2015.
Bell/Eastlink require installation fee of ~$60.
Chebucto Wireless only available as annual membership.
All services from all providers not available in all locations.
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 Re: Review of basic telecommunications services, Telecom Notice of Consultation 2015-134 – Request for information
 
 Reference: 8663-C12-201503186
 
1a. Describe in detail the services Chebucto Community Net provides as well as their characteristics (e.g. upload speed, usage allowance).

 
Chebucto Community Net is a non-profit registered society. There are several different levels of membership but our flagship membership is our Chebucto Plus level for $125.00 per year.

Chebucto Community Net provides both 56K dialup access and in two (soon to be five) select Halifax public housing buildings ("The Manors") full symmetrical 11 Mbps down and up highspeed access over wireless on both 2.4 GHz 802.11n and 5 GHz 802.11ac frequencies at the Chebucto Plus membership level. There are no download caps or other limitations to the connection. The only drawbacks would be vulnerability to power outage and lack of 24 hour telephone technical support: user support is primarily over email.

In addition to the connectivity, a $125.00 per year Chebucto Plus membership also includes a 2 GB mailbox accessible via https Webmail, SSL/TLS IMAP and POP3, and even SSH, with end-to-end server encryption and 4096-bit EV-SSL security certificate.  10 MB personal web space is also included with SFTP and SSH file access.
 
 
1b. What considerations were take into account in establishing the $125 annual membership fee?
 
 
Our purpose is to provide access for all to the tools of communication and so we needed to reach a balance between an adequate revenue stream from memberships to sustain our services and the need to keep costs to a minimum, preferably as close to $10 a month as possible (though to be specific, all our membership fees are annual only, there are no monthly plans).

From years of dealing with lower income users we know that even this $10 a month figure is too high to afford for some so we have low cost memberships that do not include PPP (Point to Point Protocol) access, just a terminal-based text access accessible from a network connection or through dialup access using a terminal emulation program. We even have a free version of this access which some still use as their primary Internet access.

The $125.00 annual Chebucto Plus membership figure is our best effort to meet the minimum cost level while still covering costs, as we do not receive any outside money for our operations other than membership fees and donations.

A typical Manors resident may have a monthly income in the $500 range with $350 deducted for rent. This does not allow a lot of extra expenses and usually the high cost of commercial Internet access means sacrificing something else. Even getting our $125 annual fee together means months of saving.
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