Telecom Public NoticeCRTC 2001-37, Price Cap Review and Related Issues

Oral Hearing October 1, 2001

Submission of Folkstone Design

I live on the Sunshine Coast of B.C., but am speaking to you today from the

Digital Divide Forum at the British Columbia Internet Association

Conference in Penticton.

I am concerned that, while the letter of the "High Cost Service Area

Decision" is being addressed, the spirit of the decision is not.

I am concerned about the quality, cost and medium term obsolescence; in

terms of the National Broadband Task Force recommendations, of

implementation in high cost service areas.

If technologies used in the Nemi'ah Valley, and Hot Springs Cove, BC, are

the benchmark used to determine inclusion of communities in these

proceeding under the terms of the High Cost Service Area Decision, I

believe the cart has been put before the horse.

In submissions by Telus a term similar to "lowest cost technology" is used.

However, a technology decision has be made which has been used to eliminate

communities from these proceedings on the basis of the expense of a

specific technology. Anderson Lake, B.C., is an example of one community

excluded in this way.

New technologies are available which can address concerns of quality, cost

and medium term obsolescence.

I propose that rather than be excluded from these proceedings, all

permanent residence in high cost service areas should be included at the

maximum allowable rate.

Telus have suggested that being the provider of last resort through the use

of subsidies would have the effect of significantly reducing competition.

I suggest that these funds should be held in trust relative to the specific

community and be made available to any organizations who can implement more

forward looking technologies which meet the requirements and spirit of the

High Cost Service Area Decision. This approach may be appropriate to all

high cost service areas.

For this approach to work it should be incumbent upon the resident ILEC to

provide interconnect at the closest point of presence, since rules that

apply to built up urban areas may prove unworkable in remote areas.

This inclusive approach will have the effect of broadening innovation,

encouraging competition, and focusing on factors that enhance potential

market growth.

Thank you for your attention.

Scott Bleackley

Folkstone Design Inc.

604 886-4502