COUNTRY LIVING AT ITS BEST

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4 THE CORPORATION OF THE TOWNSHIP OF MONTAGUE 6547 ROGER STEVENS DRIVE P.O. BOX 755 SMITHS FALLS, ON K7A 4W6 TEL: (613) FAX: (613) October 8 th, 2014 Senior Director, Spectrum Development and Operations Industry Canada 300 Slater Street (JETN, 15 th ) Ottawa, ON K1A 0A5 spectrum.operations@ic.gc.ca Dear Sir/Madam: Canada Gazette, Part I, August 19, 2014, DGSO Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas On behalf of my Council members from the Township of Montague, I am writing to express our concerns regarding your proposals contained in the above consultation document. Our municipality strongly supports the views expressed by the Chairs of the Eastern Ontario Wardens Caucus and the Eastern Ontario Regional Network. As they have expressed to you in their joint submission and their letter to Minister Moore your proposed policy changes, particularly those related to taking back 3500 MHz spectrum and reallocating it to cellular companies in the urban blocks, is completely unacceptable to us. Should you proceed along this path we know that more than 11,000 customers across a large part of eastern Ontario face the spectre of losing their connection to high-speed services. This cannot be allowed to happen. The Government along with its partners in EORN have just connected these homes and businesses at a considerable cost to the public and to its private sector partner. Millions of dollars would be wasted and the good work of EORN damaged. This must be avoided. Like the EOWC and EORN we are concerned with the view that rural areas like ours will only require limited access mobile cellular services while our urban cousins will require much more. This view is far from our reality and must be challenged. Many of our citizens and business not to mention our own municipal services like public works, fire, police and EMS require sufficient, affordable mobile services. This demand will continue to grow not decrease. Once again COUNTRY LIVING AT ITS BEST

5 THE CORPORATION OF THE TOWNSHIP OF MONTAGUE 6547 ROGER STEVENS DRIVE P.O. BOX 755 SMITHS FALLS, ON K7A 4W6 TEL: (613) FAX: (613) rural taxpayers and businesses will be left behind if you proceed with these policy proposals. As the Chairs have rightly stated we will need more not less mobile service. We urge you to hear our concerns and rethink your proposals for the sake of rural taxpayers in our municipality and across the region. Yours truly, Katie Valentin Clerk cc. Council County Council Hon James Moore, Minister MP Scott Reid MPP Randy Hillier COUNTRY LIVING AT ITS BEST

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8 The Corporation of the Township of NORTH KAWARTHA P.O. Box 550, 280 Burleigh Street Apsley, Ontario KOL 140 (705) or (ext.234) Fax: (705) c. on. ca www. north kawartha. o n. ca k.com/northkawa rtha October 8,2014 Senior Director, Spectrum Development and Operations lndustry Canada 300 Sláter Street (JETN, 15th) Ottawa, ON K1A spectrum.operat ons@ic.gc.ca Ðear Sir/Madam: Canada Gazette, Part l, August 19,2014, DGSO Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas On behalf of the Mayor and Council members of the Township of North Kawartha, I am writing to express our concerns regarding your proposals contained in the above consultation document. Our Municipality strongly supports the views expressed by the Chairs of the Eastern Ontario Wardens Caucus and the Eastern Ontario Regional Network. As they have expressed to you in their joint submission and their letter to Minister Moore your proposed policy changes, particularly those related to taking back 3500 MHz spectrum and reallocating it to cellular companies in the "urban" blocks, is completely unacceptable to us. Should you proceed along this path we know that more than 11,000 customers across a large part of eastern Ontario face the spectre of losing their connection to high-speed services. This cannot be allowed to happen. The Government along with its partners in EORN have just connected these homes and businesses at a considerable cost to the public and to its private sector partner. Millions of dollars would be wasted and the good work of EORN damaged. This must be avoided. Like the EOWC and EORN we are concerned with the view that rural areas like ours will only require limited access mobile cellular services while our urban cousins will require much more. This view is far from our reality and must be challenged. Many of our citizens and business not to mention our own municipal services like public works, fire, police and EMS require sufficient, atfordable mobile services. This demand will continue to grow not Page 1 of2

9 decrease. Once again rural taxpayers and businesses will be left behind if you proceed with these policy proposals. As the Chairs have rightly stated we will need more not less mobile service. We urge you to hear our concerns and rethink your proposals for the sake of rural taxpayers in our municipality and across the region. Sincerely,,/),fr /-/ +- /1u&,*Å l -7-lu* Connie Parent, Dipl. M.M., CMO, C/erk (on behalf of the Mayor and Council Members of the Township of North Kawartha) copied to: Council County Council Hon. James Moore, Minister Barry Devolin, MP Laurie Scott, MPP Page 2 of 2

10 Township of Perth East P.O. Box 455, 25 Mill Street East Phone- (519) Milverton, Ontario N0K 1M0 Fax- (519) October 8, 2014 Peter Hill Director General, Spectrum Management Operations Branch Industry Canada 300 Slater Street (JETN, 15 th ) Ottawa, ON K1A 0A5 spectrum.operations@ic.gc.ca Dear Mr. Hill: Canada Gazette, Part I, August 19, 2014, DGSO Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas Recently the Rural Ontario Municipal Association (of which the Township of Perth East is a member) learned that Industry Canada has proposed changes effecting rural Internet service in the Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas, DGSO , dated August 19, 2014 (the Consultation Paper ). We are gravely concerned about this proposal. The Rural Ontario Municipal Association (ROMA) is the rural arm of the Association of Municipalities of Ontario (AMO). The association is an integral part of AMO and a number of its Executive Members serve on the AMO Board of Directors. Policy, research and advocacy activities are undertaken by ROMA through AMO. Matters which affect rural communities are brought to the attention of the provincial and federal governments. These comments are in response to the proposals in questions 1, 7 and 8 of the Consultation Paper. While we share the stated goal of ensuring the best possible high-speed Internet in Ontario s rural regions, the proposals in the Consultation Paper would not have that effect. The proposals, as drafted, take away spectrum in use today to provide Internet service to Ontarians outside of the big cities and gives it to telephone companies for future mobile phone use. If that happens, hundreds of thousands of current residential and business customers in rural Canada will lose their existing high-speed Internet service, including people in our area. Access to internet is the foundation of economic enterprise in rural areas. This proposal is a step backwards for rural Ontarians and not in keeping with the stated goal of increasing Internet access for Ontarians. The proposed reclassification of the licensed areas would designate vast rural areas as urban areas. Once this reclassification happens, the proposal then calls for all the urban licenses to be taken away from rural Internet service providers (ISPs), even though the licenses are in use providing service to people today, and for that spectrum to be given to cellular phone companies for future use with smart phones that have not yet been developed. Integrity Teamwork Service Continuous Improvement Fiscally Responsible

11 We do not support any proposal that ignores the current needs of rural Ontarians by taking away ALL of the spectrum and giving it to cellular companies. The Consultation Paper states that the "Government of Canada is committed to ensuring that Ontarians benefit from the availability of advanced, competitively priced telecommunications services in all regions of the country" and has a commitment "to extend and enhance broadband Internet services in rural and northern communities in order to meet the continued demand for fixed services in rural areas". However, the proposals in the Consultation Paper do not live up to those promises. Any proposal that would see a large number of rural Ontarians being designated "urban" and having fixed wireless Internet service in the areas shut down does not benefit "all regions of the country". It sacrifices the current needs of rural communities, takes away the economic and social benefits of the Internet from rural residents and undermines all the hard work that rural areas have done to ensure we connect rural residents to high quality internet services. We urge the Minister of Industry and Industry Canada to reject the flawed proposals in the Consultation Paper and at the very minimum, to do no harm- please leave the licenses in place for spectrum that is in use today providing service to Ontarians and exempt the licenses that are delivering high speed fixed wireless internet services today from any requirement to depart from this spectrum. Please do not take away Internet Service from rural residents. Sincerely, Glenn Schwendinger Chief Administrative Officer cc Anne Marie Quinn, Senior Vice-President and Partner, FleishmanHillard - annemarie.quinn@fleishman.ca Integrity Teamwork Service Continuous Improvement Fiscally Responsible

12 Township of Sioux Narrows - Nestor Falls P.O. BOX 417 Phone (807) SIOUX NARROWS, ONTARIO FAX (807) P0X 1N0 October 7 th, 2014 Mr. Peter Hill Director General, Spectrum Management Operations Branch Industry Canada 300 Slater Street (JETN, 15 th ) Ottawa, ON K1A 0A5 spectrum.operations@ic.gc.ca Dear Mr. Hill: Canada Gazette, Part I, August 19, 2014, DGSO Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas The Rural Ontario Municipal Association learned that Industry Canada has proposed changes effecting rural Internet service in the Consultation on Policy Changes in the 3500 MHz Band ( MHz) and a New Licensing Process in Rural Areas, DGSO , dated August 19, 2014 (the Consultation Paper ). We are gravely concerned about this proposal. The Rural Ontario Municipal Association (ROMA) is the rural arm of the Association of Municipalities of Ontario (AMO). The association is an integral part of AMO and a number of its Executive Members serve on the AMO Board of Directors. Policy, research and advocacy activities are undertaken by ROMA through AMO. Matters which affect rural communities are brought to the attention of the provincial and federal governments. These comments are in response to the proposals in questions 1, 7 and 8 of the Consultation Paper. While we share the stated goal of ensuring the best possible high- speed Internet in Ontario s rural regions, the proposals in the Consultation Paper would not have that effect. The proposals, as drafted, take away spectrum in use today to provide Internet service to Ontarians outside of the big cities and gives it to telephone companies for future mobile phone use. If that happens, hundreds of thousands of current residential and business customers in rural Canada will lose their existing high- speed Internet service, including people in our area. Access to internet is the foundation of economic enterprise in rural areas. This proposal is a step backwards for rural Ontarians and not in keeping with the stated goal of increasing Internet access for Ontarians. The proposed reclassification of the licensed areas would designate vast rural areas as urban areas. Once this reclassification happens, the proposal then calls for all the urban licences to be taken away from rural Internet service providers (ISPs), even though the licences are in use providing service to people today, and for that spectrum to be given to cellular phone companies for future use with smart phones that have not yet been developed. We do not support any proposal that ignores the current needs of rural Ontarians by taking away ALL of the spectrum and giving it to cellular companies. Continued.. Live the Lake Life

13 Township of Sioux Narrows - Nestor Falls P.O. BOX 417 Phone (807) SIOUX NARROWS, ONTARIO FAX (807) P0X 1N The Consultation Paper states that the Government of Canada is committed to ensuring that Ontarians benefit from the availability of advanced, competitively priced telecommunications services in all regions of the country and has a commitment to extend and enhance broadband Internet services in rural and northern communities in order to meet the continued demand for fixed services in rural areas. 1 However, the proposals in the Consultation Paper do not live up to those promises. Any proposal that would see a large number of rural Ontarians being designated urban and having fixed wireless Internet service in their areas shut down does not benefit all regions of the country. It sacrifices the current needs of rural communities, takes away the economic and social benefits of the Internet from rural residents and undermines all the hard work that rural areas have done to ensure we connect rural residents to high quality Internet services. We urge the Minister of Industry and Industry Canada to reject the flawed proposals in the Consultation Paper and, at the very minimum, to do no harm please leave the licences in place for spectrum that is in use today providing service to Ontarians and exempt the licensees that are delivering high speed fixed wireless internet services today from any requirement to depart from this spectrum. Please do not take away Internet service from rural residents. Sincerely, Wanda Kabel Chief Administrative Officer cc. Anne Marie Quinn, Senior Vice President and Partner, FleishmanHillard annemarie.quinn@fleishman.ca 1 Consultation Paper, para. 6. Live the Lake Life

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35 United Counties of Stormont, Dundas & Glengarry 26 Pitt Street, Cornwall, Ontario K6J 3P2 September 24, 2013 Senior Director, Spectrum Development and Operations Industry Canada Ottawa, Ontario K1A 0H5 To whom it may concern: Re: Consultation on Policy Changes in the 3500 MHz Band / New Licensing Process in Rural Areas Recently I was made aware of Industry Canada s consultation document on the use of the 3500MHz Band spectrum. It is my understanding from this that if implemented more than 11,000 current residents and businesses in eastern Ontario will lose their internet connections as part of the Eastern Ontario Regional Network (EORN). Millions of public and private dollars have been invested through the EORN project, the purpose of which was to connect homes and business across eastern Ontario. The proposal by Industry Canada will also impact a significant portion of Stormont, Dundas and Glengarry. Transferring spectrum to support urban customers will only intensify the divide between rural and urban Ontario. I am in full support of the Eastern Ontario Regional Network s position on this matter, and I ask for your support in amending the consultation proposals to allow continued use of licenses for ISPs that are party to the EORN project through the 3500 MHz spectrum. Further, I ask for your support in amending the proposed urban and rural license blocks to accurately reflect rural areas of eastern Ontario, and reject the Department s view that demand for mobile services will be limited in rural areas. Your assistance on this matter is greatly appreciated. Yours truly, Eric Duncan, Warden United Counties of Stormont, Dundas and Glengarry

36 Senior Director, Spectrum Licensing and Auction Operations Industry Canada Dear Sir/Madam, The Village of Clinton is deeply concerned by the implications of the proposed changes to the 3500 MHz band described in this consultation. If these proposed changes are enacted, a significant number of our citizens face the prospect of drastically reduced or terminated internet services. Many of the homes and businesses in Clinton ( within the proposed Kamloops Tier 4 area) depend on fixed wireless services for broadband connectivity. These services are provided using the 3500 MHz spectrum license awarded to ABC Communications in the 2004 auction. ABC s continued access to this spectrum is necessary for continued investment and growth of services to rural citizens. From the information provided by Industry Canada regarding the reallocation 3.5 GHz spectrum, we do not believe that our region should be classified as Urban. We understand Industry Canada s need to provide mobile spectrum in dense urban areas, however some mechanism should be found that allows for mobile services to coexist with these important rural services. Our village has benefited from the investments made by ABC Communications, in particular, into state-of the-art fixed wireless networks. Their network brings high-speed last-mile connections to our residents, spurring business development and e-commerce. We recommend that fixed wireless operators, who have met their deployment requirements, be offered a ten-year license renewal for rural Tier-4 areas. We recommend that the Kamloops Tier 4 area not be classified as an urban region. We appreciate Industry Canada s past contribution to and concern for rural broadband connectivity, and we hope that Industry Canada will continue to support rural economies. Regards, -- Jim Rivett Mayor Village of Clinton BC

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