July 14th, 2023
Re: Timely Access for all Canadians to Wireless Services on the TTC
8620-B2-202303858 - Bell Canada
Application for Mandatory and Injunctive Orders in Respect of Rogers Communications Inc. to Ensure Timely Access for all Canadians to Wireless Services on the TTC
Dear Canadian Radio-television and Telecommunications Commissioners,
All transit users need access to cellular service, regardless of who their provider is. We, the nine undersigned organizations, are writing in agreement with Bell Canada’s request that the CRTC act in the interest of public safety and convenience and ensure timely access for all Canadians to wireless services in the Toronto Transit Commission (TTC) subway system.
Cellular access on Toronto’s subway system is not a nice-to-have, it is an urgent necessity. In light of recent high-profile violent incidents on the TTC, many transit riders have reported feeling less safe. A 2022 poll commissioned by the Woman Abuse Council of Toronto (WomanACT) and Angus Reid Group found that the subway was the mode of transit where people felt most unsafe, in contrast to streetcars and buses, which speaks to the importance of cellular access to feeling and being safe. This same study found that women, in particular, Black, Indigenous and other racialized women, feel less safe than men when using public transit.
Access to 9-1-1 emergency service is important, but not adequate to address transit users’ safety concerns. Universal cellular access will allow transit riders to communicate with loved ones during an emergency, navigate the transit network, and be informed of service disruptions in real time.
In 2012, BAI Communications was awarded a contract with the TTC that gave them the exclusive right to build, own, and operate a cellular network in Toronto’s subway tunnels. The TTC’s original Request For Proposals (RFP) asked that the proponent establish a contract with enough wireless carriers that at least 60% of cellular customers in Toronto would be able to access the network. This requirement did not make it into the contract, and only Freedom Mobile has signed on to use the existing infrastructure. The current network is extremely limited, with 25% of the subway currently covered. Coverage exists only in subway stations, within the downtown “U” tunnels, and within the tunnels of the Toronto-York Spadina Subway Extension (TYSSE) between Downsview Park and Vaughan Metropolitan Centre stations.
In April of 2023, Rogers Communications bought out BAI Canada, and with it inherited the existing infrastructure and rights to expand the network. This development presents an opportunity for upgrades and expansion of cellular coverage on the TTC Subway. Concerningly however, Rogers Communications is refusing to work with other service providers to allow access to their infrastructure.
Bell Canada’s application raises a number of troubling concerns, including that “Rogers is seeking to deny or delay access [to cell service in the TTC] for the majority of Canadian consumers for as long as possible,” and that Rogers and the TTC expect negotiations with other cellular providers to drag on “until perhaps the middle of 2025.”
Any exclusive or preferred access arrangements for Rogers, or delay or denial of access for all other cellular providers, is completely unacceptable. The public’s need to stay connected throughout Toronto’s primary transit system must come first.
We urge the Commission to intervene and ensure that all transit users, regardless of who their provider is, gain access to cellular service within the TTC as soon as possible.
Sincerely,
TTCriders
Founded in 2010, TTCriders is a membership-based organization in Toronto that gives transit users a voice.
OpenMedia
OpenMedia is a grassroots community of Internet users that work to make Canada’s Internet accessible, open and surveillance free.
WomanACT
Woman Abuse Council of Toronto (WomanACT) is a non-profit organization that works to eradicate gender-based violence through research, education, and advocacy.
A Voice for Transit
A transit advocacy group composed of current Toronto Metropolitan University (formerly Ryerson University) students and alumni that was founded in March 2019.
CodeRedTO
A volunteer-led transit advocacy group in the Greater Toronto and Hamilton Area (GTHA).
Leadnow
Leadnow is an independent advocacy organization that brings generations of Canadians together to achieve progress through democracy.
Social Planning Toronto
Challenges inequity in our city – through knowledge generation, debate, civic engagement, advocacy, and collaboration – to spark social and policy change.
Toronto Youth Cabinet
Established in 1998 by Toronto City Council, the Toronto Youth Cabinet is the official youth advocacy body to the city. We are a youth-led organization that promotes youth participation in municipal affairs and policy development.
Transport Action Ontario
Transport Action Ontario is a regional division of Canada's leading citizen transportation advocacy group, Transport Action Canada.
YWCA Toronto
YWCA Toronto is a non-profit, multi-service organization dedicated to improving the lives of women, girls and gender diverse people through service and advocacy.
1 https://womanact.ca/wp-content/uploads/2022/06/GTA-Transit-Study-Key-Findings.pdf
2 https://ttc-cdn.azureedge.net/-/media/Project/TTC/DevProto/Documents/Home/Public-Meetings/Board/2012/November-21/Reports/Wireless_Network_in_.pdf