The following piece about the CRTC’s Broadband Labels proceeding appeared as an OpEd in The Hill Times on July 23 and The Wire Report on July 24.

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Fixing what isn’t broken: Why the CRTC should rethink broadband labels

What started as a straightforward question — how best to measure and present broadband speeds to consumers — has spiraled into a regulatory exercise in search of a problem.

The CRTC’s ongoing push to mandate standardized broadband labels is a solution that’s not only unnecessary in the Canadian context, but one that has failed to deliver meaningful results elsewhere.

The Commission’s own consumer research tells a clear story: Canadians already find the information provided by their internet service providers useful and easy to understand. Consumers report being able to compare options and make informed choices based on what’s available in the market. That should be the end of the story.

But it’s not.

Instead of recognizing that the system is working well, the CRTC doubled down on the idea of creating a standardized “nutrition label” for broadband services—mirroring an approach taken in the United States. The problem? There’s no evidence the U.S. model works. On the contrary, data cited by Cogeco in its submission to the CRTC shows that only 2% of customers of its U.S.-based services even look at the broadband label. For a public policy tool that’s supposed to empower consumers, that figure should raise serious concerns.

In fact, the U.S. experience should be viewed as a cautionary tale. While standardized labels may seem appealing on paper, they haven’t improved consumer outcomes in practice. Other countries, like the UK and Australia, have opted not to mandate such labels. Rather than micromanaging how companies communicate service information, they’ve recognized that companies should have the flexibility to display product information provided it is accurate and not misleading.

The Canadian broadband landscape, while not perfect, is delivering results. Consumers are better informed than ever. Providers have every incentive to communicate clearly in a competitive marketplace where switching is relatively easy, and transparency is expected. Rather than enhancing transparency, a mandatory label risks becoming a costly distraction from the issues that matter most to consumers.

Complying with a prescriptive labelling mandate requires service providers to invest time, money, and ongoing IT system changes. These are finite resources that could be — and should be — spent on things that matter more to consumers: expanding rural coverage, boosting network speeds, and improved resiliency.

Instead, if the CRTC imposes a standard label requirement, we’re likely to see a label very few Canadians will read, developed through a lengthy regulatory process that has only a self-congratulatory press release issued by the CRTC to show for it. For the average consumer, the impact will be negligible. Meanwhile, the opportunity cost will be very real.

This isn’t to say the CRTC shouldn’t care about consumer transparency. It absolutely should. But it needs to pick its tools carefully. When the existing approach is working, when international evidence points the failure of labeling mandates, and when the cost of action outweighs the benefit, regulators should resist the urge to do something for the sake of doing something.

Canada’s telecommunications future depends not just on investment and innovation, but on smart, focused regulation. This is a moment for the CRTC to embrace pragmatism over performative policy. It should resist the temptation to fix that which isn’t broken — and acknowledge that sometimes doing nothing is the best option.

The ITU’s Broadband Commission released a report, “The State of Broadband Advocacy Targets” [pdf, 6.1MB] as part of its State of Broadband 2025 report series. The report recognizes that “communication services providers and operators have enabled, and helped deliver, years of reasonably consistent economic growth across different countries and economies.”

as gaps in access narrow, the digital divide is taking on new forms. Digital technologies are expanding in scope, scale and influence. Policy-making and regulation have moved on from questions of basic access to telecommunications and Internet to recognize different types of digital divides, such as age and/or gender digital divides, and their implications for access to education, healthcare, e-government services, employment opportunities and participation in the digital economy.

As I wrote a few weeks ago, the Broadband Commission report found strong progress in affordability, with targets having been achieved at the global level. As a result, policy-making is evolving to include new and emerging topics such as digital transformation and AI.

The State of Broadband Advocacy Targets report is intended to inform policy-makers on progress towards the Broadband Commission’s goals. It emphasizes a need to leverage the benefits of digital technologies, mitigating potential risks, while aspiring for equitable access to digital opportunities.

The report also presents an overview of broad industry trends, as well as case studies for the advocacy targets to illustrate how broad trends are playing out in practice. It briefly looks at how different initiatives, policies, platforms and programmes help make a difference in people’s lives through broadband connectivity and services.

The advocacy targets:

• Advocacy Target 1: Make broadband policy universal
• Advocacy Target 2: Make broadband more affordable
• Advocacy Target 3: Get everyone online
• Advocacy Target 4: Promote Digital skills development
• Advocacy Target 5: Increase use of digital financial services
• Advocacy Target 6: Get MSMEs online
• Advocacy Target 7: Bridge the gender digital divide

How is Canadian broadband policy evolving to recognize advances made in Canada’s competitive landscape?

TELUS recently released its second annual AI report [pdf, 15.3MB] and among its key findings, the research shows that AI trust is “fundamental to the social license required to unlock AI’s full potential to do good”.

Pam Snively (Chief Data & Trust Officer, TELUS) said, “While Canadians are actively embracing AI in their daily lives, they’re telling us that trust must be earned through meaningful human oversight, robust safeguards, and transparent practices. It is trust that will determine how far and how fast we can go.”

The TELUS study canvassed views from 5667 members of Leger’s online panel between mid-December, 2024 and mid-January 2025. It reports Canadians recognize the potential for AI to drive social impact and productivity, but are concerned about the consequences of AI, if left unchecked, especially absent human intervention. The report says confidence in AI decision making doubles when human supervision is present, especially in “high stakes” areas such as healthcare.

The report speaks about “Responsible AI”, while noting that despite widespread use of AI is, 91% of respondents expressed concern about its impact on Canadian society, implying a recognition of AI’s potential as a powerful tool, but also as a risk:

AI has the potential to drive meaningful positive impact and productivity, transforming the way we work, live, and learn in the world. But this potential comes with risk. Issues like misinformation, bias, societal disruption, and data security make it clear: the responsible development of AI is crucial to the technology’s evolution as a tool to drive amazing outcomes.

I’ll note that TELUS has been involved in projects such as Trust by Design for at least 5 years, dating back to when the company described three core principles for its use of customer data: accountability; ethical use; and, transparency.

Last year, Harvard Business Review had an article by Bhaskar Chakravorti, Dean of Global Business at The Fletcher School (Tufts University), about persistent risks associated with AI trust. “For instance, radiologists hesitate to embrace AI when the black box nature of the technology prevents a clear understanding of how the algorithm makes decisions”.

The HBR article suggests that the AI trust gap will be permanent, “even as we get better in reducing the risks.”

This has three major implications. First, no matter how far we get in improving AI’s performance, AI’s adopters — users at home and in businesses, decision-makers in organizations, policymakers — must traverse a persistent trust gap. Second, companies need to invest in understanding the risks most responsible for the trust gap affecting their applications’ adoption and work to mitigate those risks. And third, pairing humans with AI will be the most essential risk-management tool, which means we shall always have a need for humans to steer us through the gap — and the humans need to be trained appropriately.

At last month’s meeting of the G7, the leaders issued a statement on “AI for Prosperity”. The statement calls for “[driving] innovation and adoption of secure, responsible, and trustworthy AI that benefits people, mitigates negative externalities, and promotes our national security.” The term “trust” shows up 13 times in the brief document, with the final section entitled “Unlock AI opportunity through trust-building”.

Writing about “AI Slop,” Josh Gans, from the Rotman School at University of Toronto warns “disinformation drives out information in the sense that people do not trust anything to be informative at all. That is, you can’t inform any people any of the time.”

Trust in AI systems will have to be earned. We need to ensure there is an appropriate level of AI literacy among lay people, to help build sufficient understanding of AI’s challenges and opportunities. Consumers and businesses alike need to be aware of the risks that come alongside powerful capabilities.

It has been a little over three years since I last looked at mobile affordability in detail. We frequently hear the term “affordability” used interchangeably with “lower spending”. That isn’t necessarily so, as we will see from a detailed examination of data from the latest release of Statistics Canada’s Survey of Household Spending (SHS).

Lower prices make items more affordable, but stable prices with rising incomes can have the same effect. Lower prices can also serve as an incentive for people to consume more of a service, or substitute one service for another. Statistics Canada’s Consumer Price Index (CPI) reveals mobile services prices are less than half what they were 5 years ago. Contrast that with the overall price index (reflecting goods and services across the economy), which is now 20% higher over that same time frame. So, mobile services are certainly more affordable than before.

At the same time, mobile penetration has risen substantially. According to the CRTC, there were 33.0M mobile subscribers in the first quarter of 2019. There were 35.2M by the first quarter of 2023, an increase of 10%. In addition, people are subscribing to enhanced services packages, using faster mobile data with larger data buckets.

More people choosing to connect, and more people choosing more data, serve as additional indicators of affordability.

That helps to explain why monthly household spending on mobile services has increased from $111.92 in 2019 to $125.33 in 2023. Still, as a percentage of after tax household spending, mobile services have remained constant at 1.8%.

I thought it was interesting to see that household spending on income taxes have increased 38% over the period 2019-2023, nearly double the increase measured by the overall CPI.

This isn’t to say there are no households for whom communications services are unaffordable. There are households that have trouble putting food on the table and staying warm in the winter. At virtually any price point, these households might find communications services unaffordable. As I wrote last November, targeted solutions (including measures to improve digital literacy) are the best approach to address mobile affordability concerns.

I may take a deeper dive into the Survey of Household Spending data through the summer. There is a lot of data embedded in the SHS tables for those who choose to poke around.

In the meantime, be wary of those looking for overall communications prices to come down in the name of “affordability”. Targeted programs remain the best way to address such cases.

A recent paper discusses the use of spectrum set-asides to achieve policy objectives. Its conclusion merits careful review.

In Telecommunications Policy, Bronwyn Howell wrote “Using spectrum set-asides to address distributional objectives: Lessons from Canada, New Zealand, South Africa and the United States”, concluding that Canada’s use of set-asides has raised costs and has failed to foster competition effectively.

The last time I looked at set-asides (in December 2023), I wrote that “ISED got it right” by using spectrum caps (instead of set-asides) as a means to ensure smaller service providers had equitable access to the 3800 MHz band. The average cost per Mhz-pop was $0.29, as contrasted with the 3500 MHz auction held two years earlier with an average cost of $3.28 per MHz-pop. At the time, I noted that the lower spectrum cost meant carriers would be in a better financial position to invest in physical infrastructure.

The Telecom Policy article notes that set-asides “are not economically neutral.” Set-asides distort spectrum auctions by reducing the total spectrum available, creating an artificial scarcity. This has been shown to result in higher auction prices.

In Canada, set-asides have generally been used to help “new-entrant” wireless service providers with market entry. The article also looks at setting aside spectrum rights for “economically disadvantaged communities” in specific geographies to redress economic, social and digital divides.

The rationale is that the spectrum can be used to attract service provision, confer profits from network ownership and upskill individuals in network engineering skills within disadvantaged communities. However, telecommunications network operation requires substantial additional capital as well as spectrum holdings. It is not clear where already financially-disadvantaged communities will raise this additional capital to deploy networks with any spectrum they may own.

Looking at data from examples in the US and New Zealand, the author found “it is not axiomatic that spectrum ownership is necessary for these communities to participate in the digital economy or that spectrum ownership alone will close digital or skills divides.”

Looking at Canada, we read that, despite what might be the best of intentions, Canada’s spectrum set-asides “failed dismally at inducing new competition”.

A 2023 paper by Kent Fellows and Jeffrey Church at University of Calgary looked at Canada’s AWS-1 auction concluding “there was a substantial opportunity cost associated with the set aside of spectrum.” They estimated that the increase in consumer surplus from the auction would have been 6 to 8 times greater, rising from $932M to a range of $5.9B to $8.2B. Further, they believe mobile penetration would have up to a million subscribers higher. Finally, the economists found that “the set-aside policy had a modest impact in reducing quality-adjusted prices, from one to two percent, whereas if the spectrum was allocated to the three incumbents, quality-adjusted prices would have fallen by four to six percent.”

The Telecom Policy article concludes appropriately:

While set-asides can address certain short-term equity concerns or sovereignty goals, realising sustainable gains in connectivity and economic development requires complementary resources — most critically, network capital, skills, and appropriate governance structures. By illuminating these trade-offs and complexities, we aim to inform more nuanced policy-making that balances equity and efficiency in future spectrum policy.

I couldn’t say it better.