Public Safety is leaving the public unsafe

Enough is enough. Once again, we experienced another case of Canadian police forces’ use of the national public alert system.

At 5:58pm Tuesday evening, I received another useless Amber Alert on my phone.

As described by the AlertReady website, some government issuer (in this instance, the Ontario Provincial Police), crafted a message to tell the public that an 11-year old girl was last seen in Stratford and we are to dial 911 or go to amberalert.opp.ca.

More than 6 hours earlier, Stratford Police tweeted far more descriptive information: “last seen around the Rotary Complex. 5′ tall, thin build, black top with Jurassic Park logo, black shorts, black shoes, glasses.”

Why did the Amber Alert message contain so little descriptive information, when clearly, so much more useful information was available?

Thankfully, Stratford Police issued a tweet at 6:26 pm identifying that the girl had been found, safe, apparently in York Region, around 100 miles away.

That explains why the OPP website from the Amber Alert was displaying a banner with “NO ACTIVE ALERTS” when I visited the site around 7:00pm. As I write this, the OPP has not yet cancelled the Amber Alert.

There are clear responsibilities for the issuer of a public alert:

  1. Specifies the type of alert [e.g. amber alert, tornado, etc.] as well as whether it is to be broadcast immediately because of imminent threat to life.
  2. Chooses the content of the message, including which language(s) the message will be issued in.
  3. Chooses the format of the message, including whether the message will be sent as text only, audio only or in both text and audio formats.
  4. Specifies why and when the alert is sent.
  5. Ensures that the alert is updated and/or cancelled.
  6. Specifies the geographical areas covered by the alert.

That York Regional Police were involved in the rescue demonstrates the value of casting a wide net for the geographical coverage of the alert, but we should not accept the lengthy delay between the local police force’s appeal to the public over social media and the OPP issuing an official alert. Above all, the lack of useful descriptive information in the Amber Alert is inexcusable.

For more than 3 years, I have been calling for “formal process to review each use of the National Public Alert System, to help develop best practices”

The AlertReady system is a powerful tool in the hands of Canada’s public safety officials. As I have written before, I don’t question that the system was deployed in this instance. Shouldn’t we continually be examining how the system was deployed, to ensure that it will always be used in the best possible manner?

In April, I described a review of the US system being undertaken by the FCC. I would prefer to see leadership of such a review by Public Safety officials, but it is clear that multiple agencies and multiple levels of government should take interest.

As I have said repeatedly, shouldn’t we continually be examining how the NPAS system is being deployed, to ensure that it will always be used in the best possible manner?

With continued failures in the way imminent threats are being communicated to the public, the safety of Canadians is being threatened.

Ottawa needs to take action to improve the way alerts are being transmitted.

A tale of 2 acquisitions

Last week, two acquisitions in the Canadian telecom sector were met by very different reactions.

The first was Quebecor’s purchase of VMedia, a wholesale-based internet service provider with bundled TV offerings. As described by the Toronto Star, “The deal is part of Quebecor’s push to expand outside its home province”.

The other was Beanfield’s acquisition of Vancouver-Based Urbanfibre. Beanfield operates what it calls the largest independent fibre-optic network in Toronto and Montreal; Urbanfibre is a similar company operating in Vancouver.

About its acquisition of VMedia, Quebecor told the Toronto Star, “VMedia is now one of the key partners that will help accelerate Quebecor’s plan to create greater competition in Canada through advantageous bundles of services, giving Canadian consumers more choices at better prices.” The deal drew a mixed reaction from other internet service providers. According to the Star, the Competitive Network Operators of Canada (CNOC) called the VMedia deal an “exciting possibility” for competition. On the other hand, Teksavvy characterized the deal as “another blow to the market and consumer choice”, referencing Bell’s acquisition of EBOX earlier this year.

Of course, these deals don’t reduce consumer choice. None of the deals could be termed as a ‘fire-sale’ with desperate ownership. In each case, the combined entities will be better funded, and better positioned to offer an expanded array of choices to consumers across a wider geography. As VMedia’s co-founder told the Star “We’re going to be able to provide even better deals for consumers and be even more competitive than the ISP space has been. I think that’s going to bode very well for consumers.”

Economist David Stinson recently wrote:

There are two issues which, in telecom markets, are all too often conflated — i) the number of retail market competitors, and ii) the scope of competition. By “scope of competition”, I mean the proportion of network and service components that are subject to competitive market forces.

In telecom markets, which necessarily involve substantial economies of scale and scope and significant proportions of costs which are insensitive either to traffic or the number of customers or both, the number of socially optimal and sustainable facilities-based providers will be far less than a superficial, Econ-101-based notion of perfect competition would imply.

Consolidation in telecom does not necessarily result in a reduction in competition for consumers. In each of last week’s transactions, consumers will still have access to competitive choice, with a stronger, more sustainable service provider complete with stronger financial capacity to invest.

These acquisitions result in a more competitive marketplace.

That’s good for consumers.

The all-star break

We are a little past the mid-point of the year and this is already the 81st blog post of 2022.

I thought it might be worth a little pause to see which posts have resonated the most so far this year.

  1. Canada ranks 9th for quality, availability & cost of internet, May 30, 2022
  2. Truthiness and Canada’s telecom industry, March 1, 2022
  3. Canada’s 5G future, January 6, 2022
  4. 5G and Canada’s digital economy, January 27, 2022
  5. Combining LEO and 5G for rural broadband, May 31, 2022
  6. Wireless prices falling, February 7, 2022
  7. #ConnectTO: an ill-informed, misguided approach, March 29, 2022
  8. A Kobayashi Maru scenario, April 20, 2022
  9. 4 nearly national mobile competitors, June 20, 2022
  10. Sustainable competition, May 11, 2022

All of the mid-year top-10 posts were actually written in 2022; none are carry-overs from 2021. That means there seems to be active interest in the current topics, compared to archival postings. That is somewhat understandable given the pace of updates on the site (driven in part by the level of activity in policy issues in the telecom sector so far this year).

It is interesting that 5G blog posts were 3 of the top 5 posts by viewership so far in 2022. I think it is also interesting that a post from just 2 months ago is in the top position.

My personal favourites from the list are are Truthiness and Canada’s telecom industry and #ConnectTO: an ill-informed, misguided approach.

Which of these have you forwarded to a friend or colleague?

Telecom market concentration

How concentrated is Canada’s communications market? I guess the answer depends on answering “compared to what”?

If we want to examine how concentrated Canada’s market is compared to other countries, there is a reasonable way to measure that, known as the Hirschman-Herfindahl Index (HHI). To calculate a Herfindahl-Hirschman Index, take the percentage market share of each firm in a sector (measured as a whole number), square that number, and then add all of those squares together. You end up with a number between 1 and 10,000.

If there is one player in the market, with 100% share, the HHI is 100×100 = 10,000. If there are 3 players with say, 40%, 30% and 30% share respectively, then the HHI is calculated as 402 + 302 + 302 = 1600 + 900 + 900 = 3400

As described by the Economist Intelligence Unit, HHI views the concentration of global telecom markets as:

  • HHI < 3,000 “unconcentrated”;
  • HHI 3,000-4,000 “moderately concentrated”;
  • HHI > 4,000 “highly concentrated”

So, let’s look at the question from that perspective. Compared to our peers, how concentrated is Canada’s telecom market? Here is what the Economist Inclusive Internet Index is reporting:

Hirschman-Herfindahl Index
G7 + Selected Comparable Countries
Country Wireless HHI Broadband HHI
Canada 2627 1416
Australia 4006 2724
France 2604 2684
Germany 3378 2704
Italy 2796 2518
Japan 3353 2031
New Zealand 3465 2448
Sweden 2731 1958
South Korea 3538 3003
United Kingdom 2807 2020
United States 3231 1613

As can be seen in this table, Canada’s wireless and wireline communications markets are less concentrated than our international peers. Indeed, of the 100 countries examined this year, the Economist Inclusive Internet Index ranked Canada’s Broadband market as the least concentrated and ranked the Wireless market as the 90th least concentrated.

As I mentioned two weeks ago, a review of the world’s LTE deployments shows that there are 10 LTE networks operating in Canada compared to 9 in the US, 3 or 4 in most European countries (Russia has 9; Sweden has 6; Denmark has 5).

These are important factors when considering network diversity for overall resilience of Canada’s communications infrastructure.

Toward more effective government broadband funding

A recent report from the Vernonburg Group is intended to help various levels of governments develop more effective and comprehensive broadband strategies.

Last month, Boston College law professor Daniel Lyons observed that in 2010, the FCC estimated it would cost $24B to make broadband available to all Americans. Between 2009 and 2017, the US government invested $50B to do just that, but the FCC estimates that 14.5M Americans still lack access/ Under its infrastructure bill, the US is about to spend another $65B on broadband.

As Professor Lyons writes, “it is vital to understand how those earlier billions were spent and why we have not yet closed the digital divide.”

Toward Effective Administration of State and Local Fixed Broadband Programs [pdf, 3.1MB] “is designed to help governments and community-based organizations think holistically about how broadband availability and adoption initiatives can complement and further other public policy priorities.”

The report shows ways to maximize funding impact from various government broadband infrastructure programs, including principles to guide program administrators seeking to increase broadband availability and adoption. The Vernonburg report includes advice on needs analyses, prioritization, goal setting, and evaluations.

Vernonburg Group encourages government administrators to allocate funding based on nine guiding principles:

  1. Prudent Administration and Oversight: Programs should minimize red tape and only impose requirements on recipients that are necessary to achieve the defined objectives of the programs while ensuring their integrity.
  2. Targeted: Any broadband funding mechanism should be designed and limited to addressing known market failures, and should not allow other policy objectives to distract from the primary goal – bridging the digital divide.
  3. Technology Neutral: Broadband funding should be made available on a technology neutral basis. Narrowing the scope of eligible technologies and providers would reduce competition for subsidies and increase program costs.
  4. Broadband Capable: Both current and proposed networks should be required to meet at least the regulatory-defined speed for broadband, both on an advertised and actual basis.
  5. Secure and Resilient: Broadband fund recipients should be required to deploy technologies and implement measures to optimize their critical infrastructure and network resilience and implement best-in-class cybersecurity measures.
  6. Best Value: To minimize costs while aligning on desired and integrated outcomes, funding amounts should be determined through a competitive bidding process, a scoring system that balances project costs and other factors such as service quality or speed of network deployment, or by some combination of the two.
  7. Non-Distortionary: Any program should aim to minimize market distortions in how funds are collected and how they are distributed. Examples of market distortions would be targeting support to places where unsubsidized commercially sustainable networks can be deployed, choosing to fund only one technology solution when equally capable less costly solutions are available, or requiring certain market participants to internally cross subsidize the cost of deploying networks in high-cost and other commercially infeasible areas.
  8. Deployed Quickly: Preference should be given to broadband providers that commit to rapid deployment of broadband networks and services, especially in areas deemed “unserved” or “underserved.”
  9. Digital Equity by Design: Efforts to close the digital divide must account for underlying social and economic inequities. Equal access will not necessarily address inequitable access. Much like other forms of inequality, digital divides continue to disproportionately impact people who are: lower income; located in rural areas; are less educated; lack digital skills; older; and from vulnerable groups such as persons with disabilities and ethnic minorities.

The report includes themes that may sound familiar to my readers.

However, this report notes that achieving universal high-speed internet use by all citizens isn’t just a question of providing faster connections. It also involves making sure people can afford the fixed broadband services made available to them, have devices that enable them to productively work and learn online, and have the skills, comfort, and motivation to navigate and leverage online content and services.

Interestingly, available data shows that the so-called “broadband adoption gap” is far greater than the broadband availability gap. While the availability gap is closing, the adoption gap persists. Non-adoption appears strongly linked to certain demographic variables, such as income, age, disability, education level, rurality, and some ethnic distinctions—factors that state and local governments can effectively address.

The Vernonburg report says “closing the broadband adoption gap may be more challenging for state, municipal, and local governments than closing the broadband availability gap. Even if fixed broadband was made available to the entire U.S. population for little or no cost, state and local governments and their partners would need to overcome demographic and other factors that hinder some citizens from using the internet.”

The findings presented by the report mirror findings emerging from Canadian programs. Adoption isn’t just a matter of overcoming the affordability of broadband services, but also need to address access to devices, and address issues like the “relevance of content, illiteracy, concerns over safety and security of internet use, lack of so-called “digital skills” or knowing how to work devices and apps, lack of trust in private and public low- and no-cost programs, and misunderstandings about such programs.’

The 68-page report is a must-read for those involved in development of government broadband policy.

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