Mark Goldberg

Fox Group Dispatch

Relaxing the Wireless Code

Do we need to limit the amortization period for devices in the Wireless Code? The subject was raised by Bell in its intervention on Telecom Notice of Consultation CRTC 2017-259 [Reconsideration of WiFi Roaming]:

Instead of mandating access for Wi-Fi-first mobile virtual network operators (MVNOs), a far more effective measure to address the affordability concerns of low- and middle-income Canadians would be for the Commission to extend the maximum contract length under the Wireless Code from two years to four years, allowing Canadians who wish to do so to reduce the upfront cost of a wireless device with less of an impact on their monthly bill.

We can argue all you want about whether this proceeding was the right place to introduce the subject, but the fact remains that the Wireless Code has raised consumer costs significantly by virtue of the simple mathematics of amortization. Amortizing a device over 2 years instead of 3 means monthly payments are 50% higher. Last year I wrote about a number of regulatory factors that increase consumer bills.

Now Apple has introduced the iPhone X with a Canadian price point in the order of $1300 [the 256 GB version will sell for an additional $220]. Most Canadian phone subsidies have been in the order of $35 per month, which results in $840 over two years. That implies an up-front price of about $450 for consumers. That could lead to more sticker shock than anyone would want to see, inhibiting adoption of these new high-end devices. Alternatively, carriers may raise the subsidy by $15 per month to $50 per month to enable a more reasonable $100 down-payment.

What purpose is actually served by limiting device amortization to 2 years?

Customers can still switch at will anytime during the contract period. They just have to pay off the balance owing. With higher device costs, people have hefty balances owing anyway, whether it is a two or three year contract.

Eliminating the regulatory restriction on longer contracts could lead to carriers offering direct consumer incentives to switch: “Come to us and we will pay up to $600 of your remaining balance.”

Once the Commission allowed consumers the right to leave a carrier by simply paying off the remaining balance, what purpose is served by the further regulation of how long the amortization period could be?

Perhaps more faith could be placed in the marketplace to create more competitive offers. In the alternative, Canadians may find the price of new devices is just too high.

Playing the back nine

Another milestone birthday this past weekend provides an opportunity (and an excuse) to reflect. Jewish tradition wishes upon us a long life, until 120, the age Moses was said to have died. In his case, it was said that his vision not dimmed “nor his natural force abated.” [Deuteronomy 34:7] I should be so lucky. I have been working in the telecommunications industry for more than 37 years now, and I don’t think my “natural force” has abated.

If I do make it to 120, then as of today, I’ve made it to the turn, moving now to start playing the back 9. I will take the opportunity to wax somewhat philosophically in today’s post.

I get a great feeling of satisfaction when I think about some of the people with whom I have worked, people who mentored me and those who I have mentored. I was greatly influenced in my management style by my first boss at Bell Labs, Dick Grantges, who was said to have caused concern because of his supervisory style: “Dick’s people seem to get their work done, but they always look like they are having too much fun.” When he showed me around the Holmdel Labs for the first time, he paused as we reached a spot that overlooked the reflecting ponds at the front of the building. As I have written before, “he sighed and said that one of the things he liked best about working at Bell Labs is that if you get your best ideas while gazing out the windows, then we’ll pay you to stare at geese.”

Dave Hagan, who is now CEO at Boingo, had a similar perspective when we worked together at Sprint Canada. He would say that it shouldn’t be called “going to work”; we should be “going to fun.”

Whatever you choose to do with your life, find something that you enjoy doing and hopefully do it with other people who are also enjoying doing it with you.

I have learned that not every voice on Twitter deserves a reply. I don’t have to engage with everyone. Some people are beyond my skill set to help. To paraphrase Dr. McCoy from Star Trek: I am a telecommunications professional, not a proctologist.

I am really proud of the accomplishments of many of the people who I have had work with me, many of whom still hold senior leadership positions in the industry around the world. We have made some significant and lasting impacts on the telecommunications sector. As I wrote in June, we still stay in touch, though not frequently enough.

More than anything, I have been blessed with a wonderful family, inspired by my parents and supported by my wife of more than 36 years. My kids, and my grandkids, have always taken precedence over my career. Fortunately, most of the time when I was in a corporate environment, I had bosses who shared my priorities. There are countless examples, including one of my favourite moments from a little over 25 years ago. Preparing for CRTC hearings was a stressful and intense time: in the olden days, witnesses were sworn in (or affirmed) and opposing parties had an opportunity to cross-examine. Just before the Long Distance hearings opened in 1991, we were preparing in Ottawa with our law team. My daughter’s birthday was during the week before the hearings opened and her teacher had planned a special celebration. I flew back to Toronto for a couple hours, kept a cab waiting at the school to rush me back to the airport so we could continue the hearing preparations – flying was a lot easier then. The teacher went over to my wife and said “it is so nice that your husband has the kind of job that allows him to get away for a few minutes.” I hope that my kids are as fortunate.

Last October, I wrote about reflecting on my back pages, looking back on the earlier days of my career, working on national security network architectures, ending communications monopolies. Those were heady times when I was half as old as I am today. I may have added another year, but as Bob Dylan wrote, I still like to think that I was so much older then, I’m younger than that now.

My eyes may be slightly dimmed, but having spent the past month in the company of my 3 year old and 10 month old grandkids, I can attest that my natural force is still strong.

From the time I was very young, I remember my dad teaching us that what ever you do, always aim to be the very best. He would remind us that Louis B. Mayer, the founder of MGM Studios, was a junk dealer in my dad’s home town of Saint John, NB.

So my advice to my kids and grandkids can be summed up best as: find a career doing something you love doing; aim to be the best at what you do; find people who share your values to do it with; and, remember that family should always come first.

I think I still have plenty of natural force left in me, so I am ready to start playing the back nine. Let’s tee it up and have some more fun.

Resilient, robust public safety networks

Hurricane Harvey has triggered some discussion about the best way to configure public safety broadband networks.

An article by Jon Brodkin in Ars Technica observed that “Tropical Storm Harvey takes out 911 centers, cell towers, and cable networks“, triggering tweets that suggested that this proves that public safety broadband networks must be built to a higher reliability standard than those for commercial networks.

I am not as convinced that Hurricane Harvey proves the need to build a stand alone public safety network engineered to different reliability standards. Not only were some 9-1-1 centers knocked out by the storm, as the Ars Technica article described, but first response systems were also disabled:

The cause was visible across the county: Tall structures, trees and signs were folded with ease by the 130-mile-per-hour winds that enclosed the eye of the storm.

That included the signal tower outside the centrally located Rockport Police Department.

Emergency radio channels were unavailable, and first responders were limited to “shortwave radios that span only a couple miles,” said Matt Jamison, a volunteer firefighter from Fulton.

“There’s a lot of people using that one channel, and it’s not really effective when you’re trying to do a large-scale search-and-rescue (operation),” Jamison said.

Comedian Ron White sums it up nicely when he describes the experience of trying to survive hurricane force winds. It isn’t THAT the wind is blowing 130 MPH; it is WHAT the wind is blowing.

With a back-to-school theme in mind, there are three R’s to keep in mind as we architect a national public safety network solution: resilience, robustness and reliability.

Can we realistically expect a new private public safety network to be more resilient, more robust, more reliable or for that matter, more ubiquitous than having access to multiple public commercial networks? Would first response applications achieve greater reliability by having the ability to simultaneously connect to diverse networks operating on different towers and across different frequency bands?

There are lessons to be learned from Hurricane Harvey for communications networks professionals. The answer to increased network reliability might be found in smarter, multi-carrier user equipment.

Pencils? Books? Computer? Broadband?

Today marks the beginning of another school year. Across Canada, millions of kids are preparing to meet new teachers, telling stories about what this did this past summer.

Many are wearing new outfits and are carrying new backpacks filled with the supplies they bought at “back-to-school” sales over the past couple of weeks. Some basic school supplies haven’t changed for generations. Do kids still buy protractors and compasses along with their pencils, pens and loose-leaf paper?

Cutting and pasting weren’t always done digitally. Are we past the days of collecting old magazines to carefully cut out pictures and paste them into school projects? I wonder if kids in today’s elementary school generation know where the computer terms “cut” and “paste” come from.

Incidentally, Duo-Tang, the original manufacturer of the report cover of choice for generations, was bought out nearly 15 years ago. Sure, those Duo-Tangs were theoretically reusable, but who among us didn’t want to submit our projects with a brand new cover? Each of us had our own style for folding the tangs. Who folded the tangs together? Who split them? Anyone alternate the direction of the three sets of tangs? Kids: if you don’t know what I am talking about, ask your parents.

Most Canadian school-aged kids have a computer at home to connect with their friends and their teachers, using online tools to get their assignments and submit them for assessment and evaluation. What about students who still don’t have a computer at home, let alone a broadband connection? How are they able to keep up with their schoolmates? It isn’t enough for them to have access to computers in public libraries and in a room at school; kids do homework at home. How can we expect them to succeed in today’s digitally enhanced education system?

TELUS [Internet for Good] and Rogers [Connected for Success] have bold corporate initiatives to target certain households in their wireline operating territories with affordable broadband programs. But despite these great programs, there are hundreds of thousands of homes outside their areas. To date, no cable company or phone company has stepped up with a targeted affordable broadband product for residents of Saskatchewan, Manitoba, Quebec, Nova Scotia, or PEI. Government programs have typically subsidized the supply of broadband based on geography, without looking at stimulating demand with subsidies looking at financial means.

Another school year is underway. Another opportunity for a fresh look.

Watch out for kids as you drive to work. When you get to the office, whether it is government or private sector, see how you can help get connected computers into every household with school-aged kids.

Reductio ad absurdum

Reductio ad absurdum [NOUN]: a method of proving the falsity of a premise by showing that its logical consequence is absurd or contradictory.

Consider this tweet for a moment:

The “toothless #CRTC Net Neutrality decision” to which this refers is Telecom Regulatory Policy CRTC 2017-104: Framework for assessing the differential pricing practices of Internet service providers, issued this past April.

One might challenge so many different parts of this tweet. For example, is the Know Roaming service even captured by the decision? While Know Roaming sells its service to Canadians, the service is for use when travelling outside the country.

More importantly, the tweet demonstrates the absurdity of a prohibition on zero rating. How is the public interest possibly served? What benefit can there be in denying consumers access to free WhatsApp when they travel? Where is the market power of a small niche provider like Know Roaming? Why would so-called “consumer advocates” continue to argue that a regulator should take away benefits from consumers who choose to shop around for alternative services?

Roslyn Layton recently released a paper summarizing her doctoral research project at the Center for Communication, Media, and Information Technologies at Aalborg University in Copenhagen, “Does Net Neutrality Spur Internet Innovation?

Spoiler alert: no, it doesn’t.

As new leadership comes to the CRTC, will the Commission add the net neutrality framework to the growing list of decisions it needs to review?