Mark Goldberg

The Canadian Telecom Summit

This is a test. This is only a test has advised there will be another test of Canada’s emergency alert system on May 8.

It would also be a good time for authorities to review how the system has performed since going into service last year.

There have been a number of Amber Alerts issued and public safety officials have correctly credited the system as a significant contributor to a more rapid resolution of the cases.

That doesn’t mean the system can’t be improved. In February, I suggested that perhaps “Canada should have a multi-agency formal process to review each use of the National Public Alert System, to help develop best practices”:

Many commentators have scoffed at consumers who react negatively to the alerts, saying that the life a child is worth being disturbed once in a while. I think we should be considering those criticisms as an opportunity to see if the processes can be improved. Are the alerts being sent to the appropriate geography (wide enough or too wide)? Is the level of information appropriate?

Each time the trigger is pulled to transmit an alert, millions of people are being impacted, and at least one life is in imminent danger. Wouldn’t we want to make sure that alerts are following the best possible practices?

[May 2, 2019] Alert Ready advises that the test scheduled for May 8 will not take place in Ontario and Quebec due to flooding.

On trust and telecommunications

It was said that the late Paul Reichmann (the head of Olympia and York, once the world’s largest real estate development company) would seal deals with a handshake. It was well known that his business partners could trust his word.

Today, business is rarely that simple. We live in a world where lawyers create terms and conditions for ‘clickwrap’ agreements prior to logging into the WiFi network at a local coffee shop with legalese that no one reads and few understand. While I can understand why these agreements came to exist, it seems to me that it is too bad there isn’t more common sense being applied.

In exchange for some web services, we give our personal information and trust it will be somewhat safeguarded, even though it seems the biggest companies in the world have betrayed that trust over and over again. In some cases, private information was compromised by outside attacks on vulnerable systems with naive levels of security measures. In other cases, the corporate culture has been to exploit user information, pushing (or breaking) the limits of what is legally or ethically permitted.

We no longer have business relationships sealed by a simple handshake, with the implicit understanding that both parties will ‘do the right thing’.

At a recent seminar I attended, a speaker from IDC in Herzliya said there are two kinds of databases in the world: those that have been hacked, and those that don’t know they have been hacked. It is a little extreme, but it expresses a message that should raise the level of alertness among consumers and corporations alike.

In this environment, how do we assess levels of trust for suppliers of technology and services? It is easy to let feelings and prejudices get in the way of facts.

Huawei has been under considerable scrutiny for the past year, as Western governments assess levels of comfort with the company supplying 5G network equipment. Huawei has provided Canadian service providers with advanced technologies and helped discipline pricing from other companies. For that reason, a number of Canadian service providers want to keep Huawei among their approved technology suppliers.

I had the opportunity to attend the Huawei Analyst Summit in Shenzhen last week. Huawei’s emergence on the telecom technology scene is a fascinating story, as is the growth of the Shenzhen region. Less than 40 years ago, the area was largely rural and like most of China, poverty stricken and there wasn’t a single phone line in the region. The area is now a booming metropolis, home to 12.5 million people, 40,000 of whom work on the Huawei headquarters campus. In just over 30 years, Huawei grew from a 6-person reseller of Mitel telecom gear, to become the world’s largest supplier of telecommunications equipment, with revenues exceeding US$100B.

At the Huawei Analyst Summit, participants were told one third of the world’s mobile traffic is carried on Huawei gear; the company supplies 400 LTE networks around the world, covering 140 national capitals. Huawei has contracts for more than 40 5G networks with 70,000 sites operational.

In Canada, Huawei has a significant presence, including more than 1100 employees and about $200M per year in R&D spending. The company is in the process of increasing its Canadian workforce with 200 additional people expected to join its Canadian research centres. Huawei has been encouraging companies and countries to take a closer look at its software development processes and Huawei has built cyber security transparency centres in a number of countries to facilitate such scrutiny; a transparency centre in Germany was opened just a month ago. The United States is no longer demanding that Huawei be banned from Germany; it had previously threatened to limit sharing of intelligence with Germany unless Huawei was excluded from the country’s 5G networks. CNET reports “Senior US officials are ‘highly satisfied’ with Germany’s regulations setting strict 5G security standards.”

Speaking last week at the Huawei Analyst Summit about cyber security concerns, Huawei’s rotating Chairman, Ken Hu warned, “If an issue is politicized, the discussion will be moved away from facts and onto feelings.” He is right. The issue is too important to let politics get in the way of good policy, to allow old prejudices to cloud a dispassionate assessment.

Canada needs to carefully explore the measures taken by Germany and other allies that can provide assurance to national (and international) intelligence and security agencies to confirm our networks are safeguarded.

Perhaps the next Huawei Cyber Security Transparency Centre should be located in Ottawa.

Minister Bains to deliver closing keynote address at #CTS19

The 2019 Canadian Telecom Summit, taking place June 3 – 5 in Toronto, is pleased to announce that The Honourable Navdeep Bains, Canada’s Minister of Innovation, Science and Economic Development, will deliver the closing keynote address on June 5.

He joins 60 industry leaders speaking at Canada’s most important gathering of the information and communications technology industry. These senior executives and thought influencers will share their big-picture visions of where we are and where we are headed.

What role will they play in shaping how Canadian information and communications technology and services transform our business and personal lives?

You will have a chance to ask questions, share your thoughts and engage in give-and-take with our speakers and the other attendees. The 2019 Canadian Telecom Summit is all about:

  • Networking and Learning;
  • Forming Relationships and Exchanging Views;
  • Challenging and Listening.

All of this and more is what makes The 2019 Canadian Telecom Summit the must-attend event of the year.

Service providers, equipment & solutions vendors, application providers, professional services organizations, end-users, financial analysts, government and investors. All will be present at The 2019 Canadian Telecom Summit.

And so should you!

Register today for The 2019 Canadian Telecom Summit.

Canada’s 600 MHz auction concludes

Last night, Innovation Minister Bains released the results of Canada’s auction of spectrum in the 600 MHz band. The government released seven paired blocks of 5+5 MHz, 3 pairs of which were set-aside for facilities-based service providers that were not already operating nationally.

600 MHz Licence Winners
Licence Winners # of Licences Won Final Price ($) Total Population Covered $/MHzPop
Bragg 4 13,046,000 1,812,066 $0.360
Freedom 11 491,977,000 21,764,443 $0.783
Iris 7 2,556,000 633,747 $0.342
Rogers 52 1,725,006,000 35,150,715 $1.709
SaskTel 3 12,168,000 1,094,705 $0.371
TBayTel 1 2,802,000 778,449 $0.360
TELUS 12 931,238,000 19,844,765 $2.346
Vidéotron 10 255,780,000 10,225,169 $0.991
Xplornet 4 35,755,000 3,610,258 $0.990

Source: ISED and calculations by Mark H Goldberg & Associates, Inc.

You can find more coverage on the results of the auction on other sites, such as, but I look to look at these kinds of things from a different angle. All together, the government raised $3.47B which works out to roughly $100 per person in Canada. Scotiabank observed that this was about $600M more than it expected.

Bell did not end up with spectrum from this auction. In its post-auction comments to the media, Bell claimed that it has sufficient sub-gigahertz spectrum, and given that it is shutting down its old CDMA network, there is certainly spectrum available for re-purposing. quotes Bell’s CTO Stephen Howe saying “Bell looks forward to participating in upcoming federal auctions of the mid band 3500 MHz and high band millimetre wave spectrum that will be required to drive the Fifth Generation of wireless.” This raises an important consideration: antenna sizes, which are proportionate to the wavelengths of the radio spectrum. The wavelength for 600 MHz spectrum is half a meter, 50 cm; the wavelength for 3500 MHz spectrum is about one-sixth that, or 8.5 cm. With the expected increased density of towers needed for 5G, to what extent is antenna size a factor in spectrum deployment?

As I observed last night on Twitter, and as I show in the table above, there is quite a range of prices paid per MHz Pop (calculated by looking at the total price paid divided by the amount of spectrum times the population covered in each license). The opening bid price varied by region (from 13 cents in the far north to 80 cents in more densely populated Southern Ontario and Southern Quebec), but in many cases, the set-aside spectrum was sold for the opening bid price.

Two blocks of set-aside spectrum went unsold in Manitoba and in Northern Ontario, as did one block in each of Newfoundland & Labrador, Yukon, Nunavut, and the Northwest Territories. Xplornet paid about 3 times the opening bid price for its set-aside spectrum, even though its licenses are in regions where the rest of the set-aside spectrum was unsold, or was sold at what appears to be the opening bid level.

How will the auction impact pricing and the level of competition among wireless service providers? What differentiators will emerge? How will the policy makers measure success as an outcome from the sales process? Will any changes be contemplated for the next wave of spectrum to be put up for auction?

Regulating speech

The internet has long been hailed as a means for democratizing the expression of opinions. Everyone has the ability to express themselves on Twitter, on Facebook, on blogs, or in countless chat rooms.

No longer constrained by the availability of a Speaker’s Corner in a public square, on the internet, marginalized voices aren’t subjected to the discretion of a publisher seeking to conserve valuable column inches of newsprint, or limited minutes of airtime. On the internet, you are limited only by the ability to attract eyeballs interested in your perspectives.

And that creates a problem.

In order to attract an audience, people game various systems to improve positioning on search engines, or pay to ‘promote’ their posts on a variety of social media platforms. Because promoter capabilities are seen to be a software feature by the platforms (and not a bug), bad actors have been able to use these tools to spread misinformation. Many subscribers have been unable to differentiate between trusted sources of information and some commentators have charged that this influenced the results of the 2016 elections in the United States.

As a result, democracies around the world are turning their minds to the issue of regulating the kinds of communications being expressed on the internet. Earlier this week, the UK government issued its Online Harms White Paper.

In the wrong hands the internet can be used to spread terrorist and other illegal or harmful content, undermine civil discourse, and abuse or bully other people. Online harms are widespread and can have serious consequences.

This White Paper therefore puts forward ambitious plans for a new system of accountability and oversight for tech companies, moving far beyond self-regulation. A new regulatory framework for online safety will make clear companies’ responsibilities to keep UK users, particularly children, safer online with the most robust action to counter illegal content and activity.

The UK plan envisions an independent regulator to set safety standards and reporting requirements and armed with enforcement powers.

The UK White Paper has a section on The Duty of Care:

7.4 As indication of their compliance with their overarching duty of care to keep users safe, we envisage that, where relevant, companies in scope will:

  • Ensure their relevant terms and conditions meet standards set by the regulator and reflect the codes of practice as appropriate.
  • Enforce their own relevant terms and conditions effectively and consistently.
  • Prevent known terrorist or CSEA content being made available to users.
  • Take prompt, transparent and effective action following user reporting.
  • Support law enforcement investigations to bring criminals who break the law online to justice.
  • Direct users who have suffered harm to support.
  • Regularly review their efforts in tackling harm and adapt their internal processes to drive continuous improvement.

7.5 To help achieve these outcomes, we expect the regulator to develop codes of practice that set out:

  • Steps to ensure products and services are safe by design.
  • Guidance about how to ensure terms of use are adequate and are understood by users when they sign up to use the service.
  • Measures to ensure that reporting processes and processes for moderating content and activity are transparent and effective.
  • Steps to ensure harmful content or activity is dealt with rapidly.
  • Processes that allow users to appeal the removal of content or other responses, in order to protect users’ rights online.
  • Steps to ensure that users who have experienced harm are directed to, and receive, adequate support.
  • Steps to monitor, evaluate and improve the effectiveness of their processes.

It is clear that not all illegal content on the internet can be policed using conventional methods. For example, how can we deal with content that hosted in another country that violates our laws?

In its White Paper, the UK is consulting on the need to have some extraordinary tools to deal with the global nature of communications and the “particularly serious nature of some of the harms”.

  • Disruption of business activities. In the event of extremely serious breaches, such as a company failing to take action to stop terrorist use of their services, it may be appropriate to force third party companies to withdraw any service they provide that directly or indirectly facilitates access to the services of the first company, such as search results, app stores, or links on social media posts. These measures would need to be compatible with the European Convention on Human Rights.
  • ISP blocking. Internet Service Provider (ISP) blocking of non-compliant websites or apps – essentially blocking companies’ platforms from being accessible in the UK – could be an enforcement option of last resort. This option would only be considered where a company has committed serious, repeated and egregious violations of the outcome requirements for illegal harms, failing to maintain basic standards after repeated warnings and notices of improvement. Deploying such an option would be a decision for the independent regulator alone. While we recognise that this would have technical limitations, it could have sufficient impact to act as a powerful deterrent. The British Board of Film Classification (BBFC) will have this power to address non-compliance when the requirements for age verification on online pornography sites come into force. We are exploring a range of options in this space, from a requirement on ISPs to block websites or apps following notification by the regulator, through to the regulator issuing a list of companies that have committed serious, repeated and egregious violations, which ISPs could choose to block on a voluntary basis.
  • Senior management liability. We are exploring possible options to create new liability for individual senior managers. This would mean certain individuals would be held personally accountable in the event of a major breach of the statutory duty of care. This could involve personal liability for civil fines, or could even extend to criminal liability. In financial services, the introduction of the Senior Managers & Certification Regime has driven a culture change in risk management in the sector. Another recent example of government action is establishing corporate offences of failure to prevent the criminal facilitation of tax evasion. Recent changes to the Privacy and Electronic Communications Regulations (PECR) provide powers to assign liability to a specific person or position within an organisation. However, this is as yet largely untested. There are a range of options for how this could be applied to companies in scope of the online harms framework, and a number of challenges, such as identifying which roles should be prescribed and whether this can be proportionate for small companies.

The UK White Paper is roughly 100 pages setting out a “vision for online safety, including a new regulatory framework to tackle a broad range of harms”. It appears to be applying serious thought to a serious issue.

There are significant policy issues to be explored. It is difficult to imagine how Canada could conduct a consultation and have a regime in place prior to the next federal election.

Canada’s Minister of Democratic Institutions has been socializing plans for “Safeguarding our Elections” and earlier this week warned “The world’s major social media companies are not doing enough to help Canada combat potential foreign meddling in this October’s elections and the government might have to regulate them”.

Shortly afterwards, Facebook banned a number of Canadian accounts, including one belonging to a former candidate for mayor of Toronto.

If the content of these pages cross the line that defines illegal content, then it is understandable why the pages should be banned.

But what if the content is merely offensive, without being illegal? How do we ensure that actions to block content are consistent with Canada’s Charter of Rights and Freedoms, which guarantees everyone’s “freedom of thought, belief, opinion and expression, including freedom of the press and other media of communication”?