Mark Goldberg


www.mhgoldberg.com





Brave new world

Although it has been percolating for a few months already, the past week or so has seen dramatic changes in our lifestyles due to the impact of the COVID-19 virus.

Many of us are now working from home, practicing ‘social distancing’ with the hope that we can slow the spread of the disease, smoothing the curve to try to avoid overwhelming our healthcare systems. Schools are closed; businesses have asked employees to work from home where possible; entertainment venues have suspended operations; where bars and restaurants are still operating, medical officers of health are asking people to choose take-out.

Canadian telecom service providers have responded, removing data overage charges from residential internet service plans, and in many cases waiving mobile roaming fees for people caught in global hot spots. Some TV providers have opened up free access to additional channels to help keep kids entertained, or providing access to subscription news channels. Most have also promised flexible payment options, recognizing the financial difficulties that may arise as a result of job interruptions.

A number of years ago, I wrote “4 degrees of impersonal communications”, describing a paradox in that “we seem to take more care in communications when the conversation can most easily be private and candid. Conversely, we pay less attention to etiquette and courtesy when the audience is global and of diuturnal impact.”

Face-to-face communications (a first degree interaction) has no record, no evidence beyond the memory of the participants. Telephony (second degree) may have a record, such as an audio voice message. Email (3rd degree) gets circulated, over and over. Thanks to search engines and web-archiving tools, the web (4th degree) offers a permanent record.

For the next little while, our ‘first-degree’ interactions will be limited. As we use other forms of communications, let’s hope we can try to emulate more of the courtesy that comes to us more naturally when speaking face-to-face.

Please make a point of contacting people who may be isolated at home; you never know how important it can be to provide a virtual embrace for people facing a changing future.

And when you venture out to the store, or interact with someone who has a job that keeps them working on the front lines (including first responders, check-out clerks, pharmacy workers and the folks maintaining our communications systems), be sure to offer a genuine smile and ‘thank-you’.

Those little acts of courtesy, of humanity, can go a long way.

Stay safe. Stay healthy.

Are Canada’s networks ready for work from home?

With the COVID-19 pandemic leading more Canadians to work from home, some people are asking if this will put too much stress on the networks or on consumer service plans.

The good news is that Canada’s networks are ready for working from home, even with kids streaming videos while home for March break or closed schools, and very few types of work should put undue strain on typical residential subscriptions.

Popular Science recently published “Here’s how much internet bandwidth you actually need to work from home” which provided the types of bandwidth needed by many of the more popular business conferencing services.

Bandwidth requirements for video-chat applications
Zoom
Screens Up Down
Single Screen 2.0 Mbps 2.0 Mbps
Dual Screen 2.0 Mbps 4.0 Mbps
Triple Screen 2.0 Mbps 6.0 Mbps
Screen Sharing Only 150-300 kbps 150-300 kbps
Audio Only 60-80 kbps 60-80 kbps
Google Hangouts
Use Up Down
Minimum Requirements 300 kbps 300 kbps
Two-person Video Calls 3.2 Mbps 2.6 Mbps
Group Video Calls 3.2 Mbps 3.2-4.0 Mbps
Skype
Type of Call Up Down
Voice Call 100 kbps 200 kbps
Video Call (2 participants) 600 kbps 600 kbps
Video Call (3 participants) 600 kbps 2.0 Mbps
Video Call (5+ participants) 600 kbps 4.0 Mbps

Contrast these relatively low speed requirements to Netflix, which Popular Science says needs 25 Mbps for its highest quality content, or 3 Mbps for its standard definition streams.

We know that the greatest consumption of residential internet bandwidth is high definition streaming video. Very few work-at-home applications would come close; hardly any would involve sustained levels of streaming data that rival delivery of 4K video streams.

According to the CRTC’s Communications Monitoring Report, in 2018 (almost a year and a half ago), more than half of Canadian home had already subscribed to residential internet packages with more than 50 Mbps download speeds. The average residential download speed in 2018 was 126 Mbps, double the speeds experienced in the United States. A third of Canadian households subscribed to speeds faster than 100 Mbps.

According to the CRTC, “The average amount of data downloaded by residential Internet service subscribers increased by 25.4% between 2017 and 2018 to 192.9 GB per month, and by an average of 30.5% annually from 2014 to 2018.”

As temperatures begin to reflect the annual Spring thaw, it marks the beginning of outside plant construction season for wireline and wireless carriers in Canada seeking to invest in capacity upgrades and service expansion to underserved regions.

The government is launching a billion dollar economic assistance package, “to help Canadians cope with the COVID-19 outbreak, with half of the money going to the provinces and territories.”

I mused yesterday on Twitter

A number of regulatory and federal policy actions over the past year have contributed to a “hostile political environment” that inhibits private sector investment.

How much more broadband and wireless investment could be taking place?

Mobile service is safe and saves lives

The CRTC’s Mobile Wireless Review hearing wrapped up a couple weeks ago with appearances from the fringe, groups expressing concerns about mobile safety.

I addressed these issues on this blog 7 or 8 years ago, but it seems nearly impossible to halt the circulation of junk science, based on flawed studies, promoted by modern day snake oil salesmen and amplified across social media channels.

Let’s look at the facts. The groups like to claim that mobile wireless safety standards are outdated. That simply isn’t true. The Food and Drug Administration (FDA) in the US has recently published its most recent review of the scientific evidence, concluding “there is no consistent or credible scientific evidence of health problems caused by the exposure to radio frequency energy emitted by cell phones”.

The FDA is very clear in repudiating the oft-cited 2018 National Toxicology Program (NTP) Studies on High Dose Radio Frequency Radiation – sometimes called “The Rat Study”. Those experiments were conducted with high levels of radio frequency radiation over the bodies of experimental rodents. The radio frequency energy was delivered in intervals of 10 minutes on and 10 minutes off for 18 hours and 20 minutes, every day for 2 years. “The conclusions relating to public health risks reached by the FDA’s scientists differ from those of the NTP, and the FDA determination is that the study did not demonstrate that cell phones cause cancer.”

5 Facts About the Rat Study

  1. Rats received radiation over their entire bodies.
  2. Rats received this whole-body radiation for 9 hours per day for their entire lives.
  3. Rats received levels of radiation that were up to 75 times higher than the whole-body exposure limit for people.
  4. The study found no health effects on female rats or mice (both male and female) exposed to these extreme conditions that passed a test for statistical significance.
  5. Exposed rats lived longer than the control group rats.

Many cite the IARC classification of electromagnetic frequency radiation as a ‘Class 2B’ possible carcinogen, without a proper understanding of what these categories mean. The FDA clarifies that this “is an indication that more research is probably justified.” As the BBC recently observed, “That puts it in the same category as pickled vegetables or talcum powder but not as dangerous as alcohol or processed meat.”

The FDA said:

The 2013 IARC classification was based on limited evidence in humans which were from a few case-control epidemiological studies.

The IARC committee acknowledged that those studies were susceptible to certain limitations such as recall errors by the participants and the selection criteria for participation.

The FDA emphasizes “Time trends in cancer of the brain have not shown evidence of a trend that would indicate a promptly acting and powerful carcinogenic effect of mobile-phone use.”

Recently, people have raised the spectre of 5G as a new threat. The FDA says “5G cell phones will use frequencies covered by the current FCC exposure guidelines (300 kHz-100 GHz), and the conclusions reached based on the current body of scientific evidence covers these frequencies.” It is also worth noting that BBC recently reported that the UK regulator, Ofcom, found radiation levels at “tiny fractions” of safe limits in its first UK safety tests of 5G base stations. “The highest result they found for the 5G band was 0.039% of the recommended exposure limit.” Let’s clarify that number. That means exposure would need to be more than 2500 times stronger than the highest level observed, before it even begins to approach the safety limits.

Our federal agencies are aware of the public concerns and are monitoring the scientific evidence. Once again, it is important to keep in mind, mobile services are safe. Indeed, as I have written before, “Cell phones save lives”.

Moving the goalposts

Despite mobile industry prices that have fallen more than 30% over the course of the past summer, Innovation, Science and Industry Minister Navdeep Bains is looking for further reductions of another 25%, warning “If these targets are not met within two years, the Government will take action with other regulatory tools to further increase competition and help reduce prices.”

During last year’s election campaign, the Liberal party promised 25% reductions in mobile prices and it showed sample rate plans of $87.32 for a 5 GB plan and $75.44 for a 2 GB plan. The party promised to bring those rates down to $65.49 and $56.58 (respectively), when elected.

But in an announcement today, Minister Bains said that the January 2020 market prices for a 6 GB plan are $60, and $50 for a 2 GB plan, more than 10% lower than the campaign targets.

Rather than claiming victory, the Minister has announced new targets of a further 25% price reduction over the next two years. The Minister has set a target of $37.50 for the 2 GB mobile plan, more than 50% reduction in the price, when compared to the Liberal’s campaign promise.

In a note to investors earlier in the day, TD Securities Equity Research wrote: “our view is that much of the testimony at the [CRTC’s Wireless Review] hearing proved that pricing in Canada is very reasonable relative to excess geographic and spectrum costs incurred by wireless carriers in Canada. Subsequent to heavy efforts by the government to facilitate competitive tension from facilities-based new entrants in every region, we struggle to see a problem that needs to be fixed.”

We agree. The CRTC is in the midst of its review of mobile services. The intervention in the marketplace smacks of playing a populist political card at the expense of policy leadership.

With billions of dollars in funding needed for 5G network upgrades, rural expansion and targeted connectivity programs for low income households, global capital markets will be looking for more consistency from Canada’s regulatory and policy leaders.

In an environment of already turbulent global capital markets, the last thing Canada should be doing is playing Calvinball with its telecom sector.

Declare victory. Consumers are winning

Mobile prices have fallen more than 25% over the past year, according to Innovation, Science and Economic Development Canada’s “2019 Price Comparisons of Wireline, Wireless and Internet Services in Canada and with Foreign Jurisdictions” [pdf, 2.1MB], the 12th annual edition of the report.

The report is dated November 7, 2019, which means the work product has been sitting around for 4 months, waiting for today’s disclosure. The information gathered in the main body of the report was known to be stale even before it was completed. The study gathered its main pricing information in May 2019, a month before what the report calls “the relatively recent introduction of significantly modified mobile plans … Some of the market changes are greater standardization of national MNO pricing across the country as well as the offering of higher end data caps at reduced prices.” That statement appears to contradict observations that prices are lower in provinces with ‘strong regional competitors’, in evidence presented by the Competition Bureau at the CRTC’s Wireless Review.

The prices changed substantially, the plan structures changed substantially, and prices were seen to be more consistent across the country. But, rather than redo the study in its entirety, all that was done was add a ‘spotlight’ section to provide highlights of the impact of the updated rates. Moreover, according to the study authors, “foreign jurisdiction price data was primarily collected in June/July 2019”, meaning the study authors were still in the process of collecting data when the new Canadian rate plans were in the market.

Policy statements are being made based on outdated data. Regulatory measures are being contemplated based on detailed data collection that was stale before the report was written. In 2018, Canadian mobile services revenues were more than $27B. How much would it have cost to get the data right by updating the Canadian pricing data? This fundamental error in judgment is especially troubling since the already outdated report sat unreleased on a desk for a further 4 months. [Note: alleged flaws in the methodology used in the annual pricing study are described in detail in evidence filed by NERA in the CRTC’s Review of Mobile Services.]

Earlier this week, I wrote about the much more sophisticated pricing study conducted for the CTIA that used regression analysis that “considers differences in plan characteristics, network qualities, and country attributes, allowing the authors to compare value propositions, and not just a superficial price comparison.”

The CTIA study looked at the ISED methodology and observed that its comparisons are based on “six artificial demand baskets”. “Moreover, depending on how similar or dissimilar the plans are in each basket, the study reports drastic and incredible price fluctuations from year to year.” In the view of the authors of the CTIA study, “Because the baskets lack an empirical foundation, this results in a price comparison of drastically different plans that produces meaningless results.”

Extreme caution should be exercised in interpreting the data in this year’s report released by ISED. A few years ago, the study acknowledged its limitations.

Despite the current report missing the important “caveats” section acknowledging the study limitations, let’s take a closer look and carefully consider the cautions that were disclosed in the 2016 edition of the study.

  • The price comparisons are based on price data collected through a survey conducted in January and February of this year. As prices for telecommunications services are constantly evolving, the prices cited in this Study represent a ‘snapshot’ of prices in time. Also, the price differentials found are highly sensitive to currency fluctuations.

    Any study is naturally a snapshot in time. We know that the market is dynamic by virtue of regular articles like Mobile Syrup’s “Here are the changes to Canadian carrier rate plans this week”. Multiply those changes by the other countries in the study and add in currency fluctuations and you have a significant challenge.

  • Thus, the prices cited for Canada, US or the international jurisdictions are not meant to be statistically representative of the individual countries as a whole.

    Will this limitation be considered in the reporting on this study?

  • Prices in Canada and international jurisdictions are driven by a complex mix of a number of factors: cost of service, competitive positioning, technological advances, consumer behaviour and regulatory frameworks.

    The study conducted for CTIA was designed to account for many of these variables that are key to the value proposition placed in front of consumers. It found Canada beat the countries used by ISED when accounting for such factors.

  • As wireless technology is constantly improving and consumers demand ever more bandwidth and data caps, service providers are constantly increasing features. In the Study, these changes are reflected by the need to regularly update the definition of service baskets. Hence, price increases in those baskets may in part, simply reflect better service levels offered to consumers.” [emphasis added]

    Will this limitation be considered in the reporting on this year’s study?

  • This Study did not take into account the network technologies deployed in the networks nor the speed or quality of service of those networks. Finally, this Study did not account for any cost of service or socio-economic factors that may be relevant for price differences across different domestic and international jurisdictions.

    The study conducted for CTIA was designed to account for many of these variables that are key to the value proposition placed in front of consumers. It found Canada beat the countries used by ISED when accounting for such factors.

  • factors such as population density, terrain and climate have significant impacts on the cost of service.

    The study conducted for CTIA was designed to account for many of these variables that are key to the value proposition placed in front of consumers. It found Canada beat the countries used by ISED when accounting for such factors.

  • socio-economic factors such as affordability indicators (i.e. mobile prices in relation to disposable income), number of handsets per subscriber, number of minutes of usage per subscriber and other factors were not within the scope of this Study.

    Last month, I reported on an independent study on mobile service affordability, with PwC’s examination of the claim that “household budgets were being strained by spending on mobile plans”. Other attributes associated with the consumer value proposition are accounted for in the CTIA study methodology.

There are limitations to any study, and in 2016, the study conducted for the Canadian government carefully cautioned readers on the kinds of interpretations and conclusions that can be drawn from it.

Why has this section that highlights limitations of the study disappeared?

Watch for reporting on the study. Just because the report doesn’t contain a ‘caveats’ section doesn’t mean the limitations have gone away. The international price comparisons are completely meaningless in this year’s report given the significant price changes that took place in Canada.

The government plans to monitor and report on mobile plan pricing on a quarterly basis for 2GB, 4GB and 6GB plans. The spotlight section of today’s report shows the price of 2GB plans fell 30% between May and September; 5 GB plans fell almost 25% in the same period. Earlier this week, a US-based study conducted for the CTIA (based on current mobile industry pricing) “puts Canada atop the G7 + Australia when considering the price-value relationship in mobile wireless services.” In December, PwC found Canadian mobile services topped its analysis of affordability in the G7.

The election campaign promise to lower mobile prices by 25% has been delivered, confirmed by the release of the government’s own pricing study. The government’s new benchmarks are seeking a further 25%, rates that are 50% lower than the baseline used in last year’s election campaign. As I wrote in my accompanying article, “Moving the goalposts”, the January 2020 prices being used in the government’s mobile benchmarking are already 10% better than the two year targets that were promised in the run-up to last year’s election.

Today should have been time for the government to take credit for the success of measures it already put in place. The low prices are taking hold across the country (“greater standardization of national MNO pricing across the country”), evidence that all Canadians are benefiting from more vibrant competition.

Facilities-based competition is working; prices are falling; carriers are investing in new new technologies and expanding the reach of their networks.

Declare victory.

Consumers won.