Policy-based evidence making

If you believe a recent survey, 1 in 6 Canadians sent a fax last year to a government department because that agency would not accept scanned documents by email. Perhaps no other data point in the CIRA survey demonstrates that something smells wrong with the methodology or results.

Frankly, I don’t believe that 1 in 6 Canadians sent a fax to anyone last year, let alone sent one with such a specific purpose.

CIRA also reported “In Canada, the appetite to share personal data in exchange for better products and services is low across the board” other than online banking “with 52% of Canadians at least somewhat willing to provide their data if it means better service”. Only 23% responded that way for social media websites. Yet, based on adoption rates in Canada, we know that virtually all of the respondents make use of social media services in exchange for sharing their personal information.

So it seems, as should have been expected, respondents answered with what they thought was the ‘right’ answer, whether or not it was a truthful answer. It is with this in mind that we have to take all of the survey results with a grain (or tablespoon) of salt.

Five questions, numbers 33-37 dealt with cyber security, culminating with one that Strategic Counsel’s report said indicated “Level of Concern about Huawei Technologies Supplying Equipment to 5G Networks”. But the question actually read “As you may know, Huawei Technologies is a large Chinese technology firm that is a global supplier of smartphones and telecommunications network equipment. Huawei supplies equipment to 5G networks, the fifth generation of wireless networks that will eventually replace current 4G networks. How concerned are you, if at all, about potential cyber security risks from foreign-owned network technologies such as Huawei and 5G?”

Try to parse that for a minute, especially in view of the respondent answering the way they thought they were supposed to.

We just finished with 4 other cyber security questions, and those followed more than a dozen questions about privacy and security of personal data. Then there is a complex question that does not mention a few important facts: that Huawei supplies equipment already for some of Canada’s 4G networks, that all of the major equipment suppliers for Canada’s telecom networks come from foreign owned network technologies. Read the question again and consider whether the survey result applies equally to Cisco, Ericsson, Nokia – all of which are foreign owned technology suppliers.

Is the question itself meaningful when the network technologies may come from foreign owned suppliers, but once acquired, the network technologies are Canadian owned? In a number of cases, the software development for these foreign suppliers takes place in Canada. Would that information impact the way someone responded?

CIRA tells us that “Most Canadians are not comfortable with the idea of living in a smart city, and another 18 per cent say they’re not comfortable at all.” Based on the way the question was asked, it’s no wonder. Here is how Smart Cities were described in the survey [Q. 28]: “The term ‘smart city’ refers to a high tech urban area that uses a wide network of internet-connected sensors and technology to collect data and then use insights gained from that data to manage infrastructure, assets, resources and services. This includes data collected from individual citizens, devices and systems. How comfortable or uncomfortable would you be living in a smart city?”

What if the techno-jargon was put into terms like “The term ‘smart city’ refers to an urban area that uses a network of internet-connected sensors to collect data and then use insights gained to provide benefits to residents like reduced traffic congestion, improve energy efficiency and lower maintenance costs. How comfortable or uncomfortable would you be living in a smart city?”

A couple of weeks ago, I described just some of the problems with CIRA’s flawed recent internet traffic data. It is perhaps another unfortunate result of policy-based evidence making, rather than contributing independent information to ongoing discussion of the evolution of Canadian digital policy.

For a non-profit organization, CIRA does pretty well. In the year ending March 31, 2019, it had an ‘excess of revenue over expenses’ of $1.8M on revenues of $26M. That was what was left after giving away another $1.8M to “Community investment programs”. Not a bad profit for a non-profit.

I went back through the financial statements and had trouble finding a ‘down year’. For 2017-18, CIRA made $500K after giving away $1.3M; the year before, it made $300K after giving away $1.3M. Salaries and consulting have climbed from $12M in 2016-17, to $13M in 2017-18, to $14M in 2018-19, while “community investment” keeps rising as well. Notice the trend?

Perhaps it is time to ask why CIRA’s expenditures are at least an order of magnitude higher than what it takes to administer Canada’s phone numbering system under the Canadian Number Administrator.

Maybe it’s time for CIRA’s board to reflect on its bloated budget, reduce the cost of .CA, and return to its original mandate, “to administer the .CA domain space on behalf of Canadian users”.

It may also want to revisit the letter establishing the organization requiring it “put in place an effective structure predicated upon… ensuring an appropriate balance of representation, accountability and diversity on the Board of Directors for all categories of stakeholders.”

It is somewhat telling that the Board of Directors of CIRA has no representation from facilities-based ISPs, the companies that provide roughly 9 out of 10 internet access lines in Canada.

Is it possible that CIRA’s failure to ensure an appropriate balance of representation and diversity on its Board for that category of stakeholder has contributed to its one-sided, off-mandate policy pronouncements?

Archival papers in a digital age

Last week, I wrote about one of the most useful books in my personal library (Engineering Economy), a book I received when I was a Member of Technical Staff at Bell Labs in the mid 1980s. I have some other printed books that I go to regularly, such as an autographed copy of the 2006 report of the Telecom Policy Review Panel [pdf, 1.6MB], telecom law books, such as McCarthy’s “Canadian Telecommunications Regulatory Handbook”, by Grant Buchanan and Hank Intven and even a copy of Michael Ryan’s looseleaf “Canadian Telecommunications Law and Regulation.”

Books have been figuring prominently in my thinking these days. As we spend so much time in our homes, many of us are cleaning rooms, clearing spaces, going through old papers. Much of what we read today, we read online. Obviously, it wasn’t always that way. Nearly 25 years ago, in the early days of my consulting practice, I would receive regulatory filings via almost daily deliveries from various courier services. We were recently reminiscing about the way our family dog had a particular affinity for the Fedex guy. He would hear the truck from a mile away, and stand guard at the door with his tail wagging, knowing his buddy was just a minute or two away.

A number of years ago, under tremendous pressure, I donated a batch of my telecom related books to a university engineering program. I know the day is coming soon that will pressure me to release a second wave of archival materials.

But I started to wonder: will anyone want to take my old printed books and papers? Have electronic texts and digital libraries made my archival materials obsolete and better suited for recycling?

Like some old Nortel stock certificates, did I hold on to these papers too long?

A key to recovery? Communications leadership

An article in the weekend Toronto Star credits Canada’s strong telecommunications infrastructure with helping the country manage through the COVID-19 crisis so far. I would add that we need strong leadership to guide development of smart telecommunications policy.

In “What Canada can learn from Europe’s COVID-19 response”, Dr. Georg Serentschy and Derk Oldenburg claim: “while ineffective communication enabled the spread of the Spanish Flu—a pandemic that persisted for more than a year — connectivity is one of the greatest strengths at our disposal in the fight against COVID-19.”

Dr. Serentschy was the head of the Austrian communications regulatory authority (RTR) and, later, Chairman of the EU regulatory authority, BEREC. Mr. Oldenburg is a former Dutch diplomat who served as Deputy Ambassador to Germany and the European Union.

Looking at how various countries in Europe have managed to date, they write:

Broadband technology has proven to be an indispensable asset, serving as both a social and economic lifeline. “After weeks of lockdown in Europe, those networks have passed an unprecedented stress test,” says Oldenburg. The EU’s early COVID-19 successes hold important lessons for Canada. Germany, Austria and Denmark’s ability to slow the spread and contain the infection rates demonstrate the critical role of early action, a well-funded public health system, a population that demonstrates trust in elected government and resilient telecom networks that have sufficient headroom, says Oldenburg. In that view, Canada has many of the resources necessary to efficiently overcome the COVID-19 crisis: an early response, a functional federal state, universal public health care and a world-leading telecommunications network that’s been able to shoulder both societal networking needs and the influx of economic activity during the COVID-19 crisis.

As Canada’s economy begins to re-open, wary of a rebound and second wave, what policies will continue to build upon the strengths that have largely enabled our transition to being isolated at home?

How can we best approach the challenges of extending network reach to increase available supply of global-leading services?

What lessons are we learning to help the demand side, helping more people adopt digital connectivity?

A couple of weeks ago, we marked the 10th anniversary of the launch of a consultation to create a national digital strategy. That exercise, launched by then Industry Minister Tony Clement, turned out to be a complete waste of time and effort, as Canada’s digital policy drifted aimlessly.

We don’t need a new expert panel or Royal Commission to set out a digital strategy. As I have written before, we need to demonstrate leadership instead of managing political calculus.

What outcome do we want? What do we want our digital environment to look like in 5 years? In 10 years?

Basic, but strong leadership principles: Set clear objectives; Align activities with the achievement of those objectives; Stop doing things that are contrary to the objectives.

Understanding engineering economics

One of the most important books in my telecom library is entitled Engineering Economy, A Manager’s Guide to Economic Decision Making, by AT&T – the original, pre-divestiture, full Bell System, AT&T.

Mine is a copy of the third edition, dating back to 1977, just a couple years before I got into the industry, but likely well before many of my readers were born.

The age of the book doesn’t change the utility of the training contained within.

Fundamentally, when there are alternatives available for the deployment of capital, engineering economics provides a disciplined approach to evaluating the economic outcomes, considering revenue, operating expense, capital and other cash flows.

For any given project, there are usually a number of possible alternatives. For example, for a given area, should fibre or fixed wireless be deployed? The analysis tools allow the manager to assess the difference in cash flows, revenue and expenditures, over the live of the project analysis.

In each case, an option that must be considered is maintaining the status quo, a “do nothing” alternative.

I’m not an economist and I’m not a professional engineer. This book was designed to help managers like me understand how to assess business decisions.

Among other benefits, an appreciation of engineering economics provides a framework to recognize the difference between “threatening” to reduce a budget, and a budget reduction occurring as a logical consequence or outcome of a policy determination.

Why am I highlighting a 43-year-old, out-of-print text book? The concepts are just as important today. A basic understanding of economic analysis should be considered a prerequisite for regulatory or government policy work in the telecommunications industry.

A more evidenced based approach is warranted

After watching the Federal Government’s Parliamentary Standing Committee on Industry, Science and Technology (INDU) May 7 meeting, Greg O’Brien wrote a commentary entitled “Federal committee nothing but bluster”.

“There’s a waste of two hours,” he wrote. “Not just my own time. Everyone’s.” Later on, Greg writes “You’d think they would want to get to the point, let witnesses speak, maximize their time with a number of good questions. Nope. Maximum windbaggery is what I saw”.

I’m certain we both had higher hopes for last Thursday’s (May 14) meeting, when representatives from Rogers, TELUS, Cogeco and Xplornet were witnesses. I came away shaking my head.

While some productive discussion emerged, too much time was spent by Parliamentarians apparently building transcript materials to show off to constituents and future voters. As stated by Chair Sherry Romanado (MP – Longueuil—Charles-LeMoyne) at the beginning of the video record on “ParlVu”, the meetings are being held “for the purpose of receiving evidence concerning matters related to the government’s response to the COVID-19 pandemic.” Starting on April 23, there have been 7 such video conference meetings so far.

The meetings have evolved to become a forum for issues related to accelerating the deployment of broadband access in rural and remote parts of Canada. This has given rise to Michelle Rempel Garner’s May 7 release of the ‘not ready for prime time’ Conservative caucus “Connect Canada” plan, and NDP MP Brian Masse’s release of the “NDP Plan for High Speed Broadband Internet for all Canadians” just prior to the May 14 Committee meeting.

The opposition parties created their plans prior to hearing from witnesses, many of which are in the business of building and operating networks. That is disappointing enough. But Canadians should watch the performance of their parliamentarians in committee. How many would approve of a methodology that sees plans developed and conclusions drawn well in advance of gathering evidence?

For example, the opening remarks by Rogers for Business President Dean Prevost included this testimony that could have provided guidance for the plans [17:30:25]: “Unfortunately, where we do not have high capacity, high speed wireline networks, we are not able to provide unlimited wireless data for internet access at home at this time. Put simply, wireline networks have 50-200 times the capacity per consumer as rural wireless mobile networks. Removing datacaps would simply overwhelm the mobile wireless network, impairing service for everyone in that area, including the first responders and 9-1-1 services that rely on it.”

During last Thursday’s meeting, I was particularly disturbed by a couple exchanges between Calgary-Nose Hill MP Michelle Rempel Garner (‘MRG’) and TELUS Chief Customer Officer Tony Geheran (‘TG’).

We witnessed this exchange at 6:31 pm:

MRG: “Mr. Geheran, I think I am saying your name right. You made a comment tonight. You said ‘if you have a policy that fundamentally undermines an investment strategy, you have to change policy’ and I think I agree with that. So I’d start with saying, do you think that structurally separating the builders of network from Internet Service Providers is a way to solve the policy tension that I just described?”

TG: “No, I don’t. I haven’t seen that work anywhere globally, to sustainable effect.”

MRG: “It’s in the UK, right?”

TG: “Yeah.”

MRG: “It’s like the primary model in the UK.”

TG: “But if you look at the UK, they are wholesale moaning about the quality of their infrastructure, their lack of fibre coverage. across what is a very small geography. I know. I originated from there. And quite frankly, the Canadian networks are far superior in coverage and quality and performance through COVID has demonstrated that.”

MRG: “Well, that’s certainly not what we’re hearing in our offices from end users and that’s not the reality that we’re hearing in testimony tonight from you.”

I’m not sure the Honourable Member actually heard contradicting testimony that night. Perhaps she was confusing meetings.

So, I went off to find some independent sources to figure out what is actually going on in the UK. If the Committee members want independent corroborating evidence for Mr. Geheran’s perspective, they too can check with the independent regulators in Canada (the CRTC) and the UK (Ofcom). It didn’t take much effort to find information on the respective regulators’ websites.

Just a few weeks ago, in its April 24 Notice of Consultation reviewing its approach for rates for wholesale telecom services, the CRTC wrote “Ofcom has identified the lack of incentives to invest in new broadband networks, including full-fibre networks, as one of the key challenges facing the U.K. telecommunications industry.” Just 3 weeks ago, Canada’s regulator stated that the one of the key challenges facing the UK regulator was its lack of incentives to invest, just as Mr. Geheran had told Ms. Rempel Garner.

For verification of quality differences, there is plenty of data in the most recent annual reports from both regulators. For example, Ofcom is showing that broadband speeds in the UK increased 18% between 2017 and 2018 to reach 54.2 Mbps. According to the CRTC, average speeds in Canada reached 126.0 Mbps by the end of 2018, an 89% increase over 2017.

Or, the members of the committee could take a look at the Insights section from Ookla speed test results, which show Canada’s April 2020 wireline average at 118.11 Mbps for downloads and upload average at 51.80 Mbps. In the same period, wireline users in the UK were getting roughly half the download speed at 67.23 Mbps and about a third of the upload speed (18.28 Mbps).

When the Hon. Member from Calgary Nosehill said “that’s certainly not what we’re hearing in our offices from end users and that’s not the reality that we’re hearing in testimony,” the independent evidence supports ‘the reality’ portrayed by Mr. Geheran.

If they are hearing otherwise, the committee might want to take more time listening to different witnesses. Recall the opening of the meeting, where we hear that this inquiry was “for the purpose of receiving evidence”.

How would you interpret “receiving evidence”? Listening? Probing? Researching? Learning?

Instead, what we, the Canadian voters, have witnessed so far appeared to be parliamentary puffery.

A more evidenced-based approach is warranted.

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