A new report from the Canadian Internet Registration Authority’s (CIRA) shows that rural broadband speeds have increased 50% since the start of the pandemic.

In its May report, CIRA said “In April, median rural download speeds were measured at 3.78 Mbps”; the latest report, issued earlier today says “In July, median rural download speeds were measured at 5.62 Mbps”.

That is an increase of 50%.

Why then is CIRA characterizing this dramatic improvement as “Since the pandemic began, median download speeds have plateaued around 5.5 Mbps for rural internet users”?

Earlier today, TD Securities issued a report that said “it is time for the government to declare victory in the 12-year quest (since the first set aside of spectrum in the 2008 auction) to help consumers via sustainable competition from a facilities-based fourth carrier in almost every region.”

TD found that the average revenue per user (ARPU) for Canadian mobile service providers are “comfortably below” US, “which feeds into our strong view that the CRTC and ISED should not and will not implement new measures to mandate either lower prices or widespread MVNOs.” In the view of TD, network quality, spectrum costs, scale, and population density all impact operating expense and capital expenditures for Canadian carriers relative to their global peers and should be considerations in the various regulatory and policy reviews of consumer wireless pricing.

“But even if we ignore these factors and just look at what Canadian consumers pay on average per month to incumbent carriers (keeping in mind that reported ARPU for new entrants Shaw and Quebecor is even lower than that of Rogers/BCE/TELUS), we no longer see a problem that policymakers need to fix.”

I said it 5 months ago: “Declare victory. Consumers are winning”.

At the April 30 meeting of The Standing Committee on Industry, Science and Technology, Minister of Innovation, Science and Industry Navdeep Bains engaged with Bloc Québécois communications critic Martin Champoux in a discussion about the need to improve rural broadband, a problem accentuated by the current pandemic.

Mr. Martin Champoux: Minister Bains, I’ll come back to my question. You acknowledged that a high-speed Internet connection is now an essential service in 2020. We can see this clearly with the current crisis. When we spoke, you said that you intended to speed up the process and shorten the time frame for connecting Canadians. This means that 100% of Canadians and Quebeckers will be connected within a much more reasonable time frame than initially anticipated

Hon. Navdeep Bains: Once again, thank you for your question. You’re right. We must adjust the time frames for high-speed Internet. My colleague Maryam Monsef is responsible for this initiative. I’m sure that she’ll outline solutions that will help people in rural communities.

Mr. Martin Champoux: Am I to understand that you can’t provide an estimate at this time, that there’s still some uncertainty and that we don’t know whether this will take two years or five years?

Hon. Navdeep Bains: Yes. My colleague Maryam Monsef will outline exactly how long this may take and the relevant programs. All I know for sure at this point is that the time frame must be changed, because the current reality is very problematic. This issue is a priority for our government.

Mr. Martin Champoux: Thank you. You also said that you would get this work started as soon as the crisis is over. However, this matter is urgent right now. I imagine that teams are ready to proceed with the installation or, at least, to continue to implement measures to speed up the project. Why can’t this work begin immediately, Minister Bains?

Hon. Navdeep Bains: We’ll start soon. The strategy and the program already exist. We invested a great deal of money in them in the most recent budget, about $1.7 billion. I’m sure that my colleague Maryam Monsef will be outlining solutions soon.

A little over a month later, on June 8, Rural Economic Development Minister Maryam Monsef told the Rural and Remote Broadband Conference that a call for applications for Canada’s Universal Broadband Fund would be issued “in the coming days.”

That was 2 months ago. It is now more than 3 months since we were told there was a recognition that the “current reality is very problematic”, and the “issue is a priority for our government”.

A few weeks ago, I wrote, “It is sometimes painful to watch the glacial pace of government responding to the need for more investment in broadband facilities.” Sometimes, it seems governmental timetables can be measured better in geological terms.

What is taking so long? Part of the delay has to be in the mapping exercise: what areas should have the highest priority for funding? Government subsidies for broadband facilities creates a distortion in the market. The government subsidy means one service provider will have an advantage over any other provider that hopes to offer service, now or in the future. That is why funding programs need to target areas that do not appear to have any other economic way for service to be launched.

“Almost everyone who is already connected needs, or at least wants, to get connected faster and connect more devices to that faster connection.” [see: Too many pots; too little being served]

A month ago, I suggested a quick, low cost way for ISED to help rural ISPs increase broadband speeds [“An easy way to increase rural broadband speeds”]. Problem is, the theoretical reduction in collected spectrum fees means the solution requires interdepartmental approval. When Cabinet is dealing with multi-billion dollar bail-out programs, it must be tough to get the attention of other Ministers with a relatively low cost proposal. It is unfortunately a missed opportunity that could have brought immediate increases in speed and capacity to many rural areas.

The fact is, even if a rural broadband funding program was announced today, money won’t start flowing until next year. In many areas, construction season is effectively over for 2020. It is too late for detailed engineering, equipment ordering and delivery, permitting and installation before winter.

With kids heading back to school in just a month, most households will need access to computers and broadband, even if some classrooms open up for in-person instruction. The state of internet access must be frustrating for many parents.

How do we move forward?

Stakeholders need to have realistic expectations. Management consultants like to say goals should be specific, measurable, attainable. relevant and timely. There was a good reason why the CRTC didn’t set universal gigabit internet as its aspirational goal; that wouldn’t be attainable.

Further, contrary to the assertion by North Grenville Mayor Nancy Peckford in her Ottawa Citizen column, the CRTC did not set 50/10 internet as a “basic minimum standard for internet service”; it was part of a CRTC aspirational goal, to be achieved over the next 10 years (not this summer). And while just 43% of rural Canadians had access to 50 Mbps download speeds in 2018 (the latest year of data), nearly double that (72.1%) had access to at least 25 Mbps.

Those are two year old data points.

Already this year, even without federal government funding, there have been a number of significant announcements for extending higher speed rural broadband to more households [such as here, here, here, here, and here].

The federal government isn’t the only source of funding for broadband expansion, as we saw with last week’s announcement from SWIFT, awarding funding to Teksavvy for fibre-construction to serve Delaware Nation, a First Nation community located in Chatham-Kent, Ontario.

The CRTC has recognized that certain regions may need to take steps toward achieving that target. I wrote about that in “Isn’t some broadband better than nothing?”

It isn’t helpful for so-called internet advocates like Open Media to tell its followers to expect rural Canadians to have access to the same services and the same prices as urban Canadians. That simply isn’t realistic. Affordable internet doesn’t necessarily mean low cost, or low price; it doesn’t mean rural prices should be identical to urban.

Building rural broadband in Canada is expensive and low population densities mean those capital expenditures are amortized across very few people. As a country, we believe broadband should be affordable to all Canadians, but someone has to pay. Lower household densities also means more unproductive “windshield time” for technicians making service and installation calls.

As such, fibre simply isn’t an economic option for many areas. We can, and should, expect wireless to be a significant part of the rural broadband solution space for the foreseeable future. For 5 months now, I have been living and working in rural Ontario with a 25 Mbps fixed wireless service, consistently delivering service, able to support multiple HDTV streams and multiple simultaneous video conference sessions.

How do we improve the business cases for rural broadband?

How can the government help wireless ISPs expand capacity to connect towers?

How can local land use authorities simplify and expedite the process for new antennas?

Are there other regulatory or policy levers that don’t require direct subsidies to improve the business cases for rural expansion?

Like many, I’m expecting an announcement that is certain to impact rural broadband.

It will be coming any day now. But, I’m not holding my breath.

Last week, Canada’s Minister of Innovation, Science and Industry, Navdeep Bains, released the first quarterly report tracking the progress of wireless prices from the major service providers.

Following up on an election campaign promise of a 25% drop in prices from last fall, the tracking was announced in early March, just before the world started locking down to control the spread of COVID-19. “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.”

At the time the tracking was launched, I had said the government should “Declare victory. Consumers are winning.” Prices had already fallen significantly.

But that train had already left the station, and so we are left with a new reporting structure, tracking prices by province each month, releasing the results each quarter, with pricing targets set for 2GB, 4GB and 6GB plans offered by Bell, TELUS and Rogers and their flanker brands.

The press release explains that tracking is restricted to these service providers because they collectively have 90% of the national market. It doesn’t really explain leaving out tracking of significant service providers in individual provinces, such as SaskTel’s majority share in its home province.

There are other problems with the study, most significantly, limiting targets to specific 2GB, 4GB and 6GB plans. Two years ago, Canadians with mobile data plans were already using an average of more than 2.5 GB per month and the CRTC observed that in 2018, “Approximately 40% of data subscribers had a plan with 5 or more gigabytes (GB) of data”. The latest monitoring report showed mobile data consumption per subscriber climbing year over year by nearly 25%.

What happens to the political targets if (or more likely, when) service providers determine that they aren’t offering such packages because low data buckets are no longer in demand?

Interestingly, Canada’s official statistical agency, Statistics Canada produces a Cellular Price Index. Strangely, Statistics Canada doesn’t publish the Cellular Price Index; it is released on demand. The most recent report (released July 22) shows prices declining more than 12% in the twelve month period ending in June 2020. In other words, pricing is already falling at the pace sought during the political campaign (25% over 2 years).

As I said, “Declare victory. Consumers are winning.”

Statistics Canada says its mission is “Serving Canada with high-quality statistical information that matters.” Defining what it does, the agency says:

Statistics Canada produces statistics that help Canadians better understand their country—its population, resources, economy, society and culture.

In addition to conducting a Census every five years, there are about 350 active surveys on virtually all aspects of Canadian life.

In Canada, providing statistics is a federal responsibility. As Canada’s central statistical office, Statistics Canada is legislated to serve this function for the whole of Canada and each of the provinces and territories.

Objective statistical information is vital to an open and democratic society. It provides a solid foundation for informed decisions by elected representatives, businesses, unions and non-profit organizations, as well as individual Canadians.

Statistics Canada falls under the responsibility of Minister Bains, just as he restored the long form census in his very first day in office and introduced other census reforms a couple weeks ago.

Why is there a duplication of effort tracking mobile service prices? Indeed, if we include the price tracking in the CRTC’s Communications Monitoring Report, there are at least 3 different ways mobile price trends are being tracked and reported by Canadian governmental agencies.

Why isn’t “high quality statistical information” from Statistics Canada data being used to measure progress on mobile pricing?

While I disagreed with the government moving the goalposts and setting pricing targets for the mobile industry, it seems wrong for three different groups, all under the Minister’s purview, to be tracking pricing data.

We should be asking what is wrong with Statistics Canada applying its objective methodologies to collect and report on mobile price plan data?

As Statistics Canada says, aren’t objective, reliable, consistent data important for “informed decisions by elected representatives”?

Sometimes, I think the Public Interest Advocacy Centre loses sight of its primary raison d’être: “legal and research services on behalf of consumer interests, and, in particular, vulnerable consumer interests, concerning the provision of important public services.”

I recently wrote [see “Strange bedfellows”] about how PIAC is acting in a coalition with the pulp and paper industry in a CRTC review of paper billing practices.

In another CRTC proceeding, examining ways to control consumer fraudulent wireless customer transfers (“SIM-swapping”), PIAC filed a letter seeking disclosures that again left me wondering what the public interest organization is thinking. In that proceeding, the CRTC asked a series of questions of the parties, including seeking more details on methods being developed to thwart the purveyors of fraud.

Some of the responses [such as this one by CWTA] have portions redacted, with a claim for confidentiality. CWTA wrote “The information submitted contains detailed fraud prevention measures, and its release would enable fraudsters to better understand the measures implemented by the industry to protect Canadian consumers from fraud, thus circumvent these measures and expose consumers to further harm.”

One would have thought the reasons for this is somewhat self evident.

Last week, PIAC filed an application for public disclosure. “PIAC is in receipt of the heavily redacted responses to these RFIs, as well as the responses regarding implementation of the CWTA’s proposed (confidential) measures to address SIM-swap fraud, which fail to provide any meaningful information nor even the expected date of implementation of the CWTA and industry’s secret protocol.”

That is actually a good thing, isn’t it? In the public interest, wouldn’t PIAC want to help make sure that these public disclosures “fail to provide any meaningful information nor even the expected date of implementation of the CWTA and industry’s secret protocol.”

Wasn’t that precisely the idea behind the redactions?

PIAC writes “the responses argue that keeping this information confidential is important to protect the information from being disclosed to fraudsters who could circumvent the purported controls and/or to shield this information from competitors.” PIAC goes on to express “dismay” at the “lack of transparency” and the “clandestine approach” that has “not only deprived consumers of access to vital information but also denied them of an opportunity to engage in a well-informed dialogue on this serious issue.”

According to PIAC “The specific information and data being withheld is timely and relevant to SIM-swap victims and all consumers. Consumers need to have access to these details to be able to provide input and raise any concerns they might have at this stage, rather than after the subject measures are implemented.”

Why? Consumers can provide input on requirements without the details of the implementation.

PIAC claims “Adoption of security measures by keeping consumers in the dark is unfair and unnecessary.”

It is unclear how satiating PIAC’s voyeuristic curiosity will lead to better operational procedures than those developed by professionals bearing the potential risk of financial liabilities if methods fail, coupled with a review by regulators.

At the risk of publicly displaying fraud control methods, it is difficult to see how the public interest outweighs the risk of disclosure.

Aren’t internal fraud prevention methodologies an area that just might merit less transparency?

Can we keep the drapes closed when reviewing procedures to counter fraud?