There’ll be new dreams, maybe better dreams…

It’s mid-December and, as has become an annual tradition, it’s that time again for me to write a year-end wrap-up post.

Like last year, over the past 12 months I have published just over 70 blog posts, down from a few years ago in part because I am spending more time on Twitter, and also because of the need to deal with a few important personal issues, especially the two most enjoyable distractions (who have been interfering with my focus for 5 years and 3 years respectively).

The archives for this blog (accessed in the “My back pages” tab) now include more than 2800 articles, chronicling trends and issues as far back as 1997. As I look at the analytics, it is interesting to see the search terms being used. It is especially gratifying to see that a number of older posts continue to attract readers.

I continue to be optimistic about Canada’s telecommunications industry. After more than 39 years working to build advanced competitive communications networks in North America, I still find new challenges that make it a pleasure to get to work each day. Most satisfying is seeing the role played by low cost advanced communications in improving virtually everything we do.

It has never been easier or cheaper to communicate. I can talk with my kids and video-chat with my grandchildren halfway around the world every day as though they live around the corner.

Nov 6, 1970 Ad in Toronto TelegramWhen I was their age, my father would line us up in the kitchen on Sunday afternoons to stand quietly near the kitchen phone, as he prepared to call his dad in New Brunswick during the 60% discount period. Deep discount rates were also available after 11 pm each weeknight, but that just wouldn’t work for calling grandparents in the Atlantic time zone. So my dad would rush each of us through a quick “say hi” moment on the phone since long distance phone rates – even discounted long distance rates – were outrageously expensive. Our family was lucky to be able to afford weekly long distance calls. Regular trans-Canada rates were 50 cents per minute; evenings were about 3 minutes for a dollar, but late at night and on weekends, we could speak for 20 cents per minute – a crazy amount of money in those days. In those days, a McDonalds burger cost the same 20 cents; a Big Mac was 55 cents. No wonder Mother’s Day and Christmas Day were the busiest long distance calling days of the year; for many, calling home needed a special occasion to justify the cost of long distance.

Some groups talk about affordability of communications services but in most cases, they aren’t really talking about being able to find a plan that most of us can afford. There is a big difference between wanting to pay less for a device or service and being able to afford any plan or device.

I won’t get drawn into a discussion about why prices for some plans are lower in some other countries; Canadians pay more than people in other countries for a lot of goods and services, including our weekly grocery shopping bills. We still have government sanctioned ‘marketing boards’ and quota systems that inflate prices for genuine staples such as dairy products and poultry. So please forgive me for sometimes getting cynical about politicians proclaiming that they are seeking to lower costs for the middle class.

On the other hand, there are indeed some Canadians who are genuinely unable to find an affordable device or service plan that they may need to participate in today’s economy, to help find a job, maintain their health, be in touch with their families and friends. In late October, we learned that nearly 1 in 5 Canadians in the lowest income quartile doesn’t have broadband connection at home. In many cases, it isn’t just an issue of affordability; the experience learned from targeted programs that deliver low-cost connected computers have helped us to understand that there are a number of factors – not just lower prices – that inhibit adoption of communications technologies among certain demographics.

I have written a number of posts through the years calling for us to do more to develop a better understanding of those Canadians who have not yet adopted information and communications technologies. For example:

  • Building a broadband research agenda • October, 2016: “As Canada invests in its Innovation Agenda, there is a gap in understanding why nearly 1 in 6 Canadian households has no broadband connection. There is an opportunity for better understanding to emerge from a Canadian broadband research plan.”
  • Do we know what we don’t know? • November, 2017: “Is Canada doing enough research to explore the nature of its digital divide? How can we find solutions for a problem that we may not fully understand?”
  • Understanding the digital divide • March, 2018: “Bridging the digital divide isn’t just about rural infrastructure. Should Canada expand research to improve our understanding of other contributing factors that limit digital adoption?”
  • We need more data • October, 2019: “How is Canada supposed to be engaged in evidence-based policy making when there is so little information being gathered about who is online, how Canadians are using the internet and perhaps most importantly, who isn’t online yet and why not?”

As I wrote this past June, “Unfortunately, most government programs continue to focus on increasing “supply”, extending access to broadband. We need to ensure there are strategies to drive “demand”: increasing adoption rates among groups that could subscribe, but have not. That is a problem across all geographies, and is perhaps more pronounced in urban markets.”

If it is a matter of affordability, we can develop programs that target those people or households. Unfortunately, we do not currently know what all the factors inhibiting adoption really are. We need to fund much more research in this area.

In my year-end wrap-up in December 2010 entitled “Digital divide”, I wrote “I’d like to update Hoover’s 1928 promise of prosperity: We need a connected computer for every home.” We now know that it isn’t just price that is keeping people from getting online.

As we close the books on 2019 and set objectives for the coming year, let’s dream of more evidence-based policy making. Let’s dream of developing a greater understanding of those individuals and households on the wrong side of the digital divide. And let’s dream of creating solutions to bridge that gap.

I hope you and your families have a happy, healthy, safe and peaceful holiday season.

I look forward to engaging with you in the New Year.

Minister’s new mandate

Prime Minister Trudeau published the mandate letters for each of the members of the new Cabinet.

Of particular interest to the telecommunications community is the mandate letter for Navdeep Bains, Canada’s Minister of Innovation, Science and Industry.

The letter includes a telecom specific section:

  • Use all available instruments, including the advancement of the 2019 Telecom Policy Directive, to reduce the average cost of cellular phone bills in Canada by 25 per cent. You will work with telecom companies and expand mobile virtual network operators (MVNO) in the market. If within two years this price target is not achieved, you can expand MVNO qualifying rules and the Canadian Radio-television and Telecommunications Commission mandate on affordable pricing.
  • Award spectrum access based on commitments towards consumer choice, affordability and broad access. You will also reserve space for new entrants.

Some concerns came to mind on my first read of the letter, as I wrote on my Twitter stream. While the preamble in the letter says “We are committed to evidence-based decision-making…”, one might have difficulty squaring this promise with what appears to be a pre-determination of issues being explored by the CRTC in Public Notice 2019-57: Review of Mobile Services.

Some additional points set out in Minister Bains’ mandate require coordination with other members of Cabinet:

  • With the support of the Minister of Middle Class Prosperity and Associate Minister of Finance and the Minister of Seniors, create a new Canadian Consumer Advocate to ensure a single point of contact for people who need help with federally regulated banking, telecom or transportation-related complaints. Ensure that complaints are reviewed and, if founded, that appropriate remedies and penalties can be imposed.
  • Work with the Minister of Infrastructure and Communities, the Minister for Women and Gender Equality and Rural Economic Development and the Minister of Canadian Heritage to deliver high-speed internet to 100 per cent of Canadian homes and businesses by 2030.
  • Co-lead work with the Minister of Canadian Heritage to modernize the Broadcasting Act and the Telecommunications Act, examining how best to support Canadian content in English and French and ensure quality affordable internet, mobile and media access.
  • Work with the Minister of Canadian Heritage to introduce legislation by the end of 2020 that will take appropriate measures to ensure that all content providers, including internet giants, offer meaningful levels of Canadian content in their catalogues, contribute to the creation of Canadian content in both Official Languages, promote this content and make it easily accessible on their platforms. The legislation should also consider additional cultural and linguistic communities.
  • Work with the Minister of Justice and Attorney General of Canada and the Minister of Canadian Heritage to advance Canada’s Digital Charter and enhanced powers for the Privacy Commissioner, in order to establish a new set of online rights, including: data portability; the ability to withdraw, remove and erase basic personal data from a platform; the knowledge of how personal data is being used, including with a national advertising registry and the ability to withdraw consent for the sharing or sale of data; the ability to review and challenge the amount of personal data that a company or government has collected; proactive data security requirements; the ability to be informed when personal data is breached with appropriate compensation; and the ability to be free from online discrimination including bias and harassment.
  • With the support of the Minister of Canadian Heritage, create new regulations for large digital companies to better protect people’s personal data and encourage greater competition in the digital marketplace. A newly created Data Commissioner will oversee those regulations.

Like last time, the mandate letter talks about broadband coverage, without addressing factors impacting adoption.

Over the coming months, we’ll be certain to be coming back to these issues.

Spectrum policy and auctions

I was vacationing on November 21 when the International Telecommunications Society (ITS) held a workshop in Ottawa entitled “Spectrum Policy and Auctions: Best Practice from Around the World” but much of the day was captured on video. I thought it would be useful to provide a link to the archive.

The workshop attracted more than 70 participants from around the world to discuss auction best practices, opportunities and challenges, in the 5G era, including representatives from government, industry and academia.

Here are direct links to the presentations. I encourage you to visit the ITS site for a summary. Note that the video files are set up with a split screen to allow you to see the speaker and slides.

  • Professor Martin Cave, London School of Economics: Video | Slides
  • Oliver Chapman, GSMA Policy Director: Video | Slides
  • Evan Kwerel, Senior Economic Advisor at the Federal Communications Commission: Video | Slides
  • Dan Maldoom, partner at DotEcon: Video | Slides
  • Professor Pat Sujarittanonta, Chulalongkorn University: Video | Slides
  • Jan-Hendrik Jochum, Senior Expert, Public and Regulatory Affairs, Deutsche Telekom: Video | Slides
  • Nick Bone, Principal Engineer: Auctions, Security and Cryptography, Vodafone: Video | Slides
  • Professor Erik Bohlin, Chalmers University of Technology: Video | Slides
  • Panel of all speakers, moderated by Janet Yale, Chair of the Canadian Broadcasting and Telecommunications Legislative Review Panel: Video

Back in September, I wrote “The cost of spectrum policy”, introducing the GSMA report discussed by Oliver Chapman in his talk. That report found “High spectrum prices can cause negative consumer outcomes, including lower coverage levels and slower data speeds.”

The videos and slides from all of the speakers provides valuable material to productively fill time as your office empties over the winter break.

Setting the record straight on Canada’s wireless industry

The following opinion piece by CWTA President & CEO Robert Ghiz appeared in Hill Times on December 3:

During the recent federal election campaign, we heard a lot of talk about cellphone prices. Now that the election is over, it is important to put rhetoric aside and look at the facts. Not just about prices, but also about the future of mobile communications and what is required to connect more Canadians and to reap the economic and societal benefits of the new 5G technologies.

The price of wireless data has actually been declining significantly over the last several years. In fact, the CRTC recently reported that wireless prices declined by an average of almost 30 per cent from 2016 to 2018. That was before unlimited data plans were launched across the country. Today, Canadians can get unlimited data plans that start from $50 to $75 a month, a huge decline in price from 2018 when, according to the government’s own study, $75 was the average price for a 2-GB plan.

Declining prices are only one indication of successful wireless policy. Network performance and coverage are also fundamental components of a healthy wireless industry. Given its size, low population density, and climate, as well as government licence fees that are among the highest in the world, Canada is one of the most challenging countries in which to build wireless networks. Yet despite these challenges, Canada’s wireless providers have, so far, invested over $70-billion in building world-class wireless networks throughout the country, according to data gathered by the Canadian Wireless Telecommunications Association, the CRTC, and Nordicity. That’s about twice as much on a per connection basis as in the European Union, according to the industry group GSMA Intelligence.

Thanks to these massive investments, Canada’s LTE wireless networks are ranked the third fastest in the world (and twice as fast as the U.S.) and reach 99 per cent of Canadians. This success is not limited to urban areas. A recent report by OpenSignal shows that network coverage and performance in Canada’s rural areas is also among the best in the world. In fact, if rural Canada were its own country, its average download speeds would rank higher than the average speeds across all of the United States and more than 70 other countries.

These achievements were possible because successive federal governments adopted policies that fostered meaningful competition while also maintaining an environment that encourages investment in wireless infrastructure. These facilities-focused policies also encouraged the introduction of new regional wireless providers, such as Freedom Mobile, Videotron, Eastlink, and Xplore Mobile that are playing an important role in providing sustainable competition, while at the same time making significant investments in Canada’s wireless infrastructure.

Policy proposals that would instead favour companies looking to be “virtual” wireless providers, or mobile virtual network operators—whose business models depend on regulatory arbitrage rather than investing their own capital to build and maintain wireless infrastructure—have been repeatedly rejected by the CRTC. Why? Because any potential benefits are outweighed by the negative impacts on sustainable competition and investment.

MVNOs will not help extend wireless networks to rural communities or invest in 5G infrastructure, and any material impact on prices is unlikely. The fact is Canada’s wireless market is already delivering the same or lower prices than high-profile U.S. MVNOs like Tracfone and Google Fi, at speeds faster even than early 5G implementations in the U.S.

In its submission to the current CRTC proceeding, the Competition Bureau and its expert consultant concluded that a broad-based MVNO policy would not have a significant impact on prices, would harm the regional providers who have brought meaningful competition to the market, and would reduce network operators’ incentive to invest in network infrastructure. In short, “the risks associated with such a policy are too high for it to be warranted.” The bureau recommended the CRTC maintain its facilities focus as “[a]ll else equal, facilities-based competition is the most sustainable and effective form of competition.”

Canada can’t afford to ignore the success that policies supporting facilities-based competition continues to have in delivering performance, coverage, and declining prices. Countries that have turned their backs on facilities-based competition have seen the quality of their wireless networks and services suffer, investment decline, and jobs disappear. We must not let this happen in Canada. The government should focus on policies that encourage investment in Canada’s future and deliver increasing value to Canadians and our economy.

Majority isn’t always right

I came across an interesting article in The Guardian from a few years ago that is perhaps somewhat relevant to the very public discussion about Canada’s telecommunications industry.

Three years ago, Julian Baggini wrote “Think democracy means the people are always right? Wrong”. In the article he writes:

Western democracy is built around a tripartite trust: trust in the people to hold government to account and to set the general direction of policy, but also trust in politicians to make specific decisions, and in institutions to provide safeguards against rash or tyrannical actions. What we are seeing all over the western world are the last two pillars being torn down, leaving all trust resting on the people.

This is rightly called populism, not in the American sense, but as understood in the rest of the world. Populism is generally defined as a mode of politics in which the will of the people is seen as clear, virtuous and homogeneous. Populist politicians simply promise to do what this will commands, ignoring or denying the fact there are different, competing interests in society, not just those of the majority. Populists do not try to square the simple desires of the electorate with the complex realities of society but pretend that what seems simple is simple and that anyone who says otherwise belongs to an obfuscating elite looking for excuses to defend its own interests.

Sound familiar?

There is a reason we look to expert panels, such as the CRTC, to explore the complex issues associated with telecommunications regulation, hopefully acting without political interference in reaching their determinations.

The issues associated with the current review of Canada’s wireless industry are quite complex and the stakes are extremely high. There are different, competing interests involved, extending far beyond the short term interests of the majority.

As Eros Spadotto of TELUS wrote this past weekend in the Toronto Star:

This brings us to the crux of the problem around affordability: many of the arguments are not informed by facts, neglect to account for policies that have failed in other countries, and make no reference to the risk of introducing regulatory uncertainty when wireless carriers are preparing to make generational investments to accommodate the transition to 5G.

Eros, the EVP of Technology Strategy and Business Transformation, spoke about “accelerating innovation and economic prosperity in Canada” at The 2019 Canadian Telecom Summit (his address can be seen online). Better than most, he understands what is at stake in the current regulatory review. His article in the Toronto Star says the evolution to 5G is predicted to add 250,000 permanent new jobs and $40 billion to Canada’s annual GDP. “If this is what’s at stake, surely we want to be making informed choices about the right path to take.”

Returning to Baggini’s piece in the Guardian, “No sensible person thinks majority opinion is a good guide to best practice in health, education, engineering, or pretty much everything else. So why would public policy be any exception?”

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