A number of articles appeared today that seem to tie together as a partial list of reference materials for students of Canadian telecom policy:

• Carmi Levy’s article on Yahoo’s Dashboard: Mobilicity shows why wireless competition rules need to change, fast
• A story from Reuters: Analysis: Spanish telecom firms show peril of pinning hopes on 4G
• An OpEd in the Globe and Mail by Martha Hall Findlay: Our cellphone woes are real, but forcing in competitors isn’t the answer
• Canadian Press coverage of a new report from The Convergence Consulting Group: New wireless players’ low prices not sustainable over long term: report

I found a common theme in the articles. Do you get the same sense?

Mobilicity has not said who the proposed buyer is, but the Globe and Mail is reporting “that Mobilicity and Telus are in talks to rekindle a sale that the federal government publicly killed in early June”. It is not known what the value is for a new deal, or how such an arrangement would be structured to get around the restrictions in Mobilicity’s licenses [see Appendix 2 of this license, as an example] that preclude transfer prior to February 10, 2014. Mobilicity acquired its wireless spectrum in 2008 for $243M.

Why was there so little interest by others in acquiring Mobilicity, for its customers or its spectrum?

What lessons can we learn?

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Update: The court documents for the CCAA [Companies’ Creditors Arrangement Act] proceeding can be found on the Ernst & Young website. In particular, the Affidavit in the Initial Application Record [pdf, 41MB] has interesting insights for those who are voyeuristically inclined.

Let me start by saying that all of my lines are registered on the national Do Not Call List (DNCL) and have been since its launch five years ago.

That said, I am not sure I agree with a plan to make registrations permanent.

In its new release celebrating the fifth anniversary of the DNCL, the Commission said:

The CRTC is of the view that it would be too cumbersome to establish a procedure to remove numbers that have been disconnected or reassigned. It has therefore launched a consultation to find out whether registrations could be made permanent without such a procedure.

Mathematically, this effectively means that every Canadian phone number will be on the list eventually, unless people actively de-register their numbers. Ultimately, the only way to receive calls – other than from those duct cleaners who just don’t seem to care about the rules – would be to effectively opt-in.

I’d like to know what kind of person would do that.

The CRTC Public Notice details the evolution of the list from a 3 year registration period, to five years and now the CRTC’s proposal to make it permanent.

In Telecom Public Notice 2008-14, the Commission requested comments from interested persons as to whether registrations of telecommunications numbers on the National DNCL should be made permanent. In Telecom Regulatory Policy 2009-200, the Commission concluded that, if registrations on the National DNCL were made permanent, an efficient and cost-effective process would need to be established to remove disconnected and reassigned numbers from the National DNCL.

A CISC group determined that “the necessary processes and procedures for permanent number registration would be extremely time consuming, costly to implement, and unnecessary.” The CRTC engaged a US consultancy to assess the processes and concluded “that permanent number registration with a process to remove disconnected and reassigned numbers is not feasible on an efficient and cost-effective basis.”

But, the CRTC says that the National DNCL is popular with Canadians, citing a 2011 Privacy Commissioner survey that indicates 7 out of 8 Canadians surveyed “were concerned or somewhat concerned about organizations sending unwanted emails, faxes, letters, or telephone calls.” So, the CRTC is of the preliminary view that we should make DNCL registration permanent anyway.

I understand the attraction, but have to wonder if there should be more understanding about how such measures fit with a national digital economy strategy.

After all, sales people can knock on your door; companies can buy mailing lists and sent unsolicited addressed paper mail or drop flyers off at your door (or thrown on our driveways and lawns). Why are these forms of unsolicited old-media communications not being banned, but we seem to have no trouble erecting barriers to similar forms of communications using electronic media?

Has there been sufficient exploration of the impact of such measures on the development of Canada’s digital economy?

Ever since I lived in Denver 25 years ago, I have been a Broncos fan.

The NFL season so far this year has been a treat for me, with Peyton Manning providing weekly clinics in quaterbacking skills. One of the benefits of his no-huddle offense is the ability to get the next play started before the opposing coach has a chance to throw a “challenge flag” on the previous play.

More than once, the Broncos have benefited from blown calls on the field that would have been overturned by the replay official if given the chance.

For a couple months now, I have been suggesting that we need to take a deep breath, and take stock of where we are before rushing ahead with more intervention in Canada’s wireless market. Michael Geist, alluded to my posts, but apparently he wants us to go no-huddle:

we can expect calls to delay any further policy action until there are further studies or opportunities take stock [sic] of recent developments.

In this case, the government need not hand the incumbents another victory by delaying much-needed policy reforms.

But last night, I spotted flawed data in the CRTC’s Communications Monitoring Report. The data makes it appear that Canada’s mobile data networks are among the world’s slowest, when the truth is that they are among the world’s fastest. What kind of flawed policy can emerge if we follow his recommendation to run the next play before checking with the replay official.

We need to get wireless policy right, not rush ahead based on incomplete and incorrect information.

I’m throwing the challenge flag.

Back in April, the House of Commons Standing Committee on Access to Information, Privacy and Ethics issued its Fifth Report, entitled “Privacy and Social Media in the Age of Big Data“. Among its recommendations was a soft one on Digital Literacy: “The Committee recommends that the Government of Canada continue to provide support to digital literacy programs.”

Last night, I saw the government’s response to the report:

Digital literacy and skills are at the core of what is needed for individuals to succeed in today’s online economy. In this regard, the government makes significant investments in skills development programs, including those that target digital literacy. For example, Budget 2011 announced that Human Resources and Skills Development Canada (HRSDC) would reallocate $60 million to support digital skills and enrolment in key disciplines, including science, technology, engineering and mathematics (STEM).

A number of important initiatives arise from the Budget 2011 reallocation. For example, Skills Link is dedicating up to $10 million annually over three years (2011–14) for projects to support digital skills development among disadvantaged youth. Digital Jobs of Tomorrow has received nearly $1 million for a project carried out by the Canadian Coalition for Tomorrow’s ICT Skills, a group of information and communications technology (ICT) industry leaders, in conjunction with the Information and Communications Technology Council (ICTC). In 2011, the project launched the CareerMash website and career awareness activities for schools and students to promote ICT career awareness. HRSDC also provided both core and project-specific funding to the ICTC to contribute to the development of a digitally skilled workforce and improved ICT labour market intelligence.

As well, up to $4 million over two years was committed for a digital skills competition to improve awareness of ICT-related education and training programs, while $9 million of the HRSDC Skills and Partnership Fund is being invested over three years to encourage and support the training and employment of Aboriginal people in the ICT sector.

In its March 28, 2013 Response to the Report of the Standing Committee on Human Resources, Social Development and the Status of Persons with Disabilities, entitled Labour and Skills Shortages in Canada: Addressing Current and Future Challenges, the Government of Canada stated that ensuring that Canada has the skills and labour force it needs now and in the future is one of the greatest socio-economic challenges facing the country. It further recognized that this will require not only concerted action, but also innovative thinking, approaches and partnerships. In view of this, as announced in Economic Action Plan 2013, the government is taking steps to address these labour market challenges by partnering with provinces and territories, employers and other stakeholders to target skills development investments in high-demand areas.

The Response also recognized the shared responsibility for Canada’s labour market success, which requires multiple stakeholders to play important roles in this respect. Provinces and territories, which are responsible for education, have a central role to play in developing digital literacy and skills. The government will continue to work with its provincial and territorial partners to develop tomorrow’s digital workforce.

The Government of Canada is committed to protecting the privacy of Canadians and fostering an environment that will enable individuals and businesses to participate, innovate and contribute to the growth of the digital economy.

Are we making progress on the release of a comprehensive digital strategy?

When I studied statistics, we were told to look for “outliers” – results that appeared to be inconsistent with the rest of the data. If an observation is a potential outlier, you begin an analysis to determine whether a cause can be identified for the spurious result.

So, in the CRTC Communications Monitoring Report, Figure 7.1.8 has a curious, if not spurious result in its representation of mobile broadband average measured speeds in various countries.

Canada shows a measured speed in 2012 of just 1.1Mbps, a decrease from 2011 that observed 1.2 Mbps. So, despite the expansion of faster networks – the CRTC press release mentioned that LTE was available to 72% of Canadians, up from 45% – Figure 7.1.8 shows observed speeds declining. One might have expected the speeds to be increasing.

That struck me as an outlier meriting further analysis.

I went to the Akamai source document to see what might be the cause. It turns out that Akamai – and therefore, the CRTC – only had one carrier represent Canada for its characterization of mobile broadband speeds. The carrier is identified as CA-2. It may not be one of the major carriers, since Akamai discards results from carriers that mix their fixed broadband and wireless traffic:

Data is included only for networks where Akamai believes that the entire Autonomous System (AS) is mobile—that is, if a network provider mixes traffic from fixed/wireline (DSL, cable, etc.) connections with traffic from mobile connections on a single network identifier, that AS was not included in the source data set.

It appears that the rest of the CRTC table uses the observation from just one carrier from countries that have multiple service providers in the Akamai report, not the average of the observed speeds. For example, Akamai shows the following average kbps for Germany in its 3Q12 report: Germany DE-1 1543; Germany DE-2 4985; Germany DE-3 2094. The CRTC appears to list the result for DE-2 only.

Figure 7.1.8 appears to be an outlier that needs further analysis.

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Update: US Telecom, formerly known as the United States Telephone Association, has just published an analysis of Internet traffic data and it is worth reading as we examine international telecom performance.

Two graphics in particular caught my eye: