I am a fan of the Denver Broncos. We lived in Denver for about a year and had a chance to attend a number of games at Mile High Stadium. My son wanted us to invite John Elway over for a family dinner.

For the past 16 years, we have had a Super Bowl party, a tradition that was started by the Broncos back to back Super Bowl victories in January 1998 and 1999.

This year has been a great year for Broncos fans, but Denver games don’t seem to be available on the Toronto stations often enough. Fortunately, I have had a chance to test drive Bell Mobility’s Mobile TV service, which includes access to a number of NFL channels, including Red Zone.

I have often wondered why someone would watch TV on a 4 or 5 inch screen, when so many of us are getting spoiled with enormous high definition pictures at home. Last Sunday, I became a believer in Mobile TV. I was at the airport, waiting for a flight to spend New Year’s in Pasadena at the Rose Bowl. I really wanted to know if Denver would win their division and follow Adrian Peterson’s quest to break the rushing record. Thanks to Bell’s demo device loaner, I was able to watch the action in amazing high definition. Yes, it is only a 5 inch screen, but it was only 9 inches from my eyes.

As an aside, NFL Red Zone is a channel that was clearly designed for an attention deficit generation, but it is perfect for mobile TV.

A little over a year ago, I wrote that I disagreed with the CRTC’s decision to forbid mobile content exclusives. The CRTC said at the time:

Canadians shouldn’t be forced to subscribe to a wireless service from a specific company to access their favourite content. Healthy and fair competition between service providers will promote greater choice for Canadians.

I continue to believe the Commission got that decision wrong. I am not talking about vertical integration issues; if TELUS (as a mobile services provider with no affiliated broadcasters) had been the carrier that won the bidding for the NFL content, would the CRTC decision still be seen as correct?

I think that exclusives can drive more innovation, which promotes increased choice for Canadians. If a given type of content is so compelling that Canadians switch service providers, won’t this force the other service providers to respond? Either they have to find some other content or feature to offer, or drop their prices. Isn’t that in the consumer interest? Did the CRTC’s decision reduce the incentives for innovation?

If service providers all offer the same flavours of features and content, how does this promote greater choice?

Mobile TV isn’t going to replace my basement big screen, but I have new appreciation of its role on Sunday afternoons. There are a lot more channels beyond football, including new mobile access to Bloomberg TV business news. I’ll have to try out some of the other channels – but not on Sunday afternoons.

It is the beginning of a new year. A chance to make a fresh start.

So perhaps, it is time for us to take a fresh look at a long overdue file, the national digital strategy.

In the absence of a formal national digital strategy statement, it is hard to point to any catastrophic failures in our ability to compete relative to the rest of the world. But that is hardly an encouraging statement of leadership in this era, is it?

Although some like to point to the availability of ultra high speed internet access services in other markets, Canadians are leaders in adoption of social media and spend more time online than others. Canada’s software industry is faring well especially in gaming development and we have a strong application development sector. And the fact remains that most Canadians have access to broadband speeds well in excess of 100 Mbps.

Still, we can do better.

Many people, including many in government, confuse a digital economy strategy with a need to hand out cash for digital infrastructure or other forms of government spending.

I disagree. Releasing a strategy does not need to cost billions of dollars, despite the political attractiveness of a handshake in front of a ceremonial over sized cheque.

As I have written numerous times, the private sector has already been investing in infrastructure to deliver the supply side of the adoption calculus. While digital services adoption is a metric that is commonly used in global rankings, most people seem to focus on only one variable in the calculation. As a result, we have seen billions of tax dollars thrown toward broadband infrastructure in remote regions, with ever diminishing returns. The latest program saw close to $10,000 per household in subsidies, having the effect of permanently disrupting the business case for competitive supply of services.

Government handouts for internet access services should not be part of a digital strategy. Over the years, you may have seen that I am not a fan of most kinds of corporate government handouts.

So what is it that I am looking for?

I would like to see increased activity to promote demand. We need programs to ensure that low income Canadian households have affordable access to a connected home computer. It was nearly 5 years ago that I first suggested that we should consider computers and connectivity as part of Canada’s social safety net. Five years later the need is even greater. A little over a year ago, Greg O’Brien spoke of the embarrassment of relegating so many low-income Canadians away from digital participation.

We need skills development programs to increase the comfort that all Canadians have getting on-line. We need to ensure that all Canadians are able to access government services on-line.

Over the past year, more banks and utility companies started to charge fees to receive a paper bill. As a result, Canadians who can’t afford a computer or internet connection are precisely the ones getting hit with additional monthly charges. That doesn’t seem right.

We can do better.

In 2012, we saw the federal government launch red tape reduction programs, while at the same time preparing to proclaim an overly burdensome anti-spam law. The problem I have with Canada’s anti-spam law is that it goes well beyond stopping spam and will have the effect of inhibiting adoption of digital technologies by small business. A new restaurant or neighborhood business will not be permitted to buy an email mailing list to announce its opening, but can still print thousands of flyers to get dropped off by the post office. Does this make sense? The anti-spam law was prepared without an overall digital strategy and as a result, it contains provisions that over reach, that go beyond targeting spam and extend to restrict electronic commerce.

We can do better.

As we develop digital strategies. we need to make sure that existing programs that allocate funds for Canadian media development continue to be sustainable in a globally interconnected on-line world.

The digital economy strategy consultation was launched with great promise, uniting 3 government departments: Industry, Heritage and Human Resources & Skills Development.

It doesn’t take billions of dollars to enact a digital strategy, but it does require a commitment to follow a path once the strategy is enunciated. We need to start with take a vision statement that makes clear what we want a Digital Canada to look like – and then ensure that we engage in activities to lead us toward that goal.

That is what I want to see. As a country, we can do much better to lead in a digital world.

Is that asking for too much?

As we wrap up another year, I have started to move tasks forward on the calendar and did a little bit of a self performance appraisal.

I have written 139 blog posts over the past year. While some of those may have been able to stimulate some further thought and discussions, I am disappointed in myself for not doing more to accomplish my personal objectives.

I failed at my 2012 new year’s resolution to get a connected computer into every household in Canada with school aged children.

More than ever, I am convinced that kids need a computer at home to be online with their classmates, to access the resources to succeed in school today and to have a chance to participate in a digital Canada. I pledge to do more in the year ahead.

I also want to lose 20 pounds.

I wish all of you a safe, healthy and peaceful holiday season.

I look forward to engaging with you in 2013. Together, hopefully we can exceed all our targets.

The CRTC is in the middle of a consultation on the development of a Wireless Code of Conduct. It asked the public for comments to be submitted by December 4, using two different methods: the usual submissions process; and, a special online consultation which are saved separately (French on-line comments are separate from the English). Reply comments are due on December 18 – a week from today.

The comments from the online consultation do not show up on the listing of the hearing documents. As a challenge, try to find the link to the on-line consultation by navigating the CRTC website without using the links I provide above. I cheated by using an old tweet from @CRTCeng.

There were 1043 comments filed as part of the usual submissions process. I can’t figure out how these comments will be reviewed. Assuming you succeed in accessing the full table listing the comments, each of the 1043 records requires a click on the “Related Documents” link, which opens a page dedicated to that record, in turn requiring another click on the “Comments” link. In Internet Explorer, this may offer a choice to open the submission or save the file, but many other browsers only offer to save the file, even though many are in html format. The document names (such as “1246y01!.HTML”) are indecipherable, not related to the proceeding nor the party submitting the comment.

In 2012, a single click should let us to view an HTML file without first having to download it.

Despite its invitation to Canadians to participate in the creation of a meaningful code for the wireless industry, I am concerned that the inaccessibility of the CRTC’s website creates an obstacle for citizens who want to follow along. I wonder if even the carriers will have the resources to download and review all of the interventions in time to submit a reply next week.

While a number of token interventions may be read into the record by the CRTC Chair at oral hearings, the inaccessibility of the CRTC’s database means that in practice the comments of Canadians may not be given the appropriate level of consideration by the people crafting the code.

Quick action is needed by the CRTC to make its website more accessible in order to keep the confidence of consumers that their voices are being heard and that their concerns are able to be considered. As a start, there should be a link to the online consultation discussion in the listing of hearing documents.

MP Marc Garneau released a policy statement on telecommunications this morning.

Unfortunately, it is hard to see changes coming, based on the information released so far.

It was somewhat disappointing to see flawed analysis of Canadian wireless prices in the OpEd:

According to the CRTC’s latest report, Canadian wireless revenues, measured as the monthly average revenue per user (ARPU), are the highest in the G7. At $55 per month per mobile subscriber, Canadians pay 20 per cent more than users in the US, 70 per cent times more than users in France, and 100 per cent more than users in the UK and Germany.

ARPU is not a measure of prices. I spend more each month at Costco than I do at Canadian Tire; does that information indicate which has the lowest prices?

Mr. Garneau wants to further liberalize foreign ownership restrictions on telecom carriers, but continue to retain restrictions on broadcasters:

I would maintain restrictions on foreign ownership in broadcasting because of cultural and content implications to ensure continued production and broadcast of Canadian shows and content for television, film and new media.

Why would production funding and Canadian content requirements apply differently to a TV or radio station that happens to have shareholders outside the country?

More importantly, exactly which telecom carriers would benefit from further liberalizing foreign ownership, if we still restrict ownership under the Broadcast Act, given that virtually all telecom companies are licensed under the Broadcast Act as well? At a minimum, it might help to shift the broadcast distribution licensing regime under the Telecom Act. This would allow the cable and IPTV operations of carriers to be foreign owned without “risking” foreign control of our airwaves.

The good news is that telecommunications policy and the digital economy have made it onto the radar screens of Liberal party leadership candidates, as I wrote last week. We will watch for more details as the campaign continues.