Last week, comments were filed with the FCC in response to the Berkman study of international broadband comparisons.

Recall that last month Harvard’s Berkman Center for Internet and Society delivered its draft broadband study, commissioned by the FCC to assist in the development of a National Broadband Plan through an expert review of literature.

Many of the comments were not supportive of the Harvard Berkman study.

In an earlier blog posting, we had observed that there appeared to be statistical problems in the Berkman study that would not hold up to peer review. Our comments may have understated the extent of the problems.

The Phoenix Centre said that the Berkman study was “so flawed that it cannot be relied upon to formulate public policy”:

the Berkman Study first improperly estimates its econometric model and then incorrectly interprets the results from it. The error in the interpretation is significant. While the [Berkman] Study’s authors verbally conclude that open access policies stimulate increased consumption of broadband, the econometric model they rely upon shows the opposite – open access reduces the consumption of broadband.

The Phoenix Centre also said

[Under the Berkman Study’s analysis] the supply curve is downward sloping! This result implies that as broadband prices rise, network operators supply less broadband. Intuitively, this result makes little sense, violates the law of supply, and muddles interpretation.

Oops.

NTT weighed in to correct errors in Berkman’s analysis of the Japanese market – errors that it said could have been avoided had the authors of the Berkman study interviewed NTT.

First, facilities based competition, not unbundling, has been the key to broadband growth in Japan.
… Second, the report mistates the importance of ‘government-subsidized loans’ to the success of broadband deployment in Japan.
… Third, the Berkman Center’s draft study is internally contradictory.
… In sum, the review of broadband facilities and regulation in Japan contained in the Berkman Center draft study is both factually incorrect and internally inconsistent.

Verizon’s comments said the Berkman study largely ignored the body of literature that demonstrate that unbundling and mandated open access policies have not only failed to improve broadband performance, but frequently have had the opposite effect.

In particular, study after study has shown that government policies such as subsidizing the development of broadband infrastructure and a range of demand-side factors from population density to computer ownership – not the preference for unbundling over intermodal facilities-based competition – are the primary factors explaining the successes of some other countries.

Many of the comments observed that the Berkman study ignored its mandate: to conduct an independent expert review of existing literature and studies about broadband deployment and usage throughout the world.

The New Zealand Institute for the Study of Competition and Regulation, based at Victoria University of Wellington, observed that the Berkman report does not contain an explicit review of the large body of literature on policy and broadband market performance from academic and peer-reviewed sources – fewer than 10 of the more than 400 referenced citations were derived from papers in this body of literature.

The New Zealand submission raised “questions about the standards of competence and integrity applied to this aspect of the Berkman analysis, and by extension to the entire project.”

Johannes Bauer, of Michigan State University’s Department of Telecommunication, Information Studies, and Media was less harsh, but said:

The Commission should take the evidence provided in the study into consideration but be keenly aware of the limitations of the study. Furthermore, caution is appropriate when transferring lessons from abroad to the US. Not only is the market environment different, the institutional, legal, and regulatory environments also differ from those of other countries. Not all observations from abroad can be transferred to national contexts

NCTA was quoted saying “The Berkman Report, in short, is an advocacy piece, not the work of dispassionate scholarship that the Commission requested.” The Broadcasting & Cable news story said that would make it antithetical to FCC Chairman Julius Genachowski’s stated aim of having data, not ideology, drive conclusions.

Other collections of quotes can be found [here].

Recent press releases and advertisements speak about the high percentage of Canada’s population that has access to new advanced mobile wireless services.

I think it is remarkable that such a substantial majority of Canadians, close to 95% of us, fall within the HSPA and HSPA+ coverage. Looking at the competing network maps, we can see that most Canadians are already able to choose between multiple carriers for mobile voice and data services offering speeds that rival and often beat wireline access.

But a closer examination of the maps shows that, while the majority of the population is covered by mobile wireless networks, there is a vast part of the country that is beyond the reach of terrestrial towers.

About 2M Canadians live and work outside the coverage, and many other Canadians sometimes venture out of their urban and suburban comfort zones to go play.

On September 11, 2009, Rick Stephens and his hunting partner, Trent Bossence, were 7 days into a 12-day hunting trip in the Coast Mountain Range of Northern British Columbia. They were 85 miles from the nearest town, Dease Lake and four miles from their base camp, when Rick’s hunting knife slipped and he cut his leg just below the knee, severing a tendon.

We tried to treat my injury and prepare for what we thought would be a long cold night on the mountain. But I happened to have a SPOT Satellite Personal Tracker so Trent was able to instantly send a 9-1-1 message and our GPS location coordinates.

Within 2½ hours of the signal being sent, the rescue team located Stephens and his partner and airlifted them off the mountain. Since it was introduced, the SPOT Satellite Personal Tracker has initiated more than 450 rescues and sent over 10 million check-in and tracking messages around the world.

I have written before about satellite as an important part of the solution for universal broadband service for Canadians in their homes and offices to Canadians who are beyond the reach of terrestrial networks.

Similarly, Globalstar‘s SPOT tracker enables a mobile lifeline for people who venture off the beaten track. The device itself is affordable and its service subscription is only $100 per year.

With Christmas a month away, this look like a perfect gift for camping, hunting and hiking enthusiasts. I suspect that those who have boats in cottage country might consider this as part of our on-board safety equipment.

Industry Minister Tony Clement and his Israeli counterpart, Binyamin Ben-Eliezer, have committed to negotiate a Mutual Recognition Agreement (MRA) to ease the importing and exporting of telecommunications equipment between Canada and Israel.

Such agreements are already in place with the European Community, the European Free Trade Area countries, Switzerland, members of the Organization of American States and members of the Asia-Pacific Economic Cooperation forum.

An MRA will broaden trade opportunities for Canada’s telecommunications industry and provide access to Israel’s latest communications technology for Canadian industry and consumers. I look forward to having Canadian and Israeli officials meet to begin negotiating the MRA for telecommunications equipment.

Industry Canada officials are expected to travel to Israel early in 2010 to begin negotiating the MRA.

For the past two years, Israeli telecommunications firms have been actively participating in The Canadian Telecom Summit and a number of these firms are already actively working with Canadian service providers and manufacturers.

The 2010 Canadian Telecom Summit will take place June 7-9, 2010 in Toronto. Planning has already started and registrations are open.

Mark the dates in your calendar and be there!

Industry Minister Tony Clement gave parties until today to submit comments on the CRTC’s finding last month that Globalive does not comply with Canadian ownership requirements under the Telecom Act.

Why do I keep thinking of Calvinball when I read about the continuing twists and turns regarding the rules for the licensees from our last mobile spectrum auction?

Here is how Wikipedia describes the game, which was introduced about 20 years ago in the comic strip Calvin and Hobbes:

The only consistent rule is that Calvinball may never be played with the same rules twice. Scoring is also arbitrary, with Hobbes reporting scores of “Q to 12” and “oogy to boogy.” The only recognizable sports Calvinball is similar to are the ones that it emulates (i.e., a cross between croquet, polo, badminton, capture the flag, and volleyball.) Equipment includes a volleyball (the eponymous “Calvinball”), a soccer ball, a croquet set, a badminton set, assorted flags, bags, signs, and a hobby horse. Other things are included as needed, such as a bucket of ice-cold water, a water balloon, and various songs and poetry. Players also wear masks that resemble blindfolds with holes for the eyes. When Rosalyn asked Calvin what the reason for the requirement was, Calvin responded, “Sorry, no one’s allowed to question the masks.”

When asked how to play, creator Bill Watterson said, “It’s pretty simple: you make up the rules as you go.”

Calvinball is not the kind of game that the investment community will want to play. The government agencies (CRTC and Industry Canada) can’t be seen making up the rules as we go. That is why I told the Canadian Press that I don’t think the CRTC decision will be overturned.

Still, there is one aspect that the CRTC left a door open for policy guidance in its decision, as I suggested last month. There was an ambiguity in Paragraph 118 of the Decision in respect of the allowable amount of debt that could be held by a non-Canadian company.

The Industry Minister might pronounce on this particular point – providing clarity and flexibility – without tearing apart the integrity of foreign ownership restrictions.

Globalive is one of a number of new mobile spectrum license holders. Industry Canada needs to ensure that the rules are clear for all of the industry participants so that we can get on with the game.

Putting thoughts on the internet can sometimes lead to a life of being sorry.

The global village means that your tweets or random musings on a blog get broadcast around the world. Most of the time, you can’t un-ring the bell.

Employees need to be mindful of this when ranting against their employers. It is one thing to kvetch to your spouse over dinner. It is quite a different matter to go viral with it.

We have heard this before and we try to warn our kids to practice safe texting, but this is not just a problem for the young and naive among the citizen media corps.

Mainstream media organizations have challenges dealing with errors on internet news sites. Print versions of newspapers and magazines can issue corrections that reach most of the readers of the original story. How does a correction get distributed fairly in new media?

It is much tougher to counter false impressions left by factual errors in an internet environment. Although corrections may be added to a revised version of the original story, most readers don’t return.

A variety of degrees of a common problem – how do you retract what you wish you had not said?

How do you un-ring the bell?