The timing is running out for the Cabinet appeals of Telecom Decision CRTC 2021-130: Review of wireless services that was released April 15, 2021. Some people refer to this as the “MVNO decision”.

According to Section 12(1) of the Telecom Act:

Within one year after a decision by the Commission, the Governor in Council may, on petition in writing presented to the Governor in Council within ninety days after the decision, or on the Governor in Council’s own motion, by order, vary or rescind the decision or refer it back to the Commission for reconsideration of all or a portion of it.

So, time is ticking. If Cabinet is going to vary or rescind the decision, or send it back to the CRTC for another look, it has to do so by April 15, 2022. For those keeping score of Cabinet appeals, the anniversary date for Telecom Decision CRTC 2021-181 is 6 weeks later, May 27, 2022.

On April 4, the mid-year report for CCTS (the Commission for Complaints for Telecom-television Services) indicated that complaints are down 26% over the past year. Mobile price reductions beat the government’s objective. A recent CRTC press release indicated that 53.4% of rural Canadians had access to the 50/10/unlimited broadband objective in 2020, up 7.8 percentage points (or a substantial 17%) from 2019’s 45.6%. The current regulatory framework is succeeding in delivering better service, at lower prices, with enhanced technologies and services available to even more rural and remote areas.

Will the government maintain its policies to encourage investment in communications infrastructure through facilities-based competition?

For nearly two years, Canadian government policy has said “Canada’s Future Depends On Connectivity”. Will Cabinet choose to stay the course?

Please forgive the amount of time that I have been spending looking at a proposal for the City of Toronto to build a municipal broadband network. I do not subscribe to the view that the world revolves around Toronto (how many Torontonians does it take to change a lightbulb?). There are some important issues being discussed concerning the role of government ownership of digital infrastructure that have broader application beyond the greater Toronto area.

As you read in my post last week, on March 30, the Executive Committee of Toronto City Council reviewed an update of plans for ConnectTO, a project that I have criticized considerably over the past year.

Fortunately, members of the Executive Committee shared my concerns and paused for what Councillor Pasternak called a “sober second look”, seeking a more comprehensive business case before allowing ConnectTO to move forward. Consideration of the project has been deferred to the May meeting of the Executive Committee.

While we all agree that internet connectivity is important in the twenty-first century, not every household will choose to subscribe. Councillors recognized that broadband connections are only one part of the equation; some people still need devices.

Through the Connecting Families initiative, as well as research from other countries, we have learned that price is not the only inhibitor for adoption of the internet in disadvantaged communities. It is worth noting that Connecting Families was enhanced yesterday to add higher speed options. Rogers Connected for Success offers a wider range of options starting at $10 per month for 25 Mbps, and Rogers includes unlimited downloads in each of its options.

The Executive Committee asked for more information, passing this motion:

That Executive Committee defer Item EX31.8 to the May 4, 2022 Executive Committee Meeting, to permit the Deputy City Manager, Corporate Services, and the Chief Technology Officer, Technology Services to submit a supplementary report on:

1. the further questions and issues raised at the Executive Committee meeting on March 30, 2022.
2. a time frame for developing a ConnectTO Business Plan, which will include:

   a. the short, medium and long term costs of building and maintaining the proposed networks;
   b. the end-user price and download/upload capacity that will be available through the City’s Municipal Broadband Network;
   c. proof of the City’s ability to create better access and pricing for high speed internet than established Internet Service Providers, when the city does not have existing infrastructure or funding;
   d. address how ConnectTO will gain access to apartment buildings that already have contracts with other Internet Service Providers;
   e. the number of Full Time Equivalent (FTE) staff required for the planning, implementation, and on-going operations and management of this project, in addition to the 1000+ existing Technology Services FTEs;
   f. evidence that price is the main factor that challenges the use of internet services in priority neighbourhoods, and not lack of computers, computer literacy, or other fears or concerns about internet use; and
   g. a statement of the metrics for success, including the anticipated number of new internet subscriptions from residents who previously could not afford and/or lacked access to high speed internet.

3. the justification for creating this new internet infrastructure, given that most buildings already have high speed internet, and affordable high speed internet plans are available to low income families with sufficient download/upload capacity for video streaming for classroom use.
4. a comparative analysis of short and long term costs, capital and operating, of existing service versus the proposed service; such cost analysis should separate the costs for service to city properties from service to residential communities and should also show the cost differences between using private sector providers for internet service versus City-owned and managed assets.

As I have said before, Toronto is certainly not a broadband backwater. It is one of the world’s most connected cities. Every single one of the buildings that were proposed for Toronto’s initial phase of a municipal broadband network already had high-speed internet available, and 41 of the 42 buildings had more than one facilities-based service provider offering those connections. As such, it will be a challenge for proponents of the municipal network to answer point 3 from the motion, “the justification for creating this new internet infrastructure, given that most buildings already have high speed internet, and affordable high speed internet plans are available to low income families with sufficient download/upload capacity for video streaming for classroom use.”

Those providers offer a range of heavily discounted services – as low as $10 per month – to households that need assistance. The issue of broadband adoption in Toronto isn’t a question of service availability; and, it isn’t a matter of service affordability. As an aside, contrary to what some speakers at the Executive Committee meeting said, the CRTC did not say that the minimum service for broadband connections should be 50 Mbps down, 10 Mbps up with unlimited data. The CRTC’s objective is for all Canadians to have such a service available to them, not necessarily for them to subscribe to such a service. In Toronto, there are no known gaps in meeting this objective.

As such, simply building a municipal network is not going to help get internet to more people in Toronto. Increasing adoption in Toronto cannot be addressed by investing in technology to build a redundant, municipally owned fibre network.

Toronto should focus more on the social service aspects, understanding the factors that inhibit adoption, and dealing with them on a case-by-case basis.

Point 2f of the Executive Committee motion alludes to factors other than price challenging the adoption of internet services in Toronto’s priority neighbourhoods, thanks the availability of affordable internet programs in those areas from Rogers and Bell. These programs also help make computers available at affordable prices.

Although training may be available to help with computer literacy, how do we tackle the fears or concerns about internet use, and help people gain a better appreciation for the opportunities enabled by a home broadband connection? This is a key area of understanding for all level of governments to improve.

Applying less technology and more social research is an area where the city and its academic partners could show real leadership moving forward.

Some technology problems just might be handled better without more technology.

Robert Ghiz, President and CEO of the Canadian Wireless Telecommunications Association (CWTA) was the closing keynote speaker for STAC2022, the annual conference of Canada’s Structure, Tower and Antenna Council, held online again this year.

Rob’s talks are usually packed with statistics and topical information about the wireless industry and its impact on Canadians and Canada’s economy, and today’s address did not disappoint.

He also spoke about the success of the Structure, Towers and Antenna Council as a relatively new organization, growing from 10 organizations at its inception in 2016 to more than 130 now. “What started as a small group of about 40 people is now a community of over 700 like-minded individuals who have a shared committed to tower safety.”

He discussed the transformative impact of 5G, and the role played by those specialized workers actually implementing these technology changes.

Why spend so much on 5G?

5G is not just an upgrade to 4G. It is whole new telecommunications system that will transform the way that Canadians conduct business, receive critical services like healthcare, and interact with one another. 5G will be the foundation for the digital economy and will be a key enabler for Canada’s economic recovery.
…
As the demand for mobile data increases, we need to adopt technologies that allow wireless networks to operate more efficiency. Equally important, our wireless networks must support other industries’ desire to use wireless technologies to make their operations and products more environmentally friendly.

As always, Rob provided an overview of the Canadian wireless industry, its positioning in the world, the importance of wireless infrastructure, and he looked at the current political situation in Ottawa.

In his talk, he spoke of the drive, commitment and passion of Canada’s telecommunications industry workers. I encourage you to watch it in its entirety.

Indeed, speaking of passion, it is worth mentioning that Rob is arguably the most passionate promoter of Prince Edward Island as an idyllic tourist destination as you start to venture out of your COVID-induced isolation. Since Rob only made a passing reference to some “colleagues from PEI” in the context of an answer to a question, I was left wondering if someone changed the colour of the gables on Anne’s house.

Hoping someone will visit the Island and send along a photo to reassure me.

The story is told of French scientists digging 100 meters beneath the streets of Paris and finding traces of copper dating back 1,000 years. The French came to the conclusion that their ancestors had a telephone network all those centuries ago.

Not to be outdone, English scientists excavated near the Tower of London to a depth of 200 meters, found ancient broken glass, and shortly afterwards, reported “English archeologists find traces of 2,000-year-old fiber-optic cable.” They concluded that their ancestors had an advanced high-tech digital communications network a thousand years earlier than the French.”

A week later, Israeli newspapers reported “After digging as deep as 500 meters in a Jerusalem marketplace, scientists found absolutely nothing. They concluded that 5,000 years ago, the ancient tribes of Judea were already using wireless communications technology.”

I thought of that story when I read a long overdue update on Toronto’s ConnectTO project.

In a report going to Toronto’s Executive Committee, we learn that 45 groups took a look at the City’s request for proposals to build more fibre in one of the world’s most connected cities.

Not a single bid was received.

Not one.

Bell wrote a letter [pdf, 260KB] to the Executive Committee, pointing out that Bell already provides fibre based service to 41 out of the 42 buildings that were in Phase 1 of the City’s planned broadband network. Of those 41 buildings, 24 of them (with 4,099 suites) already have the latest fibre to the suite; the other 17 (with 2,218 suites) have fibre to the node. Bell says that “The majority of the buildings not fully upgraded to FTTS are privately owned and any delays are due to delays in obtaining approvals from the property owner for upgrades to our services.”

And in the one building that does not have access to Bell’s fibre services, Bell says there is already access to high-speed broadband services from at least one other provider.

One would think that the City would have learned from this exercise that the issue is not one of establishing connectivity, but in driving increased adoption.

But, no. Like the misguided archaeologists in my story, the Report [pdf, 784 KB] to Executive Committee draws the wrong conclusions:

the following are nRFP lessons staff learned that helped inform the proposed way forward for ConnectTO:

1. There is little to no incentive for service providers to partner with the City in the absence of a commitment of capital or serviceable fibre infrastructure;
2. Dominant carriers own and control most last mile infrastructure. The capital investment required for new infrastructure by non-dominant carriers is significant and can’t be recouped through the low-cost subscriber pricing targets outlined;
3. The City’s focus on older buildings further limits partnership opportunities. The City’s vulnerable populations tend to reside in older facilities where cabling to them is largely legacy infrastructure owned by dominant carriers;
4. The addition of more City-owned fibre and duct in or near Neighbourhood Improvement Areas would provide more opportunities to engage non-dominant service providers, though older facility access may still pose a challenge.

Come on, now.

Isn’t it really obvious that the RFP failed because, as the report itself acknowledges, Toronto is already incredibly well served by competitive broadband networks. The buildings targeted under Phase 1 were already completed by the private sector, without the need for public funding or involvement.

It is worth noting that Beanfield also submitted a letter to the City [pdf, 45KB], observing that “A public sector entity is simply not setup to be an effective or efficient telecom company.”

I understand that the city wants to be seen helping disadvantaged citizens get online.

We all want that. Really.

It is why I have been writing about programs to target broadband for low-income Canadians for nearly 15 years.

In urban settings, especially in the City of Toronto, the problem isn’t one of connectivity; it is getting people to make use of connectivity that is already at their doorstep.

That is a social service and education problem, not one that should be headed by the City’s Information Technology chief.

Despite what may be the best intentions, ConnectTO is following an ill-informed, misguided approach.

Last month, I wrote “Creating A Better Reflection”, talking about the importance of having a diverse set of people working on problems, to ensure we ask the right questions, or solve the right problems, and to help us come up with the best answers.

As the annual meeting of STAC, Canada’s Structure, Tower and Antenna Council, STAC2022 continued, I had an opportunity to listen to the noon panel today, “Not Just Another Checkbox: A Reflection on Equity, Diversity and Inclusion (EDI) in the Workplace”. Mandy Walsh, National Account Manager at Gap Wireless, hosted Amy Derickx, an Employment, Labour & Equalities lawyer at Gowling WLG, reflecting on the meaning of diversity, the importance of inclusivity and creating a sense of belonging, and the impact on businesses.

“Equity, Diversity and Inclusion are complex concepts that are not set in stone. Our understanding of EDI will continue to evolve as we listen to those who do the work of EDI and to those who encounter barriers in our workplaces.”

As we understand “Equity” in terms of treating employees fairly, we need to consider that this does not mean treating employees the same. When thinking about equity, it is important to think about removing systemic biases that may result in unfair treatments, despite all being treated the same.

If “Diversity” is an action, then what actions can be taken? While some view diversity as a result of EDI processes; others see diversity as a first step.

Where inclusivity is social and cultural, how is this reflected in formal and informal organizational structures and policies? When “Belonging” is a feeling, does the organization have a culture of welcoming voices that have traditionally been dismissed? How can every employee play a role in ensuring these feelings emanate throughout the company? How do these elements combine to contribute to the business’ bottom-line in a positive way?

The speakers explored how many corporate policies, processes and structures were implemented in a different era, and require a complete overhaul to adapt to the kind of diversity and inclusion that reflect today’s workforces in Canada. “Structural change takes time to achieve and is usually met with resistance.”

The legal requirements for Equity, Diversity and Inclusion should be considered a ‘floor’; satisfying workplace legislation, whether provincial or federal, is a necessary, but insufficient condition for creating a truly inclusive environment. There are roles for employees and employers to play in creating the kind of diverse and inclusive workforce where everyone has a sense of belonging.

Emphasizing the drive for increased diversity, there is a session at the event on Wednesday entitled “50 Shades of Beige: Communicate with the Cross-Cultural Advantage”, with speaker Tina Varughese.

Embracing Equity, Diversity and Inclusion in our workforce isn’t just the right thing; it’s the smart way to run a business.