A number of times over the past two years, I have promoted the webinar series from the International Telecommunications Society. There is a very special session coming up in a few weeks, and I encourage you to register early.

Vint Cerf, one of the leading creators of the earliest foundations of the internet, will be speaking about “The Future of the Internet”, looking at policy issues that have arisen with the growth of the internet and its new applications, and looking ahead to the future impact and implications of the online world.

The session is being hosted by TELUS and Munk School of Global Affairs and Public Policy at the University of Toronto.

The future of the internet is the future of humanity. What was once a tool, is now an inescapable part of our lives and livelihoods. It is ever more ubiquitous and complex, consistently creating challenges for which there are no easy answers. From fake news and deepfakes to privacy and data protection, the internet has created wicked problems alongside its immense potential to continue transforming humanity.

Where once the job of an internet evangelist may have been to persuade people of the value of getting online, now their job is to persuade us that the torrent of online challenges is not only surmountable, but that the answer is more connectivity, not less.

The one hour session will take place at 9:00am (Eastern) on April 12, 2022 and there is no charge. Register today!

A significant challenge faced by first responders at an emergency is maintaining connectivity in situations where there are large crowds or large groups of people accessing public wireless networks at the same time, such as during the Toronto Raptors victory celebration. In such circumstances, network congestion can impede access to first responders transmission requirements.

Traditionally, first responders built and managed their own private networks, using dedicated frequencies, with customized mobile devices, in order to take ownership of delivering reliable connectivity.

Although the Government of Canada has set aside billions of dollars worth of spectrum dedicated to the development of a public safety mobile broadband network, those valuable frequencies have been left to lay fallow for more than a decade. [See: Moving Too Slow On Public Safety Communications]

Why?

A little over 6 years ago, I wrote “Public safety in the public networks”, suggesting “a public safety broadband network, developed as a virtual application within existing public broadband networks would be even more robust, more reliable, more resilient than a private, dedicated network.”

This past weekend, I learned about Rogers First Priority Service for First Responders, “which provides a secure, prioritized data channel between emergency personnel and their organization’s office or headquarters, seamlessly connecting them to the vital information they need via their devices and emergency vehicles.”

Priority voice services have been in place for years, providing public safety personnel and government decision makers dedicated access to in emergency situations. But the times—and technology—have evolved. With more information available than ever before, first responders need a reliable way to transmit and receive vital, potentially life-saving data.

Enter First Priority Service from Rogers, which provides a secure, prioritized data channel between emergency personnel and their organization’s office or headquarters, seamlessly connecting them to the vital information they need via their devices and emergency vehicles.

As the name implies, First Priority Service prioritizes the reliable wireless network access public safety agencies need to optimize their communications and response times.

Canada’s public mobile networks have proven to be world leading in speeds, reliability and coverage, supported by billions of dollars of ongoing annual capital investment, managed and maintained by thousands of skilled professionals deployed throughout the country.

A virtual network approach is the right way to deliver public safety communications. Technology enables the robust public network to allocate a secure, prioritized channel to ensure uninterrupted connectivity for first responders, with reliability and coverage that would take tens of billions of dollars to replicate in a private network.

At the federal level, officials need to examine how they permitted such valuable spectrum to remain unused for so long. Recall, in his mandate letter this past December, the Prime Minister said to Minister Champagne, “Accelerate broadband delivery by implementing a “use it or lose it” approach to require those that have purchased rights to build broadband to meet broadband access milestones or risk losing their spectrum rights.”

There is a big swath of prime spectrum, in a band valuable for rural broadband delivery, sitting unused.

In my view, it is long past time for first responder agencies to review their communications service strategies. Perhaps the Spectrum Branch at ISED can help accelerate that review.

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[Update: March 24] Public Safety Canada has just posted “A Public Safety Broadband Network (PSBN) for Canada” [pdf, 3.2MB]

I wrote “The truth about structural separation” last May, describing the interaction between a Member of Parliament and TELUS COO Tony Geheran during a meeting of the Parliamentary Standing Committee on Industry, Science and Technology (INDU) that took place a year earlier.

Mr. Geheran said, “I haven’t seen [structural separation] work anywhere globally, to sustainable effect,” to which Calgary-Nose Hill MP Michelle Rempel Garner replied, “It’s in the UK, right?”

Mr. Geheran responded, “But if you look at the UK, they are wholesale moaning about the quality of their infrastructure, their lack of fibre coverage. across what is a very small geography. I know. I originated from there. And quite frankly, the Canadian networks are far superior in coverage and quality and performance through COVID has demonstrated that.”

Recently, that committee adopted a report, “Affordability and Accessibility of Telecommunications Services in Canada: Encouraging Competition to (Finally) Bridge the Digital Divide” [pdf, 3.4MB], that had been released by the Committee during the previous session of Parliament. I found it interesting that the Parliamentary Committee report did not recommend studying structural separation, despite a specific call for such a strong competitive safeguard from at least one of the witnesses. However, in its more recent report examining the Rogers – Shaw transaction [pdf, 3.1MB], that same committee suggested studying the matter further:

Recommendation 1: That the Government of Canada launch nationwide consultations to examine the implementation of structural separation in the telecommunications sector between businesses that build infrastructure and those that provide services in order to ensure a level playing field that fosters network development in both cities and rural areas.

As it turns out, the CRTC has already held nationwide consultations that examined proposals such as structural separation. In 2015, as part of its review of wholesale wireline services, the CRTC examined a CNOC proposal to implement an “Equivalence of Inputs” regime, a very basic form of structural separation, “such that any wholesale service offered by an incumbent carrier to a competitor be provided at the same price, quality, terms and conditions, and timescale, using the same systems and processes that incumbent carriers’ use in their wholesale operations to supply their own retail operations”. The Commission rejected the proposal, saying it “would represent an overly intrusive regulatory measure, which would neither be efficient nor proportionate to its purpose“.

As a regulatory measure, structural separation has rarely been used in wireline broadband markets, and only where there is a single dominant network operator. To my knowledge, it has never been used in the wireless industry.

Unlike some foreign markets, in Canada there is no single network with a dominant presence. For example, in the UK, BT agreed to separate its wholesale and retail operations into separate business units after the regulator concluded that it had a natural monopoly over phone and broadband infrastructure in the UK. In other words, if you wanted phone or broadband services, you had to use the BT network.

In contrast, Canada’s wireline and wireless broadband networks are provided by multiple national and regional wireline and wireless service providers. As discussed recently in “Truthiness and Canada’s Telecom Industry”, Canada has the least concentrated broadband market in the G7 plus Australia. Upon which network would separation be imposed?

Just as proponents of mandated wholesale MVNO access have been pushing for a wholesale model that has been tried and largely abandoned elsewhere, proponents of structural separation are pushing another form of regulatory intervention that has fallen out of favour.

As described in Federal Communications Law Journal [pdf, 2.9MB], “Concerns about the potential for such disruptions [in economic efficiencies]–combined with recognition that the more extreme forms of separation potentially are irreversible-have led most regulators to back away from mandatory separation, or to view it as a “last resort,” to be used only in cases of extreme and otherwise irremediable discrimination.” The authors indicate that separation “may discourage the introduction of new networks, thereby reducing economic welfare and harming consumers.” Further, “the available evidence fails to support the proposition that mandatory separation improves market performance, but this evidence does suggest that such a policy leads to reduced levels of innovation and investment.”

Reduced levels of innovation and investment would fail to deliver the Parliamentary Committee’s stated goal of “[fostering] network development in both cities and rural areas”.

Canada needs regulatory policies that create incentives for more investment and innovation, not less.

Structural separation isn’t a solution.

Canada’s future depends on connectivity.

Last week, the Government of Ontario announced new legislation “to help bring reliable high-speed internet to underserved and unserved communities sooner.”

The “Getting Ontario Connected Act, 2022” is said to help meet “[the Ontario] government’s commitment to connect every community with access to high-speed internet by the end of 2025.” The legislation “would remove barriers, duplication and delays, making it easier and faster to build high-speed internet infrastructure across the province.”

I note that the proposed Act is a supplement to the Supporting Broadband and Infrastructure Expansion Act, 2021 and the Building Broadband Faster Act, 2021, which were said “to reduce costs to broadband providers associated with attaching broadband wirelines to hydro utility poles, and … provide timely access to poles and to municipal rights of way to install broadband on municipal land.”

Why would 3 separate pieces of legislation over the past year be required for Ontario to accelerate broadband deployment?

The latest piece of legislation is supposed to help accelerate the work of Ontario One Call’s “locate service”, the “call-before-you-dig” service bureau that can be a significant roadblock for companies looking to plow fibre. But a year ago, Ontario was already looking at making it easier for companies to access poles owned by provincially regulated electric companies. At the same time, Ontario said that the legislation was setting a maximum of 10 days for owners of underground infrastructure to provide locations through the Ontario One Call system.

On first glance, the need for the most recent legislation should have been anticipated last year, had appropriate planning or industry consultations been undertaken prior to the drafting, or at the very least, in committee review of the bill.

With all of the activity underway across North America to extend broadband to underserved areas, it has been a challenge sometimes for service providers to find qualified construction companies and workers. As temperatures start to warm across the country, broadband construction season is beginning in Canada.

It is admirable that Ontario has been recognizing the need to clear the pathways for network operators to build facilities. Still, how many projects missed last year’s construction window because the 2021 legislation was inadequate?

How many more households could get access to better broadband more rapidly, and at lower cost, if more governments – at all levels – would recognize the importance of simplified access to publicly owned rights of way and passive infrastructure?

The following commentary appeared on Cartt.ca.

If you build it he will come.

Often misquoted as “If you build it, they will come”, the mantra from “Field of Dreams” has become a metaphor driving many business plans.

Unfortunately, reality shows that if you build it, whatever “it” may be, all you do is improve the chances for them, whoever “them” may be, to come.

The Field of Dreams business case philosophy has been a driving force behind many government broadband programs. Just get broadband built, people will sign up. Build broadband pipes into this community and knowledge-based workers will work from home. Build municipal fibre networks, and companies will relocate and expand. Employment will skyrocket.

Build it and they will come.

And if you subscribe to that view, what if we apply that philosophy to improve broadband adoption among low-income households.

We know that broadband adoption rates vary with income. Fewer low-income households have broadband connections than higher income households. According to Statistics Canada’s 2020 Canadian Internet Use Survey, 93.6% of Canadians have access to the internet at home. That sounds pretty good, but there is tremendous variability based on income: only 80.9% of Canadians in the lowest income quartile have home internet, compared to 99.6% in the highest income quartile.

Internet access cannot be considered a luxury. That’s why the overwhelming majority of low-income households have access to a wide range of heavily discounted broadband services, such as Rogers Connected for Success, TELUS Internet for Good, or nationally under ISED’s Connecting Families umbrella.

Unfortunately, we have learned that it isn’t enough to offer low-priced computers and $10 per month broadband. Indeed, as Georgetown University economist Scott Wallsten writes [pdf, 1.8MB], the FCC conducted studies associated with its Broadband Lifeline service testing “consumer responses to a range of issues, including preferences for speed, the effects of different levels and types of discounts”. Surprisingly, the FCC found “only about ten percent of the expected number of households signed up, even with the price of one plan set at $1.99 per month.” The research also found a significant avoidance of digital literacy training classes. “In one project, many participants were willing to forego an additional $10 per month savings or a free computer in order to avoid taking those classes.”

As we continue to make significant progress ensuring all Canadian households have access to broadband, we need to conduct more research to learn the non-price factors that are inhibiting people from connecting to the services at their doorsteps.

It isn’t enough to say that we built it; now we have to make sure everyone comes.