A less than rapid response stream

For the past couple of weeks, it seems that ISED press releases have been flowing on a daily basis, sometimes multiple announcements per day, announcing funding to support broadband investments in rural Canada.

In some cases, work will be completed this year. In other cases, (like this), the announcements indicate that construction will be completed by September 2022, nearly a year and a half from now.

Why such a long construction interval?

There can be a number of factors at play: availability of workers, the need for detailed needs inventories, mapping, engineering, ordering equipment, permits. All of these have to precede the start of actual construction, and in some areas, some activities simply aren’t possible at certain times of year.

In many parts of Canada – especially rural Canada – major construction is tied to the seasons. A few years ago, at The 2018 Canadian Telecom Summit, Bell Canada’s CTO spoke about the challenges of meeting the limited summer shipping window to prepare for arctic construction on Ellesmere Island. For other communities, fans of Ice Road Truckers know that some locations depend on shipping in the winter when lakes are frozen over.

The Rapid Response Stream for Canada’s Universal Broadband Fund was announced November 9, with applications due January 15. This stream set aside up to $150M for projects that could be completed before November 15 of this year. That is just 6 months from now. For many companies, that is already an awfully tight timetable to complete a project of any meaningful size.

Applicants had just 2 months to apply and nearly four months later, most of those applications have not yet been approved. Many won’t be approved. Surely, there are many that could have been rejected already and those applicants should have already been told.

I haven’t seen a scorecard on the program, but it might be a good idea for the government to produce one. It has been reported that 576 applications were received. Whoever is managing the program can hopefully let us know the key indicators being tracked:

  • how many of these projects have been approved,
  • how much of the budget have these projects consumed,
  • how many households are covered by the approved projects,
  • how many applications have been formally rejected,
  • how many projects have been completed,
  • how many households now have access,
  • how many households have subscribed.

What else would you track on your dashboard?

Time is running out. For the Rapid Response Stream to be “rapid”, remaining projects under the program will need to be finalized in the next few weeks, or it will be impossible to meet the November 15 completion deadline.

Watch for more projects to be announced, hopefully somewhat rapidly.

Census day: count yourself in

May 11 is Census Day in Canada. As Statistics Canada describes it:

Every five years, Canadians are invited to participate in the census to help paint a portrait of Canada’s diverse population and the places where we live.

The Census of Population provides high-quality information on key socioeconomic trends and analysis that helps Canadians make important decisions that affect our families, our neighbourhoods and our businesses.

The Census captures an important snapshot of Canada’s population, said to be painting “a detailed and comprehensive statistical portrait of Canada”. It yields high quality information to inform policy makers and planning for government programs and social services, infrastructure and investment from both government and private sectors, leading to better outcomes for all of us.

For most of us, it takes just a few minutes to fill out the short form. A quarter of us will receive a long form [or this version] that gathers more detailed information, such as family and demographic concepts, activities of daily living, immigration, ethnocultural diversity and languages, education, labour, commuting, and Veterans, income and expenditures, and housing.

When I did my graduate work in statistics, I chose a school in Ottawa because of Statistics Canada; many of the faculty at the time had close ties to the government agency and were world-leading statisticians. From them, I learned a lot about striving for excellence in data collection and reporting. Frequent readers know that I often decry some of the embarrassingly poor quality of analysis masquerading as reports on the digital economy.

I am much more inclined to rely on Statistics Canada for information gathering. Three months ago, I wrote “Better data leads to better decisions”, talking about Statistics Canada new telecommunications data portal. It is continuing to be enhanced with even more data and high quality information.

A few weeks ago, I described a webinar taking place later this week (on Tuesday), asking “Are pandemics caused by lack of good information?” The abstract for the session says “A pandemic is essentially an information problem, and if we solve the information problem, we can defeat the virus.” There is still time to register for Tuesday’s session.

The census sets the foundation upon which so much of our demographic information is built. Statistics Canada has even come up with a page of different Spotify and YouTube soundtracks to help get in the mood. [It clearly isn’t the same staid agency from my grad school days!]

Better data definitely leads to better decisions. Be sure to count yourself in.

Channels of appeal

Data on Tap, otherwise known as DOTmobile, says that it has appealed the CRTC’s recent Regulatory Policy – Review of Mobile Wireless Services to Cabinet.

Recall that the Telecom Act prescribes three channels of appeal for a CRTC decision: to Cabinet (the Governor in Council); to the Federal Court of Appeal; or, back to the CRTC itself.

A “petition” to Cabinet must be filed within 90 days of a CRTC Decision. The Commission’s policy was issued on April 15th, less than 3 weeks ago; Cabinet has a year from the date of the decision to respond.

The press release says:

“The CRTC decision misinterprets Canada’s wireless policy. Industry analysts, telecom experts, competitive regional providers and even the dominant carriers all recognise that this decision will not have any meaningful, immediate or nation-wide effect on the wireless market,” said Algis Akstinas, CEO of Data on Tap Inc. “It is not addressing the pain points that kicked off the Review of Mobile Wireless Services and were validated by the Commission and Competition Bureau Canada during the proceeding.”

Given that the CRTC’s model largely adopted the competitive framework proposed by the Competition Bureau, it is hard to understand the validity of this statement.

In its Application, DOTmobile asks Cabinet to:

  1. Make wholesale access to dominant networks available to Full MVNOs by removing the requirements targeting regional MNOs:
    • Remove all spectrum licensing requirements.
    • Remove the seven-year limitation on mandated wholesale access.
    • Remove the requirement to own and operate an existing radio-access network.
  2. Set a maximum wholesale rate to allow Full MVNOs to offer plans that meet the affordable and occasional-use plan requirements identified by the CRTC:
    • $0.0070 per voice minute (based on 500 average minutes of usage)
    • $0.0010 per SMS message (based on 500 average minutes of usage)
    • $0.0060 per MB of data (based on 3GB of average data usage)
    • Wholesale cost for the $35/month 3GB plan would be $22.00, leaving a moderate 37% average retail margin to cover operating costs and investments.
  3. Direct the CRTC to review maximum mandated wholesale rates every two years to determine if they allow for competitive retail pricing, based on a margin equal to the average reported wireless EBITDA margin of the dominant networks in the CRTC’s Communications Monitoring Report.

It is a hefty request with a degree of specificity that is extremely unusual to expect from Cabinet.

DOTmobile’s Application itself recognizes the close relationship between the CRTC’s Decision and the Competition Bureau’s proposed model. Recall that the Competition Bureau is an agency that reports to the Minister. As the CRTC observed, “The Commissioner [of Competition] suggested that, relative to facilities-based competitors, service-based MVNOs are inferior because, without any networks of their own, they must rely on network operators and the regulator to set the bounds in which they operate” and “proposed that the Commission [CRTC] adopt a narrowly focused, facilities-based MVNO access policy.”

It is worthwhile looking at a part of the introduction to the CRTC’s Policy Decision:

the Commission considers it necessary to apply certain targeted regulatory measures to ensure that the needs of Canadians are met, having regard to the policy objectives of the Telecommunications Act and both the 2006 and 2019 Policy Directions.

In considering its regulatory approach, the Commission must take care not to disrupt the competition that is already occurring, but instead foster an environment where this competition can grow and be sustainable over the long term.

I suspect the Minister will follow a similar approach, taking care not to disrupt the competition that is already occurring.

We’ll be following this file.

Spectrum trafficking

Speculating in spectrum can be extremely profitable as I was reminded last week. My Twitter timeline highlighted a couple articles about Canadian spectrum sales over the past few years.

One of the articles highlighted Videotron selling Shaw unused spectrum in Ontario, Alberta and BC in the 700 MHz band and 2500 MHz band for C$430M. Videotron acquired its 700 MHz spectrum in 2014 for C$233M and the 2500 MHz spectrum in 2015 for C$187M. So, on first glance, one might think the $430M sale in 2017 just covered the $420M total cost. But, the total cost included all of the spectrum Videotron kept for its own use in Quebec, so flipping the out-of-region spectrum resulted in getting Quebec for free.

The other tweet linked to a story about Videotron selling to Rogers some unused spectrum it was sitting on in Toronto. In that particular case, Videotron had acquired 10 MHz of AWS spectrum in the 2GHz band in Toronto in 2008 for C$96M, and sold it for C$184M nine years later, just a year before the original license expired.

These stories are insightful for some of the bidder qualifications that have been put in place for Canada’s upcoming 3500 MHz spectrum auction. To qualify to bid for spectrum in a particular area in the June 2021 auction, bidders must already be providing some kind of telecom services in the area. For greater precision, the auction will be conducted in Tier 4 geographic areas; there are 172 ‘localized’ geographic blocks in Canada using Tier 4 subdivisions. To qualify to bid for spectrum in any particular Tier 4 block, the bidder must already be providing a telecommunications service (such as internet, telephone, mobile, etc.) in the associated Tier 2 zone; there are 14 Tier 2 geographic blocks in Canada, generally one for each province except for Ontario and Quebec which have subdivisions.

Clearly, the consultation demonstrates there was a concern about spectrum squatting and trafficking. In the discussion about eligibility in the Licensing Framework, the Department wrote, “To promote optimal spectrum utilization and deployment, set-aside-eligible bidders must be actively providing commercial telecommunications services.” There are also specific deployment requirements set out as a condition of license, aiming to ensure spectrum is actually deployed, not hoarded.

Last week, I wrote about a recent Opensignal report that observed how Canada is falling behind its peers since the “full capabilities of 5G are best realized through the wider channel sizes in the new 5G bands”. The Policy and Licensing Framework acknowledges that “The development and deployment of 5th generation (5G) technologies will support Canada in becoming a global centre for innovation, and will position Canada at the forefront of digital development through the creation and strengthening of world-class wireless infrastructure. Beyond initial improvements to the speed and capacity of mobile broadband networks and services, 5G technologies are expected to transform services across all sectors of the economy including manufacturing, healthcare and transport.”

The 3500MHz spectrum is also important for rural broadband deployment since the mid-band frequencies provide a blend of coverage and capacity.

The upcoming auction was already delayed until June due to COVID, from its original December 2020 date. In the wake of the CRTC’s Wireless Review determination, some had called for the auction to be delayed in order to allow additional companies to decide to register to bid. Last week, Minister Champagne made it clear that the auction is moving ahead in June.

As you know, the deadline to submit an application to participate in the 3500 MHz auction was April 6, 2021. The auction’s timelines were made public in June 2020, and many applicants have now invested significant effort to apply despite the potential uncertainty surrounding the CRTC’s MVNO decision. The auction has also already been delayed by six months to allow providers to respond to COVID 19. Accordingly, we will not be reopening the auction application process at this time.

The June auction is hardly the last opportunity to acquire mid-band spectrum. It is critical for the auction to proceed without further delays, and for Canada to continue to make additional spectrum available – for deployment, not for speculation – in order to continue to support innovative new services and a seemingly insatiable thirst for wireless connectivity.

The fourth degree

Nearly 15 years ago, I wrote a little piece called “4 degrees of impersonal communications”, describing the way we speak to one another in different settings: in person, over the phone, in emails, and on web sites.

Face-to-face communications (a first degree interaction) has no record, no evidence beyond the memory of the participants. Telephony (second degree) may have a record, such as an audio voice message. Email (3rd degree) gets circulated, over and over. Thanks to search engines and web-archiving tools, the web (4th degree) offers a permanent record.

Paradoxically, we seem to take more care in communications when the conversation can most easily be private and candid. Conversely, we pay less attention to etiquette and courtesy when the audience is global and of diuturnal impact.

Earlier this month, I wrote a blog post entitled “Mythbusting Canadian telecom”. A couple weeks ago, I was asked if I would mind them promoting my tweet that linked to the post. At the time, I thought it would be a great way to drive traffic to my blog and Twitter feed.

I should have remembered the 4 degrees thing.

The promoted tweet generated thousands of additional views of the blog post and more than a hundred ‘likes’ of the tweet itself. I added a large number of followers on Twitter and a bunch of subscribers to my blog.

But, it also led to a remarkable number of venomous replies, some crossing the line into virulent antisemitism, virtually all of which came from anonymous accounts. As an aside, a significant proportion of the trolls used cat images, a bunch used Soviet-era communist icons, while most of the others are stuck in their fantasy cartoon and gaming personas. Hiding in their mom’s basement behind the safety of a shield of anonymity, it seems too easy to spread hate and be downright anti-social on some social media platforms.

Confronted with inconvenient facts, apparently some people feel the need to resort to ad hominem attacks, rather than preserving the obscurity they so richly deserve.

I’m not offering a solution; I’m just finding there is some catharsis in venting.

Your comments are welcome. (Reminder: comments are moderated on this platform)

Scroll to Top