Search Results for: affordable

It can be easy to lose focus, to lose sight of the prize. In early July, I wrote “Keeping priorities in order”, trying to prepare my regular readers for a summer with far fewer posts than usual. I typically write a couple posts per week but as I warned, I’ve had 5 higher priorities visiting for much of the summer. I kept my priorities in order. So here we are, August 19, with my first post this month.

Maintaining sight of the prize seems relevant to my impression of last week’s CRTC decision. In “Competition in Canada’s Internet service markets”, the CRTC’s summary begins with a single concise statement. “The Commission is taking action to ensure that Canadians benefit from affordable access to high-quality Internet services.”

That is a reasonable objective: “affordable access to high-quality Internet services.”

Note, the CRTC did not say the prize was counting the number of competitive internet service providers (ISPs). From the outset, we are told the target is consumer focused. “Ensure that Canadians benefit from affordable access to high-quality Internet services.”

It is through this lens that Canadians should read Telecom Regulatory Policy CRTC 2024-180.

How does the Commission envision us getting there? Indeed, how does one define affordable access? What I consider affordable is different from what other people due to a wide range of factors. I suspect the CRTC is using the term “affordability” as a euphemism for lower prices. In reality, that doesn’t solve the problem of affordability for the most vulnerable households, but wins political points for a wide range of consumers (voters).

What qualifies as a “high-quality internet service”? What utility to I get from my connection? What are the household financial circumstances? How many people share the connectivity? Is it used for business and personal use? What kind of devices do I plan to use for connectivity?

I couldn’t find answers to any of these questions in the decision.

There are some interesting statements set out as facts that should have greater supporting arguments. For example, at paragraph 17 we read

17. Since that time, the industry has continued to develop. The Commission observes the following:
    • Consumers have fewer choices when buying Internet services: in recent years, competition has been declining. By the end of 2022, independent ISPs served significantly fewer customers than they did at the start of 2020. At the same time, several of the largest independent ISPs have been purchased by incumbents.
    • The incumbents are using wholesale HSA services: various incumbents or their affiliates are increasingly using wholesale HSA services both inside and outside their traditional serving territories. This is different than in the past, where independent ISPs accounted for substantially all use of wholesale HSA services.
    • Not all Canadians are connected to higher-speed Internet services: while more than 83% of households and businesses reached by the incumbents have access to at least one gigabit-speed Internet connection, ISPs must continue to deploy and upgrade networks to ensure all Canadians can benefit from these services.
18. These facts suggest that the Commission’s prior regulatory approach, which prioritized facilities-based competition, has not brought about sustainable competition that delivers more choice and more affordable services to Canadians, nor has it resulted in universal access to higher-speed Internet services. The Commission must therefore set objectives that continue to incentivize network investment and facilities-based competition while supporting increased choice and greater affordability for Canadians.

I could devote an entire blog post to paragraph 18 and the factual flaws contained within. It appears to be policy-based fact making, rather than the other way around.

Considering the objective of affordable access to high-quality internet service, I found it somewhat strange to find no mention of Connecting Families, or any other affordable connectivity initiative to be found in the CRTC’s policy document. Ted Woodhead recently wrote an excellent post, “The FCC’s Affordable Connectivity Program ending in the United States”. His post talks about the key differences between the American government-led initiative, and Canada’s innovative carrier-developed and funded programs. Ted and I were there from the beginning.

I am sure I will return to paragraph 18 at a later date.

For now, let’s look briefly at the “facts” set out in paragraph 17. The CRTC says “Consumers have fewer choices when buying Internet services”. I’m not convinced. It isn’t as clear to me that there are fewer choices or, for that matter that competition is declining. Prices are in decline and service providers are investing billions of dollars in network upgrades. The second bullet seems to contradict the first one: “various incumbents or their affiliates are increasingly using wholesale HSA services both inside and outside their traditional serving territories”. The exit of smaller, wholesale-based ISPs in favour of better capitalized “incumbent” affiliates could be celebrated as providing greater choice and bundled services.

The decision refers to the Competition Bureau observation, “while any bundling by the incumbents could be a barrier to entry for smaller ISPs, the competitive benefits of an incumbent accessing wholesale HSA services outside its footprint likely outweigh the risks.”

As the decision notes:

55. In setting out its regulatory framework, the Commission seeks to create opportunities for innovative competitors to differentiate themselves and bring new choices to consumers. Importantly, this is not the same as guaranteeing that one type of competitor can profitably compete without risk. In respect of wholesale HSA services, the Commission enables wholesale access at just and reasonable, cost-based rates. It is then up to competitors to find commercial strategies that deliver an attractive value proposition that responds to consumers’ needs.

Too often, people lose sight of the prize. The wholesale framework is a means to an end, not an end in and of itself. It is not the CRTC’s role to preserve the independent wholesale-based competitive ISP industry. We do not guarantee “one type of competitor can profitably compete without risk.”

The target is to ensure Canadians benefit from affordable access to high-quality Internet services. And, despite what the CRTC said in paragraph 18, that is where the industry has been heading.

Last month, the Dais at Toronto Metropolitan University released an update to its flawed 2021 report, “Mapping Toronto’s Digital Divide” [pdf, 3.8MB]. You may recall that the 2021 report was used to support a misguided proposal for the City of Toronto to build its own fibre network in what is already one of the world’s most connected cities.

The new report, “Toronto’s Digital Divide” [pdf, 12.4MB], notes that 98% of Toronto residents have internet service in their home. The new report no longer blames inadequate infrastructure; price is cited as the top reason households remain unconnected. This “underscores the need for Canada to address the cost barrier of internet services for lower-income people.”

Fortunately, the telecom sector has done just that, with lower cost connections available through programs like Rogers Connected for Success, TELUS Internet for Good, and the industry led federal program, Connecting Families. The report acknowledges that “4% of Toronto residents have a home internet plan that costs them $20 a month or less”.

I have written previously that we learned that it isn’t enough to offer low-priced computers and $10 per month broadband.

Georgetown University economist Scott Wallsten described [pdf, 1.8MB] studies conducted by the FCC associated with its Broadband Lifeline service. Those studies tested consumer responses to a range of issues, including preferences for speed, the effects of different levels and types of discounts.

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 uncovered a significant aversion to 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.” It would be interesting to see this research updated by a Canadian study, perhaps working under the umbrella of the Connecting Families project.

The Dais report looked at speeds and total monthly bills for internet and mobile services observing a variability by income. Unfortunately, the study did not appear to normalize these for the variability of household size by income quintile. To that end, I found it was worth looking at Statistics Canada’s Survey of Household Spending for some analysis. When I last looked at the data 9 years ago, the average size of a household in the lowest income quintile was 1.49 members. The highest income quintile averaged 3.34 members. Obviously, with more people living in the household, there would be more cell phones, and more internet connected devices, with increased communications services demands, all contributing to higher bills. It would be important for the next iteration of this research to normalize spending analysis for household size.

Attaining universal adoption of digital technologies is the objective. I concur with the Dais concluding statement. “As Toronto looks forward to the next stages of its digital transformation, taking a broad lens of digital inclusion will provide better and more equitable outcomes for residents. Only when all residents have both access to the internet and the ability to use it effectively will we have overcome the full digital divide.”

It isn’t enough to have affordable broadband at everyone’s doorstep; we need to understand and address those factors that inhibit adoption. More research is needed to develop skills, and to develop strategies for overcoming digital phobias among underserved populations.

When looking at telecom services, regulators should focus on whether the market is sustainably competitive. That seems to be the message arising from merger reviews in Europe.

After years of focus on the number of carriers, regulators are taking note of the impact of hypercompetitive markets on investment. UK service providers are unable to cover their cost of capital. As a result, operators are unable to fund network upgrades. Vodafone and Three UK intend to merge. The Competition and Markets Authority (CMA) in the UK is moving into the next phase of its review of the merger.

In announcing its next phase, CMA said “the deal, which combines 2 of the 4 mobile network operators in the UK, could lead to mobile customers facing higher prices and reduced quality.”

The CMA’s Phase 1 investigation found that Vodafone UK and Three UK provide important alternatives for mobile customers. Both have made significant investments in their networks in recent years – which includes the rollout of 5G. Three UK is also generally the cheapest of the four mobile network operators. The CMA is concerned that combining these two businesses will reduce rivalry between mobile operators to win new customers. Competitive pressure can help to keep prices low, as well as provide an important incentive for network operators to improve their services, including by investing in network quality.

Vodafone and Three UK replied, noting “The current market structure has resulted in the quality of mobile network services in the UK lagging significantly behind other European countries. Vodafone UK and Three UK are sub-scale, unable to cover their cost of capital, and constrained in their ability to invest and compete effectively against the two market leaders.”

In February, OpenSignal reported that the UK ranked 22nd for 5G availability and download speeds when comparing to 25 European countries. The UK has the slowest download speeds in the G7. By way of comparison, I recently wrote that Canada is consistently a leader in availability and speeds.

There is a reason why EBITDA margins are necessarily higher among facilities-based telecom competitors. By definition, EBITDA measures the earnings before consideration of interest, depreciation, and amortization. Each of these are costly factors for companies with large investments in infrastructure. If the EBITDA margins are not sufficiently strong, network operators will be unable to maintain investment.

Last October, I wrote about a CRTC arbitration on MVNO access, where the Commission determination explicitly said “This decision helps to promote access to affordable telecommunications services for Canadians and to foster sustainable competition and continued investment.” At the time, I asked “To what extent does it provide clues for the way the CRTC will approach revisions to the wireline wholesale framework?” I wrote about sustainable competition two years ago, showing how the CRTC and Competition Bureau seemed to be at odds in their approaches.

A singular focus on driving lower prices fails to appropriately consider balancing competing policy objectives. In Canada, telecom policy seeks a balance between quality, coverage and price. I’d submit that the number of competitors should be a less important factor for policy makers. The more important consideration should be fostering a sustainably competitive market to deliver overall consumer benefits.

The government should be celebrating “the thrill of victory.”

Last summer, I wrote how it was time for government policy makers to declare “Mission Accomplished”. Price reductions in the mobile market were “well beyond any of the expectations that were set by Ottawa”.

While such a mission accomplished statement was likely too much to ask for, the Government’s virtual silence surrounding the significant declines in wireless service prices is counterproductive and somewhat perplexing.

Statistics Canada’s Cellular Price Index has declined by 22% in the last year and by almost 50% since 2018. While impressive, it is even more remarkable given that inflation has driven overall prices up by more than 20% since 2018.

So, when opposition parties repeatedly claim that the government has done nothing to lower prices and has failed to keep its 25% price reduction, one might think the Government would have an easy time refuting such claims. One might have even expected Minister Champagne to point out that prices for wireless services are lower than they have ever been, all under this Government’s tenure. That old “Promise made; promise kept” thing.

But, that isn’t what is happening. Having made the telecom industry its political punching bag, the Government has shown itself incapable of pulling its punches. If anything, the Government appears to regard as a weakness any kind of acknowledgment that the industry succeeded in making services more affordable for Canadians.

The failure to properly acknowledge the decline in Canadian mobile prices is a form of misinformation, perpetuating a distorted view of the industry. This leads to uninformed public discourse, and misguided policy and regulation.

In doing so, the Government has ceded the narrative to the opposition parties, who are continuing to push outdated facts and perceptions. As a result, the government comes across as being on the defensive, giving Canadians the impression that they have nothing to show for their years in office.

Let’s look at the accusation that the government has failed to meet its 25% price reduction objective.

As you may recall, in 2020 the government set an expectation that the national carriers would reduce the price of 2GB, 4Gb, and 6GB, so-called mid-range, plans by 25% within two years. As the chart below illustrates, this objective was achieved prior to the two-year deadline. Two years ago, the government boasted that the reductions “were achieved across the country three months before the target date.”

But, the good news does not stop there. As a result of vigorous competition in the mobile services marketplace, those March 2022 target price points come with substantially more data.

The government’s objective was for Canadians to get a 4G plan for $37.50 with 2GB of data. Yet, a quick survey of carrier websites shows that today there are plans from various carriers for $37.50 (or lower) offering 30GB to 50GB, including some that include 5G speeds. That represents up to a 96% reduction in the price per GB compared to the March 2022 target. This does not include some expired Boxing Day promotions that offered even more data.

The $45 price point has a similar result:

Let’s be really clear. The promise of a 25% reduction in mobile prices promise was not only met, but carriers have exceeded the government’s expectations – by far.

But, you’d probably only know that by reading it here.

We will soon be entering a federal election cycle. The current government will have to defend its record on a host of issues, including telecom policy.

By perpetuating outdated and unfounded perceptions that Canadians pay “too much” for wireless services, the Government is painting its policy initiatives (and election promises) as failures, even though the facts say otherwise. When the previous government was in office, it cost over $80 for a plan with 2GB of mobile data. Today Canadians can get as much as 75GB for $45. This should be a good news story – the thrill of victory.

By failing to highlight these obvious truths, the government is snatching defeat from the jaws of victory. And, it is suffering the resultant agony.

Just how fast is fast enough for broadband?

I last wrote about this 3 years ago, challenging the myth that universal fibre should be on the national agenda.

A couple of weeks ago, the FCC launched an inquiry [pdf, 155KB] to examine that question. The FCC intends to look at “universal deployment, affordability, adoption, availability, and equitable access to broadband”. The FCC Chair, Jessica Rosenworcel says the intent is to update the US broadband standard (currently 25Mbps down, 3Mbps up) to 100/20 and set a long-term goal for gigabit speeds.

The FCC Chair said that the 25/3 standard “is not only outdated, it masks the extent to which lowincome neighborhoods and rural communities are being left offline and left behind.”

However, FCC data shows that 94% of US households had 100 Mbps access available by the end of 2021. According to Eric Fruits of the International Center for Law & Economics (ICLE), “If the FCC wants to increase the number of households with 100/20 Mbps speeds, it should recognize that much of the gap is driven by lower rates of adoption, rather than a lack of access to higher speeds.”

That is a familiar refrain for my readers. “The problem of increased broadband adoption can’t be fixed directly by throwing money at it, but we need to undertake more serious research into those factors that stand in the way of people subscribing to broadband.”

A September brief from ICLE was entitled “Finding Marginal Improvements for the ‘Good Enough’ Affordable Connectivity Program”. ICLE found that “about two-thirds of households without at-home internet have access, but don’t subscribe. The brief argues that, for households without a broadband subscription, their smartphone internet service may provide a superior “bang for the buck” relative to fixed broadband.”

Just as mobile devices have become a substitute for wireline home phones, we need to examine the extent to which smartphones and mobile services are substitutes for home internet connections.

In 2021, Pew Research found that 19% of respondents said the most important reason for not having broadband at home is that their smartphone does everything they need to do online. That study found that 15% of US adults are “smartphone-only” internet users – that is, they have a smartphone, but do not have a home broadband connection.

What is the best approach for encouraging continued broadband investment?

Do regulators need to raise targets? CRTC data shows that more two thirds of Canadian broadband subscriptions were already at speeds of 100 Mbps or higher, well above Canada’s broadband objective. Ninety percent of households had access to 100 Mbps service by year end 2021; more than three quarters of Canadians had access to gigabit speeds.

When there is demand for higher speeds, doesn’t this demonstrate companies will make the necessary investments? As I have said many times before, the future can be brighter for Canadian innovation and investment if the government would try harder to get out of the way.