Search Results for: incentives to invest

Government programs to provide better broadband are failing underserved markets. On this point, a number of recent releases agree.

Whether it is improving availability of higher speed, better quality, more reliable services, or improving rates of adoption among certain communities, governments in Canada at all levels are simply not delivering fast enough on their commitments to improve access to broadband services for their constituents.

Subsidy programs designed to stimulate construction in underserved areas have moved too slowly, and in some cases, the overhang of promised funding may have delayed roll-outs to areas that might have otherwise seen construction without government funding. (See: “A less than rapid response stream”.)

Social service agencies aren’t dispensing direct subsidies to allow low income households to sign up for communications services of their own choosing, leaving the development of such services to the goodwill of the private sector, which has stepped up to fill the void left by a failure of government leadership. Contrast this with the Emergency Broadband Benefit in the United States, that provides “a discount of up to $50 per month towards broadband service for eligible households”.

“Waiting to Connect”, a report [pdf, 3.8 MB] from the Council of Canadian Academies, says “Canada’s current broadband funding and consultation processes are often complex, onerous, competitive, and involve many actors, making them difficult for small, capacity-limited organizations to navigate.” This is accurate. However, it is difficult to support a conclusion that says “Broadband infrastructure can only meet long-term connectivity needs if it is scalable and sustainable, and if there is local expertise and capacity to build, operate, and maintain it.” The paper appears to argue against the efficiencies of scale, in favour of local capabilities. About a year ago, I wrote “Toward a universal broadband strategy”, that talked about the problems caused by the lack of stable funding to offset the higher ongoing operating costs associated with rural and remote telecommunications services. There is a relatively easy solution, reminiscent of the funding for high-cost serving areas that was formerly administered by the CRTC before it chose to duplicate other branches of government funding capital projects.

In another paper, from the Public Policy Forum, “Future Proof: Connecting Post-Pandemic Canada” [pdf, 1.8 MB] argues that Canada needs to be a global leader in 5G as I discussed a couple weeks ago. The paper argues for “future-proof digital connectivity infrastructure — connectivity that is scalable so it is capable of supporting data rates that far exceed needs that can be foreseen today” but also notes “It is prudent to enter a caveat that truly universal future-proof connectivity cannot be assured within specified time.” Recognizing that universal access to fibre is impractical, the paper argues for Canada to develop a strategy to be a global leader in 5G.

Two papers, both talking about connectivity, but ignoring the issue of adoption. The papers focus on the supply side, without looking at measures to increase demand among those who are not yet connected.

In part, I believe the problem is a result of a failure to apply some basic systems engineering principles, defining requirements rather than specifying solutions. In the past, I have described this as having people start with a premise that they need nails, which is a specific kind of solution, rather than defining the real requirement, that they need to put two pieces of wood together.

It is easier to define problems in terms of solutions with which we are familiar, or in terms of concrete, physical solutions. As a result, we have had people hijack the need to increase broadband adoption among low income households and advocate for municipalities to build their own fibre network. The most extreme case is the Connect TO project, overlaying municipal fibre in one of the world’s most connected cities. Look at Beaumont, Alberta, a suburb of Edmonton, that in the summer of 2020 promised to have construction underway before the end of the year. A year and a half later, all that Beaumont has done is inhibit investment by private sector service providers. At least Beaumont isn’t as far along in squandering taxpayer dollars as Olds, Alberta which is rescuing its community network from bankruptcy.

As I have written before, we need a smarter approach to community networks.

The proponents and advocates for such local community network programs aren’t ill-willed, but unfortunately, I think many of these programs suffer from a failure to examine the potential for unintended consequences emerging from their solutions.

For example, if a municipality builds its own private network to link all schools, hospitals, and other municipal public institutions, it can have the effect of significantly damaging the business case for investment in communications infrastructure in the rest of the community. When a government infrastructure subsidy program is announced, it can freeze the incentives to invest until funding is distributed. Further, it is important to recognize that a government subsidized network, or a municipally owned network, impairs the business case for a competitive network build. It enshrines a monopoly in that area and the history of government telecom monopolies is not a good one.

There is some activity on the supply-side. Rogers (Connected for Success) and TELUS (Internet for Good) have each upgraded the initial targeted programs for affordable broadband, empowering disadvantaged households to choose the services that best meet their needs. It is expected that there will soon be upgrades to the national Connecting Families program, a private sector led initiative, coordinated under a federal government umbrella.

As we approach the end of the year, we need to look back at what we have learned from more than 20 months of pandemic-induced changes to our way of working and studying, driving increased needs for improved broadband connectivity at home.

Which programs are working? Can we, or should we, do more of them? How can we accelerate service improvements?

I have long argued “Isn’t some broadband better than nothing?” Isn’t it better to get some broadband service to unserved areas rather than wait for future-proof connectivity? When some Canadians are wanting for any kind of affordable broadband, it takes a certain kind of arrogance to proclaim that 25Mbps (or 50 Mbps) just isn’t good enough.

“Le mieux est le mortel ennemi du bien.”

We can’t wait for a perfect, “future-proof” solution for universal broadband for all Canadians. But surely we can strive to do a lot more, a lot better, and a lot sooner.

A while ago, I did some work with a weather agency. The project leader, we’ll refer to him as Tony since that was his name, told me that he received a call from a news station that wanted to know what the long range forecast was for the upcoming winter. Tony told the reporter, without consulting any computer models and with a completely straight face, “we’re forecasting that there is a 50% chance of a warmer than average winter.” The station led with that breaking news.

The reporter didn’t understand that there was also a 50% chance of a colder than average winter ahead. Tony got a chuckle out of that story.

This story came to mind as I read the CRTC’s Decision on staying the requirement for facilities based telecom companies to file new tariffs as part of the implementation of last year’s aggregated wholesale high-speed access services ruling (2019-288).

It seems to me to be an impossible task for a regulator, or anyone, to set the rates exactly right. Set too high, competitive service providers won’t be able to compete; set too low and facilities-based providers are effectively subsidizing their competition and lose the incentives to invest in new technology and expanding territory.

What are the defining characteristics of an ideal wholesale rate? For example, at one time, the regulator sought rates to be set at a level that smaller ISPs could find an opportunity to serve their customers, while maintaining an incentive to invest in facilities as they grow in a given area. Is this still part of the thinking when setting rates?

While the rates can never be ‘bang on’, since cost elements change over time and with 100% certainty will not precisely match the very best forecasts, there must be a range that can prove to be acceptable to both parties, the buyer and the seller.

It’s a real challenge in a regulated market for the adjudicator to find that middle ground. From the response to the rates decision of August 2019, it appears clear that the CRTC’s rate cuts coupled with retroactive rebates went too far.

Can a regulator reasonably replace the results of direct negotiations? Along these lines, I found it interesting to read in the Stay Decision of the competitive factors at play between some of the facilities-based providers. At what point should the regulator determine the wholesale marketplace is sufficiently competitive to allow market forces to take over in setting rates?

In the meantime, I’m prepared, with complete confidence, to forecast a 50% chance that the coming winter will be warmer than average. And, there is a 100% chance that however the CRTC rules in its review of the August 2019 rates, one side or the other (or maybe both) won’t be happy.

Ok kids. Gather around. Today’s lesson is engineering economics. How do you put together a business case for expanding broadband into a previously unserved area?

Putting together a business case is an important life skill. You can apply these kinds of studies to personal purchase decisions, or putting together a business case to launch a new service or discontinue an old one. And most importantly, it will help you understand better how to analyse discussions about rural broadband.

Let’s look at a business plan to expand broadband service into a certain area. For the sake of simplicity, we’ll start with an assumption that there are sufficient investment funds available to fund all the construction into unserved areas, subject to a condition that the investor is able to get a certain return on their investment.

Based on that constraint – a positive return on investment, the engineering department should be able to define an area that qualifies for construction. Their calculations would be based on a variety of assumptions: Capital cost of equipment and construction; annual operating expenses including maintenance; retail market share (and thereby retail revenue); wholesale market share (and wholesale revenue); taxes, etc.

All these numbers go into a spreadsheet and the engineer can keep adding more homes to the construction plan as long as the business case continues to be positive.

At some point in the exercise, the next incremental home has a negative impact on the business plan. The engineer can then draw a line on a map delineating a boundary.

That boundary effectively defines the digital divide: where the economics are unable to support traditional investment in infrastructure. On one side of the boundary, the more urban side, the private sector can line up investors willing to support broadband expansion.

On the other side of the boundary, the more rural side, a different approach is required. These households are candidates for government rural subsidy programs.

But let’s go back and look at the ‘urban’ side of the boundary line. That boundary is defined as precisely where the business case goes from positive to negative. Homes on the boundary effectively have a net present value (NPV) of revenues less costs of zero.

What happens if the revenue assumption changes? If revenues somehow increase, the boundary gets pushed outward. More homes (on the ‘rural’ side of the boundary) would potentially now have a positive business case. On the other hand, if revenues somehow decreased, the boundary gets pushed in the other direction and the business case is no longer positive for as many homes.

When the CRTC sets wholesale rates, it is implicitly setting the wholesale revenues for our mythical engineer’s business case calculations. The CRTC doesn’t impact the capital costs, they don’t change the retail rates, or even the market share assumptions. But, the regulated wholesale rates are what drives the wholesale revenue line in the business case. Drop the rates, wholesale revenues go down and total revenues for that area go down.

When the facilities-based carriers warn that changes to wholesale rates impact the incentives to invest in rural broadband, this is what they are talking about. These aren’t threats; it’s just basic economics.

The Federal Cabinet understood these principles of economic studies.

Now you do, too.

Is costing more of a subjective art, or is it an objective science?

A recent opinion piece by former CRTC vice-chair Peter Menzies in the Financial Post says “It [The CRTC] has a cost accounting process that is supposed to be objective and provide certainty for an industry on which, as COVID-19 has made starkly clear, Canadians and their economy depend.”

If it was only that simple.

Costing is at the centre of the appeals of last August’s Telecom Order CRTC 2019-288, “Final rates for aggregated wholesale high-speed access services”. In response to an appeal, a little over a week ago, the Federal Cabinet declined to act but said it believed the CRTC erred and set rates too low, impacting the incentives to invest.

The Menzies opinion piece says “The CRTC has the power to stand its ground based on the evidence before it. It should do so.” The implication in the OpEd is that costing is an objective mechanical process; just input a bunch of numbers into a template and out should pop the costs and the resultant wholesale rates.

In reality, there are a lot of subjective decisions required in telecom costing exercises.

The CRTC Order was complex, following a lengthy consultation. The Order itself was divided into 4 broad sections, labelled by the CRTC as “Issues”, and each Issue contained numerous individual determinations, each impacting the resultant costs and wholesale rates:

1. Costing issues common to all wholesale HSA service providers
• Annual capital unit cost change assumption
• Bell Canada’s, Bell MTS’s, and RCCI’s unrecovered costs
• Working fill factors
2. Costing issues specific to the cable carriers
• Coaxial facility costs
• Segmentation facilities – segmentation fibre, optical nodes, and CCAPs
• Segmentation fibre facilities: Access versus usage
• Cable carriers’ proposed growth rates for annual peak period upstream traffic
• RCCI’s and Videotron’s transport fibre facility costs
• RCCI’s project development costs
3. Costing issues specific to the ILECs
• Labour costs per DSLAM port
• Bell Canada’s explicit costing approach
• Attribution factors to be applied to DSLAM equipment, umbilical fibre, and Ethernet port costs
• Bell Canada’s productivity enhancements costs
• Umbilical fibre costs: Access versus usage
• Bell Canada’s FTTN bonded access installation rate
• Bell Canada’s project development costs for aggregated FTTN access rates
• TCI’s financial parameters
• SaskTel’s VDSL Access service charge
• SaskTel’s VDSL interface monthly charge
• SaskTel’s other charges
4. Other issues
• Markup
• Effective date of the final aggregated wholesale HSA service rates
• Computation errors
• Subsequent tariff applications

As can be seen, the CRTC Order actually consists of 24 decisions, each one having an impact on the rates charged to ISPs reselling carrier access services, and impacting carrier revenues.

From some of the section headers, it should be obvious that not all of these were purely objective, mechanical determinations. There is analysis required and judgment calls made in each of these sections.

For example, let’s look at some of the discussion in the “Markup” section. The CRTC introduced the section saying “Markups have varied over time depending on a number of factors, including whether the wholesale service is essential and whether there may be additional risk to network investment if the wholesale service is mandated.” The Commission acknowledged the subjectivity of setting the markup rate, saying “in setting rates, it balances the need to ensure that network providers are reasonably compensated for their costs with the need to ensure that markups are not so high as to significantly impede competitors from providing competitive alternatives in the marketplace.”

Reading such discussions in the CRTC Order helps challenge the assertion that the CRTC “has a cost accounting process that is supposed to be objective”.

In fact, there is a lot of subjectivity applied, resulting in the potential for a wide margin of error. That potential for error in any regulatory process is one of the reasons that our system includes three avenues to appeal a determination to another authority: to the regulator; to the Courts; and, to Cabinet.

As we heard from one of those avenues a little over a week ago, “the Governor in Council considers that the rates do not, in all instances, appropriately balance the policy objectives of the wholesale services framework and is concerned that these rates may undermine investment in high-quality networks, particularly in rural and remote areas.”

These are reasonable concerns for Canada’s Cabinet to have expressed. The need to focus on “investment in high-quality networks, particularly in rural and remote areas” has become more acute over the past 6 months.

In considering its own review of the August 2019 Order, the CRTC can certainly “stand its ground based on the evidence before it”. However, the Commission first needs to reassure itself that it balanced the competing Policy priorities when it made subjective determinations.

The CRTC just may find that a fresh look shines a light on a margin of error in some of those judgment calls.

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This article appears on National Newswatch.

After watching the Federal Government’s Parliamentary Standing Committee on Industry, Science and Technology (INDU) May 7 meeting, Greg O’Brien wrote a commentary entitled “Federal committee nothing but bluster”.

“There’s a waste of two hours,” he wrote. “Not just my own time. Everyone’s.” Later on, Greg writes “You’d think they would want to get to the point, let witnesses speak, maximize their time with a number of good questions. Nope. Maximum windbaggery is what I saw”.

I’m certain we both had higher hopes for last Thursday’s (May 14) meeting, when representatives from Rogers, TELUS, Cogeco and Xplornet were witnesses. I came away shaking my head.

While some productive discussion emerged, too much time was spent by Parliamentarians apparently building transcript materials to show off to constituents and future voters. As stated by Chair Sherry Romanado (MP – Longueuil—Charles-LeMoyne) at the beginning of the video record on “ParlVu”, the meetings are being held “for the purpose of receiving evidence concerning matters related to the government’s response to the COVID-19 pandemic.” Starting on April 23, there have been 7 such video conference meetings so far.

The meetings have evolved to become a forum for issues related to accelerating the deployment of broadband access in rural and remote parts of Canada. This has given rise to Michelle Rempel Garner’s May 7 release of the ‘not ready for prime time’ Conservative caucus “Connect Canada” plan, and NDP MP Brian Masse’s release of the “NDP Plan for High Speed Broadband Internet for all Canadians” just prior to the May 14 Committee meeting.

The opposition parties created their plans prior to hearing from witnesses, many of which are in the business of building and operating networks. That is disappointing enough. But Canadians should watch the performance of their parliamentarians in committee. How many would approve of a methodology that sees plans developed and conclusions drawn well in advance of gathering evidence?

For example, the opening remarks by Rogers for Business President Dean Prevost included this testimony that could have provided guidance for the plans [17:30:25]: “Unfortunately, where we do not have high capacity, high speed wireline networks, we are not able to provide unlimited wireless data for internet access at home at this time. Put simply, wireline networks have 50-200 times the capacity per consumer as rural wireless mobile networks. Removing datacaps would simply overwhelm the mobile wireless network, impairing service for everyone in that area, including the first responders and 9-1-1 services that rely on it.”

During last Thursday’s meeting, I was particularly disturbed by a couple exchanges between Calgary-Nose Hill MP Michelle Rempel Garner (‘MRG’) and TELUS Chief Customer Officer Tony Geheran (‘TG’).

We witnessed this exchange at 6:31 pm:

MRG: “Mr. Geheran, I think I am saying your name right. You made a comment tonight. You said ‘if you have a policy that fundamentally undermines an investment strategy, you have to change policy’ and I think I agree with that. So I’d start with saying, do you think that structurally separating the builders of network from Internet Service Providers is a way to solve the policy tension that I just described?”

TG: “No, I don’t. I haven’t seen that work anywhere globally, to sustainable effect.”

MRG: “It’s in the UK, right?”

TG: “Yeah.”

MRG: “It’s like the primary model in the UK.”

TG: “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.”

MRG: “Well, that’s certainly not what we’re hearing in our offices from end users and that’s not the reality that we’re hearing in testimony tonight from you.”

I’m not sure the Honourable Member actually heard contradicting testimony that night. Perhaps she was confusing meetings.

So, I went off to find some independent sources to figure out what is actually going on in the UK. If the Committee members want independent corroborating evidence for Mr. Geheran’s perspective, they too can check with the independent regulators in Canada (the CRTC) and the UK (Ofcom). It didn’t take much effort to find information on the respective regulators’ websites.

Just a few weeks ago, in its April 24 Notice of Consultation reviewing its approach for rates for wholesale telecom services, the CRTC wrote “Ofcom has identified the lack of incentives to invest in new broadband networks, including full-fibre networks, as one of the key challenges facing the U.K. telecommunications industry.” Just 3 weeks ago, Canada’s regulator stated that the one of the key challenges facing the UK regulator was its lack of incentives to invest, just as Mr. Geheran had told Ms. Rempel Garner.

For verification of quality differences, there is plenty of data in the most recent annual reports from both regulators. For example, Ofcom is showing that broadband speeds in the UK increased 18% between 2017 and 2018 to reach 54.2 Mbps. According to the CRTC, average speeds in Canada reached 126.0 Mbps by the end of 2018, an 89% increase over 2017.

Or, the members of the committee could take a look at the Insights section from Ookla speed test results, which show Canada’s April 2020 wireline average at 118.11 Mbps for downloads and upload average at 51.80 Mbps. In the same period, wireline users in the UK were getting roughly half the download speed at 67.23 Mbps and about a third of the upload speed (18.28 Mbps).

When the Hon. Member from Calgary Nosehill said “that’s certainly not what we’re hearing in our offices from end users and that’s not the reality that we’re hearing in testimony,” the independent evidence supports ‘the reality’ portrayed by Mr. Geheran.

If they are hearing otherwise, the committee might want to take more time listening to different witnesses. Recall the opening of the meeting, where we hear that this inquiry was “for the purpose of receiving evidence”.

How would you interpret “receiving evidence”? Listening? Probing? Researching? Learning?

Instead, what we, the Canadian voters, have witnessed so far appeared to be parliamentary puffery.

A more evidenced-based approach is warranted.