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“Wholesale telecom services are a lot like selling the big guys’ hand-me-downs.”

That’s how a then-independent telecom journalist described the non-facilities based service providers a few years ago.

On paper, the wholesale scheme seems to make sense: Big network owners are forced to provide airtime to any and all commercial interests at regulated terms and rates, which other companies then resell to consumers at whatever prices they see fit.
…
But in the grand scheme of things, it’s worth asking whether the whole wholesale regime has really accomplished anything.

He concluded with “If the government is going to consider regulated wholesale wireless access, it would have to ensure that it doesn’t just enable hand-me-down services. Realistically, though, that hasn’t happened elsewhere so there’s no reason to expect it would in this situation.”

The 2013 article speaks of the ineffectiveness of a 10% market share for US mobile resellers (Mobile Virtual Network Operators, or MVNOs) as “the best reason for why the Canadian government shouldn’t be – and probably isn’t – thinking of wholesale service as a solution to what ails the country’s wireless market.” [CRTC figures show that Canada’s wholesale-based internet service providers still have less than 10 percent market share [xlsx] after well over a decade of regulated access to wholesale highspeed internet service.]

In the years subsequent to this article, we have seen the capital intensive nature of telecommunications globally drive consolidation in the MVNO marketplace. The two largest US MVNOs, Tracfone and Cricket, have been acquired by Verizon and AT&T, effectively turning these two MVNOs into flanker brands of the mobile giants.

MVNOs continue to exist in Canada on a non-mandated basis and Telegeography data (filed by CWTA in its Wireless Review intervention [pdf]) shows that the market shares of Canada’s flanker brands (own-brand MVNOs) combined with MVNOs is among the highest in the OECD.

Last summer, Cabinet told us “Canada’s future depends on connectivity”, signalling quite strongly that the CRTC’s August 2019 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.” Throughout its statement, Cabinet was clear in stating that preserving incentives for network investment was missing from the August 2019 wholesale framework.

A great body of economic evidence and observations from markets around the world has been provided to the CRTC to assist in its deliberations on varying its wholesale internet rates decision and its review of wireless services.

As reported here a couple weeks ago, a recent communiqué from the Telecommunications Working Group of the C. D. Howe Institute (chaired by the Dean of McMaster University’s DeGroote School of Business) concluded “Investment in the telecommunications sector is vital for ensuring Canada’s next generation digital infrastructure.”

Balancing Quality, Coverage and Price. It takes investment, massive levels of private sector investment, to drive quality and increase coverage. Prices have been coming down thanks to facilities-based competition.

MVNOs can continue to exist without regulatory intervention (like in most countries), where carriers and operators are able to identify business opportunities that make sense.

As that former journalist wrote, wholesale telecom services aren’t the solution.

For the past couple years, I have frequently referred to the tension between the government’s telecom policy objectives, balancing quality, coverage and price. Think of it as a three legged stool. All three legs – Quality, Coverage, and Price – must be maintained in some form of balance to achieve stability in the marketplace.

Last September, in “Yes, it’s time to reboot Canada’s digital agenda”, I wrote that Cabinet’s determination in its review of the CRTC’s August 2019 Wholesale Internet rates was consistent with its stated policy priorities when it expressed concern “that these rates may undermine investment in high-quality networks, particularly in rural and remote areas.” I wrote:

as should be evident to most Canadians over the past 6 months, the pandemic has helped elevate awareness in the importance of Quality and Coverage, the other two legs of the Minister’s priorities. The government called for improving the balance to preserve incentives for investment, the key input to ensure Canadians have access to world leading network quality, covering urban and rural areas.

Cabinet was right to be concerned.

Last August, I prepared a bried tutorial on “The economics of broadband expansion”. There exists a boundary that defines the digital divide: where the total expected revenues from wholesale and retail services are unable to support traditional investment in infrastructure. On one side of the boundary, usually 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. The households on the other side of the line are candidates for government rural subsidy programs.

What happens if wholesale rates are lowered by a regulatory decision? The total expected revenues for the project logically drop and the result is that more homes end up on the wrong side of the digital divide. More homes are left having to wait for government rural broadband funding; total government funding would have to increase.

Cabinet understood this logical progression. Cabinet told the industry – and the regulator – “Incentives for ongoing investment, particularly to foster enhanced connectivity for those who are unserved or underserved, are a critical objective of the overall policies governing telecommunications, including these wholesale rates.”

As we saw in the C.D. Howe communique last week, “the federal government must provide facilities-based providers will a clear and predictable regulatory framework that coherently balances vigorous price competition with incentives for ongoing investment to improve network and service quality.”

CRTC figures show that the major facilities-based carriers in Canada invest nearly $10B per year in wireline capital, contrasted with just $50M (0.5%) invested by the wholesale services based ISPs.

Simply put, extending the reach of broadband networks (the Coverage leg) requires massive levels of investment, as does the need to maintain Canada’s leadership in the Quality of our networks (Canada’s wireless and wireline networks are consistently rated among the world’s fastest). Government rural broadband funds are simply unable to replicate the investment capacity of the private sector.

The Court appeals looked at very narrow issues of law and jurisdiction, as stated by the Court at paragraph 23:

[23] Significantly, neither section 62 nor subsection 12(1) circumscribe the types of questions that may be raised before the CRTC or the Governor in Council. This stands in contradistinction to the prescription in subsection 64(1) that limits this Court to reviewing questions of law or jurisdiction.

For that reason, no one should expect the Courts’ rulings to be harbingers of the outcome of the CRTC’s review of wholesale rates. The CRTC’s scope is much more broad than that undertaken by the Courts, and must carefully consider the policy considerations set out by Cabinet and the legislative framework under which it operates. The message from Cabinet was very clear: “Canada’s future depends on connectivity.”

If Canada’s future depends on connectivity, the corollary is certainly that Canada’s connectivity future depends on billions of dollars of continued private sector investment. We can expect CRTC to keep this in focus in how it makes determinations in both of the key proceedings under review at this time: wireless services and wholesale internet rates.

Canada’s future depends on connectivity.

Last week’s Cabinet shuffle brought a new Minister of Innovation, Science and Industry into the telecommunications policy arena, The Honourable François-Philippe Champagne. As indicated in his biography, he brings a wealth of experience at large international companies in Europe, particularly in the fields of energy, engineering, and innovation. These are great credentials for the Minister of Innovation, Science and Industry.

For telecom policy, Minister Champagne’s predecessor, Navdeep Bains, had focused on the tension between quality, coverage and price, seeking to balance the requirements for investment to support providing world-leading communications services, while ensuring affordability for all Canadians, including those in rural and remote areas. Last August, former Minister Bains succinctly summarized the policy as “Canada’s future depends on connectivity”.

Canada’s future depends on connectivity. Our government recognizes that access to affordable, high-quality high-speed Internet is a necessity for all Canadians, no matter where they live.

The COVID-19 pandemic has only reinforced the importance of connectivity. The investments our government is making in high-quality networks, particularly in rural and remote communities, are key to ensuring equitable digital access for all Canadians. Equitable access also means that it is available at fair prices that Canadians can afford.

The message from Minister Bains last summer expressed the perspective of Cabinet: “On the basis of its review, 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.”

The critical importance of maintaining a balance of competing policy objectives figured prominently. Quality, coverage, and price.

In a blog post in late August (“Acting in the public interest”), I wrote about the tension between these policy objectives. I noted that Minister Bains was careful in defining “Price” as “offering service at an affordable level.” As such, it is clear that an affordable price is not necessarily the same as having the lowest price. “Acting in the public interest involves balancing priorities to achieve an optimal outcome. It isn’t all about price.”

There can be a high cost associated with low prices. Israel serves as an example of what happens to quality when there is a singular focus on reducing prices, as Canadians have been warned: “Prices did fall, but so did the quality of the networks. The massive reductions to revenues caused major reductions in capital expenditures, network roll-out and expansion, market capitalizations of the participants and even the number of employees.”

The past year has highlighted the importance of investment in world-leading technologies and extending the geographic reach of Canada’s mobile and wireline broadband networks. A policy framework that encourages network investment is the best way to accelerate expansion of quality infrastructure into unserved territory. The vast majority of investment in networks – rural and urban, wireless and wireline – comes from the private sector, not government. While governments support and supplement network investment by carriers, large and small, governments do not (and generally should not) supplant private sector investment.

To the extent affordability is a concern, perhaps targeted support programs can be developed to supplement Connecting Families, without increasing the level of regulatory intervention in the market, consistent with the objectives of Canada’s telecom policy.

Will the CRTC’s review of mobile services and its determination on the application to review wholesale internet rates create a shift in the balance between quality, coverage and price? These proceedings are foundational, with the potential to cause significant shifts and disruptions in the marketplace and the investment climate.

The mandate letter for Minister Champagne appears to provide for continuity in Canada’s digital policy priorities. The letter incorporates Minister Bains’ mandate letter by reference (“In addition to the priorities set out in my mandate letters of 2019…”), and is entitled “Supplementary Mandate Letter.”

It is interesting that the matter of rural broadband appears in both letters. In the December 2019 letter, broadband is referenced as:

Work with the Minister of Infrastructure and Communities, the Minister for Women and Gender Equality and Rural Economic Development and the Minister of Canadian Heritage to deliver high-speed internet to 100 per cent of Canadian homes and businesses by 2030.

Thirteen months later, in a COVID environment, the new letter says:

Recognizing that all Canadians need the tools to fully participate in and benefit from the digital economy, support the Minister for Women and Gender Equality and Rural Economic Development on the continued implementation of the Universal Broadband Fund to ensure that all Canadians, no matter where they live, have access to high-speed internet. Your work should include considerations around the effective use and deployment of innovative technologies, such as low-earth-orbit (LEO) satellites, to connect all Canadians.

I found the removal of the 2030 deadline in the supplemental letter as interesting, and perhaps noteworthy. Similarly, the specificity of LEO technologies and “considerations around the effective use and deployment of innovative technologies” merit further consideration. Is it a signal to favour policies to drive investment in facilities?

How should we interpret silence in the supplemental letter regarding other areas of the Minister’s mandate? Is it a signal that the government is satisfied with progress made to date in areas such as reductions in mobile pricing?

How will the government encourage deployment of digital infrastructure, in urban and rural markets, while preserving the balance (and tension) between quality, coverage and price?

Last week, an article in the Globe and Mail called for a reboot of Canada’s digital agenda.

On that headline point, I agree. A reboot may be needed.

As part of a typical reboot process, systems start fresh with clean data, clearing out faulty information. Some systems apply filters to improve the signal to noise ratios. As part of the reboot process, the government should ensure the information being loaded for processing passes error checks.

Unfortunately, I found a few points in the article that would fail error detection algorithms.

For example, in the second paragraph, we read:

The Liberals identified consumer telecom pricing, privacy protection and a modernized internet legal framework as priorities, but have struggled to develop an effective approach. Navdeep Bains, the Innovation, Science and Industry Minister, surprisingly backed a reversal on the affordability of communications services last month and has done little on privacy reform.

There is a little sleight of hand at work in those two sentences. Although affordability and prices are related, they are not the same and the terms should not have been used interchangeably. Indeed, recall from my post in January that a report from PwC found Canada’s telecom services to be the most affordable of all our G7 partners.

Contrary to the article’s assertion, it isn’t true that Minister Bains “backed a reversal on the affordability of communications services last month.” That simply didn’t happen.

The article is apparently referring to last month’s Order in Council responding to a petition to review the CRTC’s wholesale rates Order of August 2019. Minister Bains explicitly said “Canada’s future depends on connectivity,” and indicated that Cabinet was concerned the CRTC had not balanced the objectives in a manner consistent with the government’s priorities. Minister Bains specifically chose not to act at this time, recognizing that the CRTC was already reviewing its decision. Instead, the Minister more clearly indicated the policy of the government. That is precisely what the government is supposed to be doing.

The government’s telecom policy has never had a single-minded focus on price. As I wrote a couple weeks ago, for years now, Minister Bains has consistently spoken of 3 priorities: Quality, Coverage, and Price. Price is just one element. Last month’s Order in Council should be recognized for helping guide the regulator through the challenges of balancing the policy objectives.

Look at the language of the Order in Council:

• “the Commission… is bound… to exercise its powers and perform its duties with a view to implementing the Canadian telecommunications policy objectives and in accordance with any orders made by the Governor in Council”
• “improved consumer choice and competition, further investment in high-quality networks, innovative service offerings and reasonable prices for consumers”
• “considers that the final rates set by the decision do not, in all instances, appropriately balance the objectives of the wholesale services framework… and that they will, in some instances, undermine investment in high-quality networks.”

The Order in Council sought to clarify the need for maintaining the balance.

Indeed, the Globe article itself acknowledges that “fast internet access is a must for all Canadians”, as we have all seen over the past 6 months of being home-bound. Unfortunately, the reader of the Globe article is left without an understanding of the tension between the objectives of quality, coverage and price.

Around the world, we can see what happens when low prices constrain investment, or what I have called the “high cost of low prices”.

The message from Cabinet was clear.

On the basis of its review, 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. Retroactive payments to affected wholesale clients are appropriate in principle and can foster cooperation in regulatory proceedings. However, these payments, which reflect the rates, must be balanced so as not to stifle network investments. Incentives for ongoing investment, particularly to foster enhanced connectivity for those who are unserved or underserved, are a critical objective of the overall policies governing telecommunications, including these wholesale rates.

This should not be viewed as a “reversal on the affordability of communications services.” Instead, as should be evident to most Canadians over the past 6 months, the pandemic has helped elevate awareness in the importance of Quality and Coverage, the other two legs of the Minister’s priorities. The government called for improving the balance to preserve incentives for investment, the key input to ensure Canadians have access to world leading network quality, covering urban and rural areas.

The vast majority of investment in networks – rural and urban, wireless and wireline – the overwhelming majority of capital investment in Canadian networks comes from the private sector, not government. While governments support and supplement network investment by carriers, large and small, governments do not (and generally should not) supplant private sector investment. An approach based on strategic, targeted support helps to ensure a greater reliance on market forces to achieve the objectives of Canada’s telecom policy.

As Cabinet understands, in many cases support for private sector investment does not require cash as much as it requires a policy environment that encourages investment. Cabinet more clearly understands the economics the drive network investment, as I discussed a few weeks ago in “The economics of broadband expansion”.

The Globe article also seems to be confused between judicial appeals and cabinet appeals of regulatory decisions. The article says “the government’s approach seems particularly troubling given that the Federal Court of Appeal last week upheld the CRTC decision.” In reality, this should not be troubling at all; there is no linkage between the two appeals.

In fact, the ruling of the Federal Court of Appeal itself answers the concerns that the article finds “troubling”. As stated by the Court at paragraph 23:

[23] Significantly, neither section 62 nor subsection 12(1) circumscribe the types of questions that may be raised before the CRTC or the Governor in Council. This stands in contradistinction to the prescription in subsection 64(1) that limits this Court to reviewing questions of law or jurisdiction.

The Court is limited to ruling only on “questions of law or jurisdiction” while there are no limits on the scope of issues that may be raised in appeals to Cabinet (the “Governor in Council”) or the CRTC. So, it is completely consistent for a Court to find no fault with questions of law or jurisdiction, but have Cabinet to take issue with a CRTC decision on the basis of matters of policy.

There are valid concerns raised about delays in launching new broadband funding programs and we have unfortunately squandered 3 months of prime broadband construction season in failing to implement what I described as “An easy way to increase rural broadband speeds”.

Looking forward, we need serious discussions on the role of government in implementing the recommendations of the Broadcast and Telecom Legislative Review and updates to other areas impacting the digital economy.

But we need to make sure that when the government does its reboot, it carefully examines the data being input for processing. Much of it needs error-checking.

What does it mean to act in the public interest for telecommunications?

Does it mean working to get Canadians universal access to the fastest internet speeds? The lowest prices? The greatest coverage? All of the above?

There are few people who would say they oppose lower prices, faster speeds or improving coverage. In his remarks opening The 2017 Canadian Telecom Summit, Minister Bains said:

our government understands that Canadians want three things from their telecom services.

• Quality. Is the service fast enough to do what I want it to do?
• Coverage. Is the service available where I want it to be?
• and lastly, Price. Is this service affordable?

These three areas are clearly where providers need to compete and that’s why our Government is doing our part to promote competition and investment. The goal is very clear. We want to improve quality, coverage and price for all Canadians.

There is a tension that ties these together. Quality and coverage each require capital investment, which in the Canadian context is measured in billions of dollars each year. Canada has achieved world leading quality scores for our mobile and fixed line networks. The overwhelming majority of Canadians have access to the latest generation of wireless technology, delivering the fastest speeds in the world.

The Minister carefully defined “Price” as offering service at an affordable level. An affordable price is not necessarily the same as the lowest price. PwC recently looked at Canada’s mobile affordability and described its analytic process in concluding “Canadian mobile services top G7 affordability ranking”:

To provide a holistic view of wireless affordability in Canada, this report examined a number of aspects related to the overall affordability of consumer wireless in Canada, including:

1. The changing pattern of household expenditures, as wireless data use is enabling a different delivery of products and services – including the substitution of select historic spend categories by wireless.
2. The assessment of wireless affordability in Canada, as measured by recognized affordability metrics.
3. The affordability of wireless services for Canadians in proportion to their income relative to other jurisdictions.

As I concluded at the time, “We need to focus on strategies to drive “demand”: increasing adoption rates among groups that could subscribe, but have not. That is a problem across all geographies, and perhaps more pronounced in urban markets. That should start with developing a greater understanding of those individuals and households on the wrong side of the digital divide.” Last week, I wrote more about “Using evidence to solve the digital divide.”

The third leg, coverage, is a real challenge. Many countries define regions as “rural” in terms of population densities that Canada considers to be “suburban”. Not only are there remarkably low population densities in some areas, but some of these are in extremely harsh geographies or so far north to be difficult for equatorial geostationary orbit satellites to “see”. Other underserved areas are close to high quality networks but located just beyond the economic reach of existing service providers. These households are perhaps the most frustrated, and understandably so.

In some cases, it means direct subsidy to offset the uneconomic costs associated with building to an area. Government subsidy programs only amount to a fraction of the level of investment required to extend coverage to unserved and underserved areas. The balance comes from the private sector.

The challenge is how do we create the right environment to incent investment. In some cases, there can be policy incentives, ranging from simplifying approval processes, making available government owned (or government controlled) passive infrastructure, or changing regulatory disincentives. It is important to understand that the current regulatory and financial conditions do not support the business case for extending service to other regions. To incent investment, there has to be an increase in top line revenue or a reduction in costs. Some of these levers are within the control of regulators and policy makers.

Acting in the public interest involves balancing priorities to achieve an optimal outcome. It isn’t all about price. As a nation, we can use targeted subsidies, or programs like Connecting Families to aid with affordability.

It takes a certain level of intellectual maturity to understand that reaching an optimal balance of Quality, Coverage, and Price is a challenge in the Canadian environment. There are trade-offs and prioritization required, especially in these difficult economic times with extraordinary and shift demands for connectivity.

Ultimately, the responsibility for determining the policy priorities rests with the government. Given the response to the pandemic, it is understandable that the federal Cabinet decided Canada’s future depends on connectivity.

How does this shift the equilibrium between Quality, Coverage, and Price?