{"id":20065,"date":"2026-11-10T05:01:32","date_gmt":"2026-11-10T10:01:32","guid":{"rendered":"https:\/\/mhgoldberg.com\/blog\/?p=20065"},"modified":"2026-11-09T04:17:54","modified_gmt":"2026-11-09T09:17:54","slug":"iseds-telecom-competition-roadmap","status":"publish","type":"post","link":"https:\/\/mhgoldberg.com\/blog\/?p=20065","title":{"rendered":"Canada’s telecom competition roadmap"},"content":{"rendered":"

When ISED’s Telecom Competition Roadmap<\/a> was first released, I quickly provided a link<\/a> to it, promising to say more in the coming weeks. And so, here we are. It is especially timely, given the release<\/a> of the Federal Budget [pdf<\/a>, 10.3 MB] last week that included references to the Roadmap.<\/p>\n

My initial reaction was that the document is somewhat naive. I wouldn’t call it wrong, but I found it comes across as naive in a number of important ways.<\/p>\n

For example, the Roadmap says,<\/p>\n

Building on regulatory changes to facilitate switching, the Government will promote high value plans in the market. These efforts will focus on highlighting the lowest cost and best value plans available, in order to help consumers take advantage of the latest offers and reduce the cost of living.<\/p><\/blockquote>\n

The government already has a website<\/a> to steer people to neutral third party price comparison tools. AI agents are widely available to consumers. Does the government plan to decide which plans are best for Canadians and become a marketing agency for those plans? How will “best value” be determined? Lowest price? Most data? Number of countries in roaming plans? Bundled devices? National coverage? Quality experienced in each neighbourhood? Will the government have customer service staff to answer consumers questions about the options getting promoted or field complaints about those plans the government promotes?<\/p>\n

It is as though the authors were thinking that purchasing mobile services is like finding the lowest price per gallon for gasoline before topping up your car’s gas tank. <\/p>\n

The Roadmap seems to be framed around a very simple theory: More competition \u2192 lower prices \u2192 better outcomes for consumers.<\/p>\n

That’s politically attractive, but telecom has always been a sector where the hard question isn’t whether competition is good. It’s what kind of competition is sustainable. The Roadmap tends to assume that if government removes barriers and improves wholesale access, durable national competition will naturally – perhaps magically – emerge.<\/p>\n

Here are a few observations I have made from reviewing the Telecom Competition Roadmap:<\/p>\n

1. It treats competition as the objective instead of a means<\/strong><\/h4>\n

The document repeatedly describes “cross-Canada competition” as the central policy goal. Competition in and of itself shouldn’t be what policy is striving for. Historically, Canadian telecom policy has tried to balance a number of objectives: affordability; investment for coverage, quality, resilience, advanced technology and services, etc.<\/p>\n

While the Roadmap acknowledges investment, competition seems to dominate the framework.<\/p>\n

That matters because there are real tradeoffs. A policy that maximizes short-term retail competition can reduce returns on network investment. A policy that maximizes investment can increase concentration. The Roadmap often reads as though those tensions can largely be engineered away.<\/p>\n

They can’t.<\/p>\n

2. It assumes wholesale competition naturally evolves into facilities-based competition<\/strong><\/h4>\n

This is probably the biggest conceptual weakness. The Roadmap strongly emphasizes FTTH wholesale access and MVNO access as mechanisms to create national competitors. The implicit theory is:<\/p>\n

    \n
  1. competitor gets access;<\/li>\n
  2. competitor gains customers;<\/li>\n
  3. competitor expands;<\/li>\n
  4. competitor eventually builds more infrastructure.<\/li>\n<\/ol>\n

    But Canadian history provides mixed evidence for that progression.<\/p>\n

    Many wholesale-based providers became very effective retailers. What is much more rare is the transition from reseller to nationwide infrastructure owner. Building fibre and wireless networks requires extraordinary capital and scale.<\/p>\n

    The Roadmap talks about supporting “cross-Canada competition” as though a national competitor is mainly being held back by regulatory barriers. In reality, economics may be a much bigger constraint than regulation.<\/p>\n

    3. Its treatment of market power is somewhat one-dimensional<\/strong><\/h4>\n

    The Roadmap emphasizes incumbent advantages, natural monopoly characteristics, poles, towers, spectrum, and first-mover benefits. Those observations may be true. But telecom economics are not merely a story of incumbent power. They are also a story of scale efficiencies.<\/p>\n

    A network serving ten million subscribers can often operate more efficiently per customer than one serving one million subscribers.<\/p>\n

    The Roadmap discusses the first phenomenon extensively and the second only lightly. As a result, the reader can come away thinking concentration primarily reflects policy failure rather than technological and economic realities.<\/p>\n

    Those realities don’t excuse concentration, but they do constrain what policy can realistically achieve.<\/p>\n

    4. It understates the success of the market over the last few years<\/strong><\/h4>\n

    This is where I think the Roadmap is disconnected from recent evidence.<\/p>\n

    The document notes that wireless prices have fallen substantially since 2019 and cites a 49% decline in Statistics Canada’s Cellular Services Index. The Federal Budget acknowledges “the price of a 60 GB mobile plan falling from an average of $105 in 2022 to being widely available in the $40 to $50 range.<\/p>\n

    That’s no small achievement.<\/p>\n

    Yet the Roadmap and the Budget are written as though the fundamental policy model still requires major correction. <\/p>\n

    A tougher question would have been: “If prices have already fallen dramatically, which policy interventions were actually responsible?”<\/p>\n

    The document mostly sidesteps that question. It assumes more government intervention is the answer, rather than carefully isolating which regulations produced measurable results and which did not. <\/p>\n

    5. “Dig once” and faster approvals are probably the strongest parts<\/strong><\/h4>\n

    Ironically, I found that the least ideological sections are the most persuasive.<\/p>\n