The CRTC needs to connect with Canadians, not consult with them

What follows contains some references for which links have disappeared since August 2010. Therein lies one of the most town criercompelling signs that the way the Commission does research is in sorry shape. Canada needs good information about broadband collected and stored in databases where it can be accessed in the future, rather than evaporate overnight. As you’ll see, this is just one of many reasons to question why the Commission undertook this exercise and how it reflects on Ottawa’s misguided policy priorities.

Anatomy of a public consultation

Friday August 20 marked the last official day of the CRTC’s 4-week online consultation on the “obligation to serve” (link may die any time). In a previous post I looked briefly at the Pew Internet’s current Home Broadband survey, in particular, the things people say about why they’re not on broadband.

I saw a hook to the CRTC consultation, since the consultation is focussed heavily on a similar group in Canada: those who don’t have broadband because they live in rural and remote parts of the country. That’s where the similarities end.

The Pew survey, like all Pew’s work, is rigorous and empirical, yielding results that can form part of a policy-oriented discussion (even if you don’t agree with all their conclusions). It is a) a tracking survey, i.e. done on a regular basis to identify trends over time; b) based on a large sample (N=2,252), which allows for over-sampling of minorities, regional populations, etc; and c) done by random, which means the results are representative of the US adult population within known margins of error.

The CRTC consultation, on the other hand, was initiated “to hear Canadians’ thoughts about their access to basic telephone and Internet services” (About this consultation). That’s the stated goal. The truth is the consultation couldn’t make up its mind what it was. It turned out like a shaky combination of crowdsourcing (to unearth novel policy ideas); surveying (to see what Canadians think); and marketing (to inform visitors what the CRTC thinks).

crtc broadband consultation obligation serve rural


Why the consultation was a bad idea

Let’s look at some of the things that went wrong (more detailed discussion follows below):

Methodology. An online, self-selected consultation has all the disadvantages of a townhall meeting or focus group and none of the advantages, particularly the ability of organizers and participants to engage in a real-time conversation. The five main questions asked of visitors are either far too technical or far too obvious; there is nothing representative about the responses; and the consultation was fielded during the dog days of summer, making participation even less likely.

Content. Much of the material on the site reads like an administrative law textbook. This problem starts with the site title itself: Consultation on the Obligation to Serve. Non-expert visitors can’t be expected to make the connection between better broadband (or basic telephony) and the regulatory principle of universal service obligations. And this is the Web. Visitors are in a hurry. You don’t want to give them extra reasons for not sticking around.

Policy assumptions. The CRTC is hewing to the current government’s time-honored message: the only real issue in broadband is Canada has too much geography. While we worry about connecting rural Canadians, broadband is available “virtually everywhere in urban centres.” Thus, speed and pricing are conspicuous by their absence, as is any recognition that “availability” includes awareness and affordability. I have an available Cartier boutique right in my building; that doesn’t mean I buy my watches there.

Social networking sites (SNS). In a gesture to Web 2.0, the site has a YouTube video imbed and links to several sites like Twitter. As I’ll show from the Web server analytics (in Part 2), this aspect of the site is a poorly planned shot in the dark that yields nothing of substance – little traffic, no SNS dialog, no viral activity.

Questionable questions

Let’s begin with the “ask.” For an agency that thrives on posing sharp questions in PNs and at hearings, the list of five questions here leaves much to be desired:

  1. What services should be included as part of your basic telephone services today?
  2. In the context of this objective, what role, if any, should the CRTC play in ensuring that all Canadians have access to broadband Internet service at comparable rates?
  3. Do you think that cellphone service can be a substitute for traditional home phone landline service? Explain why or why not.
  4. Do you think that wireless services (e.g. Wi-Fi, 3G networks or satellite) can be substitutes for landline services to connect to the Internet? Explain why or why not.
  5. For what activities do you use or expect to use your Internet service?

These questions are a strange mix of either pointless or way too difficult. I put 1, 3 and 5 in the former category, and 2 and 4 in the latter. Whereas #3 could be answered by any 20-something (doh!), a cogent answer to #4 presupposes a knowledge of next-gen networks, last-mile business issues, and line-of-site and other barriers to wireless deployment. Let’s say 500 respondents were to argue in their comments why they think cellphones cannot be a substitute for traditional telephony. What would that change?

I have more serious issues with the two broadband questions (2 and 5), starting with the sleight-of-hand in #2 about broadband rates:

2. In the context of this objective, what role, if any, should the CRTC play in ensuring all Canadians have access to broadband Internet service at comparable rates? (emphasis mine)

This question assumes rates should not necessarily be affordable but only “comparable.” This is a significant policy choice on the Commission’s part. Data from the OECD, Harvard’s Berkman Center, Waverman’s Connectivity Report and others all confirm that Canadian broadband prices are way too high compared to other developed countries. This is simply not a debate any more. Why does the consultation site pretend this problem doesn’t exist?

And the ultimate irony. The consultation has excluded the very people the CRTC says most need help: those in rural Canada without broadband. They belong to two sub-groups: those who are still on dialup and those who aren’t online at all. Even if you are online on rural dialup, you’re very unlikely to participate in this forum, because you haven’t got the juice. Meanwhile, Canadians in urban areas who are affected by high prices and slow speeds are not being asked to comment on issues that actually affect them, but on an issue that doesn’t affect them. To paraphrase Woody Allen, I’m not sure I’d want to ask a group that included city slickers like me how to fix rural broadband.

Broadband that’s too basic

While not addressed explicitly in the questions, there’s another questionable assumption lurking in the Glossary: the CRTC’s putative definition of “broadband”…

Low-speed Internet service includes speeds that are below 128 kilobits per second (128 Kbps). High-speed Internet service includes speeds at or above 128 kilobits per second (128 Kbps). Broadband Internet access service includes speeds that are above 1.5 megabits per second (Mbps) [see consultation Glossary, Broadband Internet].

The problem with this assertion is there is no accepted definition of broadband (see e.g. the Wikipedia entry). These happen to be the CRTC’s benchmark speeds (used in some form in the Commission’s annual Communications Monitoring Report: see e.g. the 2009 version, footnotes 229 and 230, p.213). We also know that when definitions are proposed, they reflect self-interest: public interest advocates want thresholds high, ISPs want them low.

So what is a reasonable benchmark for broadband?

The answer may lie in yet another invidious comparison with the FCC. The same week the consultation was being launched, the FCC’s Democratic majority signed off on the Sixth Broadband Deployment Report (GN Docket No. 09-137; download file FCC-10-129A1.pdf), which made a widely-discussed change to the rules (pp.7-8): a redefinition of broadband as 4 Mbps in the downlink and 1 Mbps in the uplink. The change was a big one and a long time coming: it had been a stunningly inadequate 200 Kbps. The document is worth quoting because of the consumer-oriented reasoning behind the change:

Today, Americans increasingly are using their broadband connections to access high-quality video, and we anticipate that this demand will only continue to grow in the future. For example, many Americans now communicate with their families and friends through desktop videoconference calls. Many users also now post their own videos and view others’ on such sites as YouTube and Hulu. Instead of reading articles online, Americans often watch videos of today’s top stories. The growth and demand for high-quality videos by Americans is substantial, and this demand is expected to grow at over 40 percent and 120 percent per year, respectively, through 2013.

Thus, for purposes of this report, we update the Commission’s broadband speed threshold. Specifically, we benchmark broadband as a transmission service that actually enables an end user to download content from the Internet at 4 Mbps and to upload such content at 1 Mbps over the broadband provider’s network.

The FCC has availed itself of data in the public domain that indicate last-mile bandwidth needs are climbing fast. One such source is Cisco’s Visual Networking Index: Forecast and Methodology, 2009–2014 (various links here). Cisco’s estimates for North America indicate we’re undergoing a 30% annual increase (CAGR) over this period in combined IP traffic – from about 5 exabytes in 2009 to a projected 19 exabytes in 2014 (p.7). How do the Commission and Industry Canada propose to manage these increases in usage while pretending 80% of Canadians can manage fine with the broadband they have?

In case you were wondering… One (1) exabyte is 1,000 petabytes or 250 million DVDs. One petabyte is 1,000 terabytes. Five (5) exabytes is the equivalent of a transcript of all the words ever spoken by humans. And that was last year’s traffic in North America alone!

This completes my look at some of the policy and content shortcomings of the consultation. The accompanying post (from August 22) examines the use of social media tools on the consultation site and why they didn’t do the job.





3 thoughts on “The CRTC needs to connect with Canadians, not consult with them

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  2. Excellent analysis. It seems to me the CRTC has an objective in mind (more regulation…it’s their jobs) and they are going to get there regardless. Seems in line with the conflict of interest in politicians approving their own raises.

    You wrote, “Canadians in urban areas who are affected by high prices and slow speeds are not being asked to comment on issues that actually affect them, but on an issue that doesn’t affect them.” I agree with the primary point of the argument, however, Canadians in urban areas would be affected if subsidies from urban to rural areas continue or are increased.

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