Bricks and mortar with window, Spitalfields, London E1, August 2013
How can the CRTC do a better job?
As I argued in the previous two posts, the CMR doesn’t have a life of its own; it reflects the CRTC’s larger priorities. The big one here is research and evidence-based policymaking. A close second is the Commission’s still awkward fashion of trying to reach out to the little people – i.e. anybody besides the inner circle. Here are my suggestions for how it can do what it apparently wants to do, only better:
1 – Stop wasting money on online consultations. Redeploy it for real consumer research. Online consultations aren’t just a waste of money; they can also be highly misleading. One reason for their being unrepresentative is that online “surveys” of the public can’t reach Canadians who aren’t online to begin with. Unfortunately, the Commission isn’t going to find any new money for research, not as long as it sticks to the current Expenditure Profile. As shown in the graph below, the Commission’s spending is pretty much flat from 2009 to 2016, especially if these figures were converted to constant dollars…
Source: CRTC Departmental Spending Trend
2 – Report on the state of Canadian communications honestly. Stop trying to whitewash our policy and market failures. Stop doing phoney international comparisons based on cherry-picking four or five other countries, without any empirical rationale. Use the public data available from Ookla, the OECD, ITU, etc. It’s far better and doesn’t cost anything. Ironically, the Commission notes the following in its current Report on Plans and Priorities, under International Activities: “… the CRTC will continue to work closely with Canadian counterparts, participate in research activities such as the studies by the International Telecommunications Union (ITU) and the Organization for Economic Cooperation and Development (OECD)…” Question: where are the fruits of these research collaborations?
3 – Make research for the general public really, really accessible. Nobody at the Commission should attempt to change the well-entrenched industry bent of the CMR. Instead, communications staff should team up with the number crunchers and produce a separate stream of research vehicles for regular folks. And all of it should be available on a completely overhauled CRTC website. That overhaul is likely to happen only if someone can persuade the Treasury Board overlords to exempt the CRTC from their draconian Web Standards, which assume it’s in the public interest to make all federal websites look exactly the same. (To show just how little sense this makes, here’s what the CRTC says in the current plan for its internal services: “The CRTC will also redesign its website in a manner that is compliant with Government of Canada standards for accessibility, plain language and is organized with the end-user in mind.” The triumph of brand over usability.)
4 – Be an educator as well as a regulator. Any lay research reporting should see public education as a fundamental part of its mission. Canadians are desperately confused about what the conglomerates sell them. Over the years I’ve been teaching my seminar on the broadband Internet, I consistently find 90% or more of incoming 4th-year students are incapable of identifying, let alone defining, technologies they see and use every day. These are 20-something Comm Studies majors, who are online all the time and heavy users of Web resources like YouTube. In my current crop, not a single person in the first class knew what “Mbit/s” or “720p” stands for. Imagine the bafflement that must confront older mainstreamers.
5 – Follow the example set by the FCC and Ofcom. The CRTC needs to develop a corporate culture that respects social research. Chairman Blais can’t rebuild Rome in a year or two. By the same token, he can’t expect to infuse the Commission’s work with a new-found respect for the consumer if he doesn’t get his staff to prioritize consumer research. To do that, he has only to point them to what their counterparts in Washington and London are doing. Three years ago, I wrote two posts on the anatomy of an online consultation – a perfect example of how not to do consumer research (here and here). The FCC has also taken its educational mission to heart.
As Pete Nowak said facetiously in his recent post, the 2013 CMR “should be on every Canadian’s required reading list.” The irony is that some version of the CMR research should indeed be read by a lot more Canadians. I’ll admit this is no easy job. So let me close with one small example of the trade-offs involved and one possible way of shifting priorities in favor of the consumer.
In the infographics that accompanied the launch of the CMR, the staff prepared some nifty illustrations to set the scene. For example:
While handy for experts, these figures will be meaningless to everyone else, since non-experts don’t know what a gigabyte is, let alone what those figures imply for the cost and quality of broadband service. Yet if you dig deep enough, the CMR actually provides some useful indicators of what broadband consumption patterns look like, and how they relate to industry practices like the use of data caps. If only they were easy to grasp!
Thus, on page 176 of the CMR (Table 6.1.2), we find a useful attempt to “give readers an idea of how much data is used when enjoying various online audio and video services.” The table actually goes a step further and breaks out a version of what is called the “burn rate” for various data cap levels (the CMR doesn’t use this term). Here’s a snippet from that table:
If you’re a Canadian Netflix subscriber – like the student’s family I mentioned last time – your choice of ISP speed tier, and thus of data cap, is crucial, as is the video setting in the Netflix preferences panel. If you weren’t sure before why data caps are such a ruthlessly effective tool, just look at the effect they have on limiting consumption. Low-income Canadians, the ones who have to subscribe to the cheapest tiers, are sorely disenfranchised by caps. If you have a 20-gig cap and set your video quality for the middle (Better), you might be able to squeee in six hi-def movies a month – and that’s assuming you don’t go online to do anything else.
So let me add one more suggestion to my list:
6 – Help Canadians manage their services and save money. As part of a public education mission, the CRTC must find ways to get “pocketbook” information to mainstream users. No mainstreamer is ever going to find information about burn rates on page 176 of a document like this – nor on any incumbent’s website. Having promoted this price-gouging tool to discourage Canadians from spending “too much” time on the Internet as one of its “economic” ITMPs, the least the Commission can do now is help consumers understand how not to be victimized by their ISP, and the bafflegab that goes with selling Internet access in this country.
It’s time for the CRTC to institute an annual Report to Consumers – about and for consumers, a clear and readable learning tool that won’t shy away from admitting mistakes and showing where Canada has room for improvement compared to other developed countries. Otherwise, what Canadians don’t know will just keep on hurting them.