Abstract
Many rural and remote Canadians continue to experience a digital divide. Internet Service Providers (ISPs) operating in these communities play a crucial role in connecting Canadians, yet they are understudied. This study aims to address this gap in the literature by focusing on policy, regulatory, and competitive challenges and issues facing small ISPs. Small ISPs face competitive pressures, but more importantly deal with regulatory challenges induced by the lack of a coherent national approach to rural broadband. Ten Canadian ISPs were interviewed as part of this study. The paper recommends the Government of Canada develop a national broadband strategy informed in part through consultation with small ISPs.
High broadband speeds, low subscription prices, and innovative service offerings are found in areas where consumers have multiple choices for a broadband service provider.1 Despite the existence of more than 500 domestic Internet Service Providers (ISPs) in Canada, the lack of competition and consumer choice in the Canadian broadband market has been consistently identified as a key issue.2 Canada's market is dominated by a handful of large ISPs; the five largest ISPs (Bell, Rogers, Shaw, Telus, and Videotron) captured 73.1 percent of broadband revenues in 2016.3 Moreover, Canada's domestic telecom providers are shielded from competition from foreign providers,4 and the country is one of only four Organisation for Economic Cooperation and Development (OECD) countries maintaining general restrictions on foreign investment in the telecommunications sector.5 Although urban markets, where the clear majority of Canadians live,6 benefit from competition among large ISPs (particularly between incumbent telecommunications service providers and cable companies), rural Canadians have far fewer choices and live in less competitive markets. The challenges of rural Canadians were recently highlighted by Christianne Laizner, Canadian Radio-television and Telecommunications Commission (CRTC) Vice-Chairperson for Telecommunications, when she noted that millions of Canadians in rural and remote communities face significant barriers to participation in the digital economy.7 Small ISPs play an important role in providing Internet service in rural and remote Canada, and can create competition necessary to drive down prices and improve service offerings; however, these companies face many barriers. This study aims to examine the perspectives of small ISPs8 on Canadian policy and telecom sector competition through an examination of data collected from interviews with representatives of several small ISPs based in Western Canada.
Policy and Competition Context of Canada's Telecommunications Sector
ISPs in Canada, both large and small, are bound by the policy and regulatory landscape for telecommunications in Canada as well as the nature and structure of the domestic telecom market. Regulation and competition are intertwined in shaping the Canadian telecom sector. Policymaking and regulatory functions are bifurcated between the federal department of Innovation, Science and Economic Development Canada (ISED) and the CRTC, with the former responsible for most policymaking functions and also regulation of the wireless sector and the latter being the arm's length, quasi-judicial federal regulator that also engages in some policymaking functions.9 Canada's division of policy and regulatory functions between ISED and the CRTC is not common, and there have been repeated calls to concentrate policymaking functions within ISED and empower the CRTC to regulate both the wireline and wireless sectors.10 At the highest level, Canadian telecom policy is enshrined in the Telecommunications Act, specifically section 7, which outlines the country's telecom policy objectives. These objectives clearly underscore that both urban and rural Canadians should have reliable, affordable, and high-quality services.11 The policy objectives also give competition an important role in the telecom sector, as fostering increased reliance on market forces is another policy objective.12 Over the last decade, the emphasis on market forces and competition over regulation has been reflected in two key policies. Following the recommendations of the 2006 Telecommunications Policy Review Panel (TPRP),13 the CRTC was directed by the federal Cabinet to “rely on market forces to the maximum extent feasible as the means of achieving the telecommunications policy objectives” and use minimal regulation.14 Following this directive in 2007, the Spectrum Policy Framework for Canada was also revised to emphasize maximal reliance on market forces.15 While market forces have been given preeminence in Canadian telecom regulation, a number of important regulatory decisions still shape the sector including the CRTC's emphasis on facilities-based competition, changes to the regulation of the wholesale broadband market, federal spending programs to increase rural broadband access, and a CRTC decision declaring broadband a basic telecommunication service.16 It should be also noted that while telecommunications is a federal responsibility, Canada's provinces and territories have had various approaches to spurring broadband deployment, but a full review of these programs is beyond the scope of the paper.17
One significant gap in Canada's broadband policy and regulation is the lack of an overarching strategy. While the policy objectives in the Telecommunications Act indicate the direction of Canadian telecom policy, the lack of strategy is notable. This crucial gap was underscored by then CRTC chairman Jean-Pierre Blais during the 2016 basic telecom services hearing where he stated:
Every day that goes by without a more robust Canadian broadband strategy means a Canadian who is socially and economically vulnerable continues to be profoundly disadvantaged …
Every month that goes by without a more robust Canadian broadband strategy means Canada is competitively disadvantaged as other countries move ahead and advance on their digital productivity, innovation, and competitiveness.
We are heading quickly, if we are not already there, towards a digital society and a digital knowledge-based economy, the society of algorithms. Canada needs a plan.18
While the CRTC Commissioner Blaishas highlighted the importance of a broadband strategy ISED has to date failed to deliver one.
One key aspect of Canadian telecommunications is the CRTC's emphasis on facilities-based, rather than services-based, competition. In decisions from 1997 to 2002 the national communications regulator, the CRTC, established a preference for facilities-based competition in telecommunication services,19 which continues to shape its decision-making for broadband.20 Although facilities-based competition is a key dimension of Canadian telecom policy, the CRTC also believes that the approach works best when incumbent carriers make available facilities essential for competition.21 In 2008, the Commission set out a mechanism for mandating wholesale access to certain types of broadband infrastructure, specifically aggregated ADSL and cable access high-speed services.22 In 2015, the Commission revised its regulation of the wholesale regime established in 2008 by switching from an approach that provided aggregated mandated access to both access (last-mile) and transport infrastructure to a disaggregated model that included mandated wholesale access to high speed access services including FTTP infrastructure.23 While the CRTC's wholesale regime does provide a means by which ISPs can rely on access infrastructure of other companies, it is important to note that mandated access to essential fiber transport facilities has not been adopted by the CRTC. In the 2015 decision changing the wholesale regime the Commission specifically suggested that it was “practical and feasible” for companies to duplicate transport infrastructure,24 despite calls for mandated access to fiber-based transport infrastructure from groups such as the Canadian Network Operators Consortium (CNOC), which represents many smaller and mid-sized ISPs.25 The combination of an emphasis on market forces and facilities-based competition can been seen as privileging large, incumbent providers with greater market power.
The challenges faced by ISPs in rural Canada have not gone completely unnoticed by the federal government. Over the past decade there have been two programs from Industry Canada (recently renamed ISED) subsidizing ISPs' incursion into unserved or underserved areas. The “Broadband Canada: Connecting Rural Canadians” program ran from 2009 to 2012 investing $190 million, and the “Connecting Canadians” program, which is in the process of concluding has had an allocated total budget of $305 million for rural and remote communities.26 ISED's most recent27 $500 million program, “Connect to Innovate” aims to enhance rural and remote connectivity as well,28 but this time with an emphasis on backbone infrastructure with only limited funds for last-mile connections.29 One part of this paper is an examination of small ISPs perspectives on these recent federal programs.
The CRTC also has some funding mechanisms for rural broadband. In 2006, the Commission decided that the deferral accounts30 would be primarily used to increase broadband services in rural and remote communities, though deferral account spending is done by incumbent local exchange carriers (ILECs) and the accounts do not fund small ISPs.31 The 2015–2016 review of basic telecommunication services by the CRTC culminated in a decision to set a goal of having 90 percent of Canadian households with access to broadband speeds of 50 Mbps download and 10 Mbps upload by 2021.32 In its decision, the Commission noted that to achieve such a goal, a $750 million fund would need to be established. They are currently in the process of developing a funding mechanism to enhance connectivity in rural and remote Canada.33 At the time of writing, details have yet to emerge regarding how the CRTC's new fund will be structured; however, the Commission's interest in funding rural and remote broadband mirrors the trend of recent federal programs.
In addition to regulation, competition and market forces are the other key pillar of the Canadian telecom environment, and competition or the lack thereof presents unique challenges in rural and remote communities. As a result of many factors including lower population densities,34 distance from urban centers, and lack of telecommunications infrastructure (particularly coaxial cable), rural and remote communities are at a competitive disadvantage with respect to broadband. Urban Canada has historically benefited from broadband competition between legacy copper (Digital Subscriber Line [DSL]) providers and coaxial cable providers, which contributed to the countries early leadership in broadband adoption.35 However, the infrastructure competition that characterizes urban Canada is not present in many rural and remote communities. Cable penetration rates in small and medium-sized communities in 2005 was only 57.5 percent, and data for rural Canadians is not reported, but can be assumed to be even lower.36 There is considerable reliance on fixed wireless access in rural Canada, as 31 percent of Canadian rural households do not have broadband via wireline (fiber, cable, or DSL) access.37 While satellite service is available nationwide, the CRTC notes that capacity limitations mean that practical broadband service via satellite is limited to only 1.5 percent of Canadian households.38 Rural communities are also disadvantaged in terms of access to transport/backhaul infrastructure; a shortage the Government of Canada has recognized with its most recent Connect to Innovate program. The lack of density and existing last and middle mile infrastructure provides insufficient market force conditions to create competitive market environments.
Canada's largest telecommunications firms (incumbent Telecommunication Service Provides [TSPs] [Bell and Rogers] and cable-based carriers [Rogers, Shaw, and Videotron]) have many advantages in the market. These firms are better capitalized and have operations either nationally or in multiple regions allowing them to better tolerate fluctuations in local market conditions including changes in competition. The five largest TSPs (Bell, Rogers, Telus, Shaw, and Videotron) are also horizontally integrated39 with both wireline and mobile wireless services. Rural and remote ISPs have limited financial capabilities, are more sensitive to market fluctuations in their discrete service areas and often provide only a single type of telecommunication service. Canada's largest ISPs have also benefited from incumbency. In its decision to modify the wholesale high-speed access services regime, the CRTC noted that incumbent providers in Canada have upstream market power and have benefited from years of incumbency allowing them to develop greater brand recognition and access to capital markets.40 In 2016, incumbent TSPs had a 38 percent41 share of residential Internet subscribers with cable carriers having a 49 percent share leaving only 13 percent to other providers (i.e., small ISPs).42 While small ISPs can play an important role in providing broadband service in Canada, small ISPs in rural and remote communities face multiple challenges including regulatory barriers and competition.
Literature Review
The existing literature on rural and remote broadband in Canada is characterized by two types of literature. More recent studies focus on rural broadband policy, but small ISPs perspectives are not a central area of concern. Academic literature from Canadian studies clearly highlights the connectivity challenges in rural and remote communities. Numerous studies note rural and remote communities tend to face a significant digital divide in part stemming from a lack of competitive market forces.43 The challenges facing rural and remote indigenous communities are particularly pronounced with policy being characterized as “underdeveloped and uncoordinated.”44 Although smaller ISPs face several challenges, they often play a major role in connecting rural and remote communities and function as a “competitive fringe” in contrast to the dominance of the larger firms in the oligopolistic core.45
There is also evidence that many of the challenges of rural and remote communities and the smaller ISPs that service them stem from less than ideal policy and regulatory decisions. For rural communities, where broadband infrastructure can be lacking and economies of scale are not present to develop multiple competing infrastructures service-based competition—where competitors provide last-mile services over a shared infrastructure—is suggested as a lower-barrier alternative that can build a “ladder” to eventual facilities-based alternatives.46 However, as noted earlier, facilities-based competition is a key regulatory principle practiced by the CRTC. For smaller communities, locally developed solutions, including community owned, and operated ISPs, can provide an effective solution; however, Canadian policy has tended to provide direct subsidies to ISPs (as was the case with the Broadband Canada and Connecting Canadians programs) that undermine community specific needs.47 Furthermore based on limited evidence from Canada, it has been found open access policies and performance targets have been more successful than direct public investment in backbone infrastructure in improving broadband access and quality.48
Canadian studies have also found small ISPs face significant barriers to effective regulatory participation. Though the CRTC and the Government of Canada hold regular consultations on policies and regulations, larger service providers are advantaged over smaller competitors when it comes to participation. The advantage stems in part from their ability to submit voluminous interventions49 whereas smaller ISPs tend to lack resources to participate effectively.50
There is an extremely limited body of literature making use of interviews to gain insights into Canadian broadband policy and competition.51 Despite the importance of small ISPs in the Canadian market, only one other study by Middleton and Van Gorp has focused on the perspective of Internet service providers.52 The key finding of this 2009 work was that incumbent service providers create constraints that affect independent ISPs' abilities to provide competitive services, and that consistent favoring of large incumbents was not being addressed by policy. Details in the findings outlined inconsistent public policy, including ineffective policies for wholesale access and a lack of accessibility to Canada's regulators by small service providers.53 Our study examines the market for small Canadian Internet service providers in 2016, with a particular emphasis on small ISPs' perceptions of broadband policy and regulation, and presents findings that are consistent with the work done by Middleton and Van Gorp in 2009. The consistency in the findings underscores that the challenges facing small Canadian ISPs are ongoing and systemic, which reflects limited redress of challenges over the past several years.
Methodology
Interviews with ten Internet Service Providers were conducted in the summer of 2016. Providers were purposively chosen based on their scale, the availability of retail subscriber services, their location (services provided in Alberta and British Columbia, though not necessarily exclusively in those provinces), and their ability to serve customers in rural and remote environments. The providers offer services using a mix of facilities: fiber optic, DSL, fixed wireless access and satellite based. Most providers in the sample provided on a single type of Internet connection, and none provided cable or mobile wireless connectivity. The geographic area served by the ISPs studied varied considerably. For example, two of the interviewees provided services primarily serving rural and remote communities across Canada and the other eight deliver services in the western half of the country with some serving regions as small as a single community.
Data were collected through in-depth semistructured interviews, involving 23 prewritten guiding questions divided into four areas (about the ISP, ISED policy, CRTC regulation, and future policy directions). Questions were direct, but open-ended in nature to allow for natural conversation and for participants to expand upon ideas presented by the interviewers. The areas of investigation and specific questions were developed based on the researchers' knowledge of the field, which was particularly informed through participation in intersectoral broadband symposia held in Alberta (primarily Digital Futures),54 as well as participation in the CRTC's review of basic telecommunication services.55 Sample questions from each area are: Please describe the role competition plays in your development and deployment of services (prompt, do you face competition or do you operate in areas without)? (about the ISP); Overall, how would you assess the effectiveness of federal policies from ISED/Industry Canada for improving connectivity, particularly for rural and remote Canadians? (ISED policy); How effective is facilities-based competition in enabling rural connectivity? (CRTC regulation); and, Please comment on your company's view of whether there should be government-funded initiatives to assist in providing rural broadband access (future policy direction). These four broad areas were used to garner an understanding of the ISPs size and operation, perspectives on policy and regulation from both ISED and the CRTC and insights on future policy, which align with the study's overall purpose of understanding the effectiveness of Canadian broadband policy in enabling rural and remote connectivity with an aim to develop future policy recommendations.
This study received ethics approval from the University of Alberta Research Ethics Board. Interviews were held in private places, such as offices or meeting rooms, or via two-way video communication set up through the Technologies in Education unit at the University of Alberta. Eight were conducted by two interviewers and two were conducted by just one interviewer due to schedule constraints. Interviews were recorded with a digital recorder or through video recording and were later transcribed verbatim using the oTranscribe software application. Notes were taken by the interviewers throughout each interview and were later reconciled with the transcript. Due to audio issues encountered in one interview, backup notes were used to flesh out some responses. All identifying information was anonymized and any information provided by interviewees in confidence was taken out of the transcript.
Transcripts were entered into NVivo 11 and thematically coded in two rounds by a research assistant using inductive analysis to identify patterns and emergent themes.56 Additional rounds of coding and thematic analysis were performed by a second research assistant using ATLAS.ti. Thematic analysis is particularly useful for exploratory research. Christian Herzog et al. identified two key reasons for using this approach in policy research involving qualitative data. They state, “first, it is a widely applicable and often cost-effective means of exploratory research; second, one understanding of TA [Thematic Analysis] … is that it constitutes the essential starting point of virtually all qualitative data analysis.”57
Findings
Findings were categorized into several consistent themes. These themes are: market forces and competition, wholesale regulation, definitional challenges for rural and underserved; broadband speed as a determinant of success, working with regulators, feedback on broadband deployment programs, the Alberta SuperNet, wireless spectrum challenges, and service providers' perspectives on policy recommendations. The following subsections examine each of these themes.
Market Forces and Competition
Across all technology types and markets, competition has played a significant role in the deployment of rural broadband for interview respondents. It was widely agreed that significant regional competition now exists, even in rural areas; however, most respondents credit the early ability to go into unserved or underserved areas as key to establishing their businesses. However, specific strategies for market entrance do vary among those interviewed. Fixed wireless providers tend to target underserved areas, though some providers have chosen to pursue areas with low population densities or regions that incumbents appear to have abandoned. Fixed wireless competitors note a shift in market conditions that took place once broadband satellite technologies became widely available, though opinions differ on whether satellite-based broadband is effective competition for fixed wireless technology. Fixed broadband competitors tend to build on top of existing infrastructure by extending fiber-optic or cable-based networks into areas where they do not exist. One respondent relies on market interest surveys to determine where these investments might be made.
The CRTC's reliance on market forces, which stems from the 2006 Policy Direction from the Cabinet, generated mixed feedback in the context of rural deployments. Several of the relatively large ISPs in the study suggested that market-driven policies are sound, but added that deployment subsidies or service-based competition may work better in areas where deployments are immature, or where competition is unfair or insufficient:
It would be completely cost prohibitive for us to address a community if we didn't have a cost-effective way of having access to a backhaul. Which is why everywhere else in Canada that doesn't have a SuperNet doesn't have investment in anywhere outside of the city centers. There's no way of investing in a community that relies on a proprietary network to get out of that community. There's no fundamental way of doing that.
One respondent expanded on this idea, pointing out that capital subsidies for deployments only made sense in situations where the resulting service operations were sustainable. Some respondents felt strongly that reliance on market forces leaves rural communities behind since infrastructure investments will not be made to provide services to locations where profitability is an issue. Finally, one interviewee noted that market reliance does not present a viable business opportunity for competition: since only the largest service providers have investment capital available for deployment in underserved areas and have few incentives to share their infrastructure, the net result would be further industry consolidation.
Though interviewees were asked about the CRTC's emphasis on facilities-based competition, responses indicated this was not a significant factor in rural environments. Facilities-based competition exists when multiple forms of infrastructure can be used to serve residents, and rural areas still have limited access to facilities. There was some support for greater infrastructure sharing:
Facilities-based competition, as it relates to a resident, is just a really expensive way of getting competition out there. So, as much as we can leverage the same facilities, the betterment is for the consumer.
Wholesale Regulation
Opinions on wholesale network access regulation were negative. Since the CRTC policy for wholesale high-speed access facilities regulation was still new at the time the interviews were conducted, and because implementations have been primarily made in Ontario and Quebec, respondents were limited to speculating on the likely impact of the policy. Some providers thought that adding too much competition through wholesale network access might backfire by splitting revenue streams too thinly among multiple competitors, especially in less densely populated areas. They also surmised that network operators would work around CRTC-determined rate schedules by charging fees for nonregulated aspects of the service, or by artificially limiting network capacity:
But, what they seem to be doing is, because that's regulated and they can't charge me more, they're trying to find other ways that they can charge me more of non-regulated items inside a bandwidth component. So, it seems that the wholesale bandwidth regulations are causing them to think outside the box to be able to get more money from the clientele instead of doing what it's supposed to be doing.
On the positive side, some respondents believe that true network sharing can reduce the cost of deployment of new networks. One respondent felt that opening existing networks to competition propels the industry; another advocated for the creation of a neutral host infrastructure to avoid anticompetitive measures on the part of these network operators. It is also important to note that some respondents demonstrated a lack of understanding about the wholesale regime as evinced by comments such as “I think the only wholesale that I'm aware that even has happened yet is the fiber to the home, which is in Ontario,” and “The wholesale regulations I'm not as up on as I should be.”
Rural and Underserved: Definitions and Their Application
Several examples were found where the definition (or application of definitions) for “rural,” “remote,” or “underserved,” created challenges for service providers. One respondent spoke of a resident who was classified as remote despite being located next to a major provincial highway, and another mentioned a variable definition of “rural” that encompassed the village of Caroline (population 512) and the city of Medicine Hat (population 63,000) in Alberta.
One respondent argued that no Canadians are currently “unserved” because of the deployment of broadband-capable satellites. The Connecting Canadians program defined an “underserved” population as one that could not access download speeds of 5 Mbps,58 and since satellite technology can deliver those speeds, many rural areas were excluded from program eligibility. The program's criteria presented challenges for a few respondents who wanted to invest in fixed-wireless infrastructure but were not eligible for funding under program guidelines.
Broadband Speeds as a Determinant of Success
Many respondents pointed out that advertised network speeds do not always match actual network performance, and suggest a few implications. First, in the absence of a mechanism for verifying actual network speeds, regulatory bodies seem to rely on marketing material to determine what upload and download rates are available in each area. This reliance is especially problematic in cases where a service provider advertises the same services and rates across a geographic scope that is serviced by multiple broadband technologies. Second, technical factors can cause network speeds to degrade when certain technologies are employed. As examples: DSL technology is limited by distance, technologies operating at high capacity may not be able to handle all traffic at maximum speeds, and wireless frequency interference may degrade signal quality. Third, marketing messages for any service provider must be calibrated to account for multiple factors, like technology limitations and competitors' offerings. Since not all service providers formulate marketing strategies in the same way, competitors may advertise different speeds for their services even in cases where the same underlying technologies are being deployed.
I think [it] depends on what the definition of five meg is right? If you are talking at 10 PM, to provide five meg down and one meg up, it's probably challenging … But if you're talking about having one customer at 6 AM to use it, it's easy to do that. And that goes back to the definition of what Industry Canada or CRTC has put there. The definition is very vague … it really doesn't specify what that means.
At the time when interviews were conducted, the CRTC had not yet released its updated federal broadband speed targets as part of the 2015 Review of Basic Telecommunications Services, and speeds of 5 Mbps download and 1 Mbps upload were used as the basic definition of broadband access. Several providers pointed out that their ideal service capabilities were far above the CRTC minimums, with the lowest download speed across all interviews reported at 20 Mbps. Two contrasting perspectives on the federally mandated minimums emerged: the first was that competition, not regulation, was better at increasing broadband connectivity speeds; the second was that the CRTC should be more ambitious with determinations of minimum speeds to drive broadband penetration.
Interestingly, only two of the ten ISPs interviewed offered synchronous network speeds for their service offerings. One provided fiber-to-the-premises connectivity at a minimum of 20 Mbps, and the other provided line-of-sight fixed wireless service at speeds of up to 50 Mbps.
Working with Regulators
Respondents suggested that collaboration with Canadian regulators is challenging. Small-scale ISPs do not have the resources required to participate in CRTC or ISED Canada consultations. The Basic Services Objective consultations were discussed with all respondents, and only one medium-scale ISP indicated that they had taken part. One respondent suggested that the cumbersome nature of consultations processes creates a barrier for the very organizations the consultations are intended to support. Concern was also heard from one interviewee about the lack of support when trying to get a clear understanding of newly issued or updated policy.
Four of the service providers interviewed had applied for at least one federal broadband funding program, but several indicated that the application and claims processes were onerous:
I didn't apply for any programs or grants. I was going to go through that process and I just … it was one of those things that just turned me off because … you've got to do all this paperwork and provide all this information … It was because it's becoming more competitive … there's no guarantee and my guarantee is my return on my investment … and I'm making more return on what I'm doing right now, so it's better for me to focus my energy on just building to the need as it comes …
One respondent reported that their application for the Connecting Canadians program was more than 100 pages long, and another suggested that the application requirements were the primary reason why a significant amount of Connecting Canadians funds remained unspent. Ironically, another respondent said that Connecting Canadians was a better program than Broadband Canada because the application requirements were less bureaucratic.
Some of the relatively larger ISPs in the sample acknowledged that their size afforded them the ability to take part in consultations and funding programs; however, almost all respondents felt disadvantaged relative to the ability of national-scale, incumbent telecommunications providers to influence policy making.
Feedback on Broadband Deployment Programs
Unless asked about specific strategic approaches to regulation, references to federal policy were mostly related to specific programs like Broadband Canada and Connecting Canadians. Interviewees also mentioned the Deferral Accounts program, which allowed incumbent service providers to collect funds from subscribers for additional infrastructure investments. At the provincial level, very little general feedback was received on the topic of policy, but a significant focus on the successes and challenges of Alberta's SuperNet was found. Comments about SuperNet are addressed in a separate section.
Some small service providers stated that federal program guidelines were difficult to understand, creating two problems: reluctance to apply for program funding, and significant time spent trying to interpret the underlying direction of federal strategies so that providers' business strategies can be aligned.
Several respondents told us that federal broadband deployment programs were too focused on increased access for the “have-nots” instead of creating comprehensive, forward-thinking strategies that take the complete picture of national broadband services into account. Moreover, there was a feeling among service providers that federal programs tended to favor deployments in Eastern Canada over Western Canada: a large provider said they applied for funding in every jurisdiction, using the same strategic criteria, and did not receive financing for any deployments west of Ontario:
Yeah, the interesting thing I've found on both Broadband Canada One and the Connecting Canadians is we bid on every geography in the country. We divided up the country and we bid on every single eligible piece of the country. And both times we were never awarded anything west of Ontario…. And the designs, the solutions, everything is exactly the same.
One service provider we interviewed said that federal programs had no bearing on their broadband deployment strategy since program eligibility was based on broadband speed targets that were too low to be market-competitive versus what available technologies could provide. Finally, respondents felt that programs were hindered by their focus on coverage instead of adoption, making it difficult to create ongoing sustainable revenue to support program-subsidized infrastructure deployments.
Connecting Canadians was specifically highlighted by an interviewee as an improvement over previous programs because it did not make money available to large incumbents. The Deferral Accounts program, which was mentioned by four respondents, was often pointed to as an example of a program that favored Canada's largest telecom players.
The Alberta SuperNet
Due to the prominence of Alberta-based service providers interviewed for this paper, feedback on the Alberta SuperNet was common, appearing in seven of the interviews conducted. Respondents compared the SuperNet model to other examples of network aggregation and backhaul facilities and provided commentary on its strengths and weaknesses.
Respondents agree that the concept of the Alberta SuperNet—a province-wide fiber-optic network that provides connectivity to 429 communities—is a good one. The ability to connect new last-mile broadband deployments to a fiber-optic infrastructure helps catalyze new development and ensures that connections can be aggregated reliably to a high-capacity network backbone. The breadth of the SuperNet encourages gradual expansion of fiber-optic networks to support regional projects and fiber-to-the-tower deployments for fixed-wireless technologies. One respondent pointed out that Alberta's geography reduced the cost and complexity of SuperNet implementation, relative to any similar effort that might be tried in British Columbia, which is a much more mountainous province. The lack of a widespread fiber optic backbone is problematic in British Columbia, however, where the ability to provide reliable fixed-wireless connections across extreme terrain is hindered by the lack of high-capacity methods for aggregating them:
In BC there's a lot of small communities that are a few mountain ranges apart from each other … only the fixed wireless guys that can do that, but their challenge isn't just, you know, that five megabits. It's the aggregation of those five megabits on the link back to where they're connected.
Many interviewees cited problems with SuperNet's price, performance, and governance, and noted uncertainty about the expiry of the current operator contract in 2018. Prices for SuperNet access are considered high relative to similar regional fiber-optic networks (one respondent used the term “gouging”), creating challenges for sustainable final-mile investments and encouraging the creation of parallel, competing deployments. The performance and reliability of SuperNet were deemed insufficient by several respondents, damaging the service reputation of small providers who rely on it for backhaul and aggregation. Most critically, interviewees felt that a governance structure for SuperNet is missing and should be created a way that is divorced from network operation:
SuperNet was a very good model. It wasn't any county running it or any municipality running it, but where it went wrong is that that governance, strong governance wasn't in place … I think a strong province-wide governance structure, I think that is what can help. Specifics of it, is it going to be municipalities? Is it going to be counties and all that? I'm not that optimistic. But at least a collection of all of them if they can provide that strong governance structure.
Wireless Spectrum Challenges
Most of the wireless-based service providers interviewed feel that much more can be done around wireless spectrum licensing and management. Many interviewees made calls for better spectrum management, availability, and enforcement. One large provider referred to fixed-wireless technologies as the equivalent of “fibre in the ground” and suggested that there was too much emphasis from regulators on the use of mobile wireless technologies to resolve broadband access problems:
Having a good spectrum policy that addresses both mobile and fixed is critical I think for Canada. Because knowing that, you know, the land mass that we've got and the way that broadband is going, we're not getting out of using spectrum to deliver high bandwidth services, whether they're fixed or mobile. But, fixed to the home is still the predominant consumer…. It would be like telling somebody in urban Canada that they don't need fibre because they've got cellular, you know. So, just use your mobile service, we'll get you more spectrum. It's completely different… Ability to continue to expand and get access to rural spectrum is going to be critical for rural broadband. It's the only way to deliver reliable rural services.
Fixed-wireless spectrum in the 3.5 GHz range is widely held by large service providers, leaving small competitors with minimally enforced access to unlicensed and limited-license frequencies (including first-come first-serve [FCFS] licenses). Licensed frequencies are not shared, and the geographical areas bounded by Tier 4 license blocks blur urban and rural markets. These factors restrict the ability of small providers to build networks on those frequencies. Several respondents suggested that large incumbents were sitting on unused spectrum licenses, and one respondent admitted to hanging on to licenses in areas where they simply did not have the capacity to build out infrastructure.
Several respondents noted ISED's 2014 consultation on policy changes for the 3500 MHz band, which would have added rural and urban classifications for Tier 4 license areas and restricted the use of fixed-wireless technologies in urban zones. The ministry's proposed criteria would have resulted in large rural areas being classified as urban, due to the presence of a single population center of 30,000 residents. Multiple interviewees participated in the Industry Canada request for comments on this proposal and were pleased to see the ministry abandon the option in its December 2014 decision.
Some respondents indicated limited access to frequencies that would assist with overcoming geographic hurdles, such as areas with high concentrations of trees or limited line-of-sight connections. Limited-license frequencies are also often unable to scale to high-capacity levels because contiguous ranges of unused broadcast frequencies—required to attain high download speeds—are rare. Finally, several respondents pointed out that spectrum policies cannot be isolated from backhaul policies since the delivery of quality broadband services is dependent upon reliable aggregation and connection to backbone networks. One participant specifically noted that high prices for point-to-point microwave created challenges for the aggregation and backhaul of wireless services.
Service Providers' Perspectives on Policy Recommendations
Many service providers suggested that regulators and policy creators would benefit by reaching out to small service providers during consultations instead of waiting for submissions since the latter process favors larger competitors.
On the topic of wholesale high-speed access regulation, respondents suggested that competition could be limited in rural areas, and that fiber optic penetration could be incented by restricting the creation of new fibre optic links in locations where infrastructure has already been created.
Wireless service providers agree that Canada's spectrum policies need to be refreshed and that they don't take the full gamut of fixed- and mobile-wireless services into account. Respondents suggested that broad ranges of spectrum could be repurposed, reassessed, and reapplied to increase penetration into rural areas, including the embrace of a “use it or lose it” approach to spectrum licensing that would help put more spectrum in the hands of competitors who are ready to use it.
Discussion
From the findings of the interview transcript analysis, several points for discussion arise. This section highlights questions that emerge from the findings and places the results within the greater context of the CRTC's monitoring reports, ISED activities, and previous work in this area by other researchers.
Competition and Market Forces
Deployment strategies for the ISPs interviewed centered on business sustainability, with a desire for profitability and minimal competition appearing as common factors. Though respondents felt the state of competition was healthy, they have historically driven their business expansion activity by focusing on deployments in areas where little competition existed or where a clear market need could be identified. Rural wireless providers noted a market shift with widespread deployment of satellite-based broadband technology, and it is likely a similar change will take place now that most nonremote areas can be capably served by at least two facilities (typically: satellite and fixed-wireless technology). Respondents favored competition and this is likely respondents' bias; as small firms they exist within the milieu of business that extols the value of competition and discredits reliance on government regulatory protections and subsidies for success.
Small ISPs' see market competition as the primary determinant of minimally acceptable broadband service speeds. In this regard competition, rather than regulated minimum speeds, drives small ISPs service offerings. Data from the CRTC's most recent Communications Monitoring Report states that 87 percent of rural areas can be served at speeds of 5.0 Mbps or higher on up to three platforms, but this number drops precipitously as download speeds increase.59 However, in 2011 the CRTC set a nonbinding goal of having universal access at download speeds of 5.0 Mbps in Canada.60 The fact that the goal was nonbinding and not met suggests that competitive forces in rural Canada continue to be insufficient, despite the belief of rural ISPs.
Service providers agree overwhelmingly that fiber-optic and other forms of fixed-line technologies remain cost-prohibitive for rural deployment, except for areas where incremental development can complement existing backbone infrastructures; this indicates that wireless technologies will be the foundation for rural broadband service delivery for the foreseeable future. This finding requires some qualification. The view favoring fixed-wireless connectivity is potentially due to the dominance of fixed wireless providers in the sample.
Uncertainty about the State of Networks and Licenses
Many perspectives on spectrum usage and service quality were widely shared by interviewees but are difficult to verify or debunk with data.
Differences between advertised and actual broadband speeds were suggested in many interviews, with respondents asserting that actual service speeds may not consistently attain advertised levels due to many factors including increasing demand from 4:00 pm through to the evening as people use broadband for entertainment. The CRTC has commissioned SamKnows to assess broadband performance in Canada, and reports have been released for one-month sampling periods in 2015 and 2016.61 Data collection is restricted to the country's ten largest wireline service providers, using fiber-to-the-home (FTTH), hybrid-fiber coaxial-cable (Cable/HFC) and DSL technologies. Results indicate that FTTH and HFC networks perform above expectation, but there are issues with DSL connections due to over-provisioning and other factors. DSL-related findings support some accusations made by interview respondents, with download rates for Bell Aliant falling to 77 percent of advertised speeds at peak hours.62 Unfortunately, small ISPs are not participating in this program, and SamKnows indicates that there is no plan to incorporate monitoring or reports for wireless connections.63
Wireless service providers told us that unused spectrum was an issue. ISED completed its last radio spectrum inventory in 2010,64 and though the report covered bandwidth allocations in detail, it did not provide an assessment of the level to which any of those allocations were used. Moreover, the timing of the report means that data on post-2010 auctions—including valuable 700 MHz and AWS-3 mobile frequencies—is not included. To date, the only known study of actual frequency usage in Canada has been completed by Taylor,65 in a core urban area where cellular usage is prominent. Canada needs a system for the verification of licensed spectrum usage or the assessment of capacity or interference.
Finally, respondents suggested that large incumbents hold most of Canada's most valuable spectrum licenses. Though data on spectrum band-level allocations is available through Canada's Spectrum Management System (SMS), no recent comprehensive analysis of these distributions, isolating the frequency ranges often used for fixed-wireless access, has been done. This presents an interesting opportunity for future work.
Policy and Regulation
Often, respondents referred to specific funding programs or infrastructure deployments when asked about the role of federal and provincial broadband policy. The perception of “programs as policy” is interesting considering evidence in interviews that respondents were largely unfamiliar with non–program-related policy rulings like the Policy Direction mandating the CRTC's reliance on market forces. In some cases ISPs also demonstrated a lack of a full understanding of various policy mechanisms that could address challenges they face. For example, several providers were unaware of how the wholesale regime operated, and none raised the issue of mandated wholesale access to fiber transport infrastructure. The authors theorize that this lack of awareness may be related to small ISPs' lack of ability to participate proactively in policy consultations and requests for comment.
Some of the smallest ISPs in the study have not participated in CRTC or ISED consultations, and have not benefitted from programs like Broadband Canada Connecting Canadians. Only four of the ten ISPs interviewed—generally the relatively largest of the providers covered by this study—applied for or received funding from these programs. Existing consultation and funding programs have created a ceiling that bars the smallest ISPs from participation, implying that these providers can only grow through their own initiatives and means. This has implications for long-term competition since the game continues to favor incumbents and medium sized providers.
Service providers who have dedicated themselves to wireless broadband deployment tend to be smaller and, as mentioned, are less able to participate in programs and consultations. These providers complained about the difficulties of aggregating last-mile connections over microwave links or fiber-to-the-tower deployments in our interviews, but the lack of participation in policy consultations means that these voices are absent at the federal level. This situation is further complicated by ISED Canada's control of policy and regulation in the wireless sector, separate from the broader telecommunications jurisdiction of the CRTC.66 ISED Canada's consultations are characterized by a lack of participation and transparency when contrasted with the engagement work of the CRTC.67 As a recent example, ISED Canada's 2012 consultation on mandatory roaming and antenna tower sharing, an issue that should have been of interest to many ISPs in the study, received only 22 submissions and 13 reply comments, with no representation from the ISPs interviewed for this study.68 Regulators may need to more proactively engage with small ISPs, and more public involvement with consultations is encouraged. Without adjustments of this nature, policies will continue to favor incumbent providers over independents who do not have access to infrastructure capital, hobbling potential for increased extension of network backbones into rural and underserved areas.
Rural service providers' preference for wireless broadband technology highlights a challenging relationship between the Canadian government's federal broadband deployment programs and its reliance on wireless spectrum auctions: though both the CRTC's mandate and ISED Canada's Spectrum Policy Framework highlight a reliance on market forces to the maximum extent feasible,69 this reliance has led to outcomes that could be seen to contradict their shared objective of economic and social benefit for Canadians. On the one hand, federal programs provide funds to subsidize broadband deployment to remote and rural areas; on the other hand, ISED Canada has relied extensively since 199670 on auctions for access to spectrum that is ideally suited to implement rural broadband services using fixed-wireless technology. The proceeds from wireless spectrum auctions are counted toward general Government of Canada revenues71 rather than being directly reinvested in the development of Canada's telecommunications infrastructure (for example, through increased use of subsidies provided by new federal programs) or its spectrum management activities. Frustrations about the lack of spectrum access for smaller ISPs, and the ongoing lack of access to high-quality broadband services for rural and remote Canadians, demonstrates that the outcomes of these approaches do not complement one another and that the overall federal wireless policy must be revisited. Bringing greater coherency to federal wireless policies requires a revisiting of the 2007 Spectrum Policy Framework for Canada, the guiding policy document, which could include a target consultation with small ISPs and more thoroughly consider the challenges and needs for spectrum in rural rather than urban environments.
Some respondents made references to the digital divide when commenting on the state of the rural broadband market, but aside from occasional references to the use of marketing to increase customer demand for services, there was no call from interviewees for regulatory bodies to investigate demand-side policy initiatives. A 2010 study of American demand-side broadband adoption programs suggests that effective programs should “motivate non-users to adopt, make broadband affordable, employ content and training that relates to everyday life or the use of public services, and focus on the accessibility and usability of broadband and online services.”72 This finding is a contextualized echo of five of the nine recommendations in the 2001 final report of Canada's National Broadband Task Force, which placed a strong emphasis on demand-side policy initiatives and closure of the digital divide.73 Considering respondents' comments about the difference between broadband coverage and broadband adoption, there appears to be an ongoing role for policy directives and programs that incentivize demand.
Functional and Structural Separation
Observations on the implementation and operation of the Alberta SuperNet infrastructure suggest discomfort, among respondents that the network operator is also permitted to compete with other small-scale ISPs on the delivery of services to residents. The sentiment echoes a finding of Middleton and Van Gorp's 2009 study, where the idea of structural and functional separation was more explicitly mentioned by interview respondents.74 Middleton explored this suggestion in 2011 and pointed out that Canada's complex environment, with multiple large incumbents and several already-established facilities-based networks using a mix of access- and transport-based infrastructures, would make functional and structural separation in Canada complex and difficult to achieve.75 The authors agree with Middleton's analysis, and suggest that the opportunity to achieve this kind of separation in the Canadian environment may have passed.
Additional Comparisons to Middleton and Van Gorp's 2009 Study
There is significant agreement between the findings of this study and those of Middleton and Van Gorp,76 suggesting that policies and programs have not evolved significantly over the past eight years. Participants in the 2009 study feared that the existence of independent ISPs was under threat. The evolution of the Canadian broadband market, however, has been more nuanced. CRTC reports from 2012 and 2016 have consistently numbered Canadian service providers at about 500, but the trend of consolidation has not been reversed and the largest five incumbents have maintained their revenue share near 75 percent of the total market.77 Reliance on competition and market forces may have led to gradual increases in access to broadband for Canadians, but it has also generally led to an increasing gap in broadband speed capability for urban and rural consumers.
The 2009 study was much more focused on the DSL and fixed broadband than on wireless technology, and it called for a focus on wholesale access for service providers. The CRTC has recently mandated wholesale access including fiber to the premises, but the order does not extend beyond fixed-line infrastructure. The results of the current study suggest further work is required to create an approach that accounts for fixed and wireless technologies in rural and remote contexts.
Conclusion
This study presents ISPs' perspectives on several key facets of the Canadian broadband sector in rural and remote regions with the aim of understanding ISPs perspectives on policy, regulation, competition, and other challenges. The study of small ISPs is important, because often they lack the resources to contribute their own perspectives to policy consultations; however, as revealed in their answers, their small size and focus on day-to-day operations may also limit their understanding of the range of policy and regulatory mechanisms in the telecom sector. This study also reveals that rural and remote broadband providers face distinct challenges, and that a national policy framework that privileges market forces and facilities-based competition, which benefits large, incumbent carriers who can serve profitable urban markets is ill suited for rural and remote Canada.
Over the past decade, analysis of federal and provincial broadband programs, reviews of CRTC and ISED Canada consultation proceedings like the recent basic services decision and studies of the Canadian broadband market—including this study of small Internet service providers—has established a common theme. In the words of one interviewee:
I think the federal government always helped to, you know, try to provide some means of taking it to the next level. I think if I summarize it, one thing that is missing is an overall strategy … I think most of the activities have been in an ad hoc fashion.
While a strategy is crucial, to be successful it must have a specific design. Based on the interviews the authors suggest a national broadband strategy adopt a two-pronged approach—one set of strategies for urban Canada where greater market forces exist, and a separate set of strategies for rural and remote Canada where connectivity gaps persist. To ensure the development of effective policies under the strategy the Government of Canada (specifically ISED) should directly engage with rural ISPs in a structured manner. The purpose of these engagements is twofold—it will not only allow the government to hear directly from small providers, which usually cannot participate in larger policy consultations, but it will also provide the government the opportunity to inform small providers of the range of policy measures that could be adopted. A rural strategy prong can specifically address issues like bottlenecks in access to transport infrastructure and limited access to spectrum in rural Canada. To unify the two prongs of the strategy it will be necessary to revisit the telecom policy objectives, and specifically to remove the 2006 policy direction, which poorly serves rural Canadians.
This study had some notable limitations. First the sample size was relatively small—only ten ISPs in Canada, out of a market of more than 500 ISPs were interviewed. Furthermore, the respondents were geographically limited in Western Canada, though some ISPs did have operations outside of this region. Service provider responses may be biased toward their own competitive scenario, business interest, and understandings of Canadian policy and regulation. Despite these limitations, interviews with small ISPs are an underused methodology producing responses that are quite revealing. The study's findings lead to several avenues for further research. For example, more work could be done to study ISPs in other regions of Canada to determine what geographical differences exist, and future questioning can be done to better understand ISPs views on both wholesale and retail rate regulation. More research is needed to assess small ISPs claims around spectrum access. Additionally, this study occurred before the CRTC's decision to declare broadband a basic telecommunication service, and the implication of this decision on small ISPs requires in-depth investigation.
Footnotes
Middleton, 62; OECD, Broadband Growth and Policies in OECD Countries, 8.
Middleton, 61; Middleton and Van Gorp, 32; Van Gorp, 74.
CRTC, Communications Monitoring Report 2017, 254.
Longford, 128; McNally and Trosow, 24.
OECD, Communications Outlook 2013, 46.
According to the 2011 Census, 81 percent of Canadians live in urban areas (Statistics Canada, “Population, urban and rural, by province and territory (Canada)).”
Laizner.
The participants in this study are all ISPs that provide service in rural and/or remote communities. While the size of these ISPs both with respect to number of subscribers and geographic service area does vary considerably, the authors have chosen not to attempt to differentiate among small and medium ISPs relative to the five largest Canadian ISPs which capture 73 percent of market revenues. Furthermore, while the large ISPs do have some rural service provision, they are dominant players in major urban markets unlike the small ISPs in our study.
An example of the policy making functions of the CRTC would be the 2016 decision to define broadband as a basic telecommunication service to which all Canadians should have access to at certain minimum speeds (CRTC, “Telecom Decision CRTC 2016-496”).
Canada—TPRP, Telecommunications Policy Review Panel, 8; OECD, Regulatory Reform in Canada, 12.
Telecommunications Act, s. 7(b).
Ibid., s. 7(f).
Canada—TPRP.
Governor in Council, 1.
SPFC.
The CRTC's decision to declare broadband a basic telecommunication service (CRTC, “Telecom Regulatory Policy CRTC 2016-496”) came after the interviews with ISPs were conducted; however, the consultations that informed that decision were underway and one of the central discussion points in the consultation process was whether broadband should be considered a basic telecommunication service.
For literature comparing provincial programs see Rajabiun and Middleton, “Multilevel Governance and Broadband Infrastructure Development”; “Rural Broadband Development in Canada's Provinces.”
CRTC, “Jean-Pierre Blais at the Public Hearing.”
CRTC, “Telecom Decision CRTC 2002-34,” para. 99.
CRTC, Communications Monitoring Report 2012, 5; “Telecom Regulatory Policy CRTC 2015-326,” para. 5.
CRTC, “Telecom Regulatory Policy CRTC 2015-326,” para. 6.
The Commission determined that Basic Listing Interchange File service and Directory File Service were essential services with mandated access and concluded that conditionally mandated essential services and facilities included ILEC unbundled local loops, low speed competitor digital network access facilities, ADSL access services and aggregated ADSL access cable carriers third-party Internet services. CRTC, “Telecom Decision CRTC 2008-17,” paras. 57, 66, 72, 77, and 86.
Note the implementation of this decision was delayed and is proceeding in a phased in manner. At the time of the study the wholesale decision was only mandated in the provinces of Ontario and Quebec, and as such was not applicable for the ISPs studied (CRTC, “Telecom Regulatory Policy CRTC 2015-326”).
CRTC, “Telecom Regulatory Policy CRTC 2015-326,” para. 136.
CNOC, paras. ES25, 4, and 108–10.
McNally et al., “Thematic Analysis of Eight Canadian” 18.
At the time of interviews (summer 2016) the details of this program where not publicly available. Some of the ISPs interviewed had some understanding of what the program might entail, but none of the interviewees had an informed perspective of the final configuration of the Connect to Innovate program and its funding parameters.
The share of funds for last mile versus backbone connections is not known at the time of writing.
Innovation, Science and Economic Development Canada (ISED), “Connect to Innovate.”
The CRTC's deferral accounts stem from a 2002 decision dealing when price regulation of certain incumbent local exchange carriers (ILECs) resulted in the creation of deferral accounts to fund the cost of telephone service in High Cost Service Areas (HCSA). In 2006, the funds were primarily repurposed for rural broadband (CRTC, “Telecom Decision CRTC 2002-34”; “Telecom Decision CRTC 2006-9”).
CRTC, “Telecom Decision CRTC 2006-9,” para. 80.
CRTC, “Telecom Regulatory Policy CRTC 2016-496,” paras. 80 and 114.
CRTC, “Telecom Notice of Consultation CRTC 2017-112.”
In Canada, urban communities are defined as population centers with at least 1000 people and a density of 400 or more person per square kilometer with all other areas being considered rural (Statistics Canada, “Population Centre and Rural Area Classification”). Note that the CRTC also uses this definition for rural (CRTC, Communications Monitoring Report 2017, 269).
OECD, Regulatory Reform in Canada, 48.
Statistics Canada, “Cable, Satellite and Multipoint Distribution Systems, 2006,” 6.
CRTC, Communications Monitoring Report 2017, 281.
Ibid., 258.
In the case of Bell, Rogers and Quebecor (Videotron's parent company) these three firms are also significantly vertically integrated.
CRTC, “Telecom Regulatory Policy CRTC 2015-326,” paras. 124 and 134.
Note the incumbent TSP category does include some small ISPs (CRTC, Communications Monitoring Report 2017, 255).
CRTC, Communications Monitoring Report 2017, 258.
McMahon et al., “Digital Divides and the ‘First Mile’,” 3; Rajabiun and Middleton, “Multilevel Governance and Broadband Infrastructure Development,” 712; McNally and Trosow, 38; McNally et al., “Thematic Analysis of Eight Canadian,” 78; and Pant and Odame, 435.
McMahon et al., “Making Information Technologies,” 253.
Winseck, 65.
Kelly and Rossotto, eds., Broadband Strategies Handbook, 57.
McMahon et al., “Making Information Technologies,” 253.
Rajabiun and Middleton, “Multilevel Governance and Broadband Infrastructure Development,” 712.
McNally et al., 308; Rajabiun and Middleton, “Public Interest in the Regulation of Competition,” 42.
Middleton and Van Gorp, 23.
The only other study using the interview method is Bakardjieva and Williams (2010), but their study focused on policy makers and citizens' perspectives of SuperNet, not ISPs.
Middleton and Van Gorp.
Ibid., 26–29.
Van Horne Institute.
CRTC, “Telecom Notice of Consultation 2015-134.”
Pascale, Cartographies of Knowledge.
Herzog et al., 2.
Government of Canada, “Digital Canada 150—FAQs.”
CRTC, Communications Monitoring Report 2017, 283.
CRTC, “Telecom Regulatory Policy 2011-291,” paras. 76 and 79.
CRTC, “SamKnows Analysis of Broadband Performance in Canada, October & November 2015,” 4; “SamKnows Analysis of Broadband Performance in Canada, March & April 2016,” 7.
CRTC, “SamKnows Analysis of Broadband Performance in Canada, March & April 2016,” 8.
SamKnows & CRTC, “Requirements | Measuring Broadband Canada.”
Industry Canada, “Radio Spectrum Inventory.”
Taylor et al., “A Question of Scarcity.”
McNally et al., 299; Shepherd et al., 5.
CRTC, “About Us”; Shepherd et al., 6.
ISED Canada, “Comments Received on Gazette Notice DGSO-001-12”; “Reply Comments on Gazette Notice DGSO-001-12.”
Governor in Council; Industry Canada, “SPFC—Spectrum Policy.”
Longford, 124; Taylor, “Oil in the Ether,” 131.
Taylor et al., 128.
Hauge and Prieger, 22.
Canada—NBTF, New National Dream, 11–13.
“Middleton and Van Gorp,” 28.
Middleton.
Middleton and Van Gorp, 26–31.
CRTC, Communications Monitoring Report 2012, 147; Communications Monitoring Report 2016, 246.
