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Telecom - Secretary General Letter addressed to the Distribution List

Ottawa, 30 October 2023

Our reference: 8020-1/23

VIA EMAIL

Distribution List

Subject: Expectation of outreach by wireless Internet service providers to their customers for participation in the Measuring Broadband Canada Phase 3 study of fixed wireless Internet services

Participation in a study of Canadians’ Internet service performance

The Commission and Innovation, Science and Economic Development Canada (ISED) launched Phase 3 of the Measuring Broadband Canada (MBC) project in 2022. This project was started in 2016 by the Commission, using a third-party expert in broadband measurement, SamKnows, to measure broadband Internet performance in Canadian homes. MBC Phase 3 seeks to better understand how Canadians subscribing to fixed wireless Internet services with download speeds of 50 megabits per second (Mbps) and upload speeds of 10 Mbps or faster are experiencing Internet performance in their own homes. These are Internet services mainly used to serve Canadians in rural and remote areas where wireline Internet service is not readily available. Phase 3 of the MBC project will assist the Commission, ISED, and the public in evaluating the current strengths and areas for improvement in connecting Canadians from coast to coast. 

The Commission seeks to ensure that all Canadians have access to a world-class communication system. Data developed by projects such as the MBC Phase 3 is critical to achieve this objective. Therefore, the Commission encourages all Canadians with fixed wireless Internet service to volunteer to participate in the study. Canadians can sign up directly with SamKnows on the project’s website.

Participation is free. Participants will receive a measurement device from SamKnows, called a Whitebox, that connects to the home router, allowing for Internet performance measurement. The Whitebox does not need to be returned. Participants will also get access to SamKnows’ cloud-based web portal where they can: view all their test results; see their Internet performance over time; track trends and spot problems; and use simple tools to help understand their Internet connection.

Expectation for wireless Internet service providers to support MBC Phase 3

The number of Canadians receiving fixed wireless Internet services is small compared to the other types of residential Internet services offered in Canada. Accordingly, there is a smaller number of prospective participants for MBC Phase 3; yet a sufficient number of participants is still necessary for the study’s success. The Commission is of the view that more Canadians are currently needed to participate in the study to make the data obtained from the study of most value to Canadians. Based on the Commission’s experience with the first two phases of the MBC study, recruitment of participants is greatly facilitated by Internet service providers (ISPs) contacting their subscribers directly about participation in the study.

Since November 2022, Commission staff has sought voluntary assistance from wireless ISPs in increasing participation in the study by contacting their subscribers of fixed wireless Internet services about signing up for the study.

Following information sessions and exchanges with wireless ISPs and SamKnows, a number of smaller wireless ISPs expressed support for the project and indicated they had communicated with their subscribers about signing up for the study. Other wireless ISPs, notably Bell Canada (Bell), Rogers Communications Inc. (Rogers), TELUS Communications Inc. (TELUS), and Xplore Inc. (Xplore) expressed concerns with certain aspects of the study and about communicating with customers about the study. The Commission notes that to date, these four wireless ISPs have not agreed to contact their subscribers about the project or otherwise support its rollout.

On 26 July 2023, Commission staff sent wireless ISPs a request for information asking, among other things, whether the Commission should mandate wireless ISPs to contact their subscribers regarding participation in the study and what concerns they had with such participation. Bell, Rogers, TELUS, Xplore, CanWISP, FiberSpeed Inc., IGS Hawkesbury, and an individual, Marc Nanni, submitted comments. Comments touched on the following subjects: the jurisdiction to mandate participation in the study; the scope of wireless ISPs that should be required to participate in the study; lack of clarity on the services being studied; and the conduct of the study (methodology, metrics and safeguards for wireless ISPs). Bell, Rogers, TELUS, and Xplore rejected the possibility of being mandated to provide the study’s recruitment materials to their subscribers. They raised concerns with the study’s conduct, methodology, and access to the study data.

In response to those concerns, Commission staff has worked with SamKnows and ISED to make modifications to aspects of the study as follows:

Further information on these changes can be obtained directly from Commission staff.

MBC Phase 3 is being sponsored and conducted by the Commission and ISED, in association with SamKnows (whereas ISPs acted as co-sponsors in past phases of the MBC project). As such, the Commission and ISED can determine the aspects of the study like methodology, process, safeguards of the study and ultimately the use of the data. However, the Commission is mindful that in the past phases, ISPs contacting customers about the study helped garner significant public participation. In MBC Phase 3, ISPs’ involvement in other ways will also contribute to the overall success of the project; notably, the validation of certain data and feedback on the accuracy of testing equipment is a valuable contribution by ISPs.

MBC Phase 3 is an important study that will benefit Canadians in several ways. Wireless ISPs receive public funding from various sources to increase connectivity in rural and remote areas, among others, and studies such as MBC Phase 3 can contribute to creating accountability for the outcomes achieved by public funds. Also, the study is intended to provide data that can be used to evaluate strengths and weaknesses of current fixed wireless Internet services in Canada, and assess the services against the achievement of the objectives for Internet service connectivity such as those set out in Telecom Regulatory Policy 2016-496.

New data can lead the way for the innovation and improvement of this essential service – especially in rural and remote communities. In the Auditor General of Canada’s Report 2 — Connectivity in Rural and Remote Areas of 2023, recommendation 2.31 states that the CRTC“should routinely collect and verify data from telecommunications service providers on other aspects of connectivity quality in addition to speed.” Furthermore, one of the policy objectives in section 7 of the Telecommunications Act (the Act) is “to facilitate the orderly development throughout Canada of the telecommunications system that serves to safeguard, enrich, and strengthen the social and economic fabric of Canada and its regions.” Collecting data on the telecommunications system is in service of ensuring the development of services throughout Canada. Paragraph 17(d) of the 2023 Policy Direction states that the “Commission must enhance and protect the rights of consumers in telecommunications markets by […] regularly collecting, reporting publicly and making available to consumers information relating to mobile wireless coverage and fixed Internet services, […] and any other information that the Commission considers to be in the public interest, by requiring that service providers participate in the testing of the performance of their fixed Internet services, including services based on commonly used technologies in rural areas, and developing and implementing a standardized and robust approach for reporting mobile wireless coverage.”

MBC Phase 3 is in service of understanding the performance of a certain aspect of the telecommunications services industry in Canada at a point in time. This is used to inform the Commission about its current policies and future considerations. Therefore, facilitating participation in the study would serve the purposes of the Act’s policy objectives and the Policy Direction. 

Considering the above, the Commission expects wireless ISPs, and in particular Bell, Rogers, TELUS and Xplore, to further the achievement of a successful Phase 3 study. The Commission expects wireless ISPs to provide their customers of fixed wireless services with the study participation recruitment materials prepared and provided by Commission staff.

Yours sincerely,

Marc Morin
Secretary General

c.c:
CRTC contacts regarding the project:
Guy Morin, Guy.Morin@crtc.gc.ca
Bartek Bober, Bartek.Bober@crtc.gc.ca

Distribution List

Bell Canada, bell.regulatory@bell.ca
CanWISP, executivedirector@canwisp.ca;
CountryWifi, jeff@countrywifi.ca
Ecotel, Eric@ambra.co
Fiberspeed, cosmin@fiberspeed.ca;
IGS Hawkesbury, jbogue@hawkmail.ca
Minto Communications, service@mintocomm.ca
Muskoka Wifi Inc., will@mbwd.ca
Netsolid Inc., belairtech@gmail.com
Québec Internet, ljpaquet@quebecinternet.com
Rogers Communications inc, regulatory@rci.rogers.com
Ruralnet, heiner@ruralnet.ca
TELUS, Regulatory.affairs@telus.com
Vianet, regulatory@vianet.ca
Xplore Inc., legal@xplore.ca

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