Michael McNally on the New Spectrum Consultation

Here is a guest post written by Michael McNally (Assistant Professor, University of Alberta, School of Library and Information Studies) about the recently released “Consultation on the Spectrum Outlook 2018 to 2022”:

Innovation, Science and Economic Development (ISED) Canada, has recently opened a “Consultation on the Spectrum Outlook 2018 to 2022” (http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf11333.html).  The Consultation document seeks input on a number of issues related to the upcoming demand for spectrum over the next five year period.  While it is important that ISED consult on the future of spectrum usage in Canada, the Consultation process and document highlights some ongoing challenges in Canada’s wireless and broadband sectors.

First, and most important, is that the outlook is being conducted in a vacuum with regard to strategy.  The consultation document discusses several elements (including backhaul) without any assessment of how other key parts of the broadband landscape factor in.  ISED’s Connect to Innovate (CtI) program (https://www.canada.ca/en/innovation-science-economic-development/programs/computer-internet-access/connect-to-innovate.html), which has prioritized backbone fibre infrastructure that could address some concerns around wireless backhaul, is not mentioned. It is particularly notable that CtI isn’t mentioned at all, because at this point ISED should have an understanding of how CtI will impact middle mile fibre networks.

The Consultation document is also silent on the Canadian Radio-television and Telecommunications Commission’s (CRTC) new $750 million fund for rural and remote broadband that is currently being developed (http://www.crtc.gc.ca/eng/archive/2017/2017-112.htm), and implications from the CRTC’s decision in late 2016 declaring broadband a basic telecommunication service (http://www.crtc.gc.ca/eng/archive/2016/2016-496.htm).  The CRTC’s 2016 decision is particularly important for spectrum demand because it set a goal of having 90% of Canadian households with access to high speed broadband (defined as download speeds of 50 Mbps and upload speeds of 10 Mbps) by the end of 2021.  For Canadians accessing the internet through fixed wireless connections, spectrum will be needed for service providers to be able to meet these speed requirements.

Also, the document is silent on the announced Telecommunications Act review (noted in both Budget 2017 and the recent Creative Canada Policy Framework (https://www.canada.ca/en/canadian-heritage/campaigns/creative-canada/framework.html).  While it is unclear what might come out of the review, and there probably won’t be huge impacts on spectrum demand (of course spectrum demand will increase over the next five years), there is an overall lack of vision of the whole of the broadband/telecom policy and regulatory environment.

The Consultation document also raises several other points, which require further consideration.

In regard to demand for spectrum (satellite in particular) there is a lot of emphasis on 4k TV service.  However, there is no estimate of what the actual demand for 4k TV service is.  The argument for greater demand satellite broadband capacity to deliver 4k TV service requires both a consideration of the demand and uptake of 4k TV’s, particularly among remote and isolated Canadians, and a consideration of the amount of 4k programming that can be delivered to these TVs.

There is a total lack of discussion of how effectively existing licensed spectrum is being deployed. Canada’s big three wireless providers have licensed large amounts of spectrum. While there has been a lot of “use it or lose it” rhetoric around spectrum, more so from the previous government, there has yet to be any substantive action in this regard.  In the 700MHz Policy and Technical Framework (https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/700MHz-e.pdf/$file/700MHz-e.pdf), ISED committed to reviewing Radio Policy 019, which is a “use it or lose it” policy; however,  five years later nothing has been done. RP-019 is not a panacea, but considering future demand should also involve some consideration of whether existing licensed spectrum is being effectively used.  Also the Canadian Radio Spectrum Inventory (https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/Inventory-e.pdf/$FILE/Inventory-e.pdf)  has not been updated since 2010, making assessing who licenses what in the newer bands tedious.

In general, there is a lack of emphasis on Fixed Wireless Access (FWA).  While FWA is still a poor supplement for fibre, there is a lack of consideration of how FWA fits into the mix, particularly for those regions where it does make some sense (not dense enough for a fibre network, but dense enough that FWA makes more sense than satellite).  Rural needs have consistently lacked prominence in spectrum policy. A key means to address this would be to revisit now 2007 Spectrum Policy Framework for Canada (http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf08776.html).

Finally, ISED seems interested in returning to the 3500MHz band debate from 2014 (http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10914.html).  For way of background ISED (then Industry Canada) proposed to convert some from FWA spectrum to mobile wireless in ‘urban’ areas; however, their definition of urban was poorly designed.  They looked at Tier 4 areas, the smallest geographic regions on which spectrum is licensed,  and decided any Tier 4 area with a metro region of 30,000 would be ‘urban’ and thus have its FWA spectrum converted to mobile wireless use.  In Alberta, the Wood-Buffalo region, which makes up 15% of the area of the province, was going to be declared ‘urban’ simply because of Fort McMurray.  Thankfully the proposal was shelved, but the Consultation suggests the need to repurpose some 3500MHz spectrum. Ultimately if the 3500 band is going to be used for 5G mobile wireless then it does make sense to use this spectrum for 5G in urban areas (particularly because an equipment ecosystem will develop).  However, ISED should be careful to consider the need for FWA spectrum in rural areas.  A more granular approach to delineating rural from urban is a suitable starting point.

It is crucial the ISED consider the demand for new uses of spectrum and consult with Canadians; however, as evinced by the consultation document, there is ongoing need for an overarching broadband strategy in Canada to connect and coordinate policy on both the wireline and wireless broadband.