Submission to Telecom Notice of Consultation CRTC 2024-318

(2024-02-20)

Making It Easier for Consumers to Shop for Internet Services

Submitted by:
Hugh Armstrong
Director, ThEbLoBiNc
tbi@theblobinc.com

 

1. Introduction

Thank you for the opportunity to provide input to the Canadian Radio-television and Telecommunications Commission (CRTC) regarding making it easier for consumers to shop for Internet services (Telecom Notice of Consultation CRTC 2024-318). In light of the federal government’s requirement for transparent and accurate broadband services information (formerly Bill C-288), this submission underlines the importance of:

  • Increasing consumer choice by promoting healthy competition in broadband services;
  • Ensuring clear, comparable, and standardized consumer information for Internet packages;
  • Accelerating the deployment of next-generation Internet speeds (up to and including 10 Gbps and beyond) across Canada;
  • Strengthening affordability, innovation, and social/economic well-being through robust connectivity.

Furthermore, this submission incorporates themes from the #DemandMoreInternetChoice petition and highlights why allowing carriers—both incumbents and new entrants—to compete nationwide benefits consumers and meets Canada’s connectivity objectives.

 

2. The Importance of Robust Competition and Consumer Choice

2.1. Consumer-Driven Competition

Canadians overwhelmingly support more options in home Internet and mobile services, with cost savings and service quality as their primary motivators. A recent Rubicon Strategy survey, referenced by the #DemandMoreInternetChoice campaign, found that:

  • 84% agree that Canadians should be able to choose their internet provider and get the best price and quality;
  • 77% support government action to create more competition among internet providers;
  • 76% believe increasing competition is the only way to achieve better internet prices.

Despite commitments to increase competition in the telecom sector, the federal government asked the CRTC to reconsider its decision allowing carriers like TELUS to use FTTP networks in Ontario and Quebec. Such reversals limit out-of-territory competition and reduce consumer choice. In practice, a policy environment that actively encourages new entrants—while still upholding robust consumer protections—will:

  • Lower prices and stimulate innovation in higher-speed broadband markets;
  • Introduce innovative service bundles (Internet, mobility, entertainment, home security, health services, etc.);
  • Expand coverage to regions currently under-served by entrenched incumbents;
  • Preserve a healthy marketplace that drives affordability and service excellence.

2.2. Nationwide 10 Gbps Coverage as a Benchmark

While average speeds have increased steadily over recent years, Canada must plan and invest for 10 Gbps connectivity. Doing so:

  • Future-proofs our digital infrastructure for next-generation services (telehealth, advanced remote education, AI-driven platforms, etc.);
  • Keeps Canada globally competitive, aligning with high-speed benchmarks in other advanced economies;
  • Spurs productivity and innovation, especially in key sectors—healthcare, agriculture, manufacturing—that rely on low-latency, high-capacity networks.

A robust wholesale framework that rewards investment in state-of-the-art networks while ensuring mandated access will enable smaller or out-of-region competitors to reach consumers with 10 Gbps services.

 

3. Standardizing Consumer Information: Labels, Metrics, and Transparency

3.1. A Broadband Consumer Label

We commend the CRTC for considering standardized broadband labels, akin to nutrition labels, which simplify how consumers compare ISP offerings. By requiring ISPs to display consistent information—such as:

  • Advertised speeds
  • Typical speeds at peak times
  • Latency and jitter
  • Data allowances
  • Pricing and contract details
  • Reliability or outage frequency

…consumers can make informed decisions with minimal confusion. This transparency:

  • Promotes fair competition, rewarding ISPs that invest in high reliability, faster speeds, and responsive customer service;
  • Discourages misleading ads where “up to” speeds overshadow everyday performance;
  • Ensures consistency across both urban and rural markets, so all Canadians receive the same clarity.

3.2. Peak-Time Performance and Reliability

With more Canadians relying on stable connections for remote work, telehealth, and online education—especially at peak times—ISPs should disclose:

  • Actual speeds during peak hours (e.g., 7 p.m. to 11 p.m.);
  • Any reliability metrics, such as downtime rates or average time to repair;
  • Service guarantees or thresholds for latency, jitter, or packet loss that align with real-world application needs.

This added layer of transparency helps manage expectations and holds providers accountable to their advertised claims.

 

4. Encouraging Rapid Deployment of Next-Generation Broadband (10 Gbps)

4.1. Sustaining Investment and Innovation

To achieve Canada-wide 10 Gbps coverage, the Commission’s framework should:

  1. Encourage ongoing private investment by ensuring cost recovery and fair returns for those building state-of-the-art fibre networks;
  2. Reward early adopters of high-speed technology with regulatory certainty—allowing carriers large and small to plan multi-year investments;
  3. Leverage wholesale obligations to expand reach, especially out-of-territory, so newer entrants or smaller ISPs can foster competition in both urban and rural areas.

Case in point: TELUS’s entry into Ontario and Quebec with FTTP spurred new offerings up to 1.5 Gbps, proving that out-of-territory participation invigorates markets and benefits consumers.

4.2. Public-Private Collaboration

Bridging the digital divide, especially for advanced 10 Gbps speeds, requires government-industry collaboration. Mechanisms like grants, matching funds, and flexible financing (e.g., Universal Broadband Fund) can accelerate deployment. The CRTC can:

  • Advocate for expedited funding approvals and streamlined permitting;
  • Facilitate infrastructure sharing to reduce duplication (e.g., ducts, poles, backhaul);
  • Support proactive measures to protect network equipment and reduce copper theft—a serious threat to reliability, emergency services, and local economies.

 

5. Fostering Affordability and Social Benefits

5.1. Affordability Through Competition

When more carriers operate outside their traditional footprints, consumers see:

  • Price discipline on incumbents;
  • Innovative promotions, bundling discounts, or prepaid/flexible data options;
  • Lower-cost entry-level plans for seniors, youth, low-income families, and other vulnerable groups.

Recent Statistics Canada data show that wireless prices have declined significantly, outpacing general inflation trends. Expanding competition in wired broadband can yield similar affordability gains, especially if new entrants have access to regulated wholesale rates that allow competitive pricing.

5.2. Social and Health Outcomes

Access to fast, reliable broadband profoundly impacts:

  1. Healthcare: Virtual appointments reduce travel and hospital visits; remote monitoring and telehealth solutions become viable, saving time and costs.
  2. Education: Online classes, digital libraries, and remote tutoring help address equity gaps.
  3. Environmental Benefits: Remote work, telemedicine, and precision agriculture lower commuting and carbon emissions.
  4. Economic Development: High-speed connectivity helps businesses remain competitive, boosts tourism in remote regions, and supports local entrepreneurship.

 

6. Inclusive Access for Rural, Remote, and Indigenous Communities

6.1. Addressing the Rural-Urban Divide

Although rural connectivity has improved—98.2% of rural Canadians now have advanced wireless coverage—many remote areas still lack adequate fibre or high-capacity networks. Without competitive wholesale rates or cost-sharing mechanisms, extending 10 Gbps to lower-density regions remains challenging. The Commission’s policies should:

  • Remove barriers to entry (e.g., excessive transport fees, backhaul constraints);
  • Encourage partnerships with municipalities, Indigenous communities, and local ISPs;
  • Monitor and address labour and construction costs in provinces like Alberta and BC, where challenging topography and higher labour expenses hinder broadband expansions.

6.2. Indigenous Collaboration

Connectivity is central to reconciliation efforts and supporting self-determination for Indigenous peoples:

  • Access to critical services (health, education, government services) expands;
  • Business and innovation opportunities increase in underserved communities;
  • TELUS’s Indigenous Reconciliation Action Plan underscores how advanced broadband can help close socio-economic gaps and foster cultural responsiveness.

Public-private partnerships are key to bridging the digital divide and facilitating lasting community development.

 

7. Strengthening the Position of Consumers and the Role of the CCTS

7.1. Expanded Oversight

We support the Commission’s intention to reinforce compliance with the Internet Code. This could include widening its scope to cover new entrants and smaller ISPs, ensuring that all providers follow a high standard of clarity and fairness. The Commission for Complaints for Telecom-television Services (CCTS) should handle a broad range of consumer complaints, from speed misrepresentation to billing disputes, which:

  • Strengthens consumer confidence;
  • Provides consistent recourse mechanisms for issues outside the current CCTS scope;
  • Creates uniform accountability so that no large or small carrier is exempt.

7.2. Data Collection and Transparency

The Commission should collect:

  1. Compliance data regarding any new broadband labeling or speed-disclosure rules;
  2. Complaint statistics (frequency, resolution time, outcome) in a publicly digestible format;
  3. Performance benchmarks for ISPs, ensuring ongoing transparency.

Publishing aggregate, anonymized findings will incentivize better industry practices and inform consumers about real-world service experiences.

 

8. Conclusion and Recommendations

In summary, we respectfully urge the CRTC to:

  1. Endorse a robust wholesale framework that fosters real competition—enabling out-of-territory providers to offer fibre services nationwide.
  2. Adopt mandatory, standardized broadband labels with plain-language disclosures of speed, latency, jitter, reliability, and pricing—both pre-sale and post-sale.
  3. Facilitate rapid investment in next-generation (10 Gbps) infrastructure, ensuring fair returns for innovators and streamlining the regulatory process.
  4. Champion affordability by letting competition flourish, especially in underserved regions, and by maintaining effective consumer protections.
  5. Expand data gathering and oversight via the CCTS and publish aggregate compliance information, keeping consumers informed and ISPs accountable.

The #DemandMoreInternetChoice petition demonstrates Canadians’ desire for more affordable, innovative, and competitive options. Allowing carriers—whether incumbents in one region or new entrants in another—to deliver advanced fibre connectivity is crucial to Canada’s economic future and the well-being of its citizens.

By reaffirming these principles, the Commission ensures that Canadians can:

  • Easily compare Internet packages,
  • Benefit from cutting-edge speeds (including 10 Gbps services),
  • Enjoy the social and economic advantages of world-class connectivity, including improved healthcare, education, and environmental outcomes.

We appreciate the opportunity to contribute to Telecom Notice of Consultation CRTC 2024-318. Should additional information or clarification be required, we would be pleased to respond and collaborate further.

 

Submitted respectfully,

Hugh Armstrong
Director, ThEbLoBiNc
tbi@theblobinc.com