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Robert Ghiz, Canadian Telecommunications Association President & CEO
Opening Statement to the Senate Standing Committee on Transport and Communications (TRCM)

***Check Against Delivery***

Tuesday, May 7, 2024
9:00 a.m. ET

Good morning. My name is Robert Ghiz. I am President and CEO of the Canadian Telecommunications Association. Our senior vice president, Eric Smith, is joining me today. We appreciate the opportunity to appear before you to discuss Bill C-288.

Let me start by saying we support transparency. Advertising should be accurate, and when it comes to advertising internet access service speeds in Canada, it is. This is not our conclusion; it is the conclusion of a series of internet speed studies commissioned by the CRTC.

In 2015, the CRTC found that ISP “[p]erformance was largely consistent across all regions, with the vast majority achieving between 104% and 110% of advertised download speed.” In its 2016 report, the CRTC found that the majority of ISPs were delivering speeds above their advertised rates, regardless of the access technology in use, including during peak periods. And again, in 2020, the CRTC found that “all major Canadian ISPs are delivering users with average download speeds that exceed maximum advertised rates.”

As the regulator’s studies show, ISPs’ advertising of internet speeds is accurate. And if a customer encounters issues with their internet access service, our members work closely with the customer to diagnose and resolve the issue.

This leads us to the obvious question: Is Bill C-288 necessary? Especially when we already have the Competition Bureau and the Commission for Complaints for Telecom-television Services to address concerns about advertising or unresolved service quality issues.

En tout respect, je pense que le projet de loi tente de régler un problème qui n’existe pas. Il y a beaucoup d’autres problèmes concrets et urgents en ce qui concerne Internet haute vitesse au Canada qui méritent qu’on s’y attaque.

Les exploitants de réseaux canadiens investissent des milliards de dollars chaque année pour étendre et améliorer leurs infrastructures. Grâce à ces investissements, le Canada peut se targuer d’avoir des réseaux de télécommunications parmi les plus performants du monde.

According to independent network analysts Ookla, Canada’s median fixed broadband download speed is 110.6% faster than the global median. Notably, it is 91% faster than the UK and a remarkable 233% faster than Australia.

Not only are Canada’s fixed broadband networks fast, but they are also available to a greater percentage of the population than most of our G7 peers and Australia, especially at the higher speed service tiers.

And while record investments were being made to expand and enhance coverage, StatCan’s internet service price index declined by over 15% in the last year alone.

As impressive as this is, we know more work is needed. While access to high-speed internet in rural communities increased by 65.6% between 2018 and 2022 and 60% in First Nations reserve areas, not every Canadian household has reliable, high-speed internet service.

Bill C-288 will not help close the digital divide. Only the private sector’s continued investment in network building, supplemented by strategic government funding, will realize the goal of connecting all Canadians.

Unfortunately, as in other countries, Canada faces significant challenges when investing in critical infrastructure, including high borrowing costs, network costs, climate-related risks, and increased regulatory requirements.

To sustain investment in telecom networks in Canada, Parliament must resist the urge to impose new regulations that add to the cost of doing business without a corresponding consumer benefit.

Bill C-288 presupposes a problem that the CRTC studies show does not exist.

Moreover, false or misleading advertising laws exist under the Competition Act and the Government has directed the CRTC to continue collecting and reporting information related to fixed internet services to the public. For these reasons, we respectfully ask this Committee to recommend to Parliament that Bill C-288 not proceed.

If it does proceed, we ask the Committee to adopt the following amendment. The definition of “fixed broadband service” should be amended to remove the words “high-speed data transmission service provided to a fixed location” and replace them with “fixed internet access service.” High-speed data transmission service is a broad, undefined term that could unintentionally expand the bill’s scope. Fixed internet access service is well understood by the Commission and the industry.

Thank you again for inviting us to meet with you today. We look forward to your questions.