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Robert Ghiz, CWTA President & CEO
Opening Statement: Standing Senate Committee on Transport and Communication on Bill S-242, An Act to amend the Radiocommunication Act

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Tuesday, March 7, 2023
9:00 to 10:00 a.m. Eastern

Good morning. My name is Robert Ghiz. I am President and CEO of the Canadian Wireless Telecommunications Association. Joining me today is CWTA’s Senior Vice President, Eric Smith.

CWTA is an industry association representing companies that provide services and products across the wireless communications sector in Canada, including facilities-based mobile wireless network operators and equipment vendors. We appreciate the opportunity to discuss Bill S-242. Before commenting on the Bill, I’d like to briefly discuss the state of mobile wireless communications in Canada.

Despite the challenges of deploying wireless networks in Canada, such as higher building costs, large geography, harsh terrain, and low population density, Canadians enjoy some of the best mobile wireless services in the world. Reports from the two leading independent mobile network analytics companies show that Canada has among the fastest mobile networks in the world and the fastest of any G7 country. Consulting firm PwC has also rated Canada number one among G20 countries in its Mobile Quality Index, which compares countries on network speed, availability, and video experience.

But we are not just concerned with performance. Equally important is coverage. As a result of the billions of dollars invested in capital expenditures and spectrum by our members, the CRTC reports that 99% of Canadians have access to the latest generally deployed mobile wireless technology, known as LTE, and that the wireless industry is on target to provide coverage to 100% of the population by 2026.

This brings me to Bill S-242. While we share the goal of connecting every Canadian, this Bill will not help achieve this objective. In fact, it could have the opposite effect.

The Bill seeks to impose a one-size fits all spectrum deployment requirement. As officials from ISED previously testified to this Committee, the regulation of spectrum is not a one-size-fits-all process. To achieve its policy objectives, the department requires a flexible framework that allows it to tailor its processes and spectrum licensing conditions to suit the unique characteristics of the spectrum band being licensed and its proposed use. A one-size-fits-all requirement will limit the department’s ability to do so and risk undermining the department’s and industry’s shared goal of improving network quality and coverage. For example, if the deployment target is unachievable in a particular area, it is unlikely that anyone will bid on the spectrum. If the deployment conditions are achievable by only a few service providers, the department’s goal of enabling small and regional service providers to participate in the licensing process is undermined.

As the representatives from ISED testified, deployment targets should be ambitious but achievable for all providers. What is considered ambitious but achievable varies depending on the specific spectrum band and its intended use, and a variety of other factors. Some have expressed concerns that the deployment targets set by ISED are not ambitious enough. We respectfully disagree.

In recent years, ISED has been aggressively advancing a “use it or lose it” approach to spectrum. In 2021, ISED auctioned licenses to the highly coveted 3500 MHz spectrum band, which includes, in some licensed areas, a requirement to utilize the spectrum to provide services to 90% of population within five years, and 95% within seven years. The deployment conditions for the 3800 MHz spectrum that will be auctioned later this year are very similar. Global telecom consultancy Analysys Mason has called these deployment requirements the second most stringent among 24 comparable countries it surveyed.

ISED has also recently issued several decisions and launched consultations aimed at improving spectrum access for rural and remote connectivity. The aggressive deployment conditions established in recent spectrum auctions together with these recent decisions and consultations are a clear indication that ISED has made spectrum deployment a top priority. They have done so by carefully considering each issue and tailoring a response that it thinks will best achieve the desired outcome.

Bill S-242 would severely limit ISED’s ability to create tailored solutions to complex issues. It would also risk undermining the goal of enhancing spectrum deployment, the opposite of the Bill’s objective.

As I stated earlier, we share the goal of expanding and enhancing connectivity, but, with respect, we do not think that Bill S-242 will help do so. Mr. Chair, thank you for giving me the opportunity to speak to you about this important topic. My colleague and I are happy to take your questions.

– End of Remarks –