GOVERNMENT AND REGULATIONA BRIEF CONCERNING ASPECTS OF THE ACT TO AMEND THE COMBINES INVESTIGATION ACT BILL C-42BACKGROUND ON THE COMPANY Systems Dimensions Limited (SDL) is a Canadian company formed in 1968. SDL is a publicly-owned company with shares traded on the Montreal and Toronto Stock Exchanges. The company is independent, with no single major shareholder. The shares of SDL are about 99% held in Canada by some 3,300 shareholders from coast-to-coast. SDL is the major independent supplier of computer services in Canada. It is from this point of view that we are presenting this Brief. PURPOSE OF THE BRIEF As an independent Canadian enterprise, SDL is concerned that a state of healthy competition be maintained in the Canadian marketplace. However, SDL is equally concerned about any proposed legislation which will seriously affect its operations in Canada or, in general, encroach on the ability of companies, in general, to operate effectively. We are also concerned about any proposed legislation that may expose individuals or corporations to arbitrary actions by administrative bodies without adequate protection through the Courts for the rights of those individuals or corporations. In view of the short time allowed for the presentation of briefs, we have largely restricted our comments to those matters that are of immediate relevance to our industry. We have also touched upon some other general matters of concern which, I am sure, will be brought to your attention by many other organizations. THE CANADIAN DATA PROCESSING SERVICE INDUSTRY The data processing service industry provides, on a commercial basis, remote and local batch computer time, conversational time-sharing facilities, systems design, analysis programming and implementation of computer-based systems, feasibility studies, consulting and educational services related to computer activities, input services such as keypunching, key-to-tape, optical character recognition, and similar services necessary to the use of computer and/or peripheral equipment. Statistics Canada indicated that operating revenue for the data processing service industry, by itself, in 1974 amounted to $211 million dollars. There are now approx imately 300 firms in the data processing services industry. The industry is clearly highly competitive. Our concern in this brief is not that the industry lacks competition but, rather, that one particular section of Bill C-42 could have a very serious effect on the development of the industry in Canada. The following comments should put this in perspective: SECTION 10.2 BUSINESS DATA STORED IN COMPUTERBANK SUBSECTION (1) This subsection requires that "every one who stores in a computer databank, wherever situated, data relating to a business carried on by him in Canada and who occupies premises in Canada shall maintain on premises in Canada an extensive record of the data so stored." SDL maintains that this is an unwarranted imposition on many businesses. It is an example of a universal regulation that may entail expenses for all corporations when the possibility of such information being required by the Competition Policy Advocate (CPA) is very slight. This is quite unlike the requirements of the Income Tax Act that all companies keep certain minimal records. In the Income Tax case, all companies are, or might be, expected to pay taxes and, therefore, be subject to audit. It may be that such information is of benefit to the company but this Act makes it an offence not to keep such information. One might reasonably ask if organizations are required at the present time or under the proposed Act to retain similar records of all other information that might be required from time to time by the CPA, e.g. are companies expected to keep such voluminous records for all their manual files? Beyond this general point, we are very concerned about the impact of other implications of subsection (1). It is now common practice for organizations to use outside service bureaus for the storage of data. The advantage to our clients is that they are able to share the resources of a very large computer and pay only for the time used. The further implication is, however, that the "data sets" (programs and information records of various kinds) are normally stored on shared devices. For example, it is common practice for organizations to share magnetic disk files. It is implicit in this process that the security of access to these files is vital, both to the owner of the data sets and to the data servicer organization that is acting as a temporary custodian of the data sets. Data sets are usually accessible only on the presentation to the computer of a password or other security safeguard. Subsection (1) requiring that all companies commit in hard copy the access codes for their data could compromise the security of such data. If the passwords leave the possession of the company, then either the files would be insecure or the company would have to change the passwords in which case the information provided to the CPA would be useless. In summary, we doubt, under Section (1) that the procedure proposed is either necessary or practical. SUBSECTION (2) This subsection requires that anyone who stores in a computer databank, wherever situated, data relating to a business, may be required to provide printouts or other information. We believe that it is absolutely essential that the Act be clear that this refers to the owner of the data sets and not to the data servicer. A data servicer's business depends on the integrity with which he handles a client's data sets. If a client felt that his data could be arbitrarily investigated or seized by the CPA or anyone else through the data servicer, then the entire data services industry in Canada could be seriously compromised. The principle must be established that the investigation is a matter between the CPA and the client. Requests for data must be directed to the company being investigated and not through a third party. There may be some similarity here to the data services industry and the Post Office. Both organizations act only as temporary custodians of someone else's information. We are not at liberty to give up that information without our client's permission anymore than the Post Office could turn over mail to a third party. Our present approach is that nothing less than a Court Order would cause us to release data sets held in trust. Beyond this fundamental matter of principle, however, are many practical problems: First, it is not common practice for the data servicer to know the nature of the data being held for the client. The implication of this section of the Bill is that the data servicer could be forced to give up such data. This may be impossible. For example: • at the customer's option, data held may be scrambled or otherwise coded • it is common practice to use passwords not known to the data servicer • in all likelihood, the format of the data will not be known to the data servicer The data servicer can usually only determine that a certain number of data sets are being held and the name of the client on whose behalf they are being stored. Secondly, even if a Court Order were given directly to a data servicer, a "dump" of the data would likely be unintelligible. Considerable work would have to be done to "format" the printout or otherwise analyze the data to make it meaningful. The costs for dumping, copying, or processing records, can be substantial. If special programming is involved to make sense of the data, the costs will almost certainly be non-trivial. The question of who pays these costs must be addressed. It may be either the CPA or the client. In fairness, it should not be the data servicer. Thirdly, it should be borne in mind that the acceptance of the computer printout as evidence "without further proof" is a questionable practice. Whatever may be the deeper implications for the common law of evidentiary proof, the practical consideration is that computer data can be accidentally, or purposefully, manipulated by either the investigator or the owner of the data. We point this out because we believe it is an area that requires much deeper examination before the concept is accepted into law. SUBSECTION (5) This section gives CPA the right to "enter any premises on which the Competition Policy Advocate believes there may be any record or description referred to in Subsection (1)". Once again, we believe that this extensive 'search and seize1 approach should be questioned on a matter of principle, as well as practice. Even with a Court Order allowing the CPA to examine records held in trust by a data servicer, the power of entry as described is not practical. The data servicer is responsible for the safekeeping of the records of hundreds of clients. As noted earlier, these data sets are often stored in the same physical file devices and are accessed through the same computer and communications equipment. The data servicer would, on a matter of principle, have to take steps to protect the security and the availability of other client's data regardless of the demands of the CPA for the data belonging to a single client. There is the implication that 'other things' could involve the seizure of an entire disk file containing data for many clients just because that disk file contained data for the client in question. There might even be the implication that a data servicer's entire computer could be seized under extreme circumstances. Selective copying and other procedures may be an answer, but the broad powers granted to the CPA under this section are simply not reasonable when an outside service organization is the custodian of the data. There is further the practical problem of actual physical access. Most computer rooms have very strict rules about personnel who may enter. This is for reasons of file integrity, as well as possible damage to the equipment. Further, the physical environment of most computer rooms is rigorous in their needs for air-conditioning, dust control, humidity control, etc. The granting of the right to enter any premises could lead to the serious disruption of business for both the data servicer and its other clients. SUBSECTION (6) In general, this section gives the CPA authority to . "take away for further examination" any description, program, or printout. This raises the question of how the data servicer will be able to continue to fulfill his contractual obligations to provide processing for his clients if some of these items are physically removed. The question must be resolved as to who would be responsible for the legal consequences of the data servicer being unable to fulfill his contract because of the unavailability of the needed data, e.g. magnetic tapes, punched cards, operating instruction books, etc. Further, if such items as magnetic tapes or magnetic disks are removed, the responsibility for the physical safety of these magnetic media must be addressed. BUSINESS NEEDS AN OMBUDSMAN PRESS RELEASE: Toronto, Ontario August 6, 1976. George Fierheller, President of Systems Dimensions Limited of Ottawa, today told a Toronto audience that Canada's business community needs an Ombudsman. Mr. Fierheller told the Third International Conference on Computer Communication at its Royal York meeting that "the time has come for those of us who believe in the free market system to establish an Ombudsman to protect the system from encroaching government interference". Mr. Fierheller realistically noted that for such a position to have any meaning it would have to be given constitutional powers. He further noted that the default option must be to the private sector with government required to justify any moves to take over or closely regulate a new sector of the economy. The ICCC is a U.S. based council established to foster scientific research, development and applications of computer communications. Previous conferences have been held in Washington D.C. and Stockholm. Systems Dimensions Limited (SDL) is Canada's leading independent publicly-owned computer services organization. Back to Section I Index or just read on  THE CANADIAN ENTREPRENEUR IN THE 70'SA PANEL DISCUSSION ON THE INTERACTION BETWEEN NATIONAL POLICIES AND BUSINESS DEVELOPMENTTHIRD INTERNATIONAL CONFERENCE ON COMPUTER COMMUNICATION. TORONTO. AUGUST, 1976The interaction between Government and the Free Market System is at a critical stage in Canada. Government involvement in the economies of major countries in the Western World has been growing for over a century, but has shown a marked acceleration during recent decades. The imposition of comprehensive controls on prices, wages, profits and dividends, here and elsewhere, has caused concern and even alarm. The frightening spectre is that the involvement of government at the detailed level of product development and marketing may become permanent. This is clearly a time for reason not rhetoric. Entrepreneurs and businessmen in Canada must not panic, but rather respond to the Prime Minister's challenge to open the topic for national debate. THE NATIONAL CHALLENGE The challenge we face as businessmen and citizens is to ensure that the subject is discussed and the result is a clear definition of the role that government should be permitted to play in the Free Market System for the benefit of the country. The Free Market System has provided the Western World with the highest standard of living ever known. The system should not be lightly discarded. It has not been proved in any country that extensive government’ control or direct operation of a large portion of a nation's economic enterprises does act in the best interests of the majority. However, it is equally true that the 'invisible hand' of Adam Smith is not sufficient guidance for all aspects of a complex modern economy. The question that must be addressed is not IF government involvement is required but WHERE and TO WHAT DEGREE. Let me suggest some guidelines… THE ROLE OF GOVERNMENT I believe that the first obligation of a national government is to establish a clearly stated set of objectives for the country. These objectives should be stated as rigorously as possible. The plan must be long range, e.g. to the Year 2000. By being rigorous, I mean that the government should define the national objectives in numeric terms, wherever possible. I suggest they could include: • a gradually increasing GNP per capita with specific checkpoints every five years • a defined acceptable level of inflation • a policy of substantial resource independence through development of substitutes, recycling, etc., as only this way can a National Plan be reasonably independent of external factors • a definition of acceptable environmental levels of pollution • an objective in terms of desired population size which must be linked to the desired GNP, resources, and similar factors Such a model would have to be dynamic but would at least provide objectives against which Canadians could judge the results of strategies developed by governments or private enterprise. This clearly recognizes that there must be constraints but these will be largely acceptable to both parties when viewed in the light of the national objectives to which the majority of Canadians would then have committed themselves, I believe that the greatest shortcoming of our current national government is the failure to create such a Plan. I do not underestimate the size of the task. We must not under estimate the cost in wasted effort if we do not try. The establishment of a national set of objectives is particularly difficult in a mixed economy. The implem entation will be more difficult than a series of Five Year Plans in a more authoritarian state but, if we fail to define where we are going, there will be no way of judging how well we are succeeding. Many States in the United States have established Project 2000 operations with this in mind. I believe the government in Canada owes the people no less. Without such a long range plan, Democracy as we know it and the Free Enterprise System we purport to cherish will almost certainly decline. The difficulty is that, without national objectives, the majority in a Democracy can and will vote themselves as much of the resources of the country as each generation desires. This situation is compounded by the generally short range outlook of governments elected for periods of five years or less. With clearly stated goals, the role of government can then be defined in terms of the amount of involvement in the economy necessary to reach these goals. THE INTERACTION OF GOVERNMENT AND THE FREE MARKET ECONOMY If the first objective of government is to define national goals, the next task must be the definition of minimum levels of service in Health, Transportation, Education, etc., that will have to be provided directly by the government if such services are going to be uniformly available to all Canadians. Examples might be… • a national rail network, such as the CN • a national airlines system, such as AIR CANADA • a national broadcasting system, such as the CBC Public support of such basic operations will be necessary if service is to provided to all Canadians even in marginal areas. Canada has shown great ingenuity in using Crown Corporations, or other devices, in developing our present mixed economy. However, unless it can be clearly demonstrated that further regulation, control, or operation by government of organiz ations in such industries is absolutely necessary, I believe that the Free Market System should be allowed to operate with as little interference as possible. For example, restricting Canadian Pacific Airlines to a percentage of Air Canada flights in designated areas is a restriction totally unwarranted. Having established a national broadcasting network, with its implications for national unity, it then becomes redundant to artificially restrict what can be done by private networks. It is in areas such as the latter that government is creeping into the Free Market System in a way that will ultimately lead to the destruction of the system. Where there are peripheral services that are desirable but not within the defined minimum level of necessary services, these should be left strictly to the private entrepreneurs. Those operating in the free market sector will, of course, have to live with constraints in the areas of public safety, environment or, on occasion, resource usage. But beyond this, the default option should be that the private sector is left unregulated. The role of the private sector must be to provide the choice and diversity of products and services desired by the citizens of the country. They can only do this when the Free Market System is available to allow opportunity for entrepreneurs with suitable rewards for success and the risk of failure when the entrepreneur has not properly judged the desires of the public. GOVERNMENT AS AN ENTREPRENEUR Where the national government has attempted to take over the role of the entrepreneur, the results have been almost uniformly unsatisfactory. The well-intentioned efforts to establish a computer manufacturing industry in Canada has only led to financial disasters, such as Consolidated Computer, Inc., or the provision of government funding to multinationals who could well afford to finance programs on their own. The attempts to establish a components industry with government urging and backing has been even less successful. Microsystems International is a project that I doubt would have been undertaken had it not been for the prompting and financing of the Federal Government. These and many other examples arise because of the confusion in the policy of our government between the risks that an entrepreneur can and should properly undertake in response to real and not imagined demand, and the proper role of government in providing the basic minimum levels of service designed with national objectives in mind. The government is a poor entrepreneur. It should stay out of this area. It should leave to industry the initiative in response to market demand. Government should let industry take the risks. There is more than enough to do with public money than to bear risks that should be undertaken by the private sector. THE COMPUTER COMMUNICATIONS INDUSTRY Our industry faces a major challenge in this redefinition of the role of Government and the Free Market System. First, in Canada at least, our industry is going to have to be more independent and stop requesting assistance from government. The more we request, the more difficult it will be to draw a reasonable line between government and our industry. If we do not like the results, we will then have only ourselves to blame. Secondly, as we are the entrepreneurs in the information processing field, we will have to direct our efforts towards assisting our national government in doing the computer modeling and other tasks that will be necessary in the Project 2000 I am proposing today. I am sure our industry will rise to this challenge. A BILL OF RIGHTS FOR THE FREE MARKET SYSTEM As students of Roman History will know, it became necessary for the Citizens of Rome to establish a position called The Tribuni Plebis. This Tribune of the People was responsible for protecting the rights of the citizens against the Senate. Today, the position of Ombudsman has a similar function wherever this concept is in use. I suggest that the time has come for those of us who believe in the Free Market System to establish an Ombudsman to protect the system from encroaching government interference. Such a position would have to have constitutional powers to monitor government's action and take corrective steps, where necessary. I believe that nothing less than this approach will be truly effective. The alternative will be a steady erosion of the system that has done so much for us. The default option must be the private sector. The onus must be on the government to convince the Ombudsman that it is absolutely necessary for the government to take over or closely regulate a new sector of the economy. This case can only be made by relating the need to the previously proposed national objectives. If we believe the Free Market System is worth protecting, we must act now. Back to Section I Index or just read on  RELATIONSHIPS WITH GOVERNMENTS POLICIES AND STRATEGIES THE FIRST WORLD COMPUTING SERVICES INDUSTRY CONFERENCEBARCELONA, SPAIN. JUNE 20-23, 1978A CANADIAN VIEWPOINT The Computer Services Industry in Canada is the fastest growing segment of the computer industry. In 1976, revenues for the industry exceeded $300 million. There are about 350 identified suppliers of some form of computer services in Canada, although only about half that number are of significant size. Government at all levels has been a strong influence in the industry, although this influence has not always been positive. Before discussing the role of government, it is important to understand that Canada has a highly decentralized form of government with considerable powers being granted to the Government of the ten Provinces by the British North America Act. In fact, although the government at all levels now accounts for about 40% of the Gross National Product, about half the expenditure by government is done through the Provinces. Despite this, it is the Federal Government that has had the major influence on the computer services industry. THE ROLE OF THE GOVERNMENT As in most countries, the various levels of government in Canada can play a role as • a regulator • a user • a promoter of the computer services industry. GOVERNMENT AS A REGULATOR From the earliest days of the Computer Services Industry, the Federal Government has been active in its examination of this new industry. As early as 1969, when a group of the original entrepreneurs met with Federal Government Ministers to protest the partial ownership by Canadian National Railways of Computer Science Corporation of Canada, the Government's attention has been focused on the industry. The Federal Government launched a major examination of the consequences of the computer/communications industry for a country which was both decentralized and whose population was spread along a 100 mile corridor close to the U.S. border. In a way, Canada could be viewed as a country 100 miles wide and 4,000 miles long. The studies of the Telecommission led to a report called 'BRANCHING OUT'. Although never accepted formally as Government Policy, this report recommended that the young computer services industry should not be regulated. As a result, there has been no serious attempt to directly regulate the activities of the industry in Canada. This is not to imply, however, that government regulatory activities have not had a significant indirect influence on the industry. For example, Government Tariff policy, which endeavours to protect a non-existent Canadian mainframe industry, has made it difficult for Canadian computer services firms to compete in the United States where mainframe costs are substantially lower. The Canadian Tariff Board has recognized the problems with this policy and has recommended a change. No action has been taken to date. Regulations in the field of Privacy, Freedom of Information, and similar matters will, of course, have a direct influence on the way data is handled by service bureaus. The Federal Government is groping toward a policy on transborder data flow, although this is not seen as a priority item for Canada at the present time. CADAPSO, the industry association in Canada, has taken the position that common carriers, banks, or other organizations which are granted a monopolistic advantage by the Government, should not be allowed also to operate in the computer services industry, except on a completely arms length basis. This has led the Government, once again, to get involved in a regulatory sense through the Bank Act, or regulations affecting the carriers. It is obvious, of course, that indirectly the role of the Government as a regulator has significant effect on the industry. All of the major computer services firms are highly dependent on communications. In Canada, the Canadian Radio-Television and Tele communications Commission regulates not only competition in the communications industry, but also rates. One of the major concerns of the industry in Canada is the high cost of communications relative to the cost of similar services in the United States. In general, the role of Government as a regulator has been somewhat peripheral. The Federal Government has tended to leave the industry alone, at the industry's request. It is the policy of CADAPSO to have this situation remain. GOVERNMENT AS A USER The Federal Government is the largest single user of computers in Canada. The ten Provincial Governments are also large users, as would be expected. The Federal Government has generally taken an enlightened policy towards the industry in terms of the use of outside services. In the mid-1960's, the Federal Government did establish a Central Data Processing Service Bureau. This Bureau was subsequently disbanded in favour of requiring that Government Departments use outside services unless it could be clearly demonstrated that there were cost benefits or reasons of national security making it necessary for internal computers to be installed. This is not to imply that this policy is necessarily being closely followed. At the present time, CADAPSO is pressuring the Federal Government to examine more of their in-house installations with a view to tendering some of these workloads. There is also some pressure to have the Government consider Facilities Management. This approach is almost unknown in the Canadian Federal Government computer area. However, relative to the actions of the Provincial Governments, the Federal Government has thought through the problem and made the clear policy statement encouraging the use of private service bureaus. The Provincial Governments, on the other hand, have been very slow to use outside services. In fact, there has been a recent trend in some of the larger provinces to take work back in-house. CADAPSO has been pressuring these governments to re-examine this and, in particular, to ensure that comparative costing studies are fair. Despite this pressure, most Provincial Governments have large in-house service installations and in some cases, provincially controlled service organizations compete not only for government business but directly against the private sector. This is not unusual in Canada. Canadians have developed a long tradition of direct competition between the private and public sector for private sector business. This is true in airlines, communications, broadcasting, and even in the plastics business. It is an odd situation that only complacent Canadians could tolerate. A major difficulty encountered in Canada at the present time is the tender process for computer services. This is an evolving art and all levels of Government are very sensitive to the need to improve the process. A development of the last couple of years at the Federal Government level has been very stiff price competition for Federal Government business. This, in turn, has led to some depression of prices in the private sector. It is hard to blame the Government for this, although from time to time their approach of re-tendering business already in the private sector rather than tendering new business from entrenched in-house empires has compounded the problem. The oligarchic structure of the industry in Canada, with 5 to 6 large firms all about the same size, is at the root of the present competitive situation in Canada. In general, then, the Federal Government has taken an enlightened approach toward the use of the industry and the Provincial Governments are generally acting very provincially. GOVERNMENT AS A PROMOTER This is an under-developed area. In general, neither the Federal nor Provincial Governments really understand the value of a service as an exportable product, as well as a vital national need. We view the computer services industry as really an industry's industry. Our main purpose is to sell our services to make other industries more productive. With the current low state of Canada's industrial productivity, one would think that increased computerization would be a major national priority. Instead, most levels of Government tend to concentrate their support on the manufac turing sector without particularly concerning themselves about how productive the companies are. There has been limited direct encouragement of our industry through Federal Government programs. After considerable input, the Federal Government finally altered their direct assistance programs to include some software products. In most cases, however, such direct aid for research has been difficult to obtain and often has been time consuming to justify. Until March of 1978, there was an organization known as the Computer/Communications Secretariat set up within the Department of Communications. Its purpose was to improve the interface between Government and the industry. As an economy measure, this organization was disbanded leaving any Federal promotion of the industry to the Department of Industry, Trade & Commerce. This latter organization is still very oriented towards manufacturing with little understanding of services as a product. CADAPSO is endeavouring to correct this, but it is a problem that goes far beyond our industry. One can contrast the Canadian approach with that in Japan, where the understanding of information as a commodity is very clear at the national government level. There have been some attempts by Provincial Governments to organize trade missions but, in general, all levels of Government have left the industry to do its own promotion. The most effective promotion of the industry has really been by the Federal Government through being a user. In general, this is an area that needs rethinking by all levels of Government for the services industries in general. A PROGRAM FOR GOVERNMENT I am more concerned about too much government than too little. In a large measure, the industry has been as successful as it has because of the relatively low level of government involvement. There are, however, some activities that the government could undertake which would help this industry as well as some others: 1. Encourage service industries in general. By and large, these industries are low The Government could assist research in new software programs by allowing a 150% write-off of R&D expenses for tax purposes, at least up to the amount of the tax otherwise payable. This measure was proposed in the Federal Budget of April 10, 1978. 2. Encourage the industry by using it. Even though there may be instances when an in-house computer is more efficient than the use of outside services, the difference in cost is not normally so significant that the Government would not gain back in taxes what it loses by not using in-house facilities. It is very difficult to convince other nations that the Canadian computer services are among the best if our own governments do not use the services. 3. Encourage entrepreneurial activities. It is not just large firms that come up with good ideas in the Computer Services Industry. The Federal Government could encourage entrepreneurs in this field by allowing the first $250,000 of capital gain to be tax free in a new enterprise. 4. Encourage better interface between universities and industry. Universities are largely supported by tax dollars. Many interesting innovations in the universities are therefore already paid by the public purse. Incentive schemes could be developed to encourage universities to publicize the results of their research and, if these computer software or hardware products are used, a profit sharing arrangement with the university could be developed. As noted earlier, the most important action the government can take is to stay out of the way of the industry. I would not recommend direct funding in this field by levels of government other than by giving a better tax break on industry-oriented R&D. I would also caution all levels of government to avoid indirectly constraining the industry by rushing into privacy legislation, international agreements on transborder flow and similar issues. The industry has grown because it has met real rather than perceived needs. It is a field for entrepreneurs. One cannot legislate the existence of new markets. My summary recommendation would be that, as this is a fast moving, market-oriented industry, there is little need for significant government involvement. Back to Section I Index or just read on  MINISTERIAL DISCRETION - IS THERE ADEQUATE CONSTRAINT?A VIEW OF THE REGULATED CANADIAN BAR ASSOCIATION. VANCOUVER, B.C.SEPTEMBER 1, 1981According to Webster, the word ‘discretion has two meanings. The first is the one that will get most attention today - "power of free decision or latitude of choice within certain bounds." a second meaning, however, is "cautious reserve in speech." My first experience as one of the directly regulated showed elements of both meanings of the word. In 1972 I was president of a large computer services company in Ottawa. At that time everyone was talking about the wired city. It seemed logical to me to try to put together a computer services company with a cable television company, so that the new wonders of teleshopping, in-the-home education, etc. Could be brought to people where they lived and where they worked. To this end I arranged with Gordon Henderson the president of Ottawa Cablevision Limited for my company systems dimensions limited to acquire OCL, subject of course to CRTC approval. After a public hearing and some months of delay I finally received what must be a classic telegram from Pierre Juneau, the then chairman of the CRTC. It simply said, "denied - the merger of a computer company and a cable television company is considered premature." It certainly was! Nearly a decade later both the computer and the communications industries are still just talking about all the things that could happen while other countries are moving ahead to make such in-the-home services a reality. However, whether the decision was good or bad is less important than the way this incident illustrates the awe inspiring power of ministers or the bureaucrats who report to them. There was no appeal possible. One could not even request and obtain a more detailed explanation as to why the application had been turned down. The power was absolute. The decision was final. Gordon and I had no choice but to unwind the merger. Not only had the ‘power of free decision’ been used, but there was every indication of a ‘cautious reserve’ in the bureaucrats approach to the business world. There was simply no inclination to take a risk. Perhaps more than any other single factor it is this conflict between the businessman whose main job is to take risks by pushing into new areas versus the bureaucrat who sees no personal gain in changing the status quo. This is not to imply that the decision was taken thoughtlessly for the then chairman was both perceptive and articulate, it was just that the CRTC’s mandate was not to look at cable communiÂcations as an electronic pipeline into the home for all kinds of services, but rather to narrowly interpret the broadcast act as being there to protect the over-the-air broadcaster. Anything that distracted the viewer from watching Canadian programming was somehow felt to be bad, and the uses of other technological capabilities of cable were overruled as a result. In what follows I will be using examples from my experience in the communications industry. However, as about one-fifth of industry in Canada is subject to direct regulation and most industry is subject to indirect regulation, I am sure that many of the observations will apply to a broad spectrum of circumstances. Some of the problems for the regulated could be categorised as follows: 1. THE POWER TO DELAY One of the greatest frustrations arises when legislation gives apparent power to a minister or a regulatory body in a particular area and then that minister or body refuses to deal with the situation, or simply delays decisions. This is often known as the ‘power of the in-basket’ A good example of this is pay television in Canada where at least five sets of hearings have been held over many years with still no resulting decision. The present minister finally let it be known that he wanted a decision and this pointed up an even stranger anomaly - where the power really lies. It is very difficult for the elected officials to push the entrenched bureaucracy who feel they can simply outlast any minister. In this particular case, another hearing has been called on pay television with good terms of reference, however, a decision will not likely be forthcoming for some time yet and the final decision will likely still be biased towards the original desire to protect the Canadian broadcaster. Another example was a recent rate increase application we filed for the clty of Victoria. This was filed the required 56 days before the announced hearing date. We were told however that it would not be an appearing item as they were now interpreting the regulation to be that 56 days must elapse after the material is tabled before the rate committee. Such a regulation is not published to my knowledge anywhere. The fact that hearing dates are not establish! Well in advance makes it almost impossible to second guess when material must be submitted. A decision on these matters is totally arbitrary and yet can have great financial effect on the companies operating under such regulation. 2. Escalation of jurisdiction Having mentioned rate regulation it is interesting to note that the broadcasting act does not directly reference giving rate regulatory powers over cable television companies. However, the CRTC has interpreted that the rate is a condition of license and they do have the right to grant that. No-one has ever seriously questioned this administrative regulation. In the area of non-broadcast services the regulatory power of the CRTC is even more suspect. Why has such discretionary escalation of jurisdiction gone unchallenged? 3. Legislation by intimidation To be blunt the reason is that many regulatory bodies are policeman, judge and jury. Even if one were to win a case challenging the jurisdiction of the body, one might be the long run loser because an organisation still has to appear before that body for a variety of other needs. This leads to: 4. Existence by compliance The regulated tends to figure out what the regulator really wants, e.g. increased Canadian film production, promotion of bilingualism, community involvement, etc., and then effectively trades off some of these items for some needed relief in some other area. It should be noted that this is done at the administrative level and not at the political level where one would expect such decisions to be made. 5. Inflexibility of regulation Acts of parliament do not get updated very often. In the case of the broadcast act it still treats the communications industry as though there was a limited spectrum for broadcasting, of course, with the advent of cable, there is as much spectrum as anyone could possibly need. Yet the industry is still regulated tightly on everything from content to the location of signals. 6. Justification for decisions Decisions are often disarmingly incomplete, on a recent rate application the amount requested was arbitrarily cut back simply with the comment that a 50c increase was economically justifiable. On what grounds was the additional requested 25c denied? 7. Scope of jurisdiction The scope of the CRTC’s jurisdiction is awe inspiring. This small group of people who are not elected by anyone have vast powers over what programmes Canadians can see and even when they will see them. Effectively, this group can quite arbitrarily determine what is in Canadians’ best interests, and they can make their decisions stick. Fortunately, discretion is also the prerogative of the public who will view or not view what they want despite the CRTC, 8. Cost of regulation This is a huge topic but it is worth remembering that the cost of the regulatory process is ultimately borne by the consumer. The extent of the regulation is largely determined by the bureaucracy there seems to be very little questioning of this whole process by the elected officials. The resulting rate regulation relative to current inflation rates means that the rate of plant reinvestment is on the decline in the communications industry. This will not work to the public’s advantage in the long run. Discretion may be the better part of valour. It is not likely the better part of value. THE APPEAL OF APPEAL The above are just a view of the frustrating examples one could give of arbitrary ministerial or administrative decisions. The most often heard answer is that some appeal mechanism should be allowed. But where? The only appeal possible from CRTC decisions is to cabinet. Only once or twice has such an appeal been made and in the famous Telesat case the CRTC’ s decision was in fact overturned. However, such a procedures is rarely feasible for any but the largest of companies, and even then only in very major cases. The real answer lies in reassessing what should be regulated in an economy. In the United States in the communications field there is a recognition that a significant degree of competition now exists. Many of the services that could be provided by cable can also be provided by telephone companies, transmitted by direct broadcast from satellite, or substitutes can be found through videotapes, videodiscs or other devices, to say nothing of over-the-air broadcasting. By contrast in Canada I am told that the CRTC faces a backlog of over 4,000 decisions. I simply cannot believe there are 4,000 important matters that need deciding in the communications industry in this country. It is more likely that there are 10 or 12 major issues where informed input by the government could in fact be helpful. The real problem lies with the attempt by a regulatory body such as the CRTC to do detailed management of nearly 400 companies. The CRTC asks questions on exactly how much staff is used in each area, what management services are provided between parents and subsidiaries, and other matters that frankly it has neither the time nor the competence to assess. As a result, the regulatory process is bogging down, it is this fact alone that leads to many arbitrary decisions such as a growing trend to cutback rate increase applications automatically. This is not based on any particular analysis but simply a ‘quick and dirty’ approach that gives the appearance that the CRTC is serving the public interest. Until this basic problem is resolved, an appeal process would only complicate the matter, i.e. one cannot appeal 4,000 decisions to the courts or anywhere else. If there is to be an appeal against the process it must be made at the political level. It is the approach to regulation that must be corrected. Back to Section I Index or just read on  THE ONTARIO MINISTRY OF TRANSPORTATION AND COMMUNICATIONS PLANNING CONFERENCEGEORGIAN COLLEGE. AUGUST 19, 1985The planning conference organizers have already demonstrated that the Ontario ministry of transportation and communications is not afraid of taking risks. Otherwise they would never have invited someone from British Columbia to talk to the conference. We westerners never miss an opportunity to tell those in the east what they should be doing! However, luckily enough the risk is not that high, I am a Torontonian by birth, lived in Ottawa for a number of years if that is considered part of Ontario, and have been out of the province long enough to not really know what the ministry is doing in any case. My observations, therefore, should be reasonably objective. I was specifically asked to briefly address five topics in the telecommunications field. Given the time available, I can only raise a number of points on each and then open up the topic for discussion. WHAT KEY ISSUES AND EVENTS DO YOU FORESEE IN THE NEXT FEW YEARS IN TELECOMMUNICATIONS? Your first question is very wide ranging. To narrow the field quickly I will use the major issues outlined in the McPhail's examination of Canada’s telecommunications future called, "Telecom 2000". However, I will add an extra topic they did not address. 1. Technology: The McPhail’s concluded and I concur that the rapidly changing technology will drive the development of telecommunications industry more than any other single factor. This acknowledged rapid change introduces a high level of risk into this industry. With a small local market, making investments in such a field is particularly tricky for Canada. However, it can be done very successfully. I would point to companies such as Ericsson in Sweden, and moiré in Finland, as examples of companies with worldwide reputations and populations 1/4 that of Canada. Northern Telecom is a good example of a Canadian company that has managed to live with the risk of rapid technological change. While this risk can be managed and turned into profitable opportunities, it is by and large not a risk for small companies. The Canadian high tech scene is strewn with the bodies of 'one product' companies. A good idea is under financed. There is too little money for R&D for follow on products. The original product is poorly marketed. The result is a three year wonder. I was a federal government appointee to the board of Consolidated Computer. This organization is only too well known to the Ontario government. Leaving aside the capital involvement of the government which I will return to, this was a prime example of a one product company, too small and without the diversification to really survive. Cantel is not in the manufacturing business, but we hope that we are avoiding the one service approach. We do not define ourselves as being in the cellular mobile telephone business. We even took that term out of our name. We consider that we are in the personal communications business and view cellular only as a place to start. If we do the right things in establishing ourselves as a marketing organization then we would be just as able to market the services of msat, paging, voice messaging, or other services as we are the traditional cellular product, (can you have a traditional product that is only a couple of years old?). In terms of dealing with technological risk in Canada, I would suggest that the approach we have fostered with Ericsson and Novatel is worth examining. Here we encouraged a Canadian company to make agreements with a multi national that involved use of the Canadian design to be marketed by the multi national, manufacturing in Canada and the commitment by Ericsson to do research and development in Canada for all its north American cellular requirements. 2. Marketing: This is a key issue I rank only slightly behind the technology. It is clearly the weakness of most high tech companies. In the past, it has also been a problem with government funding which often has been tied to hardware R&D or page even plant capacity but with little emphasis on funding for market surveys or market development. As I will note later, such direct government funding is questionable in any case but particularly when it excludes one of the most important areas for a company. Canada seems to set up companies that are technology driven rather than market driven. The Telidon debacle is a good example of this. I have been just as guilty, as I was one of the early proponents of the wired city. This was a good example of a technology for which there was really no market demand and, to a large degree, that demand is still not there. We must be realistic that marketing from a Canadian base is impeded by our small local market, our high labour cost, and in some parts of the country, our uncertain labour economy, and some suspicion overseas about Canadian firms' ability to sustain themselves and grow into major corporations. Mitel is a good example of this. 3. Capital: This was not included by the McPhail’s, but is clearly on the critical path. I am amazed at the jittery nature of many Canadian investors. They will take chances on Canadian penny mining stocks with virtually no analysis and yet will analyse to death a potential Canadian high tech investment. We have recently gone through the experience of trying to place a small amount of Cantel equity with a few private investors beyond the original partners. While I have no doubt this will be done (or the original partners will take up the equity gladly themselves), I was amazed to see the reaction of the investors to every article in the New York Times and the Wall Street Journal. A few years ago, it seemed easier when I was able to raise $17.5 million to start S.D.L. in Ottawa and the issue was wildly over-subscribed. I have a concern, which may sound like a comment more suited to an N.D.P. supporter, that much of the capital in this country is being taken up by major mergers and takeovers. While some of the money may filter back down to entrepreneurial activities, much of it is tied up in interest payments for large borrowings to finance such transactions. I have reservations about whether this is in the best long run interest of this country. I welcome Michael Wilson’s proposal about a $500,000 dollar exemption from capital gains tax, but have already written him noting that this will have less effect on the Canadian economy than it might otherwise have, because it is not restricted to investments in new Canadian corporations. Again, going back to my consolidated computer experience, my reaction is that direct government investment is not the answer. Government usually makes a poor shareholder. However well meaning the attempt may be, governments just do not make economic decisions when they see a situation going the wrong way. Tax incentives and other approaches are much better. 4. Regulation The model here should be Japan Inc. The Japanese view the role of government as one of promoting rather than regulating industry. Canada has had a sad history of stifling innovative activity. As Ted Rogers would point out, we had to wait years after the United States entry into black and white television, then colour television, then pay TV., and as a result lost the opportunity to become world class entrants in these fields. In 1973 S.D.L. acquired Ottawa cablevision ltd. With a view to putting the two organizations together to develop wired city concepts in Canada. After some consideration, the C.R.T.C. denied the takeover on the grounds that such a combination of cable and computers was 'premature'. Over 12 years later, still virtually nothing has happened in this field. Canada is very prone to what I often call preemptive regulation. Many in government are so influenced by minority pressure groups or are so afraid of making a mistake that they regulate a business out of existence before even it can get started. I watch, for example, with increasing dismay the concern over privacy of the individual and the use of computer data banks. I remember explaining to an international conference that all one had to do was to look at my American Express file to find out almost anything they wanted to about my living habits. However, if anyone asked me whether I would give up my American Express card because of a potential problem with having this data available somewhere, my answer would be clearly 'no'. There are much better ways of protecting the public without throwing up so many regulations that a business is discouraged from getting off the ground. I might add that I believe the launch of cellular telephone service in this country is an example of how to go at starting a new business with the right co-operative attitude between the government and industry. However, if I do not get on to the next question, you will have no time for questions. WHAT RELATIONSHIPS DO YOU SEE BETWEEN DEVELOPMENTS IN TECHNOLOGY THE MARKET PLACE, POLICY AND REGULATION IN THIS FIELD? I have covered some of these thoughts already but would add that while I am not in favour of massive corporations in Canada for the capital concentration reasons already mentioned, I am a believer in consortia as an approach for effective development of new markets. This is somewhat coloured by my own recent experience of heading the consortium of first city, Telemedia, Rogers and Ameritech to operate the Cantel cellular radio system. Again, the consortium approach is one used often in Japan. I can see many advantages for example to a consortium for launching a new product comprised of: • a marketing company, e.g. Xerox. • a bank • an engineering and/or manufacturing company • an export development company • the new tech company with the new product. I also like the idea of universities being partners in this process, just to throw out a topic, we may wish to discuss. While I was chairman of the board of governors at Carleton University, I promoted their staff getting involved in entrepreneurial activities. My reasons were: • I was concerned about the lack of entrepreneurial thrust in the teaching at Canadian universities. • I believe there is too little in the way of co-op programs such as that at the university of waterloo. • I could see the then forthcoming financial crisis in the universities and was concerned that they would lose staff if they could not pay them adequately. Outside consulting work would solve some of this problem. • I also believe the outside contact with business would help keep the teaching staff in touch with the real world. WHAT OR WHO WILL BE THE MAJOR FORCES EFFECTING CHANGE? I will mention only one. This is the necessity of Canada continuing to develop foreign markets. In the telecommunications area. There is an immense demand for approved services in developing countries. In the case of cellular, for example, it will likely make little sense for many developing countries to hardwire when new satellite or cellular techniques are available. The problem facing Canada will be to turn this demand into 'affordable demand'. I emphasize that we tend to think of exports only in terms of products, with the many good graduates being turned out of Canadian universities, we also should be able to export management expertise. For example, it is Cantel’s hope that once we have established our credibility as a personal communications service provider, we should be able to work with manufacturers around the world as part of consortia to set up such systems elsewhere and earn dollars for Canada. WHAT DIRECTIONS DO YOU SEE COMPANY, GOVERNMENT AND REGULATORY DECISIONS GOING IN? While I am optimistic on all fronts, I wish I could be as optimistic on this one. I am a believer in 'content analysis' as a way of projecting surprise-free scenarios. As you know content analysis suggests that you predict future behaviour on the basis of past behaviour, rather than current plans or election promises. Canada has had a tradition of tending to over regulate rather than promote its industries. Canada has also tended to confuse its objectives for industry with the Canadian content regulations for cable television being a prime example. I caution as well that the federal political organization of Canada has led to a regulatory situation in the telecommunications field that is almost unbelievable. While I realize that this may be a somewhat unpopular topic to raise with a provincial government, I am convinced that there must be only one national policy in telecommunications. It may, as has been suggested, be possible to have a joint regulatory body, but even here I believe this is more likely to be indecisive rather than the present situation which is merely inconsistent. HOW SHOULD THE ONTARIO GOVERNMENT BE RESPONDING TO THESE ISSUES AND EVENTS? LIGHTLY! The Ontario government could undoubtedly be helpful by bringing people together with a common interest with the aim of developing new economic opportunities and export. They could certainly be helpful with idea exchange. I am really concerned, however, when I see conclusions such as that in the telecom 2000 document which states: "the above national framework should be accomplished by joint and cooperative federal - provincial regulatory authority created for two purposes: I) to effect an orderly change in the Canadian telecommuications industry; and, II) to determine and ensure national Canadian public policy objectives such as; sovereignty, privacy, universal access, regional development goals, and economic opportunities in the high technology sector." Nowhere in this, is there mention of creating a successful business which is the only way to achieve the other objectives. SUMMARY: I am convinced that we can do as good a job in the telecommunications industry as the fins, the Swedes, or the South Koreans. Northern telecom has shown that this is possible. Government promotion rather than regulation can help this happen. Let's get out and do it. Back to Section I Index or just read on  CANADIAN COMMUNICATIONS LAW AND POLICY CONFERENCECOMPETITION IN TELECOMMUNICATIONS IN CANADA - A CASE STUDYOSGOODE HALL, TORONTO. MARCH 25, 1988There are limited examples where a reasonably free market situation has been allowed to exist in the telecommunications industry in Canada. As cellular is one of these it forms a case study in which we can examine the benefits and problems. During the late 70's and early 80's there has been a worldwide trend to increasing competition in the telecommunications industry. Based on the well known landmark decisions in the United States, interconnect of non telephone company devices has been grudgingly allowed but is now a maturing business. An even greater impact has come from the competition for Message Toll Service (MTS) in the United States and an increasing competition in the local loop alternative such as the non-switched direct access approach to provide private access to major buildings with the long distance being carried by carriers such as MCI or Sprint. There has even been limited competition with switched service built around the same principle of putting in a local service fibre loop plus a switch which in turn interfaces with one of the non telco MTS carriers. Cellular, however, provides the most obvious direct competitive model. Most governments, e.g. U.K., U.S. and Canada did not feel that providing competition to the current telephone system by allowing another organization to put copper pairs up and down streets was the answer. Instead they waited for new technology to provide this new form of local loop. In each country the decision was made to license one or more new companies to split the frequencies for cellular telephone technology with the existing telephone company. This creation of what were clearly new telephone companies was naturally greeted with some reservation by the existing organizations. The thought of competition when one had enjoyed a monopoly for 80 - 100 years was naturally a concern. Some telephone companies in Canada reacted reasonably well and took the approach that "success is capitalizing on the inevitable". In this regard, Bell Canada is to be complimented for viewing Cantel as a customer as well as a competitor. Some other companies have reacted with genuine alarm or have not reacted at all hoping this new telephone company would simply go away. The purpose of this case study is to point out that after about two and a half years of operation, there can now be no reasonable doubt that allowing competition has benefited all parties in Canada. The process has clearly benefited the public as would be expected but also the wireline telephone companies and hence the telecommunications industry as a whole. I hope that the cellular example will form a role model for the type of competition that does benefit all parties. SOME BACKGROUND In looking at the type of competition that would most benefit Canada, the Department of Communications made a wise decision in the fall of 1983. This was to license a single national company to compete against the regional telephone companies. This was unlike the cellular approach in the United States where the awards were made for individual Metropolitan Areas. In the United States the awarding of cellular franchises became so difficult that a lottery system was finally set up. This led to hundreds of bids coming in by organizations totally incapable of establishing a proper cellular operation. This in turn led to what effectively became trafficking in licences. By contrast, the Canadian model allowed one company to be strong enough to effectively compete with the wireline companies and also to follow the traditional telecommunications industry approach of allowing the Major Metropolitan Areas to subsidize the less densely populated areas. After Cantel received the national cellular telephone mandate in December, 1983 the Minister of Communications and the CRTC followed this with a series of Decisions that assisted in creating a sensible competitive environment for cellular. On March 14, 1984 the Minister announced the six months' rule which stated that neither the wireline telephone company nor Cantel could start in an area until a suitable interconnect agreement had been signed between the two organizations. This avoided the difficult head start situation experienced in the United States. In CRTC Decision 84-10, Cantel was declared a company under the Railway Act, e.g. a telephone company, cellular service was declared to be in the public interest and hence interconnect was required for federally regulated wireline companies and finally Cantel was given the right to carry its own MTS traffic. I suspect that the wireline telephone companies did not take Cantel very seriously at first. However, as the initial start date of July 1, 1985 neared, it was obvious to all that a truly competitive situation was developing. Because of this, the CRTC created a state of regulatory forebearance, i.e. while retaining its ultimate right to regulate the price charged to the public, the Commission concluded that price regulation was not necessary at this time because of the developing competitive market place. This has turned out to be a very accurate assessment. DEVELOPMENTS SINCE JULY 1, 1985 Despite the worst fears of the wireline companies, competition has worked to everyone's benefit. Sales of cellular units have far exceeded either the wireline companies' or Cantel's expectations. There are now about 125,000 cellular telephones in Canada split more or less evenly between the wireline companies and Cantel although wearing my salesman's hat, I would have to point out that there is a slight edge in Cantel's favour. Much of this development took place because of the equal start in each market and the resultant intense selling effort as two companies vied to gain the public's attention for this new service. I believe even the telephone companies would now admit that the market would be a fraction of its current size without the competitive stimulus that the companies provide to each other. Of more importance, however, in examining the benefits of competition, one should consider: • the wide range of innovative packaging of phones and usage now available to consumers; • the very wide coverage provided which is far better in many cases than that provided in the United States. Cantel alone now serves 24 centres in Canada and corridors that would not be covered had there not been the competitive situation; • new developments are in place that were brought about by the competitive atmosphere including offerings that are not available elsewhere such as those of the Mobile Office with fax machines, lap-top computers, voice messaging and a range of other services. But the benefits go beyond just the consumers. Canada as a whole has benefited greatly from this competitive environment: • the investment in plant and equipment alone exceeds $300 million to date and is growing very rapidly; • in Cantel's case, we have created over 400 direct jobs and another 800 through our Cantel ServiceCentres. I assume the employment created by the wireline telephone companies is somewhat the same; • the purchases of equipment have been largely from Canadian suppliers with the multiplier effect this has on the economy; • additional research and development is taking place in Canada that would never have been considered without a competing new telephone company. Cantel uses Ericsson equipment and was one of the earliest users of Ericsson cellular systems in North America. As a result, Ericsson has established a major R&D centre in Montreal carrying out a good part of its cellular software research for North America. It has also moved its national maintenance operations for North America to Montreal; • perhaps the most important advantage for Canada has been the productivity improvement for other industries through the wider use of cellular telephones resulting from the active promotion by two companies in each market place. This in turn can be an attractive factor for new industries to move into areas where cellular service is available. The result has been that competition has led to a major Canadian success story. THE SITUATION IN 1988 However, old attitudes die hard. In a federally regulated jurisdiction, a good standard has been set for fair competition. In the other provinces arriving at comparable interconnection arrangements has not been easy. The patchwork quilt of regulation in telecommunications in Canada has left the federal government relatively impotent in those provinces. While the DOC has granted the frequencies to Cantel on a national basis and has even laid the requirements on Cantel to serve areas, neither the DOC or the CRTC can directly require the provinces to provide Cantel with the same facilities as it has under CRTC 84-10. The result has been an inconsistent competitive situation which will ultimately reflect in lower levels of service to Canadians in some provinces than in others. A simple example is the ability of Cantel to carry its own MTS. It is this ability which subsidizes the cost of expanding Cantel's own microwave network to serve less densely populated areas. Without this contribution, these areas will be served more slowly if at all. In varying degrees, Cantel is restricted from this in several of the provinces not regulated by the federal government. In a more general way, Cantel is still not accepted as an equal competitor by any of the telephone companies; • it has been very difficult to get multiple interconnection points ensuring that Cantel would have redundant paths in its network. No wireline telephone company would design its own network in this fashion; • although in the United States cellular telephone companies are recognized as being full telephone companies and therefore have the right to their own phone numbers without ongoing payments to anyone else, this has not been the case in Canada; • in non federally regulated areas, Cantel finds itself competing against a division of the telephone company rather than a fully arms length subsidiary; • the arrangements for interconnect and the attendant costs are quite different from those of other smaller regional telephone companies. SUMMARY Despite the fact that it is still far from a level playing field across Canada, the benefits of competition cannot now be denied. Cantel is already a responsible member of the telecom community contributing significantly to the services available in this country. This is the type of competition that the DOC and CRTC envisaged when they established the rules for competition in cellular in Canada. The next step is to recognize the benefits that have accrued to the industry, the public and the country at large and to accept Cantel as a full fledged member of the telecom industry. The model works. The final artificial constraints should be removed to allow the process to continue to provide the kinds of benefits to Canada that are there for all to see. Then this case study will be an even better model for ensuring that competition brings the benefits everyone hoped it would. |
