[last updated April 30, 2021]

Did the CRTC mandate MVNOs in Canada?

No. The latest CRTC policy requires dominant wireless networks (Rogers, Bell, Telus, Sasktel) to give wholesale access to regional wireless networks (Shaw, Videotron, Eastlink), but only where they already have spectrum licenses and are planning to build more networks.

The “V” in MVNO is for “Virtual”, and there’s nothing virtual about an existing mobile network provider with towers and spectrum licenses. There’s nothing virtual about needing to build more towers after 7 years.

The good news is that these regional providers are allowed to resell their wholesale access to true MVNOs like dotmobile.

What does this mean for dotmobile?

Wholesale access to national networks can happen one of two ways.

• The first way is through an agreement directly with Rogers, Bell or Telus. We’ve been working on this path for over two years and are still trying.
• The second path is through a regional provider, which is more complicated because it involves twice as many network providers that we need to work with.

The wild card is the announcement that Rogers has agreed to purchase Shaw. The CRTC policy did not consider this because it was announced after the public record closed. The whole industry will be impacted by what conditions are imposed on this transaction and the final fate of Freedom Mobile.

Will I still be able to get dotmobile where I live?

The sad truth is that some Canadians will have to wait longer for our service to be available where they live.

Wholesale access to national networks is only mandated where regional providers already licensed spectrum, which are the rights to broadcast wireless signals (kind of like an old-school radio station license).

This means that dotmobile will only be able to launch where these conditions are met, and Rogers buying Shaw only makes it more restrictive.

The CRTC policy is not for all Canadians, no matter where they are in Canada.

We still believe that everyone should get access to affordable and awesome wireless, no matter who they are or where they live. This policy means it will take us longer to bring dotmobile to every corner of the country.

Can you tell us how much data will cost?

The CRTC has given a 90-day deadline for Rogers, Bell, Telus and Sasktel to submit the wholesale rates that they’ve negotiated with regional providers.

Until then, we won’t have much visibility into how those rates might translate to a true MVNO like dotmobile.

The CRTC mandated new affordable and occasional use plans, which may serve as a basis for these negotiations, but there are also already mandated roaming rates between regionals and national carriers which could be the starting point.

TBD.

Why are you still offering SIM card pre-orders?

We are allowing members to pre-order the SIM card for free, which lets us know where in Canada our members are and which regions are most important for us to launch first.

Given the more complicated path through regionals and the requirements for spectrum licenses, this information is even more valuable now than ever.

Pre-ordering your SIM doesn’t cost anything, and it could help us negotiate for access where you live.

How do I pre-order a SIM card for free?

Pre-ordering a SIM card is a way to tell us where in Canada our service is needed the most.

Here’s how to let us know you want our service where you live:

1. Download the app and log in.
2. Go to the Marketplace using the store icon at the bottom of the screen.
3. Tap the SIM card and add it to your cart.
4. Go to your cart and enter promo code FREESIM get your SIM card for $0

Important

• We aren’t shipping SIM cards until the service enters Beta. This might not be until next year. We can’t say exactly when we’ll launch yet, but your pre-order helps our cause.
• When we do launch, you will have a chance to update your address before we ship anything, or you can switch to eSIM and activate it right away.
• If your needs have changed by the time we launch, or we aren’t a good fit for you, then you can cancel your order. You are not making any kind of commitment to pay for service or port your existing phone number to dotmobile.

What is next for dotmobile?

Negotiations with both national and regional providers are ongoing and we expect them to be slow. The initial feedback from regional providers is that this new CRTC policy doesn’t support their needs, or encourage them to aggressively expand into areas they were not already planning to.

We are also exploring legal and political channels to both

• challenge the new policy (CRTC 2021-130) based on the misalignment with the 2019 policy direction and their own definition of what an MVNO is, as well as
• ensure the Rogers acquisition of Shaw results in regulatory support for new types of competition, like Full MVNOs, instead of more doomed-to-fail, wait-another-decade, BlackBerry-Nortel-era, region-by-region, facilities-first policies.

Why is it so important to be a Full MVNO?

We’ve made an infographic that helps illustrate the difference between an MNO, a Full MVNO, and a Thin MVNO.

• MNOs own and operate everything, including the towers. They earn money off of every customer on their network, through direct retail sales or wholesale through MVNOs.
• Full MVNOs own and operate everything, except for the towers. They pay a wholesale rate to use the MNOs towers, and compete by innovate through both technology and pricing.
• Thin MVNOs & Branded Resellers don’t own or operate any network infrastructure. They mostly handle marketing, sales, billing and customer service and compete through pricing.

Being a Full MVNO makes sure that ‘towers’ (national network infrastructure) gets built and enough independence is ensured to innovate on the operations/service level. By owning and operating core network facilities (in our case, they are in the public-cloud), Full MVNOs have a much greater opportunity to build differentiated services and prices. This also gives the Full MVNO control over the operating costs and the ability to pass along any cost savings to their customers (aka differentiated business models). Finally, this is the least expensive and complex relationship for an MNO to maintain, about the same as it takes to allow roaming between networks.

A Thin MVNO has much less control and relies heavily on the MNO. They can’t control as many of their costs, and work mostly on optimizing sales and support. Until recently, this was the typical model for an MVNO and it works well in countries with more open telecom regulations than Canada. Now, the cost to deploy a core network and other facilities is much lower than even 5 or 10 years ago, making the Full MVNO business model more viable.

What can I do to support you?

First, take a read through the blog posts we’ve shared on our website.

Second, continue supporting us through marketplace purchases.

Third, write a brief letter to your Member of Parliament (MP) to express your concerns about the Canadian wireless industry and the latest CRTC policy. We have learned from NGOs and grassroots organizations that even a meager two emails with the same concern can get noticed.

HOW TO EMAIL YOUR MP:

1. Go to the Parliament of Canada website (https://www.ourcommons.ca/members/en) and type in your postal code to find your MP.
2. Click or tap on your MP, then select the “Contact” tab on their profile.
3. Click their email address to open your email client, or copy and paste it.
4. Compose a message that reflects your views on affordable wireless connectivity.
5. Send!

THOUGHT STARTERS
We don’t want to write the email for you, but here are a few things you might want your MP to fight for on your behalf. (Even if you didn’t vote for them, they represent you!)

• International experts agree that affordable access to mobile data has a positive influence on a nation’s economy. Without it, innovation and adoption of new technologies are stifled and economic divides grow larger.
  • Why do people using basic wireless service pay 10 times for data than top tier users?
  • Why are seniors, youth, new Canadians, and families that want to save deprived of affordable options and purpose-built services? Who really benefits from this?
• Mobile network operators around the world remain profitable and continue to invest in their networks, even with multiple MVNOs using their network. Wholesale is an essential part of the telecommunications business where true infrastructure competition exists.
• The CRTC agrees that the dominant carriers (Rogers, Bell, Telus) are making too much money off of Canadians, thanks in part to decades of favourable and protectionist regulations. It’s not because Canada is a unique snowflake and it’s more expensive to build networks here than anywhere else in the world.
  • CRTC 2021-130 Paragraph 140: “High profit levels, even accounting for the large investments made by the national wireless carriers and by SaskTel, in addition to their high and stable market shares over the last five years, also point to a lack of rivalrous behaviour in Canada.”
  • CRTC 2021-130 Paragraph 151: “(...) market share is highly concentrated between the national wireless carriers. Furthermore, prices and profits are high and not fully accounted for by way of investments made in networks.”
• The latest CRTC policy does not encourage investment in research and development or other intangible assets. It only encourages investment in facilities, primarily new and expanded radio access networks. This approach has not reached all of Canada after 10 years.
  • In 10 more years, how bad will high telecom prices and a greater digital divide impact the economy?
  • Will rural Canada be excluded from the digital economy and new innovations, despite the pandemic proving that remote workforces are possible?
• The CRTC announced to the world that they had mandated MVNO access to dominant, national networks by giving access to regional providers only where they already own spectrum but don't yet have towers. This is contradictory to their definition of an MVNO.
  • "An MVNO is a wireless service provider that does not own spectrum or operate its own radio access network (RAN); instead, it relies on the spectrum and RAN of a wireless carrier and, in some cases, other facilities and/or services, to provide mobile wireless services to consumers. MVNOs encompass a variety of service-based providers that rely on wholesale services to varying degrees to support their retail businesses."