To: The Secretary General
CRTC, Ottawa, K1A 0N2
From: Telecommunities Canada
Per: Garth Graham, Director for Research
Telecommunities Canada Board
Box 86, Ashton, Ontario, K0A 1B0
Tel: 613-253-3497
September 30, 1998
Subject: Telecommunities Canada's response to the Commission's call under Telecom Public Notice CRTC 98-20, and CRTC Broadcasting Public Notice 1998-82, for comment on the range of communications services collectively known as new media
1. Telecommunities Canada has made two previous interventions to the CRTC, both including statements on the purpose and practices of community networking similar to those outlined here:
* Telecom Public Notice CRTC 95-44: Tariffs for Educational and Health Service Entities; Comments from Telecommunities Canada, February 21, 1996.
* A domain where thought is free to roam: the social purpose of community networks, (Background paper supporting Telecommunities Canada's appearance, March 29 1995, at the CRTC public hearings on information highway convergence). Telecommunities Canada, March 29, 1995.
2. The direct experience of digital communications and its impact on social processes that we have attempted to convey has been difficult to fit with the constraints of the Commission's regulatory mandate as it has interpreted it. The Commission's intention to consider defining new media in the context of the Internet makes necessary a re-visiting of issues we had previously raised. We would welcome an opportunity to explore these issues further.
3. Telecommunities Canada is the national voice for community networks. Community networks are grassroots organizations. Starting in 1992, they began assisting ordinary citizens to encounter the Internet as a factor in their daily life, well before business and government in Canada began to consider its socio-economic impact. Their continuing growth and utility depends on sustaining self-organized local initiatives. Right from the beginning, community networks were concerned, correctly, to retain the local autonomy that defines their essence and makes them both useful and ultimately sustainable.
4. As a consequence, Telecommunities Canada is an association of associations. The member associations of TC have consistently expressed the need for a national capacity, not to provide centralized services "to" community networks, but to share experiences and resources "among" community networks. TC does not 'represent" the collective interests of members, it expresses them. In other words, Telecommunities Canada's primary role is to find the means of rendering local learning into a common national knowledge base that is generally accessible to anyone who might want to use it. It can only do this by behaving as a community of community networks - by mirroring at the national level what many community nets are already doing very well to create accessible online social networks at the local level. We have a long way to go in achieving this goal.
5. Telecommunities Canada connects Canadian electronic community networking organizations that:
- operate on a not-for-profit basis;
- open their membership to every citizen of their community;
- provide equitable access to all citizens in their community;
- encourage exchange, publication and access to the broadest possible range of information of interest to the community; and
- endeavour to create connections with other computer-based networks, and to allow the free and interactive flow of information between different communities.
6. Community networks are known by many other names, including Freenets, CivicNets, Community Information Systems, Public Access Centres, and Online Communities. They share a broad-based focus on serving the communications and information needs of both communities of affinity and locality. They encompass the description of needs within the metaphor of an online community "space" within an "electronic commons."They emphasize the role of their members as citizens of that electronic public space, and encourage dialogue and interaction among those citizens by offering them equal access to a common and convenient medium of computer-mediated interactive communication. Canadian "information highway" policy does not seem to apprehend the reality of that electronic public space.
7. Telecommunities Canada defines a community network as the capacity that a community has to learn from new modes of communications and to apply that learning to its own ends. That's a learning and a process definition, not a services definition. Some level of that capacity is going to be present in any living community. Powerful means of sustaining it can be achieved through the reallocation of existing resources and priorities. The problem is consciousness of the need to do this, not money. In fact, communities that organize to achieve interdependent action within the framework of something like that definition usually succeed in negotiating access to actual communications technologies and services at far less costs than those that don't.
8. This definition makes community networking an essential means of ensuring that the privatization of electronic public space does not enclose the possibility of achieving the "interconnected and interoperable network of networks," stated as a principle in the Order in Council P.C. 1994-1689 on information highway strategy. The Internet protocol of open and distributed systems is the model for the social networks that community networks support.
9. The use of the spaces in a community network to transact communications is not inherently consumption of services. In essence, defining new media as services blocks perception of how much the technologies of electronic networking structure human connection in a knowledge based society and economy. If the public interest necessitates regulation of new media as only commercial products and services, this creates a problem. New media is just as much a tool for private interpersonal communication as it is for the creation of "content" for profit. How to draw a line between the two "outputs," it is far from clear. Regulation could inappropriately intrude into the "content" of personal communication.
10. In spite of stating that it has no views on how new media should be defined, the Commission has assumed that new media are inherently "content," services, or "cultural products" intended for consumption. This assumption clearly structures the nature of the questions about new media that the Commission has asked. Bits are bits. To pluralize "media" is to obscure the significance of a new "medium" of communication. For example, the receiver of a communication has an enormous range of choice about its actualization as an object. Given full convergence, it may no longer make sense to base regulatory categories by technology of transport (broadcast, telecommunications, print, etc) or output (book, video, email, etc). The assumption of new media as services constrains the Commission's framework for defining the public interest and thus the need for regulation. We are pointing to categories of use that impact on the motive for networked connection at both the sender's and the receiver's end - personal, public, and commercial,etc. The assumption of new media as services constrains the Commission's framework for defining the public interest and thus the need for regulation. We also encourage the Commission to consider a broad definition of the context in which new media operates.
11. There is clearly a need to consider regulation (or Internet Governance?) in a broader framework. From our perspective, what you have called "new media" is, in the context of the Internet, actually a "surround" or transaction space in which many of the significant social and economic network encounters of daily living occur. Community networks are entirely creatures of that space. We would be uncomfortable if your final definition left a community network's online presence defined in its entirety as a new media product. From a public interest point of view, the most significant national policy issue is the degree to which this electronic transaction space is public or private.
12. So far, Industry Canada's "Information Highway" policies and programs and "Connecting Canada Initiative" assume that it is private. Therefore, since access is defined by price, it's safe to leave regulation of acceptable corporate behaviour in electronic public space to the market. The Commission appears to be following Industry Canada's lead when it suggests that "all services found on the Internet could be considered a form of new media." (para 7). We assume that all of electronic public space begins as public and that some of it, like spectrum, can be assigned for private use. In effect, information highways cross public ground. The terms on which they appropriate it for private use are a legitimate concern for some public form of governance. Why is the Government of Canada abandoning a responsibility that is clearly a central function of governance in its most basic sense?
13. People need to connect, with as little control and interference as possible. The existence of a viable structure of community networks across Canada provides a guarantee of affordable access to some means of open networking that is citizen controlled.
14. Community nets are not inherently content providers. Their purpose is to defend universal participation in, and access to, electronic public space. Electronic public space is a commons.
The community itself is the network. It supplies the content as a byproduct of its communications behaviours in electronic public space. In defense of the public good, both the Telecommunications Act and the Broadcast Act assume that traditional media operate in a commons. Why are we abandoning this assumption in the adaption of public policy to the realities of a "connected" Canada?
15. Community Nets are a means of community participation in the design and evolution of the Internet as a new zone of socialization and learning. The Net (it's existence) makes social systems (the zones of socialization) into learning systems in a different way. Communities must have a say in how that learning occurs. They must experience it directly through participation in the design of the process. The strength of community is grounded in autonomy and self determination. Externally imposed communications systems can sever that link.
Whenever a sense of control in self-definition of community is lost, the impact of "connecting" Canada will be its opposite - increased social isolation. Canada, as a Knowledge Society, needs community networks in order to learn its way towards social integration in a context that is changing beyond recognition.
16. Telecommunities Canada emphasizes community-centered approaches that recognize the second level of access, the social participation level, is absent from federal information highway policy discussions.
17. We'd prefer to leave for "netiquette" the things that netiquette does best. However, netiquette does not always shelter online community life from the vagaries of humanity All community networks have variations of Acceptable Use Policies, and hard-won experience in operationally applying them. These are similar to the one the CRTC itself is using for its new media discussions on the McLuhan Program web site. There has been no adequate national synthesis of the lessons flowing from that experience. Even if that experience could be effectively communicated, we are unaware of an open public policy forum that would be interested in it.
18. The impression of conflict given by accounts of life online in traditional print journalism is completely at odds with the daily experience of hundreds of community networks. There is no reasoned public counter-balance to journalistic attempts to foster a climate of fear. We are very uncomfortable about taking the slippery slope towards externally imposed regulation and law (statutory instruments) of the Internet in a political climate that is being negatively polarized.
19. For purposes of liability, community networks are often inappropriately lumped in with Internet Service providers. The question of board directors' potential criminal and civil liability arising from material in newsgroup and listserve postings is taken very seriously by community network associations, and is potentially an inhibiting factor in the development and growth of voluntary community networking. Most community networks do not have the resources to withstand a legal attack. (See for example the report on personal and ISP liability at
20. Spam is considered piracy of a community networks's limited resources and includes things like:
* unsolicited bulk and/or commercial e-mail
* excessively cross-posted newsgroup postings
* excessively multi-posted newsgroup postings
* unauthorized and/or unwarranted article cancellations
21. The volume of spam is enormous. Community networks have long practical experience in tracking and fighting it, and will be happy to assist those requesting help. They fight Internet abuse in both newsgroups and e-mail through the application of spam-fighting tools, practical advice, online newsgroup discussion, and the blocking or banning of sites and accounts from the system.
22. In part as fallout from the privatization of the Internet backbone in Canada, there are a number of discussions underway regarding Internet "governance" issues. Providers of Internet services see these as issues of IP addresses, domain name management, and procedures for the operation of the routing system. At the national level, the public interest and the broader community of use is completely absent from these discussions.
23. The sectoral and vertically organized "stovepipes" of community-based services are beginning to break down in the face of local networks that facilitate horizontal connections. As this happens, cooperative approaches are beginning to emerge that will take advantage of deregulation to negotiate reduced bandwidth costs. As horizontal integration and falling bandwidth costs converge and deregulation progresses, communication carriers will change from selling circuits to selling capacity and bandwidth. As the reliance of community-based services on shared networks increases, it is reasonable to expect that their actual costs for connectivity can go down. Financially, community Networks live or die by the price of connectivity. To what degree might inappropriate regulatory interventions for content purposes strangle "open systems" and slow down the rapid descent of bandwidth costs?
24. Electronic public space is a commons. Social behaviour in public space is, of course, circumscribed by convention and by law. But, when everyone has a right to be there, we must expect that almost anyone, including people we might prefer not to encounter, may be there But preoccupation with the question of when offensive communication becomes illegal communication pre-empts a more important issue - are the existing safeguards for freedom of expression adequate? Freedom of expression is a fragile flower that can be destroyed by regulation imposed for the sake of avoiding the potentially offensive.
25. Increasingly, there are software filters and blockers that can, if felt necessary in controversial areas, be imposed. It is very important not to inadvertently become that which you oppose. The real success of the Internet is that it allows anyone any time to bypass gatekeepers in a completely different way than any other "tool" we've ever invented. Sustaining that success requires a huge sensitivity to ensuring we don't re-invent the gatekeepers by another means.
26. Government services don't like unbounded online discussions. Newsgroups, chat rooms and listserves are not that amenable to political manipulation through public relations methods. Some public servants express a concern to control content of online conversations about electronic government services delivery, just as if democracy was too much of a nuisance. But what they view as an impediment to efficient administration is an asset for informing citizen participation and engagement. Online discussion can reveal intentions and thereby establish an improved basis for accountability.
27. In a social sense, Canada is a network of people, just as, at the local level, a community is a network of people. As a tool, the Net is an extension of social networking by electronic means. Electronic community networking associations help Canadians achieve this externalization of social networking by:
- acting as the community-based component of universal access to full digital networking services and capacity,
- helping people to learn what full digital networking services actually are, and to use that experience to make informed decisions about the design and development of a national Net in a period of rapid change,
- allowing people, regardless of location, to interact as neighbours,
- allowing small businesses to thrive where they are located, by altering the relation of location to profitability,
- balancing the advantages that local infrastructures have in competition with global infrastructures.
28. We have actively participated in dialogue among public interest organizations about the development of a "National Universal Access Strategy." As a result of this participation, we remain concerned about the possibility of a universal access strategy continuing to undervalue the critical experience that Canada is gaining from its growing grassroots community networking movement. Community Networks are profoundly aware that the way in which a National Universal Access Strategy evolves will directly affect the climate for their future success and development.
29. Consequently, Telecommunities Canada's position on universal access begins by emphasizing how electronic community networks augment the means available to communities to participate in (or "control") the socio-economic and political restructuring that affects them. Community networks assist communities in retaining their autonomy to self determine their own interests, issues and boundaries. In effect, they are a powerful means for a community to know, to express, and to negotiate something significant about the fundamental development (and political) question of who benefits and who pays. There are three components to our model of community networks:
1. The community is the network, not the technology
2. The realization of the community's social interactions is moving online.
3. A community's survival depends on controlling the means to capture the experience of realizing community online and turn it into practice. Unless there's a conscious community networking process in place at the local level, the community lacks the means of capturing what's going on and applying it to its own interests.
30. That's the true role and purpose of community networks. They help the community apply what it is learning about the transition to ever greater degrees of electronically networked social interaction. They help the community defend the electronic public space that is essential to defining its own boundary and identity. They allow for the process of realizing community online to enhance civic engagement.
31. Federal "information highway" policy is determined by technology as an end in itself, not by its uses. The problem is not so much whether the Commission should regulate new media, but rather the complete absence of a federal government anticipatory capacity to formulate a comprehensive approach to public policy based on the uses of technology. There is no proper context in which any federal agency's regulatory role can be defined.
32. The critical functional capacity of a knowledge society is learning, not services. First comes open access to electronic public space. Then comes access to "distribution channels." Connecting Canada in the sense of implementing advanced communications technologies is not enough. Technology alone will not ensure that all Canadians fully benefit from social, economic and political participation in a more networked (i.e."connected") society.
33. From our participation in national discussions of the public interest dimensions of universal access strategy, we know that there is no one agency in the federal government established to deal with issues of governance and the public good inherent in the carriage and expression of digital communications. There is, however, a variety of departmental initiatives rushing to fill a policy vacuum. There is also a huge range of Internet-based applications that grow from within and that, in the process, alter the relationship of programs to citizens. Decision-making levels of government are not necessarily alert to the degree of restructuring that government services have already experienced.
34. Canadians need to know that the growing networking capacity is accessible to all and produces equitable social benefits. And they need to be able to adopt an advocacy stance quickly when it doesn't. They need to be able to make informed choices during a period of rapid social and economic change. Implementing a true national universal access strategy therefore requires a publicly accountable agency that does not merely regulate or give advice, but can act in the context of open and distributed systems. So far, Canada lacks key consultative mechanisms for achieving a new balance, a broader vision than the market dominated vision.
35. There is a national necessity to foster informed and accessible dialogue about socio-economic impact. Perhaps CRTC could become a component of a federal capacity to respond to the adaptive pressures that transition to a knowledge society make necessary. But not if its legislative mandate remains constrained by the Broadcast Act and the Telecommunications Act, neither of which anticipates digital communications convergence, Internet protocol, electronic public space, or the realization of community online.
36. In the middle of Canadian society and its institutions, there are committed groups of social change agents who do perceive the crisis in terms of adapting to its future unintended consequences. The members of the grassroots community networking movement are examples of this. These groups act, applying what they know about the Internet and open distributed systems as social systems, in community development and institutional restructuring.
37. We believe that, on its own, a purely market approach destroys civic engagement. The purely economic approach isolates people by separating them into service providers and their clients, the very opposite of the sort of converging social connection that occurs in electronic networks. Because electronic networks mediate social networks (the determinants of basic human identity) in new and different ways, their impacts on peace, order and good government are multidimensional, not just economic.
38. The chief value of a network lies in the complexity of its connections. The more a network connects the more it can connect, and the greater its value to its participants. When networked individuals freely give out information (that is to say they utilize any form of electronically networked expression), they collectively get lots in return. The more they share what they know, the more they can know. That's the real source of knowledge in a "knowledge" society.
39. New ideas emerge more from unexpected places than they do from corporate organizations. And new ideas are coin of the realm in a political economy of knowledge. We believe that, without conscious efforts to sustain the autonomy of communities, the potential of a knowledge society cannot be realized. The viable "spaces" for individuals in community to self-define and grow, and therefore to innovate, cannot occur. Healthy online communities lead to higher levels of inclusive social integration, to greater social capital in complex social networks, to greater capacities to know, and therefore to higher
levels of innovation.
40. Ultimately then, access is about connecting and giving, not receiving. It's about the means we have available to each of us to express our ideas and to learn from the consequences of that expression. "Now we make our networks and our networks make us." (William J. Mitchell, City of bits: space, place and the infobahn, MIT Press, 1995, 49). The Internet is an extension of our minds into a shared working memory. The organization of a community network is the extension of the idea of community into that shared working memory. If a community does not bring the parts of its experience of social and institutional change together in a community network then it cannot do this.
41. Successful community networks are in fact quite conscious of their role in community learning. It makes sense to understand and disseminate the experiences of growing a locally controlled community network. Communities that can draw upon those skills and practices have a better way of facing the social changes that confront them in their transition to a knowledge society.
42. In the interest of achieving a broader policy framework, the CRTC should act to:
- Continuously address issues of convergence that transcend the limitations of its two Acts,
- Ensure that regulatory interventions for content purposes neither strangle "open systems" nor slow down the transition to bandwidth costing and bandwidth cost descent,
- Address Internet governance in a manner that asserts the public interest in electronic public space as a commons over the market's use of that commons, and,
- Acknowledge the role of community networks in providing a means for community control of community life online, the defense of citizen participation in the design of electronic public space, and as essential components of affordable access to the means of universal participation in the knowledge society.