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Telecom Public Notice CRTC 2003-8
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Ottawa, 23 October 2003 |
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Review of price floor safeguards for retail tariffed services
and related issues
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Reference: 8663-C12-200314600 and
8622-R4-200308115 |
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In this public notice, the Commission
invites comments on proposed interim modifications to the imputation
test and the service bundle pricing rules, as well as on the
introduction of a new interim pricing safeguard for volume and term
contracts for retail tariffed services. The Commission also invites
comments on what changes to these pricing safeguards may be appropriate
on a final basis. |
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Introduction
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1. |
Section 27 of the Telecommunications Act
(the Act) requires that rates for telecommunications services be "just
and reasonable" and prohibits unjust discrimination in "the provision of
a telecommunications service or the charging of a rate for it". In
addition, subsection 7(f) of the Act indicates that in the exercise of
its jurisdiction under the Act, the Commission should "foster increased
reliance on market forces for the provision of telecommunications
services". |
2. |
In order to implement these statutory
requirements, the Commission has developed a regulatory framework that
attempts to balance the interests of the three stakeholder groups:
customers, incumbent local exchange carriers (ILECs) and competitors.
That regulatory framework comprises a number of key mechanisms. |
3. |
The central regulatory mechanism applicable
to the large ILECs (i.e., Aliant Telecom Inc. (Aliant Telecom),
Bell Canada, MTS Communications Inc. (MTS), Saskatchewan
Telecommunications (SaskTel), TELUS Communications Inc. (TCI), TELUS
Communications (Québec) Inc. (TELUS Québec) and Société en commandite
Télébec (Télébec); collectively, the large ILECs) is a price regulation
regime which groups ILEC services into service baskets and establishes
pricing constraints at the basket, sub-basket and rate element levels.
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4. |
This combination of service grouping and
upward pricing constraints ensures that the benefits of productivity
improvements are distributed amongst services and thereby balances the
interests of all three stakeholder groups. In particular, the basket and
rate element pricing constraints provide an upper bound on rates. The
grouping of services into baskets helps protect against unjust
discrimination between customers. |
5. |
While the price cap regime applicable to
the large ILECs provides a balanced framework to govern price increases
and distribute the benefit of productivity improvements, in order to
fully satisfy the statutory requirements identified above it is
necessary to also consider constraints on price decreases. |
6. |
A regulatory constraint on a price decrease
is a price floor. Price floors are required for three reasons: (a) to
ensure that the ILECs are not required to price below costs (unless
there is a policy reason for requiring such pricing and a mechanism is
available to compensate them for such a pricing requirement); (b) to
protect against unjust discrimination between customers; and (c) to
prevent anti-competitive pricing. |
7. |
The Commission first established a price
floor for certain retail tariffed services in Review of regulatory
framework – Targeted pricing, anti-competitive pricing and imputation
test for telephone company toll filings, Telecom Decision CRTC
94-13, 13 July 1994 (Decision
94-13). The price floor mechanism set out
in Decision 94-13 was applicable to interexchange voice services and
required that, in general, when proposing a new service or a price
reduction for an existing service, an ILEC would have to demonstrate
that the proposed rate for the service would be sufficient to recover
the service's costs, where those costs were defined as the Phase II
costs of the service plus an imputed contribution "cost". In light of
this latter cost component, the Decision
94-13 price floor mechanism was
referred to as the "imputation test". |
8. |
The primary purpose of the Decision
94-13
imputation test was to protect against anti-competitive pricing in the
interexchange voice market. As described below, in subsequent decisions
the Commission extended and modified the imputation test to make it
applicable to other tariffed services in other market segments,
including local exchange services: see Review of regulatory framework,
Telecom Decision CRTC 94-19, 16 September 1994 (Decision
94-19),
Local competition, Telecom Decision CRTC
97-8, 1 May 1997
(Decision 97-8), and Issues related to imputation test methodology –
Rebanding decision follow-up, Decision CRTC
2001-737, 29 November
2001 (Decision 2001-737). In its current form, the imputation test is
intended to protect against both anti-competitive pricing and unjust
discrimination between customers. |
9. |
In addition to the imputation test, which
applies to individual services, the Commission also developed a price
floor mechanism for service bundles that contain one or more tariffed
services. The service bundle pricing rules were first established in
Decision 94-19 and were subsequently modified and extended in a number
of later decisions, as described below. Once again, the purpose of the
service bundle pricing rules has been to protect against both
anti-competitive pricing and unjust discrimination between customers. |
10. |
The price cap regime applicable to the
large ILECs does not include a price floor mechanism, as such. However,
in the proceeding leading to Pricing policy for services subject to
price cap, Telecom Order CRTC
99-494, 1 June 1999 (Order
99-494),
the large ILECs, other than TELUS Québec and Télébec who were not then
subject to price cap regulation, submitted that they should not be
required to file rate reductions below Phase II costs plus a 25% mark-up
in order to meet price cap requirements. These ILECs argued that, while
competitive market forces might sometimes drive prices for services to
incremental costs, a company could not price all or the majority of its
services at this level and still remain viable in the long run. |
11. |
The Commission accepted the ILECs'
arguments in Order 99-494 and introduced a pricing policy for the single
basket of services established by Price cap regulation and related
issues, Telecom Decision CRTC
97-9, 1 May 1997 whereby the large
ILECs subject to that decision would not be required to reduce rates for
capped services below Phase II costs plus a 25% mark-up. In
Regulatory framework for second price cap period, Telecom Decision
CRTC 2002-34, 30 May 2002, the Commission adopted this same mechanism
for the Other capped services basket. The same mechanism was also
included in the price regulation regime established for TELUS Québec and
Télébec in Implementation of price regulation for Télébec and TELUS
Québec, Telecom Decision CRTC
2002-43, 31 July 2002. As indicated in
Order 99-494, the purpose of this mechanism is to protect the financial
integrity of the large ILECs. |
12. |
In the Commission's view, the service
groupings and upward pricing constraints in the price cap regime
applicable to the large ILECs appear to provide a reasonable balance
between the interests of customers, ILECs and competitors. However, the
Commission is concerned that the price floor mechanisms identified above
may not achieve a comparable balance. |
13. |
The findings of the Commission in its
December 2002 Report to the Governor in Council: Status of
Competition in Canadian Telecommunications Markets indicate
that competitors have not gained a substantial share in a number of key
telecommunications markets. For example, while revenues in the local
wireline market increased by almost 8% in 2001, competitors' share of
the market grew only marginally and represented less than 3% of total
revenues. In the interexchange market, revenues decreased by almost 6%
and competitors' share of these revenues decreased from 28% in 2000 to
26% in 2001. |
14. |
The Commission considers that the weak
state of competitive markets is attributable to a number of factors,
many of which are unrelated to the regulatory framework developed by the
Commission. However, it is the Commission's preliminary view that the
degree of downward pricing flexibility granted the large ILECs under the
current price floor mechanisms has contributed to the weakened state of
competition. In particular, that flexibility appears to have allowed the
large ILECs to engage in targeted pricing in response to competitive
entry, to the detriment to the development of competition: see, for
example, Regulatory safeguards with respect to incumbent affiliates,
bundling by Bell Canada and related matters, Telecom Decision CRTC
2002-76, 12 December 2002. Such pricing may also have resulted in unjust
discrimination between customers. Consequently, the Commission is of the
preliminary view that, for competition to evolve on a sustainable basis
and for the interests of all stakeholders to be properly balanced, the
existing price floor safeguards may require modification. |
15. |
In a related vein, the Commission is also
concerned that the degree of pricing flexibility available to the large
ILECs in connection with long term and volume contracts for tariffed
services may permit a large ILEC to provide a disproportionate benefit
to a customer who commits to a long term or volume contract. This type
of arrangement could raise concerns about possible unjust discrimination
or anti-competitive effects. |
16. |
In light of these concerns, the Commission
proposes to introduce interim modifications to the imputation test and
to the service bundle pricing rules applicable to the large ILECs. The
Commission also proposes to introduce, on an interim basis, a pricing
constraint for long term and volume contracts for tariffed services
provided by the large ILECs. The Commission is seeking comments on these
interim proposals, which are described below, as well as comments on
possible final changes to the price floor mechanisms and comparable
safeguards applicable to the large ILECs. |
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Proposed interim changes
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The imputation test
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17. |
As noted above, the Commission first
introduced the imputation test in Decision
94-13 as a safeguard against
anti-competitive pricing by the large ILECs in the interexchange voice
market. The imputation test was modified in Decision
94-19 in order to
reflect the implementation of the new Carrier Access Tariff and to
extend the application of the test to Competitive Network services.
Decision 94-19 also addressed the situation where an ILEC provides a
customized service to a single customer (referred to in Decision
94-19
as a type 1 customer-specific arrangement (CSA)) by requiring that the
imputation test be satisfied in these circumstances. |
18. |
In Decision
97-8, the Commission extended
the imputation test to establish price floors for local exchange
services. This imputation test was later modified in Decision
2001-737
because of concerns that the use of service-specific Phase II loop costs
in the test, permitted ILECs to de-average loop costs within a band when
providing service to individual customers. Accordingly, in Decision
2001-737, the imputation test was changed to require the ILECs to use
the average per-band Phase II loop costs in non-essential bands. |
19. |
In sum, the imputation test in its present
form requires an ILEC to demonstrate that the revenues from a retail
service will equal or exceed the sum of the costs of the service where
those costs are defined as the sum of: |
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- the tariffed rates for essential service components (e.g.,
the Phase II unbundled loop costs, plus a 15% mark-up in essential
bands);
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- the average Phase II loop cost per band, with no mark-up, in
non-essential bands; and
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- the Phase II cost of other service components, with no mark-up in
all bands.
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20. |
The Commission is concerned that the
application of a 15% mark-up on the Phase II costs of certain service
components and no mark-up at all on other components may set a price
floor that is too low. As noted above, the large ILECs have indicated in
the past that, on average, a mark-up of approximately 25% is required
for retail tariffed services in order to ensure the financial integrity
of an ILEC. This implies that the use of a mark-up lower than 25% for
certain retail services should require the use of a higher mark-up for
other retail services. This, in turn, raises concerns about the
potential for unjust discrimination as between the users of these
different services. |
21. |
The Commission is also concerned that the
current price floor established by the imputation test may prevent
competitors from operating on an economic basis, given that they
continue to be reliant on ILEC facilities in order to provide their
services. For example, in non-essential bands, competitors using an
unbundled ILEC local loop are required to pay the ILEC the Phase II cost
of the loop plus a 15% mark-up. Under the current imputation test, the
ILEC can price a retail tariffed service based on the Phase II cost of
the local loop, without mark-up. The lack of a requirement for a mark-up
in this latter case provides an opportunity for the ILEC to price a
retail service below the input cost of its competitors and thereby
eliminate the margin available to competitors. In fact, a competitor
would be required to take a loss on this component of the service in
order to match the ILEC's pricing. |
22. |
In light of these concerns, the Commission
is of the preliminary view that it would be appropriate, on an interim
basis, to raise the price floor established by the imputation test so as
to require a minimum mark-up of 25% on the Phase II costs of service
components. |
23. |
The Commission therefore proposes that the
imputation test be modified, on an interim basis, to require that when a
large ILEC wishes to introduce a new retail tariffed service or reduce
the price of an existing retail tariffed service, the ILEC must
demonstrate that the revenues derived from the service will equal or
exceed the sum of the cost of providing the service where that cost is
determined in the following manner: |
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- If the service incorporates a component that is already available
on a retail tariffed basis, either as a stand-alone service or as a
rate element of another retail tariffed service provided under
comparable terms and conditions, then that component must be costed at
the pre-existing tariffed rate. This costing rule should help ensure
consistency of pricing across services and thereby protect against
unjust discrimination as between customers of different services.
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- If the service incorporates a component that is already available
as a tariffed service that is classified as a Competitor Service, then
the cost of that component shall be deemed to be the greater of the
tariffed rate of the component as a Competitor Service or the Phase II
cost of the component plus a 25% mark-up. In accordance with Decision
2001-737, the Phase II cost of unbundled loops would be taken as the
average per band Phase II loop costs, where applicable. This costing
rule should help protect against anti-competitive pricing by the large
ILECs.
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- Other components of the service would be costed at their Phase II
cost plus a mark-up of 25%. This costing rule should help protect
against both unjust discrimination and anti-competitive pricing, while
also protecting the financial integrity of the large ILECs.
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Service bundle pricing rules
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24. |
When the Commission first considered
service bundling, in Decision 94-19, it began by examining whether the
bundling of tariffed services with other services should be permitted at
all, given the possibility that an ILEC could leverage its dominant
position in one market to gain or retain market share in another, more
competitive market. While acknowledging the importance of this concern,
the Commission concluded that, given the benefits of bundling to
customers, at least some types of service bundles should be permitted.
In Joint marketing and bundling, Telecom Decision CRTC
98-4, 24
March 1998 (Decision 98-4) the Commission reiterated this view: |
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In the Commission's view, the framework set out below for bundling
tariffed and other services strikes an appropriate balance between the
concerns of competitors with respect to the potential for
anti-competitive price abuses and the concerns of the Stentor
companies regarding their ability to provide cost-effective integrated
solutions. In the Commission's view, the framework provides the
Stentor companies with sufficient flexibility to meet consumer demands
for one-stop shopping and to exploit the economies of scale and scope
in the provision of these services.
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25. |
In Decision
94-19, the Commission concluded
that service bundles that included one or more tariffed services would
be required to be offered on a tariffed basis and to satisfy a service
bundle pricing rule. The Commission identified two types of service
bundles: (a) bundles offered on a general tariff basis to all customers;
and (b) service bundles provided to individual customers on a
customer-specific basis, referred to as type 2 CSAs. Separate service
bundle pricing rules were established for these two types of bundles. |
26. |
In the case of service bundles provided on
a general tariff basis, the service bundle pricing rule required an ILEC
to demonstrate that the revenues from the bundle would equal or exceed
the cost, where the service components of the bundle would be costed at: |
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- the tariffed rate(s) for bottleneck components (including, as
applicable, start-up cost recovery and contribution charges); and
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- Phase II cost for all other service components.
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27. |
For customer-specific bundles, all service
components available on a tariffed basis would be costed at their
tariffed rates, while all other service components would be costed at
their Phase II costs. |
28. |
The Decision 94-19 bundling rules were
extended and modified in Decision
97-8 to permit the bundling of local
exchange services with forborne services. Under the revised rules, local
exchange service and forborne service components would be costed at
their Phase II costs, except in the case of essential facilities and
below-cost single line residential exchange services which would be
costed at their tariffed rates. In Stentor Resource Centre Inc. –
Forbearance from regulation of interexchange private line services,
Telecom Decision CRTC 97-20, 18 December 1997, the rules were revised,
once again, to permit the bundling of non-forborne interexchange private
line services with forborne services. The non-forborne interexchange
private line services would be costed at their tariffed rates. |
29. |
In Decision
98-4 the Commission undertook a
complete review of the bundling rules and concluded that it would be
appropriate to permit an ILEC to bundle a tariffed service with any
other service, including services obtained from third parties. The
revised service bundle pricing rule for general tariff bundles
required that: |
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- essential services, non-forborne interexchange private line
services and below-cost single line residential exchange service would
be costed at their tariffed rates;
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- other service components provided by the ILEC would be costed at
their Phase II costs; and
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- services obtained from third parties would be costed at their
acquisition costs.
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30. |
The Decision
98-4 bundling rules were
revised in Bundling framework developed for customer-specific
arrangements, Order CRTC 2000-425, 19 May 2000 to permit
customer-specific bundles to include tariffed services together with
forborne services, as well as services obtained from third parties.
However, given the greater opportunity for unjust discrimination and the
potential impact on the evolution of telecommunications competition, the
Commission concluded that, for a customer-specific bundle, any tariffed
services included in the bundle would be costed at the tariffed rate.
The other aspects of the Decision
98-4 service bundle pricing rule
remained unchanged. |
31. |
The Commission is concerned that the
current service bundle pricing rules may provide the large ILECs with
greater pricing flexibility than can be justified on the basis of the
economies of scale and scope associated with the joint provisioning of
services. This, in turn, raises the concern that the large ILECs may be
able to engage in targeted price discounting in their service bundles.
Such activity could have a significant anti-competitive effect as it
would permit the large ILECs to leverage their market power from less
competitive markets in order to gain or retain market share in other,
more competitive telecommunications markets. Such discounting activity
would also raise concerns about unjust discrimination as between
customers who purchase service bundles and those customers who either do
not have such bundles available to them or who rely on other tariffed
services. |
32. |
Given these concerns, the Commission is of
the preliminary view that the service bundle pricing rules should be
modified to reduce the opportunity for targeted price discounting by the
large ILECs. In particular, the Commission is of the preliminary view
that the modifications described below should be implemented on an
interim basis. |
33. |
The Commission proposes that service
bundles offered on a general tariff basis should satisfy the following
service bundle pricing rule: the revenues from the service bundle would
be required to equal or exceed the sum of the stand-alone retail prices
of the services included in the bundle, less 10%. When demonstrating
that this pricing requirement is met, a large ILEC seeking tariff
approval of such a service bundle would be required to provide
satisfactory evidence that the individual service components are
available on a stand-alone retail basis, at the retail price identified
in the application. |
34. |
In light of the greater risk of unjust
discrimination associated with customer-specific bundles, the Commission
is of the preliminary view that it would be inappropriate to permit any
discount to be applied to the tariffed services included in such
bundles. Accordingly, a large ILEC seeking tariff approval of a
customer-specific bundle would be required to demonstrate that the
revenues from the service bundle would equal or exceed the sum of the
stand-alone retail prices of the services included in the bundle, less a
10% discount on the non-tariffed services. As in the case of a service
bundle offered on a general tariff basis, a large ILEC seeking tariff
approval of such a service bundle would be required to provide
satisfactory evidence that the individual service components are
available on a stand-alone retail basis, at the retail price identified
in the application. As an exception to this pricing rule, in the
case of an incidental feature, such as training or enhanced support,
that is not available on a stand-alone retail basis, the ILEC would be
permitted to include the feature in a customer-specific bundle at the
Phase II cost of the feature, plus a mark-up of 25% (without discount).
An ILEC wishing to include such a feature in a customer-specific bundle
would be required to provide satisfactory evidence as to the Phase II
cost of the feature, as well as to demonstrate that the inclusion of the
feature would not result in unjust discrimination. |
35. |
Finally, in order to protect against
regulatory gaming, tariff approval of a service bundle would remain in
force only for so long as each service component of the bundle remains
available on a stand-alone retail basis at a retail price not greater
than the price identified in the application for tariff approval of the
bundle. |
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Pricing safeguards for volume and term
contracts
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36. |
At present, the large ILECs can provide
retail tariffed services pursuant to contracts which provide pricing
advantages that depend on volume or the length of the contract period.
These contracts are not subject to pricing safeguards beyond the
application of the imputation test. The Commission is concerned that the
pricing flexibility available to the large ILECs in connection with such
contracts may provide them with an opportunity to skew the distribution
of price benefits under a contract in a manner that may raise concerns
about unjust discrimination as between customers or about
anti-competitive pricing. Consequently, the Commission is of the
preliminary view that it would be appropriate to introduce a pricing
safeguard for such contracts on an interim basis. |
37. |
In light of the above, the Commission
proposes that if a large ILEC wishes to modify the manner in which a
tariffed service is provided pursuant to a contract which offers price
advantages that depend on volume or length of contract period, it must
do so in a way that, within a band, preserves the existing approved rate
differentials. For example, assuming the imputation test would be
satisfied, if the rate for a service to be provided over a five-year
period is to be decreased by 10%, then the same 10% reduction must be
applied to the rate charged for other contract periods, as well as to
the monthly rate. In addition, if a large ILEC wishes to introduce new
contract periods for a new or existing tariffed service, the ILEC would
be required to demonstrate both that the proposed arrangements satisfy
the imputation test and that they embody rate differentials for volume
or length of contract commitment that are just and reasonable; for
example, by comparison with rate differentials that have already been
approved by the Commission in respect of another tariffed service. |
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Application of the interim safeguards
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38. |
The Commission's interim decision would
apply to all applications filed by the large ILECs for new services and
rate reductions for existing services, whether offered on a general
tariff or special facilities tariff basis. |
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Call for comments
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39. |
The Commission invites comments on its
proposed interim modifications to the imputation test and to the service
bundle pricing rules, as well as the proposed interim pricing safeguard
for volume and long term contracts. |
40. |
The Commission also invites comments on
possible final modifications to the pricing safeguards. In particular,
the Commission invites comments on the following issues: |
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a) Whether the interim imputation test for retail services proposed
above (or as it may be modified in the Commission's decision on the
interim pricing safeguards) should be adopted on a final basis. If
not, indicate the appropriate level of mark-up that should be used in
the test and what other modifications, if any, should be made to the
test.
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b) Whether the interim service bundle pricing rule proposed above
(or as it may be modified in the Commission's decision on the interim
pricing safeguards) should be adopted on a final basis. If not,
indicate what pricing safeguards should be applied and indicate the
modifications, if any, that should be made to the service bundle
pricing rule. Also, indicate whether there should be different service
bundle pricing rules for general tariff bundles and customer-specific
bundles and, if so, why.
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c) Whether the interim safeguard on the pricing of term and volume
contracts (or as it may be modified in the Commission's decision on
the interim pricing safeguards) should be adopted on a final basis. If
not, indicate what pricing safeguards, if any, should be applied to
term and volume contracts.
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d) Whether the large ILECs should be required to undo approved
service bundles which do not conform with the service bundle pricing
rules as they may be modified in the Commission's final decision on
the pricing safeguards.
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e) Whether it would be appropriate to establish an annual percent
limit for price reductions for certain retail services. If so,
indicate which services should be subject to such a limit and what
level of price limit should be applied.
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f) Identify the implications, if any, that changes to the pricing
safeguards would have for the price cap regimes currently applicable
to the large ILECs, especially in regard to the ILECs' ability to meet
the basket and sub-basket pricing constraints. The Commission notes
that the price cap formula, basket structure and price cap commitments
are not within the scope of this proceeding.
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g) Parties may also comment on any other aspect of the current
regulatory framework regarding the imputation test and bundling rules,
and any other related retail tariffed service pricing safeguards.
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Related application
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41. |
The Commission notes that on 27 June 2003,
it received an application from Rogers Communications Inc. (Rogers)
asking for a change in the bundling rules to prohibit the large ILECs
from bundling monopoly residential telephone services with competitive
services. The Commission has received answers and replies in respect of
this application, in accordance with the CRTC Telecommunications
Rules of Procedure. |
42. |
The record of the Rogers' application is
hereby made part of the record of this proceeding. The Commission
intends to address the relief requested by Rogers in the context of the
present proceeding. |
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Procedure
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43. |
Aliant Telecom , Bell Canada, MTS, SaskTel,
TCI, TELUS Québec and Télébec are made parties to this proceeding. Other
parties wishing to participate fully in this proceeding must notify the
Commission of their intention to do so, by 3 November 2003. They
should contact the Secretary General by mail at CRTC, Ottawa, Ontario,
K1A 0N2, by fax at (819) 953-0795 or by email at procedure@crtc.gc.ca.
They are to indicate in the notice their email address where available.
If parties do not have access to the Internet, they are to indicate in
their notice whether they wish to receive disk versions of hard copy
filings. |
44. |
The Commission will issue as soon as
possible after the registration date, a complete list of parties and
their mailing address (including their email address, if available),
identifying those parties who wish to receive disk versions. |
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Process for interim determinations
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45. |
Parties may file with the Commission comments on the proposed interim modifications to the pricing
safeguards, described above, serving copies on all parties, by 24
November 2003. |
46. |
Parties may file reply comments with the
Commission, serving copies on all parties, by
2 December 2003. |
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Process for final determinations
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47. |
Parties may file submissions with the
Commission regarding final modifications to the pricing safeguards,
serving copies on all parties, by 20 April 2004. Parties should
include with their comments any evidence they consider necessary to
support their arguments. |
48. |
All parties may address interrogatories to
any party who filed submissions pursuant to the preceding paragraph. Any
such interrogatories must be filed with the Commission and served on the
party in question, by 11 May 2004. |
49. |
Responses to those interrogatories are to
be filed with the Commission and served on all parties, by 1 June
2004. |
50. |
Requests by parties for further responses
to their interrogatories, specifying in each case why a further response
is both relevant and necessary, and requests for public disclosure of
information for which confidentiality has been claimed, setting out in
each case the reasons for disclosure, must be filed with the Commission
and served on the relevant party or parties by 8 June 2004. |
51. |
Written responses to requests for further
responses to interrogatories and for public disclosure must be filed
with the Commission and served on the party or parties making the
request by 15 June 2004. |
52. |
The Commission will determine the remaining
procedure at a later date, including whether an oral hearing would be
required. |
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General
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53. |
Where a document is to be filed or served
by a specific date, the document must be actually received, not merely
sent, by that date. |
54. |
Parties can file their submissions
electronically or on paper. Submissions longer than five pages should
include a summary. |
55. |
Where the submission is filed by electronic
means, the line ***End of document*** should be entered following the
last paragraph of the document, as an indication that the document has
not been damaged during electronic transmission. |
56. |
Please note that only those submissions
electronically filed will be available on the Commission's web site and
only in the official language and format in which they are submitted. |
57. |
Each paragraph of a submission should be
numbered. |
58. |
The Commission also encourages parties to
monitor the public record of this proceeding (and/or the Commission's
web site) for additional information that they may find useful when
preparing their submissions. |
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Location of CRTC offices
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59. |
Submissions may be examined or will be made
available promptly upon request at the Commission offices during normal
business hours: |
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Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room G-5
Gatineau, Quebec J8X 4B1
Tel: (819) 997-2429 - TDD: 994-0423
Fax: (819) 994-0218 |
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Metropolitan Place
99 Wyse Road, Suite 1410
Dartmouth, Nova Scotia B3A 4S5
Tel: (902) 426-7997 - TDD: 426-6997
Fax: (902) 426-2721 |
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405 de Maisonneuve Blvd. East
2nd Floor, Suite B2300
Montréal, Quebec H2L 4J5
Tel: (514) 283-6607
Fax: (514) 283-3689 |
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55 St. Clair Avenue East, Suite 624
Toronto, Ontario M4T 1M2
Tel: (416) 952-9096
Fax: (416) 954-6343 |
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Kensington Building
275 Portage Avenue, Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel: (204) 983-6306 - TDD: 983-8274
Fax: (204) 983-6317 |
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Cornwall Professional Building
2125 - 11th Avenue, Room 103
Regina, Saskatchewan S4P 3X3
Tel: (306) 780-3422
Fax: (306) 780-3319 |
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10405 Jasper Avenue, Suite 520
Edmonton, Alberta T5J 3N4
Tel: (780) 495-3224
Fax: (780) 495-3214 |
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580 Hornby Street, Suite 530
Vancouver, British Columbia V6C 3B6
Tel: (604) 666-2111 - TDD: 666-0778
Fax: (604) 666-8322 |
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Secretary General |
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This document is available in
alternative format upon request and may also be examined at the
following Internet site:
http://www.crtc.gc.ca |