Intervention: Intervenor 188

Document Name: 2015-134.223698.2388085.Intervention(1f6np01!).doc
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John P. Roman
5 Windmill Road, Toronto, ON *** ***
**** 30, 2015
Mr. John Traversy, Secretary-General
Canadian Radio-Television &Telecommunications Commission
Ottawa, ON *** ***
**** Mr. Traversy:
Re: Telecom Notice of Consultation CRTC 2015-134

1. This submission to Phase One is designed when combined with other input to assist in development of a strong framework of questions for use during Phase Two of this process. There are three areas for consideration: one intended as an encouragement for industry consideration, one based on the degree of influence or control the CRTC wishes to employ, and one potential solution to an established problem.

Considering the Unimaginable

2. Comprehensive review of Paragraph 10 of CRTC 2015-134 will necessitate exploration of the possibility of opening Canada’s telecommunications market to foreign competition. This will be an unpleasant and, because of current regulatory restrictions, largely academic prospect for the country’s TSPs. For the sake of fairness, however, I suggest that they should be required to justify why, in both the short and longer terms, increased (and in particular foreign) competition would not be advantageous to Canadians.

3. To enable a complete review of all available options, it is imperative that we at least consider allowing foreign interests to enter the domestic telecommunications market. With the concentration of ownership that has occurred over decades, a near oligopoly currently exists in Canada, despite a few outliers like **** and Teksavvy operating in specific markets. Can it any longer be realistic to accept that Bell, Rogers, Shaw, etc. are not yet large enough to face some international competition? Are they only capable of 'competing' against each other in our very restricted marketplace so long as they control the majority of infrastructure and market share? At this point in the evolution of our telecommunications system, if there is sincere interest in increasing competition within it, I suggest we must explore the potential impact of allowing foreign investment.

. . . 2
A gentle touch?

4. Paragraph 20 of CRTC 2015-134 raises the spectre of rate regulation. While the majority of industry prices have traditionally been left to the determination of market forces, the recent decision of May 5th, 2015 (CRTC 2015- 177) demonstrates that the CRTC may be prepared to consider adoption of rate regulation when it is called for.

5. Given the current degree of concentration of ownership within Canada’s internet delivery infrastructure, I suggest that the time has come to have the ISPs justify why fairness to the Canadian consumer does not justify the introduction of some form of rate regulation of home internet service.

6. As I take the bus in the mornings, on occasion I scan what is engaging my fellow passengers. The vast majority are on their phones: some are reading the news, others are answering emails. To deny that cell phones are major instruments of internet delivery would be preposterous – and, were that not the case, Bell and its competitors would all have been introduced unlimited data plans as part of their cell service options years ago.

7. I raise this point because if we are to focus on access to internet service, we must suitably address all the ways that we access the world-wide-web. It is for this reason that I request the CRTC to examine the data packages offered by various TSPs in order to assess their true competitive intent.

8. I recognize that the Commission dealt with competitiveness in its May 5, 2015 decision on roaming charges (CRTC 2015-177). What I am suggesting is, however, is the examination of past and present cell phone plans (and looking at data packages in particular), which likely indicates that the TSPs’ focus has always been on pushing 'newer technology and faster speeds' rather than a reduction of costs.

9. In this regard, new entrants often enhance available service options when the deals they offer are better than those of the established TSPs. But the limits of any so-called competition are made clear when the more dominant companies decline even to attempt to match the deals offered by new rivals’.

10. Obviously, it's a slippery slope. If Bell or Rogers did match a **** offer, they would be criticized for trying to drive out new entrants. On the other hand, if they don't even deign to compete with new entrants, they appear to be uninterested in retaining their customer base and increasing competition in the marketplace.

11. We know that Canada's geography does impact costs, but there is a point beyond which one has to question the reasonableness of margins of profits and consumer cost.

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A Rural High-speed Solution

12. Paragraph 31 of CRTC 2015-134 acknowledges that some rural areas are impractically located for cost-effective internet services to be efficiently delivered to homes. Paragraph 33, specifically requests new and innovative solutions for service to underserved areas. With a bit of technological wizardry and a firm regulatory nudge to cell providers, I suggest it is possible to craft a practical solution to this problem.

13. If consumers in rural areas which are not accessible to reliable high speed home internet but do have cellular phone service were provided with unlimited data packages for their smart phones, they could then tether their computers to their phones and access the data packages and reasonable internet speeds provided by the latter. The rate charged for this unlimited data plan in these underserved areas should be regulated to ensure it remains reasonable, perhaps an additional monthly fee of $15-$25 on top of the customer’s existing plan.

14. If approved, such an initiative would have two benefits:

· It could quickly provide Canadians in many sparsely populated rural areas with cost-effective high-speed internet service and eliminate TSPs’ high infrastructure costs that would be attached to alternate delivery formats.

· At the same time, such an option might encourage TSPs eventually to make the investment required to offer enhanced direct home internet delivery at a cost in which a higher profit margin could be embedded.

15. This option is well within the technical limits of current phone technologies, could be easily applied by cell phone users (assisted by support from their provider) and could usefully be considered by the Commission as a practical option for providing improved home internet service to consumers in underserved areas.

Yours sincerely,
John P. Roman
*** End of Document ***

Intervention: Intervenor 188

Document Name: 2015-134.223698.2388086.Intervention(1f6nq01!).html

Please see the attached document for comment on 2015-134.