ARCHIVED -  Telecom Order CRTC 97-1000

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Telecom Order

Ottawa, 18 July 1997
Telecom Order CRTC 97-1000
On 31 January 1997, Bell Canada (Bell) filed an application under Tariff Notice 5929 (TN 5929) for approval of tariff revisions to introduce a promotional campaign for its QuickChange and LaPuce pre-paid cash cards to run from 3 March 1997 until 31 December 1997. These cards are to be distributed at consumer exhibitions, trade shows, sporting events, or other locations where Bell considers that the promotional activities would benefit sales of its pre-paid cash cards.
File No.: Bell Tariff Notice 5929
1. In Telecom Order CRTC 97-266 dated 27 February 1997, the Commission approved TN 5929 on an interim basis.
2. AT&T Canada Long Distance Services Company (AT&T Canada LDS) filed comments on 17 February 1997.
3. Bell submitted a response on 13 March 1997.
4. AT&T Canada LDS submitted that TN 5929 does not constitute a promotion of limited duration as contemplated by the Commission in Review of Regulatory Framework - Targeted Pricing, Anti-Competitive Pricing and Imputation Test for Telephone Company Toll Filings, Telecom Decision CRTC 94-13 dated 13 July 1994 (Decision 94-13). AT&T Canada LDS submitted that the proposed ten month duration disqualifies the promotion as a promotion of limited duration. AT&T Canada LDS further submitted that Bell should be required to perform an imputation test in support of its proposal.
5. Bell replied that Decision 94-13 states that market trials and promotions will be exempt from the application of the imputation test on the condition that sufficient information is provided by the telephone companies to demonstrate the offering is a legitimate market trial or promotion of limited duration. Bell noted that the market for pre-paid cards is highly competitive and that competitors can issue promotional cards at will.
6. Bell corrected the record by noting that the effective period for TN 5929 is actually under ten months. Bell also noted that it is likely that there will be intervals during the period from 3 March 1997 to 31 December 1997 when it will have no opportunity or events at which it will be distributing its promotional cards. As a result, the length of time the cards will actually be distributed is likely to be substantially less than the eligible period.
7. Bell submitted that the inclusion of toll minutes from its pre-paid card promotions in the imputation tests for the basic message toll services would not alter the results of the imputation tests to any degree.
8. The Commission notes that the promotional cards are valued at $0.50 to $5.00 and can be used for either local or long distance calling.
9. On the basis of the record of this proceeding, the Commission is satisfied that Bell's proposed pre-paid card promotion is a legitimate promotion of a sufficiently limited duration.
10. Accordingly, the Commission considers that an imputation test is not required in this case.
11. In light of the foregoing, the Commission approves the proposed tariff revisions on a final basis.
Laura M. Talbot-Allan
Secretary General
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