ARCHIVED - Telecom Order CRTC 97-960
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Telecom Order |
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Ottawa, 11 July 1997
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Telecom Order CRTC 97-960
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On 27 March 1997, TELUS Communications Inc. (TCI) filed an application for the introduction of QuickChange Payphone Pass promotion. TCI amended its application on 7 April 1997.
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File No.: Tariff Notices 901 and 901A
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1. The proposed tariff revisions to become effective on 14 April 1997 were approved on an interim basis in Telecom Order CRTC 97-505.
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2. AT&T Canada Long Distance Services Company (AT&T Canada LDS) filed comments on 14 April 1997 submitting that the proposed year long duration of this marketing program disqualifies it as 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 (Decision 94-13), 13 July 1994. AT&T Canada LDS noted that the Commission has denied approval of offers of similar duration in the past.
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3. AT&T Canada LDS requested that the Commission either deny Tariff Notice 901 or direct TCI to perform an imputation test in support of its proposal noting that TCI had already provided the Commission with its estimate of the forecast value of the cards distributed during the offer.
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4. TCI noted in reply comments filed on 23 May 1997 that in Tariff Filings Relating to Promotions, Telecom Decision CRTC 96-7 (Decision 96-7), 18 September 1996, the Commission concluded that it was not persuaded that it would be beneficial to establish a priori criteria defining legitimate promotions of limited duration. TCI submitted that each proposed promotion must be examined on a case-by-case basis, with the Commission rendering its decision as to whether it is a legitimate promotion of limited duration.
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5. TCI submitted that its proposed promotion is not one continuous promotion, but rather a series of occasional promotional activities and that the actual duration is substantially less than the eligible period.
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6. TCI stated that while the pre-paid cash cards can be used for local or long distance calls, the low face value of the promotional cards will primarily encourage customers to place local calls from public telephones and will be used, for the most part, for that purpose. TCI noted that when compared to its revenue from message toll services, the total value of the promotional cards to be used for long distance calls is exceedingly small and that the inclusion of these minutes in the imputation test for the basic message toll services would not alter the results of the imputation test.
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7. The Commission notes that Decisions 94-13 and 96-7 addressed promotional offerings in the toll market exempting them from the application of an imputation test on the condition that sufficient information was provided by the telephone companies demonstrating that the offering was a legitimate market trial or promotion of limited duration. As well, the Commission declined to establish a priori criteria for defining legitimate promotions of limited duration.
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8. The Commission considers that given the conditions under which the proposed promotion is offered, it will primarily provide an incentive for customers to use prepaid cards to place local calls from public telephones. As submitted by TCI, only small amounts of toll traffic would be initiated by the promotional offering given the low face value of the cards.
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9. The Commission notes that TCI submitted the aggregate value of prepaid cards to be issued during the promotional period. Given the nature and the pre-determined value of the promotional offering, the Commission is of the view that the proposed promotional offering does constitute a legitimate promotion.
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10. In light of the foregoing, the Commission approves the proposed tariff revisions on a final basis.
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Laura M. Talbot-Allan
Secretary General |
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This document is available in alternative format upon request.
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