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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.
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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".
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2.
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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.
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3.
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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.
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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.
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5.
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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.
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6.
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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.
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7.
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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".
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8.
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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.
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9.
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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.
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10.
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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.
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11.
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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.
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12.
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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.
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13.
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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.
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14.
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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.
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15.
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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.
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16.
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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.
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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.
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18.
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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.
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19.
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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.
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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.
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21.
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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.
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22.
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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.
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23.
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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.
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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.
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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.
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26.
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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.
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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.
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28.
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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.
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29.
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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.
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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.
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31.
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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.
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32.
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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.
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33.
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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.
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34.
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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.
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35.
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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.
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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.
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37.
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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.
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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.
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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.
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40.
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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.
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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.
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42.
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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.
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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.
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44.
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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.
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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.
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46.
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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.
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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.
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48.
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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.
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49.
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Responses to those interrogatories are to be filed with the Commission and served on all parties, by 1 June 2004.
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50.
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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.
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51.
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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.
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52.
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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.
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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.
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54.
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Parties can file their submissions electronically or on paper. Submissions longer than five pages should include a summary.
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55.
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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.
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56.
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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.
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57.
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Each paragraph of a submission should be numbered.
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58.
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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.
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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
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Date Modified: 2003-10-23