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Ottawa, 29 January 2014
Our reference: 8665-E17-201312389
DELIVERED BY EMAIL
To: Distribution list
RE: Eastlink - Part 1 Application – contract cancellation notice requirements
Section 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.
In its application, Bragg Communications Inc., carrying on business as Eastlink (Eastlink), requested that the Commission prohibit policies that require the customer to give 30-days notice to cancel a service.
Commission staff requests that the following parties respond to the attached interrogatories associated with the above-noted Part 1 application: Eastlink, TELUS Communications Company (TELUS), Canadian Network Operators Consortium Inc. (CNOC), Saskatchewan Telecommunications (SaskTel), Bell Aliant and Bell Canada (Bell) and Rogers Communications Partnership (Rogers).
Responses to these interrogatories are to be filed with the Commission by 6 February 2014. Parties that wish to designate some or all of their answers as confidential must do so in accordance with the CRTC Rules of Practice and Procedure.
A copy of this letter and all related correspondence will be added to the public record of the proceeding.
Yours sincerely,
ORIGINAL SIGNED BY /
Nanao Kachi
Director, Social & Consumer Policy
c.c.: Neil Barratt, CRTC (819) 997-4571, neil.barratt@crtc.gc.ca
Enclosure
Distribution List:
regulatory.matters@corp.eastlink.ca; regulatory@cnoc.ca; document.control@sasktel.com; telecom_policy@diversitycanada.org; bell.regulatory@bell.ca; dennis.beland@quebecor.com; lawford@piac.ca; regulatory.affairs@telus.com; david.watt@rci.rogers.com; jfmezei@vaxination.ca
Request for Information
The following request for information sets out:
A. Questions for Eastlink
B. Questions for Bell, Rogers, TELUS and SaskTel
C. Questions for CNOC
A. Questions for Eastlink
1. In paragraph 22 of its application, Eastlink “requests that 30-day notice requirements be prohibited across all services.” In the application, Eastlink also references certain telecommunications and broadcasting services.
a. Fill out the following chart, providing a complete, itemized list of each of the services Eastlink considers should be prohibited from having 30-day cancellation notice requirements.
Service Retail/wholesale Residential/business Regulated/forborne
(a) Retail only,
(b) wholesale only, or
(c) both retail and wholesale (a) For residential customers only
(b) For residential and small business customers, or
(c) For all customers, including medium and large businesses (a) regulated only,
(b) forborne only,
(c) regulated and forborne, or
(d) not applicable
b. Clarify the precise relief that Eastlink is seeking, including a reference to the relevant section(s) of the Telecommunication Act and/or Broadcasting Act.
2. At paragraph 22, Eastlink states that a prohibition on 30-day cancellation policies should take effect immediately. In Eastlink’s view, would this require amending existing customer contracts? If so, please comment on the potential costs of this approach. Include comments on the possibility of the prohibition applying only to new contracts.
3. Paragraphs 5-7 of Eastlink’s application indicate that 30-day cancellation policies increase costs to competitors.
a. Provide additional evidence on the nature and quantum of these costs, including all supporting assumptions.
b. How often do prospective customers cancel their order when informed of notification requirements? File any supporting evidence or underlying assumptions, as appropriate.
B. Questions for TELUS, SaskTel, Bell and Rogers
1. Broadcasting and Telecom Regulatory Policy CRTC 2011-191 sets out the following principles:
• regulatory symmetry with respect to customer transfers is in the best interests of consumers;
• requiring customers to call their current TSP to cancel could be a disincentive to switching providers, and add complexity and delay to the transfer; and
• allowing the new service provider to act on behalf of the customer provides the most choice and convenience in a converged environment and simplifies the customer experience.
a. Comment on how 30-day advance notice requirements comply with these principles.
b. Comment on whether “future-dating” porting requests could cause customers any difficulty, cost or inconvenience.
2. How much notice do you require your retail customers to provide when cancelling each of the following services (as applicable). Where the notice requirement is subjective (i.e. “reasonable” notice) please explain how this threshold is established.
a. local and long-distance telephone – forborne areas
b. local and long-distance telephone – regulated areas
c. home internet services
d. broadcasting distribution (BDU) services
3. Based on the cancellation policies you have set out above,
a. Confirm whether, in cases of service transfer or cancellation, the customer may continue to pay for service that they no longer wish to receive.
b. If applicable, how much revenue, on an annual basis, is derived from service charges billed after the requested cancellation?
c. Comment on whether this increased cost impacts the consumer’s ability to change service providers.
4. How and when do you inform customers of your cancellation notice policies?
5. At paragraph 22, Eastlink states that a prohibition on 30-day cancellation policies should take effect immediately. Above, Commission staff has requested that Eastlink clarify whether it considers such a requirement should apply to new and/or existing contracts and service agreements.
If the Commission were to prohibit 30-day cancellation notice policies, comment on:
a. the potential costs of amending contracts and service agreements for new customers; and
b. the potential costs of amending all existing contracts and service agreements.
6. Some parties to this proceeding have submitted that notification requirements help companies to recover customer acquisition or upfront costs.
For each of the services identified in question 2 above,
a. Provide calculations of the customer acquisition costs, as well as the amount of these costs recovered on a monthly basis.
b. Provide information on how long, on average, customers remain with your company. How long does it take for upfront costs to be recovered? What proportion of customers stay long enough for your company to recoup upfront costs?
7. Some parties to this proceeding have submitted that up-front costs for wireline services may not be recovered by termination fees and monthly service fees, even where the customer completes a fixed term contract.
Please comment on Eastlink’s assertion that service providers should be able to build monthly plans that allow them to recover upfront costs.
Questions for Canadian Network Operators Consortium
1. Paragraphs 10-13 of CNOC’s submission argues that, in certain circumstances, service providers should be able to continue to bill customers after the cancellation request has been accepted.
Explain how this is consistent with your position supporting the prohibition of notice periods.
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