ARCHIVED - Telecom Commission Letter addressed to various parties interested in the Wholesale Domestic Wireless Roaming caps implementation

Ottawa, 29 December 2014

Our reference: 8620-C12-201407206

BY EMAIL

Distribution list

Re: Wholesale Domestic Wireless Roaming caps implementation

Dear Madam, Sir:

On 28 July 2014, Commission staff sought specific data in relation to the methodologies and assumptions used by wireless service providers with respect to the calculation of the roaming cap(s) to which a Canadian carrier is subject pursuant to section 27.1 of the Telecommunications Act when charging another Canadian carrier for certain domestic roaming services.

On 27 August 2014, TELUS, Bell Mobility, Rogers, MTS Allstream, TbayTel, Saskatchewan Telecommunications (SaskTel), Ice Wireless and Bragg Communication Inc. carrying business as “Eastlink” and Québecor Media on behalf of Vidéotron, (the wholesale roaming providers) filed responses to these questions.

Responses were also filed with the Commission by other wireless carriers that are not providing wholesale roaming.

In order to assist Commission staff, the wireless carriers are requested to provide responses to the additional questions set out in Attachment 1. These responses are to be filed with the Commission by 6 February 2015. These responses are to be received, and not merely sent, by this date.

This letter and all subsequent correspondences will form part of a public record.

Commission staff notes that the information collected through this fact finding process,

may be used to establish whether a company is in compliance with section 27.1 of Telecom Act and may lead to Commission determinations.

Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications Sector

c.c.: Abderrahman El Fatihi, CRTC, 819-953-3662, abderrahman.elfatihi@crtc.gc.ca

Attach. (2)

ATTACHMENT 1

Interrogatories

Update – To wholesale roaming providers

1. As of 31 December 2014, provide an up-to-date list of all Canadian carriers to whom the company is currently providing domestic roaming services along the applicable rates for each of wireless voice calls, text messages and wireless data.
2. With reference to the text box below, provide your interpretation of the terms “during a year” and “preceding year”. Based on your interpretation, when would the new legislated domestic roaming caps be available for a new year?

Roaming cap – wireless voice calls / wireless data / text messages

27.1 (1) The amount charged during a year by a Canadian carrier to a second Canadian carrier for roaming services with respect to the transmission of all domestic wireless voice calls and the domestic portion of all international wireless voice calls shall not exceed the amount determined by the formula

A/B

Where

A is the first Canadian carrier’s total retail revenues from the provision of wireless voice call services to its Canadian sub-scribers, for calls both originating and terminating in Canada, for the preceding year; and

B is the number of minutes provided for those calls for the preceding year.

No additional charges – To wholesale roaming providers

3. Refer to the company’s proposed roaming cap for wireless voice calls’ service. Explain, with supporting rationale, why Long Distance (Toll) charges are billed in addition to Airtime rate and how this is consistent with the “no additional charge” prohibition in section 27.1.4 of the Telecom Act, which stipulates that the Canadian carrier shall not charge the second Canadian carrier any other amount in relation to the provision of the roaming services referred to in subsections (1) to (3).

Handset subsidy – To wholesale roaming providers

4. Confirm if the handset subsidy included in the monthly wireless plan fees or any amount received upfront associated with the handset have been subtracted from the total retail wireless revenue used to calculate the proposed roaming caps. If none were subtracted, provide revised legislated domestic roaming caps for wireless voice calls, text messages and wireless data that  exclude any amounts related to the handset subsidy.
5. For those that did not include any amounts related to the handset subsidy, provide revised roaming caps for each of wireless voice calls, text messages and wireless data that include these amounts.
6. Explain, with detailed rationale, whether the approach to handset subsidy should be applied consistently across all wholesale roaming providers and, if not, why not?

Bundled services and Fair Market Value (FMV) for standalone service

To Bell Mobility

7. With reference to the company`s response to interrogatory Bell mobility CRTC) 28July14-6 where the company provided a description of the revenue allocation assumptions for wireless voice calls, text messages and wireless data.
   1. Provide the fair market value (FMV)used for the purpose of revenue allocation of retail monthly wireless plan fees for bundled services.
   2. Confirm whether these FMVs represent the current pricing available for all customers. If not, explain with supporting rationale how these FMVs were determined.

To Rogers

8. With reference to the company`s response to interrogatory Rogers(CRTC)28July14-6 where the company described the methodology used to determine its legislated wholesale domestic caps for wireless voice calls, text messages and wireless data.
   1. Provide the fair market value (FMV)used for the purpose of revenue allocation of retail monthly wireless plan fees for bundled services.
   2. Confirm whether these FMVs represent the current pricing available for all customers. If not, explain with supporting rationale how these FMVs were determined.

To wholesale roaming providers except Videotron

9. With reference to Videotron’s response to interrogatory Québecor Média (CRTC)28jui2014-6 where the company described its retail wireless revenue allocation methodology to calculate the legislated roaming caps for wireless voice calls, text messages and wireless data,
   1. Provide the company’s view on the methodology proposed by Videotron in its submission which is based on rules set in Order CRTC 2001-220 - Industry Consensus Reports submitted by the Contribution Collection Mechanism (CCM) implementation Working Groups –Appendix B.
   2. Calculate revised legislated domestic roaming caps using Videotron’s proposed methodology.

To Videotron

10. With reference Rogers’ response to interrogatory Rogers(CRTC)28July14-6 where the company described its methodology used to determine its legislated wholesale domestic caps for wireless voice calls, text messages and wireless data, provide your legislated domestic roaming caps using the same approach and principles.

To SaskTel

11. With reference to the company`s response to interrogatory SaskTel(CRTC)28Jul14-6 where the company described its methodology associated with retail wireless revenue allocation for wireless voice, text messages and wireless data,
    1. For converged plan monthly recurring charge, provide the percentages of total retail wireless revenue attributable to each of the services wireless voice, text messages and wireless data.
    2. How consistent are the values derived from these percentages with the current pricing available for all customers on a standalone basis.

To TBayTel

12. With reference to the company`s response to interrogatory TBayTel(CRTC)28July14-6) where the company described its methodology (i.e. Network Utilization percentage) to allocate retail wireless revenues from wireless bundle services, provide a detailed description of the company’s proposed methodology.

To Eastlink

13. With reference to the company`s response to interrogatory Bragg(CRTC)28Jul2014-6 and disclosed on 4 November 2014 where the company described its methodology (i.e. based on subscriber records) to allocate retail wireless revenues from wireless bundled services, provide a detailed description of the company’s proposed methodology.

List of exclusions to wireless revenue and traffic - To wholesale roaming providers

14. When calculating their proposed domestic legislated roaming caps, wholesale roaming providers listed the following exclusions which were deducted from their total retail wireless revenue and traffic:

    Revenue exclusions

    • Wholesale Roaming services
    • International Long Distance
    • International Roaming
    • International Text message
    • Northwestel (for Bell Mobility)
    • Port-in & contact renewal credit
    • Goodwill credits
    • Warranty services
    • Hardware upgrade fees
    • Number change fees
    • 911 fees
    • Government Recovery fees
    • Paper bill fees
    • Handset subsidy
    • Mobile TV
    • Investment Revenues
    • Location-based services
    • Road assistance services
    • Telematics services
    • Visual voicemail & voice-to-text services
    • Premium SMS services
    • Voice mail, Directory assistance
    • Feature add-ons
    • Downloads (e.g., ringtones, Java)
    • Miscellaneous (paging, FleetNet, Apple Care, content, apps, etc.

    Traffic exclusions

    • Wholesale
    • International roaming
    • International long distance
    • International Text message
    • Northwestel (For Bell Mobility)
    • Voice, Text and date outside Canada
    • Internally generated traffic
    • Wireless other (specify)
    1. Provide the company’s view on the appropriateness of the exclusions listed above with supporting rationale.
    2. What other adjustments, if any, should be made to the retail wireless total revenues and traffic to be consistent with section 72.1 27.1 of the Telecom Act.
    3. In order to ensure that the information provided is consistent across wholesale roaming providers and is complete, provide, where applicable, a detailed breakdown of how your company calculated the legislated roaming cap using the table provided in attachment 2.

Common approach for the calculation - To all wireless carriers

15. With respect to the calculation of the wholesale domestic roaming caps and in order to achieve consistency across all wholesale roaming providers, provide the company’s view on whether there should be a standardized and uniform approach. If not, explain why not with supporting rationale and identify what elements / methodologies / approaches that could not be applied in a consistent manner.

Distribution list:

Bell Mobility Inc., bell.regulatory@bell.ca
Bell Aliant Regional Communications, Limited Partnership, regulatory@bellaliant.ca
TBayTel, rob.olenick@tbaytel.com
Huron Telecommunications Co-operative Limited, grubb@hurontel.on.ca
Hay Communications Co-operative Limited, a.schneider@hay.net
Rogers Communications Partnership, rwi_gr@rci.rogers.com
TELUS Communications Company, regulatory.affairs@telus.com
MTS Inc., iworkstation@mtsallstream.com
Lynx Mobility Inc., aahmed@lynxmobility.com
Execulink Telecom Inc., jonathan.scott@execulink.com
Videotron G.P., regaffairs@quebecor.com
Wightman Telecom Ltd., kgugan@wightman.ca
Quadro Communications Co-operative Inc., barry.stone@quadro.net
Bragg Communications Incorporated (EastLink), regulatory.matters@corp.eastlink.ca
Sogetel Mobilité inc., sophie.houde@sogetel.com
SSI Micro Ltd., regulatory@ssimicro.com
Brooke Telecom Co-operative Ltd., jim@brooketel.ca
Ice Wireless Inc., regulatory@icewireless.ca
Dryden Mobility, jsalina@dryden.ca
Fido Solutions Inc., regulatory.aff@fidomobile.ca
Saskatchewan Telecommunications, document.control@sasktel.com
Télébec, Limited Partnership, reglementa@telebec.com
KMTS, reglementa@telebec.com
Mornington Communications Co-operative Limited, rbanks@mornington.ca
NorthernTel, Limited Partnership, reglementa@telebec.com
Globalive Wireless Management Corp. (WIND), lisajackson@globalive.com
Data & Audio Visual Enterprises Wireless Inc. (MOBILICITY), gary.wong@mobilicity.ca

Date modified:

2014-12-29