Telecom Procedural Letter addressed to Mr. Matthew Boswell (Competition Bureau)
Ottawa, 25 March 2019
Our reference: 1011-NOC2019-0057
Mr. Matthew Boswell
Commissioner of Competition
50 rue Victoria
Gatineau, Quebec, K1A 0C9
RE: Review of mobile wireless services, Telecom Notice of Consultation 2019-57 – Procedural Request of the Commissioner of Competition – seeking the issuance of a request for information
Dear Mr. Boswell:
The Commission is in receipt of your letter, dated 8 March 2019, sent in your capacity as Commissioner of Competition (Commissioner).
In that letter, the Commissioner proposes to conduct three economic analyses, with the help of certain economists – namely, a Cross-Section Analysis, an Event Study Analysis, and Structural Models. The Commissioner submits that these analyses will address the questions posed by the Commission with respect to the Canadian mobile wireless market in Telecom Notice of Consultation 2019-57 (the proceeding).Footnote1
In order to perform these analyses, the Commissioner requests that the Commission:
- issue a request for information to wireless service providers (WSPs);Footnote2 and
- disclose, or require disclosure to the Commissioner of, any information filed in response that is designated as confidential pursuant to paragraph 39(4)(b) of the Telecommunications Act.
The purpose of this letter is to seek clarification with respect to subparagraph (i), above. The issue of disclosure will be dealt with subsequently.
The Commissioner submits that steps were taken to ensure that the information sought in the request is relevant, targeted and probative.
Commission staff acknowledges the Commissioner’s interest regarding competition issues as well as its desire to participate meaningfully in this proceeding through the preparation and filing of economic analyses.
At the same time, the information sought by the Commissioner consists of highly detailed information to be provided on a very granular level and covering a broad range of subjects over a significant period of time.
Commission staff notes that the Commission’s last in-depth review of mobile wireless services took place in 2015.Footnote3 A principal purpose of the current proceeding is to review changes to the state of mobile wireless services since that time. Accordingly, it may be appropriate that the Commissioner explore ways to further tailor the information sought; for example, by focusing on information that is more recent.
Commission staff therefore respectfully requests that the Commissioner review the procedural request with a view to refining the information sought in order to ensure that the information is unconditionally necessary for the Commissioner to effectively address the competition issues relevant to this proceeding.
In the alternative, Commission staff respectfully requests that the Commissioner elaborate on how the information being sought, as currently framed, is reasonably necessary to allow the Commissioner to “provide the CRTC with important economic evidence to assist it in assessing the state of competition across various Canadian wireless markets and how certain policy changes would likely affect outcomes in those markets” (Commissioner’s letter of 8 March 2019, para. 21).
Commission staff further respectfully requests a response to this letter be received by 1 April 2019.
Director, Competition and Emergency Services Policy
c.c.: Laura Sonley, Competition Bureau, firstname.lastname@example.org
Jeremy Lendvay, CRTC, 819-997-4946, email@example.com
Adam Mills, CRTC, 819-995-4574, firstname.lastname@example.org
Sylvie Labbé, CRTC, 819-953-4945, email@example.com
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