Telecom Commission Letter addressed to the Distribution List

Ottawa, 6 September 2019

Our reference: 1011-NOC2019-0057

BY EMAIL

Distribution list

RE:  Telecom Notice of Consultation CRTC 2019-57, Review of mobile wireless services – disclosure of aggregated information regarding wholesale mobile wireless services revenues

Dear Madam, Sir:
In a letter dated 16 August 2019, Commission staff indicated that it planned to provide, for the public record, aggregated wholesale mobile wireless revenuesFootnote1 on a national basis for each of the years 2014-2018. The wholesale services categories reported by parties included revenues related to roaming services, tower and site sharing, MVNOs, and “other” wholesale services.
Parties did not object to the disclosure of aggregated revenues related to roaming services, tower and site sharing, and MVNOs. 

However, Bell Mobility, SaskTel and TELUS, in separate letters dated 30 August 2019, raised concerns over the disclosure of “other wholesale revenues”, even on an aggregated national basis. They indicated that the information they reported for this category consists almost entirely of revenues associated with their mutual network reciprocity arrangements and argued that, given the limited number of other such arrangements in existence, a competitor could easily deduce the magnitude of these arrangements by backing out its own amount. They argued that this information is highly sensitive and that its disclosure would cause significant competitive harm that outweighs any public benefits.

In this specific case, staff agrees that the potential harm from disclosure outweighs any potential benefits. As such, staff will limit the disclosure of aggregated wholesale revenues to roaming services, tower and site sharing, and MVNOs. In staff’s view, this information, in conjunction with other information disclosed on the public record, is sufficient to provide parties with meaningful insight into wholesale activities and trends with a view to preparing subsequent submissions that will better serve to inform the Commission’s deliberations on issues addressed in this proceeding.

Sincerely,

Original signed by

Philippe Kent
Director, Policy
Telecommunications Sector

Distribution List: All parties to 2019-57

Appendix 1

Total wholesale mobile wireless services revenues ($M)

- 2014 2015 2016 2017 2018
Roaming services $29.3 $58.8 $87.4 $91.0 $81.4
Tower and site sharing $60.6 $64.0 $66.3 $69.5 $71.4
MVNOs $31.8 $34.2 $36.7 $37.8 $37.3
Total $121.6 $157.0 $190.4 $198.3 $190.1
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