Broadcasting - Staff Letter adressed to Monica Auer ( Forum for Research and Policy in Communications )
Ottawa, 2 March 2023
Our reference: 1011-NOC2022-0267
BY EMAIL
Monica Auer
Executive Director
Forum for Research and Policy in Communications
Ottawa, Ontario
execdir@frpc.net
Subject: Call for comments on an application by Bell Canada, Cogeco Communications Inc., Bragg Communications Incorporated, carrying on business as Eastlink, and Saskatchewan Telecommunications regarding the increase of the maximum retail price of the basic service, Broadcasting Notice of Consultation CRTC 2022-267 (Ottawa, 28 September 2022), 2022-267-1 (Ottawa, 27 October 2022), 2022-267-2 (Ottawa, 17 November 2022) and 2022-267-3 (Ottawa, 20 February 2023)
Monica Auer:
Commission staff acknowledges receipt of the procedural request submitted by the Forum for Research and Policy in Communications (FRPC) on 23 February 2023 with respect to the above-noted proceeding regarding the clarification of subscriber information identified at paragraph 11 of Broadcasting Notice of Consultation 2022-267-3 (BNC 2022-267-3) dated 21 February 2023.
FRPC’s requests
FRPC highlighted potential discrepancies between the information requested by the CRTC and what the broadcasting distribution undertakings (BDUs) provided with respect to the number of subscribers who could be subjected to an increase in their monthly bill if the application were approved.
FRPC therefore requested that the Commission return to the majority of the BDUs with an additional request to: 1) resubmit the number of subscribers based on the definition of “basic service” in the BDU Regulations; and 2) to clarify any difference between the number of subscribers to whom they provide the basic service and the direct subscribers to basic services reported in the aggregated annual return for 2022.
Staff analysis
After examining FRPC’s request, staff notes that your attempt to reconcile the available data may be impacted by a potentially erroneous assessment of both the filing requirements for the annual aggregate returns and the public versions of the reports.
In particular, please note that the subscriber figures reported by the BDUs in their annual aggregate returns reflect their entire subscriber base. The information that they provided in response to our requests for information as part of BNC 2022-267 is a subset of what is provided in the aggregate returns and only represents the total number of subscribers the BDUs claim could have to pay more should the Commission approve the change requested in the application. As such, reconciling these figures may prove to be unsuitable for the purposes of the current proceeding.
Moreover, as per Broadcasting Regulatory Policy CRTC 2009-560, public disclosure of aggregate financial data is limited to owners of large BDUs, multi-system operators and conventional television and radio ownership groups. The Commission has been mindful of this policy in making its determinations with respect to confidentiality in the context of this proceeding and has been particularly mindful of any disclosure that may permit interested parties to derive or reverse-engineer this sensitive information and obtain information that would be otherwise held by the Commission in confidence.
Staff thanks FRPC for its letter, which has provided us the opportunity to make these clarifications. Final replies were received on 28 February 2023 and the proceeding is now closed.
Sincerely,
Scott Shortliffe
Executive Director
Broadcasting
cc. Jonathan Daniels, Bell Canada, bell.regulatory@bell.ca
Paul Beaudry, Cogeco, telecom.regulatory@cogeco.com
W.N. Beckman, SaskTel, document.control@sasktel.com
Frédérique Couette, Quebecor, frederique.couette@quebecor.com
Simon Desrochers, Cogeco, telecom.regulatory@cogeco.com
Pamela Dinsmore, Rogers, pam.dinsmore@rci.rogers.com
John Lawford, jlawford@piac.ca
Lecia Simpson, Telus, regulatory.affairs@telus.com
Peggy Tabet, Quebecor, peggy.tabet@quebecor.com
Cynthia Wallace, Shaw, regulatory@sjrb.ca
Marielle Wilson, Eastlink, regulatory.matters@corp.eastlink.ca
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