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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 10 July 2023

Our reference: 1011-NOC2023-0048

BY E-MAIL 

To: Distribution List

Subject: Telecom Notice of Consultation CRTC 2023-48, Call for comments - Facilities-based wholesale mobile virtual network operator (MVNO) access tariffs – Considering the inclusion of additional retail market segments – Requests for information

On 1 March 2023, the Commission issued a notice of consultation 2023-48 seeking comment from interested parties on the competitiveness of the enterprise and Internet of Things (IoT) / machine-to-machine (M2M) retail market segments. To clarify and develop the record of this proceeding, the parties identified in the distribution list are to file responses to the questions set out in the Attachment by 9 August 2023.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Yours sincerely

Original signed by Jeremy Lendvay for

Philippe Kent
Director, Telecommunications Services Policy
Telecommunications sector

cc: Jeremy Lendvay, CRTC, 819-997-4946, jeremy.lendvay@crtc.gc.ca   
Allison McLean, CRTC, 819-661-6588, allison.mclean@crtc.gc.ca

Requests for Information 

Parties have proposed on the record various definitions for IoT/M2M services. For the purpose of responding to these requests for information in relation to the wholesale MVNO access framework, “cellular IoT/M2M services” refer to services provided to retail customers that allow IoT/M2M devices to communicate with each other and/or with various applications in a fully or partially automated way using mobile wireless networks (e.g. 2G, 3G, 4G & 5G).

In addition, for the purpose of responding to these requests for information in relation to the wholesale MVNO access framework, “enterprise services” refer to medium -to large -sized businesses, institutions, and other enterprise customers with 100 or more employees.

Questions to all parties (identified in the Distribution List)

  1. Rogers Communications Canada Inc. (RCCI) and TELUS Communications Inc. (TCI) submitted that enterprise customers effectively do not have switching costs. Others, including Quebecor Media Inc., on behalf of Videotron Ltd. (Videotron), suggested that switching costs are considerable. In your experience, are there costs associated with enterprise customers switching service providers, such as costs associated with breaking existing contracts, training employees, reconfiguration of equipment, administrative costs, etc.? If so, identify the specific types of costs and indicate the typical amount of those costs.
  2. In your experience, are there costs associated with switching mobile wireless providers with respect to cellular IoT/M2M devices, such as costs associated with breaking existing contracts, training employees, reconfiguration of equipment, administrative costs, etc.? If so, identify the specific types of costs and indicate the typical amount of those costs.

Questions for all Canadian Wireless Carriers identified in the distribution list [Bell Mobility Inc. (Bell Mobility), Cogeco Communications Inc. (Cogeco), Bragg Communications Inc, carrying on Business as Eastlink (Eastlink), ECOTEL inc., Iristel Inc. on behalf of itself and its affiliate Ice Wireless (Ice Wireless), RCCI, Saskatchewan Telecommunications (SaskTel), Sogetel inc., TCI, Transatel, and Videotron]

For the following questions, provide your response in excel format using the template provided in Table A. Include all assumptions.

Table A

   
Brand Province/Territory 2018 2019 2020 2021 2022 2023 2024
                 
  1. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023 and 2024, for each province/territory, and for each brand your organisation operates: (i) the number of wireless enterprise accounts; (ii) total wireless lines for all enterprise accounts; and (iii) total wireless revenues from wireless enterprise accounts.
  2. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023 and 2024, for each province/territory, and for each brand your organisation operates: (i) the number of cellular IoT/M2M accounts; (ii) total wireless SIM/eSIM/device subscriptions for all cellular IoT/M2M accounts; (iii) the average rate charged per gigabyte; and (iv) total wireless revenues from cellular IoT/M2M accounts.
  3. Provide, for each of the years 2018 to 2022, as well as 2023 to date, for each province/territory, and for each brand your organisation operates: (i) the number of wireless enterprise accounts gained; (ii) the number of wireless enterprise accounts lost; and (iii) the total revenue gained or lost from those accounts. Include the number gained/lost from other wireless carriers, where known, with separate totals for each wireless carrier, and whether this was as the result of a Request for Procurement (RFP).
  4. Provide, for each of the years 2018 to 2022, as well as 2023 to date, for each province/territory, and for each brand your organisation operates: (i) the number of cellular IoT/M2M accounts gained; (ii) the number of cellular IoT/M2M accounts lost; and (iii) the total revenue gained or lost from those accounts. Include the number gained/lost to other wireless carriers, where known, with separate totals for each wireless carrier, and whether this was as the result of an RFP.
  5. TCI submitted that many enterprise customers outsource negotiations to “specialized procurement companies that seek to extract concessions from telecom service providers like TELUS, while optimizing the usage of telecom services in order to decrease the amounts paid for those services.” Comment on your organisation’s experience with procurement companies. Where possible, provide specific examples of customers who used these services to negotiate lower rates, including supporting documentation.

Questions for Incumbents [Bell Mobility, RCCI, SaskTel, and TCI]

  1. Several parties listed various Canadian and non-Canadian IoT/M2M service providers operating in Canada. Bell Mobility, RCCI and TCI, suggested that the existence of these carriers providing IoT/M2M service in Canada, whether as MVNOs, resellers, or via roaming agreements, is an indicator that there is sufficient competition in the IoT/M2M market. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of non-Canadian wireless carriers with which your organisation has an agreement that provides access to your network for the purpose of cellular IoT/M2M services; (ii) the number of cellular IoT/M2M SIM/eSIM cards and devices active on your network associated with those agreements; (iii) the average rate per gigabyte charged; and (iv) total revenues for cellular IoT/M2M services under those agreements.
  2. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of Canadian wireless carriers with which your organisation has an agreement that provides access to your network for the purpose of cellular IoT/M2M services; (ii) the number of cellular IoT/M2M SIM/eSIM cards and devices active on your network associated with those agreements; (iii) the average rate per gigabyte charged; and (iv) total revenues for cellular IoT/M2M services under those agreements.
  3. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of non-Canadian wireless carriers with which your organisation has an agreement that provides access to your network for the purpose of wireless enterprise services; (ii) the number of enterprise devices active on your network associated with those agreements; (iii) the average rate charged; and (iv) total revenues for wireless enterprise services under those agreements.
  4. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of Canadian wireless carriers with which your organisation has an agreement that provides access to your network for the purpose of wireless enterprise services; (ii) the number of enterprise devices active on your network associated with those agreements; (iii) the average rate charged; and (iv) total revenues for wireless enterprise services under those agreements.

Questions for Competitor Wireless Carriers [Cogeco, Eastlink, Ecotel, Iristel, Sogetel, Transatel, and Videotron]

  1. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of agreements you have that grant you access to a host network for the purpose of providing cellular IoT/M2M services; (ii) the number of cellular IoT/M2M SIM/eSIM cards and devices active on the host network; (iii) the average rate charged per gigabyte; and (iv) the total costs for access to the host network.
  2. Provide, for each of the years 2018 to 2022, as well as forecasts for 2023, for each province/territory, and for each brand your organisation operates: (i) the number of agreements you have that grant you access to a host network for the purpose of wireless enterprise service; (ii) the number of enterprise devices active on the host network; and (iii) the total costs for access to the host network.
  3. If your organisation has attempted unsuccessfully to negotiate an MVNO agreement with an incumbent for wireless enterprise or cellular IoT/M2M services, explain the circumstances of those negotiations and why those negotiations were unsuccessful.

DISTRIBUTION LIST

TCI, regulatory.affairs@telus.com
Bell Mobility, bell.regulatory@bell.ca
RCCI, regulatory@rci.rogers.com
SaskTel, document.control@sasktel.com
Videotron, regaffairs@quebecor.com
PIAC, jlawford@piac.ca
Eastlink, regulatory.matters@corp.eastlink.ca
ECOTEL, eric@eco-tel.co
CNOC, regulatory@cnoc.ca
Cogeco, telecom.regulatory@cogeco.com
Iristel, regulatory@iristel.com
ITPA, jonathan.holmes@itpa.ca
PSBN Innovation Alliance, phil.crnko@haltonpolice.ca
Sogetel, richard.biron@sogetel.com
Transatel, stephane.puyraveau@transatel.com
Vaxination Informatique, jfmezei@vaxination.ca

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