Thank you very much, Mr. Chairman. I believe you've been given some speaking notes from me that set out the substantive and technical objections we have to a proposed direction. I don't propose to read those speaking notes. They're too long to meet the minutes. I'm going to try to compress the main points into my address.
In general, we find the direction to be unnecessary, potentially outside the power of the minister and disruptive to the proper functioning of a regulatory agency. For better or for worse, the commission has set a course for transition to competitive markets where possible and has got out of the business of regulating most telecommunications services. There is enough competition to protect consumers.
The CRTC, by its current legislative mandate and practice, must let go of regulation. The fuss that now comes about is because the big telephone companies think they should be deregulated sooner than the commission does. What deregulation will let them do is what they call one-on-one marketing, and that's to charge rates and give services to a customer, much in the same way the banks do now. If your constituents like that kind of treatment, namely the bigger the customer, the more urban the location, the better the price and the service, then they'll be ecstatic with the plans of the big telephone companies. If you don't want the CRTC to worry about things like whether there is actual competition to protect consumers, then this direction may be very appealing. If your constituents live in a small town, you may wish to ask yourself if they're going to be happy with increases to pay for discounts to customers in denser urban areas, particularly if there's not enough competition to discipline the provider.
I would add that most Canadians don't like this idea of carte blanche to telcos. Our survey shows that only 20% back the big telephone company plans, and a majority don't even think the CRTC test of one cable provider is enough.
This direction is supposedly modelled on the recent telecommunications review panel report. It actually only reflects certain sections of that report. It leaves out whole sections of improvements to consumer protection by way of a new agency, a special review of competition-based matters, and more resources to the commission.
As well, we believe the wording of this direction is excessive and potentially biased. With respect, in its current form, this direction reads a little bit like a free enterprise version of Mao Tse-tung's little red book. Look at the language: “Rely on market forces to the maximum extent possible”; “Provide for maximum efficiency”; “Each regulatory measure shall demonstrate compliance with the policy direction”, etc. All that's missing is a slogan like “Let 100 flowers bloom”, or “The collective must meet its quota”. This is ideology, not economics, and from experience, this rarely works.
It's not good policy, and possibly without proper jurisdiction, to jump in on one aspect of the commission's mandate and objectives and try to make everything bend to a view of that one aspect.
I understand why the big telephone companies want to do this, but in my view it's shortsighted. You shouldn't corrupt powers and objectives given by legislation to an independent body by insisting they feature the flavour of the month. What happens if a public outcry about the industry moves a minister to issue a direction that the needs of an average consumer should take precedence over carriers? Is that good regulation? How do you apply something like that to the power set out in the act?
Coming back to this case, why is it reasonable to make everything else in the act, like consumer access, affordability, regional economic development, and culture subordinate to the deregulate decision in the act? The big problems in the industry don't come from the regulated remnants. They come from the parts that have never been regulated.