Thank you, Mr. Chairman, and members of the committee. Shaw certainly welcomes the opportunity to appear before your committee to provide its views on the government's initiatives in the local telecommunications market.
Shaw has publicly stated its support for the minister's order and directive because these initiatives recognize that consumers must come first. Canadian consumers can best be served by an approach that relies on market forces and facilities-based competition. The minister's initiative implements these principles, and consumers across Canada stand to benefit. However, Shaw believes that three issues must be addressed in the order.
The first is interconnection and access to rights of way and support structures. Interconnection to the public telephone system and access to support structures and rights of way are the foundation of facilities-based competition. Without interconnection, facilities-based competitors cannot serve their customers. Without access to the telephone companies' poles and conduits, we cannot build out our own networks. Timely and effective interconnection arrangements and access are therefore necessary for durable facilities-based competition. However, arbitrary delay and denial of access and interconnection are not uncommon in our business.
In order to be consistent with its policy of promoting facilities-based competition and to ensure that consumers realize the full benefits of the proposed order and directive, the government must direct the CRTC to ensure that facilities-based entrants are able to obtain efficient, timely, and effective interconnection and access to the support structures and rights of way we need to build our networks.
The second issue is winbacks. The proposed order provides for the immediate removal of winback restrictions. The telephone companies want forbearance in order to be able to win back customers through targeted marketing initiatives. The telephone companies have little or no interest in implementing broad-based price reductions for their local services; it is removal of the winback restrictions that the telcos really want, in order to retain their dominant market share. It is not forbearance. Shaw believes, therefore, that the winback restrictions should not be removed until such time as the criteria for forbearance have been satisfied.
The final issue is the need for a level playing field for telcos and cablecos. If cable is to compete effectively while delivering full benefits to consumers, then existing regulatory restrictions on cable companies must be made more flexible. At present, cable companies are subject to an extensive regulation under the Broadcasting Act. This regulation restricts their ability to respond to consumer demand. These regulations should be reviewed and replaced to the maximum extent possible by market forces. This will ensure that cable companies have full flexibility to compete aggressively with the telephone companies. More importantly, it will ensure that consumers realize the maximum benefits from competition.
In conclusion, Shaw supports the proposed order and the minister's directive; however, the three changes that we have put forward will, we believe, allow consumers to fully benefit from the minister's approach.
Thank you very much.