On the first point that wholesale roaming fees directly affect the way Canadians select and use their wireless devices and therefore affect retail competition, where unreasonably high wholesale roaming rates, or restrictive terms and conditions are imposed by one carrier on another, these rates are inevitably passed through to consumers as retail charges. Canadian consumers, on their end, are more reluctant to subscribe to carriers if they face significant prices for domestic roaming. Wholesale rate regulation is intended to address this problem.
Our second point is that high roaming rates have been impairing the goal of promoting wireless competition, so we therefore welcome measures to address that threat. As the Commissioner of Competition recently noted, the incumbent service providers have “market power”, and that the marketplace is “characterized by other factors that, when combined with high concentration and very high barriers to entry and expansion, create a risk of coordinated interaction in these markets.” This has been a real problem in recent years with smaller competitors being charged unreasonable, unsustainable roaming rates that were orders of magnitude higher than the rates the big three charged each other for roaming, and higher than rates that even the smaller competitors could get for roaming in the U.S. from major U.S. carriers.
Rightly so, therefore, the CRTC has just held a public proceeding to determine whether the rates being charged for wholesale roaming are unjustly discriminatory under the Telecommunications Act. In addition, the CRTC is in the midst of another public process to examine other broad issues affecting wireless competition, including tower-sharing and network-sharing agreements.
John.