Our first point is that the rate formula in the bill, while a step in the right direction towards greater fairness in roaming rates, will pass on the high prices that incumbents can charge their own customers by virtue of their market power.
There are a number of ways that telecom regulators set wholesale rates. What this bill proposes is a simple application of average retail rates to wholesale. Basically the rates being charged to the incumbent's own retail customers become the wholesale rate the competitors will pay so that their customers can roam on incumbents' networks.
This is a rough and ready way to approximate what the going rate is for voice, text, or data, but what it doesn't do and what the CRTC will be doing in an open and public process is assess whether the going rate is fair under the Telecommunications Act, in light of the market power that the incumbents have.
However, we recognize that this may be an acceptable approach in the interim, given the urgency and importance of the issue, as the big three retrench and the remaining competitors struggle or consider whether to even enter the market nationwide.
Our fourth point is that amending the Telecommunications Act before the CRTC has finished its review is not the preferable way to achieve the result being sought. We would have preferred the government to leave the CRTC to pursue its mandate of setting rates and regulating the wireless market. Given the situation described in our first point about the market situation, however, we understand the purpose of the approach and suggest that quick targeted amendments made in the absence of the regulators' full review of issues not become a frequent practice, as it may eventually undermine the authority of the CRTC.
Those are our remarks, Mr. Chair. Thank you.