GATINEAU – When the CRTC launched its review of mobile wireless services earlier this year it stated: “This proceeding will focus on three key areas: Competition in the retail market; The current wholesale mobile wireless service regulatory framework, with a focus on wholesale MVNO access and the future of mobile wireless services in Canada, with a focus on reducing barriers to infrastructure deployment.”
This focus on Mobile Virtual Network Operators sure did not fall in deaf ears – and some players jumped right in with strong support since the high cost of entry into the wireless business means many players cannot participate as they would like.
CNOC and its members Distributel, TekSavvy and Ice Wireless, for their part, are proposing a Full MVNO mandate from the CRTC because they believe the Big Three of Rogers, Bell and Telus need to be reined in and a Full MVNO, where the operator has something of its own core network, is the way to do it.
“At a high level, a Full MVNO service provider is an MVNO that operates its own core network and has a service profile management system,” the CNOC intervention reads. “Unlike other MVNO variants, Full MVNO service providers are able to operate with the largest degree of autonomy as they are responsible for all aspects of their operations except for those related to the operation of radio access network,” they conclude.
MVNOs which merely provide service by leasing all of its connectivity from another have no autonomy over their connections to customers.
The CNOC members’ proposal is very similar to the HMNO idea from Cogeco – except that Cogeco’s model applies to companies that have facilities, like Xplornet, Sogetel and potentially, TekSavvy.
CNOC also worked with the Canadian Communication System Alliance and the Independent Telecommunications Providers Association to co-sponsor expert evidence to support their thesis, too.
“CCSA strongly supports mandated wholesale access to the facilities required to enable competitive entry by MVNOs, including facilities-based telecommunications carriers such as the vast majority of CCSA members are today,” reads its submission.
“To set a predetermined date for forbearance to occur, commonly known as a sunset clause, is not an economically sound policy and will potentially deter full MVNOs from entering the market at all.” – CNOC
CNOC et al also oppose the Commission’s idea that mandated MVNOs on the national wireless carriers should be in place for a limited amount of time only and be subject to a phase-out period as market forces take hold. “To set a predetermined date for forbearance to occur, commonly known as a sunset clause, is not an economically sound policy and will potentially deter full MVNOs from entering the market at all,” reads the CNOC application.
To this question, an amalgam of consumer groups aptly named the Coalition for Cheaper Wireless Service (CCWS) states that: “The CCWS is dismayed that this question is even asked. To us, it sounds just like: [CRTC, to the broadcasting industry in the late 1960s] “Should colour television be phased out in the next 5 years?”
CCWS is comprised of Public Interest Advocacy Centre (PIAC), ACORN Canada, National Pensioners Federation, and CARP (formerly Canadian Association of Retired Persons).
“To our knowledge, in every other market where mandated MVNO access has been permitted it has not been sun-setted, nor removed by the regulator. Instead it continues, once introduced, as a valuable aspect of a well-functioning retail mobile wireless market,” adds the CCWS submission.
The Competition Bureau is noncommittal when it comes to the idea of MVNOs. “The Bureau cannot at this time opine on whether MVNO access is a warranted regulatory shift,” says its submission.
Of course, it wants more data to investigate the idea fully (a bureaucratic tiff we’ve been covering) but more importantly they like what they see with Freedom and Eastlink, who “provide natural experiments to understand whether existing policies aimed at promoting facilities-based competition are showing promise of disrupting the status quo in Canada.”
The Bureau concludes saying “without further information, a finding regarding whether Freedom and Eastlink are, in fact, disrupting coordination between the national wireless carriers will be more subjective based on qualitative evidence.”
The MVNO model continues to evolve, it would seem and reactions to these initial proposals will be interesting.
The record should be completed by 23 October 2019 and the hearing will be held on 13 January 2020.
