So UBB is here, must be implemented by March 1, and will only allow for a wholesaler discount of 15%… There’s got to be a way to fight this!
Here’s the CRTC’s decision on the UBB implementation:
Commission’s analysis and determinations
9. The Commission notes that carriers’ retail UBB rates are market-based and are not subject to prior Commission approval – that is, they are forborne from regulation. The Commission also notes that the flat-rate component of the carriers’ retail Internet service rates recovers most, if not all, of the associated retail UBB costs. In the Commission’s view, this situation provides carriers with the flexibility to adjust or waive retail UBB rates on a promotional basis.
10. However, the Commission considers that, for competitors, carriers’ wholesale UBB rates are an additional, direct, and unavoidable cost that competitors will need to recover from rates paid by their retail customers. The Commission also considers that wholesale UBB charges will result in additional customer care costs for competitors, including a review of the relevant carrier’s wholesale usage records and associated UBB charges.
11. Further, the Commission notes its view in Telecom Regulatory Policy 2010-632 that services provided by smaller competitors bring pricing discipline, innovation, and consumer choice to the retail Internet service market. The Commission considers that, in the absence of a discount on carriers’ wholesale UBB rates relative to their comparable retail UBB rates, smaller competitors’ ability to continue to differentiate their retail Internet services would be unduly impaired.
12. In light of the above, the Commission concludes that wholesale UBB rates should be established at a discount relative to carriers’ comparable retail UBB rates and that, in the absence of such a discount, the wholesale UBB rates would not be just and reasonable, contrary to subsection 27(1) of the Telecommunications Act (the Act).
13. Regarding the amount of the wholesale UBB discount, the Commission considers that if it is too large, the effectiveness of UBB as an economic ITMP will be reduced, while if it is too small, competitors’ capacity to recover costs will be undermined.
14. The Commission concludes that a discount of 15 percent for carriers’ wholesale UBB rates relative to their retail UBB rates recognizes these considerations appropriately.
Implementation
15. CNOC requested a minimum period of 90 days for implementation. The Bell companies submitted that implementation of the determinations in this decision must not delay the implementation of wholesale UBB rates as set out in Telecom Decision 2010-802. The Bell companies also submitted that they would require 60 days from the date of this decision to implement any required changes to their billing systems.
16. The Commission notes that wholesale UBB rates were approved for the Bell companies in Telecom Decision 2010-255, which was issued on 6 May 2010. The Commission considers that wholesale UBB rates for GAS should be implemented by the Bell companies without undue delay. The Commission considers that the Bell companies’ proposed period for the implementation of discounted wholesale UBB rates is unduly long.
17. Accordingly, the Commission directs the Bell companies, as well as cable carriers with tariffed UBB rates for TPIA services, to implement discounted wholesale UBB rates on the basis set out in this decision, by 1 March 2011. The Commission further directs carriers whose wholesale tariffs contain UBB rates to issue revised tariffs reflecting the determinations in this decision, by 1 March 2011.
You can see the full text of it here: Telecom Decision CRTC 2011-44
