March 23, 2021

ATTN: Competition Bureau Canada
Matthew Boswell, Commissioner of Competition

RE: Rogers Acquisition of Shaw

The Competition Bureau report (submitted as a part of CRTC 2019-57) extensively describes the conditions and evidence of coordination between the dominant incumbent carriers. It also explicitly supports regional providers, describing them as “wireless disruptors” and extolling their positive impact on pricing and competition where they provide service.

Shaw’s Freedom Mobile was the last regional provider with national ambitions and service in three provinces. Mobilicity and Public Mobile have already been absorbed by incumbent carriers. Freedom Mobile is the final ‘new entrant’ from the 2009 infrastructure competition cohort to be absorbed by a large incumbent, along with Shaw’s other lines of business.

As we submitted in our own CRTC 2019-57 interventions, infrastructure competition is a self-fulfilling prophecy that results in consolidation given the cost to build a radio access network (RAN) and the inefficiency of multiple overlapping and competing RANs. Bell and Telus sharing each other’s networks to provide national service is a perfect example of this. Rogers acquisition of Shaw is further proof.

A separation between infrastructure and retail service preserves focus and investment into infrastructure while allowing for greater diversity in pricing and fosters service innovation.

The best way to separate these two elements is through virtual operators who manage their own core network and interconnect to one or more radio access networks, also known as Full MVNOs.

A Full MVNO requires meaningful investment into core network infrastructure and pays a fair wholesale rate for use of radio access networks. This investment into the core network is what unlocks differentiation and innovation of pricing and service.

We are but one example of the competition and innovation that Full MVNOs could bring to everyone in Canada, no matter who they are or where they live.

With the final “wireless disruptor” being purchased by one of the incumbent telecom giants, the Competition Bureau must support Full MVNOs as the best solution to today’s diminishing competition, high prices and suppressed mobile data usage.

We are including our original response to the Competition Bureau report and the supporting economic studies for Telecom Notice of Consultation CRTC 2019-57 for reference.

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