I am writing you regarding the proposed purchase of MTS by BCE. I have several levels of concern specifically regarding competition.
1. The allocation of wireless spectrum in Manitoba is the top concern of mine. As MTS was not a national wireless company it was allowed to bid on and acquire wireless spectrum that had been set aside for "new entrants" such as Wind Mobile, Moblicity, etc. As Bell was at the time its own separate company it was allowed to also bid on spectrum which it won. As part of the proposed purchase I strongly hope the ownership of wireless spectrum of the combined BCE and MTS will be reviewed in depth to specifically ensure that wireless spectrum allows a fourth carrier to enter the Manitoba market at some point. I feel that the concentration of wireless spectrum between BCE and their close partner Telus in Manitoba would pose a significant and long term barrier to additional competition in the market without action on this front.
2. In terms of current wireless customers BCE has proposed transferring 1/3 of the existing MTS customers to Telus. It is concerning that the specific details of how customers will be assigned has not be published. It is also concerning that the exact financial terms of this deal are not part of the information made public by BCE. It is even more concerning that the proposed transaction from move both Telus and BCE from each having under 10% of the wireless customers in Manitoba to nearly equal positions with Rogers, creating a pretty even three sided market. On this front, I feel it would benefit both competition and the residents of Manitoba if the 1/3 of customers to be transferred need to be divested with supporting wireless spectrum to a "new entrant", as in a company other than BCE, Telus or Rogers.
3. Having both Telus and BCE with under 10% of the market is actually a significant contributor to the current wireless rates in Canada which are well below the Canadian average and near the best the in the world. While the current Manitoba wireless rates are low they also offer significant revenue to the companies providing service suggesting these rates are sustainable over the long term. To help ensure that wireless rates in Manitoba continue to remain competitive and reflecting the local conditions of the market I would like to request that increases to wireless rates by BCE in Manitoba be subjected to the approval of the Manitoba Public Utilities Board, or similar organization, for a period of not less than 10 years. At the end of 10 year period this restriction would be open to being lifted but only after another review and public comment period.
4. On the high speed Internet service side I am hoping it can be clarified in written direction from the competition board that BCE must open all their data networks, including all forms of DSL, fiber and any future technology, to third parties wishing to use the networks to provide service. This would mirror the recent CRTC ruling and the appeal that was declined today (May 11, 2016) as linked below. Having this is writing as a permanent condition on BCE would further expand the possibilities of competition in Manitoba as the MTS network is currently not available to third parties.
Ottawa rejects BCE appeal; must give small players Internet access - The Globe and Mail
5. In light of the ruling on opening the data network to third parties it is concerned that BCE will limit network upgrades in Manitoba. To this front it is desired that a special levy be applied to high speed internet customers to create a fund for infrastructure upgrades. Due to the cost difference in providing service I would propose creating two separate funds for these upgrades in Manitoba one for urban customers and one for rural customers. These funds would be billed as a separate line item on customers monthly bills specific to network upgrades. Having funds specifically set aside for upgrades is hoped to further encourage BCE to make network upgrades in Manitoba an on-going commitment and not a one-time promise of $1 billion over five years.
6. Similar to separating out the cost of the network upgrade above, it is desired to require BCE to split the cost of wireless hardware (phone purchase) and wireless service into separate line items on customers monthly bills. By having these items split will open the wireless hardware (phone) market to additional competition as customers will no longer be penalized with higher monthly service costs when they bring their own device as they are today across all carriers including MTS and BCE. For example a customer selecting a new iPhone was $20 from their bill allocated to the cost of that hardware purchase however a customer purchasing their own iPhone would only receive a $10 bill credit.
On a whole, I feel the BCE proposed purchase of MTS will be a step forward but I also feel some conditions need to be put in place to ensure a fair and open competitive market in Manitoba in both the short and long term after this deal closes.