OTTAWA – Lower wireless infrastructure investments could be the result of Industry Canada’s proposals to adopt indefinite roaming and eliminating the difference between in-territory and out-of-territory roaming, warn some mobile carriers.
The cautionary notes come from Bell Canada, SaskTel and Telus Corp. in comments to the department’s consultation on changes to mandated roaming and tower site sharing. They urge Industry Canada to think hard before making these changes because they could have the unintended consequence of decreasing overall wireless network investment in both urban and rural areas across the country.
SaskTel is particularly concerned that if the mandated roaming rules are adopted as proposed, the company could find itself having to provide roaming to carriers (with revenues upwards of 10 times larger) that were previously uninterested in investing in Saskatchewan. The company adds the big push from the federal government to ensure that residents and businesses in rural Canada enjoy the same level of wireless service as those in urban Canada could also be in jeopardy.
“Many companies expanded their facilities coverage to less economic rural regions because it created a marketing differentiator in more urban areas. This coverage advantage is, via these proposed rules, to be mandated away with little compensation to the facilities-based provider. This greatly reduces the incentive for companies such as SaskTel to upgrade network in rural areas, whether it be through the introduction of LTE or by building new towers for unserved or underserved areas,” the company writes in comments to the consultation.
The regional wireless carrier says this cuts the other way as well, as providers without a rural network footprint have no incentive to expand. “Why expand when facilities owners are forced to provide a company access to expensive towers and their associated spectrum resources?”
Bell Canada notes that eliminating the difference between in-territory and out-of-territory roaming “carries the risk of reducing incentives” for incumbent carriers to build out their own networks and rewards carriers who decided not to invest.
“As a result, this measure would contradict and undermine government policies intended to promote facilities-based competition and associated innovation and service differentiation,” states Bell in its submission.
Extending roaming for an indefinite period isn’t an element that Telus is supportive of, but the company recognizes that from time to time the policy should be reviewed. It suggests that the roaming policy should be renewed every five years “subject to review to ensure that adequate build-out and deployment of spectrum has occurred.”
Rogers Communications and the new entrants find themselves on the other side of the fence on these matters. They say ensuring the full benefits of wireless are enjoyed by all Canadians will be realized by adopting the proposed rule changes.
Besides, expanding a wireless network into rural and remote areas is too expensive for just one operator. “There are simply not enough potential customers living in these areas to justify the investment required to serve them. It is unlikely that demand there will justify the construction of more than a single network,” says Rogers. “It would appear therefore that it is time to introduce mandatory roaming as a means of partially offsetting the negative consequences arising from this situation.”
Public Mobile and Mobilicity agree that making roaming indefinite and eliminating the different between in and out of territory are steps in the right direction, but they need to be combined with a review of roaming rates. Public Mobile even calls for Industry Canada to allow existing roaming agreements to be negotiated.
“It would be inconsistent with the Government’s current stated public policy if the roaming agreements negotiated under the soon to be replaced COLs (conditions of licence) were required to be perpetuated and were not permitted to be re-opened,” the company states.
Mobilicity says Industry Canada should set or tariff roaming rates.
With respect to proposed changes to tower sharing rules, new entrants are concerned about the incumbents’ use of imminent future use. They say that this essentially blocks a new entrant from gaining space on an incumbent tower. Law enforcement and national security agencies are also worried that they may have to comply with regulations that could potentially put their operations at risk.
In its comments, the RCMP questions the merits of releasing tower site sharing information to the public. The national police force adds that its towers should be protected in the same that its licensing information is. “Precise information on our tower and antenna locations would be considered an increased security risk at maintaining the integrity of our communications and may reduce our ability to response to events should be we target of sabotage,” it writes.
The RCMP wants an exemption from the disclosure of such information. It adds that if it shares towers with a commercial operator then there would need to be an exemption for some commercial operators.
“If Industry Canada were to exempt the PSNO (public safety network operators) from divulging some information, we would also require commercial operators to not divulge certain information for those sites owned by them and shared with the PSNO.”
Reply comments are due June 15.
