The smallest of the major ILECs thinks the CRTC should give it a pass from considerations of winbacks and other promotions. It’s hard to argue that such campaigns limit competition when there is no competition in its operating territory to begin with, SaskTel asserts. The provincial telco filed a review and vary application with the commission on April 14 seeking changes to Telecom Public Notice 2003-1-1, which began the CRTC review process (NL Update, Mar. 17/03). SaskTel wants a waiver for itself and other firms that do not face local competition. “ILEC promotions in areas where there is no facilities-based local competitor or where facilities-based competitive entry is unlikely to appear, can not be seen to restrain competition in the local wireline market,” John Meldrum, VP corporate counsel & regulatory affairs, writes. Market conditions have evolved where certain parts of the country are not conducive to competition. Even the CRTC has accepted that competition will begin at the margins and then roll out where market forces warrant. There are no CLECs operating in Saskatchewan, nor has any interest been shown, Meldrum notes. It is not because the provincial Crown corporation has obstructed new entrants. SaskTel has removed all barriers over which it has control. The CRTC initiated the examination of promotions after it halted winback campaigns by the incumbents (NL Update, Jan. 20/03). It felt the major companies were taking advantage of the smaller telcos. Meldrum questions that logic as it applies to his company. “The objectives of non-winback promotions are to provide consumers greater choice and benefits, to introduce new services and stimulate the demand for SaskTel’s current service offerings,” he writes. “Eliminating the ILECs’ ability to offer promotions in the local wireline market will not reduce the barriers to entry substantially; especially in the ‘low potential’ markets. In fact, permitting such promotions may have the effect of increasing the incentives for competitive entry by increasing the revenue per subscriber available to the entrant.” The regulatory VP cites a recent commission ruling to bolster his argument. An independent telco in Ontario was exempted in March from the promotions ban because it operates in a low potential market. “SaskTel notes that in Telecom Order 2003-130, the commission approved Thunder Bay Telephone’s promotion in the local services market. This is completely appropriate. This will have no effect upon local competition, since none exists in Thunder Bay’s territory,” Meldrum tells the CRTC. “Likewise, granting the ILECs the ability to conduct promotions within regions where there is no evidence of facilities-based competition will not hamper the development of local competition.” Despite its call for a waiver, SaskTel is still taking part in the proceeding under PN 2003-1-1. Many of the arguments that it made in its R&V are also presented in its submissions on the public notice.“While competition will not be helped by banning promotions in ‘low potential’ areas, both customers and the ILEC will be harmed,” Candice Molnar, GM regulatory affairs, writes in an April 14 submission. Earlier in the same document, Molnar disputes that all regions of the country can be treated as one homogenous market.“It would be ridiculous, and contrary to past commission determinations, to draw conclusions and make regulatory decisions based on an analysis that lumps all geographic areas and residential and business markets together,” she tells the CRTC.