The opinions expressed in this editorial are those of the author and do not necessarily reflect those of Decima Reports.The CRTC needs to level the playing field in the local services market, not to protect competitors from the predatory practices of incumbents, but to allow incumbents to compete on an equal footing with the “protected competitors” and emerging players using alternative delivery methods. One way the commission can do this is by removing the suspension on incumbents from filing tariffs for local service promotions, a practice that has been in place for more than two years, and one that Bell Canada says has gone far beyond a suspension.  It’s one thing for the commission to impose a temporary ban on local service promotions, but it’s another when after extending the winback period to 12 months from three, ILECs still aren’t allowed to try and coax customers back through promotions. Competitive providers have had complete unfettered access to ILECs’ customers, with no fear of competitive response since January 2003.   The incumbents have a right to offer competitive packages and pricing to their subscribers and the commission is prohibiting them from doing that.   But this suspension is symptomatic of a myopic view of competition at the commission. It remains convinced that facilities-based competition is the best and only way to provide sustainable competition.   But that simply isn’t the case anymore as technological change has facilitated the entry of a number of competitors requiring little infrastructure to offer compelling services and competitive prices. There is no better example of this than the entry of the cablecos into telephony. Rogers Cable had at one time estimated a cost of more than $100 million to launch VoIP in its territory. The real number is well below that.   There’s no reason why the commission shouldn’t lift this ban so as to give ILECs the ability to defend their turf against competitors. Sure the local residential services market is a cash cow for the ILECs right now, but there is absolutely no upside in this market for incumbents. They have everything to lose, and lose to competitors, which don’t need to invest billions of dollars to offer Voice over IP services.